Guidance Manual for the 

Aircraft Drinking Water Rule 

(ADWR) – Interim Final 
Office of Water (4606M) 

EPA 816-R-10-020 

http://www.epa.gov/drink 

October 2010 
Guidance Manual

for the ADWR – Interim Final

October 2010 

Purpose of this Document 

This document provides guidance and contains EPA’s current policy 

recommendations for complying with the Aircraft Drinking Water Rule. 

This is a living document and may be revised periodically without public notice. EPA 

welcomes public input on this document at any time. Guidance provided in this 

document reflects provisions of the final rule published on October 19, 2009, at 74 

Federal Register 53590. 

The statutory provisions and the final regulations described in this document contain 

legally binding requirements. This document is not a regulation itself, nor does it 

change or substitute for those provisions and regulations. Thus, it does not impose 

legally binding requirements on EPA or public water systems. This guidance does not 

confer legal rights or impose legal obligations upon any member of the public. 

While EPA has made every effort to ensure the accuracy of the discussion in this 

guidance, the obligations of the regulated community are determined by statutes, 

regulations, or other legally binding requirements. In the event of a conflict between 

the discussion in this document and any statute or regulation, this document would not 

be controlling. 

The general description provided here may not apply to a particular situation based 

upon the circumstances. Interested parties are free to raise questions and objections 

about the substance of this guidance and the appropriateness of the application of this 

guidance to a particular situation. EPA retains the discretion to adopt approaches on a 

case-by-case basis that differ from those described in this guidance, where appropriate. 

Mention of trade names or commercial products does not constitute endorsement or 

recommendation for their use. 

 
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Maintenance Plan.................................................................................................... 33
 

4.2.5	 Procedures for Communicating Sample Results to Ensure All Required Actions Are 

Conducted in a Timely Manner ............................................................................... 33
 

4.2.6	 Scheduling Coliform Sampling to Minimize Service Disruption ............................. 34
 

4.3 RESPONDING TO COLIFORM TEST RESULTS.................................................................. 35
 

4.3.1 Total Coliform-Negative Routine Sample Result ..................................................... 38
 

4.3.2 Total Coliform-Positive and E. coli-Negative Routine Sample Result .................... 38
 

4.3.3 E. coli-Positive Routine or Repeat Sample Result Options ..................................... 47
 

4.4 SUGGESTED SAMPLING PROTOCOL............................................................................... 49
 

4.4.1 Materials and Preparation for Sampling ................................................................. 49
 

4.4.2 Sample Collection.................................................................................................... 50
 

4.5 CERTIFIED LABORATORIES AND ANALYTICAL METHODS ............................................ 51
 

4.5.1 Certified Laboratories ............................................................................................. 51
 

4.5.2 Analytical Methods .................................................................................................. 51
 

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1. INTRODUCTION............................................................................................................ 1
 

1.1 PURPOSE OF THE AIRCRAFT DRINKING WATER RULE .................................................... 1
 

1.2 APPLICABILITY OF THE AIRCRAFT DRINKING WATER RULE.......................................... 2
 

1.3 GENERAL REQUIREMENTS OF THE AIRCRAFT DRINKING WATER RULE ........................ 6
 

1.4 INTENDED USE OF THIS DOCUMENT................................................................................ 7
 

1.5 OUTLINE OF THIS DOCUMENT ......................................................................................... 7
 

2. OVERVIEW OF THE AIRCRAFT DRINKING WATER RULE ............................. 9
 

2.1 COMPLIANCE DATES AND REQUIREMENTS..................................................................... 9
 

2.2 WHAT IS AN AIRCRAFT PUBLIC WATER SYSTEM?........................................................ 13
 

2.2.1 Types of Public Water Systems ................................................................................ 13
 

2.2.2 Components of Aircraft Public Water Systems ........................................................ 14
 

2.3 QUALITY OF ONBOARD WATER .................................................................................... 15
 

2.3.1 Public Health Threats Addressed by the Rule ......................................................... 15
 

2.3.2 Maintaining Water Quality Throughout the Supply and Transfer Chain ................ 16
 

2.3.3 ADWR Public Health Protection Measures ............................................................. 19
 

3. AIRCRAFT INVENTORY ........................................................................................... 21
 

3.1 IDENTIFYING AIRCRAFT PUBLIC WATER SYSTEMS ...................................................... 21
 

3.2 AIRCRAFT STATUS AS “ACTIVE” OR “INACTIVE” ......................................................... 23
 

3.3 REPORTING INVENTORY INFORMATION ........................................................................ 24
 

4. COLIFORM MONITORING ....................................................................................... 27
 

4.1 TYPES OF COLIFORM SAMPLES ..................................................................................... 27
 

4.2 COLIFORM SAMPLING PLANS........................................................................................ 29
 

4.2.1 Coliform Sample Collection Procedures ................................................................. 30
 

4.2.2	 Sample Tap Location(s) Representative of the Aircraft Water System .................... 30
 

4.2.3	 Frequency and Number of Routine Coliform Samples to Be Collected ................... 32
 

4.2.4	 Frequency of Routine Disinfection and Flushing As Specified In the Operation and 

Table of Contents 
9. OTHER WATER SYSTEM CONSIDERATIONS .........................

9.1 WATER AGE AND BIOFILM MANAGEMENT CONSIDERATIONS .........

9.2 CONSIDERATIONS FOR SUPPLEMENTAL TREATMENT .......................

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 ......................................................................................................67
 

6. PUBLIC NOTIFICATION............................................................................................ 69
 

6.1 PURPOSE OF PUBLIC NOTIFICATION.............................................................................. 69
 

6.2 NOTIFICATION OF PASSENGERS AND CREW.................................................................. 70
 

6.2.1	 Notice for Detection of E. coli or Total Coliform Bacteria ..................................... 71
 

6.2.2	 Notice for Failure to Monitor, Failure to Conduct Disinfection and Flushing, and
 

Situations Where Water Does Not Meet Standards (Non-E. coli-Positive Event)... 74
 

6.2.3	 Notice for Failure to Conduct Follow-Up Monitoring and Situations Where Water 

Does Not Meet Standards (E. coli-Positive Event).................................................. 77
 

6.2.4	 Notice Where Necessary to Protect Public Health .................................................. 80
 

6.2.5	 Crew-only Notice ..................................................................................................... 82
 

7.	 RECORDKEEPING AND REPORTING ................................................................... 83
 

7.1 AIR CARRIER RECORDKEEPING..................................................................................... 83
 

7.1.1 Record Maintenance................................................................................................ 83
 

7.1.2 Information Included in Records ............................................................................. 84
 

7.2 REPORTING REQUIREMENTS ......................................................................................... 85
 

7.2.1 Reporting Format .................................................................................................... 85
 

7.2.2 Aircraft Inventory .................................................................................................... 85
 

7.2.3 Coliform Plan and Sampling ................................................................................... 87
 

7.2.4 O&M Plans and Activities ....................................................................................... 90
 

7.2.5 Public Notification ................................................................................................... 92
 

7.2.6 Self-Inspections........................................................................................................ 92
 

7.2.7 Compliance Audits................................................................................................... 95
 

8. VIOLATIONS OF THE RULE .................................................................................... 97
 

.......................... 107
 

.......................... 107
 

.......................... 108
 

 

4.5.3 Sample Invalidation ................................................................................................. 51
 

4.6 REPORTING SAMPLE RESULTS ...................................................................................... 53
 

5. OPERATIONS AND MAINTENANCE PLANS ........................................................ 55
 

5.1 OVERVIEW OF REQUIREMENTS AND TIMEFRAMES ....................................................... 55
 

5.2 WATERING POINT SELECTION REQUIREMENT .............................................................. 55
 

5.3 ROUTINE AND CORRECTIVE DISINFECTION AND FLUSHING ......................................... 56
 

5.4 FOLLOW-UP SAMPLING ................................................................................................. 58
 

5.5 TRAINING OF PERSONNEL ............................................................................................. 59
 

5.6 PROCEDURES FOR CONDUCTING SELF-INSPECTIONS.................................................... 61
 

5.7 PROCEDURES FOR BOARDING WATER .......................................................................... 62
 

5.7.1 Boarding Water within the United States ................................................................ 62
 

5.7.2 Transferring Water Safely for Human Consumption ............................................... 62
 

5.7.3 Ensuring Water Boarded Outside of the US is Safe for Human Consumption ........ 63
 

5.7.4 Emergency Procedures for Failure to Board Water from a Safe Watering Point ... 63
 

5.8	 COLIFORM SAMPLING PLAN.......................................................................................... 67
 

5.9	 AIRCRAFT WATER SYSTEMS DISCONNECT/SHUT-OFF/FLOW PREVENTION STATEMENT
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9.2.1 Type of Treatment Provided .................................................................................. 108
 

9.2.2 Supplemental Treatment Maintenance and Operator Training ............................. 109
 

9.3 COMMUNICATION STRATEGY ..................................................................................... 109
 

9.4 RECORDKEEPING PRACTICES FOR BOARDING OF WATER .......................................... 109
 

REFERENCES .......................................................................................................................... 111
 
 

 

Appendices
 

Appendix A Federal Register Publication of the Final ADWR Requirements 

Appendix B ADWR Quick Reference Guide 

Appendix C Example Coliform Sampling Plan 

Appendix D Public Notification Templates 

Appendix E Example Water Safety Plan for an Air Carrier 

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List of Exhibits

Exhibit 1.1 ADWR Applicability to Aircraft ................................................................ 5

Exhibit 2.1 ADWR Components and Compliance Dates ............................................ 10

Exhibit 2.2 Example Components of One Type of an Aircraft Water System ............ 14

Exhibit 2.3 Potential Contamination Pathways within the Aircraft Water System 

Supply and Transfer Chain ....................................................................... 17

Exhibit 4.1 Example Sample Locations....................................................................... 32

Exhibit 4.2 Coliform Sampling Frequencies Based on Disinfection and Flushing 

Frequencies ............................................................................................... 33

Exhibit 4.3 Overview of Possible Coliform Sample Result Scenarios ........................ 36

Exhibit 4.4 Restricting Public Access ......................................................................... 37

Exhibit 4.5 Overview of Options for Response to Total Coliform-Positive (E. coliNegative) Sample Results ......................................................................... 39

Exhibit 4.6 Total Coliform-Positive and E. coli-Negative Routine Samples: Option 1: 

Disinfection and Flushing Details ............................................................. 41

Exhibit 4.7 Total Coliform-Positive and E. coli-Negative Routine Samples: Option 2: 

Restricting Public Access ......................................................................... 43

Exhibit 4.8 Total Coliform-Positive and E. coli-Negative Routine Samples: Option 3: 

Repeat Sample Details .............................................................................. 46

Exhibit 4.9 E. coli-Positive Routine or Repeat Samples: Required Activities ............ 48

Exhibit 5.1 Example Response Plan for Failure to Board Water from a Safe Watering 

Point (E. coli-positive event) .................................................................... 65

Exhibit 5.2 Example Response Plan for Failure to Board Water from a Safe Watering 

Point (non-E. coli-positive event) ............................................................. 66

Exhibit 6.1 Public Notification Requirements in Response to a Total ColiformPositive or E. coli-Positive Sample Result ............................................... 72

Exhibit 6.2 Public Notification Requirements for Failure to Monitor, Disinfect and 

Flush, or Board Water from a Safe Watering Point (Non-E. coli-Positive)

................................................................................................................... 75

Exhibit 6.3 Public Notification Requirements for Failure to Monitor, Disinfect and 

Flush, or Board Water from a Safe Watering Point (E. coli-Positive) ..... 78

Exhibit 6.4 Public Notification Requirements When Notification is Deemed 

Necessary by EPA, the Air Carrier, or the Crew ...................................... 81

Exhibit 7.1 Duration of Record Maintenance .............................................................. 83

Exhibit 7.2 Reporting Aircraft Inventory .................................................................... 85

Exhibit 7.3 Aircraft Inventory Reporting Requirements ............................................. 86

Exhibit 7.4 Reporting for Coliform Plan and Sampling .............................................. 88

Exhibit 7.5 Implications of Changes to Coliform Sampling Frequencies ................... 89

Exhibit 7.6 Reporting O&M Plans and Activities ....................................................... 91

Exhibit 7.7 Public Notification Reporting Requirements ........................................... 92

Exhibit 7.8 Self-Inspection Reporting ......................................................................... 92

Exhibit 7.9 Self-Inspection Reporting Requirements .................................................. 94

Exhibit 7.10 Compliance Audit Reporting .................................................................... 95

Exhibit 8.1 Violations of the ADWR .......................................................................... 98
Acronyms and Abbreviations 

ADWR Aircraft Drinking Water Rule 

ANSI American National Standards Institute 

AOC Administrative Order on Consent 

ARCS ADWR Reporting and Compliance System 

ATA Air Transport Association 

BMP Best Management Practice 

CDC Centers for Disease Control and Prevention 

CFR Code of Federal Regulations 

CRMP Comprehensive Representative Monitoring Plan 

CWS Community Water System 

DBP Disinfection Byproducts 

E. coli Escherichia coli 

EPA United States Environmental Protection Agency 

EO Executive Order 

FAA United States Federal Aviation Administration 

FDA United States Food and Drug Administration 

FR Federal Register 

GWS Ground Water System 

GWUDI Ground Water Under the Direct Influence of Surface Wa

HACCP Hazard Analysis and Critical Control Point 

HHS Department of Health and Human Services 

HPC Heterotrophic Plate Count 

ICC Interstate Carrier Conveyance 

IESWTR Interim Enhanced Surface Water Treatment Rule 

LIMS Laboratory Information Management System 

MCL Maximum Contaminant Level 

MCLG Maximum Contaminant Level Goal 

mg/L Milligrams per Liter 

mL Milliliters 

MRDL Maximum Residual Disinfectant Level 

NAICS National American Industry Classification System 

NATA National Air Transportation Association 

NASA National Aeronautics and Space Administration 

ter 

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NCWS Non-Community Water System 

NELAP National Environmental Laboratory Accreditation Program 

NOV Notice of Violation 

NPDWR National Primary Drinking Water Regulation 

NSF National Sanitation Foundation International 

NTNCWS Non-Transient Non-Community Water System 

OEI Official Establishment Inventory 

O&M Operations and Maintenance 

P-A Presence-Absence 

PN Public Notification 

ppm Parts per Million 

PWS Public Water System 

SDWA Safe Drinking Water Act 

SDWIS Safe Drinking Water Information System 

SWTR Surface Water Treatment Rule 

TC Total Coliform 

TCR Total Coliform Rule 

TCRDSAC Total Coliform Rule/Distribution System Advisory Committee 

TNCWS Transient Non-Community Water System 

TT Treatment Technique 

US United States 

UV Ultraviolet 

WHO World Health Organization 

WSG Water Supply Guidance 

WSP Water Safety Plan 

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1. Introduction 

1.1 Purpose of the Aircraft Drinking Water Rule 

The primary purpose of the Aircraft Drinking Water Rule (ADWR) is to ensure that a safe and 

reliable supply of drinking water is provided to aircraft passengers and crew. The rule applies to 

aircraft that are public water systems (PWSs) and requires that the water provided through 

lavatory and galley faucets and drinking fountains on the aircraft meet standards for human 

consumption. The ADWR does not require that water be provided on an aircraft. 

 

Human consumption refers to more than just drinking water or water-based beverages. It 

includes water uses such as drinking or food preparation, as well as water for brushing teeth, 

dishwashing, and hand washing [40 CFR 141.801]. Therefore, even if passengers and crew are 

provided bottled water for drinking, water from all taps on the aircraft (including taps in the 

lavatories and galleys) must meet drinking water standards. Examples of common uses of 

drinking water by passengers and crew on an aircraft include: 

o Medical use, including ingestion of medications. 

o Hygienic purposes such as brushing teeth, washing hands 

and/or face, and where provided, onboard showering. 

o	 Food and beverage preparation such as making coffee 

and tea, mixing powered drinks, or re-hydrating 

dehydrated foods. 

o Hand washing by crew prior to providing ice or prepackaged food to passengers. 

o Sanitation activities such as washing utensils or work 

areas, or wetting towels for use in dish washing or for 

wiping hands. 

o Direct ingestion from taps or fountains (even if drinking 

cups are not provided by the air carrier). 

Aircraft classified as public water systems are subject to the 

requirements of the Safe Drinking Water Act (SDWA). Under SDWA, the United States 

onal health-based standards for drinking water 

rcement of those standards. The health-based 

egulations (NPDWRs). NPDWRs include 

ent requirements, monitoring, public 

ments. 

ter regulations have been written with 

d. Examples of stationary public water systems 

Environmental Protection Agency (EPA) sets nati

quality and oversees the implementation and enfo

standards are National Primary Drinking Water R

maximum allowable levels of contaminants, treatm

notification, reporting, and recordkeeping require

Until the ADWR was developed, safe drinking wa

traditional stationary public water systems in min

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1 

Applicability of the

ADWR 

All interstate carrier 

conveyances that provide 

piped water for human 

consumption and that 

regularly serve at least 25 

individuals daily at least 

60 days per year are public 

water systems regardless 

of whether they treat or 

sell the water and 

regardless of whether they 

are publicly or privately 

owned. Applicability is 

discussed in more detail in 

Section 1.2. 
 

 

include large municipal utilities, as well as schools and restaurants that are served by their own 

wells. The regulations for stationary systems have proven difficult to implement for aircraft due 

to the unique characteristics of aircraft water systems. For example, aircraft operate under 

rigorous flight schedules, fly to multiple destinations over the course of one day, and may board 

drinking water at many of these locations. The ADWR tailors drinking water regulations to 

provide a more feasible way for air carriers to comply with NPDWRs. The ADWR adapts to 

aircraft water systems the applicable requirements of the Total Coliform Rule, the suite of 

Surface Water Treatment Rules, and the Public Notification Rule. The ADWR also builds upon 

existing aircraft operations and maintenance programs, better coordinates federal programs that 

regulate aircraft water systems, and enables aircraft to select compliance options that minimize 

disruptions of aircraft flight schedules. 

Because aircraft board water from airport watering points via temporary connections, aircraft 

drinking water quality depends on a number of factors. These factors include the quality of the 

water boarded from each source, the care used to board the water, the water transfer equipment 

(such as water cabinets, trucks, carts, and hoses), and the operation and maintenance (O&M) of 

the onboard water system. The ADWR, along with complementary US Food and Drug 

Administration (FDA) regulations, addresses each of these factors in order to safeguard against 

possible contamination and to ensure that the water is suitable for human consumption. 

1.2 Applicability of the Aircraft Drinking Water Rule 

The ADWR applies to each aircraft that meets the definition of a public water system, boards 

only finished water, operates within US jurisdiction, and is not excluded from regulation under 

40 CFR 141.3. The ADWR applies to the onboard water system only. EPA defers to the FDA 

with respect to regulating watering points such as water cabinets, carts, trucks, and hoses from 

which aircraft board water. FDA requirements for watering points do not entail the individual 

certification of every potential source, method, facility, or system; however, interstate carrier 

conveyance selected watering points must be in accordance with FDA requirements [21 CFR 

part 1240, subpart E]. Furthermore, the applicability of the ADWR is not based on the ownership 

of the aircraft. That is, an aircraft that is subject to the ADWR may be publicly or privately 

owned, or government or foreign-owned. 

The applicability criteria for the ADWR are described in more detail below and are presented in 

Exhibit 1.1. 

 Aircraft that meet the definition of a public water system have an onboard water system of 

piped water for human consumption and regularly serve an average of at least 25 or more 

individuals daily at least 60 days out of the year. 

Piped water for human consumption means the onboard water system provides water 

through taps (e.g., in a galley, a lavatory, or drinking fountain). The onboard water can be 

supplied to the aircraft via a fill port and piping, or by a removable tank. 

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A galley is the area of the aircraft where food is cooked and prepared. If the galley has a 

water tap, even if there is only a hot water tap, the aircraft will be subject to the ADWR. 

EPA also considers “human consumption” to occur in a lavatory if there is a tap. 

Facilities with toilet seats without a lavatory tap (as seen in some small, short-range 

aircraft) are not considered to be providing water for human consumption under SDWA 

because tap water cannot be accessed by passengers or crew. A lavatory sink with a tap 

provides water for human consumption even if the tap and basin are only intended for 

hand washing and drinking cups are not provided. An aircraft need only have a galley tap 

or a lavatory tap or a drinking fountain to be considered providing water for human 

consumption. 

By definition, a public water system regularly serves an average of at least 25 or more 

individuals daily at least 60 days out of the year [40 CFR 141.2]. The 25-person average 

minimum includes the total number of passengers and crew for all of the flights in a day; 

the 60 days per year do not need to be consecutive days. If the aircraft does not operate at 

least 60 days each year, or if it does not regularly serve an average of at least 25 people 

daily at least 60 days in a year, the aircraft would not be a public water system. For 

example, the ADWR and other NPDWRs do not apply to aircraft that are used solely for 

cargo purposes if they do not regularly serve an average of at least 25 people daily, even 

if they have an onboard water system. 

 The ADWR is limited to aircraft that board only finished water. 

The ADWR assumes that only finished water is boarded for human consumption on 

aircraft because of the FDA requirement that only potable water may be provided for 

drinking and culinary purposes on interstate carrier conveyances [21 CFR 1240.80]. 

Finished water is defined as water that is introduced into the distribution system of a 

public water system and is intended for distribution and consumption without further 

treatment, except as treatment necessary to maintain water quality in the distribution 

system [40 CFR 141.801]. Disinfection, such as an ultraviolet light disinfection system, is 

an example of treatment that may be used to maintain water quality after the water has 

been boarded. Carbon filters and particle removal filters are installed on some aircraft 

water systems for aesthetic purposes. 

An aircraft public water system that boards water that is not of finished quality is not 

eligible to comply with the ADWR but is subject to all of the other applicable National 

Primary Drinking Water Regulations. 

 Aircraft that fly international routes with two or more destinations within US jurisdiction. 

Aircraft that fly international routes that make only one stop in the US solely for the 

purpose of unloading passengers transported from outside the US and/or loading 

passengers for transportation to a destination outside the US are excluded from ADWR 

regulations. Thus, under the ADWR, if an aircraft serves two or more US destinations 

before returning to an international location, the aircraft is subject to the ADWR while 

within the US. 

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 Aircraft not excluded from regulation under 40 CFR 141.3. 

The SDWA [Section 1411(4)] and NPDWRs [40 CFR 141.3] specifically exclude from 

regulation public water systems that meet all of the following criteria: 1) consist only of 

distribution and storage facilities and do not have any collection and treatment facilities; 

2) obtain all water from, but are not owned or operated by, a public water system; 3) do 

not sell water to any person; and 4) are not a carrier that conveys passengers in interstate 

commerce. 

Aircraft are carriers; therefore, if aircraft that are public water systems convey passengers 

in interstate commerce they are specifically identified as being subject to the drinking 

water regulations and cannot be excluded. 

A government-owned aircraft used solely for government purposes that is not conveying 

passengers in interstate commerce may be excluded from SDWA and ADWR regulations 

if it meets the other three criteria. However, if a government-owned aircraft does not 

obtain all water from a public water system (e.g., the aircraft boards water from a location 

that is outside of US jurisdiction), the aircraft would not be excluded from regulation. 

It is important to note that the term “interstate commerce” does not exclusively apply to 

aircraft conveying passengers between two different states. Interstate commerce includes 

activities that substantially affect interstate commerce even if they are not themselves 

interstate. As a result, EPA interprets the statute to reach intrastate carriers that meet the 

definition of a public water system; such aircraft are subject to the ADWR if all other 

necessary criteria are met. 

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Exhibit 1.1 ADWR Applicability to Aircraft 

Note 1: If the aircraft does not operate at least 60 days each year, or if it does not regularly serve an average of at 

least 25 people daily at least 60 days in a year, the aircraft would not be a PWS. The 25-person average minimum 

includes the total number of passengers and crew for all of the flights in a day. 

Note 2: A lavatory has a flushing toilet and a tap. A galley is a food preparation and handling area where food is 

cooked, prepared, or stored. 

Note 3: EPA considers water for human consumption to include water for drinking, food preparation, brushing teeth, 

and hand washing. An aircraft PWS that boards water that is not of finished quality is not eligible to comply with the 

ADWR but is subject to all of the other applicable National Primary Drinking Water Regulations. 

Note 4: Aircraft that meet all criteria in 40 CFR 141.3 are excluded from regulation under ADWR. 

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1.3 General Requirements of the Aircraft Drinking Water Rule 

In general terms, the ADWR seeks to protect the quality of drinking water onboard aircraft 

public water systems by establishing the following requirements. Details of each requirement are 

provided in later chapters in this guidance document. The rule language as published in the 

Federal Register is provided in Appendix A and a Quick Reference Guide summarizing the rule 

requirements is provided in Appendix B. 

	 Routine disinfection and flushing of the aircraft water system at a frequency consistent with 

the water system manufacturers’ recommendations. Where manufacturers do not specify a 

frequency for routine disinfection and flushing of the system, the rule gives air carriers four 

options from which to choose their preferred frequency (see Chapters 4 and 5). 

	 Routine monitoring for total coliform (TC) bacteria at aircraft water system taps, at 

frequencies ranging from monthly to annually, depending on the routine disinfection and 

flushing frequency (see Chapter 4). 

	 Aircraft water system operations and maintenance (O&M) plans, which must be incorporated 

into the air carriers’ FAA-accepted O&M program for aircraft. The O&M plans must include 

a coliform sampling plan and procedures for performing routine disinfection and flushing, as 

well as other requirements (see Chapter 5). 

	 Coliform sampling plans, which must be included in the aircraft water system O&M plan. 

The coliform sampling plan must include the frequency and number of routine coliform 

samples, location of sample taps, sampling collection procedures, as well as other 

requirements (see Chapter 4). 

	 Analysis of total coliform-positive samples for the presence of Escherichia coli (E. coli) (see 

Chapter 4). 

	 Corrective actions in response to a total coliform-positive or E. coli-positive sample (see 

Chapter 4). 

	 Corrective disinfection and flushing of the aircraft water system when specific circumstances 

occur (see Chapter 5). 

	 Follow-up sampling and analysis for total coliform to confirm the effectiveness of corrective 

disinfection and flushing (see Chapters 4 and 5). 

	 Comprehensive self-inspection of each aircraft’s water system components no less than every 

5 years (see Chapter 5). 

	 Compliance audits at an interval determined by EPA (see Chapter 5). 

	 Public notification when specific circumstances occur (see Chapter 6). 

	 Reporting and recordkeeping associated with the activities described above (see Chapter 7). 

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1.4 Intended Use of this Document 

This guidance is intended to help facilitate compliance with and implementation of the 

requirements of the ADWR. It explains the applicability of the rule to aircraft water systems and 

describes the rule requirements. It also recommends sampling procedures that ensure accurate 

sampling results and discusses other considerations to help preserve good water quality aboard 

the aircraft. This manual also provides templates for the various public notices required by the 

rule. 

While EPA has made every effort to ensure the accuracy of the discussion in this document, the 

obligations of the regulated community are determined by statutes, regulations, or other legally 

binding requirements. In the event of a conflict between the discussion in this document and any 

statute or regulation, this document would not be controlling. Furthermore, the recommendations 

offered by EPA in this technical manual are provided solely to assist air carriers in rule 

implementation. Air carriers may develop their own policies and procedures as they deem 

appropriate based on the nature of their individual operations and are responsible for ensuring 

those policies and procedures are consistent with, and support compliance with, the rule. 

1.5 Outline of this Document 

This guidance manual addresses the requirements of the ADWR and provides suggestions to air 

carriers for ensuring that safe drinking water is provided by aircraft public water systems. 

Although aircraft operators have the responsibility to protect their water systems from deliberate 

acts that may threaten public health, this issue is not within the purview of this guidance or the 

ADWR. 

The guidance manual is organized as follows: 

Chapter 1. Introduction – Explains the applicability of the ADWR and purpose of this manual. 

Chapter 2. Overview of the Aircraft Drinking Water Rule – Describes, in general terms, the 

ADWR requirements and compliance dates, aircraft public water systems, as well as key 

background information. 

Chapter 3. Aircraft Inventory– Explains the criteria for identifying if an aircraft is a public water 

system, defines the status of aircraft, and describes other aircraft inventory requirements. 

Chapter 4. Coliform Monitoring – Describes coliform monitoring requirements including 

monitoring plan content, sampling locations, sampling frequency, sampling protocol, analytical 

methods, and the reporting of sample results. Also discusses activities and options for responding 

to the detection of coliform organisms in routine or repeat samples. 

Chapter 5. Operations and Maintenance Plans – Discusses the required elements of an operations 

and maintenance (O&M) plan and recommendations for conducting disinfection and flushing 

procedures, performing water system inspections, and training personnel on the public health 

implications of their activities on the quality of water onboard the aircraft water system. 

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Chapter 6. Public Notification – Describes public notice requirements including methods, timing, 

format, and required language. 

Chapter 7. Recordkeeping and Reporting – Describes the requirements for reporting information 

to the EPA, including inventory information and compliance data, and internal recordkeeping 

requirements for the air carriers. 

Chapter 8. Violations of the Rule – Summarizes rule violations and corrective actions for 

returning to compliance. 

Chapter 9. Other Water System Considerations – Describes considerations that are above and 

beyond the ADWR regulatory requirements, which may contribute to obtaining and maintaining 

drinking water quality. Topics include water age and biofilm management, considerations for 

supplemental treatment, strategies for communications with water systems from which finished 

water is obtained, and recordkeeping practices for boarded water. 

References. – Provides a bibliographic list of references cited in this manual. 

Appendix A. Rule Language – The rule as published in the Federal Register. 

Appendix B. Quick Reference Guide – A stand-alone two-page summary of the rule 

requirements and key background information. 

Appendix C. Example Coliform Sampling Plan – Provides an example coliform sampling plan 

illustrating all of the required elements of a coliform sampling plan. 

Appendix D. Public Notification Templates – Provides examples for various public notices 

required by the ADWR. 

Appendix E. Example Water Safety Plan for an Air Carrier – Provides an outline of a water 

safety plan based on World Health Organization (WHO) guidelines. EPA encourages the 

development of comprehensive water safety plans by air carriers. Water safety plans are not 

required by the ADWR. 

Guidance Manual 8 

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2. Overview of the Aircraft Drinking Water Rule 

Aircraft public water systems are required to develop aircraft water system operation and 

maintenance plans including coliform sampling plans, conduct operations and maintenance 

activities, periodically sample the onboard drinking water, and report compliance with ADWR 

requirements to an electronic database developed by EPA (ADWR Reporting and Compliance 

System). Compliance oversight of ADWR requirements is provided by the EPA Regional Office 

in which the air carrier’s US headquarters is located. EPA Headquarters will administer the 

ADWR Reporting and Compliance System and play a continuing role in ensuring consistent 

implementation and enforcement of the ADWR. 

This chapter provides an overview of the requirements of the ADWR including compliance 

dates, a description of an aircraft water system, and background information related to the quality 

of the onboard water. 

2.1 Compliance Dates and Requirements 

Several rule components must be implemented 18 months after rule promulgation, which is April 

19, 2011 [40 CFR 141.806(a)(1)]; the remainder must be imple

promulgation, which is October 19, 2011 [40 CFR 141.800]. 

The ADWR relies on a combination of routine aircraft water 

system operations and maintenance (O&M) practices that 

build on existing air carrier O&M programs, with periodic 

monitoring. The ADWR rule components and their 

compliance dates are summarized in Exhibit 2.1. Chapters 3 

through 7 of this document provide details of the requirements 

of the ADWR. 

Air carriers that are operating under an Administrative Order 

on Consent and Request for Information (AOC) to address 

pre-ADWR non-compliance with the Safe Drinking Water 

Act and National Primary Drinking Water Regulations must 

continue to meet the requirements of their AOCs until the 

ADWR compliance date of October 19, 2011 [40 CFR 

141.800(b)]. 

If an air carrier is not subject to an AOC, then that air carrier 

must comply with the applicable requirements of the existing 

NPDWRs under 40 CFR 141 for each of its aircraft that is a 

public water system [40 CFR 141.800(b)]. The applicable requi

transient non-community water system (TNCWS) that uses fini

1,000 or fewer people per day. 

ment

Aircraft PWS 

Requirements Prior to the 

ADWR 

Until the compliance date 

of October 19, 2011, air 

carriers remain subject to 

the requirements of their 

AOCs, if an AOC is in 

effect. 

If an AOC is not in effect 

for an air carrier, then that 

air carrier must comply 

with the applicable 

requirements of the existing 

NPDWRs under 40 CFR 

141 for each of its aircraft 

that is a public water 

system. 

ed within two years after 

rements include those for a 

shed surface water and serves 

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Exhibit 2.1 ADWR Components and Compliance Dates 

Component Compliance 

Date 

Submit aircraft water system inventory. April 19, 2011 

Develop coliform sampling plan and report coliform sampling 

frequency. April 19, 2011 

Develop aircraft water system O&M plan, and report disinfection and 

flushing frequency and that the O&M plan is completed. April 19, 2011 

Aircraft water system O&M plan must be incorporated into an FAAaccepted aircraft operations and maintenance program [40 CFR 

141.804(a)]. 

October 19, 2011 

Update aircraft inventory and coliform sampling plans as needed for 

new aircraft. 

(New aircraft placed into operation after April 19, 2011, must 

complete these requirements within the first calendar quarter of 

initial operation [40 CFR 141.806(a)(2)].) 

Beginning 

October 19, 2011 

Conduct routine coliform sampling Beginning 

October 19, 2011 

Conduct routine disinfection and flushing. Beginning 

October 19, 2011 

Conduct all other reporting and recordkeeping requirements. Beginning 

October 19, 2011 

Conduct corrective disinfection and flushing as needed. Beginning 

October 19, 2011 

Conduct public notification as needed. Beginning 

October 19, 2011 

Complete initial self-inspection of each aircraft that is included in the 

inventory as of October 19, 2011, and address deficiencies or notify 

EPA of schedule to address deficiencies. 

No Later Than 

October 19, 2016 

Conduct subsequent self-inspections every 5 years thereafter. 

5 years after 

previous selfinspection 

Complete self-inspections of each aircraft that was added to the 

inventory after October 19, 2011. 

Within 5 years 

after aircraft was 

added to 

inventory 

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Aircraft Inventory 

Air carriers are required to report their fleet inventory for all existing aircraft that are public 

water systems to EPA by April 19, 2011. The inventory must specify the aircraft that are 

currently active and those that are inactive [40 CFR 141.806(b)(1)]. Once the initial inventory 

has been submitted to EPA, any change in inventory must be submitted to EPA within 10 days 

after the end of the month in which the change occurred [40 CFR 141.806(b)(2)]. Since each 

aircraft is a public water system, the inventory must include a unique identifier number for each 

aircraft [40 CFR 141.806(b)(1)]. Inventory information must be submitted to EPA electronically, 

in the ADWR Reporting and Compliance System to facilitate subsequent reporting and 

recordkeeping. If an air carrier is unable to report electronically, the air carrier may use an 

alternative approach that the Administrator approves [40 CFR 141.806(d)]. Chapter 3 includes 

more information on inventory information, what is meant by active and inactive status of an 

aircraft, and the reporting format and procedures. 

Coliform Sampling Plans 

Air carriers must develop coliform sampling plans for existing aircraft by April 19, 2011 [40 

CFR 141.802(b)]. The sampling plans must include sampling procedures, aircraft sampling 

frequencies, and routine disinfection and flushing frequencies [40 CFR 141.802(a)]. Air carriers 

are not required to submit the coliform sampling plans to EPA but must inform EPA that the 

plans are complete and submit their planned sampling frequencies by April 19, 2011 [40 CFR 

141.806(a)(1)]. EPA may choose to review the plans during a compliance audit, and can request 

that the plans be submitted at any time. Although the ADWR requires a sampling plan for each 

aircraft, individual plan documents are not required for each aircraft. EPA anticipates a plan may 

be developed that covers several aircraft and specifies the aircraft identifier numbers within the 

document. For new aircraft, air carriers must place the aircraft under an existing sampling plan or 

develop a new plan. Air carriers must report the coliform sampling frequency within the first 

three months of operation of the new aircraft [40 CFR 141.806(a)(2)]. See Chapter 4 for more 

information on coliform monitoring requirements including coliform sampling plans, sample 

collection procedures, and follow-up actions and options when routine coliform samples indicate 

coliforms are present. 

Operation and Maintenance Plans 

By April 19, 2011, air carriers must report to EPA that they have developed their aircraft water 

system O&M plans. Air carriers need not submit the O&M plans to EPA but must inform EPA 

that the plans are complete [40 CFR 141.806(a)(1)]. The O&M plans must be included in the 

Federal Aviation Administration (FAA)-accepted O&M program by October 19, 2011 [40 CFR 

141.804(a)]. EPA can request a copy of the plan at any time and may also view the plan during 

compliance audits. Although the rule requires an O&M plan for each aircraft, individual plan 

documents are not required for each aircraft – EPA anticipates a plan may be developed that 

covers several aircraft and specifies the aircraft identifier numbers within the document. 

Beginning October 19, 2011, air carriers must revise an existing plan to add the new aircraft or 

develop a new aircraft water system O&M plan within the first calendar quarter of operation of a 

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new aircraft water system and inform EPA that the plan is complete [40 CFR 141.806(a)(2)]. See 

Chapter 5 for more information on the required elements of the O&M plans. 

Self-Inspections 

Under the ADWR, air carriers or their representatives must perform a self-inspection of all water 

system components for each aircraft water system no less frequently than once every 5 years [40 

CFR 141.800(b) and 141.808(b)]. This frequency is consistent with sanitary surveys of stationary 

transient non-community water systems and intended to be compatible with other significant 

aircraft maintenance events. This schedule requires that each aircraft that is included in the 

inventory as of October 19, 2011, be inspected any time before October 19, 2016. Any new 

aircraft added to the inventory after October 19, 2011, must have a self-inspection completed 

within 5 years after it is added to the inventory [40 CFR 141.808(b)]. The air carrier must 

address any deficiency identified during compliance audits or routine self-inspections within 90 

days of identification of the deficiency. Where a deficiency is identified during a period of time 

when the aircraft water system is inactive (see Chapter 3 for a definition of an inactive aircraft 

water system), such as during extended or heavy maintenance of the aircraft, the deficiency must 

be corrected before the aircraft water system is returned to active status [40 CFR 141.808(c)]. If 

a deficiency is addressed within 90 days of identification, the air carrier will not incur a 

violation. In addition, if more than 90 days have elapsed but the aircraft water system is not 

active, the air carrier will not incur a violation as long as the deficiency is addressed before the 

aircraft water system is returned to active status. Procedures for conducting self-inspections must 

be included in the aircraft water system O&M plan [40 CFR 141.804(b)]. See Chapter 5 for more 

information on self-inspections. 

