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


ALSO IN THIS Meeting With Legislators on Your Turf

ISSUE How the Industry Is Thinking Ahead on Environmental Issues

IBWA’s Thoughts on FDA’s Proposed CGMP/ Preventive Controls Rule


ENVIRONMENTAL STEWARDSHIP IN ACTION Use IBWA’s Water Use Ratio Benchmarking Study to Identify Efficiencies Within Your Plant

ALSO INSIDE What You Need to Know About FTC’s Green Guides


VOL. 54 • NO. 1


22 | Home Sweet Home: Meetings on Familiar Turf You’ll be more at ease when discussing industry issues with legislators when you have home field advantage. COMMUNICATIONS

24 | An Industry Thinking Ahead About Environmental Issues The bottled water industry’s low water use ratio is just another example of our environmental stewardship efforts. TECHNICAL UPDATE

26 | What IBWA Thinks of FDA’s Proposed CGMP and Preventive Controls Rule IBWA encourages FDA to maintain rules that are risk-based and promote food safety but discourages requirements that are prescriptive. VALUE OF IBWA MEMBERSHIP

32 | Certified Excellence Felix Graham-Jones (Berkshire Springs Inc.) praises IBWA’s educational offerings, which help all members—especially the smaller ones.

DEPARTMENTS CHAIRMAN’S COMMENTARY................................2

TABLE OF CONTENTS 10 | Environmental Stewardship in Action: Water Use Ratio Benchmarking Beverage industry professionals, especially those in the bottled water industry, understand the importance of clean, reliable water sources. In October 2013, IBWA published the results from its inaugural Water Use Ratio Benchmarking Study as a first step toward understanding the impacts of water use in the North American bottled water industry. The study evaluated how bottling facilities use water and recognize process efficiencies over time, and BWR provides the results here. By Laura Nelson

16 | What You Need to Know About FTC’s Revised Green Guides Consumers respond positively to marketing that touts a product’s environmental benefits. If your advertising makes any environmental claims, you’ll want to make sure you understand the revised “Green Guides” published by the Federal Trade Commission (FTC). This article explains FTC’s view on deceptive advertising. By Brian Eyink

PRESIDENT’S MESSAGE.......................................4 WATER NOTES.....................................................6 BONUS 2013 IBWA CONFERENCE COVERAGE...............................8 CEU QUIZ..........................................................30 ADVERTISERS.COM............................................31 CALENDAR........................................................31 CLASSIFIEDS.....................................................31


BOTTLED WATER REPORTER, Volume 54, 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.


Let’s have a conversation about what is happening to the bottled water industry and what options we, as an Association, have for the future. IBWA’s mission has traditionally been that of communicating, advocating, defending, setting standards, and inspecting facilities for our members. But in the 25 years of my involvement, I have also seen a lot of change. When I got started in the water business in 1988, there were hundreds of small and mid-sized bottled water companies. The average per capita consumption of bottled water was only 1.2 gallons. Home and office delivery (HOD) sales made up over 80 percent of sales volume by gallons, and PET plastic was just beginning to be explored as a packaging material. Today, the per capita consumption of bottled water is over 31 gallons; HOD sales have grown in dollars but are down to less than 15 percent of total sales volume; and retail sales now make up the vast majority of sales. And all those hundreds of individual bottled water companies that existed in the 80s and 90s? They’re gone. Today, our Association may have fewer members, but the ones we do have are much bigger; they support us financially and their associates are actively involved in the work of IBWA. And because the Association is fairly healthy, this is a really good time to talk about what IBWA needs to do to serve well our membership going forward. Here are three basic options as I see them: 1. We can remain focused on bottled water only. In doing so, there may come a time in the near future, as a result of less financial resources from fewer members, we may need to slim down our mission and forgo stuff like inspections or consumer outreach. 2. We could ally with another, larger association, and our new mission could be that of an inside advocate for the water segment. This option may be difficult to implement as we are sometimes on opposite sides of a particular issue (e.g., extended producer responsibility or taxation). 3. We can open our tent of our Association and expand IBWA’s membership to include the “good for you” or “healthy” beverage categories. The buzz in this arena reminds me of the mojo of the bottled water business 20 years ago, when there were lots of new entrants with big plans and lots of energy. I think everyone would agree it’s better to manage change instead of simply being managed by change. Please know that the Association that seeks to serve you will benefit greatly by your participation in this discussion. It is a great honor to serve as the 2014 chairman of the International Bottle Water Association, and thanks in advance for getting engaged in this conversation.


International Bottled Water Association OFFICERS Chairman Breck Speed, Mountain Valley Spring Company, LLC Vice Chairman Dave Muscato, Nestlé Waters North America Treasurer Bryan Shinn, Shinn Spring Water Company Immediate Past Chairman William Patrick Young, Absopure Water Co., Inc.

