Apr 12, 2002

Bottled Water Quality

Reassuring Concerned Customers

Consumer confidence is a critical aspect of any business in
today’s marketplace. It is important to be prepared to communicate
effectively with your customers. You need to know

• What
information is important to your customers,

• What
is the most efficient way to convey the information, and

• How
to explain the information in terms your audience can comprehend.

People are not afraid to ask if your product is up to their
standards (or the government’s). Now that customers receive Consumer Confidence Reports from their municipal water supplies, they have the same expectations of their bottled water provider. They want documentation that bottled water meets or exceeds the water they can get from their tap.

Due to growing concerns about environmental contamination from industry and the use of everyday products as well as fears of intentional tampering of water supplies, people are becoming more conscious of water quality. Letting your customers know that bottled water is regulated by the U.S. Food and Drug Administration (FDA) as a food product and that it is safe is an important part of your business.

Customers may contact a bottled water company with various

• How much sodium is in your water?

• Does your water have fluoride? If so, how much?

• How do I know your water is safe?

• Is your water tested?

Lack of a prompt response that addresses your customer’s
concerns may lead them to believe you have something to hide. Prepare
documentation ahead of time so you have information ready to give customers via
telephone, mail or fax upon request.

An educated consumer can be your best customer. Customers improperly handling or storing product water is a common culprit for complaint calls. Some simple communication with your customers and distributors can help you minimize the number of inquiries and complaints. Customers should be given documentation that explains the “dos” and “don’ts” of bottled water storage. For example,

• DO—Treat bottled water like a food product.
Store it in

- Areas
free from strong odors

- Moderate
temperatures (refrigerated after opening)

• DON’T—Store water

- Near
cleaning products

- Near

- In
direct sunlight

- In
extreme hot or cold temperatures

Note: If you
receive a customer complaint and would like the sample to be tested, it is
important that you notify your laboratory immediately. Some chemicals volatile
over time and may be undetectable if the sample is not transferred to proper
containers in a timely manner.

Providing Information to the Public

Providing customers with information about your quality
control policies, procedures and/or copies of your test results in a manner
they can understand can be accomplished in several ways. One recommendation is
to provide a local or toll-free “800” number on your label so
customers can contact your company easily to request information or report
complaints. This number can be directed to your company or to a call center
where information can be relayed verbally or via mail. Call centers also may
offer bulk mailing services for distribution of your company literature.
Depending on where the water is being sold (or if you are an International
Bottled Water Association [IBWA] member) providing a telephone number on the
label may be a requirement. IBWA member bottlers are required to have written
information on file about their water quality and processes. They can relay
this information to customers as they determine appropriate (i.e., written,
verbal or electronic).

You can be proactive and give all new customers and
distributors information addressing typical questions or concerns. Annual
updates of current information then can be mailed to customers or sent with
usual water deliveries. Sending out reports on the quality of your product
water on a regular basis conveys that your company is concerned about quality and shows that you are in compliance with regulations.

Interpreting Your Laboratory Report

Bottled water companies who are members of the IBWA or
selling product in New York are required (upon request) to provide customers
with information regarding the content of their bottled water products.
Specifically, they must provide customers with information about their water
along with results from the annual product analysis. Sometimes the questions or
requests from consumers are specific. For example, they may inquire as to what
the arsenic or fluoride level is in your product. Other times the question may
be much more general such as “Can you tell me everything that is in your
water?” In order to address these customer questions, you will need to
understand and be able to explain to your customer what your test results mean.

Laboratory reports can, at first glance, appear to be
complicated and confusing. In order to address consumer questions regarding
your product quality, it is important to understand the basic components, terms
and abbreviations used in your laboratory report. Laboratory reports contain
the following basic information.

• Analysis
Performed—Refers to the substance in
the sample for which the laboratory tested.

• Method—Indicates the methodology used by the
laboratory to perform the analysis (usually from Standard Methods for the
Examination of Water and Waste Water or U.S. Environmental Protection Agency

• Lower
Reporting Level (LRL)—The smallest
quantity of a contaminant that the laboratory can detect with a high degree of
confidence. Instead of LRLs, some laboratories may use MDLs (minimum detection
limits), MRL (minimum reporting limits) or RDLs (reporting detection limits) on
their reports. Although they basically refer to the same thing, each definition
has a slightly different technical meaning.

• Level
Detected—The level actually detected
in the water or results. An “ND” indicates the parameter was not
detected at or above the LRL level. In some cases the laboratory may not show
their LRL as a separate column and instead report the level detected as less
than the LRL (<0.005 mg/L). You also may see results listed as 0.5
(±0.02), which indicates that this particular analysis can have a
variance of plus or minus 0.02.

• Units—Unit of measurement used in reporting the LRL
and Level Detected.

