September 2001: Volume 43, Number 9
Asia on the Move
by Steve Ver Strat & Tom Bruursema
Most of the developed world today is involved at some level with regulations and standards for drinking water treatment units (DWTUs). Asia is no different. Most recently, key countries have been on the move, including Japan, Mainland China (P.R.C.) and Taiwan (R.O.C.). As with the United States, these markets are growing at a rapid pace, with increasing demands for meeting consumer needs for improved water quality. In the interest of consumer safety and education, regulatory officials in many Asian markets are implementing new regulatory requirements for water treatment devices and/or the development of product standards for this type of equipment as a means of ensuring consumer protection.
This article highlights a few of those regulatory and standard initiatives. First, regulatory issues:
In January 2000,* the Japan Ministry of International Trade and Industry-now known as the Ministry of Economy, Trade and Industry (METI)-promulgated a change to the labeling standards that will affect the manner in which household drinking water treatment devices sold in Japan will be tested and labeled. This change to the labeling standards is actually an addition to the Household Product Quality Indication Law (HPQI).
HPQI-required labeling has been common in Japan for a number of years and covers a wide range of consumer products ranging from household cleaning and polishing products to detergents to cookware. Coinciding with this expanded HPQI coverage of water treatment devices was the 1999 publication of the Japanese Industrial Standards' (JIS) S3201 standard for Testing Methods for Household Water Purifiers.
Much of the labeling required under the HPQI law is based on testing performed per the JIS S3201 standard. The HPQI law allows for the use of manufacturer's data, or independent laboratory data, to support product labeling. Regardless of the source, this data must be developed using the S3201 standard. It's important to note that the labeling required by this law must be in use no later than April 1, 2002.
There are seven specific items that must be included in the labeling of the product or product packaging: materials of construction, identification of the type of filter media, flow rate, minimum-use pressure, contaminant reduction claims (including associated reduction capacity), filter replacement timing and manufacturer cautions for consumer use.
Identification of the main materials of construction, filter media type and timing for filter replacement are basically left to the discretion of the manufacturer. The flow rate indication and minimum-use pressure are to be determined and indicated per the JIS S3201 standard method. For these five items, requirements shouldn't pose a great challenge for most manufacturers. Things get a bit more interesting, however, when addressing claimed contaminants and the device's capacity to reduce these contaminants.
At a minimum, a manufacturer must indicate chlorine and chlorine capacity on the HPQI label. In addition, it's also allowed to indicate turbidity, total trihalomethanes (TTHMs), chloroform, bromoform, bromodichloromethane, dibromochloromethane, tetrachloroethylene, trichloroethylene 1,1,1-trichloro-ethane, simazine (CAT), 2-methyliso-borneol and soluble lead. Again, the methodology for determining reduction capability and capacity for these specific contaminants is contained within the JIS standard. Indication of these contaminants is voluntary, but they represent the only additional contaminants that can be included on the HPQI label; and each must indicate the rated reduction capacity per the JIS standard. It's important to note that capacity is defined as the point where the filtration efficiency falls below 80 percent reduction. In the case of turbidity, it's either the point where the filtration efficiency falls below 80 percent reduction or where the flow rate drops to less than 50 percent of the indicated flow rate (whichever occurs first).
As indicated, a device's capacity to remove a given chemical contaminant is set at the point where the reduction is less than 80 percent when tested in accordance with the JIS standard. These contaminants are tested individually-per the JIS standard-with the challenge level set at the current limit established in the Japanese Drinking Water Standard. As an example, in the case of trihalomethanes, the challenge level would be set at 0.100 milligrams per liter (mg/L) or 100 parts per billion (ppb). Devices under test are subjected to continuous flow at the stipulated challenge level for a minimum of five hours per day until the contaminant reduction drops below the 80 percent value. Since the law doesn't require the manufacturer to limit the capacity claim to the least retained contaminant, it would be possible for a manufacturer to indicate a separate capacity for each claimed contaminant. How well such indications will be understood by the consumer is subject to debate, but on the surface this indication of different capacities for different contaminants could serve as a major point of confusion.
