October 28, 2003 — McCormick Place, Chicago, IL

October 28, 2003 — McCormick Place, Chicago, IL



McCormick Place

Chicago, Illinois

Tuesday, October 28, 2003

1:00 p.m. – 4:15 p.m.




I. Call Meeting to Order

The meeting was called to order by the Chairman, Al Lear, Wissahickon Spring Water Company, who announced the presence of a quorum. Those present were:


Committee Chair

Al Lear, Wissahickon Spring Water Company


Committee Members:

Barry Bell, Blue Hills Spring Water, Inc.

Joe Benacquista, Portola Packaging

Tammy Bliss, CCDA Waters, LLC

Sam Broh, Pine Valley Water Company

Doug Carlson, Natural Waters of Viti

John Cooke, Steelhead, Inc.

Glen Davis, Absopure Water Co.

Jack Donohue, ENSR, International

Vincent Ducasse, Group Danone

Andy Eaton, MWH Labs

Rick Hess, Hess Machine International

Douglas Hidding, Blackhawk Molding Co., Inc.

John Houser, Culligan International

Kent Kise, Suntory Water Group, Inc.

Jeff Koelewyn, BSK Analytical Labs

Lisa Madsen, Pall Corporation

Kevin Mathews, Nestlé Waters North America, Inc.

Doug Oberhamer, Deep Rock Water Co.

Richard Pellerito, Severn Trent Services, UAT

Efrem J. Pesyna, S&S Biopath

Jo Russell-Price, Mountain Valley Spring Co.

Kristin Safran, National Testing Laboratories, Ltd.

Steven Stafford, Eastman Chemical Company



Stephen Edberg, Ph.D., Yale University School of Medicine

Alan Leff, QUASI, LLC

Loren Merrick, NSF International


IBWA Staff and Counsel:

Joe Doss, IBWA

Brooke Fisher, IBWA

Kim Green, IBWA

Stephen Kay, IBWA

Bob Hirst, IBWA


I. Approval of Minutes

It was MOVED AND SECONDED to approve the minutes of the June 18, 2003 Technical Committee meeting.


II. Task Force/Subcommittee Status Reports

The Committee reviewed the activity status of the Subcommittees, Task Forces, and Teams as follows:


1. Bromate Task Force (reported by Shayron Barnes-Selby, DWNA)

It was reported that IBWA received a response from the California Office of Environmental Health and Hazard Assessment (OEHHA), through Livingston and Mattesich, to the association’s request for an interpretive guideline for bromate. OEHHA ruled that the request could not be granted as it must be accomplished by the adoption of a regulation under California’s Administrative Procedures Act. It also stated that it “lacks the authority to set an alternative risk level by means of an interpretive guideline…” The agency did express a “willingness to consider the merits of developing a regulation that specifies an alternative risk level for bromate in bottled water.” However, state budget restraints will delay any such action.

The task force and technical committee discussed the future of the task force, and decided to continue the group as the D/DBP Task Force. The group will become active as needed.

2. Pilot Plant Task Force (reported by Al Lear, Wissahickon Spring Water)

A report on the low ozone study conducted at the pilot plant earlier in 2003 has been finalized and is available to IBWA members. The results of the study were discussed at the June committee meeting, and were reviewed in brief at this meeting. The task force is considering “next steps” based on the results of the low ozone study. Areas of interest that were observed during the low ozone study include the effects of pH, temperature, and other conditions on bromate formation and variables associated with container materials.

The task force publicly thanked all bottler and supplier members who contributed time and talent to the pilot plant project.

Technical Committee members agreed that projects at the Pilot Plant are an important part of the Committee’s activities. Members agreed to provide the Pilot Plant Task Force with ideas for future studies. Kristin Safran volunteered to pull together ideas for consideration by the Pilot Plant Task Force.

3. Audit Program Evaluation Team (reported by Shayron Barnes-Selby, DWNA)

It was reported that the Audit Program Evaluation Team (APET) met by conference call on August 26, 2003 to review a number of issues. First, the team was asked to review IBWA’s policy on inspection of returnable bottles at plants. Current policy is to require organoleptic testing of all returnable bottles, regardless of the cap type. A number of members had expressed concern that the practice is unnecessary for bottles returned with “spill-proof” safety caps still intact. There were also concerns about potential exposure to hazardous substances that may be in some returned bottles. The team ruled that “inspection of bottles may not include “sniffing,” but rather a thorough visual inspection is required.” Additional discussions will be conducted to include HACCP in the final language for the IBWA Audit Handbook. The policy change will be added to the Audit Handbook by January, 2004.