BOARD OF DIRECTORS Joe Bell, Bell Sales, Inc. Page Beykpour, CG Roxane Dan Bush, IGO Direct Premium Water Coolers Philippe Caradec, Danone Waters of America Tom Harrington, DS Waters Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Dave Holdener, Nicolet Forest Bottling Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Dave Muscato, Nestlé Waters North America Greg Nemec, Premium Waters, Inc. Chris Saxman, Shenandoah Valley Water Co. Bryan Shinn, Shinn Spring Water Company Robert Smith, Grand Springs Distribution Breck Speed, Mountain Valley Spring Company, LLC Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chairman, Breck Speed, Mountain Valley Spring Company, LLC Stewart Allen, DS Waters Joe Bell, Bell Sales, Inc. Philippe Caradec, Danone Waters of America Henry R. Hidell, III, Hidell International Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Dave Muscato, Nestlé Waters North America Chris Saxman, Shenandoah Valley Water Co.

COMMITTEE CHAIRS Communications Committee Jane Lazgin, Nestlé Waters North America Stephen Tischler, National Testing Laboratories Education Committee Glen Davis, Absopure Water Co., Inc. Bryan Shinn, Shinn Spring Water Company Environmental Sustainability Committee Philippe Caradec, Danone Waters of America Jeff Davis, Blackhawk Molding Co. Government Relations Committee Shayron Barnes-Selby, DS Waters Gene Belcher, Misty Mountain Spring Water, LLC Membership Committee Allen French, Edge Analytical Kelley Goshay, DS Waters State and Regional Associations Committee Joe Cimino, ChoiceH2O Ross Rosette, H2Oregon Supplier and Convention Committee Brian Grant, Pure Flo Water, Inc. Dan Kelly, Polymer Solutions International Technical Committee Andy Eaton, Eurofins Eaton Analytical Kevin Mathews, Nestlé Waters North America













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

PRESIDENT’S MESSAGE IMPROVING PERCEPTIONS WITH FACTS I was browsing through a few old issues of Bottled Water Reporter recently and noticed an article citing the need to take care of our water resources to meet the demands of the growing metropolitan communities. That was from 1968. While our critics might find it surprising that the bottled water industry has such an established, long-standing record of concern about environmental issues, it comes as no revelation to us. In 2013, IBWA took another step forward in illustrating the industry’s environmental stewardship when we announced the results from our inaugural Water Use Ratio Benchmarking Study. Conducted by Antea Group, an independent consultant, the study shows that at 1.39 liters per liter (L/L) bottled water has the lowest water use ratio of any packaged beverage. According to a Beverage Industry Environmental Roundtable (BIER) study, carbonated soft drinks, in comparison, have a water use ratio of 2.02 L/L. In “Environmental Stewardship in Action: Water Use Ratio Benchmarking,” (p. 10) Laura Nelson presents the study’s results and reviews Antea’s research process. (In our Communications column, we continue the discussion of IBWA’s Water Use Ratio Benchmarking Study and offer suggestions on how you can share the bottled water industry’s good environmental story with consumers, legislators, and the media.) In “What You Need to Know About FTC’s Revised Green Guides,” (p. 16) Bottled Water Reporter delivers an article that might best be described as a “green” advertising tutorial. First presented as part of an educational session at the 2013 IBWA Annual Business Conference last November, this article reviews the latest Green Guides updates and presents how FTC provides manufacturers with information concerning any product environmental claims they might make when marketing their products. We turn our attention to how best to educate elected officials about the bottled water industry in our Government Relations column—and propose that there’s no place like home for feeling comfortable while discussing tough topics with legislators. And finally, our Technical column presents what IBWA thinks of FDA’s proposed Current Good Manufacturing Practice (CGMP) and preventive controls rule. In short, we urge FDA to maintain rules that are risk-based and promote food safety, and we discourage requirements that are prescriptive. I hope that you can use the information presented in this issue of Bottled Water Reporter to help you educate consumers and opinion leaders about the bottled water industry’s environmental record. Working together—with facts and data—we can improve some of the inaccurate perceptions of the industry.

Joe Doss IBWA President





International Bottled Water Association 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 Government Relations Vacant Vice President of Communications Chris Hogan Chief Financial Officer Michelle S. Tiller Director of Conventions, Trade Shows, and Meetings Michele Campbell Director of Science and Research Tamika Sims Director of Government Relations J.P. Toner 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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The 2011 water use ratio for North American water bottlers was 1.39 L/L; for comparison, carbonated soft drinks’ was 2.02 L/L. Sources: 2013 IBWA Water Use Ratio Benchmarking Study and BIER’s 2012 Water Use Benchmarking in the Beverage Industry. (See page 12 for more.)



IBWA Names Jack West Honorary Life Member On November 15, 2013, the IBWA Board of Directors approved the Executive Committee’s recommendation that Jack West be named an Honorary Life Member of IBWA. Jack has made, and continues to make, many valuable contributions to IBWA and the bottled water industry. For more than 30 years, he has been a tireless bottled water advocate and the list of his accomplishments at IBWA is long and impressive. Jack has served on the IBWA Board of Directors and Executive Committee, been an IBWA chairman, chaired for many years the Government Relations Committee, received the Bottled Water Hall of Fame Award, served on numerous IBWA committees and task forces, been one of two IBWA representatives to the International Council of Bottled Water Associations (ICBWA), and been the chairman of the Drinking Water Research Foundation (DWRF) for many years. In light of his long and distinguished service to IBWA and the bottled water industry, the members of the IBWA Board of Directors were proud to recognize Jack West as an Honorary Life Member of IBWA.




