IBWA Consumer Reports Talking Points 2003

IBWA Consumer Reports Talking Points 2003



Article Talking Points and Background Information

December 12, 2002

A recent Consumer Reports article, “What’s in that Bottle?” (January 2003) included a number of inaccuracies regarding bottled water quality, packaging and other issues. Below are some facts that consumers should know:


Bisphenol A (BPA) is not a carcinogen. It is not listed as a possible carcinogen by any U.S. or state government agency or international regulatory body, including the Occupational Safety and Health Administration (OSHA), the International Agency for Research on Cancer (IARC), and the National Toxicology Program (NTP).

There is no convincing scientific or medical evidence that the minute amounts of BPA that might leach into bottled water or other food products from polycarbonate packaging pose any health concerns whatsoever, even for developing fetuses.

Polycarbonate plastics have been used and have proved to be safe for food storage for more than 35 years.

Polycarbonate plastics for food packaging use are regulated by the U.S. Food and Drug Administration (FDA) and international safety regulations to assure their safety in direct food and beverage contact.

BPA is a raw material used in polycarbonate plastics.

BPA is one of the most extensively tested materials in use today and has been extensively studied for decades.

Based on numerous safety tests, the FDA approves of the use of BPA in polycarbonate packaging for all types of foods.

All types of food packaging, bottled water included, must be approved by FDA for food use and contact.


A Multi-Barrier Approach, Disinfection and Bottled Water Quality and Safety

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.

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.

According to FDA bottled water Good Manufacturing Practices (GMPs), bottled water companies are required to use approved sources. The first consists of natural sources (i.e., springs and artesian wells). By law, these sources must be protected from surface intrusion and other environmental influences. This requirement helps ensure that Cryptosporidia and Giardia are not present.

The second type of source consists of approved, potable public water sources. Bottled water companies that use these sources typically reprocess this water using a variety of purification methods. In addition, IBWA members must apply principals of HACCP (Hazard Analysis and Critical Control Point) to bottled water production. HACCP was adapted by IBWA from FDA and the USDA for a science based approach to bottled water safety and quality.

FDA’s standards for contaminants take into account the Environmental Protection Agency’s (EPA public water standards, but are not identical. By law (Safe Drinking Water Act Amendments of 1996), FDA bottled water standards must be at least as stringent and protective of public health as EPA standards for public water. The FDA regulatory framework is not only similar to EPA’s in providing contaminant control, but also incorporates additional safeguards that are unique to regulation of bottled water as a food.

Not all EPA public water standards are applicable to bottled water. However, by law, FDA must review an EPA standard to determine its applicability to bottled water and, within 180 days after promulgation of an EPA standard, either adopt that standard for bottled water or publish in the federal register why a particular standard was not adopted for bottled water.

FDA regulations specify the frequency that bottled water producers must monitor for contaminants: weekly for microbiologics, annually for chemicals and every four years for radiological contaminants (21 CFR 129). The IBWA Model Code builds on the FDA regulatory structure and requires a minimum daily analysis for total coliforms and other microbials for testing “for each type of bottled water produced by the plant.” Typically, a bottled water plant whose daily production volume is 250,000 gallons, conducts 30 total coliform tests per day. On a per gallon basis, a bottled water plant may actually conduct more tests per day than a public water facility, which may also alter its testing/monitoring frequency based on the population level served.

Bottled water companies don’t have to disinfect or test for parasites such as cryptosporidium or giardia–a requirement for city tap water. Cryptosporidium is a waterborne parasite that lives in animals and can be passed into surface water through their waste. Cryptosporidia from animal waste have been found in rivers, streams, lakes and reservoirs and other types of surface water. FDA’s definition of bottled water from ground sources [21 CFR sec.165.110 (a)(2)(ii) states that ground water must not be under the direct influence of surface water,” and therefore is not expected to contain cryptosporidium.

In its review of the Interim Enhanced Surface Water Treatment Rule (IESWTR) FDA determined that it is not necessary to publish a bottled water standard of quality for Cryptosporidium. In the July 5, 2001 notice, FDA states: “FDA has evaluated the treatment technique requirements for the reduction of Cryptosporidium in public drinking water established in EPA’s IESWTR and finds that a standard of quality regulation for bottled water to reduce

Cryptosporidium is not necessary to protect the public health.”

In its discussion of bottled water and the IESWTR, FDA states: “The contaminant may be contained in public water systems, which would be treated to reduce Cryptosporidium before such water would be used for bottled water. Further, because bottled water sources other than public drinking water are from ground water, which by definition (§ 165.110(a)(2)(ii)) must not be ground water under the direct influence of surface water, Cryptosporidium would not be expected to be present. Thus, FDA also concludes that a standard of quality regulation for bottled water

derived from ground water is not necessary to protect public health because Cryptosporidium would not be in ground water used for bottled water.”



Bottled water is among the most stringently regulated food products in the United States, often surpassing standards set for other foods and beverages.

Bottled water is a packaged food product and falls under the strict regulatory authority of the U.S. Food and Drug Administration (FDA). It also is subject to state regulations. In addition, IBWA member companies must comply with the IBWA Model Code, a set of standards that, in many cases, exceeds federal and state requirements. One feature of the IBWA Model Code requires bottlers to undergo annual, unannounced inspections by an independent third party to ensure that they meet those high standards. Such rigorous, unsurpassed regulation goes far in ensuring safe, quality products.

As with other food products, bottled water is subject to FDA recall and misbranding or adulteration provisions, which help further ensure that only safe, high quality bottled water products reach the marketplace.

Bottled water offers consumers a convenient means of enjoying drinking water with consistent safety and quality. This is particularly important for individuals concerned with taste and for people with weakened immune systems.

Although the Consumer Reports article covered it, seltzer water is not considered or defined as “bottled drinking water” by the FDA. Seltzer water is commonly viewed as a soft drink.

Importantly, Consumer Reports’ readers should recognize that while bottled water may vary somewhat from brand to brand, bottled water overall is a high quality, safe, stringently regulated product that provides consistent good taste. The steady increase in bottled water usage in the last 30 years underscores consumers’ overwhelming satisfaction with bottled water products.


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The International Bottled Water Association (IBWA) is the authoritative source of information about all types of bottled waters distributed in the United States. Founded in 1958, IBWA’s membership includes U.S. and international bottlers, distributors and suppliers. 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. 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.