Containing Contaminants

Ground service providers are exposed to a range of contaminants when maintaining aircraft water and lavatory systems. Alicia Hammond takes a look at how the oversight agencies, airport authorities, and regulations interact with those who service the...


All public water systems must comply with the national primary drinking regulations, which require public water systems to monitor the quality of their water and to report results to the state or EPA regional office. Since this water is not any more likely to come into contact with health threatening contaminations, the EPA decided that no additional monitoring or reporting requirements would be imposed. Instead, the EPA gives the Interstate Conveyance Carrier the opportunity to skip regular testing and monitoring if they substitute a regular water system operation and maintenance program for each vehicle.

While spot checks from the FDA or EPA are not common, they are not unheard of. In 1997, the FDA sent several warning letters to various airports across the country citing them with various violations including lack of proper protection of the potable water supply, back flow prevention devices, lack of identification or labeling of the hydrants as "Drinking Water Only," lack of nozzle guard, as well as notation of dirt inside the water cart potable water storage cabinet.

Since investigations only follow after a complaint has been filed, the FDA has executed a Memorandum of Understanding with the EPA to work together in regulating the suitability of water intended for drinking and culinary purposes on Interstate Carrier Conveyances. FDA districts are notified by EPA when public water systems, interstate carrier conveyance watering points, or onboard water does not meet EPA drinking water requirements. The FDA does not specify particular actions against violators, except to notify management of findings. The most severe letter threatens seizure and/or injunction without further notice if the letter states corrective measures to be taken.

The FDA is to start a new program to take regular samples of airline water for testing. KLM Royal Dutch Airline is the only airline currently that regularly tests its water. Voluntary testing of its water began after recent discoveries of legionella bacteria were discovered at several locations in the Netherlands. In its report, KLM suggests that an official test procedure should be created, since the airline considers that the same situation could occur on the aircraft of any other airline, worldwide.

Lavatory Service and equipment
While the problems concerning water quality seem to be in the midst of change, regulations concerning lavatory trucks and carts are stuck in a rut. The main problem is that only basic policies on lavatory carts and trucks have been created.

"There are not many regulations on lav carts," Yuhasz says. "Dumping stations on the airport site must be EPA approved but there is nothing else as far as agencies."

This is a huge problem, according to Rick Duncan, a ground support worker and President of the Kentucky-based, Airworld Tech. He believes that major changes need to happen to the way lavatory trucks and carts are constructed and used.

"Leaks happen with every aircraft I have seen in commercial operations over the past eight years," he says. "Lavatory service is like playing Russian roulette - you don't know which time you will get dumped on."

The number of leaks and spills from lavatory carts and trucks is unknown but the potential hazards of these occurrences are numerous. Waste leakage can sit on the tarmac while workers and passengers walk through it, vehicles drive through it, and even baggage and cargo rest in it.

Duncan says that leakage from lavatory carts and trucks is from impractically-designed equipment and the lack of desire to change.

"The lavatory vehicles are currently designed backwards," Duncan says. "It is my belief that when these problems occurred in the early years, not many people were as worried about diseases. The mindset seems to have been, why spend money on something as insignificant lavatories, if the public doesn't see it?"

So who is in charge?
The question is also not easily answered. The FDA is responsible for the regulating of construction of the lav carts and trucks. The possible debris that hits the tarmac falls under the EPA's jurisdiction. If an agent is affected by the waste, the National Institute for Occupational Safety and Health or the Occupational Safety and Health Administration regulates. If there is a spill over six-feet in diameter, the airport fire department is supposed to be responsible for cleaning up the mess and to report it to the EPA.

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