On November 15, 2013, IBWA released the second episode of its YouTube video series “Meet Norman.” Episode 2, which premiered last November during the 2013 IBWA Annual Business Conference, highlights the importance of having access to healthy, safe, and convenient bottled water. The video has been picked up by a variety of news and online outlets, including Beverage World, Water Technology Online, The Digital Journal, BizWire Express, and BioMedicine. You can watch this video at—and IBWA encourages members to promote the video through their social media channels using the following hashtags: #bottledwater and #meetnorman.



Keep America Beautiful’s “I Want To Be Recycled” Campaign Targets the Nearly Two-Thirds of Americans Who Are Not Avid Recyclers

Imagine a plastic bottle that dreams of becoming a pair of jeans—or, perhaps, a park bench. These are just two of the many destinies that could be fulfilled if more Americans took the time to do one thing: recycle. In partnership with the Ad Council, Keep America Beautiful launched the “I Want To Be Recycled” national public service advertising (PSA) campaign in July 2013 to raise awareness and mobilize individuals to recycle more. Targeting sporadic recyclers, the campaign was created pro bono by award-winning ad agency Pereira & O’Dell to demonstrate that recyclables have value; specifically, the campaign illustrates that by recycling, individuals can give new life to their “garbage.” According to research released by the Ad Council at the outset of the campaign, only 52 percent of Americans said that they are “very” or “extremely” knowledgeable about how to properly recycle.* In addition, only 38 percent said they are “avid recyclers,” recycling as much as possible and willing to go out of their way to do so. While there are several barriers to recycling, among the most common reasons given for not recycling are that respondents did not have enough

information about where to recycle or which types of materials they are able to recycle. Keep America Beautiful and the Ad Council launched the campaign with the goal of making recycling a daily social norm. The campaign directs audiences to, a website with various educational assets and a localized search tool allowing users to find where to recycle locally. The website offers detailed information about which materials can be recycled, how they should be recycled, and what products they can become in the future. In addition to the traditional distribution of the PSAs, a number of creative uses of the campaign have been developed. Municipalities, including Chicago and Madison, Wisconsin, have put wraps with campaign imagery on their city sanitation trucks. Moreover, popular online grocer FreshDirect is featuring campaign messaging on all of its cardboard delivery boxes. The boxes include the line, “I want to be a cereal box. Recycle Me,” and direct customers to visit The “I Want To Be Recycled” campaign is funded through Keep America Beautiful by Alcoa Foundation, American Chemistry Council, Anheuser-Busch

Foundation, Nestlé Waters North America, Niagara Bottling, Unilever, and Waste Management. For more information about how your organization can support this campaign, please contact Keep America Beautiful’s Lynn Markley, senior vice president, brand development ( or Brenda Pulley, senior vice president, recycling ( *The online survey, commissioned by the Ad Council, was conducted in partnership with C + R Research. Research was conducted nationwide from June 25 - July 8, 2013. The sample consisted of 999 U.S. adults ages 18 to 64.  

One Plastic Bottle’s Journey Watch “Journey,” a PSA showcasing a plastic bottle that refuses to settle for being just a bottle and recognizes its dream in a coast-to-coast journey after being recycled on YouTube:





IBWA/NAMA ion Welcome Recept

IBWA 2013 Chairman Bill Young (left) passes the gavel to his successor, 2014 Chairman Breck Speed.

Learning and Networking in Nashville

Attendees of the 2013 IBWA Annual Business Conference collaborate and consider the future of the bottled water industry. IBWA President Joe Doss

Attendees of the IBWA, FDA, and Juice Products Association’s Food Defense Plan Workshop




From November 11-15, 2013, IBWA members and other bottled water professionals gathered in Nashville, Tennessee, to network with peers, hear from industry experts, and learn about the new and innovative products trade show exhibitors had to offer. IBWA’s annual conference and NAMA’s CoffeeTea&Water show once again co-located, which brought together the best of the bottled water, coffee, and tea industries. Early attendee feedback reports that participants thought this was the most energetic conference in recent years—and they are looking forward to the IBWA/NAMA co-location next year, November 10-14, 2014, at the Hyatt Regency in Dallas, Texas.


IBWA bottlers and suppliers participate in speed meetings. Joe Gannascoli (Vito Spatafore on The Sopranos) exhibited his line of container skins.

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(from left) Damon Grant and Brian Grant


(from left) Kim Jeffery, Jack West, Bob Hidell, and Jeff Vinyard

Hogan Lovell’s Brian Eyink presents during the “Green Guides” education session.

