UofI Bottled Water WQ Pres

Bottled Water:  Public Perceptions Regulations & Water Quality: 

Bottled Water: Public Perceptions Regulations & Water Quality MSE MILLENNIUM SCIENCE & ENGINEERING, INC DEENA LILYA MS ENVIRONMENTAL ENGINEERING UNIVERSITY OF IDAHO

Introduction: 

Introduction General Introduction Types of Bottled Water (BW) Statistics Public Perceptions 1999 U of I Survey Results Regulations Federal, State, & Industry Based Regulations Loopholes & Labeling Requirements Water Quality NRDC Report Moscow Tap Water vs. IDAHO ICE Implications of PET Reuse

Types of BW: 

Types of BW Artesian Water BW source is confined aquifer that is under pressure and flows freely at the surface Drinking Water BW sold for human consumption in sanitary containers that contain no sweeteners, chemical additives, has 0 calories, is sugar-free, and has <1% by weight flavors or essences added Mineral Water BW source is one or more bore holes or springs, that are geologically and physically protected underground water sources, water has a constant level of mineral and other trace elements at the point of emergence from the source and no minerals have been added (TDS>250 mg/L)

Types of BW (cont): 

Types of BW (cont) Purified Water Water treated by distillation, deionization, reverse osmosis, or other suitable processes, label dependent on treatment process used Sparkling Water BW that contains natural CO2 or at levels found at the source (does not include "soda water” or "seltzer water" Spring Water Water from underground formation flowing naturally to surface and collected at a spring or sanitary borehole

BW Statistics: 

BW Statistics BW sales tripled in last decade 1/3 of Americans consume BW regularly 1 gal BW costs 240 to 10,000 times more than 1 gal tap water $5.7 billion in BW sales in 2000

Public Perceptions: 

Public Perceptions Most assume BW is cleaner, safer, & better regulated than tap water More convenient Health conscious & try to drink more water while on the go Popular/Trendy 63% of Americans don’t know which regulatory agency regulates BW Popularity is Specific to Location LA consumed most BW Detroit consumed least BW

1999 UI Survey Results: 

1999 UI Survey Results 246 people interviewed Sorority Fraternity EnvSci 101 EnvSci 497 UI Faculty Ages: 17-60 yrs (60% were 18-21) Overall perception that BW of better water quality than tap water 70% of UI community preferred BW or filtered water over tap water 88% Reused Bottles by Refilling (bacteria & chemical migration concerns)

What Type of Water Do You Prefer to Drink?: 

What Type of Water Do You Prefer to Drink?

Do You Purchase Bottled Water?: 

Do You Purchase Bottled Water?

Overall Reasons For Buying Bottled Water: 

Overall Reasons For Buying Bottled Water

Overall Reasons For Not Buying Bottled Water: 

Overall Reasons For Not Buying Bottled Water

Which Source Has Higher Bacteria Levels?: 

Which Source Has Higher Bacteria Levels?

Which Source Has Higher Contaminant Levels?: 

Which Source Has Higher Contaminant Levels?

Which Source Has Stricter Regulations?: 

Which Source Has Stricter Regulations?

BW Regulations: 

BW Regulations Food & Drug Administration (FDA) regulates BW as a food EPA regulates all other drinking water sources under the SDWA BW Regulations Federal Food, Drug, & Cosmetics Act (FFDCA) Requires FDA BW regulations be no less stringent than EPA drinking water standards FDA may choose to not adopt EPA Standards but must publish justifications in Federal Register, otherwise automatically adopted after 180 days Code of Federal Regulations (CFR) 21 CFR Sections 110, 129, and 165 apply to BW

Federal BW Regulations: 

Federal BW Regulations Standard of Identity Requires consistent use of terms like "purified" and "spring," on product labels Bottles labeled "spring water" must be from springs Water from municipal sources 25-40% of all BW from municipal source Must be labeled "from community water system" or "from municipal source” if no treatment If a purification process is used (I.e., distillation or reverse osmosis) then defined by type of purification rather than from municipal source

Federal BW Regulations: 

Current Good Manufacturing Practices (GMPs) For both general food & BW specific categories Governs plant maintenance & facility sanitation BW-specific GMPs Plant construction/design, equipment design, production, process controls, & extensive record keeping. Requires safe and sanitary transportation & storage Federal BW Regulations

Federal BW Regulations: 

Federal BW Regulations Standard of Quality (SOQ) Specific BW product standards that help ensure safety from production & packaging to consumption Companies must test for pesticides, organic chemicals, minerals, bacteria, & physical properties such as color FDA BW SOQs must be at least as stringent & protective of public health as EPA’s standards for public water supplies BW subject to FDA food recall, mislabeling, & adulteration provisions