APET also prepared a summary of new responsibilities of the third party auditor, to be incorporated into the new NSF International contract, effective on January 1, 2004. The transfer of tasks was accomplished primarily in response to member concerns over privacy of information.

4. Packaging Subcommittee (reported by Al Lear, Wissahickon Spring Water Company and Jo Russell-Price, Mountain Valley Spring Company)

It was reported that the Packaging Subcommittee completed a new document for IBWA members that provides guidance for establishing and maintaining a sample retention program. The document is available from IBWA and will be made available to IBWA members through the Members Only section of the IBWA web site.

The Subcommittee met by conference call on October 14, 2003 to review the status of HDPE, PET, and container/closure work products. The safety of sports caps was also discussed. The Subcommittee was scheduled to meet in Chicago the day after the Technical Committee meeting to also review the Subcommittee’s mission and to continue discussion of sport caps.

5. Regulatory Task Force (reported by Donna Cirolia, CCDA Waters, LLC)

The Regulatory Task Force reported that FDA had published two interim final rules under the federal bioterrorism act: one rule for food facility registration and one rule for prior notice of imported food. Food facilities are required to register with FDA by December 12, 2003, while prior notice for food import will become effective for all imports beginning on December 12, 2003. IBWA will present a number of seminars in cooperation with the state/regional bottled water associations beginning in early November to educate the industry in complying with the new rules.

The task force reported on new FDA requirements for monitoring radiological parameters, including uranium. Except where otherwise required by state agencies, radiological testing will be required every 4 years in source water and annually in product water.

The task force has discussed and developed new guidelines for compliance with FDA’s nine contaminants rule. The task force recommended that the 4 synthetic organic chemicals (SOCs) be tested every 3 years in finished product and annually in source water. The committee ruled that a caviat pending approval by the FDA of IBWA’s proposed monitoring be added to the change. A separate guidance document will be completed and made available to IBWA members.

The Technical Committee voted to modify Appendix A in the IBWA Model Code to accommodate both monitoring revisions.

It was also reported that IBWA sent a letter to the FDA stating the position that EPA’s Filter Backwash Rule should not apply to bottled water. The letter asked FDA to publish a statement to that effect in the Federal Register.

6. Virus/Microbial Subcommittee (reported by Tom Condon, Suntory Water Group)

The Virus/Microbial Subcommittee received a request in June, 2003 from the Drinking Water Research Foundation (DWRF) to review two study proposals involving viruses. The Subcommittee has submitted it’s findings to DWRF.

The Subcommittee continues to seek a virus expert. It plans to select an expert soon.

The first issue of a monthly virus literature search report was distributed to members in September, 2003.

There was also a report and discussion on a recent publication in the U.K. regarding Campylobacter infection. Ensuing discussion focused on possible activities to inform/educate CDC on bottled water microbial issues.

The Subcommittee was scheduled to meet in Chicago the day after the Technical Committee meeting.

7. Bottled Watercooler Task Force (reported by Kent Kise, Suntory Water Group)

It was reported that the Bottled Watercooler Task Force is currently drafting a revised brochure for watercooler cleaning. The new brochure will seek to be more generic with diagrams and figures, and will focus more on cleaning rather than attempting to standardizing sanitization. The group plans to review a draft in December.

The task force is also reviewing sanitization documents contributed by the European Bottled Watercooler Association (EBWA) and considering proposing a study of cooler conditions that might utilize the pilot plant. The study proposal may be submitted to DWRF for development of protocols and funding.

8. Mold/Algae Task Force (reported on by Robert Hirst, IBWA)

It was reported that the new Mold and Algae Task Force convened an organizational conference call on July 15, 2003. Prior to the call, Rick Hess had contributed documents with information on the effects of ozone on mold. The group was in need of a chairperson, and Rick Hess volunteered to lead the task force. Work will continue after the convention.


III. Model Code Revisions

See Regulatory Task Force report above.


IV. Informational Updates – Programs

1. Radionuclides Rule/Uranium (Bob Hirst)

It was reported that FDA published a confirmation of the effective date for a new standard of quality for uranium–December 8, 2003. Monitoring requirements were discussed and adopted earlier in the meeting during the Regulatory Task Force report.

2. Technical Education Programs (Bob Hirst)

As of September 30, 2003, 13 technical/regulatory seminars were presented at 7 state/regional meetings and one international convention. Numerous eductional seminars are planned for the WFE over the ensuing days. IBWA has also planned, in cooperation with the state/regional associations, a series of seminars for the new FDA bioterrorism rules. The seminars will be presented at six locations around the U.S. in November and early December. A regulatory resource CD has been created for distribution at the seminars, and will also be made available to all IBWA members.

