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W W W. B O T T L E D W AT E R . O R G


ALSO IN THIS How to Share Bottled Water’s Good Story

ISSUE Why You Should Talk With Your Elected Officials

How FSMA Changes Affect You







EVALUATING THE TOTAL PACKAGE New Study Finds Bottled Water Has Lowest Water and Energy Use Ratios Among All Packaged Beverages

Volunteering: Good for You and Your Community Too Tips to Encourage Consumers to Recycle More A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION
















TechLong Inc Add.: 6817 E. Gage Ave. Commerce, CA 90040, USA Tel: +1 562 928 7755 Fax: +1 562 928 4499 Website: www. Email:

VOL. 55 • NO. 1


24 | Have You Talked With Your Newly Elected Member of Congress? Following the 2014 elections, we have new legislators to educate COMMUNICATIONS

26 | Why and How to Share Bottled Water’s Positive Environmental Sustainability Story Time for a plot twist TECHNICAL UPDATE

28 | FSMA Proposed Rules: Take Two What you need to know about FSMA’s supplemental proposed preventive controls rule VALUE OF IBWA MEMBERSHIP

32 | Network, Education, and Participation Collins Speed Pugh (Mountain Valley Spring Company) shares with Bottled Water Reporter how she gets the most out of her company’s IBWA membership.


CHAIRMAN’S COMMENTARY ...............................2 PRESIDENT’S MESSAGE ......................................4


WATER NOTES ....................................................6

12 | Evaluating the Total Package

CALENDAR .......................................................31

The results are in from IBWA’s “2014 Water and Energy Use Ratio Benchmarking Study.” Not surprisingly, bottled water’s water and energy use ratios are the lowest among all packaged beverages. Find out how environmental consulting firm Antea Group collected and analyzed the data. By Laura Nelson

18 | How to Participate in Your Community’s Recycling Event

Volunteering: Good for You and Your Community Too Have you ever thought about finding a way for your company to get involved in community recycling efforts? If so, you aren’t alone. Blackhawk Molding staff not only thought about it, they actively sought out a way to volunteer in their community. Learn why they say it was worth the effort. By Jeff Davis

CEU QUIZ .........................................................30 ADVERTISERS ...................................................31


BOTTLED WATER REPORTER, Volume 55, Number 1. Published six times a year by The Goetz Printing Company, 7939 Angus Court, Springfield, VA, 22153, for the International Bottled Water Association, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314-2973. Tel: 703.683.5213, Fax: 703.683.4074, Subscription rate for members is $25 per year, which is included in the dues. U.S. and Canadian subscription rate to nonmembers is $50 per year. International subscription rate is $100 per year. Single copies are $7. POSTMASTER: Send address changes to Bottled Water Reporter, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314-2973.


As I write this column, my first as IBWA chairman, I have an important message. When I think back to when I first joined IBWA in 2004, I am reminded of my journey to chairman of the board. My brother Doug and I own a small bottled water company, and as new members of the association, we had so much to learn. I was determined to get everything out of my IBWA membership that I could, so I joined many committees, task forces, and projects. I quickly found out that my participation was appreciated and the return on my investment was more valuable than the time or expense I invested. It is a cliché, but you get out what you put in. Admittedly, I had some concerns about how the association would benefit my company. I discovered that IBWA serves all members—large, medium, and small. I learned that the vast majority of IBWA members are small, locally owned companies. In fact, 90 percent of IBWA’s members report annual gross sales less than $10 million. Somehow, that information bolstered my confidence in those early days, and I began to vocally contribute and share my industry experience at meetings. And look at me now: I’m your chairman, and I’m asking you to do the same. Become as active as possible within IBWA, reach outside your comfort zone, decide to make a difference, and work with me to shape the future of the association and the bottled water industry. Obviously, this will take hard work from all of us. We need not only to be active on committees but also on Capitol Hill. We need to commit to meeting with legislators and regulators to ensure they understand the issues facing the bottled water industry. If you can’t make it to Capitol Hill, invite elected officials to visit your facilities. An educated legislator is an understanding one—and they like nothing more than talking with voters from their districts. An uneducated legislator, however, is actually a risk to your business. The discussions we have on Capitol Hill and in committee meetings will help us chart a prosperous course for the bottled water industry. To manage the rapidly changing political, regulatory, and retail landscape of the bottled water industry, we need to maintain control. We can do this by letting IBWA staff know what tools we need to stay relevant and successful. If IBWA is to meet our needs, now and in the future, it needs to hear from all of its members. Here’s what you need to remember: Each IBWA member—large, medium, and small—helps to define the shape and capabilities of IBWA. It is up to us to come together and work toward this vital and common goal. Join me.

Bryan Shinn IBWA Chairman





International Bottled Water Association OFFICERS Chairman Scott Hoover, Roaring Spring Bottling Bryan Shinn, Shinn Spring Water Company Vice Chairman Philippe Danone Joe Bell,Caradec, Aqua Filter Fresh Waters of America Treasurer William Patrick Young, Absopure Water Co., Inc. Shayron Barnes-Selby, DS Services Immediate Past Chairman Stewart Allen, DS Waters


Shayron Barnes-Selby, DS Services Stewart Waters Joe Bell,Allen, Aqua DS Filter Fresh Peter Baker, Vermont Pure Waters Springs,ofInc. Philippe Caradec, Danone America Joe BellEurofi Sales,nsInc. AndyBell, Eaton, Eaton Analytical Page CG Roxane Brian Beykpour, Hess, Niagara Bottling LLC Philippe Caradec, Danone Waters America Doug Hidding, Blackhawk MoldingofCo. Marty Conte, Diamond Water Co. Dave Holdener, Nicolet Springs Forest Bottling Doug Hidding,Roaring Blackhawk Molding Co. Scott Hoover, Spring Bottling Scott Hoover, Roaring Spring International Bottling Dan Kelly, Polymer Solutions Dan Kelly, Polymer Solutions International Greg Nemec, Premium Waters, Inc. Greg Premium Waters, Heidi Nemec, Paul, Nestlé Waters North Inc. America Steve OzarkaSpring WaterWater and Coffee Service Bryan Raupe, Shinn, Shinn Company Chris Saxman, Shenandoah Water Co. Robert Smith, Grand SpringsValley Distribution Bryan Shinn, Shinn Spring Water Company Breck Speed, Mountain Valley Spring Company, LLC Robert Smith, Grand Springs, Inc. Bottlers, Inc. Lynn Wachtmann, Maumee Valley Dimitrios Smyrnios, Nestlé Waters North America William Patrick Young, Absopure Water Co., Inc. Breck Speed, Mountain Valley Spring Company, LLC IBWA EXECUTIVE COMMITTEE Ray Steed, CCDA Waters, LLC Jeffrey Vinyard, Chairman, BryanCrystal Shinn,Springs Bottled Water Co. Shinn Spring WaterMaumee Company Lynn Wachtmann, Valley Bottlers, Inc. Shayron Barnes-Selby, DS Services William Patrick Young, Absopure Water Co., Inc. Joe Bell, Aqua Filter Fresh IBWA EXECUTIVE COMMITTEE Philippe Caradec, Danone Waters of America Tom Harrington, Services Chairman, Scott DS Hoover, Roaring Spring Bottling Henry Hidell,DS III,Waters Hidell International StewartR.Allen, Scott Hoover, Roaring Spring Bottling Philippe Caradec, Danone Waters of America Dan Kelly, Polymer Solutions International Marty Conte, Diamond Springs Water Heidi Nestlé North America HenryPaul, R. Hidell, III,Waters Hidell-Eyster International Breck Speed Dan Kelly, Polymer Solutions International William Patrick Shenandoah Young, Absopure Chris Saxman, ValleyWater WaterCo., Co.Inc. Dimitrios Smyrnios, Nestlé Waters North America

