IBWA ISSUE BACKGROUNDER
May 6, 2005
BACKGROUND
The ABC-TV News program 20/20 has scheduled for May 6, 2005 at 10:00 p.m. eastern a program segment on bottled water. For the piece, 20/20 Co-anchor John Stossel conducted a consumer taste test and conducted lab tests on five brands of bottled water and compared results to New York City tap water. All IBWA member brands involved in the program have been alerted about their inclusion in the program. The lab tests focused on measures of Heterotrophic Plate Count (HPC), total coliform and E coli, and male specific bacteriophage. Brands tested fared very well with minimal and fully acceptable HPC readings, total coliform and E. coli were undetectable and male specific phage all read negative. New York City tap water, tested for the same parameters, also had acceptable results. The taste test appears to be a focus of the program and although brands fared well here, too, the show may attempt to create controversy by asking the question “why pay for bottled water?”
IBWA has been working aggressively with the 20/20 producers to represent IBWA’s position on a variety of bottled water issues and has provided published research and other factual information on bottled regulation, safety and quality as well as insight into the reasons why consumers choose bottled water.
IBWA has developed this issue background document to help members in the event they receive related inquiries following the broadcast. The document is based on an estimation of the program content gained from interactions with the program producers, taped interviews, and informational requests. IBWA will monitor the broadcast and take follow up steps as warranted.
INFORMATION POINTS
Regulations and Safety
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- Bottled water is comprehensively regulated at the federal level by the U.S. Food and Drug Administration (FDA) as a packaged food product. By law, FDA bottled water standards must be at least as stringent and protective of public health as U.S. Environmental Protection Agency (EPA) tap water standards. On top of this, bottled water is subject to additional FDA bottled water-specific standards and Good Manufacturing Practices (GMPs), as well as general food regulations that help ensure the safety of our nation’s food supply.
- Bottled water is comprehensively regulated at the federal level by the U.S. Food and Drug Administration (FDA) as a packaged food product. By law, FDA bottled water standards must be at least as stringent and protective of public health as U.S. Environmental Protection Agency (EPA) tap water standards. On top of this, bottled water is subject to additional FDA bottled water-specific standards and Good Manufacturing Practices (GMPs), as well as general food regulations that help ensure the safety of our nation’s food supply.
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- FDA mandates compliance with bottled water standards including microbiological standards and regulations for inorganic chemicals, secondary inorganic parameters, volatile organic chemicals, semivolatile organic chemicals, synthetic organic chemicals, radiological contaminants, water properties, and additional regulated substances.
- FDA mandates compliance with bottled water standards including microbiological standards and regulations for inorganic chemicals, secondary inorganic parameters, volatile organic chemicals, semivolatile organic chemicals, synthetic organic chemicals, radiological contaminants, water properties, and additional regulated substances.
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- FDA requires bottled water companies to adhere to the bottled water Standard of Identity, which establishes uniform labeling terms that mandate specific conditions and other factors as to how a brand may be labeled. Some of the regulated terms commonly used include, “spring water,” “artesian water,” “purified water,” “distilled water,” “sparkling bottled water,” and “mineral water;” labeling terms to which a consumer should pay attention.
- FDA requires bottled water companies to adhere to the bottled water Standard of Identity, which establishes uniform labeling terms that mandate specific conditions and other factors as to how a brand may be labeled. Some of the regulated terms commonly used include, “spring water,” “artesian water,” “purified water,” “distilled water,” “sparkling bottled water,” and “mineral water;” labeling terms to which a consumer should pay attention.
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- If a consumer desires spring water, they should select a brand that carries the “spring water” Standard of Identity. The same holds true for purified water or any of the other bottled water categories as defined by FDA.
- If a consumer desires spring water, they should select a brand that carries the “spring water” Standard of Identity. The same holds true for purified water or any of the other bottled water categories as defined by FDA.
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- If incorrectly labeled, bottlers are subject to FDA misbranding and other provisions. Further, like all FDA-regulated food products, bottled water is subject to recall, seizure or other enforcement actions to help ensure that mislabeled, misbranded or adulterated product does not reach the consumer.
- If incorrectly labeled, bottlers are subject to FDA misbranding and other provisions. Further, like all FDA-regulated food products, bottled water is subject to recall, seizure or other enforcement actions to help ensure that mislabeled, misbranded or adulterated product does not reach the consumer.