State BW Regulations: 

State BW Regulations Regulated By Public Health Districts Responsibilities include inspecting, sampling, analyzing, & approving water sources Certify testing laboratories Perform unannounced & annual inspections Most states base regulations on FDA and/or industry-based standards

Idaho BW Regulations: 

Idaho BW Regulations Regulated by Public Health Districts Idaho Regulations Equivalent to FDA’s Idaho BWs must comply with Idaho Drinking Water Standards BW must meet all labeling requirements Misbranding is prohibited Sources usually only inspected at facility startup Few state resources available for enforcement

Industry BW Regulations: 

Industry BW Regulations Self-regulated by International Bottled Water Association (IBWA) IBWA represents ~ 85% of BW market Members must follow IBWA Model Code Annual unannounced third-party plant inspections (NSF) Inspectors audit water quality parameters, testing records, review plant operations, and check for compliance with federal, state, and IBWA’s standards Members must meet > 97% of IBWA criteria to maintain membership http://www.bottledwater.org

Slide22: 

From IBWA Website

IBWA Members: 

IBWA Members Aberfoyle Arrowhead Calistoga Clearly Canadian Crystal Geyser Dannon Evian Glacier Ice Ice Mountain Idaho Ice Naya Perrier San Pellegrino Talking Rain Vandal Ice Vittel Plus Many More!

Other Bottled Waters: 

Other Bottled Waters AQUAFINA Bottled by Pepsi Filtered Tap Water DASANI Bottled by Coca-Cola Filtered Tap Water EARTH2O From “Community Water System”

Regulatory Loopholes: 

Regulatory Loopholes Only water sold interstate is regulated by FDA 60-70% of BW is bottled & sold in same state Only covered by state regulations 20% of States do not have BW Regulatory Programs & FDA Regulations do not apply 40% of the States have some BW regulations but few resources allocated to enforce them CA has strictest state regulations (Proposition 65) & are largest BW consumers Sub-standard BW which exceeds drinking water standards may be sold if labeled “contains excessive bacteria”or “contains excessive substances” if not at dangerous levels

Regulatory Loopholes: 

Regulatory Loopholes Definition loopholes make it difficult for consumers to determine which waters are regulated by FDA Most consumers assume all water sold in bottles are covered by same regulations Consumers assume all BW is highly regulated

BW Covered By FDA Regulations: 

BW Covered By FDA Regulations “Spring Water” “Natural Spring Water” “Mineral Water” “Drinking Water” “Purified Water” “Purified Drinking Water” “Bottled Water” “Distilled Water” “Artesian Water”

Exempt from FDA Regulation by Definition: 

Exempt from FDA Regulation by Definition Only sanitary standards apply for the following (water quality standards do not) “Water” “Carbonated Water” “Disinfected Water” “Filtered Water” “Seltzer Water” “Soda Water” “Sparkling Water” “Tonic Water”

What to look for on label?: 

What to look for on label? IBWA Certification “Natural Spring Water” Bottled at Source Bottled at municipal source Bottling Date/Expiration Date Contact Information Call and ask questions Ask for water quality reports May not want to drink BW if company won’t discuss water quality data or provide information

Label Information: 

Label Information

NRDC Report: 

NRDC Report Natural Resources Defense Council Non-Profit Environmental Group Released 4-yr BW Study in 1999 Petitioned FDA with specific recommendations Increased public concern over BW regulations Evaluated >1000 bottles (103 brands) Water Quality Regulatory Status http://www.nrdc.org/water/drinking/bw/bwinx.asp

NRDC Report - WQ Results: 

NRDC Report - WQ Results Found most BW of good quality 25% of the BW tested exceeded at least one CA BW standard (stricter than FDA) Found BW that exceeded regulatory levels or were above levels of concern: Arsenic HPC Bacteria Nitrates Phthalates No BW standard for phthalates under request of BW companies although MCL exists & it is a harmful chemical Industry pressure to remove standard

NRDC Conclusions: 

NRDC Conclusions 60-70% of BWs are exempt from FDA Regs 20% of the States have no BW Regulations Some BW Regulations may be less strict than tap water standards Regulations poorly enforced by FDA & State Agencies FDA & State Regulatory Programs severely underfunded IBWA efforts important, but should not replace Federal & State Regulations More research needed on leaching from plastic bottles & health effects associated w/ bottle reuse

NRDC Recommendations: 

NRDC Recommendations Fix tap water quality Establish BW public right to know laws Develop BW website/phone information system Re-evaluate FDA BW Regulations Require Annual BW Facility Inspections Charge “Penny-per-Bottle” Fee to fund regulatory programs Transfer BW program to EPA if FDA lacks resources & will to implement effectively Establish “certified safe” bottled water (Recommended in Petition to FDA)

