While the Environmental Protection
Agency (EPA) regulates tap water as a utility, the Food and Drug
Administration (FDA) regulates bottled water as a packaged food product.
FDA bottled water regulations include:
Standard of Identity—FDA
requires uniform use of terms like "purified" and
"spring," so consumers can be sure different companies use the
same descriptions consistently on their product labels. For example, a
bottle marked "spring water" must be from a spring. One-fourth
of bottled water comes from municipal sources, rather than a spring or
well. The FDA requires these products be labeled "from a community
water system" or "from a municipal source." However, if
this water goes through a purification process such as distillation or
reverse osmosis, FDA has determined that the product can be defined by
the type of purification (i.e.; "drinking water"), rather than
as from a municipal source.
Current Good Manufacturing Practices (GMPs)—for
both general food and bottled water-specific categories. General GMPs
govern plant and ground maintenance and facility sanitation. Bottled
water-specific GMPs cover plant construction and design, equipment
design and production, process controls specific to bottled water, and
extensive record keeping. They also require safe and sanitary
transportation and storage.
Standard of Quality (SOQ)—Along
with Good Manufacturing Practices, SOQs are specific bottled water
product standards that help ensure safety from production and packaging
to consumption. To ensure compliance, companies must test for
pesticides, minerals, and physical properties such as color. By law, FDA
bottled water SOQs must be at least as stringent and protective of
public health as EPA’s standards for public water supplies.
Bottled Water is also subject
to FDA food recall, mislabeling, and adulteration provisions.
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States also regulate bottled
water. They are responsible for inspecting, sampling, analyzing, and
approving water sources. States certify testing laboratories and perform
unannounced and annual inspections. Some states have unique bottled water
regulations, and many base their regulations on FDA, and in some cases,
industry-based standards.
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The bottled water industry has developed
standards through a trade association. The International Bottled Water
Association (IBWA) requires members to follow the IBWA Model
Code, which
includes annual, unannounced third-party plant inspections. The inspectors
audit quality and testing records, review plant operations, and check
member companies for compliance with federal and state regulations, as
well as IBWA’s standards.
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