In a U.S. House subcommittee hearing, the ...
It’s a simple concept: Name a type of product, and it should be easy to determine the applicable standard for it. Unfortunately, in today’s complex regulatory environment, reality isn’t always that simple.
Conversely, as products evolve, the definition of product type is not always all that clear. There are now devices that are very difficult to categorize: Is it a phone or a digital music player? Is it a computer or a personal digital assistant? Is it a refrigerator or a water filtration system?
These realities lead to situations in which determining the correct standard used to certify a product is a research project in itself.
Water coolers are a prime example of products that have evolved and can now fall under a number of possible standards based on specific product features and functions. Let’s examine the possibilities in detail.
In the good old days, a water cooler was simply a refrigerated reservoir with a dispenser. On top of the reservoir sat a 5-gal carboy full of water, ready to be refrigerated and dispensed. Today, the realm of possible water cooler configurations has evolved significantly. Some of the familiar mainstays are still around and still serve our needs very well, but now some of these products feature heating and cooling. Some of them are directly connected to plumbing, as opposed to having the carboy on top. Some of them, often known as point-of-use (POU) coolers, incorporate water treatment. Water treatment technologies can include filtration, reverse osmosis (RO) and ultraviolet (UV) light.
These possible variations allow products to fall under the scope of different standards for product safety. In fact, some of these standards are developed by completely separate expert joint committees. The reason for application of different standards—and different committees of standard developers—is product evolution and the blurring of product type definitions.
In the old days, when a water cooler used to be a water cooler with a manually filled carboy of water on top, it was considered to be a piece of food service equipment. As such, in 1972, the NSF Joint Committee on Food Equipment developed NSF/ANSI Standard 18 for manual food and beverage dispensing equipment.
This arrangement held for many years and water coolers were neatly pigeonholed into NSF/ANSI Standard 18. It was simple and clear. And during this time, expert committees for other products developed other standards. The NSF Joint Committee on Drinking Water Treatment Units was developing standards for point-of-entry (POE) and POU water treatment technologies. The NSF Joint Committee on Drinking Water Additives was developing NSF/ANSI Standard 61, covering the health effects of leachable contaminants from products used in drinking water distribution systems. See Figure 1 for a review of the scopes of these various standards.
Eventually, consumer needs and tastes required innovation, and the water cooler evolved. This evolution led to a collision of worlds, so to speak, in terms of applicable product standards, as the water cooler began to take on functions related to water treatment and plumbed-in water distribution systems. The result of this collision was a complicated landscape of standards, depending on product characteristics. NSF developed a flow chart to help navigate this landscape and determine the applicable standard or standards for a specific cooler configuration. This flow chart can be seen in Figure 2 (page 6).
A close examination of Figure 2 shows that two of the end points include multiple standards—coolers that incorporate treatment and are not connected to plumbing, and plumbed-in coolers that dispense both treated and non-treated water.
Coolers that incorporate treatment and are not connected to plumbing fall under NSF/ANSI DWTU standards for treatment aspects, and also fall under NSF/ANSI Standard 18. The most important requirement of this standard for manufacturers to consider is the cleaning and sanitizing requirement, which includes a cleanability test. This test involves exposing the water contact surfaces of the cooler to a suspension of E. coli, cleaning the cooler according to manufacturers’ instructions, exposing the cooler’s water contact surfaces to sterile buffered water, and determining whether any E. coli is picked up in this water from exposure to the cleaned cooler. There is no other test like this in the NSF/ANSI DWTU standards.
Conversely, the NSF/ANSI DWTU standards require extraction testing for material safety, which goes a step beyond the requirements of NSF/ANSI Standard 18. A further requirement covered by the NSF/ANSI DWTU standards, which is not addressed by NSF/ANSI Standard 18, is testing for the verification of water treatment claims. Most manufacturers who offer products that incorporate water treatment wish to verify their claims according to these standards.
Plumbed-in coolers that dispense both treated and non-treated water have two different water pathways. The treated water pathway is covered by the NSF/ANSI DWTU standards, and therefore is required to have wetted material formulation disclosure and extraction testing. The non-treated water pathway falls under the scope of NSF/ANSI Standard 61. Standard 61 has formulation disclosure requirements for wetted materials that are very similar to the DWTU standards, and it also requires extraction testing of those materials. The extraction test has the same end objective as extraction testing required by the NSF/ANSI DWTU standards, but the conditioning procedure, exposure procedure and exposure water chemistry are quite different from those specified in the DWTU standards.
I am fortunate to be attending and presenting a workshop at a trade show in London, April 24 to 26, entitled “AVEX 2007 Featuring The Cooler Show.” The structure of this show is quite interesting, considering the complex landscape of coolers. There will be separate conferences for vending, POU and bottled water coolers. These separate conferences wrapped into one demonstrate the subtleties and different features of the products collectively known as coolers.
As the cooler landscape continues to broaden, it may begin to encompass even more features, functions and, of course, standards. In fact, I just may have to update my flow chart after my trip to London!