COMMITTEE CHAIRSValley Spring Company Breck Speed, Mountain

William PatrickCommittee Young, Absopure Water Co., Inc. Communications Damon Grant, Pure Flo Water, Inc. Jane Lazgin, Nestlé Waters North America COMMITTEE CHAIRS Education Committee Communications Committee Glen Water Co., Inc. Mick Davis, Gunter,Absopure Primo Water Corporation Douglas Hupe, Aqua Filter Fresh Water Co., Inc. William Patrick Young, Absopure Environmental Sustainability Committee Education Committee Philippe Caradec, Danone Waters of America Marty Conte, Diamond Springs Water Jeff Molding GlenDavis, Davis,Blackhawk Absopure Water Co.,Co. Inc. Government Relations Committee Environmental Sustainability Committee Shayron Barnes-Selby, DSWaters Services Philippe Caradec, Danone of America Gene Belcher, Grand Springs Breck Speed, Mountain ValleyDistribution Spring Company Membership Committee Government Relations Committee Marge Polymer Solutions ShayronEggie, Barnes-Selby, DS WatersInternational Kelley Goshay, DS Services Robert Smith, Grand Springs, Inc. State and Regional Associations Committee Membership Committee Joe Cimino, David Carlile,ChoiceH2O 3M Purification, Inc. Ross Dave Rosette, Muscato,H2Oregon Nestlé Waters North America Supplier and Convention Committee Small Bottler Resources Committee Brian Grant, Pure Flo Water, Inc. Water Co. Bill Saxman, Shenandoah Valley Dan Kelly, Polymer Solutions International Bryan Shinn, Shinn Spring Water Company Technical Committee State andEaton, Regional Associations Committee Andy Eurofins Eaton Analytical Ross Rosette, H2Oregon Kevin Mathews, Nestlé Waters North America Supplier and Convention Committee Brian Grant, Pure Flo Water, Inc. Dan Kelly, Polymer Solutions International Technical Committee Andy Eaton, MWH Laboratories


Beverage Marketing Corporation predicts that by 2016 bottled water will overtake carbonated soft drinks as the No. 1 packaged beverage on the market. And I’m not surprised. The bottled water industry provides a safe, healthy, convenient product that consumers are increasingly making their packaged beverage of choice. That’s despite many critics who attempt to discourage people from drinking bottled water due to a number of unfounded reasons. Some of their misinformed concerns deal with environmental issues. In this Environmental Sustainability edition of Bottled Water Reporter, we present just a few examples of how the bottled water industry continues to be a good steward of the environment.

BOTTLED WATER REPORTER is published for: International Bottled Water Association 1700 Diagonal Road, Suite 650 Alexandria, VA 22314-2973. Tel: 703.683.5213 Fax: 703.683.4074

IBWA STAFF President Joseph K. Doss Vice President of Education, Science, and Technical Relations Robert R. Hirst Vice President of Communications Chris Hogan Vice President of Government Relations Kristin Pearson Wilcox Chief Financial Officer Michelle S. Tiller

IBWA Environmental Sustainability Committee Co-Chair Jeff Davis (Blackhawk Molding) explains in “How to Participate in Your Community’s Recycling Event” (p.18) the extra effort his company went through to volunteer in its community. Admittedly, Davis says it involved a lot of legwork, but the reward was worth it. He hopes that other IBWA members will be inspired to volunteer in their communities and use the opportunity to educate people about the bottled water industry.

Director of Government Relations J.P. Toner

I hope you enjoy the articles in this issue of Bottled Water Reporter. As always, feel free to contact IBWA Publications Manager Sabrina Hicks ( if you have any article suggestions for future issues.

Joe Doss IBWA President BWR

International Bottled Water Association

In “Evaluating the Total Package” (p.12), Laura Nelson (Antea Group) details how data was collected for IBWA’s “2014 Water and Energy Use Ratio Benchmarking Study.” The study covers the period 2009-2013 and represents more than half (56 percent) of the total 2013 U.S. bottled water consumption. The study’s conclusions: North American bottled water facilities have a water use ratio of 1.32 liters per liter (including the liter of water packaged for consumption); the industry’s energy use ratio measures at 0.24 megajoules per liter. Those are the lowest water and energy use ratios among all packaged beverages.

Our Government Relations column (p.24) continues the education theme—this time, the importance of sharing bottled water facts with your local and federal legislators. It also presents the dates IBWA has scheduled to visit Capitol Hill in 2015, and we encourage all IBWA members—large, medium, and small—to join us. The Communications column (p.26) offers suggestions on how to dispel any untruths you read about the bottled water industry in print and online. And this issue’s Technical Update column (p.28) identifies the changes the U.S. Food and Drug Administration (FDA) has made to its Food Safety Modernization Act (FSMA) proposed rule for preventive controls. FDA’s published supplemental proposed prevention controls rule includes more detail, addresses hazards, adds a new section on supplier programs, and further discusses corrective actions.




Director of Conventions, Trade Shows, and Meetings Michele Campbell Director of Science and Research Tamika Sims, PhD

Manager of Publications and Special Projects Sabrina E. Hicks Manager of Member Services Dennis Carpenter Education and Technical Programs Coordinator Claire Crane Executive Assistant Patrice Ward Bottled Water Reporter Layout and Design Rose McLeod Tel: 315.447.4385 Editor Sabrina E. Hicks Advertising Sales Stephanie Schaefer

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“I WANT TO BE RECYCLED” National Advertising Campaign Breaks Through Clutter to Educate Consumers to Recycle Right Despite heightened visibility of public recycling bins and more curbside programs, national recycling rates continue to hover at 34 percent. On average, Americans recycle 1.5 pounds out of the 4.4 pounds of trash they produce daily. There’s an urgent need for consistent national consumer messaging and education to complement effective infrastructure programs to raise recycling rates. To address that issue, Keep America Beautiful and the Ad Council launched a breakthrough public service advertising (PSA) campaign in July 2013 designed to raise awareness about recycling. The “I Want To Be Recycled” campaign aims to motivate Americans to recycle every day. The campaign artfully shows that recyclable materials, like plastic bottled water containers, can be given another life and 6



become something new when someone chooses to recycle. (Watch the “I Want To Be Recycled” video at IWantToBeRecycled.) Since the campaign’s launch, there has been more than $56 million in donated media, including more than 50 percent of donated TV appearing in prime-time slots and donated national print appearing in TIME, Forbes, Family Circle, and Money magazines, among others. The campaign will launch new TV and outdoor creative in the spring. “Recycling is a tough proposition for most Americans. You need to have access, know what to do, and believe it’s important,” said Jennifer M. Jehn, Keep America Beautiful president and chief executive officer. “Our research showed that 77 percent of American adults say they recycle, but only 38 percent of those are ‘avid

recyclers,’ who recycle nearly everything and will go out of their way to do so. Rather than trying to get non-recyclers to completely change their behaviors, we are focusing on trying to get occasional recyclers to do a little bit more.” Education

Keep America Beautiful is focused on influencing people’s recycling behaviors at work, at home, and on the go through awareness and

education campaigns. The English-language “I Want To Be Recycled” PSA campaign directs audiences to, while new Spanish PSAs direct people to Here, people can find educational information about recycling, including a search tool showing nearby recycling locations. The campaign website provides a variety of tools and resources, including a series of infographics that show the “journey” a recyclable takes to become something new as well as the “Super Sorter” game, which demonstrates how a materials recovery facility (MRF) works. Find out if you’re a “Super Sorter” and play the game: Get Involved

If you would like more information on this campaign, contact Brenda Pulley at Keep America Beautiful: You can also visit the website and follow and interact with the campaign on Facebook, Twitter, YouTube, and Tumblr.

The Super Sorter game ( demonstrates how a materials recovery facility works.