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- In addition, IBWA bottler members take extra measures to help ensure that their products and production facilities adhere to FDA and state regulations as well as the IBWA Model Code, a set of standards that in certain cases exceeds those required by federal and state authorities.
- In addition, IBWA bottler members take extra measures to help ensure that their products and production facilities adhere to FDA and state regulations as well as the IBWA Model Code, a set of standards that in certain cases exceeds those required by federal and state authorities.
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- Bottled water products are produced utilizing a multi-barrier approach, from source to finished product, that helps prevent possible harmful microorganisms from contaminating the finished product as well as storage, production, and transportation equipment. Measures in a multi-barrier approach may include source protection, source monitoring, reverse osmosis, distillation, filtration, ozonation or ultraviolet (UV) light. Many of the steps in a multi-barrier system may be effective in safeguarding bottled water from microbiological and other contamination. Piping in and out of plants, as well as storage silos and water tankers are also maintained through daily sanitation procedures. In addition, bottled water products are bottled in a controlled, sanitary environment to prevent contamination during the filling operation.
- Bottled water products are produced utilizing a multi-barrier approach, from source to finished product, that helps prevent possible harmful microorganisms from contaminating the finished product as well as storage, production, and transportation equipment. Measures in a multi-barrier approach may include source protection, source monitoring, reverse osmosis, distillation, filtration, ozonation or ultraviolet (UV) light. Many of the steps in a multi-barrier system may be effective in safeguarding bottled water from microbiological and other contamination. Piping in and out of plants, as well as storage silos and water tankers are also maintained through daily sanitation procedures. In addition, bottled water products are bottled in a controlled, sanitary environment to prevent contamination during the filling operation.
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- IBWA members are required to employ a HACCP (Hazard Analysis Critical Control Point) approach to quality assurance. This practice scrutinizes every step of the production process – from source to finished product – that are critically important to the safety of the product and puts in place systems to help ensure that all safety and quality control processes are functioning effectively. Identification of risk and severity of health effects and control measures for specific biological, chemical and physical agents are included. Widely used in the food and pharmaceutical industries, FDA considers HACCP a comprehensive method for assuring product safety.
- IBWA members are required to employ a HACCP (Hazard Analysis Critical Control Point) approach to quality assurance. This practice scrutinizes every step of the production process – from source to finished product – that are critically important to the safety of the product and puts in place systems to help ensure that all safety and quality control processes are functioning effectively. Identification of risk and severity of health effects and control measures for specific biological, chemical and physical agents are included. Widely used in the food and pharmaceutical industries, FDA considers HACCP a comprehensive method for assuring product safety.
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- Municipal sourced bottled waters municipal sourced bottled waters are valid, regulated and accepted by FDA and state governments. Those that are purified, per the FDA bottled water Standard of Identity, must meet the definition of purified water in the United States Pharmacopoeia and labeled appropriately as “purified water” or other suitable names for treated bottled water such as “distilled water” or the other allowable terms.
- Municipal sourced bottled waters municipal sourced bottled waters are valid, regulated and accepted by FDA and state governments. Those that are purified, per the FDA bottled water Standard of Identity, must meet the definition of purified water in the United States Pharmacopoeia and labeled appropriately as “purified water” or other suitable names for treated bottled water such as “distilled water” or the other allowable terms.
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- The 20/20 lab tests focused on measures of HPC, total coliform and E coli, and male specific bacteriophage. Brands tested fared very well with minimal and fully acceptable HPC readings, total coliform and E. coli were undetectable and male specific phage all read negative.
- The 20/20 lab tests focused on measures of HPC, total coliform and E coli, and male specific bacteriophage. Brands tested fared very well with minimal and fully acceptable HPC readings, total coliform and E. coli were undetectable and male specific phage all read negative.
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- All bottled water brands tested by 20/20 for this report had excellent results of their microbiological lab tests, a point that should be highlighted in the final segment.
- All bottled water brands tested by 20/20 for this report had excellent results of their microbiological lab tests, a point that should be highlighted in the final segment.
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- Some of the tested brands had minimal or “background” levels of HPC. Any health or food standards agency, worldwide, would agree that these are acceptable measurements and such results, would not raise concern for human health. Such expert agencies include the World Health Organization (WHO), FDA and EPA.
