October 2002: Volume 44, Number 10
Bottled Water -- A Primer to Proper Operations
by Loren M. Merrick
The verdict is in--bottled water isn’t a passing fad. The acceptance of packaged water by our culture and the annual double-digit growth in the industry over the past decade make it clear that bottled water is here to stay.
With the success of bottled water came some new players. Dairies and soft drink companies realized that it wasn’t a big stretch to add treated water or even spring water as a product. The success of PepsiCo’s Aquafina, Coca-Cola’s Dasani and Deja Blue are a testament to the success of the crossover to bottled water for soft drink companies.
The other new players in the bottled water business--most are also new to the food and beverage industry--are the water treatment equipment manufacturers and suppliers. For many years, bottled water (particularly 5-gallon sales) was competition for treatment equipment sellers. This competition still exists. Consumers who are looking to improve the taste of their drinking water have been faced with a decision--treatment at point-of-use/point-of-entry (POU/POE) or delivery in a bottle. Many water treatment companies have decided to join the water bottlers and offer customers a choice rather than keep fighting the phenomenon. Americans are receptive to good quality processed water, making it a perfect companion to the water treatment business. Culligan International has become a major national presence in the 5-gallon delivery business and scores of independents have followed into the market with their own processed water.
How to get started
The first thing needed is a change in mindset. Treating and processing water is a small part of the whole scope of a water bottling operation. Bottled water is considered a packaged food by the U.S. Food and Drug Administration (FDA) and by all the individual 50 states as well. With food processing comes new rules, good manufacturing processes (GMPs) and testing. The International Bottled Water Association also requires members adhere to its “Model Code” (see www.bottledwater.org/public/model_main.htm). In fact, bottled water is arguably the most regulated food product in the United States. Can you name one other food product that is required to have an annual chemical test of over 140 parameters at a cost of $2,000 and up? All U.S. bottlers must meet FDA requirements for testing and sanitation as well as any extra rules demanded by each particular state (see EXTRA).
Most regulated food product
What are some of these GMPs and rules? Here’s a short summary of the criteria water bottlers face in order to comply with regulations:
Construction: Outside bottlers’ facilities, there can’t be used equipment, pallets, etc., stored near the building--pests can gather there. Shrubs, grass or weeds should be kept away (recommended distance is 18-36 inches) from the exterior wall for the same reason. Litter and debris must be controlled and not evident. Dumpsters need a good cover and must remain covered at all times. The parking lot and road near the facility must be dust controlled. The exterior walls of a food-producing facility must be sound with no openings for pests to enter the building or harbor inside.
Inside walls must be of sound construction as well. Walls and floors in the treatment and processing areas must be non-absorbent and easily cleanable. There must be adequate lighting throughout, particularly in the fill room and treatment/production areas. Plumbing must be properly installed. There can be no cross connections. Water to be treated into product must be separate from the water used for operations.
The filling and capping of the product must be in a room separate from all other plant operations (i.e., fill room or clean room). This means no boxes in the room, and no washers or other equipment unrelated to the actual filling/capping process. The floors, walls and ceilings in this room must be of smooth construction, non-absorbent, and easy to clean and sanitize. Doors must be self-closing. There must be adequate ventilation with filtered replacement air. A hand wash sink must be available and readily accessible for employees who work in this room. Good lighting is required and all light fixtures must be covered to protect bulbs from breakage to prevent potential contamination.
Storage throughout the plant and building must be away from walls and off the floor to allow access to clean as well as observe potential pest activity.
Operations: Sources, other than municipal supplies, must be approved by local authorities. Water from sources must be delivered, transferred and stored in a sanitary manner. Exposed clean bottles must always be protected from dust and human sneezes, even those on conveyors. Caps and bottles must be stored and handled to avoid contamination. Reusable bottles must be “sniffed”--with contaminant sensing equipment--and examined before washing and sanitizing. Bottles to be thrown away because of sanitary or cleaning issues must be destroyed and stored away from production.
Equipment: All equipment must be constructed of food-grade materials where applicable, be of cleanable design and construction, and installed to allow access for cleaning of the equipment and the surrounding area.
Testing: The FDA requires annual testing of bottled water products for over 140 chemical, physical and radiological parameters. Private sources and products must have a minimum weekly microbiological (total coliform) testing at an approved lab.