90% of

IBWA’s members are small businesses, reporting less than $10 million in annual gross sales. EDUCATION

Americans Recycling Less Although bottled water bottles continue to be the most frequently recycled PET beverage container in curbside recycling programs (at 38.04 percent), a 2014 Harris Poll survey conducted on behalf of the Institute of Scrap Recycling Industries found that American adults ages 18-34 are significantly less likely to say they always recycle (33 percent vs. 48 percent of those ages 35+). However, there’s still hope as those same younger Americans say they wish they recycled more than any other age group (37 percent vs. 22 percent of those age 35+). Interestingly, a survey conducted on behalf of the American Chemistry Council by the Kelton

Group found Americans say they would recycle more if they had better information on what to recycle, particularly for plastics. Forty-six percent of Americans surveyed said they are more likely to recycle when they know that an item is recyclable, as opposed to when they are unsure. It seems Americans continue to be interested in recycling; they simply need more education about what can and cannot be recycled. For the bottled water industry, perhaps that means we need to ensure our customers are aware that all of our containers are 100-percent recyclable. IBWA has some information

that members might find helpful with that endeavor. On IBWA’s website, under the Education tab, we have a recycling section: education/recycling. That page presents some “Did You Know” facts that we encourage members to share with their current and perspective customers. For example, did you know that recycling a single plastic bottle can conserve enough energy to light a 60-watt lightbulb for up to six hours? Source: americans-recycling-lesssurveys-show/

Recycling 101: How Plastic Bottles Are Recycled

Ever wanted to show your customers what happens to their empty plastic bottles after they place them in the recycling bin? This IBWA-produced video shows how empty bottles are turned into other products. Tour guide Ben McElrath, president of Marglen Industries, says his recycling factory is hungry for empty bottles, so we all need to recycle more and promote recycling too! In case you haven’t heard, it takes much less energy to make products from recycled material rather than using virgin materials. Check the video out and share it with your customers: IBWARecyclingPlasticBottles.

JAN/FEB 2015





IBWA Announces 2014 Award Winners During the 2014 IBWA Annual Business Conference and Trade Show, held November 10-14 in Dallas, Texas, the association announced the winners of six prestigious awards. IBWA Board Member, and Supplier and Convention Committee Co-Chair, Dan Kelly (Polymer Solutions International) presented awards in the categories of Route Salesperson of the Year, Plant Manager of the Year, Supplier of the Year, Environmental Stewardship, and Advocacy during the conference’s general session, which was attended by more than 300 IBWA members and convention attendees. “These winners truly represent excellence within the bottled water industry and IBWA’s membership,” said IBWA President Joseph Doss.


Shayron Barnes-Selby, DS Services of America, Inc. The inaugural winner of IBWA’s Advocacy Award, Shayron is active in all IBWA state and federal legislative and regulatory efforts. She assists with IBWA’s communications and public outreach activities. She has for many years served as the co-chair of the IBWA Government Relations Committee, and she is also the treasurer of the IBWA Political Action Committee. And last year, Shayron was appointed to the IBWA Board of Directors.


Nicole Boehm, DS Services of America, Inc. Nicole prides herself on producing a high-quality product, in a safe and productive work environment. The Lakeside DS facility achieved IBWA’s Excellence in Manufacturing status each and every year Nicole managed the plant. In 2013, her facility received top honors among all DS facilities across the country for product quality and safety.




ROUTE SALESPERSON OF THE COMPANY SALES OVER $8 MILLION: YEAR Mike Forristall, Nestlé Waters North America, Framingham, MA Mike’s great service is one of the many reasons customers from his previous routes still ask for him. His commitment to his customers is only outshone by his commitment to Nestlé and his team.

ROUTE SALESPERSON OF THE YEAR COMPANY SALES BETWEEN $2.1 - $8 MILLION: Shawn Kelleher, Culligan Bottled Water, Brooklyn Park, MN Although his route is the hardest and least popular at the company, last year Shawn not only ensured that his current customers were well taken care of—he also brought on 52 new clients. And not just any clients—corporate clients that brought great exposure and revenue to Culligan.



ENVIRONMENTAL STEWARDSHIP AWARD The Water Guy Among its many exceptional environmental stewardship efforts, The Water Guy’s bottling plant uses an ultra-efficient cleaning method to reduce water usage when cleaning empty bottles. They have also instituted a sophisticated ozone application to significantly reduce the use of chemical agents and cleaners when sterilizing water pipes, storage tanks, and finished products.

Blackhawk Molding Blackhawk keeps customers up-to-date on any new technology available that might help them save money. With 100-percent on-time product delivery, the company provides exceptional customer service along with exceptional quality products. Blackhawk is a great representation of the term “vendor partner.”

Niagara Bottling Founder Inducted Into Bottled Water Hall of Fame On November 13, 2014, IBWA and Beverage World magazine inducted Andrew Peykoff, Sr. into the Bottled Water Hall of Fame during the 2014 IBWA Annual Business Conference in Dallas, Texas. Peykoff, founder and chairman of the board at Niagara Bottling, LLC, is a selfmade success story within the bottled water industry. Born the son of Macedonia immigrants, Peykoff lugged 5-gallon glass bottles door-to-door when he started his bottled water business 51 years ago. “I was the chief cook and bottle washer, salesman, route driver, and mechanic,” said Peykoff to an audience of 300 IBWA members at the organization’s general session. “I worked late most nights for many years. That’s what it took. Give it your best or give up—and giving up was not in my DNA.” Today, Niagara Bottling is the largest family-owned bottled water company in the United States and a technology leader. It has lightweighted bottles and caps, and pioneered many other innovations, including nested packs that reduce the use of corrugated cardboard and has saved millions of trees. Peykoff is only the 38th bottled water executive to be inducted into the Bottled Water Hall of Fame. Members of this exclusive group have shown devotion, creativity, and love for the bottled water industry above and beyond the call of duty. In addition, their association with the industry, and civic and charitable activities exceed those of the average businessperson. In short, Hall of Fame inductees are those who have Andrew Peykoff, Sr., and Derieth Sutton, economic development and government earned the respect and admiration of their peers for their extraordinary relations manager at Niagara Bottling, service to the bottled water industry. pose for a photo after the Bottled Water Hall of Fame induction ceremony.

JAN/FEB 2015




DWRF: Thanks to Our Sponsors This wonderful evening could not have happened without the support of DWRF sponsors and guests. All of the money raised during the 2014 DWRF Casino Night will help to fund vital research impacting the future of the bottled water industry. DWRF would like to give a special thanks to the following event sponsors: Presenting Sponsor Nestlé Waters North America

The Drinking Water Research Foundation (DWRF) would like to thank all of the sponsors and attendees of the 2014 DWRF Casino Night fundraiser event held in Dallas, Texas, on November 11, 2014. The event, which took place at Gilley’s Dallas, was held during the 2014 IBWA Annual Business Conference and Trade Show. More than 90 guests enjoyed Texan cuisine, entertainment from singer/songwriter Israel Gonzales, and fun, friendly gambling on the casino tables. (No money was exchanged for winning; all gambling was done with “fake” chips. All money collected went to DWRF.)



Gold Sponsors Hogan Lovells MTN Products, Inc. Silver Sponsors AQUAQUEEN Australia Bell Sales, Inc. Blackhawk Molding Co. Inc. Consolidated Container Company Mountain Valley Spring Company Polymer Solutions International The Water Guy Van Ness Feldman



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Gaining a Better Understanding of the Bottled Water Industry’s Resource Use Through IBWA’s 2014 Water and Energy Use Ratio Benchmarking Study By Laura Nelson

Has your company developed an environmental sustainability strategy or considered some sustainable initiatives? If you are reading this article, chances are you have already participated in a sustainability initiative of some sort—perhaps engaging in energy savings programs, reducing water use, or recycling waste. More companies are beginning to build sustainable initiatives into their business plans not only because “it’s the right thing to do” but also because it makes sound business sense. Sustainable business practices result in more efficient processes and reduce wasted resources—and can save a company money in the long term. The key to a successful sustainability program is to begin by evaluating how resources are used in operational processes to


generate your finished product, and then using that information to gauge performance. Perhaps the most difficult step is quantifying resource use: How do you set the scope? Where do you find the data? And how do you engage the right personnel to ensure you are effectively acquiring the information you need most? In 2013, as part of its commitment to driving environmental stewardship and social responsibility in the beverage industry, IBWA commissioned a water use ratio benchmarking study as a first step toward understanding the impacts of water use in the North American bottled water industry. That inaugural study resulted in several key accomplishments: members collaborated to provide water use and production data for the study, best practices in water stewardship were identified, and an average water use ratio was established (i.e., 1.39 liters of water used per liter of bottled water produced for consumption). Based on the success of the inaugural study, IBWA elected to pursue a new benchmarking study in 2014 that expanded the study scope to include a five-year period (2009-2013) and an evaluation of both water and energy trends. The 2014 study further evaluated trends and observations reported in the inaugural study, updated the average water use ratio—the latest figure is 1.32 liter per liter (L/L)—and established an average energy use ratio—0.24 megajoules per liter (MJ/L)—for the North American bottled water industry. This study found that bottled water has the lowest water use ratio and energy use ratio of all packaged beverages.







