USA: IBWA Comments on FDA Draft Study Report

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The International Bottled Water Association (IBWA) filed comments with the Food and Drug Administration (FDA) on the "FDA Draft Feasibility Study Report: Feasibility of Appropriate Methods of Informing Consumers of the Contents of Bottled Water." The draft study report was published in the Federal Register on February 22, 2000.

IBWA stated, "IBWA believes that consumers should be able to obtain information about the safety and quality of bottled water in a timely fashion. Indeed, consumers can now readily obtain that information upon a simple request. FDA labeling requirements mandate that the name and place of business of the manufacturer, packer or distributor appear on the label. Further, IBWA members must comply with the association's Model Code, which calls for providing a telephone number on the label. This allows consumers easy access to information if they wish to have it. We believe additional regulations for an industry that voluntarily shares comprehensive information about its products with all consumers are simply not necessary."

The basis for the feasibility study on bottled water lies in the Safe Drinking Water Act (SDWA) Amendments of 1996, which required EPA to issue regulations mandating each municipal water system to provide an annual Consumer Confidence Report (CCR) to their customers on water quality, including contaminant levels found in that water. The SDWA Amendments also required FDA, in conjunction with EPA, to prepare a study on the feasibility of methods, if any, of informing consumers of the contents of bottled water.

IBWA asserted that, while the distribution of a Consumer Confidence Report under SDWA may be appropriate for municipal water systems, a CCR is not necessary for bottled water. This type of information is easily available, nor is it legally required, under the extensive regulatory system for packaged foods under the Federal Food, Drug and Cosmetic Act. (21 U.S.C. S 321 et seq.)

"There are vastly different regulatory programs for bottled water versus municipal water systems," IBWA stated. "Since (municipal water) is conveyed to consumers through a distribution system that does not allow for product recall or other product removal, information about the quality of municipal water is appropriate. A Consumer Confidence Report makes sense in such a distribution system. It does not make sense for packaged foods such as bottled water."

In discussing the Association's comments, Stephen R. Kay, IBWA Vice President of Communications said, "FDA already has in place strong and sensible Standards of Identity, Standards of Quality, and Good Manufacturing Practices. Bottled water is a packaged food product that is fully regulated -- like other packaged foods -- and held to the highest of standards by the FDA under the Federal Food, Drug and Cosmetic Act, state authorities and the industry itself, through the IBWA Model Code. There is no public health or public policy basis to single out bottled water from other food products for additional label reporting, especially considering the vast number of food products that utilize water in the ingredients."

Kay concluded, "Consumers have no choice in the municipal water systems that serve their homes and communities, regardless of the amount of solicited or unsolicited information they may receive. With bottled water, consumers have a choice and ready access to contact the manufacturer based on information already required on the label.

"It is critical for the public to understand that -- by law -- standards imposed by the FDA for bottled water are at least as stringent as those required by the EPA for tap water. This is a fact as written in Section 410 of the Federal Food, Drug and Cosmetic Act. It has also been confirmed in numerous EPA publications, which have stated, 'Bottled water is required to meet the same standards the EPA sets for tap water."'

IBWA's comments can be viewed online at "Press Center" "Comments."

The International Bottled Water Association (IBWA) is the authoritative source of information about all types of bottled waters distributed in the United States. Founded in 1958, IBWA has grown to over 1,500 member companies that account for more than 85 percent of all bottled water sales in the U.S. IBWA's membership includes U.S. and international bottlers, distributors and suppliers. Consumers can contact IBWA at 1-800-WATER-11 or log onto IBWA's web site -- -- for more information about bottled water and a list of members' brands.

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