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How
is the Bottled Water Industry Regulated ? The Model Code mandatory for members of ABWA is based on the Codex Alimentarius, individual adjustments to country standards Bottled water is a highly regulated
product, subject to international, national and industry standards. The
U.S. Food and Drug Administration (FDA), under the Federal Food, Drug
and Cosmetic Act (FFDCA or the Act), regulates bottled water as a food
product. This includes packaged water sold in smaller containers
at-retail outlets as well as larger five-gallon containers distributed
to the home and office market. Like all food products except meat and
poultry (which are regulated by USDA), bottled water is subject to
FDA’s extensive food safety and labelling requirements, which include: - Food adulteration and misbranding
provisions; When
was The Bottled Water Industry First Regulated ? Since 1938, the
FDA has regulated bottled water as a packaged food under the Federal
Food, Drug and Cosmetic Act (FFDCA). As a food product, bottled water
must be packaged in sealed, sanitary containers. The EPA has regulated
the quality of public water supplies (tap water) delivered to consumers
by their local utilities since 1974. By law, FDA regulations for bottled
water must be no less stringent than the EPA’s regulations for tap
water. It is the GMPs that ensure the safety
of all bottled water products from production to packaging to
consumption. GMPs were mandated by law under the 1962 Kefauver-Harris
Drug Amendments. Some GMPs, which are specific to bottled water
processing and bottling, address plant construction and design; sanitary
facilities; sanitary operations; equipment design and construction;
production and process controls; and record keeping. Bottled water is
one of only five food products that have GMP's above what is required of
all foods. In compliance with the FDA's standard of quality regulation
established in 1974, bottled water manufacturers are also required to
ensure that their products adhere to the allowable levels for substances
in bottled water, such as those for coliform and lead. This regulation
includes levels related to microbiological quality, such as the limit on
the number of coliform organism; physical quality, such as turbidity,
color and odor; chemical quality, such as the limits on organic and
inorganic chemicals; and radiological quality, such as the limit on
radium 226. Bottled water manufacturers also must
ensure that their products meet the FDA established standard of identity
for bottled water products, which was established in 1996. A bottled
water product bearing a particular statement of identity, for example
“mineral water”, must meet the particular requirements of the
standard of identity for mineral water to avoid being misbranded. There
are definitions for bottled water, drinking water, artesian water,
ground water, distilled water, deionized water, mineral water, reverse
osmosis wate, purified water, sparkling bottled water, spring water,
sterile water and well water. If a bottled water is misbranded, it is
subject to recall. On 1 November 2000, The Codex Alimentarius Committee reached a consensus on regulating “Bottled/Packaged Waters Other than Natural Mineral Waters” and has jumped to Step 5 out of an 8 Steps process. It was finalized in 2001 in its current form CODEX STAN 227-2001. The regulation on Natural Mineral Waters was last revised in 1997 and is currently under review. The last format is on CODEX STAN 108-1981, Rev.1-1997. Point 5. 2. 3 Prepared Water from a
Water Distribution System stated that: How
is Bottled Water Different from Tap Water? Consistent quality and taste are two of
the principal differences between bottled water and tap water. While bottled water originates from
protected sources (75 percent from underground aquifers and springs),
tap water comes mostly from rivers and lakes. Another factor to consider
is the distance tap water must travel and what it goes through before it
reaches the tap. In compliance with international regulations, bottled
water is sealed and packaged in sanitary containers. In the unlikely
chance a bottled water product is found to be substandard, it can be
recalled. Tap water cannot. If
Bottled Water is from a Municipal Source, does The Source Have to be
Indicated on the Label? When the source for bottled water comes
from a community water system and does NOT undergo any treatment, the
product label must state that the bottled water is “from a community
water system” or “from a municipal source”. However, if the water is subject to
distillation, deionization or reverse osmosis, the bottled water product
can be legally defined as purified water, demineralized water, deionized
water, distilled water or reverse osmosis drinking water and does NOT
have to state on its label that it is “from a community water
system” or “from a municipal source”. Processing methods such as
reverse osmosis remove most chemical and microbiological contaminants. What
is The Water Tested For? On an annual basis, bottlers must also
analyze finished product samples for the In addition to the tests listed above
and frequencies cited, bottlers conduct additional internal quality
control testing that includes the testing of containers and closures,
which are required quarterly. The testing required for microbiological
evaluation, fillers and the quality of the air in the bottling facility
are conducted on an ongoing basis.
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