|Water and Sanitation|
Potable water supplies on U.S. airlines are jointly regulated by the Environmental Protection Agency (EPA), the Food and Drug Administration (FDA), and the Federal Aviation Administration (FAA). In accordance with the Safe Drinking Water Act (SDWA), EPA regulates water quality in public water systems, including those that supply water to the airports and the drinking water once it’s onboard the aircraft. The regulatory structure for all public water systems relies upon self-monitoring and reporting of results to the primacy (primary enforcement) agency, which for aircraft public water systems is EPA. The EPA signed an Aircraft Drinking Water Rule (ADWR) on October 5, 2009, the purpose of which is to “ensure that safe and reliable drinking water is provided to aircraft passengers and crew … [by] providing air carriers with a feasible way to comply with the … SDWA … and the national primary drinking water regulations (NPDWRs).”
The Proposed Aircraft Drinking Water Rule was published on April 9, 2008 in the Federal Register. In developing this proposal, EPA sought the views of all interested stakeholders. AFA-CWA played a significant role in representing the interests of flight attendants throughout this process by submitting comments on the proposed rule and by attending three stakeholder workshops in 2005, 2006 and 2007. During the second workshop, in January 2006, AFA-CWA staff presented The Flight Attendant Position on Airline Drinking Water, which summarizes the laws and regulations governing airplane drinking water, hygiene and sanitation, and contrasts this legal framework with the actual, sometimes deplorable conditions present in cabins, galleys and lavs.
Sanitation and Hygiene
The FDA has jurisdiction over water used in food preparation including coffee, tea and ice and the pipes, tankers, etc. at the airport where aircraft obtain water. The FDA also regulates food-handling operations by, for example, requiring that running water and soap be provided to facilitate proper hand washing by food-handling employees; see 21 Code of Federal Regulations PART 1250 INTERSTATE CONVEYANCE SANITATION and the FDA Guide to Inspections of Interstate Carriers and Support Facilities. The FAA, working with the EPA and FDA, oversees operation and maintenance programs covering all parts of the aircraft, including the potable water system.
AFA-CWA has also been an active participant in the long-term process of updating the International Health Regulations (IHR), an international legal instrument binding on 194 countries including the U.S. AFA-CWA’s ability to affect the IHRs is the result of our membership in the International Transport Workers’ Federation (ITF), an organization granted observer status in the International Civil Aviation Organization (ICAO). ICAO, a UN Agency, is the “global forum of States for international civil aviation.” A collateral benefit of our work with ICAO has been the ability to participate in a recent process to draft a third edition to the Guide to Hygiene and Sanitation in Aviation (GHSA), a document by the World Health Organization (WHO). A downloadable PDF version of the Guide to hygiene and sanitation in aviation (third edition), including Module 1 – Water, and Module 2 – Cleaning and disinfection of facilities, is available at this link. Additional chapters on Food, Waste Disposal, Vector Control and Cargo will be included in the final version of the GHSA 3rd edition, to be published on some future date.