- mg/L
(milligrams per liter)—A unit of
concentration calculated on weight/volume basis. It is equivalent to ppm (part
per million). One mg/L can be equated to one ounce of whisky in 8,000 gallons
of water.

- mg/L
(micrograms per liter)—Unit of
concentration calculated on weight/volume basis. It is equivalent to ppb (part
per billion). One (g/L can be equated to one ounce of whisky in 8 million gallons
of water.

- pci/L
(pico curries per liter)—A
measurement used for radiological contaminants.

Other information that may appear on a report includes the

• Date
and Time Collected or Opened—This is
when the sample was collected into the proper laboratory sample containers by
the sampler or, in the case of sealed finished product water, when the bottle
was opened by the laboratory for analysis.

• Federal
ID—The standard code number assigned
by the EPA to identify each contaminant.

(maximum contaminant level)—The
maximum acceptable level of a contaminant in water as determined by the EPA.

• Analysis
Date—The date the sample was
analyzed. Some methods require analysis to be performed within a specified time
period from collection (or opening) for results to be considered

By simply understanding the format and terms used in the
analytical report, you can reassure customers with answers to simple questions
such as “How much (contaminant) is in your water?” In addition to
knowing the results of your water analysis, it often is necessary to be able to interpret what the results mean. To accomplish this, bottlers must understand how and why a certain contaminant in water is regulated at a given level or MCL.

Bottled water is regulated by the FDA. However, the
Standards of Quality (SOQs) that bottled water must meet are driven by EPA
regulations. For each contaminant regulated by EPA, the FDA is required to
determine if this is a potential contaminant in bottled water and, if so, at
what level should it be regulated? For all but a few contaminants that were
determined to be not applicable to bottled water, the FDA has established an
SOQ limit equal to the EPA MCL. For this reason, as well as the fact that
consumers (and the media) are likely to compare bottled water quality to tap
water, it is important to understand why contaminants are regulated and what an
MCL means.

The EPA Safe Drinking Water Act (SDWA) allows the EPA to set
National Drinking Water Standards. These standards are divided into two
categories—primary and secondary. Primary Drinking Water Regulations
pertain to contaminants that pose potential health risks. For example, nitrites
are a primary drinking water contaminant and have been regulated at a level of 1 mg/L because data show a link between exposure to water supplies over that level and increased risk for methemoglobinemia (blue baby syndrome). Secondary Drinking Water Regulations pertain to contaminants that are regulated for aesthetic (nonhealth-related) reasons such as adverse effects on plumbing, taste or odor issues. An example of a secondary contaminant is iron, which is regulated at a level of 0.3 mg/L. Water with iron above this level can have an undesirable taste and color and may cause brown stains on fixtures such as sinks and tubs. However, drinking water with iron above 0.3 mg/L is not known to create any adverse health effects.

When discussing product test results with a consumer, it is
important to know whether the contaminant is a primary (health-related) or
secondary (aesthetic) contaminant. In addition, it is important to know the MCL
for that contaminant. For example, total trihalomethanes (TTHMs) are regulated
by the EPA at an MCL of .080 mg/L because of an increased risk for nervous system problems and cancer.
“Increased” is stressed because this does not mean that someone
consuming a sip of water containing .081 mg/L of TTHMs will develop cancer. The
MCLs for primary contaminants generally are established so that an individual
who drinks 64 ounces of water daily (over an extended period of time) that
contains levels above the MCLs, would have no more than a one in 100,000 chance
of developing adverse health effects. (Often, they are based on a one in one
million chance.) Bottled water
containing a detection of a primary contaminant does not mean that the product
is “unsafe” to drink unless that parameter is above the FDA SOQ or
EPA MCL. In addition, bottled water containing a detection of a secondary
contaminant does not mean that it is “unsafe” to drink as these
parameters are not associated with any health effects. Being able to explain
your results to consumers can help to reassure them of your product quality.

Bottlers must develop effective methods of communicating
with customers regarding the safety and quality of their products. Three keys
to good communication include having information prepared for distribution,
providing customers with an easily accessible method of obtaining your
information and being able to explain what the information means. With the
increased attention that water quality is getting in the media, customer
inquiries regarding product quality will continue to increase along with
expectations about the type of information bottlers should be supplying.

About the author

Barbara L. Marteney and Kristin M. Safran of National
Testing Laboratories, Ltd. (NTL), specialize in consulting with bottled water companies regarding testing requirements and bottled water quality. They maintain contacts with bottled water regulators, industry associations and the FDA regarding regulatory changes and other issues that impact bottlers. They have authored numerous articles and given various presentations on these topics.
Marteney and Safran can be reached at 800-458-3330 or 440-449-2525, Marteney at extension 217 and Safran at extension 215; [email protected].