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October 30, 2008

International Bottled Water Association
Position Statement

Polycarbonate Plastic Containers Used For Bottled Water Products are Safe for Consumer Use

Recent media stories have raised questions about the safety of polycarbonate plastic bottles due to the presence of a substance known as bisphenol A (BPA). Polycarbonate plastic is used in a wide variety of consumer products, including food and drink containers. Many 3- and 5-gallon bottled water containers are made of polycarbonate plastic and consumers can remain confident about the safety of these products.

" Bottled water is comprehensively regulated as a food product by the U.S. Food and Drug Administration (FDA). Plastic food and beverage containers, including polycarbonate plastic made with BPA, must meet or exceed all FDA requirements. FDA clears all food-contact plastics for their intended use based on migration and safety data. The clearance process includes stringent requirements for estimating the levels at which such materials may transfer to the diet. FDA's safety criteria require extensive toxicity testing for any substance that may be ingested at more than negligible levels. This means FDA has affirmatively determined that, when cleared plastics are used as intended in food-contact applications, the nature and amount of substances that may migrate, if any, are safe.

" Polycarbonate plastic has been the material of choice for food and beverage product containers for nearly 50 years because it is lightweight, highly shatter-resistant, and transparent. During that time, many studies have been conducted to assess the potential for trace levels of BPA to migrate from polycarbonate bottles into foods or beverages. The conclusions from those studies and comprehensive safety evaluations by government bodies worldwide are that polycarbonate bottles are safe for consumer use.

" On October 28, 2008, FDA issued a statement in response to a report by an FDA Science Board Subcommittee which raised questions regarding FDA's safety assessment concerning BPA. FDA agreed that more research "would be valuable" and the agency is "moving forward" with additional planned studies.

" FDA's October 28, 2008, statement reaffirmed the agency's position regarding the safety of BPA. They stated:

"Consumers should know that based upon all available evidence, the present consensus among regulatory agencies in the United States, Canada, Europe and Japan is that current levels of exposure to BPA through food packaging do not pose an immediate health risk to the general population, including infants and babies."

" The National Toxicology Program released its final report on the potential human reproductive and developmental effects of bisphenol A on September 3, 2008. From a wide variety of possible adverse health effects that were considered, the NTP has only some concern for effects on the brain, behavior, and prostate gland in fetuses, infants, and children at current human exposures to bisphenol A. This means that NTP believes that more research is needed in this area, which IBWA supports.

" A publication by Yale University claims to have linked BPA to problems with brain function and mood disorders in monkeys. The American Chemistry Council responded to the Yale study in a statement, saying "there is no direct evidence that exposure to bisphenol A adversely affects human reproduction or development." Further, on September 17, 2008, Lang et al. published in the Journal of the American Medical Association an epidemiological study linking an increased presence of bisphenol A in the blood of humans to an increase in diabetes and certain cardiovascular diseases. While epidemiological research can provide insights into the occurrence of diseases, it can never establish a causal relationship. Therefore, this study does not demonstrate that bisphenol A was the cause of any of the reported effects.

" Germany's Federal Institute for Risk Assessment (BFR, the German equivalent to the FDA) evaluated the relevance of both the Yale and JAMA studies and concluded that the results published in these reports do not question the current risk assessment of bisphenol A in food. Moreover, The European Food Safety Authority (EFSA) released a statement on October 22, 2008 concerning the JAMA study that concluded that there is no sufficient proof for a causal link between exposure to BPA and the health conditions mentioned in the article.

For more information on this issue, visit the FDA's website at http://www.fda.gov/oc/opacom/hottopics/bpa.html or the American Chemistry Council's website at www.factsonplastic.com or www.bisphenol-a.org

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The International Bottled Water Association (IBWA) 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. IBWA 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. In addition to FDA and state regulations, the Association requires member bottlers to 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 an annual, unannounced plant inspection by an independent, third party organization. Consumers can contact IBWA at 1-800-WATER-11 or log onto IBWA's web site (www.bottledwater.org) for more information about bottled water and a list of members' brands. Media inquiries can be directed to Tom Lauria at 703-647-4609 or tlauria@bottledwaterorg.