JAN/FEB 2015 • BWR • 13

IBWA sees benchmarking as an opportunity for the North American bottled water industry to demonstrate its dedication to sustainable business practices. The Challenge: Preparing to Launch Your Study As IBWA has found, building a successful benchmarking study is not easy. Several challenges may be encountered along the way. Those challenges can be overcome with thoughtful planning up front and communication with participants throughout the process. Following are some examples of how IBWA approached those challenges in order to generate a successful benchmarking study. Setting the scope. Many factors need to be considered when evaluating resource use at a facility or company level, and it is easy to become overwhelmed when initiating the process. Your first priority should be to set the scope of what is to be included and excluded from the study. IBWA modeled its study using the Beverage Industry Environmental Roundtable (BIER) methodology. (To learn more about BIER’s methodology, visit www.


its dedication to sustainable business and to collaborate on best practices that could be shared internally and with external stakeholders, so that the greater industry could continue to work towards more efficient bottled water operations. The successful outcome of the inaugural study also helped to boost member participation in the 2014 study by 20 percent. Collecting the data. The success of a benchmarking study relies upon the availability of a complete, reliable data set. An effective data collection effort will set clear guidelines for required data, define the requested measures (e.g., what constitutes “total water use”), establish a reasonable response period, and ensure that all parties involved with data collection and validation are aware of the study scope and boundaries. Participants in the IBWA study had varying internal data collection processes: some use advanced data management systems to electronically track data among several sites, others use spreadsheets to manually track information across invoices, and many participants needed to perform unit conversions to align with the requirements of the study. Use of the IBWA standard data collection workbook helped to take the guesswork out of data submittal. The workbook included standard definitions, well-defined data categories, and a unit conversion guide to support participants with consistent data entry, regardless of the source.

Participants were asked to provide data for bottled water manufacturing facilities only; distribution centers, office buildings, and other non-manufacturing locations were excluded. Metrics data was provided for operations “within the four walls” of the facility. That meant information for valuechain operations was not included in the study (e.g., off-site bottle production, distribution to customers, customer refrigeration). IBWA selected total production, total water use, and total energy use as the key metrics for the benchmarking analysis based on IBWA member goals and alignment with other beverage industry studies. The study provided IBWA with valuable information on operational metrics use, and paved the way for future benchmarking studies to incorporate new factors, such as carbon emissions.


Building participation. Active participation and buyin from your team is critical for the success of a benchmarking study. Data collection, process evaluation, and analysis require a lot of effort, so it is important to present the business case: Why should the team engage in this study? What’s in it for them? IBWA approached members by presenting benchmarking as an opportunity for the North American bottled water industry to demonstrate

• Seek supplemental process information to help support process drivers—start with basic information, and build in future studies.



• Determine what data will be the most meaningful to your business and your sustainability program. • Collect data that can feasibly be provided for your operations (e.g., does the data exist?). • Create a glossary of terms for your study—define boundaries, measurements, units of measure, etc. • Allow ample time for data collection and analysis. • Define a clear process for data collection and reporting.

• Make the business case for benchmarking—identifying efficiencies can lead to cost savings.

IBWA STUDY Supplemental process data. Collecting quantitative and qualitative supporting data on facility process can shed light on the drivers of performance trends, and highlight process efficiencies or opportunities for improvement. The challenge lies in pinpointing the processes that should be the focus of the study, and making sure the data is available to support the trends that are being evaluated. To evaluate process characteristics among several facilities, IBWA asked participants a series of high-level process questions (e.g., Are bottles blow molded on site?). Such questions provided a good starting point for mapping data trends (e.g., facilities with on-site blow molding operations had a higher average energy use ratio than those that do not blow mold bottles on site) and paved the way for further evaluation in future studies (e.g., evaluation of process efficiencies associated with on-site blow molding operations).

The Outcome: 2014 IBWA Benchmarking Study Results In November 2014, IBWA released the results of its second benchmarking study. This study represents 21.61 liters of bottled water production–more than half (56 percent) of the total U.S. bottled water consumption. That is a 20

The study by Antea Group found that bottled water has the lowest water use ratio and energy use ratio of all packaged beverages. percent increase in participation from the inaugural study. As mentioned previously, participants provided five years (2009-2013) of metrics data, and supplemental information such as facility type—small pack, home and office delivery (HOD), or mixed packaging; percent of final product packaged in refillable containers; use of cooling towers; and presence of on-site blow molding operations. The study identified the following five key takeaways. No 1. The 2013 water use ratio was 1.32 L/L—including the liter of product for consumption, and the 2013 energy use ratio was 0.24 MJ/L for North American bottled water facilities. Those ratios demonstrate a higher level of performance when compared to the global 2012


JAN/FEB 2015



Water Use Ratio (WUR)

the liters of water (including product water) used to make one liter of product.

The bottled water industry continues to make significant efforts to reduce water and energy use through process improvements and best practices.

five-year study period. These trends in water and energy use demonstrate that the industry’s investment in efficiency measures and process improvements are yielding positive results in water, energy, and cost savings, while the industry experiences sustainable growth. No 3. In general, bottled water facilities have the lowest water use ratio and energy use ratio when compared to other beverage sectors. On average, beverage sectors (such as carbonated soft drink bottling and beer production) have higher water and energy use ratios driven by higher intensity process unique to those other beverages, such as flavor mixing, blending, carbonation, and fermentation.

averages for bottled water facilities as reported by the BIER (1.46 L/L water use ratio, 0.27 MJ/L energy use ratio). The charts below present the water and energy use ratio trends over the five-year period: the columns represent the fixed data set (facilities that provided five full years of water or energy use data) and the lines represent the dynamic data set (facilities that provided any data over the five years of the study).

No 4. Facility-specific processes also drive differences in the magnitude of water and energy use ratios. For example, some small pack facilities have bottle blow molding operations on site, resulting in additional energy use and a higher energy use ratio for small pack facilities (0.25 MJ/L) compared to facility types where bottles are sourced from off-site blow molding operations (HOD facilities, 0.12 MJ/L).

No 2. Total production for the industry increased from 2009 to 2013, while total water use and energy use also increased. The water use ratio remained relatively flat, and the energy use ratio decreased 14 percent over the






1.00 1.35






0.00 16

0.40 1.35


















0.20 0.28










0.10 0.00


Energy Use Ratio (EUR)

the megajoules of total energy (electricity + fuel + heat) used to make one liter of product.

No 5. The North American bottled water industry continues to make significant efforts to reduce water and energy use through process improvements and best practices. The 2014 IBWA data collection workbook included a survey for participants to identify the top water stewardship and energy management initiatives implemented at their operations, as presented in the tables below.

The Payoff: Understanding Your Resource Use When you have addressed the aforementioned challenges and launch a benchmarking study, the results provide a holistic view of the operational resources that contribute to the generation of your final product. As IBWA has demonstrated in its benchmarking studies, this greater visibility

into the North American bottled water industry’s water and energy use has helped bottlers measure their efficiency progress, identify additional opportunities for improvement through evaluation of process drivers, and share best practices for resource conservation and cost savings. By evaluating the total package in this manner, you begin to quantify all that really goes into producing that bottle of water—and that will allow you to make sound sustainability investments resulting in savings to your business and a better final product for consumers. Laura Nelson, a sustainability consultant with Antea Group, managed the data collection, analysis, and report preparation for the 2014 IBWA Water and Energy Use Ratio Benchmarking Study. For more information on water and energy use benchmarking or other sustainability initiatives, contact Laura:



Improving performance and recovery in the reverse osmosis process.

Regular inspection, leak testing, and repair programs for compressed air and steam.

Optimizing washer units through automated timers, select cleaning chemicals, flow control, etc.

Optimized production schedules – minimize start up/shut down times.

Reducing filler overflow through system optimization.

Regular cleaning and inspection of HVAC systems.

Routing HVAC unit condensate to cooling tower.

Automatic/timed temperature controls.

Using chemical controls for zero discharge at on-site cooling tower.

Standard use of high-efficiency motors.

Maximize wastewater management through system optimization or non-product reuse.

