Bottled Water Quality

April 2, 2018
Reassuring Concerned Customers

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].


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 questions.

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 gasoline

- 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 [EPA]).

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 following.

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.

MCL (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 “valid.”

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.

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