Notification to Passengers and Crew 

Beginning October 19, 2011, air carriers are required to notify passengers and crew that are on 

board the aircraft of specific situations related to the quality of the water. If access to the water 

system by passengers is physically prevented through disconnecting or shutting off the water, or 

the flow of water to the taps is prevented (such as if water is supplied only to lavatory toilets and 

not to any lavatory taps), then only the notice to the crew is required. This exception only applies 

when there is no possibility of the passengers accessing the water system for consumptive use. 

See Section 4.3 for more details on restricting public access. 

Notification requirements and timeframes depend on the severity of the health risk created by the 

situation. When public notice must be provided, the ADWR requires only onboard notification of 

passengers and crew. Passengers on previous flights may be notified as part of an illness or event 

investigation, but this is not a requirement of the ADWR. Notification of passengers and crew 

aboard the aircraft must continue to be provided until situation-specific criteria are met [40 CFR 

141.805]. See Chapter 6 for more information on public notification requirements. 

Reporting and Recordkeeping 

In addition to the reporting described previously for aircraft inventory, coliform sampling plans, 

and O&M plans, the rule requires air carriers to report [40 CFR 141.806]: 

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 Sample results; 

 Routine disinfection and flushing; 

 That self-inspections were completed and any unresolved deficiencies that were noted; 

 Failure to comply with monitoring or disinfection and flushing requirements; and 

 The occurrence of events requiring corrective disinfection and flushing of the water 

system and notification of passengers and crew. 

This reporting begins October 19, 2011; actual reporting deadlines vary. See Chapter 7 for more 

information on recordkeeping and reporting. 

Air carriers must maintain their coliform sampling plans and O&M plans. The records do not 

need to be retained on the aircraft, and may be kept in electronic format. Records of coliform 

monitoring and disinfection and flushing must be kept for at least five years, and records of selfinspections must be kept for at least 10 years. The rule also specifies public notice records must 

be kept for a minimum of three years [40 CFR 141.807]. Records that are required to be 

maintained by the ADWR must be made available to EPA upon request and during compliance 

audits. 

Implementation Oversight and Enforcement 

The rule authorizes EPA to conduct onsite compliance audits of aircraft and aircraft records. 

EPA may review records, collect coliform samples, and observe procedures at any time. The 

ADWR does not affect or modify the responsibilities or requirements of the FDA or FAA. 

2.2 What is an Aircraft Public Water System? 

2.2.1 Types of Public Water Systems 

The National Primary Drinking Water Regulations (NPDWRs) define a public water system 

(PWS) as a system for providing water for human consumption to the public through pipes or 

other constructed conveyances if such system either has at least 15 service connections or 

regularly serves an average of at least 25 individuals daily, at least 60 days per year [40 CFR 

141.2]. As described in Section 1.1, human consumption includes uses such as water for drinking 

or food preparation, as well as water for brushing teeth and hand washing. 

Public water systems are subject to different requirements of the NPDWRs based on the type of 

population they serve. The type of population served is defined whether consumers are exposed 

to the water for short time periods or extended time periods. The two main categories of public 

water systems are community water systems (CWSs) and non-community water systems 

(NCWSs). CWSs primarily serve residential populations; non-community systems primarily 

serve nonresidential users. NCWSs are further divided based on whether they regularly serve at 

least 25 of the same people for more than 6 months per year, such as schools or workers at a 

business or industry. If the same people are served, the system is classified as a non-transient 

non-community water system. If different people are served, as occurs at campgrounds, 

restaurants, or highway rest stops, the system is classified as a transient non-community water 

system. 

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Aircraft public water systems are regulated as transient non-community water systems because 

they are NCWSs that do not regularly serve at least 25 of the same people over six months per 

year. They are also regulated as surface water systems because they are likely to board finished 

water from public water systems that use surface water (since many stationary systems serving 

airports rely, at least in part, on surface water as a source). Since aircraft public water systems 

serve a transient population, they are subject only to regulations that address acute health effects 

resulting from short-term exposure to drinking water contaminants. Acute health effects are 

impacts on health that occur over a short period of time after exposure to the contaminant. The 

ADWR is designed to address such health risks. 

2.2.2 Components of Aircraft Public Water Systems 

The ADWR applies to the onboard water system only. The components of an aircraft water 

system include the water service panel, the filler neck of the aircraft finished water storage tank, 

the onboard water storage tank(s), piping, treatment equipment, galley and lavatory faucets, and 

any other plumbing fixtures that supply water to passengers or crew. An example of one type of 

an aircraft water system is shown in Exhibit 2.2. 

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Exhibit 2.2 Example Components of One Type of an Aircraft Water System 
 

 

Generally, water is supplied to the aircraft through a fill port or ports. 

Water is drained from the water system through a drain port on the 

underbelly of the aircraft. The water system may be pressurized using 

bleed air from the operation of the aircraft engines or an on-demand 

electric pump. 

Aircraft water systems vary depending on the type of aircraft. 

Onboard storage tank capacity varies from a single 

removable/portable tank in a regional jet to multiple tanks exceeding 

one hundred gallons in long-range aircraft. Various piping 

configurations in the galley may include separate lines for the sink 

and a hot water tap located on the coffee maker. Some aircraft have 

activated carbon filters and/or particle removal filters on the supply 

line to the coffee makers; others may have more elaborate onboard 

supplemental treatment systems. 

The aircraft water system may also include some protective devices to meet sanitation 

requirements. Examples include air filters in bleed-air lines and at compressor inlets for 

protection from contaminants, self-venting valves in galley and lavatory supply lines to help 

drain the system, and air gaps between the water supply and the drain system. 

Many large aircraft have more than one water service panel and associated storage and piping 

system. For example, one may be in the forward section of the aircraft to serve a galley and a 

lavatory, and one in the rear of the aircraft to serve a galley and/or lavatory. Interconnections 

between such systems commonly exist so water service can be provided if one system is not 

operational. Even if interconnections do not exist and the storage and piping systems are distinct, 

each aircraft is regulated as a single aircraft public water system. That is, all compliance tracking 

and activities are based on the aircraft, not the number of discrete storage and piping systems that 

comprise the aircraft water system. 

2.3 Quality of Onboard Water 

2.3.1 Public Health Threats Addressed by the Rule 

Because aircraft are transient non-community public water systems, only contaminants that cause 

acute health effects are of concern. An acute health effect is a brief and severe onset of illness 

after short-term exposure. Acute health effects are often caused by microbiological organisms 

and by some chemicals. Chemicals that can cause acute health effects include nitrate, nitrite, and 

high levels of chlorine dioxide. 

The ADWR seeks to protect against disease-causing microbiological contaminants (pathogens) 

in the drinking water of the onboard water system. Microbiological contamination is a concern 

because it can occur after the finished water leaves the public water system from which the water 

is obtained. The contamination can occur during the water boarding process if there are problems 

with the watering point connections, water transfer equipment, or the sanitary practices 

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Aircraft with More 

Than One Water 

Storage Tank and 

Piping System 

Each aircraft is 

regulated as one 

public water system 

regardless of 

whether the aircraft 

has more than one 

discrete storage and 

piping system. 
 

 

employed. Contamination can also occur if the aircraft water system is not properly operated and 

maintained. 

Because the NPDWRs require that nitrate, nitrite, and chlorine dioxide levels be controlled to 

regulatory limits and monitored by the public water system (parent system) serving the airport 

watering point, the ADWR does not require onboard monitoring for these chemicals. This 

assumes that only finished water is boarded for human consumption on aircraft. Finished water 

means water that is introduced into the distribution system of a public water system and is 

intended for distribution and consumption without further treatment, except as necessary to 

maintain water quality in the distribution system (e.g., supplemental disinfection, addition of 

corrosion control chemicals) [40 CFR 141.2]. The assumption that only finished water is boarded 

on aircraft is based on an FDA requirement that only potable water may be provided for drinking 

and culinary purposes on interstate carrier conveyances (ICCs) [21 CFR 1240.80]. However, 

aircraft water systems that are boarding water that is not finished water will continue to be 

subject to existing NPDWRs, which include requirements for chemical monitoring for nitrate 

and nitrite in addition to microbial monitoring. Chlorine dioxide monitoring also would be 

required if chlorine dioxide was used as a disinfectant or oxidant in the treatment process. 

2.3.2 Maintaining Water Quality Throughout the Supply and 

Transfer Chain 

The aircraft water system supply and transfer chain refers to the steps necessary to provide 

drinking water onboard an aircraft. The supply and transfer chain includes the public water 

system used as the source of finished water; the airport (that may be a public water system with 

its own source or convey water from another public water system to the watering points and 

servicing areas); the watering points and service areas and associated transfer equipment; and the 

aircraft water system. 

Exhibit 2.3 illustrates potential mechanisms and pathways through which water may be 

contaminated prior to being boarded, or may become contaminated or deteriorate in quality while 

onboard the aircraft. The discussion that follows provides protection measures to reduce or 

eliminate potential mechanisms and pathways. The ADWR is intended to complement existing 

regulations to minimize contamination events and prescribe appropriate response actions if they 

occur. 

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Exhibit 2.3 Potential Contamination Pathways within the Aircraft Water System 

Supply and Transfer Chain 

Public Water System 

The public water system is required by the NPDWRs to provide a reliable quality and quantity of 

finished water to all consumers. They must perform monitoring and must comply with reporting 

and recordkeeping requirements to document the quality of the water provided. 

The ADWR requirements for finished water to be boarded are intended to ensure water will be 

available for boarding that is fully in compliance with drinking water quality standards. 

However, treatment failures or events within the distribution system of the public water system 

could result in contamination of the water supplied to the airport or watering point. 

In the event the public water system that provides the water to be boarded is not in compliance 

with standards, it is required by the NPDWRs to notify all of its customers, which would include 

airport authorities and/or air carriers. Violations of drinking water standards for acute 

contaminants (which are the contaminants addressed by the ADWR) require notification to 

consumers within 24 hours of learning of the violation. The ADWR assumes these events would 

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be infrequent and temporary. However, if air carriers are notified of such an event, then air 

carriers should ensure personnel responsible for taking appropriate actions regarding the 

boarding of water and any follow-up actions if the water is boarded are notified immediately. 

Development of a communications strategy to address this situation is described in more detail in 

Chapter 9. 

Airport Watering Points 

Finished water from a regulated public water system is delivered to the airport and is accessible 

to aircraft and water service providers at watering points that are in accordance with FDA 

regulations [21 CFR 1240.83]. Water is transferred to the aircraft storage tank either by a direct 

hose connection from a water cabinet mounted on the terminal building, a mobile truck, or a cart, 

depending on the aircraft’s relative location to the watering point. Small aircraft such as regional 

jets may not have a service port for filling the onboard storage tank. Instead, these aircraft water 

systems may be equipped with a removable container (usually 5 gallons) that is refilled at the 

airport’s servicing area or catering facility. 

FDA regulations for interstate carrier conveyance watering points require that the water supply 

meets the NPDWRs [21 CFR 1240.83]. FDA requirements also ensure that the methods and 

sanitary conditions for delivery of the water to the aircraft prevent the introduction, transmission, 

or spread of communicable diseases [21 CFR 1250.63]. FDA administers and enforces these 

requirements through inspections. FDA inspects watering points to ensure they are clean and 

sanitary. 

Because watering points and servicing areas for aircraft are regulated by FDA, the ADWR does 

not duplicate the FDA program. The ADWR aligns with the FDA program by requiring that the 

aircraft water system operations and maintenance (O&M) plan include procedures for boarding 

water that ensure the water will not become contaminated during transfer. These watering point 

and boarding water procedure requirements are discussed further in Chapter 5, which covers the 

requirements for the aircraft O&M plan. 

Aircraft Water System 

The FDA approves the design of aircraft water systems [21 CFR 1250.41], treatment systems [21 

CFR 1240.90], and requires that interstate carrier conveyances only provide potable water for 

drinking and culinary purposes [21 CFR 1240.80]. In general, the FDA’s review of the design of 

aircraft water systems includes all of the following: 

	 Ensuring potable water systems are independent systems not connected to non-potable 

systems, or are protected by backflow prevention devices if non-potable water 

connections are present (e.g., humidifiers and flush rings on vacuum toilets). 

	 The equipment making up the water system is made of material suitable for use in a 

potable water system. 

	 The water system is constructed to prevent contamination (e.g., fill connection fittings 

are quick-coupling, no more than 3⁄4” in diameter, clearly labeled “Potable Water 

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Filling,” and provided with protective dust cover; vents are oriented downward; 

backflow prevention devices are installed at possible cross connections; insulation is 

protected to prevent water adsorption and contamination; etc.). 

Therefore, additional treatment of the water should not be needed prior to boarding the water. 

Although protection measures exist for the boarding of water, the opportunity exists for 

microbiological organisms to be introduced during the process of boarding water. Contamination 

of the aircraft water system by microbiological or chemical contaminants can occur inadvertently 

if water is boarded onto an aircraft that is not known at the time to be in violation of drinking 

water standards, or if water that does not meet standards is knowingly boarded to operate 

essential systems such as toilets. Water quality can also deteriorate if water is held in the 

airport’s distribution system or in the aircraft’s water system for too long. As the water ages, 

coliform bacteria and other bacteria, although generally harmless, can accumulate on pipe and 

storage tank interior surfaces forming biofilm, a layer of microorganisms that can provide shelter 

for pathogens if they were to enter the system. 

Routine disinfection and flushing procedures and other O&M requirements are intended to 

control biofilm growth and ensure water quality is maintained. 

As illustrated in Exhibit 2.3 there are numerous pathways for potential contamination within the 

aircraft water supply and transfer chain. Timely and effective communication is essential 

between the responsibilities parties (i.e., public water system, airport, air carrier) as well as with 

the appropriate regulatory authorities if a drinking water contamination event occurs. 

Communication strategy is discussed in more detail in Chapter 9. 

2.3.3 ADWR Public Health Protection Measures 

It is impractical for aircraft to monitor the water for microbiological contaminants every time 

water is boarded because several samples may be necessary in one day for some aircraft and 

coliform bacteria analytical results would not be available for at least 24 hours after sample 

analysis has begun. Therefore, results would not be known until long after the water was 

consumed. 

To provide meaningful public health protection, the ADWR requires air carriers to develop a 

comprehensive O&M plan for each aircraft water system to minimize opportunities for 

contamination [40 CFR 141.804]. The plan must include procedures for routine disinfection and 

flushing which must be performed at frequencies recommended by the aircraft water system 

manufacturer. The plan requires periodic testing for total coliform bacteria to confirm the 

effectiveness of O&M procedures. It also identifies minimum training content and requires 

training of key personnel. In the event that an air carrier becomes aware of contamination on an 

aircraft, the ADWR requires corrective action and onboard public notification of passengers 

and/or crew, when appropriate. 

In addition to the O&M plan, the ADWR requires self-inspections by air carriers of each aircraft 

water system and provides for EPA compliance audits. Lastly, the rule requires reporting and 

recordkeeping to facilitate compliance tracking and rule implementation. 

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3. Aircraft Inventory 

Under the ADWR, air carriers are required to submit to EPA an inventory identifying all aircraft 

public water systems in their fleet and to update the inventory as fleet changes occur [40 CFR 

141.806(b)]. The reporting requirements for inventory are effective April 19, 2011. Compliance 

with the requirements of the ADWR will be tracked for each aircraft individually. To facilitate 

collection and analysis of aircraft water system data, EPA will use an internet-based electronic 

data collection and management system, referred to as the ADWR Reporting and Compliance 

System (see Section 7.2.1). This Chapter describes how to identify aircraft that are public water 

systems and the information to be reported. It also provides a reference for more information on 

how to submit the inventory data. 

3.1 Identifying Aircraft Public Water Systems 

Air carriers must identify all aircraft in their fleet that are subject to the requirements of the 

ADWR and include these aircraft in their inventory that is reported to EPA [40 CFR 

141.806(b)(1)]. Although the applicability of the ADWR to aircraft and the definition of an 

aircraft public water system have been covered previously in this guidance manual, it is repeated 

here because it is pertinent to identifying aircraft that must be included in the air carrier 

inventory and will be covered by the coliform monitoring and aircraft O&M plans. 

The applicability criteria for an aircraft with an onboard water system to be regulated under the 

ADWR are as follows: 

	 Aircraft that meet the definition of a public water system have an onboard water system of 

piped water for human consumption and regularly serve an average of at least 25 or more 

individuals daily at least 60 days out of the year. 

Piped water for human consumption means the onboard water system provides water 

through taps (e.g., in a galley, a lavatory, or drinking fountain). The onboard water can be 

supplied to the aircraft via a fill port and piping, or by a removable tank. 

A galley is the area of the aircraft where food is cooked and prepared. If the galley has a 

water tap, even if there is only a hot water tap, the aircraft will be subject to the ADWR. 

EPA considers “human consumption” to occur in a lavatory if there is a tap. Facilities 

with toilets without a lavatory tap (as seen in some small, short-range aircraft) are not 

considered to be providing water for human consumption under SDWA because tap 

water cannot be accessed by passengers or crew. A lavatory sink with a tap provides 

water for human consumption even if the tap and basin are only intended for hand 

washing and drinking cups are not provided. An aircraft need only have a galley tap or a 

lavatory tap or a drinking fountain to meet this criterion. 

Guidance Manual 21 

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By definition, a public water system regularly serves an average of at least 25 or more 

individuals daily at least 60 days out of the year [40 CFR 141.2]. The 25-person average 

minimum includes the total number of passengers and crew for all of the flights in a day; 

the 60 days per year do not need to be consecutive days. If the aircraft does not operate at 

least 60 days each year, or if it does not regularly serve an average of at least 25 people 

daily at least 60 days in a year, the aircraft would not be a public water system. For 

example, the ADWR and other NPDWRs do not apply to aircraft that are used solely for 

cargo purposes if they do not regularly serve an average of at least 25 people daily, even 

if they have an onboard water system. 

 The ADWR is limited to aircraft that board only finished water. 

The ADWR assumes that only finished water is boarded for human consumption on 

aircraft because of the FDA requirement that only potable water may be provided for 

drinking and culinary purposes on interstate carrier conveyances [21 CFR 1240.80]. 

Finished water is defined as water that is introduced into the distribution system of a 

public water system and is intended for distribution and consumption without further 

treatment, except as treatment necessary to maintain water quality in the distribution 

system [40 CFR 141.801]. Disinfection, such as an ultraviolet light disinfection system, is 

an example of treatment that may be used to maintain water quality after the water has 

been boarded. Carbon filters and particle removal filters are installed on some aircraft 

water systems for aesthetic purposes. 

An aircraft public water system that boards water that is not of finished quality is not 

eligible to comply with the ADWR but is subject to all of the other applicable National 

Primary Drinking Water Regulations. 

 Aircraft that fly international routes with two or more destinations within US jurisdiction. 

Aircraft that fly international routes that make only one stop in the US solely for the 

purpose of unloading passengers transported from outside the US and/or loading 

passengers for transportation to a destination outside the US are excluded from ADWR 

regulations. Thus, under the ADWR, if an aircraft serves two or more US destinations 

before returning to an international location they are subject to the ADWR while in the 

US. 

 Aircraft not excluded from regulation under 40 CFR 141.3. 

The SDWA [Section 1411(4)] and NPDWRs [40 CFR 141.3] specifically exclude from 

regulation public water systems that meet all of the following criteria: 1) consist only of 

distribution and storage facilities and do not have any collection and treatment facilities; 

2) obtain all water from, but are not owned or operated by, a public water system; 3) do 

not sell water to any person; and 4) are not a carrier that conveys passengers in interstate 

commerce. 

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Aircraft are carriers; therefore, if aircraft that are public water systems convey passengers 

in interstate commerce they are specifically identified as being subject to the drinking 

water regulations and cannot be excluded. 

A government-owned aircraft used solely for government purposes that is not conveying 

passengers in interstate commerce may be excluded from SDWA and ADWR regulations 

if it meets the other three criteria. However, if a government-owned aircraft does not 

obtain all water from a public water system (i.e., aircraft that board water from a location 

that is outside of US jurisdiction), the aircraft would not be excluded from regulation. 

As discussed in Chapter 1, it is important to note that the term “interstate commerce” 

does not exclusively apply to aircraft conveying passengers between two different states. 

3.2 Aircraft Status as “Active” or “Inactive” 

One of the aircraft water system inventory details that must be reported is whether each aircraft 

water system is under ‘active’ or ‘inactive’ status [40 CFR 141.806(b)(1)(ii)]. EPA requires 

accurate information on an aircraft water system’s status for ensuring accountability and 

compliance. Aircraft water systems under active status must comply with the ADWR; aircraft 

water systems that are inactive would not be required to comply with the ADWR during the 

period of inactivity. 

Aircraft water systems are defined in 40 CFR 141.801 as follows: 

“Aircraft Water System means an aircraft that qualifies as a public water system under 

the Safe Drinking Water Act and the national primary drinking water regulations. The 

components of an aircraft water system include the water service panel, the filler neck of 

the aircraft finished water storage tank, and all finished water storage tanks, piping, 

treatment equipment, and plumbing fixtures within the aircraft that supply water for 

human consumption to passengers or crew.” 

Active status refers to time periods during which an aircraft water system is in normal operation 

flying routes in the US. EPA anticipates that this will be the default for most of the operating 

life of an aircraft water system. However, there may be some periods within the operating life of 

the aircraft where the aircraft water system may be considered inactive. 

In order for an aircraft water system to be considered “inactive” for purposes of compliance 

determination under the ADWR, the following conditions must be met to avoid the automatic 

issuance of a violation by the ADWR Reporting and Compliance System: 

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	 The aircraft water system must be identified in the ADWR Reporting and Compliance 

system as inactive by the end of the compliance period in which the monitoring or 

disinfection and flushing requirement is due to be performed; 

	 Passenger access to the water system must be prevented by (1) disconnecting or 

shutting off the water, (2) preventing the flow of water through the tap(s), (3) 

allowing water to be supplied only to lavatory toilets and not to any lavatory or galley 

tap, or (4) removing the aircraft from passenger service; and 

	 The missed requirement(s) must be performed prior to the aircraft water system 

serving water to the public. 

For example, if an aircraft is having unavoidable logistic problems (such as occurred in early 

2010 when aircraft in some areas were grounded due to a volcanic eruption) that causes the 

aircraft to miss a required routine disinfection and flushing event because the aircraft is out of 

service, the air carrier may identify the aircraft water system in the ADWR Reporting and 

Compliance System as inactive before the end of the compliance period in which the routine 

disinfection and flushing event should have occurred. Once the aircraft returns to service, 

passenger access to the water system must be prevented by disconnecting or shutting off the 

water, preventing the flow of water through the taps, or allowing water to be supplied only to 

lavatory toilets and not to any lavatory or galley tap. The aircraft water system must not provide 

water to the public until the missed requirement(s) has been performed. 

3.3 Reporting Inventory Information 

The air carrier must report its complete inventory of existing aircraft that are public water 

systems to EPA no later than April 19, 2011. Aircraft inventory includes but is not limited to the 

following: 

	 The unique aircraft identifier number; 

	 The status of aircraft water systems as active or 

inactive; 

	 The type and location of any supplemental treatment 

equipment installed on the water system; and 

	 Whether the aircraft water system can be physically 

disconnected or shut off, or the flow of water 

prevented through the tap(s). 

Any changes in aircraft inventory must be reported no later 

than 10 days following the calendar month in which the 

change occurred [40 CFR 141.806(b)(1)]. This includes 

permanent removal of an aircraft from the inventory, or 

changes to the active/inactive status, treatment equipment, or 

ability to shut off the water or prevent the flow of water to 

taps. This also includes adding new aircraft with public water 

systems to the fleet. 

Prompt notification to EPA of all inventory changes is 

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Reporting Inventory

Updates and Updated

Coliform Sampling Plans or 

O&M plans

The reporting requirement for 

inventory updates is no later

than 10 calendar days

following the calendar month 

in which the change occurred.

This differs from the 

requirement that new 

aircraft coliform sampling 

plans and operations and 

maintenance plans must be 

completed and reported 

within the first calendar 

quarter of aircraft operation. 
 

 

necessary to ensure violations are not incurred by aircraft that are out of service or otherwise 

inactive, and that new and active aircraft are in compliance with the rule. 

The ADWR Reporting and Compliance System and its User Guide will include information on 

the inventory update reporting format and how to make inventory changes. 

Details regarding the reporting of aircraft inventory information are provided in Chapter 7. 

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October 2010
 
 

 

 

4. Coliform Monitoring 

Total coliforms are a group of closely related bacteria that, with a few exceptions, are not 

harmful to humans. Coliforms are abundant in the feces of warm-blooded animals, but can also 

be found in aquatic environments, in soil, and on vegetation. Total coliforms have long been 

considered an indicator that a potential pathway exists through which fecal contamination could 

enter a water system. The absence of total coliforms in the distribution system indicates a 

reduced likelihood that fecal contamination and/or waterborne pathogens are present. 

The ADWR uses coliform monitoring as a means of periodically evaluating the bacterial quality 

of the water on board the aircraft. All aircraft public water systems are required to monitor for 

the presence of total coliforms and to further analyze any total coliform-positive samples for the 

presence of Escherichia coli (E. coli). E. coli bacteria are members of the total coliform group 

that almost always originate from the gut of warm-blooded animals. Therefore, the presence of 

E. coli indicates that the water may be contaminated by human or animal wastes. Many of the 

analytical methods for total coliforms simultaneously detect the presence or absence of E. coli. 

See Section 4.5.2 for more information on analytical methods. 

This chapter discusses the types of coliform samples required by the ADWR; coliform sampling 

plan requirements; responses to coliform sample results; coliform sampling protocols; laboratory 

and analytical method requirements; and reporting of sample results. 

4.1 Types of Coliform Samples 

There are three types of coliform samples required by the ADWR: routine samples, repeat 

samples, and follow-up samples. Special purpose samples are also an option for air carriers, and 

replacement samples may be required if routine, repeat, or follow-up samples or sample results 

are invalidated by the laboratory or EPA. 

Routine Samples 

Routine samples are collected on a specified schedule, which is determined by the frequency of 

routine disinfection and flushing of the aircraft water system and must be described in the 

coliform sampling plan prepared for the aircraft. See Section 4.2.3 for more information on 

routine sampling frequencies. EPA intends for air carriers to schedule routine monitoring at 

regular intervals throughout the calendar year. Routine monitoring should be scheduled so that 

the amount of time between each monitoring event is approximately equal. Air carriers should 

not schedule routine monitoring events to take place back-to-back such that samples are taken at 

the end of one monitoring period and again at the beginning of the following period. Routine 

samples cannot be collected within 72 hours after completing routine disinfection and flushing 

procedures [40 CFR 141.803(b)(6)]. 

For routine sampling, two samples of 100 milliliters (mL) each must be collected, one from a 

galley and one from a lavatory tap during each monitoring period [40 CFR 141.803(b)]. 

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If the aircraft has only one tap, two 100 mL samples must be collected from that tap. An 

exception to the requirement for two routine samples each monitoring period is allowed by the 

ADWR for aircraft water systems consisting of only one tap and a removable or portable 

container that is drained every day of passenger service. These systems must collect only one 

100 mL routine sample from the available tap [40 CFR 141.803(b)(2)]. 

Aircraft with a single water system but more than two possible sampling locations may also 

adjust the sample locations each monitoring period if necessary to collect representative samples 

throughout the system. See Section 4.2.2 for more discussion on rotating sample locations. 

Repeat Samples 

When one or more routine samples are total coliform-positive and E. coli-negative, air carriers 

have the option to collect repeat samples instead of performing corrective disinfection and 

flushing of the system. Repeat samples provide information on the extent of the contamination 

event that resulted in the presence of coliform organisms in t

collect repeat samples is selected, three repeat samples of 

100 mL each must be collected no later than 24 hours after 

the laboratory notifies the air carrier of the routine total 

coliform-positive sample results [40 CFR 141.803(c)(3)(iii)]. 

The three repeat samples must be collected and analyzed 

from three taps within the aircraft as follows: the tap that 

resulted in the total coliform-positive routine sample, one 

other lavatory tap, and one other galley tap. If less than three 

taps exist, then a total of three 100-mL samples must be 

collected and analyzed from the available taps within the 

aircraft water system. For example, if an aircraft has only 

two taps, two 100-mL samples would be collected from one 

of the taps, and one 100-mL sample would be collected from 

the other tap. 

If the carrier cannot collect the repeat samples within 24 

hours, no extensions to this timeframe are allowed. The air 

carrier must proceed with another option. 

Follow-up Samples 

he routine samples. If the option to 

­

Follow-up samples are used to indicate the effectiveness of corrective disinfection and flushing 

procedures. Follow-up samples consist of two samples of 100-mL each that must be collected at 

the same locations as the routine samples – that is, a galley tap sample and a lavatory tap sample 

must be collected if both are available [40 CFR 141.803(e)]. The ADWR does not specify a 

timeframe by which follow-up samples must be collected; however, follow-up samples must be 

collected prior to providing water to the public for human consumption from the aircraft water 

system. 

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Repeat Sample 

Twenty-four Hour 

Timeframe 

Repeat samples must be 

collected no later than 

24 hours after 

notification of routine 

sample total coliformpositive and E. coli

negative results. 

No extensions to the 

twenty-four hour time 

frame are allowed. If 

repeat samples cannot be 

collected within 24 

hours, the air carrier 

must proceed with 

another option. 
 

 

Follow-up samples must be collected when: 

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o	 Corrective disinfection and flushing is performed in response to a total coliformpositive or E. coli-positive sample. 

o	 Corrective disinfection and flushing is triggered by failure to: perform routine 

disinfection and flushing or routine coliform monitoring; failure to collect repeat 

samples or follow-up samples; or failure to board water from a safe watering point. 

Follow-up samples may be collected after routine disinfection and flushing. See Section 4.2.6 for 

more information. 

Special Purpose Samples 

Special purpose samples are not required by the ADWR. They are samples collected by the air 

carrier on a voluntary basis, as needed, to indicate the quality of the onboard water. Special 

purpose samples may be useful indicators of water quality following repair or replacement of 

water system components or fixtures. 

Replacement Samples 

In the event a routine, repeat, or follow-up sample is invalidated by the laboratory or EPA, a 

replacement sample would be required to fulfill the monitoring requirements of the ADWR. The 

sample must be collected within the monitoring period applicable to the original sample. For this 

reason, EPA recommends routine monitoring be performed early enough in the monitoring 

period to allow notification of the need for replacement samples and their collection before the 

monitoring period is over. 

Further details regarding invalidated samples are provided later in this chapter. 

4.2 Coliform Sampling Plans 

By April 19, 2011, air carriers must develop a coliform sampling plan for each aircraft in their 

inventory [40 CFR 141.802(b)]. The sampling plan ensures representative and meaningful 

samples are collected from each aircraft. A separate plan does not need to be developed for each 

aircraft, but each aircraft must be covered by a plan. Therefore, a single plan could be developed 

to cover each aircraft that has identical requirements and schedules. Coliform sampling plans 

should include the unique aircraft identifier numbers to which the plan applies. 

Once completed, the air carrier must notify EPA that the coliform sampling plan has been 

prepared [40 CFR 141.806(a)] and the plan must be included in the aircraft water system O&M 

plan. Air carriers need not submit the coliform sampling plans to EPA but EPA can request a 

copy of the plan at any time and may also view the plan during compliance audits. When 

additional aircraft are added to the fleet, EPA must be notified that a sampling plan has been 

completed for the new aircraft by the end of the calendar quarter in which the aircraft begins 

operation [40 CFR 141.806(a)(2)]. New aircraft may be added to the list of aircraft covered by an 

existing plan, or a new plan may be developed. Air carriers must notify EPA electronically using 

the ADWR Reporting and Compliance System. If they are unable to report the information 
 

 

electronically, they may use an alternative approach as approved by EPA [40 CFR 141.806(d)]. 

See Chapter 7 for more discussion regarding reporting requirements. 

At a minimum, all coliform sampling plans must include the following [40 CFR 141.802(a)]: 

 Coliform sample collection procedures. 

 Sample tap location(s) representative of the aircraft water system. 

 Frequency and number of routine samples to be collected. 

 Frequency of routine disinfection and flushing as specified in the operation and 

maintenance plan. 

 Procedures for communicating sample results to ensure that all required actions are 

conducted in a timely manner. 

Each of these elements of a coliform sampling plan is discussed in more detail below. An 

example coliform sampling plan is provided in Appendix C. 

4.2.1 Coliform Sample Collection Procedures 

Standardized procedures ensure representative samples are collected and meaningful sample 

results are obtained. Proper sample collection procedures will ensure that contaminants on the 

surface of faucets and fixtures are not transferred to the sample container. Suggested sampling 

procedures are included in Section 4.4. 

4.2.2 Sample Tap Location(s) Representative of the Aircraft Water 

System 

Coliform sample locations should be those most representative of water used for human 

consumption by passengers and crew. As described in Chapter 1, human consumption is not 

limited to water used only for drinking or beverage preparation. 

Because passengers may access water in the lavatory for hand washing, teeth brushing, drinking, 

or preparing dehydrated foods, lavatories must be sampled to represent water provided to the 

public. To ensure representative sample collection locations are used, the ADWR requires that 

routine coliform samples be collected from a lavatory tap and a galley tap during each 

monitoring period if the aircraft has taps in these locations. If an aircraft has a single tap, the 

sample(s) must be collected from that tap [40 CFR 141.803(b)]. Follow-up samples are collected 

consistent with routine sample collection locations. 

Since there is a potential for the water temperature in hot water taps to be high enough to kill 

existing microorganisms in the sample, thus masking any microbiological contamination in the 

aircraft water system, samples should be collected from cold water taps when they are available. 

However, if there is only one tap available in the lavatory, then that tap must be used for the 

lavatory sample regardless of the temperature. Similarly, when only a hot water tap is available 

in the galley such as those used for making hot tea, the galley sample must be collected from the 

hot water tap. If a sample is collected from a hot water tap, it is suggested that the temperature of 

the water be recorded, if available. The temperature of the water may be useful in diagnosing 

Guidance Manual 30 

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problems in the water system, but measuring the temperature of the water is not required by the 

ADWR. 

The ADWR requires that sample collection locations be identified in the coliform sampling plan 

[40 CFR 141.802(a)(2)]. Identifying sample taps as to whether they are fore or aft, lavatory or 

galley, and other details helps identify the specific location from which a sample was collected. 

When this location information is entered on the coliform sample form submitted to the 

laboratory, the sample results will also be reported with the location. This information is useful 

for follow-up investigations if an issue arises. For example, air carriers have noted to EPA that 

being able to identify the specific sample location from which coliform-positive samples were 

collected helped detect problematic faucets as well as cleaning issues. This information may 

have helped to identify and resolve persistent coliform-positive sample problems. 

Air carriers have flexibility to consider a variety of approaches in developing sampling 

procedures to collect representative samples, including: 

	 If more than one galley and lavatory tap are available, rotate the sample collection 

locations each monitoring period on a scheduled basis so that the entire aircraft water 

system is sampled periodically. For example, Exhibit 4.1 illustrates an aircraft with 3 

lavatories and 4 galleys. If the aircraft is on quarterly coliform monitoring, a sample from 

a lavatory and a galley on opposite ends of the aircraft may be appropriate during each 

monitoring period. The table in Exhibit 4.1 provides an example of how the galleys and 

lavatories on this aircraft might be paired for each of the four quarters of sampling. Note 

that a different lavatory and galley is sampled each monitoring period so they are all 

routinely sampled. 

	 If more than one galley and lavatory tap are available, select sample collection locations 

randomly to obtain representative samples over time. 

	 If an aircraft has more than one water tank and plumbing system and the systems are not 

interconnected, alternate the sample locations between the discrete systems. 

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Exhibit 4.1 Example Sample Locations 

Monitoring 

Period 1 

Monitoring 

Period 2 

Monitoring 

Period 3 

Monitoring 

Period 4 

Lavatory 1 & 

Galley 3 

Lavatory 2 & 

Galley 1 

Lavatory 3 & 

Galley 2 

Lavatory 1 & 

Galley 4 

4.2.3 Frequency and Number of Routine Coliform Samples to Be 

Collected 

Including the required frequency and number of samples to be collected in the coliform sampling 

plan helps ensure personnel responsible for this task will collect the correct number of samples 

during the required monitoring period. The number of routine coliform samples that must be 

collected is discussed in Section 4.1. The frequency of sample collection can be either monthly, 

quarterly, semi-annually, or annually. It is determined by the routine disinfection and flushing 

frequency recommended by the manufacturer of the aircraft water system. If the manufacturer 

does not recommend a frequency, the air carrier must choose a frequency and a corresponding 

routine coliform sampling frequency as specified in the ADWR [40 CFR 141.804(b)(2)(iii)] and 

displayed in Exhibit 4.2. Exhibit 4.2 shows monitoring frequencies that correspond to a given 

disinfection and flushing frequency [40 CFR 141.803(b)(3)]. Additional voluntary coliform 

sampling is encouraged by EPA. 

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Any changes to the frequency of required coliform sampling must be reported to EPA and must 

be incorporated into the sampling plan and the aircraft water system O&M plan [40 CFR 

141.806(b)(6)] as discussed in Chapter 7. 

Exhibit 4.2 Coliform Sampling Frequencies Based on 

Disinfection and Flushing Frequencies 

Minimum Routine Disinfection and 

Flushing Frequency 

Minimum Routine Coliform 

Sampling Frequency 

At least 4 times per year = At least 

once within every three-month period 

(quarterly). 

At least 1 time per year = At least once 

within every twelve-month period 

(annually) 

At least 3 times per year = At least 

once within every four-month period. 

At least 2 times per year = At least 

once within every six-month period 

(semi-annually) 

At least 2 times per year = At least 

once within every six-month period 

(semi-annually) 

At least 4 times per year = At least 

once within every three-month period 

(quarterly) 

At least 1 time per year or less = At 

least once within every twelve month 

period (annually) or less. 

At least 12 times per year = At least 

once every month (monthly) 

4.2.4 Frequency of Routine Disinfection and Flushing As 

Specified In the Operation and Maintenance Plan 

The frequency of routine disinfection and flushing of the aircraft water system determines the 

minimum frequency for routine coliform sample collection. Including the disinfection and 

flushing frequency in the coliform sampling plan helps ensure the proper frequencies are 

followed and that both activities are performed. Air carriers may conduct disinfection and 

flushing more frequently, but not less frequently, than the manufacturer recommends. However, 

it is the responsibility of the air carrier to ensure that the frequency would not result in damage to 

the aircraft water system’s components. 

4.2.5 Procedures for Communicating Sample Results to Ensure 

All Required Actions Are Conducted in a Timely Manner 

The first step in the communications process is the notice the laboratory performing the coliform 

analyses provides to the air carrier regarding the sample results. Notification of both positive and 

negative sample results in a timely manner is critical to ensure any required action is promptly 

implemented. Required actions may entail repeat or replacement sampling, restricting public 

access including notification of passengers and/or crew, corrective disinfection and flushing, 

follow-up sampling, or returning to unrestricted access of the water. EPA suggests that 

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communications procedures include specific contact personnel names, phone numbers, and backup contact information. 

