October 24, 2003
Food Guide Pyramid Reassessment Team
USDA Center for Nutrition Policy and Promotion
3101 Park Center Drive, Room 1034
Alexandria, VA 22302
To the Food Guide Pyramid Reassessment Team:
The International Bottled Water Association (IBWA) welcomes this opportunity to submit comment on proposed revisions to the food intake patterns that form the basis of the Food Guide Pyramid. IBWA is a trade association representing the bottled water industry and 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.
IBWA stresses the importance of water consumption for proper hydration and refreshment and strongly encourages the inclusion of water consumption in the 2005 revision of the Dietary Guidelines and resulting Food Pyramid. The National Academy of Sciences Panel on Dietary Reference Intakes (DRIs) for Water is expected to report on specific water DRIs; a report that was scheduled for release in March 2003 but has been delayed with a possible release in, I have been informed, December 2003. DRIs are most often used as the scientific basis for additions/inclusion in the Dietary Guidelines. IBWA respectfully urges the Food Guide Pyramid Reassessment Team to seriously consider and utilize the science as reflected in the water DRI as a basis for inclusion of water for refreshment and hydration in the Food Guide Pyramid. If Guidelines are provided for general fluid intake, water – whether from a bottle or the tap – should be specified among those recommendations.
IBWA has noted that, while the final report on the 2000 Dietary Guidelines include references to the importance of drinking water, there are no specific daily intake recommendations. Proper hydration is absolutely crucial for human fitness, health, and well being. The “Modified Food Pyramid for 70+ Adults,” developed by the USDA Human Nutrition Research Center on Aging at Tufts University, has made a recommendation for eight daily servings of water to form the foundation for the “Modified Food Pyramid for 70+ Adults.” By all accounts, recommended water intake is most appropriate for inclusion in the 2005 Dietary Guidelines and resultant general Food Pyramid for all age groups.
Water is an excellent choice for hydration and refreshment because it does not contain calories, caffeine, sugar, artificial coloring, alcohol and other ingredients that may contribute to overweight/obesity, hypertension and other maladies. Based on statistics , the average consumer drinks up to two quarts of water per day, regardless of the source. Depending on an individual’s weight and level of exercise or activity, that amount may vary. However, water is an ideal drink of choice for all age groups and levels of activity. For the active to moderately active person, water provides hydration and refreshment to replace fluids lost during exercise. For sedentary individuals, water hydrates and refreshes without adding calories. For all persons, water and proper hydration aids many other physiological functions including cushioning of the joints, aiding digestion, cognitive function and respiration.
Bottled water, as a package food product regulated by the US Food and Drug Administration (FDA) is a sensible reference point for the Dietary Guidelines as it is a food product that delivers the above mentioned benefits of water while providing consistent safety, quality, convenience and good taste.
Stephen R. Kay
Vice President, Communications