Drinking Water—Safety on Tap - Bottled Water

Water is called "bottled water" only if it meets federal and state standards, is sealed in a sanitary container, and is sold for human consumption. The members of the International Bottled Water Association (IBWA) produce and distribute 85% of the bottled water sold in the United States.

Growing Market

According to the Beverage Marketing Corporation in its "2004 Stats" (http://www.bottledwater.org/public/Stats_2004.doc), Americans consumed about 6.8 billion gallons of bottled water during 2004, an 8.6% increase over 2003. That figure translated into about twenty-four gallons per person in the United States, with bottled water ranking second only to soda pop as the American beverage of choice.

Why Do Americans Like Bottled Water?

American consumers have given a variety of reasons for their preference for bottled water. Some say they dislike the smell or taste of water from the tap or drawn from wells. Others cite the convenience of bottled water.

In addition to convenience and taste, concerns over the safety of public water-supply systems since the September 11, 2001, terrorist attacks on the United States are prompting more Americans to rely on bottled water for their drinking water needs. According to "Take Me to the Water," an article published in the May 26, 2003, issue of Supermarket News, a number of retailers reported that concerns about terrorism have fueled a surge in the consumption of bottled water in the United States. The article states that between the years 1998 and 2003, sales of bottled water increased 150%.

Regulation of Bottled Water

Bottled water, like tap water, comes from one of two sources: groundwater or surface water. Depending on the source, it may be subjected to the same treatment as tap water to remove contaminants and to make the taste more appealing.

In February 1999 the Natural Resources Defense Council (NRDC), a nonprofit environmental organization, announced results of its four-year study on the safety and benefits of bottled water. The study (Bottled Water: Pure Drink or Pure Hype?) includedtestingofmorethan1,000 bottles of 103 brands of bottled water. In general, the study FIGURE 5.7
Waterborne-disease outbreaks associated with drinking water, by year and causative agent, 1971–2002
SOURCE: "Figure 3. Number of Waterborne-Disease Outbreaks (n = 764) Associated with Drinking Water, by Year and Etiologic Agent—United States, 1971–2002," in Morbidity and Mortality Weekly Report, October 22, 2004, http://www.cdc.gov/mmwr/PDF/SS/SS5308.pdf (accessed April 1, 2005) stated that while the market for bottled water is driven by an image of purity, that purity may be an illusion due to inadequate regulation of the product. The NRDC concluded, "Bottled water sold in the United States is not necessarily cleaner or safer than most tap water."

In July 1999 the Drinking Water Research Foundation (DWRF) issued a report that analyzed the findings of the NRDC report and the data supporting it. The report concluded that the data in the NRDC report did not support a finding that bottled water in the United States is an inadequately regulated product. The DWRF used both the NRDC's and DWRF testing to reach its conclusion. The DWRF also found that the U.S. Food and Drug Administration (FDA) regulatory system that governs bottled water was functional and provided a high level of public health protection. When combined with the requirements of the "Model Code" (the sanitary production practices that IBWA members voluntarily accept as a condition of IBWA membership), the DWRF stated that there was an even better system to ensure that the public receives a safe and healthy product.

Bottled water is regulated as a "food" by the FDA, under the Federal Food, Drug and Cosmetic Act (FFDCA). Bottled water companies must also adhere to the FDA's Good Manufacturing Practices, and are subject to extensive general food safety and labeling requirements that are not applicable to tap water. Section 410 of the FFDCA requires that the FDA review all new EPA drinking water requirements for tap water and determine if they should be applied to bottled water. As a result, only very small discrepancies exist between the EPA's and FDA's contaminant limits. The primary difference is the emphasis of the bottled water industry on the secondary drinking water standards of taste, odor, and color.

The current relationship in required quality between bottled water and drinking water can best be summed up by the FDA's policy statement concerning bottled water (Drinking Water Research Foundation Analysis of the February 1999 Natural Resources Defense Council Report, July 1999):

In general, adopting the EPA's standards for chemical contaminants as allowable levels in bottled water FIGURE 5.8
Waterborne-disease outbreaks associated with drinking water, by year and type of water system, 1971–2002
SOURCE: "Figure 4. Number of Waterborne-Disease Outbreaks (n = 758) Associated with Drinking Water, by Year and Type of Water System—United States, 1971–2002," in Morbidity and Mortality Weekly Report, October 22, 2004, http://www.cdc.gov/mmwr/PDF/SS/SS5308.pdf (accessed April 1, 2005) is appropriate because it will protect the public health, maintain consistent standards for identical contaminants in bottled water and tap water, prevent duplication of efforts between the EPA and FDA in evaluation of the effects of contaminants in drinking water, prevent public confusion concerning the significance of different standards for bottled water and public drinking water, and not foster public perception that bottled water is required to be of better quality than tap water.

Many states have regulations that are binding on bottled water suppliers and more stringent than the FDA regulations. If the bottler is a member of the IBWA, the bottler is subject to IBWA's additional requirements over and above those required by the FDA and state or local jurisdictions. One of the more stringent IBWA requirements is an annual, unannounced plant inspection administered by an independent, internationally recognized third-party inspection organization to ensure that members are implementing the agreed-upon Model Code practices.

On March 3, 2003, the FDA amended its bottled water quality standard regulations by establishing an allowable level for the contaminant uranium. The final rule took effect on December 8, 2003. The purpose of the new regulation was to ensure that the minimum quality of bottled water, as affected by uranium, combined radium, gross alpha particle radioactivity, and beta particle and photon radioactivity will remain comparable with the quality of public drinking water that meets the EPA's standards. Bottled water manufacturers are now required to monitor their finished bottled water products for uranium at least once each year under the Current Good Manufacturing Practice (CGMP) regulations for bottled water. Manufacturers are also required to monitor their source water for uranium as frequently as is necessary, but must do so at least once every four years unless they meet the criteria for the source water monitoring exemptions under the CGMP regulations.

Despite stringent regulations imposed on bottled water manufacturing, bottled water was epidemiologically implicated in a ten-state outbreak of disease in the United States in 2002. Eighty-four cases were reported in the multistate area from April through August 2000. According to the CDC, in its Surveillance for Water-borne-Disease Outbreaks—United States, 1999–2000 (2002), this was the first widespread outbreak implicating FIGURE 5.9
Number of waterborne-disease outbreaks^* associated with drinking water, by state, 2001–02
SOURCE: "Figure 2. Number of Waterborne-Disease Outbreaks (n = 31) Associated with Drinking Water, by State—United States, 2001–2002," in Morbidity and Mortality Weekly Report, October 22, 2004, http://www.cdc.gov/mmwr/PDF/SS/SS5308.pdf (accessed April 1, 2005) bottled water in the United States. The CDC also stated that prior to this outbreak bottled water had not been identified as a vehicle for transmission of infectious organisms in the United States. The CDC cautioned that because of the wide geographic distribution of bottled water products, an outbreak associated with the consumption of bottled water would be difficult to recognize and suggested that the CDC, EPA, FDA, and the bottled water industry work together to address concerns regarding consumption of bottled water and public health.

Imported European waters must meet the same federal and state standards. In addition, they must meet the strict standards set by the European Union. International bottler members who sell products in the United States must submit a certificate of inspection to the IBWA.