On November 12, 2013, as part of the IBWA Annual Business Conference, the Drinking Water Research Foundation (DWRF) held a Casino Night Fundraiser at BB King’s Blues Club in downtown Nashville. Attendees enjoyed good music, tasty southern cuisine, and friendly gambling on the casino tables. (No money was exchanged for winning; all gambling was done with “fake” chips.) And the best part—all money collected went to DWRF to help fund vital research impacting the future of the bottled water industry. PLATINUM SPONSORS • DS Waters • Nestlé Waters North America GOLD SPONSORS • Hogan Lovells • Mountain Valley Spring Company • MTN Products, Inc.

SILVER • AQUAQUEEN Australia • Bell Sales, Inc. • Blackhawk Molding Co., Inc. • Consolidated Container Company • Polymer Solutions International, Inc. • The Wohl Russell Family Foundation • Van Ness Feldman

DWRF promotes and supports research that verifies, identifies, and often solves current and potential problems that confront our world’s drinking water supplies.

Dr. Lawrence Armstrong presented a “Health and Hydration” education session.





ENVIRONMENTAL STEWARDSHIP IN ACTION How water use ratio benchmarking at the facility level is a first step toward broader water stewardship initiatives By Laura Nelson


ustainable management of water resources is a priority that spans the globe and impacts all of us—from household water users who rely on the tap to provide clean drinking water, to industry users who rely on a dependable source of water to keep daily processes flowing. A heightened focus on water stewardship has surfaced as access to high-quality water resources continues to be threatened by natural disasters, industrial pollutants, inadequate infrastructure, rising water costs, and rights disputes. Individuals, organizations, and companies are implementing water conservation and management efforts to support a viable water supply throughout the value chain. Beverage industry professionals especially understand the importance of clean, reliable water sources–because without water, there can be no beverage product and thus,

no viable business. Water stewardship has become an inherent tenet of business practice throughout the beverage industry, with many companies making exceptional efforts to build conservation into their business culture, while supporting the efforts of suppliers, customers, and the community. For stewardship efforts to be successful, company employees must first understand how to recognize efficiencies within their control. Employing a water use ratio to benchmark progress over time is a good starting point. As an organization dedicated to promoting an environmentally responsible and sustainable industry, IBWA published its inaugural Water Use Ratio Benchmarking Study in October 2013. That study was a first step toward understanding the impacts of water use in the North American bottled water industry by evaluating how bottling facilities use water and recognize process efficiencies over time.





Water Use Ratio Studies IBWA selected the water use ratio as a key performance metric to align with the methodology used by other beverage industry studies. Using a recognized methodology adds value to IBWA’s study because it ensures consistency in reporting, which results in ratios that are comparable to other industry benchmarks for performance evaluation. Below are examples of other water use ratio studies. Beverage Industry Environmental Roundtable (BIER): For the past seven years, BIER has conducted an annual water use benchmarking study that evaluates three-year global beverage industry trends, including specific facility-type evaluations for breweries, distilleries, wineries, and carbonated soft drink and bottled water plants. Since 2011, BIER has released select results of the study for public review. For more information, visit www. European Federation of Bottled Waters (EFBW): EFBW has conducted two water use benchmarking studies, using the BIER methodology to evaluate five year trends for European water bottling plants. EFBW has released select results of both studies (2011 and 2013). For more information, visit International Bottled Water Association (IBWA): IBWA’s inaugural Water Use Ratio Benchmarking Study evaluated a three-year trend (2009, 2010, 2011) for North American water bottling plants, including specific facility-type evaluations based on primary package type. An executive summary is available for review on IBWA’s website (, and IBWA members may also request a copy of the full report (for internal review only). Contact IBWA Director of Science and Research Tamika Sims, PhD, for more information:

Water Use Ratio: What Is It and Why Use It? For beverage industry purposes, a water use ratio is defined as the total amount of water used to produce 1 liter of finished product in a given time period within a defined scope of operations. Generating a water use ratio requires 12



a facility to first quantify how much water is used for all on-site processes including the following: • on-site water treatment • ingredient water • cleaning/sanitization • operation of employee washrooms or canteen services • landscaping. It does not include value stream water use (e.g., water used for off-site bottle blowing, product transportation, customer refrigeration, etc.). The reason for that distinction is to keep the focus of the ratio on identifying efficiencies within the facility’s control. Thus, the ratio provides a starting point for evaluating how process changes, conservation efforts, and other aspects of a facility’s operation have influenced water use over time. Using that information, a facility can further evaluate potential drivers for ratio performance, and then identify opportunities for process improvements. IBWA selected the water use ratio as a key performance metric to align with the methodology used by other beverage industry studies. (For more, see the “Beverage Industry Water Use Ratio Studies” sidebar at left.) Using a recognized methodology adds value to the IBWA study by ensuring consistency in reporting, resulting in ratios that are comparable to other industry benchmarks for performance evaluation.