Moscow Tap Water: 

Moscow Tap Water Regulated by IDEQ/EPA Water Quality Data Easily attainable SDWIS Consumer Confidence Reports Website Contains high iron & manganese levels Chlorinated for disinfection Water Source: (5 local GW wells) 2 Upper Aquifer Wells (treated with filtration system & chlorinated) 3 Deep Aquifer Wells (not treated)

Moscow Tap Water: 

Water Treatment Process Chlorination Single pass filtration system 1 ft anthracite 2 ft manganese green sand 4 inches 0.5 mm sand 3 inches 2-3 mm sand 3 inches ½ to ¼ inch gravel Filters backwashed regularly Moscow Tap Water

Moscow Tap Water: 

Moscow Tap Water Regulatory Requirements Collect > 40 samples/mth Must meet all National Primary Drinking Water Regulations (I.e., MCLs) Not required to meet Secondary Standards but must test for them 1989-1999 Moscow Water Violations 1 reported violation Coliform (> 5% of 40 samples positive for coliform in 1 mth due to dead bird in system) 1989-1999 U of I Water System 5 reported violations for coliform

IDAHO ICE: 

IDAHO ICE Regulated by FDA (sold interstate) Water Quality Data Easily Attainable Bottled at source (Elk River, Idaho) Water Source: Protected Natural Spring Idaho Ice owns all land in drainage area and has all grazing rights Source protected from grazing, agricultural, & industrial impacts that may contaminate aquifer Member of IBWA IBWA has much stricter regs than Idaho

IDAHO ICE: 

IDAHO ICE Treatment System (min required by IBWA) Sand Filter 5 micron Filter System (7 total) Activated Carbon Filter Ozone Disinfection 1-2 hr life in water no residual taste unlike chlorine 1 micron Filter (bacteria removal prior to bottling) Bottling Procedure Automated to reduce bacterial contamination Sterile clean room environment (gloves & white coat) Limited room access during bottling Some companies still bottle by hand (increased potential for bacterial contamination)

Bottling Facility : 

Bottling Facility

IDAHO ICE : 

IDAHO ICE Water Quality Testing Regular testing required by IBWA pH, ozone, TDS, taste, & bacteria tested daily Weekly & annual testing for compliance with Primary & Secondary drinking water standards No violations of regulatory levels Regularly inspected/audited by IBWA Inspected by State Health District only when starting business

PET Bottle Constituents: 

PET Bottle Constituents PET = Polyethylene Terephthalate (Labeled as #1 Recyclable Plastic) Unreacted ingredients (TPA, DMT) Monomers and oligomers PET degradation products Additives Plasticizers Stabilizers Antioxidants Dye Carriers

Problems with PET Reuse: 

Problems with PET Reuse FDA analytical procedures only measure non-VOCs, although VOCs and SVOCs greatly increase total migration concentrations Total Migration Limits = 50 ppm (FDA) and 60 ppm (EEC) (gravimetric determination) FDA tests do not identify or quantify migration compounds

Problems with PET Reuse: 

Organic chemical migration from “reused” PET bottles has not been investigated Long-term reuse exposes bottles to heat, sunlight, & physical degradation, which may increase organic chemical migration Increased Bacterial Contamination Problems with PET Reuse

MS Thesis: 

MS Thesis Objective 1: Determine migration potential from reused PET bottles from exposure to reuse scenarios such as heat, sunlight, & physical degradation. Objective 2: Assess human health risks associated with PET bottle reuse due to migration of potentially harmful chemicals into the water being consumed.

PET Bottles Tested: 

PET Bottles Tested

PET Reuse Conclusions: 

PET Reuse Conclusions PET reuse increased migration & contaminant concentrations increased with length of reuse For reuse > 4 wks concentrations may continue to rise Only reuse PET bottles for short time periods (< 1 week) Protect bottles from light and heat

PET Reuse Conclusions: 

PET Reuse Conclusions Carcinogenic risks may be exceeded for some reuse exposure scenarios Little is known about toxicity of migration compounds More research needed on toxicity of migration compounds before risk assessment can adequately determine human health risks

PET Reuse Conclusions: 

PET Reuse Conclusions Original and reused PET bottles had different migration compounds specific to color or brand of bottle Several non-PET reusable bottles showed high migration potentials Same analytical procedure may be used for non-PET bottles Further testing required

PET Reuse Conclusions: 

PET Reuse Conclusions PET reuse is a growing trend that is assumed to be safe, but it may increase chemical migration, exposing consumers to compounds for which few toxicity data exist.

QUESTIONS: 

QUESTIONS ARE YOU SURE BW IS LESS CONTAMINATED, SAFER, & BETTER REGULATED THAN TAP WATER?