IBWA READY TO WORK WITH FDA TO CONSIDER GOVERNMENT ACCOUNTABILITY OFFICE’S BOTTLED WATER STUDY RECOMMENDATIONS
July 08, 2009
(Alexandria, VA) – The International Bottled Water Association (IBWA) stands ready to work with the U.S. Food and Drug Administration (FDA) to consider the recommendations found in the US Government Accountability Office (GAO) Report to Congress on the regulation of bottled water, released today at a hearing of the U.S. House Subcommittee on Oversight and Investigations. A review of the new GAO Report indicates that the bottled water industry has an outstanding record of voluntary compliance to meet or exceed federal and state regulations that safeguard the safety, quality, and labeling of bottled water.
In its new report on bottled water regulation, the GAO issued two recommendations:
- that FDA issue a standard of quality for DEHP, an organic compound used to produce polyvinyl chloride plastics, or publish its reasons for not doing so, and
- implement FDA findings from a Year 2000 study regarding methods that are feasible for conveying information to consumers regarding the quality and safety of bottled water.
On the issue of an FDA standard of quality for DEHP -- or (Di(2-ethylhexyl) phthalate, or Bis 2-ethylhexyl phthalate -- this is an example of a substance for which EPA has issued a regulation for tap water but FDA has not promulgated a similar standard of quality for bottled water.
The three principal materials used in plastic containers in the bottled water industry -- polyethylene terephthalate (PET), polycarbonate, and high density polyethylene (HDPE) – do not contain DEHP or any other phthalate chemical. Therefore, DEHP is not likely to be found in bottled water products.
The EPA maximum contaminant level (MCL) for DEHP in tap water is 6 parts per billion (ppb). In an effort to maintain parity with the EPA public drinking water standards, IBWA adopted an identical standard in our Code of Practice prior to 1998, which all members must meet as a condition of membership.
Consumers Right to Know
On the issue of implementing the 2000 FDA study on the feasibility for conveying information about the quality and safety of bottled water, IBWA supports a consumer’s right to clear, accurate and comprehensive information about the bottled water products they purchase. All packaged foods and beverages, including bottled water, are subject to extensive FDA labeling requirements that provide consumers with a great deal of product quality information.
In addition, virtually all bottled water products include a phone number on the label that consumers can use to contact the company. IBWA believes that the most feasible way for consumers to obtain information not already on the label is through a request to the bottler. (In 2001, IBWA submitted a petition to FDA requesting that the Agency require a phone number to be listed on the label of all bottled water products.)
Also, consumers can go to the IBWA website to obtain contact information or water quality information for all IBWA member brands. (www.bottledwater.org)
The FDA Feasibility Study Report looked at various ways that bottled water information could be communicated to consumers, including company contact information on the label, placing specific contaminant and other information on the label, distributing pamphlets at the point of purchase and providing information via the internet. IBWA agrees with the FDA’s views on whether it is feasible to provide the same information on a bottled water label that is contained in CCRs provided by public water systems. FDA concluded that:
“We agree with comments that stated it is not feasible to provide all of the information that is analogous to that contained in a CCR on a bottled water label. Such information would be excessive in limited label space, particularly on the small, single serving bottles. In addition, information that requires frequent changes due to changing test results may result in a misbranded product. Costs of frequent label changes that are necessary to ensure accurate information on the contents of a bottled water product, due to frequently changing information, may present an economic hardship to companies. Moreover, even annual updates that represent the contaminant history would need information to put the history for all such CCR-type information in context for the consumer and would be excessive in limited label space.”
IBWA believes that consumers should have timely and easy access to information about their bottled water products. To help ensure that consumers have access to useful and meaningful bottled water product information, the IBWA Code of Practice requires all members to comply with the following:
- All proprietary brand products must include a telephone number on their labels so consumers can easily contact the company and request product information.
- IBWA maintains an online member database, which also contains a specific link to a member company’s water quality information and/or contact information that may be used to secure a company’s water quality report.
IBWA offers counsel to bottlers as to how to prepare and present water quality reports. Such assistance is provided one-on-one with bottlers; in educational sessions at national, regional, or local bottled water industry meetings; and in monthly, weekly, and targeted publications. IBWA makes available to its members an online Water Quality Reporting Template, which users may download and enter extensive water quality reporting information based on analytical testing results for all regulated parameters. IBWA provides either company contact information, a link to the company website for contact purposes or a direct link to water analysis data by brand on the IBWA website: www.bottledwater.org
A Strong Environmental Record
Although the GAO Report did not make environmental recommendations, there is discussion in the new report about the environmental impact of bottled water containers. Bottled water is just one of thousands of food and beverage products that are packaged in plastic containers. IBWA points out that the national recycling rate for PET plastic bottled water containers (.5 liter or 16.9 ounce size) has improved by 16.42%, according to new data from two new studies: “2008 Post Consumer PET Bottle Bale Composition Analysis” and “2007 Report on PET Water Bottle Recycling,” both produced by the National Association for PET Container Resources (NAPCOR). According to data from an earlier 2006 bale content study for all beverages, the number of PET bottles counted per pound was approximately 12. In 2008, the total number of PET bottles increased to 13.78, a reflection of the dramatic increase in water bottle collection, as well as the continued lightweighting of other plastic containers. The 2007 NAPCOR study on water bottle recycling has determined that the recycling rate for water bottles is 23.4%, representing a significant 16.42% increase over the 2006 recycling rate of 20.1%.
With data compiled during an extensive bale composition study in 15 locations in 14 states, the 2008 NAPCOR PET analysis states: “Water bottles are now the most recycling container in curbside programs by weight, and overwhelmingly by number.” PET water bottles now account for 50% of all the PET bottles and containers collected by curbside recycling. This trend was consistent in all curbside bales sampled nationally, with no major shifts observed in any other plastic container category. The biggest jump in water bottle collection for recycling was in California, where a state-funded consumer education campaign, emphasizing that water bottles are recyclable, seems to be having the desired effect.
In tandem with the new NAPCOR data, IBWA tracked the average amount of plastic used in .5 liter (16.9 ounce) PET bottles, using published data from the Beverage Marketing Corporation (BMC) to determine the lightweighting trend currently being seen in many brands of bottled water. In the year 2000, the average weight of a plastic water bottle was 18.90 grams. It has declined consistently on an annual basis and by 2007, the last year BMC has complete and finalized data, the average weight of a PET water bottle was 13.83 grams – a 26.7% decline.