IBWA Arsenic Communications Talking Points

IBWA Arsenic Communications Talking Points


Bottled Water Safety and Arsenic Standards

December 3, 2003


Arsenic is a little understood compound which, despite the many other elements regulated in bottled water, captures the attention — and imagination — of consumers and media. To provide background information to IBWA members as they may address consumer and other inquiries, IBWA has prepared the talking points below. This information is for background. Any statements or communications with regard to a specific brand must be tailored to include the facts as they pertain to that specific brand.


Talking Points

    • Arsenic is a naturally occurring substance widely found in soil, water, and almost all plant and animal life, including the human body.
    • IBWA members, through the IBWA Model Code, are currently required to adhere to a 10 parts-per-billion (ppb) arsenic standard and has recommended to FDA that the agency lower the arsenic standard of quality to 10 ppb and implement this new standard promptly.
    • If either the federal government or IBWA conclude that, based on good science, present levels are not stringent enough, IBWA will support more stringent standards.
    • The Total Dietary Study (TDS), sometimes called the Market Basket Study, is an ongoing FDA program that determines levels of various contaminants and nutrients in foods.
    • Results from FDA’s TDS indicate that the highest concentration of arsenic in foods occur in seafood, followed by rice/rice cereal, mushrooms, and poultry. Arsenic levels found in shellfish range from 1,100 ppb to 30,000 ppb. (The U.S. FDA allowable limits for arsenic in seafood range from 2,000 ppb to 50,000 ppb).
    • Arsenic levels were found in turkey breast tested as part of the TDS at levels up to 53 ppb. Arsenic levels in sweet potatoes were found up to 26 ppb. Mashed potatoes contained arsenic up to 42 ppb. Rice contained arsenic up to 100 ppb. Black olives contained arsenic up to 30 ppb. Apple pie contained arsenic levels up to 32 ppb. Wine contained arsenic levels up to 23 ppb.
    • The international Codex Committee on Food Additives and Contaminants (CCFAC), which establishes standards for contaminants in foods, states that arsenic levels in the typical diet do not present a public health concern.
    • Arsenic is the 20th most abundant element in the earth’s crust. As such, it occurs naturally in soil, foods, water, and the human body. According to the EPA, the average U.S. arsenic levels are 5,000 ppb in soil, 20 to 140 ppb in food, 2 ppb in water, and 0.02 to 0.10 ug/m3 in air. As a result of all these “natural” exposures, the average American is exposed to approximately 50 ppb per day of arsenic. Once absorbed into the body, most arsenic is metabolized and excreted quite quickly, with a half-life of 2-4 days. Because arsenic can be metabolized within the body into less toxic forms, many scientists believe that there exists an exposure level below which no adverse health effects would occur.


General FDA/Regulatory Background Information

    • Bottled water is fully regulated as a packaged food product by the U.S. Food and Drug Administration (FDA) and bound by FDA’s quality, safety, inspection and labeling requirements. Bottled water products are required to comply at all times with FDA Standards of Quality. As with other food products, bottled water is subject to voluntary recalls and FDA enforcement actions ranging from warning letters to product seizures, which help ensure that adulterated or mislabeled products do not reach the consumer.
    • In addition to federal and state regulations, members of the International Bottled Water Association (IBWA) are required to adhere to standards in the IBWA Model Code that, in several cases, are stricter than FDA and state bottled water regulations. The IBWA Model Code is enforced through a mandatory, annual, unannounced plant inspection by an independent, third-party organization.
    • Water used to produce bottled water is tested both as it enters the plant, during production and as finished product. Multiple tests and regular screening are performed by trained quality control technicians to evaluate microbial, physical and chemical quality. Such screening can be used to detect the presence of agents that may be an indicator of product contamination. These protection measures and other quality control programs help ensure that substandard products do not reach the market.
    • 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, the FDA considers HACCP a comprehensive method for assuring product safety.


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The International Bottled Water Association (IBWA) is the authoritative source of information about all types of bottled waters. Founded in 1958, IBWA’s membership includes U.S. and international bottlers, distributors and suppliers. Strengthened by IBWA Model Code, the Association is committed to working with the U.S. Food and Drug Administration (FDA), which regulates bottled water as a packaged food product, and state governments to set stringent standards for safe, high quality bottled water products. Consumers can contact IBWA at 1-800-WATER-11 or log onto IBWA’s web site (www.bottledwater.org) for more information about bottled water and a list of members’ brands. Media inquiries can be directed to Gwen Haynes at 703-683-5213.