The final requirement provides for cautions that must be observed when using the water treatment device. Unlike the other requirements, the cautions in use must be affixed to the actual device. Examples of the cautions include an indication that performance and service life may vary in accordance with water quality and water pressure, only water deemed suitable for drinking shall be used with the device, the filtered water shall be used as soon as possible (avoiding prolonged storage), and the unit must be thoroughly flushed after periods of prolonged non-use.
The April 1, 2002 effective date of this regulation is rapidly approaching. Manufacturers of product sold in Japan that weren't aware of this pending requirement will need to take prompt action if they're to avoid regulatory compliance challenges to their continued product sale or importation. Manufacturers of third party certified equipment will face an additional challenge in reconciling the discreet contaminant specific capacity statements required by this regulation vs. the single capacity (least-retained contaminant) indication required by most certification programs.
And now for standard initiatives:
There's the potential for Mainland China to follow a similar path as that of Taiwan. A delegation of Ministry of Health officials visited several organizations in April, including NSF International and the Water Quality Association (WQA). The primary goal of their visit was to understand the ANSI/NSF standards for DWTUs and the process used for their development. Few standards exist in China for these devices, yet the market is flourishing. It's the intent of the ministry to establish similar standards to those of ANSI/NSF.
The next critical step is to educate all health officials in China regarding the standards and their applications in China. To address this need, a seminar for ministry officials from all Chinese provinces, totaling about 100, has been organized. Amway China has taken the lead in coordinating the event with the ministry officials. NSF and Amway China are working together to identify appropriate speakers and presentation subjects. The seminar is tentatively scheduled for Nov. 6-8 in Beijing. At the present time representatives of NSF, WQA, the U.S. Environmental Protection Agency, World Health Organization and Aqua Europa are all expected to participate.
At a signing on June 12 in Taipei, the director general of the Bureau of Standards, Metrology and Inspection (BSMI) for Taiwan, having responsibility for product standards and compliance, signed an agreement with NSF International for use of the ANSI/NSF DWTU standards as Taiwanese national standards. This signing concludes two years of discussion regarding accessibility and applicability of the ANSI/NSF Standards (see Table 1) for use in Taiwan.
The final adoption of these standards is expected to take some months, quite possibly a year or more. It's the responsibility of the BSMI expert drafting committee to decide if any changes are needed to address water quality issues and regulations in Taiwan. While the majority of participants in the drafting committee are from the academic community, local industry representatives will remain active. The Taiwanese WQA chapter, ROC-WQA, will take the lead in coordinating industry input as directed by the committee's technical chair, Paul Leung of Amway Taiwan. NSF will also remain active. To begin the review process, NSF presented to the drafting committee a detailed understanding of the standards and background.
The final impact of these new standards is yet to be determined. Discussions are under way to determine if they'll remain as voluntary standards or become mandatory. If mandated, another consideration will be their application to imported product vs. those manufactured locally. NSF is actively engaged in these discussions, as is ROC-WQA.
Time doesn't stand still and the issue of standards and regulations for water treatment and water treatment devices in Asia are on the move, particularly in the Far East.
About the authors
Steve Ver Strat is a graduate of Michigan State University, and is presently the group leader for Technical/Regulatory Affairs in the Access Business Group LLC. He has over 15 years experience in international regulatory compliance and serves as the chairman of the WQA World Assembly Division Standards and Regulations Committee. He can be reached at (616) 787-6133 or email: steve_ firstname.lastname@example.org
Tom Bruursema is a graduate of Eastern Michigan University, and is presently general manager for the DWTU Program and Environmental Research Services at NSF International. He has over 16 years experience in product testing and certification. He can be reached at (734) 769-5575 or email: email@example.com
Table 1. Drinking water standards in Taiwan
NSF standard designation...............Standard title
ANSI/NSF 61-2001...............Drinking Water System Components-Health Effects
ANSI/NSF 42-2001...............Drinking Water Treatment Units-Aesthetic Effects
ANSI/NSF 44-2001...............Residential Cation Exchange Water Softeners
ANSI/NSF 53-2001...............Drinking Water Treatment Units-Health Effects
ANSI/NSF 55-2000...............Ultraviolet Microbiological Water Treatment Systems
ANSI/NSF 58-2001...............Reverse Osmosis Drinking Water Treatment Systems
ANSI/NSF 62-1999...............Drinking Water Distillation Systems