At least four of each type of bottle and cap must be tested for coliform and total heterotrophic plate count (HPC) every three months.
Numerous process tests are also required or recommended for pH, total dissolved solids (TDS) and taste tests. These are performed regularly on finished product during processing to prove the product is consistent and treatments are effective. A carry-over test must be performed for detergents in washed bottles to determine if rinsing is adequate.
Process controls: Documentation is required for all aspects of the production. Cleaning procedures, cleaning records, and maintenance records for treatment equipment and washers are required. Distillation, reverse osmosis and all specific treatments need special scrutiny and documentation to show that the processes are working and effective. Ozone, if used, must also be monitored and levels documented. Bottled water detergent levels, temperature and sanitizer levels must also be monitored, maintained and documented. The pest control plan must be spelled out and records kept of all inspections and activities.
Personnel: Employees who work with or near the bottling production must wear effective hair restraints, clean clothing, not smoke anywhere except designated areas, not eat in production areas and must handle equipment and bottles/caps in a sanitary manner. Yes, it’s much more than just water in a bottle.
A safe, quality product
How can bottled water producers take steps to be sure that their processes meet the FDA requirements while producing a safe, quality product? How can they demonstrate to consumers a safe, quality product? Most water treatment dealers and manufacturers are familiar with the NSF International drinking water treatment unit (DWTU) certification program. Did you know that NSF has certified bottled water since 1985? Since then, its auditors have performed almost 7,000 audits of bottling facilities and tested over 5,000 bottled water products and sources.
The verdict is in. Bottled water is here to stay and is also one of the most regulated foods in the United States. If you’re thinking about trying to produce bottled water, you’re now aware of the detailed requirements. Either way, the next time you drink or pour a glass of bottled water, you might consider and appreciate what it took for that water to get to you.
About the author
Loren M. Merrick heads the bottled water program at NSF International, of Ann Arbor, Mich. He’s the trainer for NSF bottled water auditors in GMPs and HACCP. Merrick has visited over 120 bottled water plants around the world and performed over 400 bottled water plant inspections before moving to his current position. He can be reached at (734) 913-5762 or email: email@example.com
EXTRA: Don’t forget your state’s laws
In addition to FDA’s extensive regulatory requirements, the bottled water industry is subject to state regulatory requirements as well. A significant responsibility of the states is inspecting, sampling, analyzing and approving sources of water. Under the federal GMPs, only approved sources of water can be used to supply a bottling plant. Another area in which some states have important responsibilities that complement federal regulation is the certification of testing laboratories. As with any food establishment, the states perform unannounced spot inspections. Some states perform annual inspections as well.
SOURCE: International Bottled Water Association
FYI: Checking the Archives
A quick run-down of WC&P’s archives provides a wide range of bottled water articles within the last three years. For this overview, we have narrowed our focus to three general topics -- ozone in bottled water, its international appeal and regulation issues within the industry. Of course, aside from these articles, you should also look into the websites of USEPA (www.epa.gov), IBWA (www.bottledwater.org), WQA (www. wqa.org) and Canadian WQA (www.cbwa-bottledwater.org) for further information.
* Mork, Dale, “Ozone in Spring Water,” January 2002, p. 38-40.
* Hess, Rick, “Ozone as the Cure -- Instrumentation & Reduction of Bromate Formation in Bottled Water,” November 2001, p. 52-53.
* Davis, Gerald B., “Ozone & Bottled Water: Bromate Levels Shift,” February 1999, p. 80-84.
* Hidell III, Henry R. (Bob), “Australia -- In the Land Down Under, the Bottled Water Industry is Over the Top,” October 2001, p. 90-91.
* Subramaniam, H., “The Bottled Water Industry in India: Living with the New Standards,” February 2001, p. 134-138.
* Holway, Jason, “Bottled Water in the Asian Pacific Region -- China Coming on Strong,” October 2000, p. 86-89.
* von Wiesenberger, Arthur, “Bottled Water: Labeling -- Reading Between the Lines,” October 1999, p. 56-58.
* Bredehoeft, John D., and Michael J. King, “Bottled Water: Feds Release New Guidelines on ‘Spring Water,’” July 1999, p. 98-101.
* Saltzgiver, Kristin M., and Barbara L. Marteney, “Bottled Water Companies Await FDA Guidance on Testing of Nine Parameters,” March 1999, p. 116-119.