- Some of the tested brands had minimal or “background” levels of HPC. Any health or food standards agency, worldwide, would agree that these are acceptable measurements and such results, would not raise concern for human health. Such expert agencies include the World Health Organization (WHO), FDA and EPA.
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- HPC is a measure of naturally occurring microbes found in a wide array of food products. HPC also is found in both bottled and municipal waters. In general, HPC organisms serve to prevent the growth of opportunistic pathogens because they have the strength to help overcome harmful bacteria and pathogens that may pose a health threat. There has never been a documented illness associated with HPC.
- HPC is a measure of naturally occurring microbes found in a wide array of food products. HPC also is found in both bottled and municipal waters. In general, HPC organisms serve to prevent the growth of opportunistic pathogens because they have the strength to help overcome harmful bacteria and pathogens that may pose a health threat. There has never been a documented illness associated with HPC.
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- Both public water and bottled water have some HPC content regardless of treatment method or residual disinfection concentrations. No treatment process used in mass production of drinking water yields a totally sterile product.
- Both public water and bottled water have some HPC content regardless of treatment method or residual disinfection concentrations. No treatment process used in mass production of drinking water yields a totally sterile product.
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- In April 2002, a World Health Organization Expert Panel on HPC Bacteria determined that the presence of HPC bacteria in water does not pose a health threat. Specifically, the panel concluded “Microorganisms naturally occurring in water are a normal part of the microbiota of bottled waters that meet appropriate safety norms. HPC counts are used by some as process management indicators in bottled water production and not as health risk indicators.”
- In April 2002, a World Health Organization Expert Panel on HPC Bacteria determined that the presence of HPC bacteria in water does not pose a health threat. Specifically, the panel concluded “Microorganisms naturally occurring in water are a normal part of the microbiota of bottled waters that meet appropriate safety norms. HPC counts are used by some as process management indicators in bottled water production and not as health risk indicators.”
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- The WHO findings confirm the EPA and the FDA’s belief that the presence of HPC bacteria does not pose a health threat. EPA conducted an extensive review of the health effects of HPC prior to promulgating new drinking water regulations in 1991 and the FDA conducted a similar review in generating its bottled water regulations.
- The WHO findings confirm the EPA and the FDA’s belief that the presence of HPC bacteria does not pose a health threat. EPA conducted an extensive review of the health effects of HPC prior to promulgating new drinking water regulations in 1991 and the FDA conducted a similar review in generating its bottled water regulations.
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- For bottled water, the water entering a bottle is free of harmful pathogens. Harmful pathogens cannot develop in the sealed environment provided by the bottle. Once water enters the bottle, the small number of HPC do what they do in nature: they utilize available nutrients and multiply. The dead HPC deteriorate, returning available carbon and nitrogen to the water. Individual species of HPC increase and decrease in numbers over a long period of time. Thus, sampling a particular bottle will only produce a snapshot of the HPC content at that one point in time. Eventually, all the nutrients are utilized and the HPC counts become very low, or even undetectable.
Consumers Demand Bottled Water
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- Consumers recognize the value of bottled water and view it as a worthwhile expenditure because of the convenience and consistent safety, quality and good taste. Statistics from the Beverage Marketing Corporation show that in 2003, bottled water became the second most consumed beverage behind carbonated soft drinks and this trend continued in 2004. Key statistics from 2004 demonstrate continued consumer demand for bottled water with bottled water volume of nearly 6.8 billion gallons, an 8.6 percent increase over 2003, and 2004 bottled water per capita consumption level of 23.8 gallons, compared to 22.1 gallons per capita the previous year.
- Consumers recognize the value of bottled water and view it as a worthwhile expenditure because of the convenience and consistent safety, quality and good taste. Statistics from the Beverage Marketing Corporation show that in 2003, bottled water became the second most consumed beverage behind carbonated soft drinks and this trend continued in 2004. Key statistics from 2004 demonstrate continued consumer demand for bottled water with bottled water volume of nearly 6.8 billion gallons, an 8.6 percent increase over 2003, and 2004 bottled water per capita consumption level of 23.8 gallons, compared to 22.1 gallons per capita the previous year.