IBWA Water Use Ratio Benchmarking Study In 2013, IBWA invited all North American bottler member companies to participate in an inaugural water use ratio benchmarking study. In total, nine IBWA members and one industry peer provided three years (2009, 2010, 2011) of total water use and total production data, as well as supplemental process data including facility type: small pack, home and office delivery (HOD), and mixed pack. By providing supplemental data, participants were able to shed additional light on possible drivers of perceived water use ratio trends. Five key takeaways were identified: 1. The 2011 water use ratio for North American water bottlers was 1.39 L/L. This ratio demonstrates a higher level of performance when compared to the global 2011 average for bottled water facilities (1.47 L/L, as reported by the Beverage Industry Environmental Roundtable). 2. Industry water use ratio remained relatively flat, while total water use and total production both increased over the study period. This trend demonstrates that process efficiencies are being recognized while the industry experiences sustainable growth.

Water Use Ratio


Water Use Ratio Performance of the North American Bottled Water Industry: 2009 - 2011











3. In general, bottled water facilities have the lowest water use intensity when compared to other beverage sectors. On average, it takes 1 liter of ingredient water and 4/10 of a liter of water used for facility processes to produce 1 liter of finished bottled water product. Other beverage sectors, such as carbonated soft drink bottlers, on average have larger water use ratios driven by higher intensity processes unique to those other beverages, (e.g., flavor mixing, carbonation, etc.). 4. The study also reviewed water use ratios by facility type and concluded that facility-specific processes contribute to the magnitude of water use ratios. For example, the 2011 average water use ratio for HOD facilities was 1.63 L/L, compared to the small pack average of 1.36 L/L. HOD facilities typically bottle finished product in refillable containers, resulting in additional water use for sanitization processes that do not exist at facilities that use single fill packaging (e.g., most North American small pack facilities). 5. North American bottlers have made significant efforts to reduce water use through process improvements. When asked to identify the top water conservation efforts implemented in the past three years, participants identified the following best practices:

improved flow management to reduce product waste during changeovers

optimization of cleaning/sanitizing units through automated timers, selection of cleaning chemicals, flow control, air rinsing, etc.

recognition of production schedule efficiencies

reuse/reclamation of water for non-product contact or gray-water applications, such as on-site landscaping.

Next Steps: Continued Stewardship Through exemplary member participation, the IBWA benchmarking study accomplished its primary goal: evaluate water use efficiencies and trends among North American bottlers as a first step toward understanding impacts of water use in the bottled water industry. Now the question arises–how can benchmarking results be used to impact broader industry performance and further sustainable water management? Use the Results to Implement Change. The water use ratio is a starting point for understanding efficiencies in how water is used for processes. Dig deeper into the ratio to understand the drivers for observed trends. Through additional investigation, a facility might identify key processes or equipment as primary drivers for ratio


Carbonated Soft Drinks: 2.02 L/L

1 liter of water for product

1 liter of water for product

+ 0.39 liter of process water (treatment, bottling, sanitization, etc.)

+ 1.02 liters of process water (treatment, bottling, blending, product changeover, sanitization, etc.)

= 1 liter finished bottled water

= 1 liter finished carbonated soft drink




Increased IBWA member participation in future studies will enhance analyses and contribute to a better understanding of water stewardship practices within the beverage industry. performance or uncover inefficiencies, such as plumbing leaks. After identifying potential drivers, evaluate feasible conservation measures that can be implemented at a facility level with minor production impacts. Use the examples identified in the IBWA study as well as other sources of industry best practice to select the solutions that best fit the facility’s needs. Remember that not all process changes need to be significant capital investments– seemingly minor changes, such as increasing employee

awareness of water conservation, can have significant results. Keep in mind that water conservation efforts can also result in secondary benefits: process optimizations and culture changes could also reduce energy use, waste generation, and chemical use—and lead to comprehensive cost savings over time. Stewardship Beyond the Facility Walls. Having achieved a good understanding of facility performance, opportunities exist to engage in stewardship efforts throughout the value chain. In the case of IBWA, establishing a water use ratio was the first step toward understanding the bottled water industry’s broader water footprint. The same applies on a facility level–now that internal operations are accounted for, reach out to suppliers to understand how water is used in the value chain (e.g., water use for bottle blowing, transportation of finished product, etc.). Engage with other community water users and industry peers to share best practices and make a greater impact on water stewardship efforts. Participate in Future Benchmarking Studies. IBWA plans to continue to benchmark North American bottled

PRACTICAL APPLICATION OF THE IBWA BENCHMARKING METHODOLOGY IBWA’s study methodology can be applied at any bottled water facility by using the steps below: Step 1: Identify Scope. Before initiating the benchmarking process, it is important to evaluate the scope of the study. Determine which facility processes contribute to total water use, and coordinate with facility personnel to identify how many years of reliable water use and production data are available for review. Step 2: Data Procurement. Production data is typically sourced from sales records, and total water use data can be sourced from on-site meter readings, public utility invoices, or production manager estimates. Data should be reviewed for completeness and accuracy. Step 3: Calculate Ratio(s). Calculate water use ratio by dividing total water use by total production. For companies with more than one facility, calculate facility ratios first to identify internal trends, then calculate weighted company-wide ratios (total company water use divided by total company production) to evaluate overall performance. Step 4: Evaluation. Once ratios have been calculated, evaluate performance over the selected time period, or compare results to the ratios published by IBWA and other beverage industry studies. If water use ratios are improving over time (or less than industry averages), identify the processes that are driving this success and seek opportunities for continuous improvement. If water use ratios are increasing over time (or greater than industry averages), evaluate facility processes to target areas for improvement. Step 5: Repeat. Benchmarking studies are meant to be continuous, so repeat the study in future years to build upon results and further evaluate opportunities for efficiencies among facility processes.