Use of indoor/outdoor automatic light controls.

Source: Data collection for the 2014 IBWA Water and Energy Use Ratio Benchmarking Study

Use of energy efficient light fixtures. Individuals or teams who are responsible for energy management and efficiency initiatives. Comparison of metered energy data with energy invoices to ensure consistency in measurement. JAN/FEB 2015







On May 14, 2014, Blackhawk Molding, Inc., an IBWA supplier member headquartered in Addison, Illinois, participated in a city recycling event. Fifteen Blackhawk employees volunteered their time to help Illinois’ School and Community Assistance for Recycling and Composting Education (SCARCE) program, a nonprofit recycling and community organization. As director of operations at Blackhawk and co-chair of IBWA’s Environmental Sustainability Committee, I was thrilled that my company was able to be a part of this very successful event for our community. Although I had no idea how much effort it would take on our part to volunteer, I have to admit the reward of serving our community in this hands-on manner was well worth it.

How It All Started It was while working out at my gym in Addison that I first noticed a flyer promoting an event sponsored by





the Chamber of Commerce, a local state representative, SCARCE, and the Addison Park District to collect various household items for recycling and documents for shredding. This event represented exactly the type of opportunity members of the IBWA Environmental Sustainability Committee had discussed participating in to help promote the environmental stewardship of the bottled water industry. While those of us in the industry are aware of our long-standing history as a good steward of the environment, others are not. This community effort offered Blackhawk a chance to promote its environmental efforts in a positive way that also gave back to our community. It also provided an opportunity for our employees to learn more about recycling. What really interested me in this particular event was the range of items being collected and the numerous organizations involved.


Here’s a rundown of what was being collected: •

A local electronics recycling company was collecting various types of equipment—everything from TVs to computers to VCRs.

The Park District was collecting used lightbulbs.

A local business provided the funding to bring a mobile paper shredder to the event.

The local Veterans of Foreign Wars organization was collecting old flags.

The local Lions Club was collecting used eyeglasses and hearing aids.

The Addison Fire Department was collecting used medical equipment still in good working condition (e.g., crutches and wheelchairs).

A nonprofit, Working Bikes Cooperative, was collecting used bikes to repair and give to low income kids in the community.

SCARCE was collecting old and new crayons, buttons, zippers, and keys for a variety of different secondary uses.

JAN/FEB 2015



How Persistence Paid Off After the initial decision was made to participate, I thought getting involved would be easy: I’d make one phone call, organizers would be happy to learn of Blackhawk’s interest, we’d be given a time to arrive for the event, and that would be the end of it. Unfortunately, that wasn’t the case. First, I called the Addison Park District, leaving messages every time. I even stopped by its office, but to no avail. Next, I left several message for—and stopped by during lunch at—the local Chamber of Commerce before I was finally able to talk with the appropriate person. From that discussion, I learned the Chamber supported the event by providing advertising in the community, but it had no direct involvement. Unfortunately, my Chamber contact could not provide me with the name of someone directly involved. My third set of phone calls was to the participating state representative. Office staff there informed me that, although

they helped promote the event and the representative would be in attendance, they also had no direct involvement— and they also could not provide me with a contact who could help me with my volunteering request. Finally, when I reached out for the fourth time, this time to SCARCE, I scheduled a face-to-face meeting with the person in charge. SCARCE staff were excited about Blackhawk’s interest, but, because we are a part of the bottled water industry, they were, admittedly, a little skeptical about our sincerity. And honestly, convincing them that we just wanted to help—that we did not “want” anything in return—was the biggest obstacle to overcome. During that initial meeting with SCARCE, my objective was to make sure they understood that the only thing either I or Blackhawk wanted was a chance for our employees to volunteer at the event and show our commitment to the community. Only after we established ourselves as truly committed

7 STEPS TO IMPROVE RECYCLING IN YOUR WORKPLACE Step 1: Form a green team and set goals. Step 2: Review your current waste disposal contract and waste collection system. Step 3: Identify what can be recycled and conduct a waste sort. Step 4: Research and select a recycling and/or food waste composting company. Step 5: Plan and implement your internal recycling collection system. Step 6: Educate your employees. Step 7: Track your success and maintain the momentum. Source:




to the cause did I suggest that we would be interested in supplying on-site promotional banners indicating that IBWA was a supporter of the event. I learned SCARCE was in charge of assigning participating groups donation areas to work and for organizing the volunteers from some of the local middle schools. I also learned that for Blackhawk’s request to volunteer to be accepted, we needed to speak with the Park District employee who was actually in charge of the entire event. Thankfully, after an introduction from Kay McKeen, founder and executive director of SCARCE, to Geri Estvanik, development and community relations manager of the Addison Park District, I was able to ensure that our request to volunteer was accepted. While it sounds like a lot of legwork, I believe my experience is typical of the effort a company has to put forth to volunteer in its community. You have to understand that people might not return your calls because they are trying to figure out if you or your company has an “angle.” Sadly, it might just be human nature to be suspicious and wonder, Why do they want to participate? What’s in it for them? It wasn’t until I was able to sit down with McKeen and Estvanik did they truly understand: we just wanted to volunteer.

How to Ask for External Buy-in I had been in contact with IBWA staff throughout this entire process, and, as IBWA was holding its 2014 Winter Board and Committee Meetings soon, I felt the time was right to make a formal presentation before the Environmental Sustainability Committee to update members on Blackhawk’s progress. During that face-to-face meeting, I explained what we planned to do, and I wanted to make sure everyone on the committee was comfortable with


our volunteer plans. I also used this opportunity to successfully solicit a volunteer to donate bottled water for the event. Committee Member Mark Lindblom (Premium Waters) donated 25 cases of bottled water for the SCARCE recycling event. Being able to provide volunteers with free bottled water was just another way we could promote a positive image of bottled water and IBWA to our community.

Premium Waters donated bottled water for the SCARCE volunteers.

World Water Day: March 22 Earth Day: April 22 Arbor Day: April 24 World Environment Day: June 5 America Recycles Day: November 15

How to Get Internal Buy-in The recycling event was set, Blackhawk was given the thumbs up to volunteer, IBWA was on board with the plan, and I had secured donated bottled water to hand out to volunteers. What I needed now were Blackhawk employees who wanted to participate. Initially, we posted a flyer at the office asking for volunteers and included a sign-up sheet, but only a few employees signed up. We started asking around to determine why there was so little interest. What we learned was that the recycling event was being held on a holiday weekend for the MexicanAmerican community, and some of our employees were worried that they would have to invest too much time to participate, which would take away time from their families. After we explained the limited time frame involved (about 2.5 hours) and that several managers had already volunteered, more than a dozen employees signed up. It seems the little extra effort to personally explain the details—and again, to let people




for good.

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JAN/FEB 2015



AT THE END OF THE DAY, WE RECYCLED MORE THAN FIVE TONS OF PAPER WASTE AND COMPLETELY FILLED A HUGE METAL DUMPSTER WITH ELECTRONIC WASTE. know there were no ulterior motives— motived more employees to devote time to community service.

through, donating electronic waste, bikes, prescription bill bottles, and paper for shredding.

How to Have a Successful Event

I was stationed at the mobile shredding truck, which included a 55-gallon dumpster into which people tossed their private, old, or personal documents. The truck would then lift the dumpster up to the shredder; people could watch, via closed circuit TV, their papers being shredded. Because the shredder was the most popular station, the local state representative also volunteered here, conducting meet-and-greets with her constituents. For me, it was a great opportunity to get to know her and for her to get to know a little more about Blackhawk, a company in her district.

Blackhawk employees were asked to arrive 30 minutes before the event started to receive basic training on each of the recycling stations and for organizers to ensure they had enough workers at each station. Weather wise, the day was perfect. This was a drivethru event, and people started lining up early, almost 30 minutes before we were ready to accept donations. From the time the event opened until about 15 minutes after it closed, we had a constant stream of cars. The sponsors estimated that nearly 300 cars drove

A COMMUNITY ENGAGED The City of Austin, Texas, has a goal to keep 50 percent of its trash out of landfills by December 2015. City residents can make progress toward that goal by recycling 5 pounds more each month per household. To spur Austin residents into action, the City of Austin and Austin Resource Recovery (ARR) is localizing Keep America Beautiful’s “I Want To Be Recycled” PSA campaign across the city. The City and ARR are distributing campaign educational materials to schools and other civic organizations, and they are working closely with Keep Austin Beautiful to educate and motivate Austin residents to give their garbage another life by recycling. For more on Keep America Beautiful’s “I Want To Be Recycled” campaign, turn to page 6.




