Sep 20, 2002

Bottled Water Testing

What lab results mean and how to explain them to customers

Consumers want to know if the bottled water they buy is
safe. How and why bottled water is regulated is not common knowledge and can be
confusing to customers. Bottlers who understand and can explain aspects of
water quality, regulations and test results to their customers have a useful
sales tool to promote their product.

The true definition of water is represented by the simple
formula H2O. A molecule formed by one oxygen ion and two hydrogen ions
double-bonded together to create an odorless, colorless and tasteless liquid.
Water in its purest form of exclusively H2O virtually is nonexistent due to its
instability. Water is known as the universal solvent because of its ability to
dissolve at least a portion of whatever it touches including rocks, gases, dust
and other particles. It is this solvent action that drives drinking water
quality concerns. When assessing water quality, three basic questions must be

* What
is in the water?

* What
levels of contaminants are present in the water?

* Is
the water safe to drink?

What Is in the Water?

For drinking water, a contaminant can be defined as any
substance or matter other than pure H2O. Some contaminants may be undesirable
as they may pose a health risk or impart an undesirable taste, odor or color. Other contaminants are highly desirable and may be added to water for a unique taste, texture and body. Regardless of being desirable or undesirable, water
contaminants can be broken down into the following classifications:
microbiological, inorganic, organic and radiological.

* Microbiological. This includes microscopic living organisms such as
bacteria, yeast, viruses, molds, cysts, algae, etc.

* Inorganic. Elemental metals and chemical substances that do
not contain hydrocarbons (ex: calcium, iron, nitrates, bromate, etc.)

* Organic. Compounds with a carbon-hydrogen structure. These
can be further broken down into volatile organic chemicals (cleaning solvents,
petroleum by-products) and semi-volatile organic chemicals (pesticides,
herbicides, base/neutral acid extractable compounds).

* Radiological. Elements that emit atomic energy which is generally
in the form or alpha and beta particles of gamma rays (uranium, radon, radium,

At What Level is a Contaminant Present, and Is It Safe to

To answer these questions it is important to understand how
contaminants are regulated and the process by which limits are developed.

Unfortunately, testing for everything in water is not
possible as analytical methods have not been developed for every conceivable
chemical combination. Even if there were methods, the testing would be
extremely cost prohibitive. For this reason, bottled water is required to test
for the presence of a list of undesirable contaminants that have been
identified as potentially present in bottled water. Since bottled water is
regulated as a food product, the FDA establishes the contaminants for which it
must be tested as well as which levels are considered safe. These guidelines,
which bottled water must meet, are the Standards of Quality (SOQ's).

In general, "drinking water" is regulated by the
U.S. Environmental Protection Agency (EPA). The Safe Drinking Water Act (SDWA)
enables the EPA to establish the contaminants and maximum contaminant levels
(MCLs) that public water supplies must meet.

The contaminants regulated by the FDA and the SOQs for those
contaminants, are almost identical to the EPA SDWA National Drinking Water
Contaminants and corresponding MCLs. The FDA is required by a congressional
hammer clause in the SDWA to consider each contaminant the EPA adds to
determine the applicability to bottled water. In almost every instance, the FDA
has determined the parameter is a potential contaminant for bottled water and
established an SOQ equivalent to that of the EPA's MCL. Therefore,
understanding the process by which MCLs are established by the EPA can help
clarify the impact of contaminant detection in bottled water.

First, the EPA SDWA Drinking Water Standards divides
contaminants into two categories.

* Primary
contaminants pose a potential health risk.

* Secondary
contaminants have shown no potential health impact and are regulated purely for
aesthetic reasons such as taste, color, odor or potential plumbing nuisances
for public water systems.

When the EPA regulates a primary (health-based) contaminant
they also establish an MCL. An MCL is the practical and legally enforceable
standard that a PWS must meet. Generally, MCLs are established at a level
resulting in a less than 1 in 100,000 to 1 in 1 million chance of contributing
to a health effect if an individual consumes eight 8-oz. glasses of water
containing the contaminant at that level each day over the course of a

Interpreting an Analytical Report

While report formats differ slightly from one laboratory to
the next, results generally are presented in a tabular format and include the
following information.

Analysis Performed.
The items or parameters for which the laboratory tested.

Method. References
the analytical method the laboratory used to perform the test.

Lower Reporting Level (LRL). The smallest quantity of a contaminant that the instruments can detect with
accuracy. This also can be referenced as the detection limit or minimum
detection level (MDL) by some laboratories.

Results. The actual
level found in the sample. An "ND" means the parameter was not
detected at a level above the LRL. Some laboratories omit an LRL column and
report a less than result (for example, <0.001) if the parameter is not
detected above their LRL.

Units of Measure.

* Milligrams
per liter (mg/L). Unit of measurement
often used for reporting. For example, 1 mg/L of iron can be thought of as for
every million grams of water, there is one gram of iron.

* Micrograms
per liter (ug/L). Unit of measurement
often used for reporting. For instance, 1 ug/L of iron can be thought of as for
every billion grams of water there is one gram of iron. (1,000 ug/L is equal to
1 mg/L)

* Pico
curries per liter (pCi/L). Unit of
measurement used for radiological contaminants.

Customer Communication

It often is helpful to inform customers that, by law, all
bottled water in the United States must be in compliance with the FDA SOQs,
ensuring that it is safe to drink. Understanding and being able to explain to
consumers on what the MCLs and SOQs for bottled water are based can offer
reassurance as to the safety of your product. If there is a detection of a parameter considered undesirable but not
above the established limit, providing a clear, concise explanation can help
allay the customer's concerns. MCLs essentially represent a very
long-term exposure risk; therefore, a detection of a primary contaminant does
not typically represent an immediate health risk.

Bottled water companies should establish a policy for
addressing customer complaints or inquiries. Every employee who may come in
contact with customers in person or over the telephone should be
informed about the company's customer communication policies, procedures
and materials. Miscommunication or conflicting information can cause confusion
and undermine consumer confidence in the product. Industry associations such as
the International Bottled Water Association as well as certain state or local government agencies require
bottlers to have information about water quality readily available to

There are several useful tools for customer communication
such as a telephone number on the bottle label, copies of current test results
and bottled water quality reports. A telephone number printed on the label can
go directly to the plant so employees can handle the calls or the calls can be routed to a call
center where information about the bottling company and the water quality can
be discussed and/or mailed to customers upon request. Bottlers can send out a sample
copy of their latest laboratory report or they may choose to have a high
quality brochure produced to convey test results along with treatment process
and quality control information. This can be an effective tool for
communicating a consistent message
in a professional manner that
readily is available upon request or as a routine mailer. No matter which form
of communication a bottler chooses, today's highly competitive
marketplace makes it critical to project a professional image to current or
potential 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.