Water Use Ratio

water industry performance. Benchmarking studies are meant to be continuous to capture stewardship efforts’ effectiveness over time, and increased IBWA member participation in future studies will enhance analyses and contribute to a better understanding of water stewardship practices within the beverage industry.

Continuing Stewardship Practices The 2013 IBWA Water Use Ratio Benchmarking Study provides a first look into process efficiencies and best practices within the North American bottled water industry. Although the industry has a good story to tell, it is important to remember that water stewardship is a process of continual improvement. Opportunities always exist for water conservation in the beverage industry–and it all starts with processes within a company’s control. Companies should consider implementing water use ratio benchmarking studies at a facility level to identify ways they can impact water resource conservation within the four walls and throughout the broader value chain.

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Laura Nelson is a sustainability consultant with Antea Group, and managed the data collection, analysis, and report preparation for the 2013 IBWA Water Use Ratio Benchmarking Study. Antea Group is an international engineering and environmental consulting firm specializing in full-service solutions in the fields of environment, infrastructure, urban planning, and water. Believing the best sustainability programs integrate sustainable strategies into core business practices, Antea Group helps clients identify and act on business-relevant social and environmental opportunities. For more information on water use benchmarking or other sustainability initiatives, contact Laura:


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With consumers becoming increasingly interested in the environmental effects of the products they purchase, it can seem as if everyone wants a piece of the “green advertising” action. The Federal Trade Commission (FTC), the federal body charged with overseeing advertising in the United States, certainly does. In the summer of 2012, the FTC released a long-awaited update to its “Green Guides,” which contained more than 300 pages of policies and guidance for advertisers making environmental claims. The Green Guides represent FTC’s views on when environmental marketing claims are unfair or deceptive under Section 5 of the FTC Act, 15 U.S.C. § 45. Although technically nonbinding, the FTC will follow the Green

Guides when investigating environmental benefit advertising, and advertisers diverging from the Green Guides risk an investigation by the FTC or a state attorney general, or a lawsuit by a private litigant or a competitor, all of whom also look to the Green Guides when considering false advertising claims. The FTC provided an initial grace period for advertisers to implement the new guidance, but, as recent FTC enforcement actions demonstrate, that grace period is over, and the new Green Guides can be expected to guide FTC action for many years to come. If your company is currently making (or considering making) environmental marketing claims, now is the time to make sure you understand the new Green Guides.




FTC expects advertisers to have substantiation in g place before makin any environmental claim in an advertisement.

Key Themes The Green Guides embody several key themes that reflect the FTC’s more general policy toward all advertising: Advertisers are responsible for all expressed and implied claims. This is a key driving factor for the Green Guides. A significant portion of the guidance is targeted toward identifying what a specific environmental marketing statement might imply and putting boundaries on those claims. In other words, the FTC expects an advertiser to be able to substantiate all expressed and implied claims conveyed by an environmental claim. All advertising claims can be qualified. The FTC states that qualifications are appropriate to use to prevent consumers from assuming unintended inferences. Qualifications must be clear, prominent, and understandable. (For example, an advertiser might state a product is “environmentally friendly” because it reduces plastic usage by 50 percent and decreases landfill loads.) The claim should be placed close to the qualifying language; this is especially important in online advertising. The FTC generally does not believe that qualifiers presented through hyperlinks or popups are effective, nor is a qualifier placed in fine print at the bottom of a webpage necessarily




going to be sufficient, in the FTC’s view, to qualify a claim made prominently at the top of the webpage. The FTC expects consumers to be able to see the qualification in context with the claim. The same is true for product labels: in the FTC’s view, it is not sufficient to put qualifications on websites for product claims made on labels. Thus, putting a referral statement—“Please see our website for more details”—won’t cut it. Moreover, an advertiser may need to use qualifications to make sure the focus of the claim is clear—the product, the packaging, the lifecycle, the production process, etc. The Green Guides are intended, among other things, to help advertisers identify what implied claims consumers will draw from various environmental claims. Advertisers can use the Green Guides to determine when qualifications are necessary to ensure consumers don’t draw more significant conclusions from an environmental claim than what the advertiser might intend. Claims must be substantiated by competent and reliable scientific evidence. The FTC typically expects environmental marketing claims to be substantiated by competent and reliable scientific evidence. The type of evidence required can vary depending on the

context of the claim, but, in many cases, scientific studies may be required. Importantly, FTC expects the advertiser to have the substantiation in place before making the claim in the advertisement.

