Containing Contaminants

Feb. 1, 2003

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 aircraft.

February 2003

As integral as lavatory and water carts and trucks are to aviation ground support teams, training on how the equipment works and how it is supposed to be operated and maintained is often minimal as is the training on compliance with regulations specific to this area of aircraft servicing. Add to this mix, the various agencies and organizations that issue regulations can get confusing in their regulatory development and implementation - different rules can apply at different stages of the procedures.

Of the two, water carts and trucks seem to have more consistent regulations for use of the equipment. Yet questions remain if these regulations are being accurately followed. A recent article that appeared in the Wall Street Journal claimed that water on airlines is unsafe to drink. After testing water on 20 different airlines traveling around the world, various bacteria were found in quantities that exceed U.S. government standards. While these findings were studied informally, they have brought attention to an area often taken for granted.

The problem is the finger of blame cannot be pointed at one specific place concerning occurrences of contamination. David Yuhasz, President of the Georgia-based, Aerosafe Products, agrees that contamination is a hard thing to track down. "Where or how bacteria gets into water is unknown and could come from many different places or people," Yuhasz says.

Yuhasz offers that in order to keep the equipment clean, water carts and trucks need to be disinfected every 30 to 45 days and the aircraft tanks every 60 to 90 days. Yet, much more than simple disinfection is required to keep contamination from the drinking water supply.

The Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA) are the two agencies in charge of regulating water on airlines, including the transportation and storage of water for drinkable and non-drinkable sources. The FDA is accountable for managing the sanitary practices and quality of airports' water facilities.
The EPA is responsible for the water onboard and requires airlines to clean tanks quarterly and confirm that their water complies with federal standards. Most of the monitoring is left to the airlines. The Federal Aviation Administration (FAA) is also involved and requires airlines to clean and flush their onboard tanks approximately every 12 to 14 months.

Regulatory Roulette
The FDA has specific guidelines covering aircraft drinking water service vehicles. While these regulations are responsible for keeping the equipment free from possible contamination, the EPA regulates the water systems for quality in carrier watering points and onboard carrier drinking water suitability. As the water used in airplanes is constantly crossing borders, compliance falls under the 1974 Safe Drinking Water Act on Interstate Carrier Conveyance.

Waste sits on the tarmac after a lavatory leak, possibly exposing employees, cargo, passengers, and equipment. Photo by Rick Duncan

Since the Safe Drinking Water Act, the EPA has been responsible for regulating public water systems serving airplanes but also for regulating the potable water quality onboard the conveyances. The National Primary Drinking Water Regulations say that while a state may be given authority to enforce regulations, enforcement authority over all public water systems on interstate carriers is specifically delegated to the EPA.

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.

Agents have several precautions available to prevent exposure to themselves and the ground, including a face shield, surgical gloves, and alcohol moist wipes. According to Duncan, agents have recently been using five-gallon buckets that sit under the aircraft during service to catch any leaks.

What is the solution? It's hard to say. For many, the service is fine the way it is, especially considering other problems facing the aviation industry. But for some like Rick Duncan, change is necessary now. Duncan has created an accessory for lavatory carts and trucks called the Blue Bagger, which aims to eliminate most leaks.

The FDA has set up basic regulations concerning the design and storage of lavatory carts and trucks. Other agencies have issued regulations, such as International Air and Transport Association as well as individual airlines and airports, but these regulations do not go much further than the FDA's.

While the many regulations can get confusing, it is important to remember why they are in place - safety for the employees and the passengers is of top concern for all involved.