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- 20/20’s admittedly “non-scientific” taste test, where some respondents gave New York City tap water high marks, indicates that New York City tap water providers deliver quality drinking water. The 20/20 taste testers also rated bottled water highly.
- 20/20’s admittedly “non-scientific” taste test, where some respondents gave New York City tap water high marks, indicates that New York City tap water providers deliver quality drinking water. The 20/20 taste testers also rated bottled water highly.
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- But consumers in New York and other cities across the United States choose bottled water because they are not always satisfied with the aesthetic qualities (e.g., taste, odor, color) of their tap water. Where the five brands of bottled water taste-tested by 20/20 fared well, there was not an “apples to apples” comparison where tap water samples from other municipalities were tasted and compared.
- But consumers in New York and other cities across the United States choose bottled water because they are not always satisfied with the aesthetic qualities (e.g., taste, odor, color) of their tap water. Where the five brands of bottled water taste-tested by 20/20 fared well, there was not an “apples to apples” comparison where tap water samples from other municipalities were tasted and compared.
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- There are thousands of tap systems across the US, most of which are succeeding; but others are faced with occasional “challenges” or natural events such as hurricanes, blizzards or floods that may cause service interruptions. In these cases, consumers, often at the behest of state agencies, have boil or bottled water alerts. The bottled water industry works in partnership with states/localities to provide bottled water to households during these events.
- There are thousands of tap systems across the US, most of which are succeeding; but others are faced with occasional “challenges” or natural events such as hurricanes, blizzards or floods that may cause service interruptions. In these cases, consumers, often at the behest of state agencies, have boil or bottled water alerts. The bottled water industry works in partnership with states/localities to provide bottled water to households during these events.
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- It does not, however, always boil down to a tap versus bottled water choice. Many consumers likely drink both bottled and tap water, depending on their circumstances.
- It does not, however, always boil down to a tap versus bottled water choice. Many consumers likely drink both bottled and tap water, depending on their circumstances.
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- If a consumer chooses to carry around a personal container and fill it with tap water, drink from a public water fountain, use the sink at home or work, or make any other beverage choice, the bottled water industry does not disparage these choices.
- If a consumer chooses to carry around a personal container and fill it with tap water, drink from a public water fountain, use the sink at home or work, or make any other beverage choice, the bottled water industry does not disparage these choices.
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- Widespread bottled water advertising is a recent development. Consumers have, for many decades, selected bottled water based on its merits, not on a massive ad campaign. Further, typical bottled water advertisements focus on brand and lifestyle attributes and the value of water – and bottled water – for refreshment and hydration and there is no industry-wide campaign to demean the quality of tap water. IBWA members ascribe to the IBWA Code of Advertising, which encourages members not to disparage tap water.
- Widespread bottled water advertising is a recent development. Consumers have, for many decades, selected bottled water based on its merits, not on a massive ad campaign. Further, typical bottled water advertisements focus on brand and lifestyle attributes and the value of water – and bottled water – for refreshment and hydration and there is no industry-wide campaign to demean the quality of tap water. IBWA members ascribe to the IBWA Code of Advertising, which encourages members not to disparage tap water.
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- Considering our national (and global) obesity epidemic as reported by government agencies and health experts worldwide, water — and the selection of bottled water – provides a beverage that helps individuals avoid or moderate calories or ingredients such as caffeine, sugar, alcohol, and artificial coloring or flavoring.
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- Also consider the recently released USDA “My Food Pyramid” and Dietary Guidelines, which encourage physical activity and choice of healthy foods and beverages, it makes sense to encourage consumers to drink plenty of water, bottled water included.
- Also consider the recently released USDA “My Food Pyramid” and Dietary Guidelines, which encourage physical activity and choice of healthy foods and beverages, it makes sense to encourage consumers to drink plenty of water, bottled water included.
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- For consumers who want fluoride in their drinking water and wish to choose bottled water, there are a number of clearly labeled fluoridated bottled water brands available across the United States. However, for consumers that do not wish to ingest fluoride from their bottled water, there are non-fluoridated brands to choose from.
The Value of Bottled Water, Why It Costs Money and Tap Water Is Not Free
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- The cost of bottled water to the consumer includes the cost of the water at the source, operation of facilities to process and/or package the water, quality control equipment and staff, regulatory compliance, the bottling operation and delivery costs, which include personnel, route management and equipment.