3. CPO Program (Bob Hirst)

An update of the IBWA CPO program and summary of exam performance was presented to the committee.

4. ICBWA Technical Committee (Jack West, Puro and Alan Leff, QUASI, LLC)

It was reported that the ICBWA Technical Committee has approved the draft ICBWA Model Code and will recommend to the ICBWA Board of Directors that it be formally adopted. The ICBWA Technical Committee also approved a third party audit selection criteria document.


V. Informational Updates – Meetings

12th Annual ABINAM Congress in Florianopolis, Santa Catarina, Brazil

Bob Hirst reported that he participated in the 12th Annual ABINAM Congress, this year located in Florianopolis, Santa Catarina state, Brazil. His topic for the seminar was developing recall programs and plans, and the new FDA bioterrorism rules for food facility registration and prior notice for food import.


October 2003 Meeting with FDA

Kim Green reported that IBWA staff and member representatives met with FDA staff on October 6, 2003 at FDA’s office in College Park, MD. The agenda included discussions of:

    • Arsenic – FDA has agreed to proceed with establishing a new standard of quality for arsenic, based on the proposed USEPA MCL.
    • Total coliform – IBWA expressed appreciation to FDA for retraction of a 1993 proposed rule for total coliform and continued to pursue action on a final rule based on regulation of E. coli. FDA reported that it will not move forward with issuing a total coliform rule until EPA has completed its planned revision of its SDWA standard for total coliform.
    • FDA Audits – IBWA requested that FDA provide general commentary on their audits of bottled water facilities in early 2003. FDA responded that they do not have the information available.
    • Imported foods – IBWA requested and received more information on who to contact for import issues.
    • Perchlorate – FDA informed IBWA that they intend to conduct a study of perchlorate in bottled water in the near future. They will test using a new analytical method (LC-MS/MS) that has a much lower detection limit than the currently used EPA method.
      Dr. Andrew Eaton provided the committee with a presentation on perchlorate detection incidents and a laboratory analysis overview. Andy Eaton, Kristin Safran, and Kent Kise agreed to work with IBWA staff on this issue and on providing input/feedback to FDA on its planned testing.
    • IBWA briefly discussed proposed USEPA rules for disinfectants and disinfection byproducts (Stage 2) and Long Term 2 Enhanced Surface Water Treatment Rule. IBWA recommended that FDA adopt the D/DBP rule as proposed by the USEPA and that FDA consider ruling that the LT2ESWTR, as with the Surface Water Treatment Rule and LT1SWTR, does not apply to bottled water.
    • IBWA thanked FDA for sending a letter to the State of Maine regarding preemption of the state’s labeling regulations and the recurring issue of FDA’s intrastate jurisdiction.


LA County Update

Shayron Barnes-Selby reported that a group of IBWA and member representatives met with L.A. County Supervisor Antonovich, at which time he was provided with a tour of a member bottling facility. The meeting’s outcome was positive.


VI. Sports Caps

IBWA staff provided Technical Committee members with informational handouts regarding sports caps, including a Consumer Product Safety Commission guideline for safety testing. An issue status report was provided. In the ensuring discussion, the Technical Committee agreed that IBWA should liaison with the International Society of Beverage Technologists, which is developing a test method for sports caps.


VII. New Business

A discussion of Campylobacter and a study published by the University of Wales was proposed as new business, but was discussed during the Virus/Microbial Subcommittee report.

Joseph Benaquista reported that an issue has developed regarding the detection of semicarbazide (SEM) in some food products sealed with plastic sealing gaskets. The compound originates from the blowing agent (azodicarbonamide) used in the manufacture of the gaskets in lids.

Kevin Mathews reported that an issue has developed in the Maine state legislature regarding the presence of antimony trioxide in PET (antimony trioxide is used as a catalyst in PET manufacturing), specifically with regards to recycled PET.

Kim Green reported that a graduate student at the University of Maryland (Jorge Loyo-Rosales) will be publishing a paper soon in the Journal of Agriculture and Food Chemistry claiming that water bottled in HDPE is a source of nonylphenol to the diet.

Al Lear thanked Kevin Mathews for serving with him as Co-chair of the Technical Committee for 2003 and announced that Vincent Ducasse will serve with him as the Co-Chair for 2004.


VIII. Adjournment

There being no additional new business, a motion was made and seconded for adjournment. The motion passed, and the meeting was adjourned at 4:15 PM.

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