Bottled Water Quality Guidelines: FDA to WHO or What ?

The bottled water industry is exposed to regulations from the local level through the international level. The industry as a whole attempts to support the position that bottled water is a premium drinking water product. Regulators set minimum standards. The most conscientious bottlers strive to meet current and anticipated requirements in order to demonstrate that their products provide the highest level of health protection.

This article reviews the scope of requirements for manufacturers who sell bottled water products in the United States and around the world. A comparison will be made between the requirements of the U.S. Environmental Protection Agency and those of the World Health Organization (WHO). Finally, the impact of WHO guidelines on domestic and international bottlers will be discussed.

In 1996, the U.S. Federal Government re-enacted the Safe Drinking Water Act (SDWA). This act sets the minimum quality standards for municipal drinking water throughout the United States. The U.S. Environmental Protection Agency (EPA) has the responsibility to set the minimum standards on a national level. The Food and Drug Administration (FDA) has set standards for bottled water based on EPA standards. Although bottled water, for the most part, is used for drinking water, it is considered a food product and is subject to the regulations guiding food stuffs. IBWA has worked avidly to encourage the FDA to adopt bottled water regulations that are as stringent as the SDWA requirements for drinking water. The states or provinces in North America can-and have-set requirements for municipal and bottled water that are more stringent than those required by either the FDA or the EPA. Massachusetts and Quebec are examples of where regional standards are of broader scope than federal standards.

Regulations for bottled water in the U.S. have been driven by two factors: the SDWA and the push by the industry to have bottled water regulated to be above reproach. Now the impacts of a global economy could be making its mark on the direction the bottled water regulations take in the form of the World Health Organization (WHO) Guidelines for Drinking Water Quality.

In 1985, WHO published the first edition of Guidelines for Drinking Water Quality. The primary aim of the Guidelines is the protection of public health through the identification and minimization of chemical, physical, microbiological, and radiological contaminants that are known to be hazardous to health. In 1992, a more comprehensive revised version of the guidelines was issued based on the combined research of over 200 experts from over 40 countries. These guidelines have been used by numerous countries in the establishment of national drinking water standards and the creation of international standards for food quality.

These international standards are being developed by the Codex Alimentarius commission, a joint commission of the Food and Agriculture Organization of the United Nations and WHO. The purpose of the United Nations' Codex Alimentarius Commission is to facilitate international trade through the development of international standards for identification, quality and good manufacturing practices. Recently the Codex Commission adopted a draft standard for natural mineral water. Standards for other bottled waters will begin next year. With the WHO co-sponsoring the commission, the WHO Guidelines for Drinking Water Quality will have an obvious impact in the creation of these standards. It is important to understand the differences between the EPA SDWA parameters and the WHO guidelines in order for the bottled water industry to stay ahead of these new guidelines.

A comparison of the EPA and WHO standards shows that the analytes identified for health concerns are similar. However, there are significant differences on the volatile and semi-volatile list. The EPA SDWA identifies 62 volatile organic compounds. This is far broader than the WHO list of only 29 analytes. On the other hand, the scope of semi-volatile compounds listed by WHO exceeds that of the EPA. Because the WHO guidelines were developed for international application, there are compounds identified by WHO which are not prevalent, and thus not regulated by the EPA (e.g., MCPA). In addition, the WHO guidelines include disinfection-by-products which the EPA is currently studying as part of the International Collection Rule, but have not been adopted to the SDWA.

Internationally, the WHO guidelines have been used as the basis of the development and revision of many national regulations for drinking water in many countries outside of the Untied States. These regulations also have become the quality standards for bottled water in those same countries.

In conclusion, water quality is a worldwide issue of concern. It is the intent of all nations to protect their population as best they can. The Codex Commission is attempting to provide a set of analytes and concentrations that can be used as international standards to protect the health of the world's population. Since bottled water can help supply quality drinking water on a worldwide basis, bottlers should anticipate having to meet the WHO standards. Bottlers exporting internationally today should meet these standards now. Bottlers distributing domestically should anticipate the FDA to make regulations closer to the WHO standards. ·

About the Authors:
Dr. Alan A. Leff is vice president of operations and Kristen Saltzgiver is a technical service representative at National Testing Laboratories, Ltd. (NTL) in Cleveland, Ohio.

NTL is a network of laboratories including National Testing Laboratory Ltd. (Ypsilanti, Michigan), Broward Testing Laboratory Ltd. (Ft. Lauderdale, Florida) and Free-Col Laboratory Ltd. (Meadville, Pennsylvania). This network of laboratories carries a wide spectrum of state certifications for drinking water, environmental and industrial hygiene analyses. NTL is also the producer of the Watercheck analysis for the water treatment industry.

Leff and Saltzgiver may be reached at 440-449-2525, fax 440-449-8585, or e-mail [email protected].


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