During the lunch break, volunteers enjoyed the Premium Waters-donated bottled water with our sandwiches. In addition to the recycling event, the Addison community had about 200 middle school students working throughout the Park District conducting some fall cleaning and landscaping tasks. Those students returned to the main Addison Park District Office to share our lunch space—and we were able to share with them the donated bottled water. At the end of the day, we recycled more than five tons of paper waste and completely filled a huge metal dumpster with electronic waste. In addition, we collected about two dozen bikes (which are being repurposed), eyeglasses, medical equipment, shoes, prescription medicine, and more. To commemorate the event, we gathered all the Blackhawk employee volunteers together for a photo (including a few of the employees’ children who also helped out). We now prominently display that photo in the company’s main production meeting room. My personal favorite memory of the day occurred when a nice lady stopped me and asked, “Are you the one with the van that can get my TV from my house?” This certainly wasn’t part of the “plan,” but I gladly followed this lady to her house and loaded up her old and very heavy TV (and it gets heavier every time I tell this story) and brought it back for recycling.


Participating at this SCARCE recycling event proved to be a positive experience for all the Blackhawk volunteers. The feedback Blackhawk management received indicates that we will have no issues getting plenty of volunteers for this year’s event.

How the Community Reacted The Addison Park District was so happy with Blackhawk’s support that it invited us to come to its next monthly board meeting to receive a certificate of appreciation from the community. That meeting was attended by many of the employee volunteers, plus Blackhawk President Douglas Hidding and Vice President Bob Hidding, which further added to the sense of pride for our employees and enhanced the relationship between our community and Blackhawk.

The Blackhawk Crew of Volunteers: (from left) Cristina Alonzo, Claudia Santoyo, Iliana Velazquez, Jose Torres, Terry Cavanaugh, Yolanda Mora, Josefina Limon, Jeff Davis, Jacqueline Limon, Enrique Torres, Butch Fellows, and Roberto Castro. Not pictured Tom Urie.

Jeff Davis is director of operations at Blackhawk Molding, Inc. and co-chair of IBWA’s Environmental Sustainability Committee.

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JAN/FEB 2015



Have You Talked With Your Newly Elected Member of Congress Yet? By James Toner, IBWA Director of Government Relations

In 2014, IBWA staff and members held nearly 200 meetings with members of Congress and their staff on Capitol Hill. We will again need to meet with elected officials at state capitols and in Congress to continue educating them about bottled water industry issues and asking for their support of the Bottled Water Quality Information Act (H.R. 4978), landmark legislation that would make it easier for consumers to obtain clear, consistent, and comprehensive information about the bottled water products they buy. 24



But following the 2014 elections, there have been several changes in Washington, DC. Whether you call it the actions of a frustrated electorate or just the usual party in power losing seats during a volatile midterm election, there is no doubt that Republicans made great gains. Because Washington lawmakers need to understand the challenges facing the bottled water industry, IBWA encourages members to become acquainted with all of their elected officials. Following are a few of the interesting stories from election night 2014.

U.S. Senate After winning several states, Republicans garnered majority control of the Senate, now holding 54 of the 100 seats. Incumbent Democrats faced strong challenges from Republicans in several states, ultimately losing after months of back-and-forth polling. In Arkansas, Representative Tom Cotton (R), who held a significant lead in the polls since the early part of summer 2014, defeated incumbent Democrat Mark Pryor. In Colorado, incumbent Mark Udall (D) lost to Representative Cory Gardner (R) in what was viewed as one of the

GOVERNMENT RELATIONS closer contests for a Senate seat. Many conservative election watchers saw this as a major victory in a state that was considered a major coup for the Obama campaigns of 2008 and 2012. Senator Kay Hagan (D) battled neck-and-neck with businessman Thom Tillis (R), but she was unable to hold on to her North Carolina seat (even with Libertarian candidate Sean Haugh pulling in nearly 4 percent of the vote). As a final blow, during a runoff election on December 6, 2014, Louisiana voters ultimately selected Republican Congressman Bill Cassidy over incumbent Democrat Mary Landrieu. In Iowa—traditionally a red state that the Democrats won in the last two presidential campaigns—Joni Ernst (R) defeated Congressman Bruce Braley (D). This race was a virtual tie coming into election night. However, Ernst’s campaign far exceeded predictions, and she won by 8.5 percentage points. Ernst becomes the first female senator from Iowa. Open Senate seats went almost exclusively to the Republicans with wins in Georgia, Montana, Nebraska, Oklahoma, South Dakota, and West Virginia. Only in Michigan did Democratic Congressman Gary Peters defeat Michigan Secretary of State Terri Lynn Land (R). The only hotly contested seat Democrats were able to hold on to was New Hampshire, where Senator Jeanne Shaheen (D) fought back former Massachusetts Senator Scott Brown (R) to retain her seat.

U.S. House of Representatives Republicans were able to increase their majority in the House; they now hold 244 seats to the Democrats’ 186. One newsworthy story was Mia Love, the first African-American Republican woman—and the first Haitian-American—elected to Congress. Another race of note took place in North Carolina’s second district, where Representative

Renee Ellmers (R), sponsor of IBWA’s Bottled Water Quality Information Act (HR 4978), handily defeated her challenger, former American Idol runner up, Clay Aiken (D).  

SCHEDULED IBWA HILL DAYS FOR 2015 • Wednesday, January 28 • Wednesday, February 25


• Tuesday, March 17

Already holding a large lead in the gubernatorial numbers, Republicans picked up several seats in 2014, including a few major surprises. The one swing for Democrats was in Pennsylvania, where Tom Wolf (D), who led in all major polls well before election day, beat incumbent Republican Tom Corbett. In the governor races, we saw some major upsets. Republicans won in Illinois, Maryland, and Massachusetts, and held the competitive states of Florida, Georgia, Kansas, Maine, and Wisconsin. In an outcome few predicted, Republican Larry Hogan defeated Lieutenant Governor Anthony Brown (D) in the strong blue state of Maryland: winning by 9 percentage points. While it’s not unusual to have a Republican Governor in Massachusetts (William Weld, Paul Cellucci, and, most recently, Mitt Romney), most expected a tight race between GovernorElect Charlie Baker, a former Secretary of Administration and Finance under Weld and Cellucci, and Attorney General Martha Coakley (D), who had previously run a weak campaign for the U.S. Senate seat that was occupied by the late Teddy Kennedy (D), losing to Scott Brown (R). A victory for Governor Rick Scott (R) in Florida made opponent and former Governor Charlie Crist (D) a three-time loser for the top seat in the state: once as a Republican, once as an Independent, and once as a Democrat.

• Tuesday, April 28 • Wednesday, May 20 • June Hill Days – June 1-4 (during IBWA Board and Committee Meetings) • Wednesday, July 22 • Tuesday, September 29 • Tuesday, October 20 • Wednesday, December 2

switches that may ultimately benefit the bottled water industry. Those include the following chambers that went from Democratically-controlled or tied to a Republican majority: Maine Senate, Minnesota House, New Hampshire House, New York Senate, and Washington Senate.

The Importance of Education Knowing the names of your elected officials and how they came to be elected isn’t beneficial if you don’t work to get to know them. By far the most important meetings for IBWA are the ones members have with elected officials. We encourage all IBWA members—big, medium, and small—to start planning now to join us in 2015 as we continue vital work to ensure our messages are heard and understood by those in positions of influence.