4.2.6 Scheduling Coliform Sampling to Minimize Service 

Disruption 

Each aircraft water system must be routinely monitored for total coliform at the frequency 

specified in the coliform sampling plan for that aircraft. During each monitoring period – which 

may be once every monthly period, once every three-month period (quarterly), once every sixmonth period (semi-annually), or once every twelve-month period (annually) – a set of two 

routine samples must be collected unless the aircraft qualifies for one routine sample because it 

has only a single removable/portable tank-based system with a single tap [40 CFR 141.803(b)]. 

In order to provide meaningful results, routine coliform sampling is 

intended to be representative of the general conditions of the aircraft 

water system. That is, they should represent water provided to 

passengers and crew on a typical flight. 

To ensure that routine sample results are not inadvertently influenced 

by sampling too soon after a routine disinfection and flushing event, 

routine coliform samples must not be collected within 72 hours after 

completing routine disinfection and flushing procedures [40 CFR 

141.803(b)(6)]. They can, however, be collected immediately prior to a 

routine disinfection and flushing event. This option is provided in the 

ADWR to minimize unscheduled flight interruptions for sample 

collection. 

Flight disruptions may be minimized further in the following situation. 

If either of the routine samples that were collected immediately prior to the routine disinfection 

and flushing procedure test positive for total coliform or total coliform and E. coli, as long as the 

air carrier collected a set of follow-up samples after the routine disinfection and flushing 

procedure, then the routine disinfection and flushing event would also serve as a corrective 

action disinfection and flushing event. However, if the routine sample was E. coli-positive, a 

complete set of follow-up sample results must be total coliform-negative before the air carrier 

provides water for human consumption from the aircraft water system and returns to the routine 

monitoring frequency for coliform as specified in 40 CFR 141.802. If the routine sample was 

total coliform-positive but E. coli-negative, the follow-up samples need only be collected before 

the aircraft water system provides water to the public. 

Guidance Manual 34 

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If any routine,

repeat, or follow-up 

sample is total 

coliform-positive or 

E. coli-positive, the 

entire aircraft water 

system is subject to 

the applicable 

corrective actions. 

This is true even if 

samples were 

collected from 

distinct piping and 

storage systems on 

a single aircraft. 
 

 

 

Tip: Minimizing Flight Disruptions from Coliform Sampling 

and Disinfection and Flushing Events 

Routine coliform samples must not be collected within 72 hours after completing routine disinfection 

and flushing procedures [40 CFR 141.803(b)(6). However, there is no restriction on how much time 

must elapse after routine samples are collected and before disinfection and flushing occurs. The 

ADWR allows for the performance of both of these tasks while an aircraft is out of service if the 

specified routine coliform monitoring frequency and routine disinfection and flushing frequency will be 

met. Many of the routine disinfection and flushing frequency options will accommodate this 

arrangement. 

For example, when an aircraft is taken out of service to perform its routine disinfection and flushing 

procedure and the aircraft is also due for collection of its routine coliform samples, the air carrier may 

collect the routine coliform samples prior to initiating the routine disinfection and flushing procedure. 

Combining these two activities and performing them while the aircraft is already out of service for other 

regularly scheduled maintenance may help to reduce associated disruption to flight service. Another 

possible benefit is that the sample collector does not have to wait for the aircraft to arrive if it is already 

in the hangar for service. The disinfection and flushing procedure can begin before the results of the 

routine coliform samples are known. In this case, because the disinfection and flushing procedure has 

not yet occurred when the coliform samples are collected, the quality of the water in the routine 

samples will be representative of the water that had been served to passengers and crew. If this 

practice is implemented, the samples should be collected as soon as possible after taking the aircraft 

out of service to avoid water quality deterioration that may be caused by stagnant water. 

Furthermore, if the air carrier, as a precaution, also collects a set of follow-up samples after the routine 

disinfection and flushing but before the aircraft serves water to the public and the routine samples test 

postive, then the routine disinfection and flushing may serve as a corrective action disinfection and 

flushing. However, if the routine sample was E. coli-positive, a complete set of follow-up sample results 

must be total coliform-negative before the air carrier provides water for human consumption from the 

aircraft water system and returns to the routine monitoring frequency for coliform as specified in 40 

CFR 141.802. If the routine sample was total coliform-positive but E. coli-negative, the follow-up 

samples need only be collected before the aircraft water system provides water to the public. 

4.3 Responding to Coliform Test Results 

If coliform bacteria are detected in any sample collected from an aircraft, the air carrier must 

take follow-up action but has some discretion regarding the activities to be performed [40 CFR 

141.803(c)(3)]. However, due to the possible imminent public health threat if E. coli is present in 

any sample, options for follow-up activities and their timeframes are very limited [40 CFR 

141.803(c)(2)]. 

Exhibit 4.3 provides a general overview of possible coliform sample result scenarios and refers 

to additional exhibits presented in this section, which provide required situation-specific actions 

based on those sample results. The details of the required follow-up activities presented in this 

section are found in 40 CFR 141.803. 

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Exhibit 4.3 Overview of Possible Coliform Sample Result Scenarios 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

Restricting Public Access 

Some of the response action requirements in the ADWR include the restriction of public access 

to the water system to prevent passengers and crew from accessing the water [40 CFR 

141.803(d)]. Restricting public access includes three key items: physically disconnecting or 

shutting off the aircraft water system, or otherwise preventing flow of water through the taps 

where feasible; providing public notification as applicable; and providing alternatives to water 

such as bottled water and antiseptic hand gels to enable passengers and crew to maintain sanitary 

conditions. The components of restricting public access are presented in Exhibit 4.4. 

There may be operational constraints to physically disconnecting the water system. For example, 

if water to the taps cannot be shut off without also shutting off water to the toilets, then the air 

carrier may determine that physically disconnecting the water system is not feasible. 

Furthermore, EPA interprets the ADWR requirement “otherwise preventing the flow of water 

through the taps” to be accomplished through means similar to physical disconnection. As a 

result, if the "prevention" is easily removed, it would not meet the terms of the ADWR because it 

is not similar in effect to physical disconnection and is not an effective means of "preventing the 

flow of water through the taps." 

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Exhibit 4.4 Restricting Public Access 

Air carriers must give public notice for each aircraft as part of restricting access to the water 

system. 

 If passenger access to the water system is physically prevented through disconnecting or 

shutting off the water or the flow of water prevented through the tap(s), or if water is 

supplied only to lavatory toilets and not to any lavatory or galley taps, then the ADWR 

requires notice that is directed at the crew. Notice to the crew may be conveyed as part of 

a mandatory crew briefing or prominently displayed in the galley. 

 If the aircraft water system cannot be physically disconnected or the flow of water to the 

taps otherwise prevented, prominent notice must be displayed in the galley for the crew 

and prominently displayed in the lavatory for the passengers. 

Public notification requirements are discussed in detail in Chapter 

6 [40 CFR 141.805(c)]. 

Whether the water system can be physically disconnected or not, 

alternatives to water from the aircraft water system, such as bottled 

water for drinking and coffee or tea preparation, are required if 

such services are provided. In addition, antiseptic hand gels or 

wipes and other feasible measures are necessary to help maintain 

sanitary conditions for passengers and crew. EPA also recommends 

that if public access to the water is restricted, all paper cups or 

paper cones be removed from the lavatories and faucet areas to 

reinforce the message that the water should not be consumed. 

Bottled Water 

The requirement for the use 

of bottled water, if water use 

is restricted and beverages 

are provided, is consistent 

with the FDA requirements of 

21 CFR 333. This does not 

require that bottled water be 

provided, but it does require 

that bottled water be used to 

prepare beverages under 

these circumstances. 

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4.3.1 Total Coliform-Negative Routine Sample Result 

If total coliform bacteria are not detected in any routine sample in a monitoring period, the 

aircraft must continue collecting routine samples for total coliform analysis at the frequency 

specified in the coliform sampling plan [40 CFR 141.803(c)(1)]. A sample must be total 

coliform-positive before it is required to be analyzed for E. coli. Therefore, a sample that is total 

coliform-negative is also E. coli-negative and the aircraft should continue conducting routine 

disinfection and flushing. 

4.3.2 Total Coliform-Positive and E. coli-Negative Routine Sample 

Result 

A routine coliform sample result that is total coliform-positive but is E. coli-negative indicates 

the aircraft water system may be vulnerable to contamination by pathogens (e.g., viruses, 

bacteria, or parasitic protozoa from fecal contamination) that can cause disease. If any routine 

sample is total coliform-positive and E. coli-negative, the aircraft has three options: 1) disinfect 

and flush the water system within 72 hours; 2) disinfect and flush on an alternative schedule if 

public access to the water system is restricted within 72 hours; or 3) collect repeat samples 

within 24 hours and take further action, if necessary [40 CFR 141.803(c)(3)]. These three options 

are illustrated in Exhibit 4.5 and described in more detail below. 

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Exhibit 4.5 Overview of Options for Response to Total Coliform-Positive 

(E. coli-Negative) Sample Results 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

Guidance Manual 39 

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Option 1: Disinfect and Flush Within 72 Hours and Collect Follow-up Samples 

If an aircraft chooses Option 1 in response to a routine total coliform-positive and E. colinegative sample result, they must disinfect and flush the aircraft water system within 72 hours of 

being notified of the positive result and collect follow-up samples. After the follow-up samples 

are collected, water from the aircraft water system may be provided for human consumption (see 

Exhibit 4.6). 

	 If all of the follow-up sample results are total coliform-negative, the air carrier may return to 

routine coliform monitoring and continue serving water to the public. Public notification of 

the situation is not required if this option for corrective action is selected and successfully 

implemented. 

	 If either of the follow-up samples are total coliform-positive but E. coli-negative, the air 

carrier must restrict public access within 72 hours after receiving the sample results and 

disinfect and flush the water system again, with the process continuing until a complete set of 

follow-up samples is total coliform-negative. If the aircraft is returned to service, unrestricted 

access to the water system cannot be provided until a set of follow-up samples is total 

coliform-negative. 

	 If any of the follow-up samples are E. coli-positive, the air carrier must restrict public access 

within 24 hours after receiving the sample results and disinfect and flush the water system 

when able and collect follow-up samples. Restricted access must be maintained until a 

complete set of follow-up samples is coliform-negative. If the aircraft water system cannot be 

shut off or physically disconnected, or the flow of water otherwise prevented through the 

taps, then the corrective disinfection and flushing with follow-up sampling must be 

performed within 72 hours and restricted access must be maintained until a complete set of 

follow-up samples is coliform-negative. 

Guidance Manual 40 

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Exhibit 4.6 Total Coliform-Positive and E. coli-Negative Routine Samples: 

 Option 1: Disinfection and Flushing Details 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

Guidance Manual 41 

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Option 2: Restricting Public Access Within 72 Hours and Disinfecting and Flushing When Able 

If an air carrier chooses Option 2 in response to a routine total coliform-positive and E. colinegative sample result, they must restrict public access to the aircraft water system within 72 

hours after the laboratory notifies them of the positive test result, provide public notice 

appropriately (see Chapter 6), and disinfect and flush the water system on an alternative schedule 

(see Exhibit 4.7). Restricting public access enables the air carrier to delay the corrective 

disinfection and flushing procedure and follow-up sampling until the activity can be scheduled at 

a more convenient time. 

After disinfection and flushing and follow-up samples are collected, the aircraft water system can 

be unrestricted and water can be provided to passengers and crew. 

	 If all of the follow-up sample results are total coliform-negative, the system may return to 

routine coliform monitoring and continue serving water to the public. 

	 If either of the follow-up samples are total coliform-positive and E. coli-negative, the air 

carrier must restrict public access within 72 hours after receiving the sample results and 

disinfect and flush the water system again, with the process continuing until a complete set of 

follow-up samples is total coliform-negative. If the aircraft is returned to service, unrestricted 

access to the water system cannot be provided until a set of follow-up samples is total 

coliform-negative. 

	 If any of the follow-up samples are E. coli-positive, the air carrier must restrict public access 

within 24 hours after receiving the sample results and disinfect and flush the water system 

when able and collect follow-up samples. Restricted access must be maintained until a 

complete set of follow-up samples is coliform-negative. If the aircraft water system cannot be 

shut off or physically disconnected, or the flow of water otherwise prevented through the 

taps, then the corrective disinfection and flushing with follow-up sampling must be 

performed within 72 hours and restricted access must be maintained until a complete set of 

follow-up samples is coliform-negative. 

Guidance Manual 42 

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Exhibit 4.7 Total Coliform-Positive and E. coli-Negative Routine Samples: 

Option 2: Restricting Public Access 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

Guidance Manual 43 

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Option 3: Collecting Repeat Samples Within 24 Hours 

If an air carrier chooses Option 3 in response to a routine total coliform-positive and E. colinegative sample result, they must collect three repeat samples within 24 hours of learning of the 

result. One repeat sample must be collected from the same tap as the total coliform-positive 

routine sample, one sample must be collected from another galley tap, and the third sample must 

be collected from another lavatory tap, if these types of taps are available. If less than three taps 

are available, then the samples must be collected from the available taps within the aircraft water 

system. It may be necessary for more than one sample to be collected from the same tap. If 

samples cannot be collected within 24 hours, the air carrier must choose Option 1 or 2. 

Exhibit 4.8 provides an illustration of actions that are required based on the analytical results of 

the repeat samples. 

There are three possible analytical results and respective follow-up actions for repeat samples: 

	 If all of the repeat samples are total coliform-negative the aircraft returns to the routine 

monitoring frequency and need not restrict access to the water system or conduct corrective 

disinfection and flushing. 

	 If any of the three repeat samples indicate the presence of total coliforms but not the presence 

of E. coli, the air carrier can choose one of the following response options: 

o	 Conduct disinfecting and flushing of the aircraft water system within 72 hours of 

being notified of the positive result and collect follow-up samples. After the followup samples are collected, water from the aircraft water system may be provided for 

human consumption. 

 If all of the follow-up sample results are total coliform-negative, the system 

may return to routine coliform monitoring and continue serving water to the 

public. 

 If either of the follow-up samples are total coliform-positive, the air carrier 

must restrict public access within 72 hours and disinfect and flush the water 

system again, with the process continuing until a complete set of follow-up 

samples is total coliform-negative. If the aircraft is returned to service, 

unrestricted access to the water system cannot be provided until a set of 

follow-up samples is total coliform-negative. 

 If any of the follow-up samples are E. coli-positive, the air carrier must 

restrict public access within 24 hours and disinfect and flush the water 

system when able and collect follow-up samples. Restricted access must be 

maintained until a complete set of follow-up samples is coliform-negative. If 

the aircraft water system cannot be shut off or physically disconnected, or the 

flow of water otherwise prevented through the taps, then the corrective 

disinfection and flushing with follow-up sampling must be performed within 

72 hours and restricted access must be maintained until a complete set of 

follow-up samples is coliform-negative. 

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o	 Restrict public access to the aircraft water system within 72 hours after the 

laboratory notifies them of the positive test result, provide public notice 

appropriately, and disinfect and flush the water system on an alternative schedule. 

After the follow-up samples are collected, water from the aircraft water system may 

be provided for human consumption. 

 If all of the follow-up sample results are total coliform-negative, the system 

may return to routine coliform monitoring and continue serving water to the 

public. 

 If either of the follow-up samples are total coliform-positive, the air carrier 

must restrict public access within 72 hours and disinfect and flush the water 

system again, with the process continuing until a complete set of follow-up 

samples is total coliform-negative. If the aircraft is returned to service, 

unrestricted access to the water system cannot be provided until a set of 

follow-up samples is total coliform-negative. 

 If any of the follow-up samples are E. coli-positive, the air carrier must 

restrict public access within 24 hours and disinfect and flush the water 

system when able and collect follow-up samples. Restricted access must be 

maintained until a complete set of follow-up samples is coliform-negative. If 

the aircraft water system cannot be shut off or physically disconnected, or the 

flow of water otherwise prevented through the taps, then the corrective 

disinfection and flushing with follow-up sampling must be performed within 

72 hours and restricted access must be maintained until a complete set of 

follow-up samples is coliform-negative. 

	 If any of the repeat samples are E. coli-positive, the aircraft must meet the requirements for 

E. coli-positive routine or repeat samples described in Section 4.3.3. 

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Exhibit 4.8 Total Coliform-Positive and E. coli-Negative Routine Samples: 

Option 3: Repeat Sample Details 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

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4.3.3 E. coli-Positive Routine or Repeat Sample Result Options 

The presence of E. coli in a water sample indicates that the water may be contaminated with 

human or animal fecal waste. This is a serious situation and requires an immediate response 

(within 24 hours of notification of the sample result) by the air carrier. 

If E. coli is present in any routine or repeat sample, the air carrier must restrict public access to 

the water system, including providing public notice, within 24 hours of learning of the test 

result. The air carrier must then conduct corrective disinfection and flushing when able and 

collect follow-up samples. Restricted access must be maintained until a complete set of followup samples is coliform-negative [40 CFR 141.803(c)(2)]. 

If the aircraft water system cannot be shut off or physically 

disconnected, or the flow of water otherwise prevented 

through the taps, then the air carrier must provide public 

notice within 24 hours and conduct corrective 

disinfection and flushing no later than 72 hours after the 

laboratory notifies the air carrier of the E. coli-positive 

result and collect follow-up samples. Restricted access 

must be maintained until a complete set of follow-up 

samples is coliform-negative. 

Exhibit 4.9 presents the required actions based on E. coli

positive routine samples or E. coli-positive repeat samples 

that were collected in response to a total coliform-positive 

and E. coli-negative routine sample. Repeat sampling is not an option when any sample is E. 

coli-positive. 

­

Guidance Manual 47 

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If passengers or crew are able

to access the water, the air 

carrier must provide public 

notice to the passengers and

crew within 24 hours and 

disinfect and flush the 

aircraft water system no 

later than 72 hours after the 

laboratory notifies the air 

carrier of the E. coli-positive 

result and collect follow-up 

samples. 
 

 

Exhibit 4.9 E. coli-Positive Routine or Repeat Samples: Required Activities 

[TC(+) means total coliform-positive; TC(-) means total coliform-negative; 

EC(+) means E. coli-positive; EC(-) means E. coli-negative] 

*Includes preventing the flow of water through the taps. 

There are other violations or situations that require the corrective actions shown in Exhibit 4.9. 

Examples of other situations include: 

o	 Failing to collect follow-up samples after corrective disinfection and flushing that 

was triggered by an E. coli-positive routine or repeat sample; 

o	 Becoming aware of an E. coli-positive event that resulted from failing to board water 

from a safe watering point; and 

o	 Boarding water that is otherwise determined to be unsafe due to non-compliance with 

the procedures for boarding water that are included in the aircraft O&M plan. 

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4.4 Suggested Sampling Protocol 

The following is a suggested sampling protocol that could be used for the collection of routine, 

repeat, or follow-up samples. Critical steps in the sample collection procedure include ensuring 

the sample is representative of water provided to passengers and crew (including any 

supplemental treatment), the sample collection bottle does not become contaminated, and the 

faucet or fixture to be sampled will not contribute contamination from the external surface. 

4.4.1 Materials and Preparation for Sampling 

The laboratory that will perform the analyses should be contacted in advance of the planned 

sampling collection date. In advance, it should be determined if the laboratory will provide 

sample bottles, and if so, how many will be needed. Additionally, it should be determined 

whether the laboratory will provide a return shipping cooler and ice packs (shipment of ADWR 

samples on ice to obtain a shipping temperature of 10 degrees Celsius or less without freezing 

the sample is recommended). Sufficient time should be allowed to obtain materials and to agree 

on a sample submittal date. 

All materials should be on-hand and ready for use at least 48 hours prior to sampling. (Note that 

a separate cooler or holding container for each day/location of sample collection will be needed 

if samples are not hand-delivered to the laboratory each day.) The analysis of the samples by the 

laboratory must begin within 30 hours of sample collection or the sample will be invalid and a 

replacement sample will be required [40 CFR 141.803(a)(4)]. 

Below is a list of suggested materials needed for sampling. 

1) Sample collection sheet 

2) Laboratory chain of custody form 

3) Indelible pen 

4) Sample bottles (150-mL sterile plastic with non-toxic cap and dechlorinating agent) 

5) Cooler with ice packs (optional) (contained-ice packs are preferable to ice cubes) 

6) Rubber, latex, or non-latex exam gloves 

When collecting a sample, label the bottle (not the lid) prior to sample collection with the 

following information: 

 Sample ID correlating to the sample tap location (e.g., lav or gal and aft or fore) and other 

information listed on the laboratory chain of custody form and data sheet 

 Date and time of collection 

 Analyses requested (e.g., total coliform) 

 Sampler’s initials 

For each aircraft, total coliform samples must be collected from a galley tap and a lavatory tap 

unless there is only one tap. Both lavatory and galley samples should be collected from a cold 

water tap if possible. If the only sampling point in the lavatory or galley is a hot water tap or the 

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------------------------------------------------------------------------------------------------------------ 

 

coffee maker, collect the sample at that location and indicate the sampling location on the sample 

collection sheet [40 CFR 141.803(b)]. 

During sampling, exam gloves should be used when handling samples to minimize sample 

contamination and exposure to sample preservatives. Bottles should be kept closed until ready to 

be filled. 

4.4.2 Sample Collection 

The following steps are recommended for routine, repeat, and post-disinfection follow-up sample 

collection. The term “tap” in this procedure means water tap, faucet, drinking fountain, or other 

fixture which provides water for human consumption to passengers or crew. Do not sample from 

leaking taps or taps which allow water to run down the outside of the fixture. 

1) Put on gloves. 

2) Open tap and allow water to run for at least 30 seconds to flush tap. 

3) Reduce water flow so the stream is not greater than 1⁄4 inch in diameter, or the width of a 

pencil. Check for steady flow; do not change the water flow once the sample collection 

has begun, as this could dislodge microbial growth. 

4) Remove cap of total coliform sample bottle. 

5) Be careful not to contaminate the bottle by touching the interior of the cap or the inside of 

the sample container. Do not place cap on counter (which may be contaminated) or in 

your pocket to prevent container contamination. 

6)	 Place bottle under water stream allowing for an air gap between top of the bottle and the 

water tap. Hold the bottle in one hand and the cap in the other. Fill the bottle to the 100 

mL fill line. If the bottle becomes overfilled, do not pour out the sample (this may lead to 

sample contamination); instead send it to the laboratory as is. 

7) Do not rinse the bottle either before or after sample collection. 

8) Replace cap and tighten. Turn off water.
 

9) Ensure that sample ID matches that recorded on the sample collection sheet. 

10) Place bottles into Ziploc® or similar bag. Place bag in cooler or other transport container 

(packing the sample on ice (NOT dry ice) is recommended, but optional) 

11) Complete chain of custody sheet provided by laboratory. Ensure that sample ID matches 

that on the label and data sheet. If chain of custody sheet is not provided in duplicate, 

photocopy it for your records. 

12) Sign and date the following statement on the sample collection sheet. If there was any 

deviation from protocol, note this at the bottom of sample collection sheet. 

I certify that all samples were collected in accordance with the protocol entitled “Protocol for 

Sampling Drinking Water on Aircraft.” 

Signature Date 

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4.5 Certified Laboratories and Analytical Methods 

4.5.1 Certified Laboratories 

The ADWR specifies that samples will be considered valid only if they are analyzed by a 

laboratory certified by a state or by EPA [40 CFR 141.803(a)(6)]. 

EPA’s laboratory certification manual, Manual for the Certification of Laboratories Analyzing 

Drinking Water: Criteria and Procedures Quality Assurance, 5th Edition (EPA 815-R-05-004, 

January 2005) indicates that EPA’s Office of Ground Water and Drinking Water (OGWDW) 

will accept National Environmental Laboratory Accreditation Program (NELAP) accreditation as 

equivalent to Drinking Water certification. There are some international laboratories that are 

accredited by the NELAP program (See http://www.nelac-institute.org/accred-labs.php or 

http://www.nelac-institute.org/membership.php). 

The following link provides an explanation of the NELAP accreditation program: 

http://www.nelac-institute.org/accred-bodies.php 

4.5.2 Analytical Methods 

The ADWR requires that a certified laboratory be used for all coliform sample analyses, and also 

requires a maximum holding time between sample collection and analysis for coliform samples 

of 30 hours. 

EPA-approved analytical methodologies must be used for the analysis of total coliform bacteria 

and E. coli, as listed in 40 CFR 141.21(f)(3) and 141.21(f)(6) [40 CFR 141.803(a)(3)]. The 

current list of approved analytical methods for total coliforms and E. coli is also provided on 

EPA’s web site at http://www.epa.gov/safewater/methods/pdfs/methods/methods_tcr.pdf. 

Each sample need only be analyzed for the presence or absence of the organisms; enumeration of 

the bacteria present is not necessary. 

Discuss with the laboratory the test methods it is certified to perform and the anticipated 

timeframe for reporting results, as well as its procedure for reporting results. Because of the 

availability of overnight shipping, the preferred laboratory may not be the one closest to the 

sampling location. 

4.5.3 Sample Invalidation 

EPA recognizes that in rare circumstances a total coliform-positive or E. coli-positive sample 

result may not reflect the water quality in the aircraft water system. The ADWR references the 

sample invalidation provisions of the Total Coliform Rule (TCR) as found in 40 CFR 

141.21(c)(1)(i), (ii), and (iii) for invalidation by EPA, as the State, and in 40 CFR 141.21(c)(2) 

for invalidation by the certified laboratory. 

These provisions address three scenarios when EPA may invalidate a total coliform-positive 

sample. 

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The first scenario is if the laboratory establishes that improper sample analysis caused the total 

coliform-positive result. If it is a routine sample that is invalidated, then a replacement routine 

sample must be collected and analyzed before the end of the monitoring period in order to avoid 

a violation for failure to collect the required routine sample(s). If it is a repeat sample that is 

invalidated, then a replacement repeat sample must be collected within 24 hours of being notified 

of the invalidated repeat sample. This timeframe is consistent with the requirements for 

collecting repeat samples within 24 hours of notification under the ADWR. If it is a follow-up 

sample that is invalidated, then a replacement follow-up sample should be collected as soon as 

possible to ensure compliance. 

The second scenario, which is not readily applied to aircraft public water systems, allows EPA to 

determine that the total coliform-positive sample resulted from a domestic or other nondistribution system plumbing problem on the basis of the results of repeat samples. However, 

because all of the aircraft water system plumbing is the responsibility of the air carrier, from the 

storage tank filler neck to the tap, aircraft water systems do not have “domestic” or “other nondistribution system plumbing” that would justify the invalidation of a total coliform-positive 

sample. 

The third scenario allows EPA to invalidate a sample if EPA has substantial grounds to believe 

that a total coliform-positive result is due to a circumstance or condition which does not reflect 

water quality in the distribution system. In this scenario, the system must still collect all required 

repeat samples and use them to determine compliance. There is no replacement sample required 

since the system has collected all repeat samples that are required under the ADWR and 

compliance has been determined. To invalidate a total coliform-positive sample under this 

scenario, EPA must document the decision and its rationale in writing and make the decision 

available to the public. The written documentation must state the specific cause of the total 

coliform-positive sample and what action the system has taken, or will take, to correct this 

problem. EPA may not invalidate a total coliform-positive sample solely on the grounds that all 

repeat samples are total coliform-negative. 

Under the only laboratory-invalidation scenario, a laboratory must invalidate a total coliform 

sample (unless total coliforms are detected) if the sample produces a turbid culture in the absence 

of gas production using an analytical method where gas formation is examined (e.g., the 

Multiple-Tube Fermentation Technique), produces a turbid culture in the absence of an acid 

reaction in the Presence-Absence (P–A) Coliform Test, or exhibits confluent growth or produces 

colonies too numerous to count with an analytical method using a membrane filter (e.g., 

Membrane Filter Technique). If a laboratory invalidates a sample because of such interference 

the system must collect another sample from the same location as the original sample within 24 

hours of being notified of the interference problem and have it analyzed for the presence of total 

coliforms. The system must continue to re-sample within 24 hours and have the samples 

analyzed until it obtains a valid result. EPA may waive the 24-hour time limit on a case-by-case 

basis. 

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4.6 Reporting Sample Results 

The reporting requirements for sample results become effective October 19, 2011. As the 

primacy agency, EPA will oversee reporting by air carriers. To facilitate collection and analysis 

of aircraft water system data, EPA has developed the ADWR Reporting and Compliance System 

(ARCS), an Internet-based electronic database. Analytical results for microbiological testing will 

be reported directly to this database. ARCS will perform logic checks on data entered and 

calculate final results for accountability and regulatory oversight. This is intended to reduce 

reporting errors and limit the time involved in investigating, checking, and correcting errors at all 

levels. ARCS has a companion User Guide that provides information pertinent to users of the 

system. The user guide includes a description of the spreadsheet format and reporting method, 

how to access the downloadable spreadsheet and Web user interface, and other key information. 

Air carriers should instruct laboratories to either manually enter analytical results into the EPAmanaged Web-based data system, or to electronically upload data files from their laboratory 

information management systems (LIMS) to a Web-based data file submission program. 

Regardless of the method or personnel used to report the data, these data files must be in a 

format prescribed by EPA. If an air carrier determines that its laboratory does not have the 

capability to report data electronically, it can submit a request to EPA to use an alternate 

reporting format. Air carriers may determine the best method of data upload and reporting that 

meets their needs. The ADWR does not require laboratory reporting nor prohibit consultants or 

other agents from gathering and reporting results on the carrier’s behalf. If it is believed that a 

result was entered into the data system erroneously, the air carrier has the responsibility to notify 

the laboratory or responsible party to rectify the entry. 

All routine sample results that are total coliform-negative must be reported to EPA no later than 

10 calendar days following the end of the monitoring period in which the sampling occurred [40 

CFR 141.806(b)(3)]. Remember that the length of the monitoring period depends on the routine 

coliform sampling frequency; therefore, air carriers may need to report the results monthly, 

quarterly, semiannually, or annually. 

All routine, repeat, or follow-up sample results that are total coliform-positive or E. coli-positive 

must be reported to EPA no later than 10 calendar days after receiving the sample results. 

Refer to Chapter 7 for more details on the requirements for reporting sampling results. 

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5. Operations and Maintenance Plans 

5.1 Overview of Requirements and Timeframes 

Developing and implementing operations and maintenance (O&M) plans that cover every 

aircraft public water system is crucial to tailoring the National Primary Drinking Water 

Regulations to the unique needs of aircraft. This chapter discusses each of the ADWR 

requirements for O&M plans and includes example O&M practices used by some air carriers. 

These practices may not be applicable to all types of aircraft or all configurations of aircraft 

water systems. 

For each aircraft listed in an air carrier’s inventory, an aircraft water system O&M plan must be 

developed and its completion reported to EPA by April 19, 2011 [40 CFR 141.806(a)(1)]. A 

separate plan need not be developed for each aircraft – more than one aircraft may be covered by 

the same plan. However, each aircraft water system must be covered by an O&M plan. New 

aircraft added to the inventory after April 19, 2011, must be either added to an existing plan or a 

new plan developed and reported to EPA by the end of the first calendar quarter during which 

the aircraft is placed into operation as a public water system. Air carriers need not submit the 

O&M plans to EPA but EPA can request a copy of the plan at any time and may also view the 

plan during compliance audits. The ADWR requires air carriers to include the O&M plans in 

their FAA-accepted O&M programs [40 CFR 141.804(a)]. Also, any changes to the aircraft 

water system O&M plan must be included in the FAA-accepted air carrier O&M program. 

In order to ensure that the appropriate multiple barriers to contamination are in place, each 

aircraft water system O&M plan must include the components described below [40 CFR 

141.804(b)]. 

5.2 Watering Point Selection Requirement 

The O&M plan must specify that all watering points must be selected in accordance with FDA 

regulations [21 CFR part 1240, subpart E]. The FDA regulations, in part, state, “Only potable 

water shall be provided for drinking and culinary purposes by any operator of a conveyance 

engaged in interstate traffic... Such water shall either have been obtained from watering points 

approved by the Commissioner of Food and Drugs, or, if treated aboard a conveyance, shall have 

been subjected to treatment approved by the Commissioner of Food and Drugs.” 

An official classification list of watering points that are in accordance with FDA regulations is 

anticipated to be available through the FDA website in late 2010. FDA’s list of aircraft watering 

points and service areas is a complete list of known watering points and service areas on the day 

of its posting. The list is derived from FDA’s Official Establishment Inventory (OEI) and 

supplemented by verifiable information from airline companies, airport authorities, and 

cooperating state health authorities with jurisdiction at US airports. The listing is scheduled to be 

updated quarterly. If a watering point is not listed or has not been approved, the FDA may permit 

its temporary use under such conditions as, in FDA’s judgment, are necessary to prevent the 

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introduction, transmission, or spread of communicable disease [21 CFR 1240.83(c)]. The 

Internet website will provide FDA District Office contact information so that users of the 

watering point and service area can communicate directly with FDA to add, remove, or obtain 

permission for temporary use of a specific watering point and service area during a quarterly 

update period. 

EPA and its federal partner FDA stress the importance of effective communication between all 

of the responsible parties along the aircraft water supply and transfer chain including public 

water systems serving airports, airport authorities, air carriers, and regulatory authorities (i.e., 

state drinking water primacy agencies, FDA, and EPA). 

5.3 Routine and Corrective Disinfection and Flushing 

The O&M plan must include specific information on the procedures and frequency of routine 

disinfection and flushing for aircraft water systems. The procedures and frequency must be in 

accordance with the manufacturer’s recommendations [40 CFR 141.804(b)(2)]. EPA specifically 

designed the rule to allow air carriers to be consistent with the manufacturer recommendations 

for disinfecting and flushing aircraft water systems, instead of prescribing the frequency and the 

chemical type and concentration to be used. By allowing air carriers to be consistent with the 

manufacturer recommendations for disinfection and flushing, the rule requirements will 

automatically evolve with technological improvements in aircraft water tank lining and piping 

materials, and as more effective disinfectants are developed. 

EPA understands that some manufacturers do not provide equipment disinfection and flushing 

recommendations and others specify that it be performed as required by the applicable regulating 

authority. Where a recommended routine disinfection and flushing frequency is not provided by 

the aircraft water system manufacturer, the air carrier must choose a disinfection and flushing 

frequency and corresponding routine coliform sampling frequency from the four options 

identified in the ADWR (see Section 4.2.3). In addition, air carriers may conduct disinfection 

and flushing more frequently, but not less frequently, than the manufacturer recommends. 

However, it is the responsibility of the air carrier to ensure the selected frequency would not 

result in damage to the aircraft water system’s components. 

The ADWR requires that the O&M plan identify the following details of disinfection and 

flushing practices [40 CFR 141.804(b)(2)]: 

	 Routine disinfection and flushing frequency (i.e., quarterly; at least three times per year; 

semi-annually; annually). 

	 Type of disinfecting agent – chemical used as the disinfectant (e.g., chlorine dioxide, 

chlorine, ozone, etc.). 

	 Disinfectant concentration – concentration of the disinfecting agent or the diluted 

disinfectant solution that is applied to the aircraft water system (e.g., milligrams per Liter 

(mg/L), parts per million (ppm)). 

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	 Disinfectant contact time – amount of time the disinfecting agent or solution is in contact 

with aircraft water system components (e.g., 20 minutes, 1 hour, etc.). 

	 The flushing volume or flushing time – volume of potable water or length of time 

required to flush the disinfecting agent out of the aircraft water system (e.g., replace one 

tank volume, 5 minutes, etc.). 

Corrective disinfection and flushing is triggered by the following situations: 

	 Total coliform-positive routine sample(s) if the corrective disinfection and flushing 

option is selected. 

	 Any repeat samples are total coliform-positive. 

	 E. coli is detected in any routine, repeat, or follow-up sample. 

	 An air carrier fails to conduct routine or corrective disinfection and flushing. 

	 An air carrier fails to collect routine, repeat, or follow-up coliform samples as required 

(see Chapter 4 for coliform monitoring requirements). 

	 An air carrier boards water from a watering point that is not in accordance with FDA 

regulations, that does not meet EPA drinking water standards for transient noncommunity water systems, or that may be unsafe due to noncompliance with the boarding 

procedures in the aircraft water system O&M plan. 

The time frame in which air carriers must conduct corrective disinfection and flushing depends 

on which situation or event triggered the corrective action. See Chapter 8 for more information. 

Chemicals used in the aircraft water system must meet all applicable laws and regulations and 

should be certified as meeting the standards of NSF/American National Standards Institute 

(ANSI) 60 or an equivalent standard. This ensures the chemical has been tested and found 

acceptable for use in public water supplies. 

Examples of disinfection and flushing procedures. 

Several air carriers submitted their aircraft water system disinfection and flushing procedures to 

EPA. Those procedures were found to have relatively common steps and recommendations. The 

following is a list of items that air carriers should consider to ensure disinfection and flushing 

procedures are effective. They are not intended to replace manufacturer’s recommendations. 

	 Open all taps and completely drain the water system. 

	 Remove filters and replace filter caps to provide water-tight seal. 

	 Make up disinfectant solution following manufacturer’s instructions. 

	 Fill water system tank with disinfectant solution and/or add water until full (full when 

water drains out of tank overflow). 

	 Ensure disinfected water flows from galley and lavatory taps and drinking fountains until 

proper disinfectant concentration is measured at all taps or the disinfectant is observed to 

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flow from the taps. Various procedures have been suggested to accomplish this task. For 

example: 

o	 Flush galley and lavatory taps until disinfecting solution flows from the tap. 

o	 Flush toilets in vacuum waste systems 2 to 5 times with a 15 second interval between 

flushes. 

o	 Flush galley and lavatory taps for 3 minutes. 

o	 Flush galley taps enough to run 5 liters of solution through the tap. 

o	 Flush cold water tap in lavatory enough to fill sink, drain the sink, then flush hot 

water tap enough to fill sink. 

	 Top off water system tank with disinfectant solution. 

	 Hold disinfectant solution in water system for predetermined contact time in accordance 

with manufacturer’s recommendations. 

	 Completely drain water system. 

	 Flush the water system with potable water by allowing the water to flow from each tap 

until disinfectant is no longer observed or otherwise detected. 

	 To ensure disinfectant has been flushed out of the water system, completely drain the 

water system after it has been flushed and refill again with potable water. 

	 Install new filters (installation may be prior to collection of follow-up samples to ensure 

the filters do not degrade water quality). 

	 Remove and clean tap aerators. 

	 Adhere to procedures and considerations for electronic controls, system pressurization 

limits, and tag and safety circuit breakers. 

	 If the aircraft will be parked for more than three days, drain the water system. When it is 

returned to service, perform the disinfection and flushing procedure and then fill the 

water system with potable water. 

