Airport Community, Water Quality Events, and the Aircraft Drinking Water Rule (2018)

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28 CHAPTER FOUR CONCLUSIONS AND FURTHER RESEARCH Protecting public health by providing safe drinking water and other health-related practices is a priority for all members of the airport community. Airport management, airlines, and other airport tenants share a common objective of providing safe drinking water to their employees, tenants, and the traveling public. Drinking water quality events that affect airports can trig- ger a spiral of operational challenges for the airports, airlines, and other tenants. In such an event, receiving prompt and accu- rate information about the event is essential for airport management and tenants to address and mitigate its adverse effects. Airport personnel can provide an invaluable service to airlines and other tenants by assisting with dissemination of water quality event information. However, because water quality events occur infrequently, many airports do not have standard operating procedures (SOPs) in place to address the notifications and are not always fully aware of the implications of the events on their tenants’ operations. This synthesis compiled airport experiences with notifications related to water quality events. The synthesis found the fol- lowing observations and conclusions: • Airports, airlines, and other members of the airport community are partners in addressing water quality events that affect airports. • Improving airport management awareness of the importance of water quality event notifications and options for the messaging could prompt more widespread implementation of effective response strategies. Educational flyers and other outreach materials could be used for this effort. • Airports have excellent emergency communications systems that can be used to disseminate water quality event infor- mation to airlines and other interested parties. Airports with previous experience with drinking water quality events use directed emergency notification procedures for effective communications. One airport synthesis participant emphasized that the Emergency Operations Center (EOC) is readily available and should be used without hesitation. • Airports without experience with water quality events envision using airport emergency plans (AEPs) and SOPs to improve notifications of the events. • A significant challenge in the response process is obtaining prompt and accurate notification. Airports and airlines are currently often notified in the same manner and time frame as the general public, which often means notice is received late or not at all. • Interviewees observed that a potential remedy to the prompt notification challenge is to have appropriate airport person- nel included on the water utility’s critical contact list so that they receive notices promptly. • Existing airport notification procedures can be used to disseminate water quality event information to interested airport personnel and tenants. Maintaining accurate contact information is essential; notification recipients must keep their information current. • Several of the synthesis participants consider water quality events to be emergencies and believe they should be handled as such; one airport felt the events could be addressed similar to communicable disease responses. • An SOP for a water quality event can be included as an appendix to existing AEPs, as detailed in FAA Advisory Circular (AC) 150/5200-31C, which gives guidance in meeting the requirements outlined in 14 CFR 139.325. • Each airport has its own unique contact list of stakeholders, including the air carrier station managers located at the airport. Airports can secure buy-in for response plans by engaging these stakeholders in the development of a water quality response. Maintenance of the contact list should occur regularly. This synthesis identified gaps in practice to be addressed by future research and/or collaboration between airports, public water systems, and airlines. • SOPs for water quality event notifications. Airports and airlines requested examples of SOPs for water quality event notifications. SOP templates could address the various types of events that might occur, including precautionary mea-

29 sures, and provide example messaging for conveying the critical event details. Input from airlines, applicable regulatory agencies, and other airport stakeholders can help secure buy-in and ensure that the suggested SOPs meet the needs of the airport community. Examples of potential events include: – Waterborne disease outbreaks – Microbial contamination of the water system – Chemical contamination of the water system – Low chlorine residuals in the water distribution system or water storage tanks – Depressurization that can allow contaminants to enter the water system – Cross connections and backflow events – Water main breaks that disrupt water service – Planned water system infrastructure repair or replacement – FDA watering point inspection non-compliance determination – Adverse conditions in the public water system, such as droughts or floods – Watering point operations and maintenance practices and inspections • Tabletop exercises for emergency response to and notifications of a water quality event. Related to development of SOPs, tabletop exercises could be created for the airport community to address various drinking water quality events and include notification protocols, other activities such as water cabinet lock-out, and essential messaging. • Water cabinet quality and maintenance. Concerns were raised regarding the extent to which operation and maintenance of aircraft watering points affect the quality of water that is boarded onto aircraft. Potential issues that were identified include connective hoses in poor condition; water stagnation; hoses that are exposed for long periods to sunlight, which may affect the quality of water within the hose; and procedures that involve boarding water onto aircraft without properly flushing the equipment. Ownership of water cabinets and the related obligations for their operation and maintenance were also mentioned. An airport interviewee included an example SOP for water cabinets at international terminals, which reflects International Air Transport Association recommendations. The example SOP is included as Appendix C. • List of the water utilities that serve airports. To assist airlines in receiving accurate, real-time information during a water quality event, airline representatives noted that a database of water utility contacts for each airport would be helpful. • Clarification of the regulatory and contractual responsibilities of an airport for issuing notices or performing additional sampling when a water quality event that originates at the water utility affects the airport. There is also interest in airport legal obligations related to the ADWR that should be included in lease agreements between airlines and airports. • Role of the U.S. Food and Drug Administration (FDA) at airports during a water quality event. Airports sought clarification on FDA responsibilities during a water quality event, including who should contact FDA, the role of FDA ITP staff regarding watering point operations and resumption of service after an event, and how FDA ITP staff can be reached. • Considerations for airport water system treatment and operations. Airports with frequent water quality events requested support for compiling a summary of the options for installing water treatment at the airport and the related regulatory, operational, and financial considerations of adding treatment. • Water quality monitoring at airports. Airports considering water quality monitoring would benefit from informa- tion regarding which types of monitoring should be conducted if they are customers of a water utility and have no legal requirements for such monitoring under the Safe Drinking Water Act. Airports requested information on any sugges- tions and reporting protocols for lead and copper, coliform, or other water quality parameters that might be advisable for monitoring. • Water quality and cabinet maintenance at international terminals. Airports expressed concerns about maintenance of these aircraft watering points. They also expressed concern about the sampling of the facilities that is performed by third-party fixed-base operators, the analytical methods and laboratories used and whether they are EPA-approved or -certified, the condition of equipment, and potential confusion with International Air Transport Association standards compared to Aircraft Drinking Water Rule requirements that is created when third parties get positive sample results. Identifying who is responsible for notifications based on those sample results was also identified as a priority.