December 12, 2002

James B. Bramson, D.D.S.

Executive Director

American Dental Association

211 East Chicago Avenue

Chicago, IL 60611

Dear Dr. Bramson:

The International Bottled Water Association (IBWA) is aware of the American Dental Association’s (ADA) House of Delegates Resolution 67H, which calls for all bottled water labeling to include fluoride concentration and company contact information, including address and telephone number. While IBWA appreciates ADA’s commitment to informing consumers about the bottled water they choose, we feel that such measures as called for in the Resolution are not necessary and duplicative of existing U.S. Food and Drug Administration (FDA) and certain state regulations and bottled water industry standards.

Bottled water is regulated comprehensively by FDA as a packaged food product and a number of regulations and standards already exist that govern bottled water labeling in both of these important areas.

As a packaged food product, bottled water labels must contain the name and place of business of the bottler, packer or distributor. With this information, consumers may contact the bottled water company directly to obtain information about the product. Bottled water companies must also follow fluoride labeling guidelines should fluoride be added to the product or be present at a naturally occurring level that warrants inclusion of such information. Additionally, bottled water companies must adhere to the Nutrition Labeling and Education Act (NLEA), which dictates ingredient and nutrition labeling requirements for bottled water and all foods.

Furthermore, IBWA members are required, by the IBWA Model Code to include a contact telephone number on proprietary brand labels so that consumers may contact a company directly to obtain meaningful information about their bottled water brand of choice.

For consumers who want fluoride in their drinking water and wish to choose bottled water, approximately 30 IBWA member companies make clearly-labeled fluoridated bottled water products that typically contain a fluoride concentration of one part-per-million, which is within the range of optimally fluoridated water as recommended by ADA. As required by FDA regulations, these brands are labeled as “fluoridated,” “fluoride added,” “fluoride enhanced,” or other language that clearly informs the consumer about the product’s fluoride content. FDA has determined that products, which contain only trace levels of nutrients, including fluoride, are not required to carry concentration labeling as these products do not contain quantities of any health or dietary significance. IBWA supports this conclusion, as bottled water is a conventional food product regulated under FDA authority, which does not require fluoride labeling of other food products despite the fact that these foods may or may not contain fluoride at, what are considered, optimal levels.

While IBWA does not support inclusion of fluoride concentration labeling for all bottled water products, we fully agree with ADA’s counsel to dentists and dental care providers to question patients about their source of drinking water to determine if they are consuming water with optimal fluoride levels or not. IBWA already advises consumers to consult with their dental care providers if they drink – or are considering – fluoridated bottled water products.

We would also encourage ADA to advise its members to further expand their line of questioning to include inquiries about the other foods and beverages in their diet that may or may not deliver fluoride via ingestion.

In March 2000, IBWA had the privilege of meeting with ADA staff representatives at your Chicago headquarters to share information about bottled water, the availability of fluoridated brands and to expand dialogue between our groups on mutually important issues. Since that meeting, we have continued to exchange information with key ADA staff. In fact, as of this writing, we have a call scheduled with Jane McGinley, ADA’s manager of fluoridation and preventive health activities to explore how ADA and IBWA may maximize effective, logical dental care provider and consumer outreach on these issues.

It is my sincere hope that IBWA may again meet with ADA at a time and location convenient to you and your staff at the earliest opportunity. I very much look forward to enhancing our interaction so that we may best serve American consumers and take steps to promote accurate information on this topic.

Thank you in advance for your consideration.

Sincerely,

Joseph K. Doss

IBWA President

cc:

Jane McGinley, ADA Manager of Fluoridation and Preventive Health Activities

Stephen Kay, IBWA Vice President, Communications