	 If the aircraft will be stored (i.e., taken out of service), conduct the following prior to 

storage: drain the water system, perform the disinfection and flushing procedure, and then 

drain the water system again so that there is no water in the system while the aircraft is 

stored. Before the aircraft is returned to service, conduct the following: perform the 

disinfection and flushing procedure, replace charcoal filters if installed, and fill with 

potable water. 

5.4 Follow-up Sampling 

The O&M plan must include written procedures for conducting follow-up coliform sampling 

after a corrective disinfection and flushing event takes place. Follow-up samples indicate 

whether the disinfection and flushing event was successful. See Section 4.3 for corrective actions 

based on sample results that require follow-up sampling and could be incorporated into an O&M 

plan, and Section 4.4 for recommended sampling procedures. 

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5.5 Training of Personnel 

Training is required for air carrier staff and contractors responsible for operating and maintaining 

the aircraft water system [40 CFR 141.804(b)(4)]. This includes staff that board water, conduct 

sampling and disinfection and flushing, or perform self-inspections. Training may be tailored to 

individual job descriptions so that it is specific to the tasks the employees are charged with 

performing. For example, a person charged exclusively with boarding water will not have to be 

trained in the techniques for collecting and transporting 

coliform water samples if they will not be performing 

that duty. 

The purpose of the training is to ensure that personnel 

participating in the performance or oversight of the 

aircraft water system are knowledgeable of the rule as it 

pertains to their job responsibilities. This includes 

implications of contaminated water on the health of the 

public served by the aircraft water system, effective 

operations and maintenance procedures for the system, 

the monitoring requirements of the ADWR, how 

compliance with the ADWR will be reported to EPA 

and tracked by EPA, and the air carrier-specific aspects 

of the rule such as the public notification requirements 

and aircraft water system shut-off procedures, if 

applicable. 

The rule requires that, at a minimum, personnel are 

trained on the procedures for boarding water, collecting 

samples, disinfecting and flushing the water system, and 

the public health and safety reasons for the requirements 

of the ADWR. 

The O&M plan must describe training requirements for all personnel involved with the O&M 

provisions of the ADWR. At a minimum, persons performing the activity and the supervisor of 

the person performing the activity should be included in the training. Based on input from the air 

carrier industry, EPA understands that many air carriers will integrate training requirements 

under the ADWR with the existing FAA regulated procedures and practices for aircraft operation 

and maintenance and carrier ground handling practices. For example, water system selfinspection training may be conducted in a manner consistent with existing FAA practices for 

inspection of an aircraft. Accordingly, the format and delivery method of the training is at the 

discretion of the air carrier so that carriers may customize their training programs in a manner 

appropriate to the carrier’s operations, using a variety of training procedures to satisfy the 

requirements of the rule. In view of this situation, EPA has not developed a one-size fits all 

training plan. 

Training should emphasize the use of sanitary practices in operating and maintaining the water 

system in order to maintain water quality and to protect public health. It should also address 

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What if individuals that board 

water or collect coliform 

samples are not air carrier 

personnel? 

Air carrier personnel might not 

perform all of the duties of 

boarding water or sampling for 

coliform - these services are 

often provided by contracted 

entities. 

Even if air carrier personnel do 

not perform the essential duties 

in the O&M plan, the air carrier 

is responsible for ensuring the 

entity providing the services is 

adequately trained on proper 

procedures. The air carrier need 

not provide the training, but 

must ensure adequately trained 

personnel are used. 
 

 

reporting and recordkeeping requirements and procedures to ensure the air carrier remains in 

compliance with the ADWR. 

The aircraft water system O&M plan must include the air carrier’s program for training 

personnel responsible for water system O&M activities. The O&M plan can also serve as a 

training reference for personnel through inclusion of recommended operating procedures and 

guidance for making operational decisions. An up-to-date plan should always be accessible to 

operations staff. 

The following training elements and topics are offered by EPA as an ADWR training program 

approach solely to assist air carriers. Carriers may develop their own programs as they deem 

appropriate based on the nature of their individual operations so long as they are consistent with, 

and ensure compliance with, the rule. 

The O&M plan should describe the following elements of the training program: 

 Training topics and typical training schedule, including the frequency and duration of the 

training for each pertinent personnel category. 

 Training program for new staff. 

 Refresher training for existing staff should be on an annual basis or more frequently as 

needed. 

Training topics for aircraft water system personnel should include the following elements. 

Elements that are mandatory are noted. 

 The public health and safety reasons for the ADWR requirements (mandatory). 

 ADWR requirement details applicable to their duties. 

 Acute contaminants, contaminant pathways, and control measures. 

 Procedures for boarding water (mandatory). 

 Sample collection procedures for coliform bacteria analysis and transport of samples to 

the laboratory (mandatory). 

 Routine and corrective disinfection and flushing practices (mandatory). 

 Procedures pertaining to aircraft water systems when aircraft are taken out-of-service and 

returned to service (e.g., draining, disinfection, flushing). 

 Procedures for performing self-inspections. 

 Backflow prevention and cross connection control. 

 Water treatment equipment maintenance and replacement requirements. 

 Reporting and recordkeeping requirements. 

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5.6 Procedures for Conducting Self-Inspections 

The O&M plan must describe how self-inspections of the aircraft water system will be 

conducted, including but not limited to inspection of the storage tank, piping, supplemental 

treatment units, plumbing fixtures, valves, and backflow prevention devices [40 CFR 

141.804(b)(5)]. 

The purpose of the self-inspection is to make sure the aircraft water system is intact and not 

compromised or subject to contamination. A thorough inspection is needed to determine: 

	 The ability of the water system to provide a safe and adequate supply of drinking water to 

the passengers and crew; 

	 The potential for degradation of the water quality or sanitary risks; and 

	 The system’s reliability and vulnerability. 

A complete self-inspection of the entire aircraft water system must be conducted no less 

frequently than once every five years [40 CFR 141.808(b)]. The first inspection must be 

completed by October 19, 2016, for aircraft that are included in the inventory as of October 19, 

2011. EPA has provided flexibility in the rule so that a full self-inspection of an aircraft water 

system may be conducted over time rather than all at once so long as a complete self-inspection 

of the entire aircraft water system occurs no less frequently than once every five years. This 

allows air carriers to develop their own unique self-inspection procedures that coordinate, to the 

maximum extent possible, water system self-inspections with the existing aircraft inspection and 

maintenance process. An air carrier’s self-inspection plan may include references to and 

explanations of those existing procedures. 

In recognition that each air carrier’s self-inspection procedures are likely to be unique since they 

will be based on each air carrier’s unique FAA-accepted operation and maintenance program, 

EPA has not developed a “one-size fits all” set of self-inspection procedures for this guidance 

manual. Instead, EPA offers the following general guidance for consideration by air carriers in 

the development of self-inspection procedures. 

The self-inspection procedures are intended to provide the degree of scrutiny necessary to 

identify potential public health risks and reliability issues associated with the aircraft water 

system. Generally, a self-inspection of the aircraft water system includes a visual inspection of 

the storage tank, distribution system, supplemental treatment, fixtures, valves, backflow 

prevention devices and fittings to detect cracks, leaks, corrosion, or damage, and to ensure that 

the distribution system piping is correctly attached with no cross-connections. A visual 

inspection is a visual examination of an interior or exterior area, installation, or assembly to 

detect obvious damage, failure, or irregularity. This level of inspection is made from within 

touching distance, unless otherwise specified by the manufacturer or determined to be necessary. 

For example, an air carrier may identify the need to perform an internal optical inspection of an 

aircraft’s water tanks and piping if there are chronic water quality problems (taste, odor, and/or 

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positive sample results) that are not corrected by disinfection and flushing or if water flow has 

slowed. Also, a mirror may be necessary to enhance visual access to all exposed surfaces in the 

inspection area. This level of inspection is made under normally available lighting conditions 

such as daylight, hangar lighting, flashlight or drop-light and may require removal or opening of 

access panels or doors. Stands, ladders, or platforms may be required to gain proximity to the 

area being checked. 

Specific reporting and recordkeeping requirements apply to aircraft self-inspections. These 

requirements are discussed in Chapter 7. 

5.7 Procedures for Boarding Water 

The operations and maintenance plan must include requirements and procedures for boarding 

water as discussed below. 

5.7.1 Boarding Water within the United States 

Within the United States, the air carrier must board water from watering points in accordance 

with Food and Drug Administration (FDA) regulations [21 CFR part 1240, subpart E]. It is 

advisable to periodically check FDA’s website (www.fda.gov) for updated information and 

guidelines. For example, at a future date, FDA is planning to have a list of watering points and 

service areas that are in accordance with FDA regulations on its website. 

FDA regulatory requirements are found in FDA regulations at 21 CFR part 1240, subpart E – 

Source and Use of Potable Water and 21 CFR part 1250, subpart D – Servicing Areas for Land 

and Air Conveyances. Published FDA guidance is found in the Guide to Inspection of 

Conveyances and Support Facilities, April 1995. 

http://www.fda.gov/ICECI/Inspections/InspectionGuides/ucm074964.htm. FDA Form 2528 

Inspection Summary – Airline Service Area or Watering Point Sanitation further informs airlines 

on FDA criteria for determining compliance with FDA regulations. 

5.7.2 Transferring Water Safely for Human Consumption 

Water is transferred to aircraft at the airport’s watering points using either water cabinets 

mounted on the airport terminal building or a mobile water cart or truck. The design, operation, 

and maintenance of watering point facilities are regulated by the FDA [21 CFR 1240 and 21 

CFR 1250]. Accordingly, EPA defers to the FDA with respect to regulating watering points such 

as water cabinets, carts, trucks, and hoses from which aircraft board water. However, because 

aircraft board water via these temporary interconnections, the process of boarding water presents 

numerous opportunities for contamination of the drinking water. Therefore, the ADWR requires 

that air carriers have in their water system operations and maintenance plans procedures for 

boarding water [40 CFR 141.804(b)(6)] that include a description of how the water will be 

transferred from the watering point to the aircraft in a manner that ensures it will not become 

contaminated during the transfer. 

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5.7.3 Ensuring Water Boarded Outside of the US is Safe for 

Human Consumption 

EPA understands that aircraft involved in international travel may board water from watering 

points at locations that are outside EPA and FDA’s jurisdiction. Therefore, it is essential that air 

carriers have procedures in place to ensure that the water obtained from these sources is of a 

quality that is safe for consumption by passengers and crew. Accordingly, the ADWR requires 

that air carriers include in their aircraft water system operations and maintenance plans a 

description of how the air carrier will ensure that water boarded outside of the United States is 

safe for human consumption [40 CFR 141.804(b)(6)(iii)]. This procedural requirement is 

squarely within EPA's authority under SDWA to ensure that water that is boarded outside of the 

US and then served to consumers in the US is safe. Consequently, if an aircraft boards water not 

in accordance with its water system operation and maintenance plan procedures for boarding 

water outside of the US [40 CFR 141.804(b)(6)(iii)], the ADWR, under 40 CFR 141.803(h)(3) 

and (i)(3), requires an air carrier to perform the appropriate corrective actions on the aircraft (see 

Exhibits 5.1 and 5.2). 

5.7.4 Emergency Procedures for Failure to Board Water from a 

Safe Watering Point 

The Agency is aware that in limited circumstances water is boarded to operate essential systems 

such as toilets, but the watering point is not in accordance with FDA regulations or the water 

does not meet the NPDWRs. To address these circumstances, the ADWR requires that the O&M 

plan include emergency procedures to be used in the event that water is boarded to operate 

essential systems, such as toilets, but was boarded from a watering point not in accordance with 

FDA regulations, does not meet NPDWRs applicable to transient non-community water systems 

(found in 40 CFR 141.62 and 141.63, as applied to TNCWSs), or is otherwise determined to be 

unsafe due to non-compliance with the procedures specified in 40 CFR 141.804(b)(6). When 

situations such as these occur, the quality of the water that is boarded will determine the 

corrective action and public notification requirements. If the quality of the water to be boarded 

does not meet the NPDWRs for transient non-community water systems (i.e., total coliform; E. 

coli; nitrate; nitrite; or chlorine dioxide if the PWS serving the watering point (parent system) 

uses chlorine dioxide as a disinfectant or oxidant) but the situation is not related to an E. colipositive sample result, then the air carrier must follow the requirements under 40 CFR 141.803(i) 

Failure to Board Water from a Safe Watering Point (non-E. coli-positive). Similarly, when water 

must be boarded from a watering point that is not in accordance with FDA regulations but the 

situation is not known to be related to an E. coli-positive sample result, then the air carrier must 

also follow the requirements under 40 CFR 141.803(i) Failure to Board Water from a Safe 

Watering Point (non-E. coli-positive). 

If the water that must be boarded is known to have tested positive for E. coli, then the air carrier 

must follow the requirements under 40 CFR 141.803(h) Failure to Board Water from a Safe 

Watering Point (E. coli-positive). 

It may be necessary for an air carrier to have different emergency response plans for different 

types of aircraft, for example, if some aircraft have a separate water system for toilets. Example 

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response plans for an E. coli-positive event and non-E. coli-positive event are provided as 

Exhibits 5.1 and 5.2, respectively. 

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Exhibit 5.1 Example Response Plan for Failure to Board Water from a Safe 

Watering Point (E. coli-positive event) 

Response Plan: Failure to Board Water from a Safe Watering Point 

[E. coli-positive event] 

Step Action Timeframe Responsible Party 

1 

Restrict public access, including all of the 

following: 

Shut off water or otherwise prevent flow to 

taps, faucets, and fixtures, if possible. 

Develop and deliver public notice for crew 

(and post for passengers if water shut off or 

flow prevention to taps is not possible). 

Provide alternatives to water from the aircraft 

water system such as bottled water for 

drinking and coffee or beverage preparation; 

provide antiseptic hand gels or wipes. 

As expeditiously as 

possible, but no later 

than 24 hours of 

learning of the event. 

2 Schedule and perform corrective disinfection 

and flushing of the aircraft water system. 

As expeditiously as 

possible, but no later 

than 72 hours of 

learning of the event if 

the water system is not 

shut off or the flow 

prevented. 

When able, if water shut 

off or flow prevented. 

3 Collect two follow-up samples. 

Immediately after 

corrective disinfection 

and flushing. 

4 

If any follow-up samples are total coliformpositive or E. coli-positive, then repeat 

disinfection and flushing with follow-up 

sampling. 

As expeditiously as 

possible, but no later 

than 72 hours of 

learning of the sample 

results if the water 

system is not shut off or 

the flow prevented. 

When able, if water shut 

off or flow prevented. 

5 Unrestrict public access to the water. 

Only after a complete 

set of follow-up samples 

is total coliformnegative. 

6 

Report event to the EPA ADWR Reporting 

and Compliance System. 

Within 10 days of 

learning of the event. 

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Exhibit 5.2 Example Response Plan for Failure to Board Water from a Safe 

Watering Point (non-E. coli-positive event) 

Response Plan: Failure to Board Water from a Safe Watering Point 

[non-E. coli-positive event] 

Step Action Timeframe Responsible Party 

1 

Restrict public access, including all of the 

following: 

Shut off water or otherwise prevent flow to 

taps, faucets, and fixtures, if possible. 

Develop and deliver public notice for crew 

(and post for passengers if water shut off or 

flow prevention to taps is not possible). 

Provide alternatives to water from the aircraft 

water system such as bottled water for 

drinking and coffee or beverage preparation; 

provide antiseptic hand gels or wipes. 

As expeditiously as 

possible, but no later 

than 72 hours of 

learning of the event. 

2 Schedule and perform corrective disinfection 

and flushing of the aircraft water system. When able 

3 Collect two follow-up samples. 

Immediately after 

corrective disinfection 

and flushing and prior to 

allowing public access 

to the water. 

4 Optional: unrestrict public access to the 

water. 

Once follow-up samples 

are collected. 

5a 

If either of the two follow-up samples is total 

coliform-positive and E. coli-negative, then 

restrict public access and repeat the 

disinfection and flushing procedures with 

follow-up sampling. 

Restrict public access 

as expeditiously as 

possible, but no later 

than 72 hours of 

learning of the sample 

results. 

Disinfect and flush when 

able. 

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Response Plan: Failure to Board Water from a Safe Watering Point 

[non-E. coli-positive event] 

Step Action Timeframe Responsible Party 

5b 

If either of the two follow-up samples is total 

coliform-positive and E. coli-positive, then 

restrict public access and repeat the 

disinfection and flushing procedures with 

follow-up sampling. 

Restrict access as 

expeditiously as 

possible, but no later 

than 24 hours of 

learning of the sample 

results. 

If water system not shut 

off or the flow prevented 

disinfect and flush within 

72 hours. 

If water shut off or flow 

prevented, disinfect and 

flush when able. 

6 Unrestrict public access. 

Only after a complete 

set of follow-up samples 

is total coliformnegative. 

7 Report event to the EPA ADWR Reporting 

and Compliance System. 

Within 10 days of 

learning of the event. 

5.8 Coliform Sampling Plan 

The O&M plan must include the monitoring plan for coliform bacteria. The coliform sampling 

plan is described in Chapter 4. Plan elements include but are not limited to: 

 Coliform sample collection procedures 

 Sample tap locations representative of the aircraft water system 

 Frequency of coliform sampling and number of samples to be collected during each 

sampling event 

 Frequency of routine disinfection and flushing 

 Procedures for communicating sample results 

5.9 Aircraft Water Systems Disconnect/Shut-off/Flow 

Prevention Statement 

The O&M plan must include an explanation of whether the aircraft water system can be 

physically disconnected/shut-off or the flow of water through taps prevented. The O&M plan 

could include procedures for disconnecting/shutting off the water so personnel have a reference 

in the event restricting public access to the water becomes necessary. 

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6. Public Notification 

Due to the unique characteristics of aircraft water systems, the ADWR includes separate 

provisions for air carriers regarding public notification from those required of stationary water 

systems under Subpart Q of the NPDWRs. This chapter summarizes the public notification 

requirements for specific violations and situations under the ADWR. Some of the public 

notification requirements are the same for certain violations and/or situations; therefore, there is 

repetitive text in this chapter. 

6.1 Purpose of Public Notification 

Public notification requirements of the NPDWRs are intended to alert consumers to potential 

health risks from violations of the drinking water standards or other situations that may present a 

health risk. Public notification requirements for stationary systems are divided into three tiers to 

take into account the seriousness of the violation or situation and any potential adverse health 

effects that may be involved. Public notices related to acute health risks are categorized as tier 1, 

and typically must be provided within 24 hours of identification of the violation. Because many 

of the violations or situations encountered by aircraft water systems pose potential acute health 

risks (e.g., an E. coli-positive sample result), notification should be provided as soon as possible, 

but is required within 24 hours. All other violations or situations require notification within 72 

hours. Timeframes for issuing notice for specific violations and situations are discussed in 

subsequent sections in this chapter. 

Passengers and crew served by an aircraft water system have a right to be informed of problems 

with the drinking water. The right to know about drinking water problems extends not just to 

contamination but also to failure to perform required monitoring or maintenance. For example, 

when an air carrier fails to monitor, the quality of the water is unknown. If the carrier does not 

conduct routine disinfection and flushing, it cannot be sure the water system is adequately 

maintained. 

Due to the transient nature of the public served by transient non-community water systems 

(TNCWSs) such as aircraft, public notice is provided by posting the notice at locations where 

passengers may access drinking water from the water system. Notification may be given to crew 

through written or verbal means in certain situations. 

When a violation or situation arises that requires public notice, the notice can be provided only to 

the crew if passenger access to the water system is physically prevented through disconnecting or 

shutting off the water, or the flow of water prevented through the tap(s), or if water is supplied 

only to lavatory toilets and not to any lavatory or galley taps. If the passengers can access the 

water system, then public notice must be provided to them to warn them not to use the water 

even for hand washing or brushing teeth. 

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In all situations that require public notice, the ADWR requires that the crew receives notice to 

ensure that the crew understands and can explain why there is no water available or why the 

water, if accessible, should not be used for human consumption. 

6.2 Notification of Passengers and Crew 

Air carriers must issue public notice to crew for all events described below [40 CFR 141.805]. 

Notice to passengers may not be required in some cases. 

1) When public access to the water is restricted due to a routine, repeat or follow-up total 

coliform-positive or E. coli-positive sample result [40 CFR 141.805(a)(1)]. 

2) Failure to perform routine disinfection and flushing or failure to collect required routine 

samples for coliforms [40 CFR 141.805(a)(2)]. 

3) Failure to collect the required follow-up samples in response to a sample result that is E. colipositive [40 CFR 141.805(a)(3)]. 

4) Failure to collect the required repeat or follow-up samples in response to a sample result that 

is total coliform-positive and E. coli-negative [40 CFR 141.805(a)(4)]. 

5)	 When the air carrier becomes aware of an E. coli-positive event resulting from water that has 

been boarded from a watering point that is not in accordance with FDA regulations, that does 

not meet EPA standards for TNCWSs, or has been determined to be unsafe due to 

noncompliance with the procedures for boarding water [40 CFR 141.805(a)(5)]. 

6)	 When the air carrier becomes aware of a non-E. coli-positive event resulting from water that 

has been boarded from a watering point that is not in accordance with FDA regulations, that 

does not meet EPA standards for TNCWSs, or has been determined to be unsafe due to 

noncompliance with the procedures for boarding water [40 CFR 141.805(a)(6)]. 

7) EPA, the air carrier, or the crew otherwise determine that public notification is necessary to 

protect public health [40 CFR 141.805(a)(7)]. 

The specific notice requirements for each violation or situation are discussed further in the 

following sections. In most cases, the ADWR specifies health effects language that must be 

included in the notice to the crew. Standardized language ensures that the crew (and, indirectly, 

the passengers via the crew) receives a consistent message. Some of the standard language 

paragraphs contain bracketed sections. The brackets indicate where the necessary information 

specific to each event should be inserted, or where an applicable phrase could be selected. If the 

bracketed phrases request information, such as dates or number of samples, the required 

information should be inserted and then the brackets deleted. 

Each public notice [40 CFR 141.805(b)]: 

	 Must be displayed in a conspicuous way when printed or posted; 

	 Must not contain overly technical language or very small print; 

	 Must not be formatted in a way that defeats the purpose of the notice; 

	 Must not contain language that nullifies the purpose of the notice; and 

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	 Must contain information in the appropriate language(s) regarding the importance of the 

notice reflecting a good faith effort to reach the non-English speaking population served, 

including where applicable, an easily recognized symbol for non-potable water. 

All events requiring notification to passengers and/or crew must also be reported to EPA within 

10 days of the event triggering the notification, such as the air carrier being informed of sample 

results by the laboratory. This reporting must include an indication of whether the required 

notification was provided to passengers or crew or both [40 CFR 141.806(b)(4)]. The ADWR 

does not require that a copy of a notification be provided to EPA. However, a copy must be 

available for EPA review as part of an audit. Paper or electronic copies of notices must be kept 

for at least three years after issuance [40 CFR 141.807(f)]. See Chapter 7 for more information 

on recordkeeping and reporting requirements. 

The four main events that trigger notice are described in detail in the remainder of this chapter. 

Appendix D of this manual contains example templates for notifying passengers and/or crew of 

violations or situations that require public notification under the ADWR. 

6.2.1 Notice for Detection of E. coli or Total Coliform Bacteria 

Public notification is required when public access to the aircraft water system is restricted in 

response to a total coliform-positive sample or an E. coli-positive sample [40 CFR 

141.805(a)(1)]. Air carriers must issue notice within 72 hours of receiving sample results that are 

total coliform-positive and E. coli-negative [40 CFR 141.803(c)(3)(ii)] and within 24 hours of 

receiving sample results that are E. coli-positive [40 CFR 141.803(c)(2)(i)]. For a total coliformpositive routine or repeat sample that is E. coli-negative, air carriers are not automatically 

required to restrict public access. If they choose to collect repeat samples or conduct disinfection 

and flushing within 72 hours of learning of the positive sample, they are not required to restrict 

public access or provide public notification. Samples positive for E. coli, however, always 

require restriction of public access including public notification no later than 24 hours after the 

laboratory notifies the air carrier of the E. coli-positive result (see Chapter 4 for more 

information). 

Exhibit 6.1 provides a flow-chart illustration of the public notification requirements associated 

with a total coliform-positive sample result (when public access to the water supply is restricted) 

or an E. coli-positive sample result. 

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Exhibit 6.1 Public Notification Requirements in Response to a Total ColiformPositive or E. coli-Positive Sample Result 

If passenger access to the water system is physically prevented through disconnecting or shutting 

off the water, or the flow of water prevented through the tap(s), or if water is supplied only to 

lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required, 

only to the crew (see Appendix D, Template 2 for E. coli-positive event and Template 3 for Total 

Coliform-positive non-E. coli event). In this situation, the notice to the crew may be conveyed 

either as a prominent notice in the galley or as a mandatory crew briefing as described in Section 

6.2.5. 

If passenger access to the water system cannot be physically prevented through disconnecting or 

shutting off the water, or the flow of water cannot be prevented through the tap(s), then public 

notice to the passengers is required. The public notice must consist of a prominently displayed, 

clear statement in each lavatory indicating that the water is non-potable and should not be used 

for drinking, food or beverage preparation, hand washing, teeth brushing, or any other 

consumptive use (see Appendix D, Template 1). In this situation, the notice to the crew must be 

conveyed as a prominent notice in the galley. 

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	 Notice to the crew must include the following: A clear statement that the water is nonpotable and should not be used for drinking, food or beverage preparation, hand washing, 

teeth brushing, or any other consumptive use. 

	 A description of the violation or situation triggering the notice, including the contaminant 

of concern. 

	 When the violation or situation occurred. 

	 Any potential adverse health effects from the violation or situation, including the required 

health effects language for total coliform bacteria or E. coli bacteria, as provided in this 

section. 

	 The population at risk, including sensitive subpopulations particularly vulnerable if 

exposed to the contaminant (the provided health effects language should address this 

element). 

	 What the air carrier is doing to correct the violation or situation. 

	 When the air carrier expects to return the system to unrestricted public access. 

Use the following health effects language when any routine, repeat, or follow-up sample is total 

coliform-positive, but is negative for E. coli: 

Coliform are bacteria that are naturally present in the environment and are used as an 

indicator that other, potentially harmful, bacteria may be present. Coliforms were found in 

[INSERT NUMBER OF SAMPLES DETECTED] samples collected and this is a warning of 

potential problems. If human pathogens are present, they can cause short-term health effects, 

such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special 

health risk for infants, young children, some of the elderly, and people with severely 

compromised immune systems. 

Use the following language for any routine, repeat, or follow-up sample that is positive for E. 

coli (note that in this situation, the notice for total coliform-positive samples is not issued, even 

though these samples would have also been total coliform-positive): 

E. coli are bacteria whose presence indicates that the water may be contaminated with 

human or animal wastes. Microbes in these wastes can cause short-term health effects, such 

as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special health 

risk for infants, young children, some of the elderly, and people with severely compromised 

immune systems. 

The air carrier must continue to provide the notice until a set of follow-up samples is negative for 

total coliforms. 

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6.2.2 Notice for Failure to Monitor, Failure to Conduct Disinfection 

and Flushing, and Situations Where Water Does Not Meet 

Standards (Non-E. coli-Positive Event) 

Air carriers must provide public notice if they fail to collect required routine samples, if they fail 

to perform required routine disinfection and flushing, or if they fail to collect repeat or follow-up 

samples in response to a sample result that is total coliform-positive and E. coli-negative. In 

addition, notice is required when an air carrier becomes aware of a non-E. coli-positive event 

resulting from water that has been boarded from a watering point not in accordance with FDA 

regulations, that does not meet EPA requirements for TNCWSs, or that has been otherwise 

determined to be unsafe due to non-compliance with the procedures for boarding water as 

described in the aircraft water system O&M plan [40 CFR 141.805(a)(2), (4), and (6)]. A “nonE. coli-positive” event is a situation that results in a non-acute event. In other words, the water 

quality issue is not due to an E. coli detection in the water supply, and unsafe boarding 

procedures have not knowingly resulted in E. coli in the water supply. 

For all conditions described above, public notification must be issued to the passengers and/or 

crew and restriction of public access implemented within 72 hours. 

Exhibit 6.2 provides a flow-chart illustration of the public notification requirements discussed in 

this section. 

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Exhibit 6.2 Public Notification Requirements for Failure to Monitor, Disinfect and 

Flush, or Board Water from a Safe Watering Point (Non-E. coli-Positive)
 

 

If passenger access to the water system is physically prevented by disconnecting or shutting off 

the water, or the flow of water prevented through the tap(s), or if water is supplied only to 

lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required, 

only to the crew [see Appendix D, Template 4 - Failure to Perform Routine Disinfection and 

Flushing Notice to the Crew; Template 5 - Failure to Perform Routine, Repeat, or Follow-up 

Monitoring After a Non-E. coli-Positive Sample Notice to the Crew; Template 6 - Boarding 

Water that Does Not Meet FDA Regulations or EPA Standards for Transient Non-community 

Water Systems (Boarded Water Quality or Boarding Procedures) Notice to the Crew (Non-E. 

coli-Positive)]. In this situation, the notice to the crew may be conveyed either as a prominent 

notice in the galley or as a mandatory crew briefing as described in Section 6.2.5. 

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If passenger access to the water system cannot be physically prevented through disconnecting or 

shutting off the water, or the flow of water cannot be prevented through the tap(s), then public 

notice to the passengers is required. The public notice must consist of a prominently displayed, 

clear statement in each lavatory indicating that the water is non-potable and should not be used 

for drinking, food or beverage preparation, hand washing, teeth brushing, or any other 

consumptive use (see Appendix D, Template 1). In this situation, the notice to the crew must be 

conveyed as a prominent notice in the galley. 

Notice to the crew must include the following: 

	 A clear statement that the water is non-potable and should not be used for drinking, food 

or beverage preparation, hand washing, teeth brushing, or any other consumptive use. 

	 A clear statement that it is not known whether the water is contaminated because there 

was a failure to perform required routine disinfection and flushing; or a failure to perform 

required monitoring; or water was boarded from a watering point that is not in 

accordance with FDA regulations, or does not meet the NPDWRs applicable to 

TNCWSs, or has otherwise been determined to be unsafe due to noncompliance with the 

O&M procedures for boarding water. (Inclusion of the health effects language provided 

below should in many cases address this requirement.) 

	 When and where the unsafe water was boarded, or when the specific monitoring or 

disinfection and flushing requirement was not met. 

	 Any potential adverse health effects from exposure to waterborne pathogens that might 

be in the water, as appropriate. (Inclusion of the health effects language provided below 

addresses this requirement.) 

	 The population at risk, including sensitive subpopulations particularly vulnerable if 

exposed to the contaminant (the provided health effects language should address this 

element). 

	 A statement indicating when the system will be disinfected and flushed and returned to 

unrestricted public access. 

Public notices for failure to conduct routine monitoring or disinfection and flushing, or repeat or 

follow-up monitoring in response to a sample result that is total coliform-positive and E. colinegative, must include the following text. Notices for a non-E. coli-positive event resulting from 

water that has been boarded from a watering point not in accordance with FDA regulations, that 

does not meet EPA standards for TNCWSs, or is otherwise deemed unsafe due to noncompliance 

with the procedures in the aircraft water system O&M plan must also use the following language. 

Select the appropriate phrase from the options inside the brackets and delete the inapplicable 

phrases: 

Because [REQUIRED MONITORING AND ANALYSIS WAS NOT CONDUCTED], 

[REQUIRED DISINFECTION AND FLUSHING WAS NOT CONDUCTED], [WATER WAS 

BOARDED FROM A WATERING POINT NOT IN ACCORDANCE WITH FDA 

REGULATIONS (21 CFR PART 1240, SUBPART E)] or [OTHER APPROPRIATE 

EXPLANATION], we cannot be sure of the quality of the drinking water at this time. 

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However drinking water contaminated with human pathogens can cause short-term health 

effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a 

special health risk for infants, young children, some of the elderly, and people with severely 

compromised immune systems. 

The air carrier must continue to provide the notice until a set of follow-up samples is negative for 

total coliforms. 

6.2.3 Notice for Failure to Conduct Follow-Up Monitoring and 

Situations Where Water Does Not Meet Standards (E. coliPositive Event) 

Air carriers must provide public notice if they fail to collect required follow-up samples in 

response to a sample result that is E. coli-positive. In addition, notice is required when an air 

carrier becomes aware of an E. coli-positive event resulting from water that has been boarded 

from a watering point not in accordance with FDA regulations, that does not meet EPA 

requirements for TNCWSs, or that has been otherwise determined to be unsafe due to noncompliance with the procedures for boarding water as described in the aircraft water system 

O&M plan [40 CFR 141.805(a)(3) and (5)]. An “E. coli-positive” event is an event where E. coli 

has been detected or is otherwise introduced in the water boarded on the aircraft. 

For all conditions described above, public notification must be issued to the passengers and crew 

and restriction of public access implemented within 24 hours. 

Exhibit 6.3 provides a flow-chart illustration of the public notification requirements discussed in 

this section. 

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Exhibit 6.3 Public Notification Requirements for Failure to Monitor, Disinfect and 

Flush, or Board Water from a Safe Watering Point (E. coli-Positive)
 

If passenger access to the water system is physically prevented by disconnecting or shutting off 

the water, or the flow of water prevented through the tap(s), or if water is supplied only to 

lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required, 

only to the crew [see Appendix D, Template 7 – Failure to Perform Follow-up Monitoring After 

an E. coli-Positive Sample Result Notice to the Crew; Template 8 – Boarding Water that Does 

Not Meet FDA Regulations or EPA Standards for Transient Non-community Water Systems (E. 

coli-Positive event) Notice to the Crew]. In this situation, the notice to the crew may be 

conveyed either as a prominent notice in the galley or as a mandatory crew briefing as described 

in Section 6.2.5. 

If passenger access to the water system cannot be physically prevented through disconnecting or 

shutting off the water, or the flow of water prevented through the tap(s), then public notice to the 

passengers is required. The public notice must consist of a prominently-displayed, clear 

statement in each lavatory indicating that the water is non-potable and should not be used for 

drinking, food or beverage preparation, hand washing, teeth brushing, or any other consumptive 

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use (see Appendix D, Template 1). In this situation, the notice to the crew must be conveyed as a 

prominent notice in the galley. 

Notice to the crew must include the following: 

	 A clear statement that the water is non-potable and should not be used for drinking, food 

or beverage preparation, hand washing, teeth brushing, or any other consumptive use. 

	 A clear statement that the water is contaminated and there was a failure to conduct 

required monitoring; or a clear statement that the water is contaminated because water 

was boarded from a watering point that is not in accordance with FDA regulations, or the 

water does not meet requirements applicable to TNCWSs, or the water has otherwise 

been determined to be unsafe due to noncompliance with the O&M procedures for 

boarding water. (Inclusion of the health effects language provided below should in many 

cases address this requirement.) 

	 A description of the contaminant(s) of concern. 

	 When and where the unsafe water was boarded, or when the specific monitoring 

requirement was not met. 

	 Any potential adverse health effects from the situation, as appropriate. (Inclusion of the 

health effects language provided below addresses this requirement.) 

	 The population at risk, including sensitive subpopulations particularly vulnerable if 

exposed to the contaminant (the provided health effects language should address this 

element). 

	 What the air carrier is doing to correct the situation. 

	 When the air carrier expects to return the system to unrestricted public access. 

Public notices for failure to conduct follow-up monitoring in response to a sample result that is 

E. coli-positive must include the following text. 

Because required follow-up monitoring and analysis was not conducted after the aircraft 

water system tested positive for E. coli, we cannot be sure of the quality of the drinking water 

at this time. E. coli are bacteria whose presence indicates that the water may be 

contaminated with human or animal wastes. Microbes in these wastes can cause short-term 

health effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may 

pose a special health risk for infants, young children, some of the elderly, and people with 

severely compromised immune systems. 

Notices when an air carrier becomes aware of an E. coli-positive event that is a result of water 

that has been boarded from a watering point not in accordance with FDA regulations, that does 

not meet EPA standards for TNCWSs, or is otherwise deemed unsafe due to noncompliance with 

the procedures in the aircraft water system O&M plan must use the following language. Select 

the appropriate phrase from the options inside the brackets and delete the inapplicable phrases: 

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Water was boarded that is contaminated with E. coli because [WATER WAS BOARDED 

FROM A WATERING POINT NOT IN ACCORDANCE WITH FDA REGULATIONS (21 

CFR ART 1240, SUBPART E)] or [OTHER APPROPRIATE EXPLANATION]. E. coli are 

bacteria whose presence indicates that the water may be contaminated with human or animal 

wastes. Microbes in these wastes can cause short-term health effects, such as diarrhea, 

cramps, nausea, headaches, or other symptoms. They may pose a special health risk for 

infants, young children, some of the elderly, and people with severely compromised immune 

systems. 

The air carrier must continue to provide the notice until a set of follow-up samples is negative for 

total coliforms. 

6.2.4 Notice Where Necessary to Protect Public Health 

The ADWR provides for notice to be given where EPA, the carrier, or the crew determines it is 

necessary to protect public health from potentially serious health effects resulting from shortterm exposure or specific conditions creating a public health risk [40 CFR 141.805(a)(7)]. This 

notice provision is intended to address unique circumstances where required notifications under 

other provisions in 40 CFR 141.805(a) may not be triggered or may otherwise prove to be 

inadequate under the circumstances. Accordingly, this notice provision would not apply to 

circumstances where the notification provisions set forth at 40 CFR 141.805(a)(1) through (a)(6) 

have been triggered. Furthermore, if passenger access to the water system is physically prevented 

through disconnecting or shutting off the water, or the flow of water prevented through the 

tap(s), or if water is supplied only to lavatory toilets, and not to any lavatory or galley taps, then 

only the crew notice under 40 CFR 141.805(c)(2), (d)(2), (e)(2), and (g) is required as 

appropriate. EPA understands that flight crews would be expected to comply with existing airline 

policies regarding communication with the public, including how to initiate, conduct, and 

document the public notification. This may include notifying or gaining approval from the pilotin-command prior to conducting the public notification. 

If the public water system that serves the airport has a violation or situation that requires public 

notification, they are required to notify their customers including the airport who in turn must 

notify the air carriers whose aircraft board water from the watering points at the airport. Air 

carriers can use the notice provided by the public water system for the crew notice if all public 

notification requirements under the ADWR are met or they can use information from the notice 

to supplement their notice. 

Notification must be reasonably calculated to reach all passengers and crew that are onboard the 

aircraft at the time the notification is made with one or more of the following forms of delivery 

applicable to this provision of the ADWR: 

1) Broadcast over a public announcement (PA) system on aircraft; 

2) Posting of the notice in conspicuous locations (such as all the galleys and lavatories in the 

affected aircraft); 

3) Hand delivery of the notice to passengers and crew; or 

4) Another delivery method approved in writing by EPA. 

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If EPA determines that public notification is necessary, air carriers must provide notification to 

passengers and crew within 24 hours of being informed by EPA to issue notification and must 

continue notification for the duration determined by EPA (see Appendix D, Template 9). 

