Bottled water testing requirements and drinking water contaminants continue to present new layers of complexity for bottled water producers. Bottlers must be diligent in tracking federal, state, local and industry requirements in order to stay in regulatory compliance. They also must have resources to stay informed about drinking water contaminants. Bottlers who do not have the internal resources to dedicate to these arduous tasks may rely on industry associations and qualified industry professionals, such as consultants or their laboratory representatives, to keep them current on this vital information.
U.S. Testing
The U.S. FDA regulates bottled water for sale in the U.S. as a food product. Regulations can be found in the Federal Register - FDA Quality Standards, 21 CFR, Section 165.110 (b). Enforcement of the FDA regulations is managed at the state level, typically by the Department of Health, Department of Agriculture, Department of Environmental Protection, Department of Environmental Quality, etc. Each state’s regulations pertaining to bottled water testing may simply refer to the FDA Federal Register requirements, or the state may have its own legislation dictating testing requirements, which may be more stringent than the FDA’s.
The FDA regulations are derived from those established by the U.S. EPA. Under the Safe Drinking Water Act, the EPA continually evaluates drinking water contaminants and sets Maximum Contaminant Levels (MCLs), which apply to public water supplies. Once the EPA has established that a particular compound poses a risk for drinking water contamination and sets an MCL, the FDA must then determine if the regulation is also applicable to bottled water. A surface water supply can be at greater risk for certain contaminants that are not likely to be a concern in a groundwater supply. As bottled water is typically produced from a contained underground water supply (not under the direct influence of surface water), such contaminants usually would not be required testing for bottlers. For bottlers using surface water sources, these sources are already tested for contaminants by the municipality. Location is another factor in considering applicability of regulations. Certain geographic locations may be more susceptible to a contaminant based on geology or historical usage.
Global Testing
In addition to testing requirements mandated by U.S. government regulations, other countries, industry associations and agencies have established guidelines to ensure bottled water producers adhere to a high standard of quality. For example, the International Bottled Water Association, Canadian Bottled Water Association, Asian Bottled Water Association (ABWA), Australian Bottled Water Institute and the World Health Organization (WHO) all have their own Model Codes or Guidelines for Drinking Water Quality (GDWQ). Some companies even have their own corporate water quality standards to which production facilities must adhere. These corporate quality standards may include testing requirements from various regulatory agencies—adding another layer of complexity to the task of tracking what testing must be performed.
WHO is the specialized agency for health established by the United Nations on April 7, 1948. The WHO GDWQ are used worldwide for setting standards and regulations to ensure drinking water safety. Many countries that have not established their own regulations for bottled water testing require bottlers to meet the WHO GDWQ.
Analytes of Global Interest
Acrylamide. Acrylamide is an odorless, white, flake-like crystal organic solid that is sometimes used in drinking water treatment and industrial effluents. It coagulates suspended solids and traps them for easier removal from the water. In this process, some acrylamide may not coagulate and would remain in the water as a contaminant. Polyacrylamides are also used as grouting agents in the construction of wells and reservoirs. If acrylamide is used in the water treatment process, the EPA requires public water supplies to show that the amount of uncoagulated acrylamide does not exceed 0.5 ppb. The WHO guideline value is also 0.5 ppb. Acrylamide is absorbed readily by inhalation, ingestion and through the skin. Potential health effects from exposure to acrylamide (a cumulative neurotoxin) can include weakness, nervous system damage, paralysis and cancer. It is highly soluble in water but is also degraded by microorganisms. Although conventional treatment does not remove acrylamide, using potassium permanganate or ozonation can reduce concentrations.
Atrazine. Atrazine is a crystalline, white organic solid that is widely used as an herbicide. It is heavily used in the U.S. on corn and soybean crops. It is also used for asparagus, sugar cane and pineapple crops. Exposure can cause weight loss, low blood pressure, muscle spasms, damage to the adrenal glands and cardiovascular system, heart/lung/ kidney congestion and cancer. Atrazine is subject to microbial degradation. The EPA MCL is 3 ppb. For WHO and ABWA, the guideline value is 2 ppb.
Benzene. Benzene is a highly flammable, colorless liquid used in the production of other organic chemicals and as a petrol additive. It is also used in the manufacture of compounds such as resins, rubber, plastics, nylon, polyester, paint, ink, paint thinner, degreasers, rubber, adhesives and coatings, detergents and dry cleaning. It is also used extensively in the shoe and tire industries, the synthesis of styrene, and the production of drugs, insecticides and dyes. Benzene typically enters the atmosphere through gasoline emissions and exhaust. Benzene exposure can also come from cigarette smoke. The EPA MCL of 5 ppb for benzene in drinking water was established based on reasonable removal capabilities of water supplies using current technology. The MCLG (goal) is zero. For WHO and ABWA, the guideline value is 10 ppb. Health effects include anemia, depression of the immune system, nervous system disorders, chromosome aberrations and cancer. Granular activated charcoal, along with packed tower aeration, are recommended for removal.
Epichlorohydrin. Epichlorohydrin is a colorless liquid organic chemical. It has a pungent odor that smells like garlic. It is used in making plastic and other polymers, including water treatment resins. Trade names include: Chloromethyl-ethylene oxide, Chloromethyl-oxirane and Glycidyl chloride. Like acrylamide, it is used for coagulation of suspended solids, and it is possible that not all of the epichlorohydrin will coagulate. If epichlorohydrin is used in the water treatment process, the EPA requires public water supplies to show that the amount of uncoagulated epichlorohydrin does not exceed 2 ppb. The WHO guideline value is 0.4 ppb. It is readily absorbed by inhalation, ingestion and through skin and can have detrimental effects on the central nervous system, kidneys, liver and blood, as well as cause skin irritation, chromosome aberrations and cancer. Concentrations of epichlorohydrin in drinking water are primarily controlled by limiting its use, as conventional treatment options do not remove it.
Formaldehyde. Formaldehyde is a colorless gas with a pungent straw/hay-like odor. It is used in production of urea-formaldehyde, phenolic, melamine, pentaerythoritol, polyacetal resins, cosmetics, fungicides, textiles and embalming fluids. It is emitted into the air from plastics and resin glues, as well as cigarette smoke and formaldehyde foam in insulation. It is highly soluble in water and does not volatilize. Contact dermatitis and irritation have been associated with skin exposure at higher levels than those found in drinking water. There is some evidence that it is a potential carcinogen through inhalation; however, the majority of evidence suggests that formaldehyde is not carcinogenic from oral exposure. For WHO and ABWA, the guideline value is 900 ppb.
Organizations and government agencies are continually evaluating potential drinking water contaminants and considering regulatory action in order to ensure that the public has access to safe drinking water. Therefore, bottlers must remain diligent in their regulatory monitoring and water monitoring.