Claim Guidance The Green Guides cover a number of environmental claims—including carbon offsets, compostable, nontoxic, ozone-safe and ozone-friendly, renewable energy, and renewable materials— but those most relevant to the bottled water industry are detailed below: General environmental benefit claims. These are claims that suggest a general environmental benefit without any clear focus on what that benefit is—“green,” “eco-friendly,” “earth-smart,” “eco-balanced,” and so forth. FTC takes the position that such claims are difficult if not impossible to substantiate because they imply a wide range of environmental benefits. The FTC’s position is that when the consumer sees a phrase such as “ecofriendly” on a label, he or she might think a number of things: this product is made from recycled materials, is recyclable, is made with a lower carbon footprint, is biodegradable, or all of the above. In FTC’s view, all of those (and other) claims are implied by a general environmental benefit claim; therefore, all must be substantiated. An advertiser may, however, qualify a general environmental benefit claim. If your company is using such a claim, make sure to qualify it in a way that the FTC will find acceptable. For example, if you use “eco-friendly” to describe your product, explain specifically why the product is eco-friendly in a way that is fully supported by your company’s substantiation. The takeaway: if you are making an environmental benefit claim, be very careful and cognizant of the risks involved in how you frame that claim to the consumer.

Certifications and seals of approval. Generally speaking, all certifications and seal endorsements need to be true and accurate. (They are also subject to the FTC’s testimonial and endorsement guides, which are beyond the scope of this article.) Importantly, though, if there are any financial ties between the certifier and the advertiser, other than a customary fee for the certification services, those ties should be disclosed (e.g., if the advertiser owns the certifying entity or if the certifier is an in-house, but independent, wing of the company). The FTC says that unqualified seals or certifications can be general environmental benefit claims, raising all the issues discussed above. If a seal has, for example, a picture of the earth or includes the word “eco” or “green” in it, the FTC will view that as a general environmental benefit claim. Although the seal merely signifies that the manufacturer went through that certification process, the FTC is of the opinion that the consumer will see the word “green” on the product and assume general environmental benefit claims that the manufacturer can’t substantiate. How do you handle that situation? The FTC expects that, if you put a seal on your product, you will also provide (if necessary) a description explaining what that seal means (i.e., what criteria the product was evaluated on). An advertiser might discuss this question


Pictures can also suggest a general environmental benefit claim. For example, images such as a tree or a green leaf on a product could be a general claim. The FTC cites an example of a printer cartridge that had the earth’s image on it, saying that image implies all sorts of environmental benefits—recyclable, recycled material, recycled content— that may not be true for that printer cartridge. But the FTC would expect the manufacturer to substantiate every single one of those implied claims.

RECENT FTC ENFORCEMENT ACTIONS The Federal Trade Commission (FTC) monitors the marketplace, responds to consumer or competitor complaints, and monitors investigations and proceedings at other dispute resolution bodies. FTC operates by both providing guidance documents and using enforcement action to demonstrate what advertising it views as deceptive. The FTC has announced several recent enforcement actions in the area of environmental advertising, reinforcing that the FTC is actively enforcing its new Green Guides.

Examples of FTC Enforcement • FTC settled cases with five window manufacturers who had made claims about their windows’ energy efficiency and cost savings. • FTC settled cases with several major national retailers regarding claims that products were made from bamboo when in fact, according to FTC, the products were made from rayon derived from bamboo, which was misleading. FTC collected a total of $1.26 million in penalties from the retailers. • FTC entered into consent decrees settling cases with three mattress manufacturers regarding claims that mattresses were free of volatile organic compounds (VOCs). • FTC announced on October 29, 2013, that it was taking enforcement action against six manufacturers of biodegradable plastics. According to FTC’s complaint, one manufacturer advertised that its organic biofilm, when introduced into a plastic resin, would cause the plastic to biodegrade in nine months to five years. The FTC alleged the manufacturer’s substantiation was more limited than the claim being made, did not support the full biodegradability claim, and, in some cases, the manufacturer made unqualified biodegradability claims. A hearing is scheduled for June 2014 before an administrative law judge. FTC also announced it was settling cases with four other plastics companies—some of whom used the manufacturer’s resin in their products and made claims similar to the manufacturer’s—and a paper plate and paper products manufacturer that had advertised its products as biodegradable, compostable, and recyclable. The paper manufacturer paid a $450,000 civil penalty. • FTC announced on November 22, 2013, a settlement with a manufacturer claiming its fuel additive increased fuel efficiency and reduced emissions. The settlement included an $800,000 civil penalty.