State Legislatures Although not expected to see much change during the 2014 midterm, several state legislatures experienced key JAN/FEB 2015



Why and How to Share Bottled Water’s Positive Environmental Sustainability Story By Chris Hogan, IBWA Vice President of Communications 26



Last year, the bottled water industry was in the middle of a potentially volatile environmental debate. With California facing one of the most prolonged droughts in its recent history last fall, an article claiming that bottled water was a direct contributor to the state’s environmental crisis was released by a consortium of influential media outlets, led by the nonprofit news organization Mother Jones. The story leveled numerous false charges at the bottled water industry: we’re an irresponsible manager of groundwater resources, we deplete groundwater supplies, we ship vast quantities of water out of state. All nonsense. IBWA responded quickly, issuing a press release that provided the facts about bottled water’s minimal use of groundwater (less than 0.02 percent of the total U.S. groundwater withdrawn each year), participating in interviews, and updating our social media accounts with the facts. We stated clearly that the bottled water industry was not responsible for California’s drought and that much of what was claimed in the Mother Jones’ story was false and misleading. To put everything into perspective, we made sure to mention that the entire U.S. bottled water market of 10 billion gallons equals the amount of tap water Los Angeles goes through in less than three weeks. We also created and distributed a map illustrating that IBWA member bottling plants are located throughout the United States, making use of local water sources to meet the hydration needs of regional consumers. IBWA’s map successfully debunked its misleading counterpart from the Mother Jones’ article, which falsely inferred that most bottled water sources are in California. During a live interview with The Weather Channel, we shared our map, easily highlighting Mother Jones’ errors. Then, something amazing happened. Other media outlets, including national

COMMUNICATIONS news organizations, began to dispute the “bottled water contributes to drought” storyline. With relative swiftness, the media’s focus shifted to other legitimate issues concerning the state’s drought crisis.

Time for a Plot Twist The above communications success story offers just one example of how, although bottled water consumption continues to increase, the media insists on pushing the storyline that our industry is an environmental bad guy. For every positive story about bottled water helping consumers make healthy beverage and lifestyle choices, there are numerous newspaper headlines, magazine articles, blog posts, or social media stories excoriating our industry about one thing or another. Well, it’s time for a plot twist. Beverage Marketing Corporation predicts that by 2016 bottled water will surpass carbonated soft drinks as the No. 1 packaged beverage on the market. And for good reason: We provide one of the healthiest package beverage options on the retail shelf. From an environmental sustainability standpoint, when people choose bottled water instead of any other canned or bottled beverage, they are choosing less packaging, less energy consumption, and less use of natural resources. Which, honestly, makes for a great story. If someone is going to promote the positive stories about bottled water, it will have to be you, IBWA members. Here’s how: Correct misinformation in print. For example, when you see a story in your local newspaper stating erroneously (as these stories often do) that recycling rates for bottled water containers range between less than 10 percent to no more than 20 percent, correct them. Let the journalist and newspaper editor know that they’ve made an error and have done a disservice

IT IS UP TO US TO PROMOTE THE POSITIVE STORIES ABOUT BOTTLED WATER. to their readers. Write the editor a letter to let her know that the recycling rate for single-serve PET plastic bottled water containers (38.04 percent) has more than doubled between 2003 and 2012. Inform her of the fact that bottled water bottles are the most frequently recycled PET beverage container in curbside recycling programs. Correct misleading information online. The blogosphere is flooded with incorrect “facts” about bottled water. To combat false or misleading information on the Web, it will take an army of well-informed IBWA members posting comments daily to muffle the bullhorn of anti-bottled water activists. If you read an online article that mistakenly suggests that bottled water containers are not recyclable, correct them. Post a comment containing the facts: All bottled water containers are 100-percent recyclable and should be recycled. Then educate them. Inform the blogger (and all of his or her readers) that when you recycle any plastic beverage container you are supporting good business. Because you are an informed bottled water professional, you can tell them about how a domestic PET recycling industry exists in America that employs 462,000 people. You can also let them know that industry needs more raw material to make recycled PET (rPET). Due to the popularity of rPET products, demand is currently outstripping supply. Thus, a continued focus on increased recycling is important for everyone—those concerned about the environment and those concerned about American businesses.

If you are unable to respond due to the pressures of other business, don’t hesitate to contact IBWA. We’ll be happy to contact the publication’s editor and author and share bottled water facts with them. Meet with your elected officials. Educating lawmakers about the bottled water industry is incredibly important. How do you impress upon local and national decision makers the challenges the industry faces? You meet with them. Here’s how we can help. IBWA staff can set up appointments for you during one of our Capitol Hill Days in 2015. We’ll provide you with background information and even attend meetings with you—whatever you need to make this experience easy and successful. (Read this issue’s Government Relations column to learn about IBWA’s scheduled Hill Days for 2015.)

One Message, Many Voices Combatting falsehoods, unsupported statistics, and imagined conspiracy theories is a huge undertaking. But the importance of promoting bottled water facts supersedes all that. If erroneous information goes unchallenged, the industry suffers. Had IBWA not fought back as aggressively as we did about the misinformation concerning the terrible drought that hit the West Coast in 2014, you can be sure that critics would still be blaming us well into 2015 and beyond. It’s up to IBWA staff and members— small, medium, and large—to tell bottled water’s story, get out the facts, and respectfully engage with those who oppose bottled water.

JAN/FEB 2015



FSMA Proposed Rules: Take Two

FDA publishes supplemental proposed rules for preventive controls and FSVPs By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations For those of us working on the technical side of the bottled water industry, the 2013 releases of the Food Safety Modernization Act (FSMA) proposed rules for preventive controls and foreign supplier verification programs (FSVPs) were exciting. Now, we’ve got even more to look forward to: the U.S. Food and Drug Administration’s (FDA) latest releases. FDA has decided that the preventive controls and FSVPs rules will have sequels (known as “supplemental proposed rules”). These supplemental rules serve two purposes: (1) to modify several areas in the original proposed rules that, through stakeholder comments received, FDA 28



found needed modifications, and (2) to complete the sections of the original proposed rule that FDA left incomplete (e.g., sections on product testing and environmental monitoring) and elected to request comments from stakeholders. The rule that will impact domestic bottlers—the supplemental proposed rule for preventive controls—is discussed below. It should be noted up front that one portion of the original proposed rule will remain unchanged from its original version: the section on Current Good Manufacturing Practices (CGMPs). FDA has retained the original content for its final cut, with no edits.

So, what did FDA add or change in the preventive controls rule?

From Foreseeable Hazards to Significant Hazards FDA has redefined the hazards to be identified during a hazard analysis. Previously referred to as “known or reasonably foreseeable hazards,” the term FDA will now use is “significant hazards.” One must also assess the severity of the illness or injury should such a hazard occur, and the probability that the hazards will occur in the absence of preventive controls. Readyto-eat (RTE) foods must also assess

TECHNICAL UPDATE hazards associated with environmental pathogens when the food is exposed to the environment before packaging.

Preventive Controls Details The detail FDA provides concerning preventive controls is more specific, which is another change from the original proposed rule. The supplemental proposed rule lists types of preventive controls, including the following: • Process controls: procedures, practices, and processes to ensure the control of parameters during operations such as heat processing, acidifying, irradiating, and refrigerating foods. • Food allergen controls: procedures, practices, and processes to control food allergens. Food allergen controls must include those procedures, practices, and processes employed for ensuring protection of food from allergen cross-contact, including during storage and use and labeling the finished food, including ensuring that the finished food is not misbranded under section 403(w) of the Federal Food, Drug, and Cosmetic Act. • Sanitation controls: procedures, practices, and processes to ensure that the facility is maintained in a sanitary condition adequate to significantly minimize or prevent hazards such as environmental pathogens, biological hazards due to employee handling, and food allergen hazards. • Supplier controls: includes the supplier program now required (detailed below). • Recall plan: must now address hazards identified in the facility’s hazard assessment. • Other controls: any other procedures, practices, and processes necessary to adequately control hazards at critical control points (CCPs) and at other points in the process that are necessary to assure the safety of the product. Examples of other controls include hygiene training and other current good manufacturing practices.

WHAT DID FDA ADD OR CHANGE IN FSMA’S PREVENTIVE CONTROLS RULE? Addition of New Supplier Program Perhaps the most significant change to the original proposed rule was the addition of a new section on supplier programs. IBWA member facilities must now establish and implement a risk-based supplier program for those raw materials and ingredients for which they have identified as a significant hazard when the hazard is controlled by the supplier before receipt of the raw material or ingredient by the bottling (receiving) facility. In short, IBWA bottlers must identify the measures in place at supplier facilities that serve as preventive controls for hazards to their bottled water products. This would include suppliers of mineral salts, containers, closures, and resins for the bottled water industry. If you purchase water intended for bottling from an independent supplier, you will also need to consider that supplier’s hazards. For two years, IBWA’s supplier members have been asking how they will be affected by FSMA, and how they may support our bottler members. As a result of these new FSMA rules, we now know, and IBWA will provide training for supplier members in 2015.