Exhibit 6.4 provides a flow-chart illustration of the public notification requirements when EPA, 

the air carrier, or the crew determines that notification is necessary to protect public health. 

Exhibit 6.4 Public Notification Requirements When Notification is Deemed 

Necessary by EPA, the Air Carrier, or the Crew
 

While there are general requirements regarding the content of all public notices in the ADWR 

(found in 40 CFR 141.805(b) and described in Section 6.2 of this chapter), there are no specific 

content requirements for this situation. However, the content requirements specific to other 

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violations or situations requiring notification may be used as a guideline, when applicable. In 

addition, Template 9 in Appendix E provides an example of a notice that can be used for posting 

or hand delivery for this situation. 

6.2.5 Crew-only Notice 

Under the ADWR, in all situations when public notice must be provided, the rule allows for 

notice to be provided only to the crew so long as access to the water system is prevented by (1) 

disconnecting or shutting off the water, (2) preventing the flow of water through the tap(s), or (3) 

allowing water to be supplied only to lavatory toilets and not to any lavatory or galley tap. This 

provision of the ADWR ensures that the crew is notified of the water system status without the 

need for placing notices in each lavatory on the aircraft since the passengers would not be 

exposed to any health risks associated with the aircraft water system. However, input from air 

carriers expressed concern that if the required “prominent” notice to the crew is posted such that 

it is viewable by passengers, it may be misinterpreted without the understanding that they are not 

exposed to a risk because the aircraft water system has been shut-off. EPA understands this 

concern. Since the intent of this crew-only notice is to not notify the public when the system is 

inaccessible and does not represent a risk to passengers, the “prominent notice in the galley 

directed at the crew” does not need to be visible to the passengers. It need only be “prominent” 

with respect to the crew. EPA recognizes that any posted notices must be in accordance with 

FAA signage requirements. 

EPA believes that the following procedure also satisfies the requirement of crew-only 

notification when access to the water system is prevented by (1) disconnecting or shutting off the 

water, (2) preventing the flow of water through the tap(s), or (3) allowing water to be supplied 

only to lavatory toilets and not to any lavatory or galley tap. 

1.	 The “prominent notice to the crew” is read orally by the pilot to the entire crew 

during each pre-flight Crew Briefing for which attendance must be mandatory for all 

cabin crew members. 

2.	 The oral notice must meet all of the applicable requirements in 40 CFR 141.805 

including (c)(2), (d)(2), (e)(2), and (g). 

3.	 A copy of the notice read to the crew by the pilot must be maintained as a record for 

three years as required under 40 CFR 141.807(f). EPA may request a copy of the 

notice at any time. 

Under all situations involving crew-only notice, crew members must be prohibited from 

reactivating the water system once it has been established as inoperative. Access to the water 

system must not be restored until all of the applicable corrective action requirements of the 

ADWR have been met and the FAA regulations that govern the process for reactivating the 

water system have been followed. 

The air carrier must keep copies of public notices that have been issued to passengers and crew 

as required by the ADWR for at least 3 years after issuance [40 CFR 141.807(f)]. Air carriers 

may keep electronic copies of these notices in lieu of paper copies. 

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7. Recordkeeping and Reporting 

This chapter presents the recordkeeping and reporting requirements of the ADWR. The ADWR 

recordkeeping requirements are in 40 CFR 141.807, and reporting requirements can be found in 

40 CFR 141.806. 

7.1 Air Carrier Recordkeeping 

Air carriers must keep records to document activities performed for compliance with the ADWR 

[40 CFR 141.807]. Many of the records which must be kept are not also reported to EPA. 

However, the records must be made available to EPA upon request. EPA may ask to view the 

records at any time as part of its ADWR oversight activities. EPA expects records to be made 

available within 14 calendar days of its request. 

The ADWR does not specify a format in which the records must be retained or a location where 

they are to be housed. The air carrier’s records retention system should be designed and 

organized to enable retrieval of specific records for each aircraft upon request by EPA. Records 

may include hard copy and/or electronic files. 

7.1.1 Record Maintenance 

Exhibit 7.1 summarizes the records that must be kept by the air carrier and the minimum time 

period they must be maintained. The dates are consistent with the recordkeeping requirements 

for similar items by other types of public water systems. 

Exhibit 7.1 Duration of Record Maintenance 

Type of Record to be Maintained Minimum Retention Time 

Bacteriological Analysis 

(Applies to all routine, repeat, and follow-up samples, including any 

replacement samples.) 

5 Years 

Aircraft Water System Disinfection and Flushing Events 

(Performed as routine and corrective action disinfection and flushing 

activities.) 

5 Years 

Self-Inspection 10 Years 

Coliform Sampling Plans Maintained on an Ongoing Basis 

Water System Operations and Maintenance Plans Maintained on an Ongoing Basis 

Copies of Public Notices to Passengers and Crew 3 Years After Issuance 

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7.1.2 Information Included in Records 

The ADWR is specific regarding the minimum information that must be included for each type 

of record that is required to be maintained. Additional information may also be retained at the air 

carriers’ discretion. 

	 Records of bacteriological analyses include all sample results for routine, repeat, and 

follow-up samples (including any replacement samples) as well as results from any special 

purpose samples. All of the following information must be retained (this may be standard 

information entered on the laboratory data sheet accompanying the sample from collection 

through reporting of analysis results): 

o	 The date, time and place of sampling, and the name of the person who collected the 

sample. 

o	 Identification of the sample as a routine, repeat, follow-up, or other special purpose 

sample. 

o	 Date of the analysis. 

o	 Laboratory and person responsible for performing the analysis. 

o	 The analytical technique/method used. 

o	 The results of the analysis. 

	 Records of disinfection and flushing include all routine and corrective action disinfection 

and flushing events. The records may be kept as a compiled list of events for each aircraft, or 

as separate activity records. Because the procedures for disinfection and flushing events are 

included in the aircraft water system O&M plan, a separate record for procedures is not 

required. However, all of the following information must be recorded and maintained: 

o	 The date and time of the disinfection and flushing event. 

o	 The type of disinfection and flushing event: a routine disinfection and flushing event, a 

corrective action event, or an event that meets the criteria for both a routine and a 

corrective event (See Chapter 4). 

	 Records of self-inspections must include the following: 

o	 The completion date of each self-inspection. This may include completion dates of 

distinct aspects of the self-inspection, if the inspection is performed as a series of steps 

and not as a single activity. 

o	 Copies of any written reports, summaries, or communications related to a given selfinspection. 

	 Copies of coliform sampling plans must be available for review by EPA during compliance 

audits and upon request. 

	 Copies of aircraft water system O&M plans must be maintained in accordance with FAA 

requirements and available for review by EPA during compliance audits and upon request. 

	 Copies of public notices provided to passengers and crew must be maintained to document 

the information that was included in the notice. 

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7.2 Reporting Requirements 

The reporting requirements of the ADWR pertain to an air carrier’s inventory of aircraft water 

systems, the coliform plan and sampling, the O&M plan and activities, public notification, selfinspections and deficiencies, and compliance audits [40 CFR 141.806]. 

7.2.1 Reporting Format 

Unless EPA has approved an alternative method of reporting, the ADWR requires air carriers to 

report required information electronically. To facilitate the collection and analysis of aircraft 

water system data, EPA will use an Internet-based electronic data collection and management 

system (ADWR Reporting and Compliance System). Air carriers’ primary contact will be issued 

a username and password to access the ADWR Reporting and Compliance system. The data 

system will perform logic checks on data entered and will calculate final results for 

accountability and regulatory oversight. This system is intended to reduce reporting errors and 

limit the time involved in investigating, checking, and correcting errors at all levels. 

The ADWR Reporting and Compliance System will have a companion User Guide that will 

provide information pertinent to users of the system. The User Guide will include a description 

of spreadsheet format and reporting method, how to access the downloadable spreadsheet and 

Web user interface, and other key information. 

7.2.2 Aircraft Inventory 

Air carriers are required to report a complete inventory of aircraft that are public water systems. 

In addition, they must report any changes to that inventory. Exhibit 7.2 summarizes the reporting 

timeline and pertinent information for establishing and maintaining an accurate inventory of 

aircraft water systems. 

Exhibit 7.2 Reporting Aircraft Inventory 

Reporting Item Reporting Timeline Information to Report to EPA 

Aircraft Water System Inventory 

(existing aircraft) April 19, 2011 

Unique aircraft identifier number, 

active or inactive status, type and 

location of supplemental treatment, 

and whether the aircraft water 

system can be shut off or the flow of 

water prevented through the taps 

Aircraft Water System Inventory 

(new aircraft) 

Within the first calendar quarter of 

initial operation of the aircraft 

Unique aircraft identifier number, 

active or inactive status, type and 

location of supplemental treatment, 

and whether the aircraft water 

system can be shut off or the flow of 

water prevented through the taps 

Changes to Existing Inventory 

No later than 10 days following the 

calendar month in which the 

change occurred 

Changes to any of the information 

reported for the existing aircraft 

inventory 

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As illustrated in Exhibit 7.2, by April 19, 2011, air carriers must provide EPA a complete 

inventory of existing aircraft public water systems [40 CFR 141.806(b)]. Existing aircraft means 

any aircraft that was in operation when the final ADWR was published on October 19, 2009, or 

any aircraft that was brought into operation by April 19, 2011. The inventory will be reported 

directly to ADWR Reporting and Compliance System. 

Changes to any information reported for the existing aircraft inventory must also be reported to 

ensure EPA has accurate information on aircraft public water systems for the ADWR 

implementation oversight program. Inventory changes (e.g., change of status from “active” to 

“inactive,” adding or removing aircraft, etc.) must be reported within 10 days following the 

calendar month in which the change occurred. If no changes are made during that month, no 

reporting is required. Exhibit 7.3 illustrates the reporting requirements for aircraft inventory. 

Exhibit 7.3 Aircraft Inventory Reporting Requirements 

If there is a change in inventory 

(including adding new aircraft or 

removing aircraft) 

after submitting the initial 

inventory 

Report the inventory 

change

 information within 10 

days following

 the month in which the

 change occurred 

For Existing Aircraft: 

Report inventory 

information 

by April 19, 2011 

Develop Aircraft Inventory 

Aircraft inventory reported to EPA must include all of the following information: 

 The unique aircraft identifier number. 

This may be the nose or tail number that is unique to the aircraft and is used for other 

aircraft tracking requirements. 

 The status of the aircraft as active or inactive. 

Refer to Section 3.2 for information on determining active and inactive status. 

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	 The type and location of any supplemental treatment equipment installed on the aircraft 

water system. 

Supplemental treatment equipment includes treatment applied to the finished water to 

maintain water quality or to change aesthetic water quality conditions. Examples include 

disinfection systems, carbon filters or particle removal filters on water lines, or other 

apparatus that changes the chemical, biological, or physical condition of the water. 

Although it is possible for increased temperature to cause changes to the chemical, 

biological, and physical condition of water, for the purposes of aircraft inventory, hot 

water heating units on coffee makers and/or hot water lines are not considered to be water 

treatment equipment. 

	 Whether the aircraft water system can be physically disconnected or shut off, or the flow of 

water prevented through the taps. 

This information is important because the ability to shut off the supply of water to all 

faucets and other plumbing fixtures that provide water to passengers or crew affects the 

requirements for public notification and the timeframe for implementation of corrective 

disinfection and flushing. 

7.2.3 Coliform Plan and Sampling 

For each aircraft water system, air carriers must inform EPA when coliform sampling plans are 

completed and report the frequency of coliform monitoring. Copies of coliform sampling plans 

must be retained but they are not required to be submitted to EPA. However, EPA can request a 

copy of the plan at any time and may also view the plan during compliance audits. The frequency 

of coliform monitoring will be tracked and compared to the minimum requirements of the rule, 

and used as the basis for determining compliance with the provisions of the ADWR. Exhibit 7.4 

summarizes the reporting items and timeline related to establishing and maintaining coliform 

sampling plans and conducting coliform monitoring. 

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Exhibit 7.4 Reporting for Coliform Plan and Sampling 

Reporting Item Reporting Timeline Information to Report to EPA 

Coliform Sampling Plan 

(existing aircraft) April 19, 2011 

Date the plan has been developed 

and the frequency of routine 

coliform sampling for each aircraft 

Coliform Sampling Plan 

(new aircraft) 

Within the first calendar quarter of 

initial operation of the aircraft 

Date the plan has been developed 

and the frequency of routine 

coliform sampling for each aircraft 

Changes to required sampling 

frequency 

No later than 10 days following the 

calendar month in which the 

change occurred 

Changes to the required sampling 

frequency 

All sample results that are 

TC(-) & EC(-) 

(routine, repeats and follow-up) 

No later than 10 calendar days 

following the monitoring period in 

which the sampling occurred. 

Sample results 

Any routine sample TC(+) & EC(-) Within 10 calendar days of 

receiving sample results 

Sample results and, if applicable, 

whether required notification was 

provided to passengers and crew or 

crew only 

Any sample TC(+) & EC(+) (routine, 

repeat, and follow-up) 

Within 10 calendar days of 

receiving sample results 

Sample results and whether 

required notification was provided to 

passengers and crew or crew only 

Any repeat or follow-up sample Within 10 calendar days of 

receiving sample results 

Sample results and whether 

required notification was provided to 

passengers and crew or crew only 

Return to routine monitoring 

No later than 10 calendar days 

following the return to routine 

monitoring 

Cessation of public notification or 

restricted public access 

requirements 

Failure to conduct routine monitoring Within 10 calendar days of 

discovery of the failure 

Whether required notification was 

provided to passengers and crew or 

crew only 

Failure to collect repeat samples Within 10 calendar days of 

discovery of the failure 

Whether required notification was 

provided to passengers and crew or 

crew only 

Failure to collect follow-up samples Within 10 calendar days of 

discovery of the failure 

Whether required notification was 

provided to passengers and crew or 

crew only 

For existing aircraft, both sampling frequencies and coliform sampling plan completion must be 

reported to EPA by April 19, 2011. For new aircraft placed into operation after the initial 

inventory is submitted, sampling frequencies and plan completion must be reported within the 

first calendar quarter of initial operation of the aircraft. See Chapter 4 for more information on 

coliform sampling plan requirements. 

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Changes in coliform sampling frequencies must be reported to EPA no later than 10 days 

following the calendar month in which the change occurred. Such changes must also be 

incorporated in the coliform sampling plan, although the plan itself need not be submitted. 

Changes to coliform sampling frequencies and coliform sampling plans require changes to 

disinfection and flushing frequencies and O&M plans. Exhibit 7.5 summarized the implications 

of changing the coliform sampling frequency. 

Exhibit 7.5 Implications of Changes to Coliform Sampling Frequencies 

In most cases, all coliform sampling results (routine, repeat, and follow-up) must be reported no 

later than 10 calendar days after the end of the monitoring period in which the samples were 

collected. The monitoring period is based on the monitoring frequency identified in the coliform 

sampling plan and may vary for different aircraft in an air carrier fleet. Thus, the monitoring 

period could be one month, one quarter (three months), six months, or 1 year. 

If sample results (or any other event) trigger repeat sampling, or follow-up samples are collected 

after disinfection and flushing, the event must be reported to EPA within 10 days of being 

informed of sample results by the laboratory including whether the notification was provided to 

passengers and crew, or crew only. 

All analytical sample results will be reported to the ADWR Reporting and Compliance System. 

Air carriers may instruct laboratories to either manually enter analytical results into EPA’s 

electronic data system, or to electronically upload data files from their laboratory information 

management systems (LIMS) to a Web-based data file submission program. 

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Regardless of the method or personnel used to report the data, these data files must be in a 

format prescribed by EPA. Air carriers may determine the best method of data upload and 

reporting that meets their needs. The ADWR does not require laboratory reporting or prohibit 

consultants or other agents from gathering and reporting results on the carrier’s behalf. If it is 

believed that a result was entered into the data system erroneously, the air carrier is responsible 

for notifying the laboratory or responsible party to rectify the entry. 

Failure to comply with the monitoring requirements of this regulation must also be reported to 

EPA within 10 calendar days. Failure to comply with monitoring requirements includes, but is 

not limited to, failure to collect routine samples according to the schedule in the coliform 

sampling plan, failure to collect repeat samples or follow-up samples within the time required, 

and failure to use a state or EPA-certified laboratory or EPA-approved analytical methods. 

7.2.4 O&M Plans and Activities 

For each aircraft water system, air carriers must inform EPA when the O&M plan is completed 

and report the frequency of routine disinfection and flushing. Copies of aircraft water system 

O&M plans must be retained but are not required to be submitted to EPA. However, EPA can 

request a copy of the plan at any time and may also view the plan during compliance audits. The 

frequency of routine disinfection and flushing will be tracked and compared to the minimum 

requirements of the rule, and used as the basis for determining compliance with the provisions of 

the ADWR. Exhibit 7.6 summarizes the reporting items and timeline that are related to 

establishing and maintaining O&M plans and conducting O&M activities. 

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Exhibit 7.6 Reporting O&M Plans and Activities 

Reporting Item or Event Reporting Timeline Information to Report to EPA 

Operations and Maintenance Plan 

(existing aircraft) April 19, 2011 

Plan has been developed and the 

frequency of routine disinfection 

and flushing for each aircraft 

Operations and Maintenance Plan 

(new aircraft) 

Within the first calendar quarter of 

initial operation of the aircraft 

Plan has been developed and the 

frequency of routine disinfection 

and flushing for each aircraft 

Changes to disinfection and flushing 

frequency 

No later than 10 days following the 

calendar month in which the 

change occurred 

Changes to disinfection and 

flushing frequency 

Disinfecting and Flushing 

(routine) 

Within 10 calendar days following 

the disinfection and flushing 

period in which the disinfection 

and flushing occurred. 

Routine disinfection and flushing 

event was completed 

Disinfecting and Flushing 

(corrective) 

Within 10 calendar days of 

conducting disinfection and 

flushing 

Corrective disinfection and flushing 

was completed and whether 

required notification was provided to 

passengers and crew or crew only 

Restriction of public access Within 10 calendar days of 

restriction 

Notification was provided to 

passengers and crew or crew only, 

corrective action type, and reason 

Shutting off an aircraft water system Within 10 calendar days of 

notification 

Whether the water system has been 

shut off 

Failure to conduct disinfection and 

flushing Within 10 calendar days of failure 

Whether required notification was 

provided to passengers and crew or 

crew only and corrective actions 

implemented 

Failure to board water from a safe 

watering point 

Within 10 calendar days of 

identification of failure 

Whether required notification was 

provided to passengers and crew or 

crew only and corrective actions 

implemented 

For existing aircraft, both routine disinfection and flushing frequency and O&M plan completion 

must be reported to EPA by April 19, 2011. For new aircraft placed into operation after the 

initial inventory is submitted, frequency of routine disinfection and flushing and O&M plan 

completion must be reported within the first calendar quarter of initial operation of the aircraft. 

See Chapter 5 for more information on O&M plan requirements. 

Changes in routine disinfection and flushing frequencies must be reported to EPA no later than 

10 days following the calendar month in which the change occurred. Such changes must also be 

incorporated in the O&M plans, although the plan itself need not be submitted. Changes to the 

routine disinfection and flushing frequencies require changes to the routine coliform sampling 

frequencies and coliform sampling plans. 

Failure to comply with the disinfection and flushing requirements of this regulation must also be 

reported to EPA within 10 calendar days of discovery of the failure. Failure to comply with 

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disinfection and flushing requirements includes failure to perform routine disinfection and 

flushing according to the schedule in the O&M plan, and failure to conduct corrective 

disinfection and flushing. 

Anytime corrective action (i.e., restriction of public access or disinfection and flushing) is 

implemented, air carriers must notify EPA within 10 calendar days of the event and report the 

reason for the corrective action, the type of corrective action implemented, and whether required 

notification was provided to the passengers and crew or crew only. 

7.2.5 Public Notification 

All events requiring notification to passengers and crew must also be reported to EPA within 10 

days of the event triggering the notification (see Exhibit 7.7). This reporting must include 

information on whether the required notification was provided to passengers and crew or crew 

only [40 CFR 141.806(b)(4)]. This does not require that a copy of a notification be provided to 

EPA; however, a copy must be available for EPA review as part of an audit. 

Exhibit 7.7 Public Notification Reporting Requirements 

Reporting Item Reporting Timeline Information to Report to EPA 

Public notification to crew and 

passengers 

Within 10 calendar days of 

notification 

Whether required notification was 

provided to the passengers and 

crew or crew only 

Public notification to crew only Within 10 calendar days of 

notification 

Whether required notification was 

provided to the passengers and 

crew or crew only 

7.2.6 Self-Inspections 

Air carriers must provide evidence of a self-inspection to EPA within 90 days of completion of 

the self-inspection [40 CFR 141.806(c)]; self-inspections of aircraft water systems are required 

every 5 years. The report must include evidence that all deficiencies identified in the inspection 

have been addressed. See Exhibit 7.8 on reporting requirements for self-inspections. 

Exhibit 7.8 Self-Inspection Reporting 

Reporting Item Reporting Timeline Information to Report to EPA 

Completion of self-inspection 90 days after completion of the 

self-inspection 

Provide evidence that a selfinspection was completed 

Deficiencies identified during selfinspection Within 90 days of identification of 

the deficiency 

Notification that the deficiency has 

been addressed, or if not addressed, 

provide a description of the 

deficiency and an explanation of why 

it has not been addressed and a 

schedule for addressing the 

deficiency as soon as possible 

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EPA has provided flexibility in the rule so that a full self-inspection of an aircraft water system 

may be conducted over time rather than all at once so long as a complete self-inspection of the 

entire aircraft water system occurs no less frequently than once every five years. This allows air 

carriers to develop their own unique self-inspection procedures that coordinate, to the maximum 

extent possible, water system self-inspections with the existing aircraft inspection and 

maintenance process. Consequently, deficiencies may be identified periodically throughout the 

compliance period. If any deficiency has not been addressed within 90 days of identification of 

the deficiency, the air carrier must report a description of each unaddressed deficiency, an 

explanation as to why it has not been addressed, and a schedule for addressing each deficiency as 

quickly as possible [40 CFR 141.806(c)]. 

If more than 90 days have elapsed since a deficiency was identified and it has not been 

addressed, the aircraft will incur a violation of the ADWR if the aircraft is used in passenger 

service, even if public access to the water is restricted [40 CFR 141.808(c) and 141.810(e)]. If 

the aircraft is not returned to service, such as during extended or heavy maintenance, more than 

90 days are allowed for addressing the deficiency without incurring a violation. Exhibit 7.9 

illustrates the self-inspection reporting requirements. 

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Exhibit 7.9 Self-Inspection Reporting Requirements 

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7.2.7 Compliance Audits 

Because EPA performs compliance audits, there are no reporting requirements for the air carrier 

related to completion of the audit. However, if deficiencies are identified during the audit, there 

are reporting requirements related to the status of the deficiency. If a deficiency is identified 

during a compliance audit, the carrier must report to EPA within 90 days of completion of the 

audit that the deficiency has been addressed. Exhibit 7.10 provides the compliance audit 

reporting requirements related to water system deficiencies. 

Exhibit 7.10 Compliance Audit Reporting 

Reporting Item Reporting Timeline Information to Report 

Deficiencies identified during 

compliance audits 

Within 90 days of notification of the 

deficiency 

Notification that the deficiency has 

been addressed, or if not addressed, 

provide a description of the 

deficiency and an explanation of why 

it has not been addressed and a 

schedule for addressing the 

deficiency as soon as possible 

If any deficiencies have not been addressed within 90 days of identification of the deficiency, the 

air carrier must report a description of each unaddressed deficiency, an explanation as to why it 

has not been addressed, and a schedule for addressing each deficiency as quickly as possible [40 

CFR 141.806(c)]. 

If more than 90 days have elapsed since a deficiency was identified and it has not been 

addressed, the aircraft will incur a violation of the ADWR if the aircraft is used in passenger 

service, even if public access to the water is restricted [40 CFR 141.808(c) and 141.810(e)]. If 

the aircraft is not returned to service, such as during extended or heavy maintenance, more than 

90 days are allowed for addressing the deficiency without incurring a violation. 

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8. Violations of the Rule 

Implementation and enforcement of National Primary Drinking Water Regulations applicable to 

aircraft public water systems is the responsibility of the EPA. Violations of the ADWR are 

specified in 40 CFR 141.810. Most of the violations involve failure of the air carrier to perform a 

specified action. An important exception is that any routine or repeat coliform sample result that 

is E. coli-positive is a violation of the ADWR. 

Exhibit 8.1 summarizes rule violations and actions that the ADWR specifies must be taken in 

response to the violation, along with the rule citations. The exhibit also provides references to 

chapters in this guidance that provide further information on the ADWR requirements that were 

violated and the activity that is required in response to the violation. EPA’s enforcement options, 

including penalties, are not addressed in this table. 

In some cases, actions to bring the aircraft water system into compliance with the rule are not 

specified in the ADWR and will be determined by EPA. Exhibit 8.1 provides information on the 

violations to which this applies. EPA-required actions may be situation-specific. 

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Exhibit 8.1 Violations of the ADWR 

-- Summary -- 

Violation Required Response for the Violation (including citation) 

Failure to perform any requirements in There are no rule citations specifying actions in response to these 

[40CFR 141.803 or 141.804]. This violations. Actions will be determined by EPA. One of the actions could 

includes failure to: use analytical methods include replacing the sample. approved in accordance with 141.21(f)(3) and 141.21(f)(6) of the National Primary Drinking Water Regulations; and/or use laboratories certified by EPA or a “State”. Failure to perform routine disinfection The responses specified for this violation under 40 CFR 

and flushing [40 CFR 141.810(a)]. This 141.803(c)(3)(ii) are as follows: 

includes failure to conduct routine (1) Restrict public access to aircraft water system within 72 hours 

disinfection and flushing as specified in which includes: the O&M plan.  Physically disconnecting/shutting off aircraft water system, 

where feasible, or otherwise preventing the flow of water through the tap(s). 

 Providing public notification to passengers and crew per 

40 CFR 141.805. 

 Providing alternatives to water from the aircraft water 

system (e.g., bottled water, antiseptic hand gels, etc.). 

(2) Conduct disinfection and flushing. (3) Collect follow-up samples. Once samples are collected, aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(5) requires the violation be reported to EPA within 10 calendar days of discovery of the failure. 

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Violation Required Response for the Violation (including citation) 

Failure to perform corrective 40 CFR 141.806(b)(5) requires the violation be reported to EPA within disinfection and flushing [40 CFR 10 calendar days of discovery of the failure. By failing to perform 141.810(a)]. This is triggered by sample corrective disinfection and flushing, the air carrier also would have 

results or failure to perform required failed to collect follow-up samples. Therefore, the air carrier must activities. complete the required responses for failing to collect follow-up 

samples for an E. coli-positive or a total coliform-positive and E. colinegative routine or repeat sample, whichever is applicable. 

Failure to restrict public access to the By failing to restrict public access by not physically disconnecting or 

aircraft water supply by not physically shutting off the aircraft water system when feasible, the air carrier also 

disconnecting or shutting off the would have failed to perform corrective disinfection and flushing in the aircraft water system where feasible [40 required timeframe and failed to collect the required follow-up CFR 141.810(a)]. This is triggered by samples. Therefore, the aircraft must complete the required responses sample results or failure to perform for failing to collect follow-up samples for an E. coli-positive or a total 

required activities. coliform-positive and E. coli-negative routine or repeat sample, 

whichever is applicable. 

Failure to restrict public access to the There are no rule citations specifying actions in response to this aircraft water supply by not providing violation. Actions will be determined by EPA. 

public notification [40 CFR 141.810(a)]. This is triggered by sample results or failure to perform required activities. Failure to restrict public access to the aircraft water supply by not providing alternatives to water or other measures [40 CFR 141.810(a)]. This is triggered by sample results or failure to perform required activities. 

There are no rule citations specifying actions in response to this violation. Actions will be determined by EPA. 

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Violation Required Response for the Violation (including citation) 

Failure to provide notification to passengers and crew [40 CFR 141.810(c)]. This includes public notification required for passengers and crew per [40 CFR 141.805] triggered by sample results, failure to perform required activities, or as determined by EPA, the air carrier, or the crew. 

There are no rule citations specifying actions in response to this violation. Actions will be determined by EPA. 

Failure to collect routine coliform The responses specified for this violation under 40 CFR 

samples [40 CFR 141.810(a)]. This 141.803(c)(3)(ii) are as follows: 

includes failure to collect and analyze the (1) Restrict public access to aircraft water system within 72 hours 

required number of coliform samples in which includes: accordance with the coliform monitoring  Physically disconnecting/shutting off aircraft water system, 

plan. where feasible, or otherwise preventing the flow of water 

through the tap(s). 

 Providing public notification to passengers and crew per 

[40 CFR 141.805]. 

 Providing alternatives to water from the aircraft water 

system (e.g., bottled water, antiseptic hand gels, etc.). 

(2) Conduct disinfection and flushing. (3) Collect follow-up samples. Once samples are collected, aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(5) requires the violation be reported to EPA within 

10 calendar days of discovery of the failure. 

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Violation Required Response for the Violation (including citation) 

Failure to collect repeat or follow-up The responses specified for this violation under 40 CFR 

samples as a result of a total coliform- 141.803(c)(3)(ii) are as follows: 

positive and E. coli-negative result [40 (1) Restrict public access to aircraft water system within 72 hours CFR 141.810(a)]. This includes failure to which includes: conduct repeat sampling after routine  Physically disconnecting/shutting off aircraft water system, 

samples are found to be positive for total where feasible, or otherwise preventing the flow of water coliform, and failure to conduct follow-up through the tap(s). monitoring after corrective disinfection and  Providing public notification to passengers and crew per 

flushing. [40 CFR 141.805]. 

 Providing alternatives to water from the aircraft water 

system (e.g., bottled water, antiseptic hand gels, etc.). 

(2) Conduct disinfection and flushing. (3) Collect follow-up samples. Once samples are collected, aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(5) requires the violation be reported to EPA within 

10 calendar days of discovery of the failure. 

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Violation Required Response for the Violation (including citation) 

Failure to collect follow-up samples as The responses specified for this violation under 40 CFR 

a result of an E. coli-positive result [40 141.803(c)(2)(i), (ii), and (iii) are as follows: 

CFR 141.810(a)]. This includes failure to (1) Restrict public access to aircraft water system within 24 hours 

conduct follow-up monitoring after which includes: corrective disinfection and flushing when a  Physically disconnecting/shutting off aircraft water system, 

routine sample is E. coli-positive. where feasible, or otherwise preventing the flow of water 

through the tap(s). 

 Providing public notification to passengers and crew per 

[40 CFR 141.805]. 

 Providing alternatives to water from the aircraft water 

system (e.g., bottled water, antiseptic hand gels, etc.). 

(2) Conduct disinfection and flushing prior to resumption of unrestricted public access to the aircraft water system, or no later than 72 hours if the aircraft water system cannot be physically 

disconnected/shut off to the crew and passengers. (3) Collect follow-up samples. Follow-up samples results must be 

total coliform-negative before aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(5) requires the violation be reported to EPA within 10 calendar days of discovery of the failure. 

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Violation Required Response for the Violation (including citation) 

Failure to board water from a safe The responses specified for this violation under 40 CFR 

watering point (non-E. coli-positive 141.803(c)(3)(ii) are as follows: 

event) [40 CFR 141.810(a)]. When an air (1) Restrict public access to aircraft water system within 72 hours 

carrier becomes aware of a non-E. coli- which includes: positive event resulting from water that  Physically disconnecting/shutting off aircraft water system, 

has been boarded from a watering point where feasible, or otherwise preventing the flow of water not in accordance with FDA regulations, through the tap(s). does not meet EPA standards for transient  Providing public notification to passengers and crew per 

non-community water systems, or has [40 CFR 141.805]. been determined unsafe due to  Providing alternatives to water from the aircraft water noncompliance with procedures for system (e.g., bottled water, antiseptic hand gels, etc.). boarding water specified in the O&M plan. (2) Conduct disinfection and flushing. 

(3) Collect follow-up samples. Once samples are collected, aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(4) requires the violation be reported to EPA within 

10 calendar days of the event. 

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Violation Required Response for the Violation (including citation) 

Failure to board water from a safe The responses specified for this violation under 40 CFR 

watering point (E. coli-positive event) 141.803(c)(2)(i), (ii), and (iii) are as follows: 

[40 CFR 141.810(a)]. When an air carrier (1) Restrict public access to aircraft water system within 24 hours 

becomes aware of an E. coli-positive which includes: 

event resulting from water that has been  Physically disconnecting/shutting off aircraft water system, 

boarded from a watering point not in where feasible, or otherwise preventing the flow of water accordance with FDA regulations, does through the tap(s). not meet EPA standards for transient non-  Providing public notification to passengers and crew per 

community water systems, or has been [40 CFR 141.805]. determined unsafe due to noncompliance  Providing alternatives to water from the aircraft water with procedures for boarding water system (e.g., bottled water, antiseptic hand gels, etc.). specified in the O&M plan. (2) Conduct disinfection and flushing prior to resumption of 

unrestricted public access to the aircraft water system, or no later than 72 hours if the aircraft water system cannot be physically disconnected/shut off to the crew and passengers. (3) Collect follow-up samples. Follow-up samples results must be 

total coliform-negative before aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(4) requires the violation be reported to EPA within 10 calendar days of the event. 

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Violation Required Response for the Violation (including citation) 

Any E. coli-positive sample in any The responses specified for this violation under 40 CFR 

monitoring period [40 CFR 141.810(b)] 141.803(c)(2)(i), (ii), and (iii) are as follows: 

(routine and repeat samples are used in (1) Restrict public access to aircraft water system within 24 hours 

this determination). which includes: 

 Physically disconnecting/shutting off aircraft water system, 

where feasible, or otherwise preventing the flow of water through the tap(s). 

 Providing public notification to passengers and crew per 

[40 CFR 141.805]. 

 Providing alternatives to water from the aircraft water 

system (e.g., bottled water, antiseptic hand gels, etc.). 

(2) Conduct disinfection and flushing prior to resumption of unrestricted public access to the aircraft water system, or no later than 72 hours if the aircraft water system cannot be physically disconnected/shut off to the crew and passengers. (3) Collect follow-up samples. Follow-up samples results must be total coliform-negative before aircraft water can be provided for human consumption. 

40 CFR 141.806(b)(4) requires the violation be reported to EPA within 10 calendar days of the event. 

Failure to comply with the reporting There are no rule citations specifying actions in response to this 

and recordkeeping requirements [40 violation. Actions will be determined by EPA. CFR 141.810(d)]. This includes failure to report required information, results, or actions to EPA; and failure to retain records for the required time period or failure to retain the required information. 

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Violation Required Response for the Violation (including citation) 

Failure to conduct a self-inspection or address a deficiency in accordance with the O&M plan [40 CFR 141.810(e)]. Self-inspections are required every 5 years. Deficiencies noted during selfinspections or compliance audits must be addressed within 90 days of identification of the deficiency, or where such deficiency is identified during extended or heavy maintenance, before the aircraft is put back into service. 

There are no rule citations specifying actions in response to this violation. Actions will be determined by EPA. 

Failure to develop a coliform sampling plan [40 CFR 141.810(f)]. Coliform sampling plans must be developed by April 19, 2011, for existing aircraft, or within the first calendar quarter of initial operation for new aircraft. 

There are no rule citations specifying actions in response to this violation. Actions will be determined by EPA. One of the actions would include developing the plan. 

Failure to develop and follow operations and maintenance plan [40 CFR 141.810(f)]. Operations and maintenance plans must be developed by April 19, 2011, for existing aircraft, or within the first calendar quarter of initial operation for new aircraft. 

There are no rule citations specifying actions in response to this violation. Actions will be determined by EPA. One of the actions would include developing the plan. 

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9. Other Water System Considerations 

This chapter offers guidance on operations and management considerations for aircraft water 

systems that are beyond the regulatory requirements of the ADWR. These are not required 

practices, but this information may assist with maintaining the quality of water provided by 

aircraft water systems. 

This chapter includes sections that address efforts to maintain water quality by limiting bacterial 

growth in water systems; supplemental treatment considerations; and additional communications 

strategies and recordkeeping practices. Although many of the practices may apply to a given 

aircraft water system or specific condition, they will not be applicable to all systems. 

9.1 Water Age and Biofilm Management Considerations 

Under certain conditions, the design and/or operation of aircraft water systems can cause water 

to be held for extended periods of time. Increased water age (described as the length of time 

water remains in the aircraft water system after it has been boarded and before it is used or 

flushed from the system) is a major factor in water quality degradation. Water quality 

degradation may include formation of disinfection byproducts (DBPs), accumulation of 

sediments, microbial growth such as biofilms, nitrification, taste and odor problems, and 

increased disinfectant decay. Thoroughly disinfecting and flushing the aircraft water system may 

help minimize and/or correct these problems. 

Biofilm are thought to exist in all distribution systems and are accepted as a normal part of the 

distribution system. Biofilms are growths of microorganisms that are typically attached to the 

interior surfaces of piping, storage, and plumbing fixtures. Biofilm can entrain substances in the 

water (including waterborne pathogens) and later release these substances into the water, causing 

water quality problems such as tastes and odors and increased disinfectant demand. Biofilm can 

increase pipe corrosion, can affect pipe hydraulics, and make microbial disinfection more 

difficult. Microbes can enter distribution systems through physical gaps in the distribution 

system piping or tank, or due to contamination during the water transfer process to the aircraft. 

Microbial growth and biofilm development are a concern when an aircraft water system 

experiences excessive water age, higher temperatures, and when nutrients are present in the 

water. 

Some air carriers “top off” or add water to the onboard storage tank on a repeated basis without 

completely draining the storage tank. This practice can cause stored water to have a longer water 

age. Many air carriers have existing procedures for draining a water system if the aircraft is 

going to be parked for an extended period of time. Some also have procedures for draining the 

water system due to either very cold or very warm ambient air temperatures. These practices 

protect the aircraft water system piping from breakage due to freezing, limit bacterial growth 

which can be enhanced in warm water, and also help to minimize water age. Draining of tanks 

every three days is a common practice for some air carriers where they do not have a high turnover of the water through frequent high-volume boarding events. 

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Recommended practices to minimize water age include the following (when and where it is 

appropriate to dispose of the water should be considered): 

1.	 Drain and refill tank frequently , when feasible, (e.g., daily, especially when aircraft are 

parked overnight in warm climates). 

2.	 Limit the amount of water carried on the aircraft to only what is needed (due to the 

weight of water, air carriers typically do this but it is also a good practice for minimizing 

water age by maximizing water turn-over). 

3.	 Conduct periodic disinfection and flushing more frequently than the manufacturer’s 

recommendations if bacterial growth or water age is a concern. It is the responsibility of 

the air carrier to ensure that any increase in frequency would not result in damage to the 

aircraft water system’s components. 