- The cost of bottled water to the consumer includes the cost of the water at the source, operation of facilities to process and/or package the water, quality control equipment and staff, regulatory compliance, the bottling operation and delivery costs, which include personnel, route management and equipment.
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- Waters used for bottled water come from private springs, wells, underground aquifers or from municipal sources. Costs per gallon at the source vary widely by region and source.
- Waters used for bottled water come from private springs, wells, underground aquifers or from municipal sources. Costs per gallon at the source vary widely by region and source.
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- Consumers recognize the value of bottled water and view it as a worthwhile expenditure to ensure that they are enjoying high quality water that is safe to drink.
- Consumers recognize the value of bottled water and view it as a worthwhile expenditure to ensure that they are enjoying high quality water that is safe to drink.
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- Substantial costs may be incurred to secure high quality water supplies. These include land acquisition, returning land to non-commercial or non-agricultural use, land management and land grading.
- Substantial costs may be incurred to secure high quality water supplies. These include land acquisition, returning land to non-commercial or non-agricultural use, land management and land grading.
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- A large percentage of the cost of some bottled water brands goes to water filtration and purification processes, such as ozonation, distillation and reverse osmosis. For example, highly specialized filters can cost bottlers tens of thousands of dollars each month.
- A large percentage of the cost of some bottled water brands goes to water filtration and purification processes, such as ozonation, distillation and reverse osmosis. For example, highly specialized filters can cost bottlers tens of thousands of dollars each month.
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- Ongoing quality monitoring, frequent water testing and plant inspections account for significant costs for each bottler. The IBWA Model Code, followed by all IBWA members, requires daily microbial sampling and analysis.
- Ongoing quality monitoring, frequent water testing and plant inspections account for significant costs for each bottler. The IBWA Model Code, followed by all IBWA members, requires daily microbial sampling and analysis.
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- All bottled water must be packaged in FDA approved food-grade containers. Caps used to seal each container must also meet strict government standards.
- All bottled water must be packaged in FDA approved food-grade containers. Caps used to seal each container must also meet strict government standards.
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- Costs for transporting water to retailers, homes, businesses and institutions (hospitals, schools, nursing homes, etc.) include delivery equipment, labor and route management.
- Costs for transporting water to retailers, homes, businesses and institutions (hospitals, schools, nursing homes, etc.) include delivery equipment, labor and route management.
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- The bottled water industry does not receive government subsidies, does not use government facilities for water delivery and does not have free access to water sources.
- The bottled water industry does not receive government subsidies, does not use government facilities for water delivery and does not have free access to water sources.
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- Tap water is not free. Households and businesses pay water/utility bills as rate-payers. Further, these systems may be supported by taxes and government subsidies. And, according to organizations representing the tap water industry, EPA, state governments and others, the tap/drinking water infrastructure is in need of repair, maintenance and/or upgrade or aging pipes and distribution systems. The cost of this has been estimated to be in the trillions of dollars, which is expected to result in a per-household cost that may be several thousand dollars.
Recycling
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- The bottled water industry believes in recycling and actively supports curbside or “comprehensive” recycling programs. Bottled water is only one product in a big universe of all packaged goods, which are delivered to consumers in plastic. While beverage containers comprise a fraction of materials in landfills, bottled water containers are an even smaller percentage of that. To single out bottled water as any more polluting or dangerous than others is to focus on a miniscule portion of the challenge and ignore the fact that today’s society demands and relies upon food and drink packaged in materials allowed by FDA.
- The bottled water industry believes in recycling and actively supports curbside or “comprehensive” recycling programs. Bottled water is only one product in a big universe of all packaged goods, which are delivered to consumers in plastic. While beverage containers comprise a fraction of materials in landfills, bottled water containers are an even smaller percentage of that. To single out bottled water as any more polluting or dangerous than others is to focus on a miniscule portion of the challenge and ignore the fact that today’s society demands and relies upon food and drink packaged in materials allowed by FDA.
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- The bottled water industry is one of the original recyclers as we collect, properly clean, sanitize and re-use the larger water cooler bottles found in many homes and offices. When their life cycle is complete, they are collected and recycled to become part of many common consumer products.