Corrective Action Details The supplemental proposed rule for preventive controls also addresses corrective action in more detail, including corrective action in the event of an unanticipated food safety problem. Food processors are responsible for verifying all aspects of their food safety program, and those responsibilities are

now explained in great detail in the supplemental proposed rule. Thus, facilities will now be required to write and implement verification activities such as the following: • calibration of process monitoring instruments • product testing • environmental monitoring • records reviews. With regard to product testing and environmental monitoring, IBWA anticipates that these rule provisions will have minimal impact on the bottled water industry, as we already have one of the most extensive product testing programs in the food industry. FDA will also likely acknowledge that our current container and closure testing program will suffice as a suitable environmental monitoring program because, in a closed system, containers and closures are the only materials exposed to the environment in the bottling process. Because the supplemental proposed rule addresses only parts of the original proposed rule that have been added or modified, all previously identified requirements remain as part of the current proposed rule. Watch for IBWA educational sessions at a state and regional meeting venue near you in 2015 for more information on the preventive controls rule.

JAN/FEB 2015





certified plant operators (CPOs) are encouraged to complete the following quiz for ½ IBWA continuing education unit (CEU). The questions are derived from material presented in this issue of the Bottled Water Reporter, the IBWA Plant Technical Reference Manual, and the IBWA Bottled Water Code of Practice. Submit this quiz to Claire Crane, IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22134. Look for additional quizzes in future issues and earn additional IBWA CEUs!

Name______________________________________________________ Company__________________________________________________ Address____________________________________________________ City_______________________________________________________ State/Province______________________________________________

ZIP/Postal Code____________________________________________

Check your selection for each question


FSMA addresses _____ foods specifically and repeatedly in most of the proposed rules as they are considered to be associated with higher risk.


raw ready to eat (RTE) multi-component (MC) fast


Which of the following proposed rules under FSMA was recently re-proposed as a “supplemental” proposed rule?


Intentional Adulteration Produce FSVP Sanitary Transportation


Which two food programs are addressed in the IBWA Bottled Water Code of Practice?


HACCP Safe Food Transportation Current Good Manufacturing Practices OSHA Health and Safety


_____ must not be under the direct influence of surface water as defined at 40 CFR §141.2.


spring artesian around all of the above


IBWA requires every member bottling facility to have the following, except _____.




recall plan HACCP plan food defense plan business plan



The supplemental proposed rule for preventive controls includes new requirements for supplier verification.

OO True OO False


Which of the following is not a form of verification under FSMA?


product testing environmental monitoring records reviews routine checks on employee health


Natural source waters (i.e., springs, artesian wells) must be tested _____ for radiological contaminants.


annually quarterly every 4 years every 3 years


Which of the following is a disinfection byproduct that is regulated by FDA?


vinyl chloride haloacetic acids tetrachloroethyelene chlordane


Methoxychlor is a _____.


volatile organic chemical inorganic chemical semivolatile organic chemical synthetic organic chemical

ADVERTISERS Analytical Technology Inc. . . . . . . . . . . . . . . . . . . 5 Blackhawk Molding Co. . . . . . . . . . . . . . . . . . . . .3 Crystal Mountain Products . . . . . . . . . . . . . . . . . . 10 Edge Analytical . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Eurofins . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 National Coffee Service & Vending . . . . . . . . . . . . . . . 11 Pacific Ozone Technology . . . . . . . . . . . . . . . . . . . . . 21 Sidel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C3 Steelhead . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C4 Tech-Long . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C2


IBWA Winter Board of Directors and Committee Meetings Mayfair Hotel Coconut Grove, FL

MARCH 4 - 6

Mid America Bottled Water Association Annual Convention & Trade Show Wyndham Garden San Antonio River Walk San Antonio, TX

MARCH 11 - 13

Central States Bottled Water Association Spring Education Conference St. Louis, MO

MARCH 18 - 20

Southeastern Bottled Water Association Annual Convention & Trade Show Young Harris, GA

MARCH 27 - 28

Northeast Bottled Water Association Spring Conference Mystic Hilton Mystic, CT

APRIL 16 - 18

South Atlantic Bottled Water Association Spring Event Pawleys Island, SC

MAY 6 - 8

Upper Midwest Bottled Water Association Annual Meeting Plymouth, MN

MAY 13 - 16

Northwest Bottled Water Associatoin Convention Hotel Murano Tacoma, WA

JUNE 1 - 4

IBWA June Board of Directors and Committee Meetings Hilton Old Town Alexandria, VA

CALENDAR 2016 JUNE 6 - 9

IBWA June Board of Directors and Committee Meetings Hilton Old Town Alexandria, VA

JAN/FEB 2015



VALUE OF IBWA MEMBERSHIP COLLINS SPEED PUGH DIRECTOR OF MARKETING MOUNTAIN VALLEY SPRING COMPANY ALL ABOUT COLLINS Born and raised in Arkansas, and the daughter of an avid duck hunter, Collins loves to duck hunt with her dad when she travels home. When Collins is not working, she says she is usually chasing her 16-month-old daughter, Frances, around the house. Prior to joining Mountain Valley, Collins worked for Anheuser-Busch on a National Special Events Team.

Social media savvy members may be aware of IBWA bottler member Mountain Valley Spring Water Company’s success with engaging in the ever-expanding social network arena. Much of what they’ve achieved is largely due to the company’s Director of Marketing Collins Speed Pugh. Since joining her dad, Breck Speed, at Mountain Valley in 2008, Pugh has grown the company’s social community to reach thousands of customers and fans. Pugh says she sees clear value in her company’s IBWA membership. “Networking with other bottled water companies, suppliers, and industry members is one of the main reasons we are members of IBWA,” Pugh says. “Most of our suppliers are fellow IBWA members.” Other membership perks include continued learning through IBWA’s educational session offerings and keeping up-to-date with the latest bottled water trends. “Without IBWA keeping us informed, I don’t know how we’d be able to do this ourselves.” As an example, Pugh points to the latest rules on environmental marketing claims released by the Federal Trade Commission. IBWA prepared a “Green Guides” document, which delineated the new rules and became a vital piece of information to help members understand them. Pugh says non-IBWA members should consider membership so that they too have access to resources to help fight against negative legislation that affects the bottled water industry. “We appreciate all of the hard work IBWA has done on our behalf,” she says. Active members will tell new members that one way to get great value from their IBWA memberships is to participate on committees—either by becoming a committee member or by attending meetings and contributing to the discussions. Pugh is an active member of IBWA’s Communications Committee. Reflecting on the bottled water industry in recent years, Pugh says she feels like we’re reaching a tipping point: “Consumers are more interested in the clear benefits of drinking water versus the environmental and tap water substitute concerns.” Marketed as “America’s Premium Water Since 1871,” Mountain Valley Spring Water is the oldest continuously operated bottled water company in the United States. The company was started by a pharmacist, Peter Greene, and his brother. People continue to drink Mountain Valley today because of its high pH and naturally occurring minerals such as calcium, magnesium, potassium, and zinc. Mountain Valley continues to bottle natural spring water in glass at the original spring source near Hot Springs, Arkansas. The company is one of only a few that still deliver 2.5 and 5 gallon returnable glass bottles to their customer’s doorsteps.






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One Operator Bottling Systems: 150 – 350 bph 5 Gallon Systems

Water Treatment: RO, Mineral Injection, Ozone

Check with us for pre-owned options

Full Plants: Turnkey Solutions for Every Size


High Speed Bottling Systems: 450 – 3000 bph 5 Gallon Systems




All bottling processes are not equal. Steelhead stands alone with our commitment ommitme ent ients. to innovation, efficiency and bottom line profitability for our clients.


Bottled Water Reporter  

Environmental Sustainability Issue January/February 2015

Bottled Water Reporter  

Environmental Sustainability Issue January/February 2015