October 30, 2002

Mark McClellan, MD, PhD

Commissioner

Food and Drug Administration

14-71 Parklawn Building

5600 Fishers Lane

Rockville, MD 20857

Dear Commissioner McClellan:

The International Bottled Water Association (IBWA) congratulates you on your appointment and confirmation as Commissioner of the Food and Drug Administration (FDA). We offer our continued assistance to FDA in ensuring that consumers have access to safe, quality bottled water.

IBWA is the trade association representing the bottled water industry. Founded in 1958, IBWA member companies include over 500 domestic and international bottlers, distributors, and suppliers. Membership in IBWA is contingent on compliance with the IBWA Model Code, which contains a program of annual, unannounced, independent third-party inspections.

The IBWA Model Code provides standards of quality, standards of identity, production practices, labeling requirements, and a Hazard Analysis and Critical Control Points (HACCP) program, along with other requirement for bottle water and its production. As an example of the bottled water industry’s commitment to excellence, the attached new provision on bottled water security was added to the IBWA Model Code at the recent IBWA meeting in Phoenix, Arizona.

The bottled water industry is proud of its high standards and safety record. At an IBWA meeting in June 2002, FDA Deputy Commissioner Lester Crawford said the bottled water industry is “probably the most compliant industry regulated by FDA.” Dr. Crawford went on to say, “Over the years, we’ve [FDA] found bottled water to be among the safest food products on the market.”

IBWA is committed to working with state and federal governments, in concert with the IBWA Model Code, to set stringent bottled water standards for safe, high quality products. Enhanced cooperation and the sharing of information between the bottled water industry and governmental agencies will help provide the basis for appropriate evaluations and responses to improvements in bottled water regulation.

It is in this spirit that IBWA has recommended that FDA issue three new standards of quality for bottled water. Currently, IBWA has asked FDA to institute standards of quality for total coliform, uranium, and arsenic, and to provide guidance to the industry on the monitoring test for nine contaminants. Attached is a copy of the IBWA submission on the FDA Priorities that urges greater priority be placed on developing regulations on these four items.

Again, congratulations on your appointment. If you have any questions or concerns with the bottled water industry, please do not hesitate to contact me at (703) 683-5213 ext. 105, or at jdoss@bottledwater.org.

Sincerely,

Joseph Doss

President

Enclosures (2)