IBWA Response to Consumer Reports Article on PFAS

September 24, 2020

The claim by Consumer Reports that bottled water products with PFAS levels of greater than 1 part per trillion (ppt) pose a human health risk is not based on sound science. The 1 ppt PFAS limit is not a standard generally recognized as appropriate by the scientific community. The testing method used by Consumer Reports cannot accurately and reliably detect the amount of PFAS in bottled water. As a result, their reporting on this issue is misleading and will unnecessarily frighten consumers.

PFAS standards must be set at levels at which the substance can be reliably detected, and the amount can be reported with a reasonable degree of accuracy and precision. Based on this fundamental principle, several state agencies have considered this issue and adopted tap water standards that range from 10 to 14 ppt for individual PFAS compounds. Some of these standards also apply to bottled water. These state standards were based on recommendations from scientists and toxicologists.

IBWA members take consumer health and safety very seriously, which is why IBWA, in the absence of federal requirements for PFAS set stringent standards for PFAS, which all IBWA bottler members must meet. While not mandated by law, IBWA requires its members to test their bottled water products annually for PFAS, using the Environmental Protection Agency Method 537.1. IBWA has adopted a PFAS standard of 5 ppt for one PFAS compound and 10 ppt for more than one compound. This is more stringent than any current state or federal requirement. EPA has set a 70 ppt “health advisory” limit for tap water (not a maximum contaminant level (MCL).

IBWA continues to encourage the U.S. Food and Drug Administration to issue a Standard of Quality (SOQ) regulation for PFAS in bottled water. In late 2019, IBWA sent a letter to FDA with this request, and FDA responded to IBWA’s letter stating that the agency would not issue a PFAS regulation at this time. FDA also said it believes that “establishing SOQs for PFAS in bottled water at this time would not significantly enhance FDA’s mission of public health protection.”

However, FDA said that it would continue to monitor any action by EPA on establishing PFAS MCLs for public drinking water. Under federal law, bottled water regulations must be as protective of the public health as tap water regulations. If EPA issues a PFAS regulation for tap water, FDA is required to review the EPA rule and determine its applicability to bottled water.

For more information on FDA’s research and investigation of PFAS in foods and beverages, see “Statement on FDA’s scientific work to understand per- and polyfluoroalkyl substances (PFAS) in food, and findings from recent FDA surveys” (https://www.fda.gov/news-events/press-announcements/statement-fdas-scientific-work-understand-and-polyfluoroalkyl-substances-pfas-food-and-findings).

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PFAS and Bottled Water Background
Currently, there are no FDA Standards of Quality (SOQs) or testing requirements for per- and polyfluoroalkyl substances (PFAS) in bottled water. However, while not mandated by law, IBWA requires its members to test their bottled water products annually for PFAS, using EPA Method 537.1. In addition, IBWA has established stringent SOQs for PFAS that all bottler members must meet.

These actions underscore the commitment of IBWA members to always provide consumers with the safest and highest quality bottled water products. Testing for PFAS provides consumers, local and state governments, and disaster and emergency relief personnel further assurance that bottled water is a safe and convenient product for everyday use and in times of need when tap water is compromised.

IBWA SOQs for Its Members
IBWA established the following SOQs for PFAS in member company bottled water products:

  • 5 parts per trillion (ppt) for one PFAS
  • 10 ppt for more than one PFAS

IBWA’s SOQs for PFAS are substantially below the EPA’s health advisory level of 70 ppt for tap water. Public water systems that are contaminated with more than 70 ppt must notify their customers and provide an alternate source of drinking water.

Processes and practices used in producing bottled water, such as source protection, reverse osmosis, and carbon filtration, greatly reduce the likelihood that PFAS would be found in bottled water. If it is, IBWA members have access to association-supplied guidance materials for monitoring and controlling PFAS levels in bottled water.

In late 2019, IBWA sent a letter to FDA asking it to issue a SOQ regulation for PFAS in bottled water. FDA responded to IBWA’s letter stating that the agency would not issue a PFAS regulation at this time. FDA also said it believes that “establishing SOQs for PFAS in bottled water at this time would not significantly enhance FDA’s mission of public health protection.”

However, FDA said that it would continue to monitor any action by EPA on establishing PFAS maximum contaminate levels (MCLs) for public drinking water. Under federal law, bottled water regulations must be as protective of the public health as tap water regulations. If EPA issues a PFAS regulation for tap water, FDA is required to review the EPA rule and determine its applicability to bottled water.

For more information on FDA’s research and investigation of PFAS in foods and beverages, see “Statement on FDA’s scientific work to understand per- and polyfluoroalkyl substances (PFAS) in food, and findings from recent FDA surveys” (https://www.fda.gov/news-events/press-announcements/statement-fdas-scientific-work-understand-and-polyfluoroalkyl-substances-pfas-food-and-findings).

PFAS Background
PFAS are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States, since the 1940s (not bottled water companies). PFOA and PFOS have been the most extensively produced and studied of these chemicals.

Both chemicals are very persistent in the environment and in the human body—meaning they don’t break down and can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.

PFAS can be found in the following:

  • Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-contaminated soil or water.
     
  • Commercial household products, including stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams (a major source of groundwater contamination at airports and military bases where firefighting training occurs).
     
  • Workplaces that use PFAS, including production facilities or industries (e.g., chrome plating, electronics manufacturing, or oil recovery).
     
  • Tap water, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility).
     
  • Living organisms, including fish, animals, and humans, where PFAS can build up and persist over time.

For more information about bottled water, visit IBWA’s website: www.bottledwater.org

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Media Contact:
Jill Culora
[email protected]
703.647.4609

The International Bottled Water Association (IBWA) is the authoritative source of information about all types of bottled waters, including spring, mineral, purified, artesian, and sparkling. Founded in 1958, IBWA's membership includes U.S. and international bottlers, distributors and suppliers. IBWA is committed to working with the U.S. Food and Drug Administration (FDA), which regulates bottled water as a packaged food product, to set comprehensive and stringent standards for safe, high-quality bottled water products.

In addition to FDA regulations, IBWA member bottlers must adhere to the IBWA Bottled Water Code of Practice, which mandates additional standards and practices that in some cases are more stringent than federal and state regulations. A key feature of the IBWA Bottled Water Code of Practice is a mandatory annual plant inspection by an independent, third-party organization.

IBWA is proud to be a partner with Keep America Beautiful and a supporter of Drink Up, an initiative of former First Lady Michelle Obama and the Partnership for a Healthier America (PHA), which encourages Americans to drink more water more often – whether from the tap, a filter, or in a bottle. Choosing water is always the healthy choice.