4.	 Disinfect and flush the aircraft water system before serving water to the public if the 

water system has been worked on or the aircraft has been inactive or stored for an 

extended period (e.g., 3-days or more). 

9.2 Considerations for Supplemental Treatment 

The rule applies to aircraft that board only finished water for human consumption. In the 

ADWR, supplemental treatment is not required to be used with finished water that has been 

boarded on the aircraft. EPA believes the rule prescribes the minimum requirements necessary to 

provide safe drinking water to passengers and crew onboard aircraft, including the requirement 

to board finished water; boarding finished water in accordance with FDA requirements; 

transferring the water from the watering point to the aircraft in a manner that ensures it will not 

become contaminated during the transfer; compliance monitoring; corrective action; appropriate 

training of personnel; implementation of a water system operation and maintenance plan; selfinspections; compliance audits; reporting; and recordkeeping. However, supplemental treatment 

can provide an additional barrier of protection in the event of a failure in any of the basic 

protection barriers required under this rule. EPA believes the basic requirements of the ADWR, 

when performed consistently and diligently by the air carriers and their agents, provide assurance 

that drinking water onboard aircraft is safe for passengers and crew. Based on the information 

that EPA has at the time of this rulemaking, there is not sufficient information or data to support 

a requirement of supplemental treatment for aircraft water systems or for reducing any of the 

minimum requirements based on the installation of supplemental treatment. However, EPA plans 

to revisit this issue as part of the Six-Year review of the ADWR under SDWA Section 

1412(b)(9) and as more data become available. 

9.2.1 Type of Treatment Provided 

Specific types of supplemental treatment installed on an aircraft public water system may 

provide an additional barrier against contamination. Installation of supplemental disinfection 

treatment units is an established practice in some corporate and charter jet fleets as well as in 

some new commercial passenger aircraft. Ultraviolet light disinfection systems are examples of 

supplemental disinfection units that are installed on some aircraft. 

Guidance Manual 108 

for the ADWR – Interim Final 

October 2010 
 

Supplemental treatment consisting of carbon adsorption and/or particle removal filters is 

intended to improve the aesthetic quality of the water and not to provide microbial inactivation. 

If not properly maintained, these units may harbor bacteria and promote biofilm growth. 

Any supplemental treatment units installed onboard existing or new aircraft must be acceptable 

to FAA and FDA and must be installed, operated, and maintained in accordance with the 

manufacturer’s plans and specifications and FAA requirements. Supplemental treatment units 

must not cause the water to violate the standards prescribed in the ADWR. 

9.2.2 Supplemental Treatment Maintenance and Operator Training 

It is important to educate aircraft maintenance personnel on the details regarding supplemental 

treatment, including ensuring the equipment is properly installed, operated, maintained, and 

inspected. Manufacturer’s recommendations for installation, operation, and maintenance, as well 

as any issues that have been encountered, should be reviewed periodically and incorporated into 

the training program and the operations and maintenance plan for the aircraft water system. 

The consequences of improperly installed, operated, or maintained treatment equipment can 

include the degradation of the quality of the water and a false-sense of confidence in the water 

provided to passengers and crew. 

9.3 Communication Strategy 

Stationary public water systems serving airports are usually community water systems and are 

required to meet more requirements than are aircraft water systems which are transient noncommunity water systems. Despite these requirements, stationary public water systems may 

experience temporary periods of non-compliance or water quality degradation. Accordingly, 

public water systems that sell or otherwise provide drinking water to other public water systems 

(i.e., to consecutive systems) are required to give public notice to the owner or operator of the 

consecutive system; the consecutive system is responsible for providing public notice to the 

persons it serves. Even though it is the responsibility of the stationary system to provide public 

notice to its users, it may be beneficial for airport personnel to establish strong communication 

links to the providers of water to the airport to ensure that the airport receives any drinking water 

public notice in a timely manner. Likewise, air carrier personnel should establish communication 

links with the appropriate airport personnel to ensure that they are notified immediately of any 

circumstances that may affect the quality of water supplied to the aircraft. Effective and timely 

communications between the public water system, airport, and air carrier may help the air carrier 

avoid unknowingly boarding water that does not meet the NPDWRs. Accordingly, EPA plans to 

work with FDA to help facilitate communication between all of the responsible parties along the 

aircraft water supply and transfer chain. 

9.4 Recordkeeping Practices for Boarding of Water 

Air carriers are not required by the ADWR to record the volume of water that is boarded onto 

aircraft, the date and time of boarding, or the location of boarding. The ADWR did not include 

such a requirement because of the large number of records the requirement would entail, and the 

limited value of the information. The information was believed to be of limited use since only 

finished water from watering points that are in accordance with FDA regulations is to be 

Guidance Manual 109 

for the ADWR – Interim Final 

October 2010 
 

boarded, and water from several sources may be mixed within a given aircraft water system at 

any time. This information, however, may be valuable to the air carrier in the event that onboard 

water is later implicated in a public health problem, or the onboard water is tested and found to 

contain coliform bacteria. If the water could be traced back to a specific location, the water 

quality issue could potentially be identified and resolved. Although the ADWR does not require 

information on water that is boarded, air carriers may implement this recordkeeping practice if 

desired. 

Guidance Manual 110 

for the ADWR – Interim Final 

October 2010 
 

 

References 

USEPA Office of Ground Water and Drinking Water. 2002a. Health Risks From Microbial 

Growth and Biofilms in Drinking Water Distribution Systems. Available at: 

http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper_tcr_biofilms.pdf . 

USEPA Office of Ground Water and Drinking Water. 2002b. Effects of Water Age on 

Distribution System Water Quality. Available at: 

http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper_tcr_waterdistribution.pdf 

USEPA Office of Ground Water and Drinking Water. January 2005. Manual for the Certification 

of Laboratories Analyzing Drinking Water: Criteria and Procedures Quality Assurance. 5th 

Edition. (EPA 815-R-05-004). 

WHO 2009. Guide to Hygiene and Sanitation in Aviation. 3rd Edition. Geneva, World Health 

Organization. Available at: 

http://www.who.int/water_sanitation_health/hygiene/ships/guide_hygiene_sanitation_aviation_3 

_edition.pdf 

Guidance Manual 111 

for the ADWR – Interim Final 

October 2010 
 

This Page Intentionally Left Blank. 

Guidance Manual 112
 for the ADWR – Interim Final
 

October 2010
 
Appendix A 

Federal Register Publication of the Final ADWR Requirements 
This Page Intentionally Left Blank 

sroberts on DSKD5P82C1PROD with RULES

53618 Federal Register / Vol. 74, No. 200 / Monday, October 19, 2

Canada. 2007a. Health Canada. Healthy 

009 / Rules and Regulations 

■ 2. Part 141 is amended by adding a 

new subpart X to read as follows: 

Subpart X—Aircraft Drinking Water Rule 

Sec. 

141.800 Applicability and compliance date. 

141.801 Definitions. 

141.802 Coliform sampling plan. 

141.803 Coliform sampling. 

141.804	 Aircraft water system operations 

and maintenance plan. 

141.805	 Notification to passengers and 

crew. 

141.806 Reporting requirements. 

141.807 Recordkeeping requirements. 

141.808 Audits and inspections. 

141.809 Supplemental treatment. 

141.810 Violations. 

Authority: 42 U.S.C. 300f, 300g–1, 300g

2, 300g–3, 300g–4, 300g–5, 300g–6, 300j–

300j–9, and 300j–11. 

– 

4, 

Agency. No substantive comments were 

provided by NDWAC. 

On August 8, 2007, EPA consulted 

with the Department of Health and 

Human Services (HHS) on the proposed 

rule. EPA also consulted with HHS on 

Living. Aircraft Inspection Program— 

Frequently Asked Questions. http:// 

www.hc-sc.gc.ca/hl-vs/travel-voyage/ 

general/inspection/airplane-aeronefs 

_e.html. 

the final rule and received a favorable 

response to the Agency’s novel 

approach and development of the 

ADWR and no issues were raised as a 

result of the consultation. 

L. Plain Language 

Executive Order 12866 encourages 

Federal agencies to write rules in plain 

language. Whenever possible, EPA 

wrote the action in active voice, with 

simplified language, and displayed 

information in tables to make it easier 

for the public to read and understand. 

M. Congressional Review Act 

The Congressional Review Act, 5 

U.S.C. 801 et seq., as added by the Small 

Business Regulatory Enforcement 

Fairness Act of 1996, generally provides 

that before a rule may take effect, the 

agency promulgating the rule must 

submit a rule report, which includes a 

copy of the rule, to each House of the 

Congress and to the Comptroller General 

of the United States. EPA will submit a 

report containing this rule and other 

required information to the U.S. Senate, 

the U.S. House of Representatives, and 

the Comptroller General of the United 

States prior to publication of the rule in 

the Federal Register. A Major rule 

cannot take effect until 60 days after it 

is published in the Federal Register. 

This action is not a ‘‘major rule’’ as 

defined by 5 U.S.C. 804(2). This rule 

will be effective November 18, 2009. 

N. Analysis of the Likely Effect of 

Compliance With the ADWR on the 

Technical, Financial, and Managerial 

Capacity of Public Water Systems 

Section 1420(d)(3) of SDWA, as 

amended, requires that, in promulgating 

a NPDWR, the Administrator shall 

include an analysis of the likely effect 

of compliance with the regulation on 

the technical, managerial, and financial 

(TMF) capacity of regulated entities. 

This analysis can be found in the 

Economic and Supporting Analyses 

document in EPA’s public docket. 

Analyses reflect only the impact of new 

or revised requirements, as established 

by the ADWR; the impacts of previously 

established requirements are not 

considered. 

VIII. References 

ATA (Air Transport Association of America, 

Inc.) 2003. Air Transport Association: 

Aircraft Drinking Water Sampling Program, 

Final Report: December 31, 2003. http:// 

www.airlines.org. 

Canada. 2007b. Health Canada. Healthy 

Living. Advisory. Health Canada cautions 

air travelers with compromised immune 

systems regarding water quality on aircraf

http://www.hc-sc.gc.ca/ahc-asc/media/ 

advisories-avis/2006/2006_53_e.html. 

Davison, A., Howard, G., Stevens, M., et al. 

2005. Water, Sanitation and Health 

Protection and the Human Environment, 

World Health Organization, Geneva. Wate

Safety Plans: Managing drinking-water 

quality from catchment to consumer. 

http://www.who.int/water_

sanitation_health/. 

Lehtola, M., Torvinen, E., Kusnetsov, J., et a

2007. Survival of Mycrobacterium avium, 

Legionella pneumophila, Escherichia coli,

and Caliciviruses in Drinking WaterAssociated Biofilms Grown under HighShear Turbulent Flow. Applied and 

Environmental Microbiology, 73:2854– 

2859. 

USEPA. 1986. Water Supply Guidance 29: 

Plan for Implementation of the Safe 

Drinking Water Act on Interstate Carrier 

Conveyance. 

USEPA. 1989. National Interim Primary 

Drinking Water Regulations; Total Colifor

Rule; Final Rule. Part III. Federal Register

54:124:27544. (June 29, 1989). 

USEPA. 2008. Economic and Supporting 

Analyses; Aircraft Drinking Water Rule. 

EPA 816–D–08–002. 

USEPA. 2008. DRAFT Information Collectio

Request for the National Primary Drinking

Water Regulations: Aircraft Drinking Wate

Rule. EPA 816–D–08–001. 

USFDA. 2005. Title 21—Food and Drugs, 

Chapter 1—Food and Drug Administratio

Part 1250—Interstate Conveyance 

Sanitation. http://www.accessdata.fda. 

gov/. 

WHO. 1997. HACCP—Introducing the 

Hazard Analysis and Critical Control Poin

System. Geneva, Switzerland: WHO. 

WHO. 2004. Guidelines for Drinking-Water 

Quality. 3rd Edition, Volume 1— 

Recommendations, Chapter 4 Water 

Supply Plans. Geneva, Switzerland: WHO

List of Subjects in 40 CFR Part 141 

Environmental protection, Chemicals

Indian-lands, Intergovernmental 

relations, Radiation protection, 

Reporting and recordkeeping 

requirements, Water supply. 

Dated: October 5, 2009. 

Lisa P. Jackson, 

Administrator. 

■ For the reasons set out in the 

preamble, title 40, chapter 1 of the Cod

of Federal Regulations is to be amende

as follows: 

PART 141—NATIONAL PRIMARY 

DRINKING WATER REGULATIONS 

■ 1. The authority citation for part 141 

continues to read as follows: 

. 

. 

t

r

l

m

, 

n

r

n,

t 

. 

, 

e 

d 

Subpart X—Aircraft Drinking Water 

Rule 

§ 141.800 Applicability and compliance 

date. 

(a) Applicability. The requirements of 

this subpart constitute the National 

Primary Drinking Water Regulations for 

aircraft that are public water systems 

and that board only finished water for 

human consumption. Aircraft public 

water systems are considered transient 

non-community water systems 

(TNCWS). To the extent there is a 

conflict between the requirements in 

this subpart and the regulatory 

requirements established elsewhere in 

this part, this subpart governs. 

(b) Compliance Date. Aircraft public 

water systems must comply, unless 

otherwise noted, with the requirements 

of this subpart beginning October 19, 

2011. Until this compliance date, air 

carriers remain subject to existing 

national primary drinking water 

regulations. 

§ 141.801 Definitions. 

As used in this subpart, the term: 

Administrator means the 

Administrator of the United States 

Environmental Protection Agency or 

his/her authorized representative. 

Air Carrier means a person who 

undertakes directly by lease, or other 

arrangement, to engage in air 

transportation. The air carrier is 

responsible for ensuring all of the 

aircraft it owns or operates that are 

public water systems comply with all 

provisions of this subpart. 

Aircraft means a device that is used 

or intended to be used for flight in the 

air. 

Aircraft Water System means an 

aircraft that qualifies as a public water 

system under the Safe Drinking Water 

Act and the national primary drinking 

water regulations. The components of 
Federal Register / Vol. 74, No. 200 / Monday, October 19, 2009 / Rules and Regulations 53619 

TABLE B–1—ROUTINE DISINFECTION AND FLUSHING AND ROUTINE SAMPLE FREQUENCIES 

Minimum routine disinfection & flushing per 

aircraft 

Minimum frequency of routine samples per 

aircraft 

At least 4 times per year = At least once within every three-month pe- At least 1 time per year = At least once within every twelve-month period (quarterly). riod (annually). 

At least 3 times per year = At least once within every four-month pe- At least 2 times per year = At least once within every six-month period 

riod. (semi-annually). 


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an aircraft water system include the 

water service panel, the filler neck of 

the aircraft finished water storage tank, 

and all finished water storage tanks, 

piping, treatment equipment, and 

plumbing fixtures within the aircraft 

that supply water for human 

consumption to passengers or crew. 

Aircraft Water System Operations and 

Maintenance Plan means the schedules 

and procedures for operating, 

monitoring, and maintaining an aircraft 

water system that is included in an 

aircraft operation and maintenance 

program accepted by the Federal 

Aviation Administration. (14 CFR part 

43, 14 CFR part 91, 14 CFR part 121) 

Finished Water means water that is 

introduced into the distribution system 

of a public water system and is intended 

for distribution and consumption 

without further treatment, except as 

treatment necessary to maintain water 

quality in the distribution system (e.g., 

supplemental disinfection, addition of 

corrosion control chemicals). (40 CFR 

141.2) 

Human Consumption means drinking, 

bathing, showering, hand washing, teeth 

brushing, food preparation, 

dishwashing, and maintaining oral 

hygiene. 

Self Inspection means an onsite 

review of the aircraft water system, 

including the water service panel, the 

filler neck of the aircraft finished water 

storage tank; all finished water storage 

tanks, piping, treatment equipment, and 

plumbing fixtures; and a review of the 

aircraft operations, maintenance, 

monitoring, and recordkeeping for the 

purpose of evaluating the adequacy of 

such water system components and 

practices for providing safe drinking 

water to passengers and crew. 

Watering point means the water 

supply, methods, and facilities used for 

the delivery of finished water to the 

aircraft. These facilities may include 

water trucks, carts, cabinets, and hoses. 

§ 141.802 Coliform sampling plan. 

(a) Each air carrier under this subpart 

must develop a coliform sampling plan 

covering each aircraft water system 

owned or operated by the air carrier that 

identifies the following: 

(1) Coliform sample collection 

procedures that are consistent with the 

requirements of § 141.803(a) and (b). 

(2) Sample tap location(s) 

representative of the aircraft water 

system as specified in § 141.803(b)(2) 

and (b)(4). 

(3) Frequency and number of routine 

coliform samples to be collected as 

specified in § 141.803(b)(3). 

(4) Frequency of routine disinfection 

and flushing as specified in the 

operations and maintenance plan under 

§ 141.804. 

(5) Procedures for communicating 

sample results promptly so that any 

required actions, including repeat and 

follow-up sampling, corrective action, 

and notification of passengers and crew, 

will be conducted in a timely manner. 

(b) Each air carrier must develop a 

coliform sampling plan for each aircraft 

with a water system meeting the 

definition of a public water system by 

April 19, 2011. 

(c) The coliform sampling plan must 

be included in the Aircraft Water 

System Operations and Maintenance 

Plan required in § 141.804. Any 

subsequent changes to the coliform 

sampling plan must also be included in 

the Aircraft Water System Operations 

and Maintenance Plan required in 

§ 141.804. 

§ 141.803 Coliform sampling. 

(a) Analytical Methodology. Air 

carriers must follow the sampling and 

analysis requirements under this 

section. 

(1) The standard sample volume 

required for total coliform analysis, 

regardless of analytical method used, is 

100 mL. 

(2) Air carriers need determine only 

the presence or absence of total 

coliforms and/or E. coli; a determination 

of density of these organisms is not 

required. 

(3) Air carriers must conduct analyses 

for total coliform and E. coli in 

accordance with the analytical methods 

approved in § 141.21(f)(3) and 

141.21(f)(6). 

(4) The time from sample collection to 

initiation of analysis may not exceed 30 

hours. Systems are encouraged but not 

required to hold samples below 10°C 

during transit. 

(5) The invalidation of a total coliform 

sample result can be made only by the 

Administrator in accordance with 

§ 141.21(c)(1)(i), (ii), or (iii) or by the 

certified laboratory in accordance with 

§ 141.21(c)(2). 

(6) Certified laboratories. For the 

purpose of determining compliance 

with this subpart, samples may be 

considered only if they have been 

analyzed by a laboratory certified by a 

State or EPA. For the purposes of this 

paragraph, ‘‘State’’ refers to a State or 

Tribe that has received primacy for 

public water systems (other than aircraft 

water systems) under section 1413 of 

SDWA. 

(b) Routine Monitoring. For each 

aircraft water system, the sampling 

frequency must be determined by the 

disinfection and flushing frequency 

recommended by the aircraft water 

system manufacturer, when available, 

and as identified in the operations and 

maintenance plan in § 141.804. 

(1) Except as provided in paragraph 

(b)(2) of this section, the air carrier must 

collect two 100 mL total coliform 

routine samples at the frequency 

specified in the sampling plan in 

§ 141.802 and in accordance with 

paragraph (b)(3) of this section; 

(2) The air carrier may collect one 100 

mL total coliform routine sample at the 

frequency specified in the sampling 

plan in § 141.802 for aircraft with a 

removable or portable tank that is 

drained every day of passenger service, 

and the aircraft has only one tap. 

Aircraft meeting the requirements of 

this paragraph do not have to comply 

with paragraph (b)(4) of this section. 

(3) Air carriers must perform routine 

monitoring for total coliform at a 

frequency corresponding to the 

frequency of routine disinfection and 

flushing as specified in the Table b–1 

(Routine Disinfection and Flushing and 

Routine Sample Frequencies). Air 

carriers must follow the disinfection 

and flushing frequency recommended 

by the aircraft water system 

manufacturer, when available. Where 

the aircraft water system manufacturer 

does not specify a recommended routine 

disinfection and flushing frequency, the 

air carrier must choose a frequency from 

Table b–1 (Routine Disinfection and 

Flushing and Routine Sample 

Frequencies): 
53620 Federal Register / Vol. 74, No. 200 / Monday, October 19, 2009 / Rules and Regulations 


sroberts on DSKD5P82C1PROD with RULES

TABLE B–1—ROUTINE DISINFECTION AND FLUSHING AND ROUTINE SAMPLE FREQUENCIES—Continued 

Minimum routine disinfection & flushing per 

aircraft 

Minimum frequency of routine samples per 

aircraft 

At least 2 times per year = At least once within every six-month period At least 4 times per year = At least once within every three-month pe­

(semi-annually). riod (quarterly). 

At least 1 time per year or less = At least once within every twelve- At least 12 times per year = At least once every month (monthly). 

month period (annually) or less. 

(4) One sample must be taken from a 

lavatory and one from a galley; each 

sample must be analyzed for total 

coliform. If only one water tap is located 

in the aircraft water system due to 

aircraft model type and construction, 

then a single tap may be used to collect 

two separate 100 mL samples. 

(5) If any routine, repeat, or follow-up 

coliform sample is total coliformpositive, the air carrier must analyze 

that total coliform-positive culture 

medium to determine if E. coli is 

present. 

(6) Routine total coliform samples 

must not be collected within 72 hours 

after completing routine disinfection 

and flushing procedures. 

(c) Routine Coliform Sample Results. 

(1) Negative Routine Coliform Sample 

Results. If all routine sample results are 

total coliform-negative, then the air 

carrier must maintain the routine 

monitoring frequency for total coliform 

as specified in the sampling plan in 

§ 141.802. 

(2) Positive Routine E. coli Sample 

Results. If any routine sample is E. colipositive, the air carrier must perform all 

of the following: 

(i) Restrict Public Access. Restrict 

public access to the aircraft water 

system in accordance with paragraph (d) 

of this section as expeditiously as 

possible, but in no case later than 24 

hours after the laboratory notifies the air 

carrier of the E. coli-positive result or 

discovery of the applicable failure as 

specified in paragraphs (g) and (h) of 

this section. All public access 

restrictions, including applicable public 

notification requirements, must remain 

in-place until the aircraft water system 

has been disinfected and flushed and a 

complete set of follow-up samples is 

total coliform-negative; and 

(ii) Disinfect and Flush. Conduct 

disinfection and flushing in accordance 

with § 141.804(b)(2). If the aircraft water 

system cannot be physically 

disconnected or shut-off, or the flow of 

water otherwise prevented through the 

tap(s), then the air carrier must disinfect 

and flush the system no later than 72 

hours after the laboratory notifies the air 

carrier of the E. coli-positive result or 

discovery of the applicable failure as 

specified in paragraphs (g) and (h) of 

this section; and 

(iii) Follow-up Sampling. Collect 

follow-up samples in accordance with 

paragraph (e) of this section. A complete 

set of follow-up sample results must be 

total coliform-negative before the air 

carrier provides water for human 

consumption from the aircraft water 

system and returns to the routine 

monitoring frequency as specified in the 

sampling plan required by § 141.802. 

(3) Positive Routine Total Coliform 

Sample Results. If any routine sample is 

total coliform-positive and E. colinegative, then the air carrier must 

perform at least one of the following 

three corrective actions and continue 

through with that action until a 

complete set of follow-up or repeat 

samples is total coliform-negative: 

(i) Disinfect and Flush. In accordance 

with § 141.804(b)(2), conduct 

disinfection and flushing of the system 

no later than 72 hours after the 

laboratory notifies the air carrier of the 

total coliform-positive and E. colinegative result. After disinfection and 

flushing is completed, the air carrier 

must collect follow-up samples in 

accordance with paragraph (e) of this 

section prior to providing water for 

human consumption from the aircraft 

water system. A complete set of followup sample results must be total 

coliform-negative before the air carrier 

returns to the routine monitoring 

frequency as specified in the sampling 

plan required by § 141.802; or 

(ii) Restrict Public Access. In 

accordance with paragraph (d) of this 

section, restrict public access to the 

aircraft water system as expeditiously as 

possible, but in no case later than 72 

hours after the laboratory notifies the air 

carrier of the total coliform-positive and 

E. coli-negative result or discovery of 

the applicable failure as specified in 

paragraphs (f), (g), and, (i) of this 

section. All public access restrictions, 

including applicable public notification 

requirements, must remain in-place 

until the aircraft water system has been 

disinfected and flushed, and a complete 

set of follow-up samples has been 

collected. The air carrier must conduct 

disinfection and flushing in accordance 

with § 141.804(b)(2). After disinfection 

and flushing is completed, the air 

carrier must collect follow-up samples 

in accordance with paragraph (e) of this 

section prior to providing water for 

human consumption from the aircraft 

water system. A complete set of followup sample results must be total 

coliform-negative before the air carrier 

returns to the routine monitoring 

frequency as specified in the sampling 

plan required by § 141.802; or 

(iii) Repeat Sampling. Collect three 

100 mL repeat samples no later than 24 

hours after the laboratory notifies the air 

carrier of the routine total coliformpositive and E. coli-negative result. 

Repeat samples must be collected and 

analyzed from three taps within the 

aircraft as follows: The tap which 

resulted in the total coliform-positive 

sample, one other lavatory tap, and one 

other galley tap. If fewer than three taps 

exist, then a total of three 100 mL 

samples must be collected and analyzed 

from the available taps within the 

aircraft water system. 

(A) If all repeat samples are total 

coliform-negative, then the air carrier 

must maintain the routine monitoring 

frequency for total coliform as specified 

in the sampling plan in § 141.802. 

(B) If any repeat sample is E. colipositive, the air carrier must perform all 

the corrective actions as specified in 

paragraphs (c)(2)(i), (c)(2)(ii), and 

(c)(2)(iii) of this section. 

(C) If any repeat sample is total 

coliform-positive and E. coli-negative, 

then the air carrier must perform the 

corrective actions specified in 

paragraphs (c)(3)(i) or (c)(3)(ii) of this 

section, and continue through with that 

action until a complete set of follow-up 

samples is total coliform-negative. 

(d) Restriction of public access. 

Restriction of public access to the 

aircraft water system includes, but need 

not be limited to, the following: 

(1) Physically disconnecting or 

shutting off the aircraft water system, 

where feasible, or otherwise preventing 

the flow of water through the tap(s); 

(2) Providing public notification to 

passengers and crew in accordance with 

§ 141.805. 

(3) Providing alternatives to water 

from the aircraft water system, such as 

bottled water for drinking and coffee or 
Federal Register / Vol. 74, No. 200 / Monday, October 19, 2009 / Rules and Regulations 53621 


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tea preparation; antiseptic hand gels or 

wipes in accordance with 21 CFR part 

333—‘‘Topical Anti-microbial Drug 

Products for Over-the-Counter Human 

Use’’ in the galleys and lavatories; and 

other feasible measures that reduce or 

eliminate the need to use the aircraft 

water system during the limited period 

before public use of the aircraft water 

system is unrestricted. 

(e) Post Disinfection and Flushing 

Follow-up Sampling. Following 

corrective action disinfection and 

flushing, air carriers must comply with 

post disinfection and flushing follow-up 

sampling procedures that, at a 

minimum, consist of the following: 

(1) For each aircraft water system, the 

air carrier must collect a complete set of 

total coliform follow-up samples 

consisting of two 100 mL total coliform 

samples at the same routine sample 

locations as identified in paragraphs 

(b)(2) and (b)(4) of this section. 

(2) Follow-up samples must be 

collected prior to providing water to the 

public for human consumption from the 

aircraft water system. 

(3) If a complete set of follow-up 

samples is total coliform-negative, the 

air carrier must return to the routine 

monitoring frequency for total coliform 

as specified in the sampling plan 

required by § 141.802. 

(4) If any follow-up sample is E. colipositive, the air carrier must perform all 

the corrective actions as specified in 

paragraphs (c)(2)(i), (c)(2)(ii), and 

(c)(2)(iii) of this section. 

(5) If any follow-up sample is total 

coliform-positive and E. coli-negative 

the air carrier must restrict public access 

to the aircraft water system in 

accordance with paragraph (d) of this 

section as expeditiously as possible, but 

in no case later than 72 hours after the 

laboratory notifies the air carrier of the 

total coliform-positive and E. colinegative result. All public access 

restrictions, including applicable public 

notification requirements, must remain 

in-place until the aircraft water system 

has been disinfected and flushed in 

accordance with § 141.804(b)(2) and a 

complete set of follow-up samples is 

total coliform-negative. The air carrier 

must collect follow-up samples in 

accordance with paragraph (e) of this 

section. A complete set of follow-up 

sample results must be total coliformnegative before the air carrier provides 

water for human consumption from the 

aircraft water system and returns to the 

routine monitoring frequency for 

coliform as specified in § 141.802. 

(f) Failure to Perform Required 

Routine Disinfection and Flushing or 

Failure to Collect Required Routine 

Samples. If the air carrier fails to 

perform routine disinfection and 

flushing or fails to collect and analyze 

the required number of routine coliform 

samples, the air carrier must perform all 

the corrective actions as specified in 

paragraph (c)(3)(ii) of this section. 

(g) Failure to Collect Repeat or 

Follow-up Samples. If the air carrier 

fails to collect and analyze the required 

follow-up samples as a result of an E. 

coli-positive result, then the air carrier 

must perform all the corrective actions 

as specified in paragraphs (c)(2)(i), 

(c)(2)(ii), and (c)(2)(iii) of this section. If 

the air carrier fails to collect and 

analyze the required repeat samples or 

follow-up samples as a result of a total 

coliform-positive and E. coli-negative 

result, then the air carrier must perform 

all the corrective actions as specified in 

paragraph (c)(3)(ii) of this section. 

(h) Failure to Board Water from a Safe 

Watering Point (E. coli-positive). For the 

aircraft water system, the air carrier 

must perform all the corrective actions 

specified in paragraphs (c)(2)(i), 

(c)(2)(ii), and (c)(2)(iii) of this section 

when it becomes aware of an E. colipositive event resulting from: 

(1) Boarding water from a watering 

point not in accordance with FDA 

regulations (21 CFR part 1240 subpart 

E), or 

(2) Boarding water that does not meet 

NPDWRs applicable to transient noncommunity water systems (§§ 141.62 

and 141.63, as applied to TNCWS), 

(3) Boarding water that is otherwise 

determined to be unsafe due to noncompliance with the procedures 

specified in § 141.804(b)(6). 

(i) Failure to Board Water from a Safe 

Watering Point (non-E. coli-positive). 

For the aircraft water system, the air 

carrier must perform all the corrective 

actions specified in paragraphs (c)(3)(ii) 

of this section when it becomes aware 

of a non-E. coli-positive event resulting 

from: 

(1) Boarding water from a watering 

point not in accordance with FDA 

regulations (21 CFR part 1240, subpart 

E), 

(2) Boarding water that does not meet 

NPDWRs applicable to transient noncommunity water systems (§§ 141.62 

and 141.63, as applied to TNCWS), or 

(3) Boarding water that is otherwise 

determined to be unsafe due to noncompliance with the procedures 

specified in § 141.804(b)(6). 

§ 141.804 Aircraft water system operations 

and maintenance plan. 

(a) Each air carrier must develop and 

implement an aircraft water system 

operations and maintenance plan for 

each aircraft water system that it owns 

or operates. This plan must be included 

in a Federal Aviation Administration 

(FAA)-accepted air carrier operations 

and maintenance program (14 CFR part 

43, 14 CFR part 91, 14 CFR part 121). 

(b) Each aircraft water system 

operations and maintenance plan must 

include the following: 

(1) Watering Point Selection 

Requirement. All watering points must 

be selected in accordance with Food 

and Drug Administration (FDA) 

regulations (21 CFR part 1240, subpart 

E). 

(2) Procedures for Disinfection and 

Flushing. The plan must include the 

following requirements for procedures 

for disinfection and flushing of aircraft 

water system. 

(i) The air carrier must conduct 

disinfection and flushing of the aircraft 

water system in accordance with, or is 

consistent with, the water system 

manufacturer’s recommendations. The 

air carrier may conduct disinfection and 

flushing more frequently, but not less 

frequently, than the manufacturer 

recommends. 

(ii) The operations and maintenance 

plan must identify the disinfection 

frequency, type of disinfecting agent, 

disinfectant concentration to be used, 

and the disinfectant contact time, and 

flushing volume or flushing time. 

(iii) In cases where a recommended 

routine disinfection and flushing 

frequency is not specified by the aircraft 

water system manufacturer, the air 

carrier must choose a disinfection and 

flushing, and corresponding monitoring 

frequency specified in § 141.803(b)(3). 

(3) Follow-up Sampling. The plan 

must include the procedures for followup sampling in accordance with 

§ 141.803(e). 

(4) Training Requirements. Training 

for all personnel involved with the 

aircraft water system operation and 

maintenance provisions of this 

regulation must include, but is not 

limited to the following: 

(i) Boarding water procedures; 

(ii) Sample collection procedures; 

(iii) Disinfection and flushing 

procedures; 

(iv) Public health and safety reasons 

for the requirements of this subpart. 

(5) Procedures for Conducting Selfinspections of the Aircraft Water 

System. Procedures must include, but 

are not limited to, inspection of storage 

tank, distribution system, supplemental 

treatment, fixtures, valves, and backflow 

prevention devices. 

(6) Procedures for Boarding Water. 

The plan must include the following 

requirements and procedures for 

boarding water: 

(i) Within the United States, the air 

carrier must board water from watering 
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sroberts on DSKD5P82C1PROD with RULES

points in accordance with Food and 

Drug Administration (FDA) regulations 

(21 CFR part 1240, subpart E). 

(ii) A description of how the water 

will be transferred from the watering 

point to the aircraft in a manner that 

ensures it will not become contaminated 

during the transfer. 

(iii) A description of how the carrier 

will ensure that water boarded outside 

the United States is safe for human 

consumption. 

(iv) A description of emergency 

procedures that meet the requirements 

in § 141.803(h) and (i) that must be used 

in the event that the air carrier becomes 

aware that water was boarded to operate 

essential systems, such as toilets, but 

was boarded from a watering point not 

in accordance with FDA regulations, 

does not meet NPDWRs applicable to 

transient non-community water systems 

(§§ 141.62 and 141.63, as applied to 

TNCWSs), or is otherwise unsafe. 

(7) Coliform Sampling Plan. The air 

carrier must include the coliform 

sampling plan prepared in accordance 

with § 141.802. 

(8) Aircraft Water System Disconnect/ 

Shut-off, or Prevent Flow of Water 

Through the Tap(s) Statement. An 

explanation of whether the aircraft 

water system can be physically 

disconnected/shut-off, or the flow of 

water otherwise prevented through the 

tap(s) to the crew and passengers. 

(c) For existing aircraft, the air carrier 

must develop the water system 

operations and maintenance plan 

required by this section by April 19, 

2011; 

(d) For new aircraft, the air carrier 

must develop the operations and 

maintenance plan required in this 

section within the first calendar quarter 

of initial operation of the aircraft. 

(e) Any changes to the aircraft water 

system operations and maintenance 

plan must be included in the FAAaccepted air carrier operations and 

maintenance program. 

§ 141.805 Notification to passengers and 

crew. 

(a) Air carriers must give public 

notice for each aircraft in all of the 

following situations: 

(1) Public access to the aircraft water 

system is restricted in response to a 

routine, repeat or follow-up total 

coliform-positive or E. coli-positive 

sample result in accordance with 

§ 141.803(d); 

(2) Failure to perform required routine 

disinfection and flushing or failure to 

collect required routine samples in 

accordance with § 141.803(f); 

(3) Failure to collect the required 

follow-up samples in response to a 

sample result that is E. coli-positive in 

accordance with § 141.803(g); 

(4) Failure to collect the required 

repeat samples or failure to collect the 

required follow-up samples in response 

to a sample result that is total coliformpositive and E. coli-negative in 

accordance with § 141.803(g); 

(5) In accordance with § 141.803(h), 

the air carrier becomes aware of an E. 

coli-positive event resulting from water 

that has been boarded from a watering 

point not in accordance with FDA 

regulations (21 CFR part 1240, subpart 

E), or that does not meet NPDWRs 

applicable to transient non-community 

water systems, or that is otherwise 

determined to be unsafe due to noncompliance with the procedures 

specified in § 141.804(b)(6); 

(6) In accordance with § 141.803(i), 

the air carrier becomes aware of a nonE. coli-positive event resulting from 

water that has been boarded from a 

watering point not in accordance with 

FDA regulations (21 CFR part 1240, 

subpart E), or that does not meet 

NPDWRs applicable to transient noncommunity water systems, or that is 

otherwise determined to be unsafe due 

to non-compliance with the procedures 

specified in § 141.804(b)(6). 

(7) The Administrator, the carrier, or 

the crew otherwise determines that 

notification is necessary to protect 

public health. 

(b) Public notification: 

(1) Must be displayed in a 

conspicuous way when printed or 

posted; 

(2) Must not contain overly technical 

language or very small print; 

(3) Must not be formatted in a way 

that defeats the purpose of the notice; 

(4) Must not contain language that 

nullifies the purpose of the notice; 

(5) Must contain information in the 

appropriate language(s) regarding the 

importance of the notice, reflecting a 

good faith effort to reach the nonEnglish speaking population served, 

including, where applicable, an easily 

recognized symbol for non-potable 

water. 

(c) Public notification for paragraph 

(a)(1) of this section must meet the 

requirements of paragraph (b) of this 

section in addition to the following: 

(1) Public notification must include a 

prominently displayed, clear statement 

in each lavatory indicating that the 

water is non-potable and should not be 

used for drinking, food or beverage 

preparation, hand washing, teeth 

brushing, or any other consumptive use;

and 

(2) A prominent notice in the galley 

directed at the crew which includes: 

(i) A clear statement that the water is 

non-potable and should not be used for 

drinking, food or beverage preparation, 

hand washing, teeth brushing, or any 

other consumptive use; 

(ii) A description of the violation or 

situation triggering the notice, including 

the contaminant(s) of concern; 

(iii) When the violation or situation 

occurred; 

(iv) Any potential adverse health 

effects from the violation or situation, as 

appropriate, under paragraph (g) of this 

section; 

(v) The population at risk, including 

sensitive subpopulations particularly 

vulnerable if exposed to the 

contaminant in the drinking water; 

(vi) What the air carrier is doing to 

correct the violation or situation; and 

(vii) When the air carrier expects to 

return the system to unrestricted public 

access. 

(3) If passenger access to the water 

system is physically prevented through 

disconnecting or shutting off the water, 

or the flow of water prevented through 

the tap(s), or if water is supplied only 

to lavatory toilets, and not to any 

lavatory or galley taps, then only the 

notice specified in paragraph (c)(2) of 

this section is required. 

(4) Air carriers must initiate public 

notification when restriction of public 

access is initiated in accordance with 

§ 141.803(d) and must continue until 

the aircraft water system is returned to 

unrestricted public access. 

(d) Public notification for paragraphs 

(a)(2), (a)(4), and (a)(6) of this section 

must meet the requirements of 

paragraph (b) of this section in addition 

to the following: 

(1) Public notification must include a 

prominently displayed, clear statement 

in each lavatory indicating that the 

water is non-potable and should not be 

used for drinking, food or beverage 

preparation, hand washing, teeth 

brushing, or any other consumptive use; 

and 

(2) A prominent notice in the galley 

directed at the crew which includes: 

(i) A clear statement that the water is 

non-potable and should not be used for 

drinking, food or beverage preparation, 

hand washing, teeth brushing, or any 

other consumptive use; 

(ii) A clear statement that it is not 

known whether the water is 

contaminated because there was a 

failure to perform required routine 

disinfection and flushing; or a failure to 

perform required monitoring; or water 

was boarded from a watering point not 

in accordance with FDA regulations, or 

that does not meet NPDWRs applicable 

to transient noncommunity water 

systems, or that is otherwise determined 
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sroberts on DSKD5P82C1PROD with RULES

to be unsafe due to noncompliance with 

the procedures specified in 

§ 141.804(b)(6); 

(iii) When and where the unsafe water 

was boarded or when the specific 

monitoring or disinfection and flushing 

requirement was not met; 

(iv) Any potential adverse health 

effects from exposure to waterborne 

pathogens that might be in the water, as 

appropriate, under paragraph (g) of this 

section; 

(v) The population at risk, including 

sensitive subpopulations particularly 

vulnerable if exposed to the 

contaminant in the drinking water; and 

(vi) A statement indicating when the 

system will be disinfected and flushed 

and returned to unrestricted public 

access. 

(3) If passenger access to the water 

system is physically prevented through 

disconnecting or shutting off the water, 

or the flow of water prevented through 

the tap(s), or if water is supplied only 

to lavatory toilets, and not to any 

lavatory or galley taps, then only the 

notice specified in paragraph (d)(2) of 

this section is required. 

(4) Air carriers must initiate public 

notification when restriction of public 

access is initiated in accordance with 

§ 141.803(d) and must continue until 

the aircraft water system is returned to 

unrestricted public access. 

(e) Public notification for paragraphs 

(a)(3) and (a)(5) of this section must 

meet the requirements of paragraph (b) 

of this section in addition to the 

following: 

(1) Public notification must include a 

prominently displayed, clear statement 

in each lavatory indicating that the 

water is non-potable and should not be 

used for drinking, food or beverage 

preparation, hand washing, teeth 

brushing, or any other consumptive use; 

and 

(2) A prominent notice in the galley 

directed at the crew which includes: 

(i) A clear statement that the water is 

non-potable and should not be used for 

drinking, food or beverage preparation, 

hand washing, teeth brushing, or any 

other consumptive use; 

(ii) A clear statement that the water is 

contaminated and there was a failure to 

conduct required monitoring; or a clear 

statement that water is contaminated 

because water was boarded from a 

watering point not in accordance with 

FDA regulations, or that does not meet 

NPDWRs applicable to transient 

noncommunity water systems, or that is 

otherwise determined to be unsafe due 

to noncompliance with the procedures 

specified in § 141.804(b)(6); 

(iii) A description of the 

contaminant(s) of concern; 

(iv) When and where the unsafe water 

was boarded or when the specific 

monitoring requirement was not met; 

(v) Any potential adverse health 

effects from the situation, as 

appropriate, under paragraph (g) of this 

section; 

(vi) The population at risk, including 

sensitive subpopulations particularly 

vulnerable if exposed to the 

contaminant in the drinking water; 

(vii) A statement indicating what the 

air carrier is doing to correct the 

situation; and 

(viii) When the air carrier expects to 

return the system to unrestricted public 

access. 

(3) If passenger access to the water 

system is physically prevented through 

disconnecting or shutting off the water, 

or the flow of water prevented through 

the tap(s), or if water is supplied only 

to lavatory toilets, and not to any 

lavatory or galley taps, then only the 

notice specified in paragraph (e)(2) of 

this section is required. 

(4) Air carriers must initiate public 

notification when restriction of public 

access is initiated in accordance with 

§ 141.803(d) and must continue public 

notification until a complete set of 

required follow-up samples are total 

coliform-negative. 

(f) Public notification for paragraph 

(a)(7) of this section must meet the 

requirements of paragraph (b) of this 

section in addition to the following: 

(1) Notification must be in a form and 

manner reasonably calculated to reach 

all passengers and crew while on board 

the aircraft by using one or more of the 

following forms of delivery: 

(i) Broadcast over public 

announcement system on aircraft; 

(ii) Posting of the notice in 

conspicuous locations throughout the 

area served by the water system. These 

locations would normally be the galleys 

and in the lavatories of each aircraft 

requiring posting; 

(iii) Hand delivery of the notice to 

passengers and crew; 

(iv) Another delivery method 

approved in writing by the 

Administrator. 

(2) Air carriers must initiate public 

notification within 24 hours of being 

informed by EPA to perform notification 

and must continue notification for the 

duration determined by EPA. 

(g) In each public notice to the crew, 

air carriers must use the following 

standard health effects language that 

corresponds to the situations in 

paragraphs (a)(1) through (a)(6) of this 

section. 

(1) Health effects language to be used 

when public notice is initiated due to 

the detection of total coliforms only (not 

E. coli) in accordance with paragraph 

(a)(1) of this section: 

Coliform are bacteria that are naturally 

present in the environment and are used as 

an indicator that other, potentially harmful, 

bacteria may be present. Coliforms were 

found in [INSERT NUMBER OF SAMPLES 

DETECTED] samples collected and this is a 

warning of potential problems. If human 

pathogens are present, they can cause shortterm health effects, such as diarrhea, cramps, 

nausea, headaches, or other symptoms. They 

may pose a special health risk for infants, 

young children, some of the elderly, and 

people with severely compromised immune 

systems. 

(2) Health effects language to be used 

when public notice is initiated due to 

any E. coli-positive routine, repeat, or 

follow-up sample in accordance with 

paragraph (a)(1) of this section: 

E. coli are bacteria whose presence 

indicates that the water may be contaminated 

with human or animal wastes. Microbes in 

these wastes can cause short-term health 

effects, such as diarrhea, cramps, nausea, 

headaches, or other symptoms. They may 

pose a special health risk for infants, young 

children, some of the elderly, and people 

with severely compromised immune systems. 

(3) Health effects language to be used 

when public notice is initiated due to a 

failure to conduct routine monitoring or 

routine disinfection and flushing in 

accordance with paragraph (a)(2) of this 

section; or when there is a failure to 

conduct repeat or follow-up sampling in 

accordance with paragraph (a)(4) of this 

section; or in accordance with 

paragraph (a)(6) of this section, when 

the air carrier becomes aware of a nonE. coli-positive event that is the result of 

water that was boarded from a watering 

point not in accordance with FDA 

regulations (21 CFR part 1240, subpart 

E), or that does not meet NPDWRs 

applicable to transient non-community 

water systems, or that is otherwise 

determined to be unsafe due to noncompliance with the procedures 

specified in § 141.804(b)(6): 

Because [REQUIRED MONITORING AND 

ANALYSIS WAS NOT CONDUCTED], 

[REQUIRED DISINFECTION AND 

FLUSHING WAS NOT CONDUCTED] 

[WATER WAS BOARDED FROM A 

WATERING POINT NOT IN ACCORDANCE 

WITH FDA REGULATIONS (21 CR 1240 

SUBPART E)], or [OTHER APPROPRIATE 

EXPLANATION], we cannot be sure of the 

quality of the drinking water at this time. 

However, drinking water contaminated with 

human pathogens can cause short-term 

health effects, such as diarrhea, cramps, 

nausea, headaches, or other symptoms. They 

may pose a special health risk for infants, 

young children, some of the elderly, and 

people with severely compromised immune 

systems. 

(4) Health effects language to be used 

when public notice is initiated due to a 
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failure to conduct required follow-up 

monitoring in response to a sample 

result that is E. coli-positive in 

accordance with paragraph (a)(3) of this 

section; or in accordance with 

paragraph (a)(5) of this section, when 

the air carrier becomes aware of an E. 

coli-positive event that is the result of 

water that was boarded from a watering 

point not in accordance with FDA 

regulations (21 CFR part 1240, subpart 

E), or that does not meet NPDWRs 

applicable to transient non-community 

water systems, or that is otherwise 

determined to be unsafe due to noncompliance with the procedures 

specified in § 141.804(b)(6): 

Because required follow-up monitoring 

and analysis was not conducted after the 

aircraft water system tested positive for E. 

coli, we cannot be sure of the quality of the 

drinking water at this time. E. coli are 

bacteria whose presence indicates that the 

water may be contaminated with human or 

animal wastes. Microbes in these wastes can 

cause short-term health effects, such as 

diarrhea, cramps, nausea, headaches, or other 

symptoms. They may pose a special health 

risk for infants, young children, some of the 

elderly, and people with severely 

compromised immune systems. 

OR 

Water was boarded that is contaminated 

with E. coli because [WATER WAS 

BOARDED FROM A WATERING POINT 

NOT IN ACCORDANCE WITH FDA 

REGULATIONS (21 CR 1240 SUBPART E)], 

or [OTHER APPROPRIATE EXPLANATION]. 

E. coli are bacteria whose presence indicates 

that the water may be contaminated with 

human or animal wastes. Microbes in these 

wastes can cause short-term health effects, 

such as diarrhea, cramps, nausea, headaches, 

or other symptoms. They may pose a special 

health risk for infants, young children, some 

of the elderly, and people with severely 

compromised immune systems. 

§ 141.806 Reporting requirements. 

(a) The air carrier must comply with 

the following requirements regarding 

reporting of the development of the 

coliform sampling plan, the operations 

and maintenance plan, and the 

disinfection and flushing and coliform 

sampling frequencies. 

(1) The air carrier must report to the 

Administrator that it has developed the 

coliform sampling plan required by 

§ 141.802, which covers each existing 

aircraft water system, as well as report 

the frequency for routine coliform 

sampling identified in the coliform 

sampling plan by April 19, 2011. The air 

carrier must report to the Administrator 

that it has developed its operations and 

maintenance plan required by § 141.804 

and report the frequency for routine 

disinfection and flushing by April 19, 

2011; 

(2) For each new aircraft meeting the 

definition of an aircraft water system, 

which becomes operational after 

publication of this subpart, the air 

carrier must report to the Administrator 

that it has developed the coliform 

sampling plan required by § 141.802, as 

well as report the frequency for routine 

coliform sampling identified in the 

coliform sampling plan, within the first 

calendar quarter of initial operation of 

the aircraft. The air carrier must report 

to the Administrator that it has 

developed the aircraft water system 

operations and maintenance plan 

required by § 141.804, and report the 

frequency for routine disinfection and 

flushing within the first calendar 

quarter of initial operation of the 

aircraft. 

(b) The air carrier must report the 

following information to the 

Administrator: 

(1) A complete inventory of aircraft 

that are public water systems by April 

19, 2011. Inventory information 

includes, at a minimum, the following: 

(i) The unique aircraft identifier 

number; 

(ii) The status (active or inactive) of 

any aircraft as an aircraft water system 

as defined in § 141.801; 

(iii) The type and location of any 

supplemental treatment equipment 

installed on the water system; and 

(iv) Whether the aircraft water system 

can be physically disconnected or shutoff, or the flow of water prevented 

through the tap(s). 

(2) Changes in aircraft inventory no 

later than 10 days following the 

calendar month in which the change 

occurred. Changes in inventory 

information include, at a minimum, the 

following: 

(i) Change in the unique identifier 

number for any new aircraft, or any 

aircraft removed from the carrier’s fleet; 

(ii) Change in status (active or 

inactive) of any aircraft as an aircraft 

water system as defined in § 141.801; 

and 

(iii) Change to the type and location 

of any supplemental treatment 

equipment added to or removed from 

the water system. 

(iv) Change to whether the aircraft 

water system can be physically 

disconnected or shut-off, or the flow of 

water prevented through the tap(s). 

(3) All sampling results no later than 

10 calendar days following the 

monitoring period in which the 

sampling occurred. The monitoring 

period is based on the monitoring 

frequency identified in the coliform 

sampling plan required under § 141.802. 

Routine disinfection and flushing events 

must be reported no later than 10 

calendar days following the disinfectio

and flushing period in which the 

disinfection and flushing occurred. The

disinfection and flushing period is 

based on the frequency identified in the

operations and maintenance plan 

required under § 141.804. 

(4) All events requiring notification t

passengers or crew, or non-routine 

disinfection and flushing, or nonroutine sampling, within 10 days of the

event (e.g., notification of positive 

sample result by laboratory), including 

information on whether required 

notification was provided to passengers

or crew or both. 

(5) Failure to comply with the 

monitoring or disinfection and flushing

requirements of this subpart within 10 

calendar days of discovery of the failur

(6) Changes in disinfection and 

flushing and coliform sampling 

frequencies no later than 10 days 

following the calendar month in which 

the change occurred. Changes to an 

aircraft’s routine coliform sampling 

frequency and routine disinfection and 

flushing frequency must be included in

the aircraft water system operation and 

maintenance plan that is included in th

air carrier operations and maintenance 

program accepted by FAA in accordanc

with § 141.804. 

(c) The air carrier must provide 

evidence of a self-inspection to the 

Administrator within 90 days of 

completion of the self-inspection 

required under § 141.808(b), including 

reporting whether all deficiencies were 

addressed in accordance with 

§ 141.808(c). The air carrier must also 

report to the Administrator within 90 

days that any deficiency identified 

during a compliance audit conducted i

accordance with § 141.808(a) has been 

addressed. If any deficiency has not 

been addressed within 90 days of 

identification of the deficiency, the 

report must also include a description o

the deficiency, an explanation as to wh

it has not yet been addressed, and a 

schedule for addressing it as 

expeditiously as possible. 

(d) All information required to be 

reported to the Administrator under thi

subpart must be in an electronic format 

established or approved by the 

Administrator. If an air carrier is unable

to report electronically, the air carrier 

may use an alternative approach that th

Administrator approves. 

§ 141.807 Recordkeeping requirements. 

(a) The air carrier must keep records 

of bacteriological analyses for at least 5 

years and must include the following 

information: 

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f 

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s 

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sroberts on DSKD5P82C1PROD with RULES

(1) The date, time, and place of 

ampling, and the name of the person 

ho collected the sample; 

(2) Identification of the sample as a 

outine, repeat, follow-up, or other 

pecial purpose sample; 

(3) Date of the analysis; 

(4) Laboratory and person responsible 

or performing the analysis; 

(5) The analytical technique/method 

sed; and 

(6) The results of the analysis. 

(b) The air carrier must keep records 

f any disinfection and flushing for at 

east 5 years and must include the 

ollowing information: 

(1) The date and time of the 

isinfection and flushing; and 

(2) The type of disinfection and 

lushing (i.e., routine or corrective 

ction). 

(c) The air carrier must keep records 

f a self-inspection for at least 10 years 

nd must include the following 

nformation: 

(1) The completion date of the selfnspection; and 

(2) Copies of any written reports, 

ummaries, or communications related 

o the self-inspection. 

(d) The air carrier must maintain 

ampling plans and make such plans 

vailable for review by the 

dministrator upon request, including 

uring compliance audits. 

(e) The air carrier must maintain 

ircraft water system operations and 

aintenance plans in accordance with 

AA requirements, and make such 

lans available for review by the 

dministrator upon request, including 

uring compliance audits. 

(f) The air carrier must keep copies of 

ublic notices to passengers and crew 

ssued as required by this subpart for at 

east 3 years after issuance. 

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A

d

p

i

l

§ 141.808 Audits and inspections. 

(a) The Administrator may conduct 

routine compliance audits as deemed 

necessary in providing regulatory 

oversight to ensure proper 

implementation of the requirements in 

this subpart. Compliance audits may 

include, but are not limited to: 

(1) Bacteriological sampling of aircraft 

water system; 

(2) Reviews and audits of records as 

they pertain to water system operations 

and maintenance such as log entries, 

disinfection and flushing procedures, 

and sampling results; and 

(3) Observation of procedures 

involving the handling of finished 

water, watering point selection, 

boarding of water, operation, 

disinfection and flushing, and general 

maintenance and self-inspections of 

aircraft water system. 

(b) Air carriers or their representatives 

must perform a self-inspection of all 

water system components for each 

aircraft water system no less frequently 

than once every 5 years. 

(c) The air carrier must address any 

deficiency identified during compliance 

audits or routine self-inspections within 

90 days of identification of the 

deficiency, or where such deficiency is 

identified during extended or heavy 

maintenance, before the aircraft is put 

back into service. This includes any 

deficiency in the water system’s design, 

construction, operation, maintenance, or 

administration, as well as any failure or 

malfunction of any system component 

that has the potential to cause an 

unacceptable risk to health or that could 

affect the reliable delivery of safe 

drinking water. 

§ 141.809 Supplemental treatment. 

(a) Any supplemental drinking water 

treatment units installed onboard 

existing or new aircraft must be 

acceptable to FAA and FDA; and must 

be installed, operated, and maintained 

in accordance with the manufacturer’s 

plans and specifications and FAA 

requirements. 

(b) Water supplemental treatment and 

production equipment must produce 

water that meets the standards 

prescribed in this part. 

§ 141.810 Violations. 

An air carrier is in violation of this 

subpart when, for any aircraft water 

system it owns or operates, any of the 

following occur: 

(a) It fails to perform any of the 

requirements in accordance with 

§ 141.803 or § 141.804. 

(b) It has an E. coli-positive sample in 

any monitoring period (routine and 

repeat samples are used in this 

determination). 

(c) It fails to provide notification to 

passengers and crew in accordance with 

§ 141.805. 

(d) It fails to comply with the 

reporting and recordkeeping 

requirements of this subpart. 

(e) It fails to conduct a self-inspection 

or address a deficiency in accordance 

with § 141.808. 

(f) It fails to develop a coliform 

sampling plan in accordance with 

§ 141.802, or fails to have and follow an 

operations and maintenance plan, 

which is included in a FAA accepted 

program in accordance with § 141.804. 

[FR Doc. E9–24552 Filed 10–16–09; 8:45 am] 

BILLING CODE 6560–50–P 
Appendix B 

ADWR Quick Reference Guide 
This Page Intentionally Left Blank 
Aircraft Drinking Water Rule: 

A Quick Reference Guide

Overview of the Rule

Title Aircraft Drinking Water Rule (ADWR) 74 FR 53590. October 19, 2009

Purpose To ensure that safe and reliable drinking water is provided to aircraft passengers and crew by 

amending and consolidating National Primary Drinking Water Regulations for aircraft public 

water systems (PWSs). 

General 

Description

To protect against disease-causing microbiological contaminants through the required 

development and implementation of aircraft water system operations and maintenance plans. 

The plans include routine disinfection and flushing of the water system, air carrier training 

requirements for key personnel, and periodic sampling of the onboard drinking water, as well 

as self-inspections of each aircraft water system and immediate notification of passengers and 

crew when violations or specific situations occur.

Aircraft 

Covered by 

the ADWR

The ADWR applies only to aircraft with onboard water systems that provide water for 

human consumption through pipes and regularly serve an average of at least twenty-five 

individuals daily, at least 60 days out of the year, and that board only finished water for human 

consumption. Human consumption includes water for drinking, hand washing, food preparation, 

and oral hygiene.

Components 

of an Aircraft 

Water 

System

Aircraft water systems include the water service panel, the filler neck of the aircraft finished 

water storage tank, and all finished water storage tanks, piping, treatment equipment, and 

plumbing fixtures within the aircraft that supply water to passengers or crew.

Major Provisions

Operations and Maintenance (O&M Plan)

Air carriers develop and implement an O&M plan for each aircraft water system in active service. More than 

one aircraft can be covered by the same O&M plan. The water system O&M plan must be included in a Federal 

Aviation Administration-accepted aircraft operations and maintenance program. If a new aircraft or PWS is 

added to an air carrier fleet, the aircraft is added to an existing O&M plan or a new O&M plan is developed. The 

O&M plan for the new aircraft is implemented by the end of the first calendar quarter during which the aircraft is 

placed into service. 

Each aircraft 

water system 

O&M plan 

includes:

► Watering point selection requirement – all water sources must be from a watering point 

selected in accordance with Food and Drug Administration regulations [21 CFR part 

1240 subpart E].

► Procedures for routinely disinfecting and flushing the aircraft water system in accordance 

with the manufacturer’s recommendations.

► Procedures for follow-up coliform sampling after a corrective disinfection and flushing 

event.

► Training requirements for all staff involved with the O&M provisions of the rule and those 

managing or conducting the coliform sampling requirements of the rule.

► Self-inspection procedures, procedures for boarding water, and the coliform sampling 

plan.

► A statement of whether the aircraft water system can be physically disconnected or shut 

off so that the flow of water through the tap(s) is prevented.

Coliform Sampling Plan

Air carriers develop a coliform sampling plan covering each aircraft owned or operated by the carrier. Sampling 

plans are developed for each new aircraft by the end of the calendar quarter in which the aircraft is placed in 

service.

At a minimum, all 

plans include the 

following:

► Coliform sample collection procedures. 

► Sample tap location(s) representative of the aircraft water system, including both galley 

and lavatory taps.

► Frequency and number of routine coliform samples to be collected.

► Frequency of routine disinfection and flushing as specified in the operations and 

maintenance plan.

► Procedures for communicating sample results to ensure any required actions including 

repeat and follow-up sampling, corrective action, and notification of passengers and crew 

are conducted in a timely manner.

Routine Disinfection and Flushing

Air carriers routinely disinfect and flush aircraft PWSs at the frequency recommended by the water system 

manufacturer or, if not specified by the manufacturer, may choose from one of four options.
Office of Water (4606M) EPA-816-F-10-077 www.epa.gov/drink October 2010

Coliform Sampling Requirements

All aircraft PWSs sample for total coliform bacteria according to the frequency and procedures described in 

the coliform sampling plan. The routine sampling frequency is based on the routine disinfection and flushing 

frequency—the more often an aircraft PWS disinfects, the less often it is required to monitor for coliform.

Routine coliform samples may be collected immediately prior to but not within 72 hours after a routine 

disinfection and flushing event. 

Each routine, repeat, or follow-up sample that is positive for total coliform is tested for the presence of E. coli. If 

any sample is positive for E. coli, public notification and corrective disinfection and flushing are triggered.

Air carriers select from specified options for follow-up and corrective measures when routine coliform samples 

indicate total coliform but E. coli contamination is not present. The options include collecting 3 repeat samples 

within 24 hours or disinfecting and flushing the system with follow-up sampling. 

► The disinfection and flushing procedure must be completed within 72 hours unless public access is 

restricted. 

► If any repeat sample is positive for coliform, public notification and corrective disinfection and flushing 

with follow-up sampling are triggered. 

Corrective Disinfection and Flushing

If corrective disinfection and flushing is opted or required, air carriers follow the procedures in their O&M plans. 

Unscheduled flight disruptions to perform corrective disinfection and flushing can be minimized by shutting 

off the water or preventing the flow of water to the taps. Before allowing unrestricted access to the aircraft 

water system, a complete set of two follow-up samples must be collected and submitted for analysis after the 

disinfection and flushing event if triggered by a total coliform-positive sample, and must be reported as total 

coliform-negative if triggered by an E. coli-positive sample.

Self-Inspection

Each aircraft PWS must be inspected by the air carrier at least every 5 years according to the procedures in their 

O&M plans. At a minimum, the self-inspection procedures for an aircraft water system must include inspection 

of the storage tank, distribution system, supplemental treatment, fixtures, valves, and backflow prevention 

devices. Any deficiencies detected must be addressed, and any deficiency that is unresolved within 90 days of 

identification of the deficiency must be reported to EPA.

Public Notification

Notification of passengers and crew onboard the aircraft is required when:

► Any sample results are total coliform-positive or E. coli-positive.

► An air carrier fails to perform required routine disinfection and flushing.

► An air carrier fails to collect required samples.

► An air carrier boards water from a watering point that does not meet FDA regulations, EPA standards, 

or is otherwise determined to be unsafe.

► EPA, the air carrier, or crew determines public notification is necessary to protect public health.

For E. coli-positive events or when EPA, the air carrier, or crew determines public notification is necessary, notice 

must be issued within 24 hours. For all other situations, notice must be issued within 72 hours. 

► Notice to passengers need not be provided if the water is shut off, if flow of water to taps is prevented, 

or if water is supplied only to the lavatory toilets and not the lavatory or galley taps.

Reporting and Recordkeeping Requirements

Air carriers submit compliance information to EPA including sampling results; all events requiring public 

notification and corrective disinfection and flushing; notification of failure to comply with monitoring or disinfection 

and flushing requirements; and evidence of self-inspection, along with a report of unresolved deficiencies. Most 

reporting will be done electronically to the ADWR Reporting and Compliance System, a database developed and 

supported by EPA. 

Records of coliform sampling, disinfection and flushing, self-inspections, and public notices are kept by the air 

carrier. Sampling plans and O&M plans are maintained and made available for EPA review.

Key Dates

Within 18 

months of the 

final rule 

April 19, 2011

► Develop a coliform sampling plan and report to EPA that it has been completed.

► Develop O&M plans that cover every aircraft PWS and report to EPA that they have been 

completed.

► Report the coliform sampling and disinfection and flushing frequencies to EPA for each 

aircraft.

► Report the complete air carrier inventory of aircraft that are PWSs to EPA.

24 months after 

the final rule 

October 19, 2011

► The compliance date for all other rule requirements applies, unless otherwise noted.

For additional information 

on the ADWR

Call the Safe Drinking 

Water Hotline at 1-800-

426-4791; visit the EPA 

web site at www.epa.gov/

drink; or contact your EPA 

Regional Office. 
Appendix C 

Example Coliform Sampling Plan
 
This Page Intentionally Left Blank 
 

[AIR CARRIER]
 

Coliform Sampling Plan for [AIRCRAFT MAKE/MODEL] 

Prepared for 

[AIR CARRIER] Personnel and Contractors 

[REVISION # AND DATE OF SAMPLING PLAN]
 

In Compliance with United States Environmental Protection Agency 

Aircraft Drinking Water Rule 

40 CFR Part 141 - Subpart X 
 

1. Background & Purpose 

The purpose of this Coliform Sampling Plan (CSP) is to describe the activities that will be performed 

by [AIR CARRIER] personnel and contractors to collect drinking water samples from onboard 

aircraft water systems. Specifically, this CSP outlines the objectives and methods that will be used to 

comply with the Aircraft Drinking Water Rule (ADWR) and includes monitoring frequencies, 

procedures, and analytical methods to be used by [AIR CARRIER] for drinking water sampling for 

total coliform. In addition, it describes the lines of communication for reporting sample results. This 

CSP has been prepared in accordance with ADWR requirements. 

The purpose of monitoring the aircraft water systems for total coliform is to determine compliance 

with the ADWR by ensuring the water meets water quality levels determined safe by Environmental 

Protection Agency (EPA). The data collected must be of sufficient quality to clearly determine if the 

water onboard the aircraft consistently meets the standards of the ADWR for total coliform and to 

avoid false identification of regulatory standard exceedances. 

Any [AIR CARRIER] employee or contractor will abide by the protocol set forth in this CSP for the 

collection of drinking water samples from aircraft water systems. 

2. Applicability 

This CSP applies to [AIRCRAFT MAKE/MODEL] and covers the following aircraft: [AIRCRAFT 

FAA AIRCRAFT REGISTRY ID NUMBER (a.k.a tail number or N-number)]. 

Inventory data on each aircraft identified in this CSP, including if the aircraft has a lavatory and/or 

galley with a drinking water tap, the number of taps, lavatories, galleys and other information, has 

been submitted to EPA in accordance with the ADWR requirements through the ADWR Reporting 

and Compliance System. 

All terms not defined in this CSP shall have their ordinary meaning, unless such terms are defined in 

the ADWR, in which case the statute or regulatory definitions will apply. 

3. Routine Monitoring Frequency 

The manufacturer of the onboard water systems for [AIRCRAFT MAKE/MODEL] has recommended 

that routine disinfection and flushing be conducted at a rate frequency of [once in a one-month period 

(monthly), at least once within every three month period (quarterly), at least once within every four 

month period, at least once within every six-month period (semi-annually), or at least once within 

every 12-month period (annually) or less]. [AIR CARRIER] has chosen to follow the manufacturer’s 

recommendations (or [AIR CARRIER] has chosen to disinfectant and flush at a rate more frequent 

than manufacturer’s recommendations: [SPECIFY RATE FREQUENCY FROM ABOVE LIST]). 

Consequently, routine total coliform samples will be collected at a rate of [at least once within every 

twelve-month period (annually), at least once within every six-month period (semi-annually), at least 

once within every three-month period (quarterly), or at least once every month (monthly)]. 

4. Analyses to be Performed 

Sampling may occur at any time during normal airline operations or maintenance activities. However, 

routine total coliform samples must not be collected within 72 hours after completing a routine 

disinfection and flushing. 
 

 

 

All drinking water samples collected from the onboard aircraft water system shall be analyzed for 

total coliform. In the event of a total coliform-positive result, the sample shall be analyzed for E.coli. 

Each total coliform sample will be sent to be analyzed by a State- or EPA-certified laboratory for 

analysis of the drinking water sample(s). In the event of a total coliform-positive sample result, the 

sample will be analyzed for E. coli. The protocol for sample collection is described in Section 9 of 

this CSP. 

5. Aircraft Sampling Sites 

In accordance with the ADWR, routine coliform samples will be collected from one galley and one 

lavatory tap [change if only one tap available] for total coliform during each monitoring period from 

each aircraft identified in this CSP. 

The [AIRCRAFT MAKE/MODEL] contains [NUMBER] galley(s) and [NUMBER] lavatory(s) with 

taps. The following diagram illustrates the location of the galleys and lavatories. The sample locations 

will be rotated each monitoring period to ensure the entire aircraft water system is sampled 

periodically. In addition, during each monitoring period, a sample will be collected from a galley and 

a lavatory at opposite ends of the aircraft, whenever possible. 

[PROVIDE DIAGRAM OF LOCATION OF AIRCRAFT LAVATORIES AND GALLEYS] 

Both lavatory and galley samples should be collected from a cold water tap if possible. If the only 

sampling point in the lavatory or galley is a hot water tap or the coffee maker, collect the sample at 

that location and indicate the sampling location on the sample collection sheet. [Suggest adding: If a 

sample is collected from a hot water tap, record the temperature of the water on the sample collection 

sheet if available. Temperature maybe a useful diagnostic tool.] 

6. Analytical Methods 

Specific details regarding the compliance criteria and sample requirements are illustrated in Table 1. 

All analytical methods for total coliform and E. coli to be used by the analytical laboratories shall be 

those approved by the EPA for drinking water analysis as provided in 40 CFR 141.21(f)(3) and 

141.21(f)(6). Current approved analytical methods are provided in Table 2. 

Table 1: Sample Requirements 

Analyte 

Compliance 

Criteria 

Holding 

Time 

Sample Volume 

(Bottle) Preservative1 

Total Coliform, E. 

coli 

Presence-absence. 

If present, test for 

E. coli 

30 hours (not 

to exceed) 

100 mL (150-mL 

Sterile Plastic with nontoxic cap) 

Cool to 4°C 0.008% 

Na2S2O3 

1 Preservative to be added to empty bottle by laboratory prior to sample collection. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2. Approved Analytical Methods [40 CFR 141(f)(3) and 141.21(f)(6)] 

Organism Methodology12 Citation1 

Total Coliforms2 Total Coliform Fermentation Technique3,4,5 9221A, B. 

Total Coliform Membrane Filter Technique6 9222A, B, C. 

Presence-Absence (P-A) Coliform Test5,7 9221D. 

ONPG-MUG Test8 9223. 

Colisure Test.9 

E*Colite®Test.10 

m-ColiBlue24®Test.11 

Readycult®Coliforms 100 Presence/Absence Test.13 

Membrane Filter Technique using Chromocult®Coliform Agar.14 

Colitag®Test.15 

E. coli Total Coliform Membrane Filter Technique6 9222A, B, C. 

 E*Colite®Test.10

 m-ColiBlue24®Test.11

 Readycult®Coliforms 100 Presence/Absence Test.13 

Membrane Filter Technique using Chromocult®Coliform Agar.14

 Colitag®Test.15 

Membrane Filtration, Two Step.16, 17 9222G 

 MMO-MUG.18

 Colisure Test.19 

1 Standard Methods for the Examination of Water and Wastewater, 18th edition (1992), 19th edition (1995), or 20th edition (1998). 

American Public Health Association, 1015 Fifteenth Street, NW., Washington, DC 20005. The cited methods published in any of these 

three editions may be used. In addition, the following online versions may also be used: 9221 A, B, D–99, 9222 A, B, C–97, and 9223 

B–97. Standard Methods Online are available at http://www.standardmethods.org. The year in which each method was approved by 

the Standard Methods Committee is designated by the last two digits in the method number. The methods listed are the only Online 

versions that may be used. 2

The time from sample collection to initiation of analysis may not exceed 30 hours. Systems are encouraged but not required to hold 

samples below 10 deg. C during transit. 3

Lactose broth, as commercially available, may be used in lieu of lauryl tryptose broth, if the system conducts at least 25 parallel tests 

between this medium and lauryl tryptose broth using the water normally tested, and this comparison demonstrates that the falsepositive rate and false-negative rate for total coliform, using lactose broth, is less than 10 percent. 4

If inverted tubes are used to detect gas production, the media should cover these tubes at least one-half to two-thirds after the sample is 

added. 5

No requirement exists to run the completed phase on 10 percent of all total coliform-positive confirmed tubes. 6

MI agar also may be used. Preparation and use of MI agar is set forth in the article, “New medium for the simultaneous detection of total 

coliform and Escherichia coli in water” by Brenner, K.P., et. al., 1993, Appl. Environ. Microbiol. 59:3534–3544. Also available from 

the Office of Water Resource Center (RC–4100T), 1200 Pennsylvania Avenue, NW., Washington, DC 20460, EPA/600/J–99/225. 

Verification of colonies is not required. 7

Six-times formulation strength may be used if the medium is filter-sterilized rather than autoclaved. 8

The ONPG-MUG Test is also known as the Autoanalysis Collect System. 9

A description of the Colisure Test, Feb 28, 1994, may be obtained from IDEXX Laboratories, Inc., One IDEXX Drive, Westbrook, 

Maine 04092. The Colisure Test may be read after an incubation time of 24 hours. 10A description of the E*Colite®Test, “Presence/Absence for Coliforms and E. Coli in Water,” Dec 21, 1997, is available from Charm 

Sciences, Inc., 36 Franklin Street, Malden, MA 02148–4120. 11A description of the m-ColiBlue24®Test, Aug 17, 1999, is available from the Hach Company, 100 Dayton Avenue, Ames, IA 50010. 12EPA strongly recommends that laboratories evaluate the false-positive and negative rates for the method(s) they use for monitoring 

total coliforms. EPA also encourages laboratories to establish false-positive and false-negative rates within their own laboratory and 
 

 

 

 

sample matrix (drinking water or source water) with the intent that if the method they choose has an unacceptable false-positive or 

negative rate, another method can be used. The Agency suggests that laboratories perform these studies on a minimum of 5% of all 

total coliform-positive samples, except for those methods where verification/confirmation is already required, e.g., the M-Endo and 

LES Endo Membrane Filter Tests, Standard Total Coliform Fermentation Technique, and Presence-Absence Coliform Test. Methods 

for establishing false-positive and negative-rates may be based on lactose fermentation, the rapid test for β-galactosidase and 

cytochrome oxidase, multi-test identification systems, or equivalent confirmation tests. False-positive and false-negative information is 

often available in published studies and/or from the manufacturer(s). 13The Readycult®Coliforms 100 Presence/Absence Test is described in the document, “Readycult®Coliforms 100 Presence/Absence Test 

for Detection and Identification of Coliform Bacteria and Escherichla coli in Finished Waters”, November 2000, Version 1.0, available 

from EM Science (an affiliate of Merck KGgA, Darmstadt Germany), 480 S. Democrat Road, Gibbstown, NJ 08027–1297. Telephone 

number is (800) 222–0342, e-mail address is: adellenbusch@emscience.com. 14Membrane Filter Technique using Chromocult®Coliform Agar is described in the document, “Chromocult®Coliform Agar 

Presence/Absence Membrane Filter Test Method for Detection and Identification of Coliform Bacteria and Escherichla coli in 

Finished Waters”, November 2000, Version 1.0, available from EM Science (an affiliate of Merck KGgA, Darmstadt Germany), 480 

S. Democrat Road, Gibbstown, NJ 08027–1297. Telephone number is (800) 222–0342, e-mail address is: 

adellenbusch@emscience.com. 15Colitag®product for the determination of the presence/absence of total coliforms and E. coli is described in “Colitag®Product as a Test 

for Detection and Identification of Coliforms and E. coli Bacteria in Drinking Water and Source Water as Required in National 

Primary Drinking Water Regulations,” August 2001, available from CPI International, Inc., 5580 Skylane Blvd., Santa Rosa, CA, 

95403, telephone (800) 878–7654, Fax (707) 545–7901, Internet address http://www.cpiinternational.com. 16EC medium supplemented with 50 μg/mL of 4-methylumbelliferyl-beta-D-glucuronide (MUG) (final concentration). The 18th edition 

(1992) may be used if at least 10 mL of EC medium is supplemented with 50 μg/mL of MUG before autoclaving. The inner inverted 

fermentation tube may be omitted. If the 18th edition is used, apply the procedure in paragraph 40 CFR 141.21(f)(5) for transferring a 

total coliform-positive culture to EC medium supplemented with MUG, incubate the tube at 44.5 ±0.2 °C for 24 ±2 hours, and then 

observe fluorescence with an ultraviolet light (366 nm) in the dark. If fluorescence is visible, E. coli are present. 17Nutrient agar supplemented with 100 μg/mL of 4-methylumbelliferyl-beta-D-glucuronide (MUG) (final concentration). The 18th 

edition (1992) may be used if the membrane filter containing a total coliform-positive colony(ies) is transferred to nutrient agar, as 

described in Method 9221B (paragraph 3) of Standard Methods (18th edition), supplemented with 100 μg/mL of MUG. If the 18th 

edition is used, incubate the agar plate at 35 °C for 4 hours and then observe the colony(ies) under ultraviolet light (366 nm) in the dark 

for fluorescence. If fluorescence is visible, E. coli are present. 18Minimal Medium ONPG-MUG (MMO-MUG) Test, as set forth in the article “National Field Evaluation of a Defined Substrate 

Method for the Simultaneous Detection of Total Coliforms and Escherichia coli from Drinking Water: Comparison with PresenceAbsence Techniques” (Edberg et al.), Applied and Environmental Microbiology, Volume 55, pp. 1003–1008, April 1989. (Note: The 

Autoanalysis Colilert System is an MMO-MUG test). If the MMO-MUG test is total coliform-positive after a 24-hour incubation, test 

the medium for fluorescence with a 366-nm ultraviolet light (preferably with a 6-watt lamp) in the dark. If fluorescence is observed, 

the sample is E. coli -positive. If fluorescence is questionable (cannot be definitively read) after 24 hours incubation, incubate the 

culture for an additional four hours (but not to exceed 28 hours total), and again test the medium for fluorescence. The MMO-MUG 

Test with hepes buffer in lieu of phosphate buffer is the only approved formulation for the detection of E. coli. 19The Colisure Test. A description of the Colisure Test may be obtained from the Millipore Corporation, Technical Services Department, 

80 Ashby Road, Bedford, MA 01730. 

7.	 Materials Required 

 Sample collection sheet 

 Laboratory chain of custody form 

 Indelible pen 

 Sample bottles (150-mL sterile plastic with non-toxic cap and dechlorinating agent) 

 Cooler with ice packs (optional) (contained-ice packs are preferable to ice cubes) 

 Rubber, latex, or non-latex exam gloves 

 Safety glasses 

8.	 Safety and Sample Integrity 

 Rubber/latex gloves shall be utilized when handling samples to minimize sample contamination 

and exposure to sample preservatives. 

 Safety glasses shall be worn when filling sample bottles. 

 Bottles are to be kept closed until ready to be filled. 
 

 

 

9.	 Sampling Procedures 

A. Pre-sampling Activities 

Notify laboratory and place order for sample bottles, labels, and cooler(s) at least 48 hours prior to 

sampling. (Note: You will need a separate cooler for each day/location of sample collection.) 

B. Sampling Event Preparation 

1.	 Notify ramp personnel to refrain from servicing aircraft water system until completion of 

sampling. 

2.	 Pre-label all bottles with the following information: 

	 Sample ID correlating to the sample tap site location [lav or gal] and location (e.g., aft, 

or fore, #1 gal, #2 lav] and other information listed on the laboratory chain of custody 

form and sample collection sheet 

 Date and time of collection 

 Analyses requested (e.g., total coliform)
 

 Sampler’s initials 

C. Total Coliform Sampling Procedures 

The following steps are to be followed any time total coliform samples are collected from an 

aircraft (e.g., routine, repeats, or follow-up samples). The term “tap” in this procedure means 

water tap, faucet, drinking fountain, or other fixture which provides water for human 

consumption to passengers or crew. Do not sample from leaking taps or taps which allow water to 

run down the outside of the fixture.
 

1) Put on gloves. 

2) Open tap and allow water to run for at least 30 seconds to flush tap. 

3) Reduce water flow so the stream is not greater than 1⁄4 inch in diameter, or the width of a 

pencil. Check for steady flow; do not change the water flow once the sample collection has 

begun, as this could dislodge microbial growth. 

4) Remove cap of total coliform sample bottle. 

5) Be careful not to contaminate the bottle by touching the interior of the cap or the inside of the 

sample container. Do not place cap on counter (which may be contaminated) or in your 

pocket to prevent container contamination. 

6)	 Place bottle under water stream allowing for an air gap between top of the bottle and the 

water tap. Hold the bottle in one hand and the cap in the other. Fill the bottle to the 100 mL 

fill line. If the bottle becomes overfilled, do not pour out the sample (this may lead to sample 

contamination); instead send it to the laboratory as is. 

7) Do not rinse the bottle either before or after sample collection. 

8) Replace cap and tighten. Turn off water. 

9) Ensure that sample ID matches that recorded on the sample collection sheet. 

10) Place bottles into Ziploc® or similar bag. Place bag in cooler or other transport container 

(packing the sample on ice (NOT dry ice) is recommended, but optional) 

11) Complete chain of custody sheet provided by laboratory. Ensure that sample ID matches that 

on the label and data sheet. If chain of custody sheet is not provided in duplicate, photocopy it 

for your records. 

12) Sign and date the following statement on the sample collection sheet. If there was any 

deviation from protocol, note this at the bottom of sample collection sheet. 
 

------------------------------------------------------------------------------------------------------------

 

 

I certify that all samples were collected in accordance with the sample procedures provided in 

the “Coliform Sampling Plan for [AIRCRAFT MAKE/MODEL]”. 

Signature Date 

13) Submit samples to: 

[LABORATORY NAME, ADDRESS] (for those samples collected in [HUB NAME OR 

AIRCRAFT LOCATION]) 

14) The lab shall receive samples within 24 hours of collection. 

10. Procedures for Communicating Sample Results 

The laboratory will report results in accordance with the Manual for Certification of Laboratories 

Analyzing Drinking Water to: [NAME and ADDRESS]. The laboratory reports will include the date 

and time of sample receipt, date and time of analysis, protocol used and analyst performing the test. 

All sample collection sheets and associated chain of custodies should be forwarded to: [NAME and 

ADDRESS] 

[AIR CARRIER or NAME] will report all routine, repeat, and follow-up sample results that are total 

coliform-negative to the ADWR Reporting and Compliance system within 10 calendar days 

following the end of the monitoring period in which the samples were collected. 

[AIR CARRIER or NAME] will report all routine, repeat, and follow-up sample results that are total 

coliform- or E. coli-positive to the ADWR Reporting and Compliance system within 10 calendar days 

of receiving the analytical results. 

Table 3 summarizes the lines of communication for specific events related to coliform monitoring. 

Table 3: Lines of Communication for Coliform Sampling Results 

Event Primary Contact Back-up Contact 

Receiving sample results from 

the Analytical Laboratory 

Name: 

Phone Number: 

E-Mail: 

Name: 

Phone Number: 

E-Mail: 

Reporting routine, repeat, and 

follow-up sample results to EPA 

(including positive results) 

Name: 

Phone Number: 

E-Mail: 

Name: 

Phone Number: 

E-Mail: 

Reporting total coliform or E. 

coli-positive sample results to 

[LIST APPROPRIATE 

DEPARTMENT OR NAME] 

Name: 

Phone Number: 

E-Mail: 

Name: 

Phone Number: 

E-Mail: 

Ensuring corrective actions are 

implemented in accordance with 

ADWR 

Name: 

Phone Number: 

E-Mail: 

Name: 

Phone Number: 

E-Mail: 

11. Attachments (list all separate documents) 

1. Sample Collection Sheet 
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Appendix D 

Public Notification Templates 

D-1 
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D-2 
This appendix contains example templates for notifying passengers and crew of violations or 

situations that require public notification under the ADWR 

The templates are as follows: 

	 Notice to the Passengers – Template 1. This template can be used for all ADWR 

violations or situations requiring public notification to passengers. This notice is required 

when passenger access to the water cannot be physically prevented through disconnecting 

or shutting of the water, or preventing the flow of water through the taps. This notice 

must be posted in the lavatory of the aircraft. 

	 E. coli-Positive Notice to the Crew – Template 2. This template can be used for 

notifying the crew when a routine, repeat, or follow-up sample tests positive for E. coli 

bacteria. This is a prominent notice to the crew in the galley of the aircraft. 

	 Total Coliform-Positive Notice to the Crew – Template 3. This template can be used 

for notifying the crew when a routine or repeat sample tests positive for total coliform 

bacteria and public access to the aircraft water system has been restricted. This is a 

prominent notice to the crew in the galley of the aircraft. 

	 Failure to Perform Routine Disinfection and Flushing Notice to the Crew – 

Template 4. This template can be used for notifying the crew if the aircraft carrier fails 

to perform routine disinfection and flushing of the aircraft water system. This is a 

prominent notice to the crew in the galley of the aircraft. 

	 Failure to Perform Routine, Repeat, or Follow-up Monitoring Notice to the Crew – 

Template 5. This template can be used for notifying the crew if the aircraft carrier fails 

to collect routine, repeat, or follow-up samples. This is a prominent notice to the crew in 

the galley of the aircraft. 

	 Boarding Water that Does Not Meet FDA Regulations or EPA Standards for 

Transient Non-community Water Systems (Boarded Water Quality or Boarding 

Procedures) Notice to the Crew – Template 6. This template can be used for notifying 

the crew when the air carrier becomes aware of an event which has resulted from water 

that has been boarded from a watering point that is not in accordance with FDA 

regulations, does not meet EPA standards for transient non-community water systems, or 

is otherwise determined unsafe because boarding procedures under the ADWR were not 

followed. In this case, these events are referred to as “non-E. coli-positive” events 

because E. coli is either not detected or not applicable to the event. This is a prominent 

notice to the crew in the galley of the aircraft. 

	 Failure to Perform Follow-up Monitoring After an E. coli-Positive Sample Result 

Notice to the Crew – Template 7. This template can be used for notifying the crew if 

the aircraft carrier fails to collect follow-up samples after a routine or repeat sample result 

is E. coli-positive. This is a prominent notice to the crew in the galley of the aircraft. 

	 Boarding Water that Does Not Meet FDA Regulations or EPA Standards for 

Transient Non-community Water Systems (E. coli-positive event) Notice to the Crew 

– Template 8. This template can be used for notifying the crew when the air carrier 

D-2 
becomes aware of an E. coli-positive event which has resulted from water that has been 

boarded from a watering point that is not in accordance with FDA regulations, does not 

meet EPA standards for transient non-community water systems, or is otherwise 

determined unsafe because boarding procedures under the ADWR were not followed. In 

this case, these events are referred to as “E. coli-positive” events because E. coli has been 

detected or was otherwise introduced in the water boarded on the aircraft. This is a 

prominent notice to the crew in the galley of the aircraft. 

	 Notification to Protect Public Health as Determined by EPA, the Carrier, or the 

Crew – Template 9. This template can be used when EPA, the carrier, or the crew 

determines it is necessary to issue notice to protect public health. This template is a 

generic template that should be modified to reflect the specific situation that is not 

covered by the prescribed templates (Templates 2 through 8). This template is intended 

for both the crew and passengers and should be posted in conspicuous locations (e.g., the 

galley and lavatories). With regard to the crew, prior to issuing a notice, the crew should 

first go through the proper chain of command/authority to determine whether a notice 

should be issued and, if so, the type of notice that should be provided. 

Mandatory language, which must be included as written (with blanks filled in), is presented in 

italics in each template. For more information on the requirements for public notification under 

the ADWR including a list of violations or situations requiring public notification and the 

required timeframe, format and content of the notices, refer to Chapter 6 of this manual. 

D-3 
D-4 

WARNING

DO NOT DRINK THE WATER

The water is non-potable. Do not use it for human consumption, 

which includes drinking, food or beverage preparation, hand 

washing, or teeth brushing. 

1111 N ti t th P f All Vi l ti Sit ti R i i PN 

Notice to the Passengers – Template 1
E. coli‐Positive Notice to the Crew – Template 2

DRINKING WATER WARNING 

DO NOT DRINK THE WATER 

E. coli Bacteria were Found in the Water Supply on [give date] 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

One of our [routine/repeat/follow-up] coliform samples tested positive for E. coli. 

Possible Health Effects 

E. coli are bacteria whose presence indicates that the water may be contaminated with 

human or animal wastes. Microbes in these wastes can cause short-term health effects, 

such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a 

special health risk for infants, young children, some of the elderly, and people with 

severely compromised immune systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

[Describe corrective action (e.g., We have disconnected the aircraft water system. We 

will disinfect and flush the water system as soon as possible and conduct follow-up 

sampling to ensure the water no longer contains E. coli bacteria.)] 

We will inform you when additional samples show no E. coli bacteria and you may drink 

the water. We anticipate resolving the problem within [estimated time frame]. 

 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-5 
D-6 

Total Coliform-Positive Notice to the Crew – Template 3

DRINKING WATER WARNING

Tests Show Presence of Coliform Bacteria in Water 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use.

We are required to sample for coliform bacteria on our aircraft [list frequency (i.e., 

monthly, quarterly, semi-annually, annually)]. On [give date], we received notice that the 

sample collected on [give date] showed the presence of total coliform bacteria in our 

water.

What This Means 

This is not an emergency. Total coliform bacteria themselves are generally not harmful. 

Coliform are bacteria that are naturally present in the environment and are used as an 

indicator that other, potentially harmful, bacteria may be present. Coliforms were found 

in [INSERT NUMBER OF SAMPLES DETECTED] samples collected and this is a 

warning of potential problems. If human pathogens are present, they can cause shortterm health effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. 

They may pose a special health risk for infants, young children, some of the elderly, and 

people with severely compromised immune systems.

People at increased risk should be particularly careful to avoid this water.

Steps We Are Taking

[Describe corrective action (e.g., We will disinfect and flush the water system as soon 

as possible and conduct follow-up sampling to ensure the water no longer contains 

coliform bacteria.)]

 

We will inform you when additional samples show no coliform bacteria. We anticipate 

resolving the problem within [estimated time frame]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 
 

 

 

Failure to Perform Routine Disinfection and Flushing Notice to the Crew –

Template 4

DRINKING WATER WARNING
 

Routine Disinfection and Flushing was Not Performed 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

We are required to routinely disinfect and flush our water system. On [give date], we 

failed to perform routine disinfection and flushing and, therefore, it is not known whether 

the water is contaminated. 

What This Means 

Because required disinfection and flushing was not conducted, we cannot be sure of the 

quality of the drinking water at this time. However, drinking water contaminated with 

human pathogens can cause short-term health effects, such as diarrhea, cramps, 

nausea, headaches, or other symptoms. They may pose a special health risk for infants, 

young children, some of the elderly, and people with severely compromised immune 

systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

We will disinfect and flush the water system on [give date]. We anticipate having the 

water system back in service on [estimated date]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-7 
 

 

Failure to Perform Routine, Repeat, or Follow‐up Monitoring Notice to the

Crew – Template 5

DRINKING WATER WARNING
 

[(Routine/Repeat/Follow-up)] Coliform Sampling was Not 

Conducted 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

We were required to collect [(routine) OR (repeat) OR (follow-up)] coliform samples. On 

[give date], we failed to perform the required monitoring and, therefore, it is not known 

whether the water is contaminated. 

What This Means 

Because required monitoring and analysis was not conducted, we cannot be sure of the 

quality of the drinking water at this time. However, drinking water contaminated with 

human pathogens can cause short-term health effects, such as diarrhea, cramps, 

nausea, headaches, or other symptoms. They may pose a special health risk for infants, 

young children, some of the elderly, and people with severely compromised immune 

systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

We will disinfect and flush the water system on [give date]. We anticipate having the 

water system back in service on [estimated date]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-8 
Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
 

Transient Non‐community Water Systems (Boarded Water Quality or Boarding
 

Procedures) Notice to the Crew – Template 6
 

 

 

DRINKING WATER WARNING
 

Water was Boarded from a Watering Point that Does Not Meet 

Requirements 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

We are required to board water on the aircraft that meets FDA regulations and EPA 

standards and follows the boarding procedures prescribed in the Aircraft Drinking Water 

Rule (ADWR). On [give date], water was boarded from [provide watering point location] 

which was not in accordance with FDA regulations, or did not meet EPA standards for 

transient non-community water systems, or was otherwise determined to be unsafe due 

to noncompliance with the procedures for boarding water under the ADWR and, 

therefore, it is not known whether the water is contaminated. 

What This Means 

Because [(water was boarded from a watering point not in accordance with FDA 

Regulations (21 CFR part 1240, subpart E) OR (other appropriate explanation)], we 

cannot be sure of the quality of the drinking water at this time. However, drinking water 

contaminated with human pathogens can cause short-term health effects, such as 

diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special 

health risk for infants, young children, some of the elderly, and people with severely 

compromised immune systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

We will disinfect and flush the water system on [give date]. We anticipate having the 

water system back in service on [estimated date]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-9 
 

 

Failure to Perform Follow‐up Monitoring After an E. coli‐Positive Sample Result

Notice to the Crew – Template 7

DRINKING WATER WARNING
 

DO NOT DRINK THE WATER
 

Follow-up Sampling was Not Conducted After E. coli Bacteria 

were Found in the Water Supply 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

We were required to collect follow-up samples after being notified that our water tested 

positive for E. coli. On [give date], we failed to perform the required monitoring. 

What This Means 

Because required follow-up monitoring and analysis was not conducted after the aircraft 

water system tested positive for E. coli, we cannot be sure of the quality of the drinking 

water at this time. E. coli are bacteria whose presence indicates that the water may be 

contaminated with human or animal wastes. Microbes in these wastes can cause shortterm health effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. 

They may pose a special health risk for infants, young children, some of the elderly, and 

people with severely compromised immune systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

We will disinfect and flush the water system and collect follow-up samples on [give 

date]. We anticipate having the water system back in service on [estimated date]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-10 
 

Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
 

Transient Non‐community Water Systems (E. coli‐Positive event) Notice to the
 

Crew – Template 8
 

 

DRINKING WATER WARNING
 

DO NOT DRINK THE WATER
 

E. coli Bacteria were Found in the Water Supply Because Water 

was Boarded from a Watering Point that Did Not Meet 

Requirements 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

We are required to board water on the aircraft that meets FDA regulations and EPA 

standards and follows the boarding procedures prescribed in the Aircraft Drinking Water 

Rule (ADWR). On [give date], water was boarded from [provide watering point location] 

which was not in accordance with FDA regulations, or did not meet EPA standards for 

transient non-community water systems, or was otherwise determined to be unsafe due 

to noncompliance with the procedures for boarding water under the ADWR. As a result, 

E. coli bacteria were found in the water supply. 

What This Means 

Water was boarded that is contaminated with E. coli because [(water was boarded from 

a watering point not in accordance with FDA Regulations (21 CFR part 1240, subpart E) 

OR (other appropriate explanation)]. E. coli are bacteria whose presence indicates that 

the water may be contaminated with human or animal wastes. Microbes in these wastes 

can cause short-term health effects, such as diarrhea, cramps, nausea, headaches, or 

other symptoms. They may pose a special health risk for infants, young children, some 

of the elderly, and people with severely compromised immune systems. 

People at increased risk should be particularly careful to avoid this water. 

Steps We Are Taking 

We will disinfect and flush the water system on [give date]. We anticipate having the 

water system back in service on [estimated date]. 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-11 
 

Notification to Protect Public Health as Determined by EPA, the Carrier, or the Crew 

– Template 9 

 

DRINKING WATER WARNING
 

DO NOT DRINK THE WATER 

The water is non-potable. Do not use it for drinking, food or beverage preparation, hand 

washing, teeth brushing, or any other consumptive use. 

[Insert text to describe the situation triggering the notice]. 

What This Means 

The unsafe situation observed by the crew could lead to contamination of this aircraft’s 

drinking water. Short term health effects caused by drinking water contamination can 

pose increased risk for sensitive populations. 

People with severely compromised immune systems, people with an infant, people with 

young children, pregnant women, and some elderly should be particularly careful to 

avoid this water. 

Steps We Are Taking 

[Describe corrective action].
 

This notice is provided by [Aircraft Carrier]. Date distributed: ______. 

D-12 
 

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D-13 
 

Appendix E 

Example Water Safety Plan for an Air Carrier 

E-1 
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E-2 
 

 

 

 

 

Example Water Safety Plan for an Air Carrier 

(Revision Date: [list date]) 

Section 1. Goals and Objectives 

Instructions: State the air carrier’s goals and objectives for developing and implementing a 

water safety plan for aircraft water systems. 

Example: This water safety plan (WSP) summarizes Airline XYZ’s comprehensive and 

systematic risk management approach for assuring the safety of drinking water onboard 

[Make/Model] aircraft. Although the water safety plan is not required by regulation, Airline 

XYZ believes the water safety plan is a necessary component of a proactive risk management 

approach to ensure safe drinking water is obtained, boarded, and maintained for use by aircraft 

passengers and crew. 

Section 2. Jurisdictional Requirements 

Instructions: List all federal, state, and local regulations, standards and guidelines that are 

pertinent to the aircraft water transfer and supply chain. 

Example: See Table 2.1 below. 

Table 2.1. Summary of Aircraft Water System Jurisdictional Requirements for Airline 

XYZ 

Title Reference 

Regulations 

Aircraft Drinking Water Rule http://water.epa.gov/lawsregs/rulesregs/sdwa/airlinewate 

r/regs.cfm 

Food and Drug Administration, 

Control of Communicable Diseases, 

FDA certification of aircraft 

sanitation systems including potable 

water, sewage, and galleys. 

21 CFR 1240. 

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/ 

CFRSearch.cfm?fr=1240.83 

Food and Drug Administration, 

Interstate Conveyance Sanitation, 

approval and certification of watering 

points 

21 CFR 1250. US Food and Drug Administration. 2005. 

Code of Federal Regulations Subchapter L Part 1250 

Interstate Conveyance Sanitation [Online] Available: 

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/ 

CFRSearch.cfm?CFRPart=1250 

Standards 

FAA Airworthiness Standards http://edocket.access.gpo.gov/cfr_2003/14cfr43.9.htm 

Guidelines 

Guidance Manual for the ADWR USEPA 2010 

www.water.epa.gov/lawsregs/rulesregs/sdwa/airlinewater 

WHO Guide to Hygiene and 

Sanitation in Aviation, Third edition 

http://www.who.int/water_sanitation_health/hygiene/ship 

s/guide_hygiene_sanitation_aviation_3_edition.pdf 

E-3 
 

 

 

 

(2009) 

FDA Guide to Inspection of 

Interstate Carriers and Support 

Facilities 

http://www.fda.gov/ICECI/Inspections/InspectionGuides/ 

ucm074964.htm 

NSF/ANSI1

 Standard 60 – Drinking 

Water Treatment Chemicals – 

Health Effects 

http://www.nsf.org/business/water_distribution/index.asp 

?program=WaterDistributionSys 

NSF/ANSI Standard 61 Drinking 

Water System Components – Health 

Effects 

http://www.nsf.org/business/water_distribution/index.asp 

?program=WaterDistributionSys 

1

NSF = National Sanitation Foundation International; ANSI = American National Standards 

Institute 

Section 3. Water Safety Team 

Instructions: Identify your employees and other stakeholders that share responsibility for 

providing safe drinking water to aircraft passengers and crews. Identify each individual’s 

specific roles and responsibilities. List responsible parties for each airport location used to board 

water for the aircraft addressed by this WSP. 

Example: 

Name 

Title 

Organization 

Roles and Responsibilities Contact Information 

Susan Smith 

Water Quality Officer 

Airline XYZ 

Development and implementation of 

Water Safety Plan and procedures for 

transferring water from watering point to 

onboard water system; compliance with 

ADWR; staff training. 

Phone: 

Fax: 

Email: 

John Jones 

Maintenance Director 

Airline XYZ 

Development and implementation of 

aircraft water system flushing and 

disinfection program, and associated 

employee and vendor training. 

Phone: 

Fax: 

Email: 

International Airport ([City], [State]) 

Joe Jones 

Chief Engineer 

Massachusetts Water 

Resources Authority 

Potable water supply: Source of supply 

meets federal and state drinking water 

regulations. 

Phone: 

Fax: 

Email: 

Jim Jones 

Maintenance Director 

City Airport 

Drinking water quality is maintained 

within airport water system. 

Phone: 

Fax: 

Email: 

Jeff Jones 

Field Supervisor 

Drinking water quality is maintained at 

watering point (transfer point from 

Phone: 

Fax: 

E-4 
 

 

Contract Service Co. source/airport water system to aircraft 

water system). Watering point meets FDA 

regulations and has no potential sources of 

contamination. 

Email: 

Vendor A Aircraft water system flushing and 

disinfection as directed by Airline XYZ. 

Phone: 

Fax: 

Email: 

Vendor B Aircraft water system flushing and 

disinfection as directed by Airline XYZ. 

Phone: 

Fax: 

Email: 

Vendor C Aircraft water system flushing and 

disinfection as directed by Airline XYZ. 

Phone: 

Fax: 

Email: 

Phone: 

Fax: 

Email: 

Airport (XYZ) (List Contacts for Each Airport Served) 

Section 4. Aircraft Water System Description and Inventory 

Instructions: Describe aircraft water system using a brief narrative, overall system schematic 

and a table summarizing key specifications for system components. 

Examples: 

The components of the aircraft water system include the water service panel, the filler neck of 

the aircraft finished water storage tank, the onboard water storage tank(s), piping, treatment 

equipment, galley and lavatory faucets, and any other plumbing fixtures that supply water to 

passengers or crew. For (insert make/model) aircraft owned and operated by Airline XYZ, the 

following components are also included (provide details): 

(Insert schematic for each make/model owned and operated by air carrier that is addressed by 

this WSP) 

E-5 
Figure 4.1. Example Schematic of Aircraft Water System 

Table 4.1. Example Summary of Aircraft Water System Components (List Aircraft Type) 

Component Specifications Operation and Maintenance 

Schedule 

Storage tank (fixed) 1 tank, 200 gallons, plastic Drain if aircraft idle for >48 

hrs; drain, clean and disinfect 

every 3 months. 

Storage Tank (removable) 2 tanks, 5 gallons each, plastic Drain, clean and disinfect each 

use. 

Fill line 1 inch (list material of 

construction) 

Disinfect and flush every 3 

months. 

Distribution lines 3⁄4 and 1 inch (list materials of 

construction) 

Disinfect and flush every 3 

months. 

Tank overflow lines 1 inch, (list material of 

construction) 

Disinfect and flush every 3 

months. 

Particulate Filter Make and Model Replace filter every 4 months 

or every 1,000 hours. 

E-6 
Section 5. Hazard Assessment 

Instructions: Identify potential hazards and their relative risk for your aircraft water system (low, 

medium, high). Identify control measures used to mitigate each potential hazard. 

Example: 

Table 5.1 Example Summary of Potential Hazard Events and Control Measures 

Potential Hazard Event (Estimated Risk 

Level) 

Control Measures 

Water to be boarded is known to have a - Do not board water, if operational needs 

NPDWR maximum contaminant level (MCL) (e.g., flush toilets) can be met without boarding 

or treatment technique violation that poses a additional water. 

potential significant public health threat (e.g., - If operational needs cannot be met, board 

acute violation of the coliform MCL, acute water and: 

violation of the surface water treatment rules,  Restrict public access per 40 CFR 

or exceeding the nitrate or nitrite MCL). (High 141.803(d). 

risk level)  Notify passengers and crew per 40 CFR 

141.805. 

Use of watering point, including transfer and - If used, aircraft is non-compliant with FDA 

delivery systems, not approved by FDA under regulations 

21 CFR 1240.83 (High) - If not used, identify alternate watering points 

in accordance with FDA regulations. 

Boarded water degrades within onboard water 

system (biofilm growth). (Low) 

-Conduct routine total coliform monitoring. 

-Routinely disinfect and flush aircraft water 

system. 

Contaminant enters onboard water system due 

to system design flaw. (Low to medium; high 

risk if E. coli) 

 Restrict public access per 40 CFR 

141.803(d) as warranted by monitoring 

results. 

 Notify passengers and crew per 40 CFR 

141.805. 

 Disinfect and flush aircraft water system. 

 Resample aircraft water. 

 Repeat disinfection, flushing, and followup sampling if necessary. 

 Determine if other maintenance or system 

modifications are needed to prevent future 

contamination events. 

E-7 
Backflow due to failure of backflow prevention  Restrict public access per 40 CFR 

devices (Medium; high if sewage is present) 141.803(d) as warranted by monitoring 

results. 

 Notify passengers and crew per 40 CFR 

141.805. 

 Disinfect and flush aircraft water system. 

 Sample aircraft water. 

 Inspect and repair failed backflow 

prevention devices. 

Water quantity insufficient to meet minimum 

sanitary water demands during flight. (Low to 

medium) 

 Restrict public access per 40 CFR 

141.803(d) and based on need (i.e. only 

enough water available to flush toilets). 

 Notify passengers and crew if water is not 

shut off at taps. Notify crew only if water 

is shut off. 

Section 6. Operations & Maintenance Plan 

Instructions: Describe standard operating procedures (SOPs) for routine operations of the 

onboard water system including boarding water from the airport watering point; collecting water 

samples for regulatory compliance; draining the water system; disinfection and flushing of the 

water system; and related personnel training requirements. Describe maintenance practices 

including disinfection and flushing. Include technical references that provide details of 

regulatory requirements and/or recommended practices. 

Example: 

Table 6.1. Example Summary of O&M Practices 

O&M Practice Description Reference 

Watering Point Selection 

Requirement 

A statement that all water that is 

boarded onto the aircraft will be from 

a watering point in accordance with 

FDA regulations. 

ADWR Guidance 

Manual (2010); 

21 CFR 1240.83; 

21CFR 1250.67; FDA 

Manual of Sanitation 

Practices for Boarding Potable 

Water and non-potable water 

1. Confirm that transfer point meets 

FDA requirements. 

2. See detailed practices in O&M 

Plan. 

ADWR Guidance 

Manual (2010); 

21CFR 1240.83. 

E-8 
Coliform Sampling Plan Coliform sampling protocol for 

routine, repeat and follow-up samples; 

list of certified laboratories; analytical 

methods; representative sample 

locations; frequency and number of 

routine, repeat and follow-up samples; 

reporting sampling results. 

ADWR Guidance 

Manual (2010) 

Draining System Procedures for completely draining 

aircraft water system. 

WHO (2006). Health 

Aspects of Plumbing. 

FDA Manual of 

Sanitation 

Cleaning Water Storage 

Tank(s) 

Draining procedures; frequency of 

routine disinfection and flushing; 

disinfection procedures; flushing 

procedures; disinfecting agent; 

disinfectant concentration; 

disinfectant contact time; flushing 

volume or flushing time. 

Aircraft 

Manufacturer’s 

Guidelines; 21CFR 

1250.82. 

Disinfection and Flushing Frequency of routine disinfection and 

flushing; disinfection procedures; 

flushing procedures; disinfecting 

agent; disinfectant concentration; 

disinfectant contact time; flushing 

volume or flushing time. 

Aircraft 

Manufacturer’s 

Guidelines; 21CFR 

1250.82; 

Cross Connection Control Inspect system for potential cross 

connections; install and maintain 

backflow prevention devices as 

needed. 

21CFR 1250.82; FDA 

Manual of Sanitation. 

Maintenance for Treatment 

Equipment Including Filter 

Cartridges 

Frequency and procedures for 

replacing filter cartridges. 

21 CFR 1240.90; FDA 

Manual of Sanitation 

Maintenance Procedures Review FAA-accepted aircraft water 

system O&M plan 

14 CFR 43 – 

Maintenance, 

Preventive 

Maintenance, 

Rebuilding, and 

Alteration; 21CFR 

1250.30. 

Self-inspection Procedures Inspection of the storage tank, piping, 

supplemental treatment, plumbing 

fixtures, valves, and backflow 

prevention devices. 

ADWR Guidance 

Manual (2010) 

E-9 
Personnel Training Training topics include: public health 

and safety issues; ADWR 

requirements, sample collection, 

boarding water, flushing and 

disinfection procedures, 

communications and emergency plan, 

O&M plan 

ADWR Guidance 

Manual (2010); WHO 

Guide to Hygiene and 

Sanitation in Aviation, 

Third edition (2009). 

Section 7. Communications and Emergency Plan 

Instructions: Identify specific events that require communication, and the communications 

strategy needed to address the event. 

Example: 

Table 7.1 Communications and Emergency Plan 

Event Communications Strategy Key Contacts 

ADWR monitoring yields 

positive result. 

If source of water is known, 

notify PWS and Airport Water 

System Manager of water 

quality issue and to discuss 

possible resolution. Notify 

public per 40 CFR 141.805. 

Report to EPA per 40 CFR 

141.806. 

Contact Name: 

Phone: 

Fax: 

Email: 

Coliform monitoring was not Notify passengers and crew Contact Name: 

conducted as required. per corrective action 

requirement (see Table 8.2 

below). Report to EPA. 

Phone: 

Fax: 

Email: 

Disinfection and flushing of Notify passengers, crew, EPA Contact Name: 

aircraft water system was not per corrective action Phone: 

conducted as required. requirement (see Table 8.2 

below). 

Fax: 

Email: 

Backflow prevention device 

does not pass 

testing/inspection. 

Inspector notifies Air Carrier. Contact Name: 

Phone: 

Fax: 

Email: 

Source water monitoring PWS notifies Air Carrier and Contact Name: 

detects contamination. Airport. Air Carrier contacts 

alternate PWS. 

Phone: 

Fax: 

Email: 

E-10 
 

Boarded water quality meets 

federal and state regulations 

for finished water. 

PWS sends periodic reports 

(annual water quality reports 

or more frequent if issues 

arise) on regulatory 

compliance. Air Carrier calls 

PWS to discuss any water 

quality issues. 

Contact Name: 

Phone: 

Fax: 

Email: 

Section 8. Corrective Actions 

Instructions: Identify corrective actions that will be implemented if ADWR requirements are not 

met (See Table 8.1). Maintain record of corrective actions taken and how/when problems were 

resolved (See Table 8.2). 

Examples: 

Table 8.1 Summary of Corrective Actions 

ADWR-related Issue Corrective Action 

Failure to board water from a safe watering 

point (E. coli-positive). 

Perform all of the following corrective 

actions: 

1. Restrict public access per 40 CFR 

141.803(d) as expeditiously as possible and 

within 24 hours after laboratory notifies air 

carrier of sample results. Restriction applies 

until aircraft water system has been 

disinfected and flushed and a complete set of 

follow-up samples is total coliform-negative. 

2. Disinfect and flush per 40 CFR 

141.804(b)(2). 

3. Conduct follow-up sampling per 40 CFR 

141.803(e). 

Failure to board water from a safe watering 

point (non-E. coli-positive). 

Disinfect and flush per 40 CFR 

141.804(b)(2). Notify passengers and crew. 

Failure to disinfect and flush. This includes 1. Notify passengers and crew. 

failure to conduct routine disinfection and 2. Within 10 calendar days of discovery of 

flushing as specified in the O&M plan and failure, report failure to EPA per 40 CFR 

failure to conduct corrective disinfection and 141.806. 

flushing. 

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ADWR-related Issue Corrective Action 

Failure to monitor for coliforms. This 

includes failure to monitor according to the 

frequency in the coliform monitoring plan, 

along with failure to analyze total coliformpositive samples for E. coli, failure to conduct 

repeat sampling after routine samples are found 

to be positive for total coliform, and failure to 

conduct follow-up monitoring after 

disinfection and flushing. 

(1) For failure to collect routine, repeat or 

follow-up samples, restrict public access to 

aircraft water system; (2) Notify passengers 

and crew as expeditiously as possible, but in 

no case later than 24 hours after discovery of 

failure to collect required samples or after 

being notified by EPA of failure to collect 

required samples, whichever comes first, (3) 

conduct disinfection and flushing within 72 

hours (if water system cannot be 

disconnected), (4) collect follow-up samples. 

(5) Within 10 calendar days, report failure to 

EPA per 40 CFR 141.806. 

Failure to conduct a self-inspection or Conduct a self-inspection and provide 

address a deficiency in accordance with 40 evidence to EPA that the self-inspection was 

CFR 141.808. Self-inspections are required completed and whether all deficiencies have 

every 5 years. Deficiencies identified during been addressed [40 CFR 141.806(c)]. Report 

self-inspections or compliance audits must be to EPA a description of any deficiencies not 

addressed within 90 days. Deficiencies addressed, an explanation as to why it has not 

identified during extended or heavy yet been addressed, and a schedule for 

maintenance must be addressed before the addressing any deficiencies as expeditiously 

aircraft is returned to service. as possible. 

Failure to develop a coliform sampling plan 

in accordance with 40 CFR 141.802. 

Coliform sampling plans must be developed by 

April 19, 2011. 

Report to EPA within 10 calendar days of 

discovery of the failure. 

Failure to perform any of the requirements Perform the requirements specified in 40 CFR 

for coliform sampling (per 40 CFR 141.803) 141.803 or 40 CFR 141.804 as applicable, 

or the O&M plan (per 40 CFR 141.804). and report to EPA. Notify passengers and 

crew. 

Routine sample is total coliform-positive 

and E. coli-negative. 

Perform at least one of the following three 

corrective actions and continue with that 

action until a complete set of repeat samples 

is total coliform-negative or a complete set of 

follow-up samples is collected: 

1. Disinfect and flush per 40 CFR 

141.804(b)(2). 

2. Restrict public access per 40 CFR 

141.803(d). 

3. Conduct repeat sampling per 40 CFR 

141.803(c). 

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ADWR-related Issue Corrective Action 

Routine sample is E. coli-positive. Perform all of the following corrective 

actions: 

1. Restrict public access per 40 CFR 

141.803(d) as expeditiously as possible and 

within 24 hours after laboratory notifies air 

carrier of sample results. Restriction applies 

until aircraft water system has been 

disinfected and flushed and a complete set of 

follow-up samples is total coliform-negative. 

2. Disinfect and flush per 40 CFR 

141.804(b)(2). 

3. Conduct follow-up sampling per 40 CFR 

141.803(e). 

Repeat sample is E. coli-positive. Perform all of the following corrective 

actions: 

1. Restrict public access per 40 CFR 

141.803(d) as expeditiously as possible and 

within 24 hours after laboratory notifies air 

carrier of sample results. Restriction applies 

until aircraft water system has been 

disinfected and flushed and a complete set of 

follow-up samples is total coliform-negative. 

2. Disinfect and flush per 40 CFR 

141.804(b)(2). 

Failure to provide notification to passengers 

and crew in accordance with 40 CFR 

141.805. 

Implement public notification and the 

correction necessary to remove the need for 

public notification. 

Failure to comply with the reporting and 

recordkeeping requirements of the ADWR. 

Implement a reporting and recordkeeping 

process and procedure. 

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Table 8.2. Summary of Corrective Actions Taken and Problem Resolution 

Event Identified 

(Date) 

Corrective Actions Taken (Date) Source of Problem 

Identified 

Date 

Problem 

Was 

Resolved 

Failure to conduct 

routine monitoring 

for coliforms (9/1/09) 

Restrict public access to aircraft 

water system (9/2/09). 

Notify passengers and crew 

(9/2/09). 

System disinfected and flushed 

(9/4/09). 

New employees trained (9/5/09). 

Follow-up samples collected 

(9/5/09). 

New employees 

needed training in 

sampling 

requirements and 

procedures. 

9/7/09 

Section 9. Recordkeeping 

Instructions: Identify all documents related to aircraft water system and Water Safety Plan. List 

the date for the current revision and location of the document. 

Example: 

Document Revision Date Location of Master Copy 

Coliform Sampling Plan Sept. 2009 Server X, Corporate Office 

Bacteriological Analyses 2004-2009 Server A, Corporate Lab 

Operations & Maintenance 

Plan 

March 2009 Server X, Corporate Office 

Disinfection and Flushing 

Records 

2004-2009 Server Z, Corporate Office 

Corrective Action Reports to 

EPA 

Multiple Server Z, Corporate Office 

Self-Inspection Records 1999-2009 Server Z, Corporate Office 

Public Notices 2010-2013 Server Z, Corporate Office 

Section 10. Annual Review of Water Safety Plan 

Instructions: Review Sections 1-8 of Water Safety Plan and update/revise as needed. Complete 

review at least annually and whenever there is a change in process, procedures, equipment, 

regulations etc. Include revision date on title page of Plan. Distribute revised Plan to Water 

Safety Team and other stakeholders. 

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