with its certifying body, as it might have already developed appropriate qualifying language to use. Keep in mind that obtaining a certification does not alleviate the advertiser’s obligation to substantiate claims. Sometimes a certification will be enough to substantiate claims; sometimes it will not. A certifying organization that puts products through a rigorous scientifically accepted testing process, for example, could provide the scientific substantiation

for a claim, but the claim should reflect any limitations of the testing process. Degradable claims. The FTC believes words like “degradable,” “biodegradable,” “oxo-degradable,” or “oxo-biodegradable,” when used without qualification, implies that the item will completely break down into elements found in nature within a reasonably short period after customary disposal. What is a “reasonably short period?” FTC provides some guidance by stating that, JANUARY/FEBRUARY 2014



eral If making a gen enefit environmental b l and claim, be carefu risks cognizant of the you involved in how to frame that claim qualify consumers and it appropriately.

if the product enters the solid waste stream, consumers expect the product to degrade fully within one year. (See the sidebar on p. 19 to read about how FTC has taken some forcible action on biodegradable claims.) Advertisers can qualify a biodegradable claim. If your evidence shows that your product will fully degrade within two years, for example, stating that the product will biodegrade within two years could be an appropriate claim. “Free-of ” claims. Advertisers might not always think of claims that a product is “free of ” a toxic material (e.g.,“BPA free”) as “green” claims, but the FTC addresses those claims in the Green Guides. The FTC says a “free-of ” claim is appropriate if •

the product is truly free of the substance (and doesn’t contain a substance that poses the same or similar risks)

the substance has been associated with the product category.

However, there are exceptions: •



If the product has trace amounts of the substance (i.e., background levels), presence at those background levels does not cause material harm typically associated with the substance, and the substance has not been added intentionally, a “free-of ” claim can still be appropriate. WWW.BOTTLEDWATER.ORG

If consumers typically associate a substance with the product classification, although it is not actually found in the product, it might be appropriate to make a “free-of ” claim. This is where “BPA free” claims come in: BPA is sometimes associated with small-pack bottles, even though small-pack bottles are most often made from PET, which does not contain BPA.

Recyclable claims. If an advertiser says a product is recyclable, the FTC takes that to mean the product—with the exception of minor components (like a bottle cap)—can be recycled by a substantial majority of consumers. What is a “substantial majority”? According to the FTC, it’s 60 percent of consumers or 60 percent of communities in which the product is sold. Think of it this way: if an advertiser has a national product, and 60 percent of the U.S. population has access to appropriate recycling facilities, the advertiser’s product is “recyclable.” If the advertiser is selling only in the state of California, and 40 percent of Californians have access to recycling facilities, the FTC would view an unqualified “recyclable” claim as deceptive. If you can’t substantiate (in advance) that a product is recyclable by 60 percent of consumers or that appropriate

facilities are available in 60 percent of the communities in which your product is sold, you can qualify the claim. FTC provides some guidance on how to make those qualifications. Importantly, the qualifications vary in strength depending on the availability of appropriate recycling facilities. The lower the availability of recycling facilities, the more strongly the FTC would expect the claim to be qualified. FTC provides a few examples of how to do that: •

If “slightly less” than a substantial majority of consumers can recycle the product, it would be appropriate to qualify a recyclable claim this way: “This package may not be recyclable in your area” or “Recycling facilities for this package may not exist in your area.”

If a very small percentage of your consumers can recycle the product, FTC would expect the qualifier to say something like, “This package is recyclable only in the few communities that have appropriate recycling facilities.”

The Green Guides also offer examples of insufficient qualifications, including “Recyclable where facilities exist,” and “Recyclable—Check to see if recycling facilities exist in your area.” The FTC says those statements are insufficient because they don’t give the consumer a sense for the extent to which recycling facilities are actually available for that product. Resin identification codes (a number within three arrows in a triangular shape identifying the plastic resin) can look a lot like a recycling symbol. The FTC knows this and offers the following guidance: the conspicuous use (e.g., near product name or logo) of a resin identification code can be a recycling claim, depending on the context. A resin code placed prominently on the front of your package, may imply the product is recyclable—and FTC will expect it to be recyclable by 60 percent of consumers unless the claim is qualified. But, FTC advises that the inconspicuous use

Recycled content claims. The FTC advises recycled content claims are appropriate if all but incidental components (like a bottle cap) are made from recycled material. Thus, you can have a recycled-material water bottle with a new cap, and that qualifies as a “made from recycled content” product. These claims can also be qualified—stating that the product is, for example, 70 percent recycled material or 40 percent recycled material—and the claim does not have to identify if the material is pre- or post-consumer waste. Notably, the FTC says that the unqualified use of the three-chasing arrows symbol likely conveys both recyclable and recycled content claims. An advertiser using a symbol like this on its product should give some thought about the context in which the symbol is presented and whether a consumer would likely draw the wrong conclusions. If that is possible, the advertiser should think about how to qualify that claim to mean what is intended—because if FTC looks at the symbol, the Commission might think it means both. Source reduction. Source reduction claims (e.g., 50 percent less plastic, 25 percent less waste) are popular among packaged goods manufacturers, including the bottle manufacturing industry. Any claim stating that something (source material, emissions, energy, etc.) has been reduced is viewed as a source reduction claim. Such claims are entirely appropriate, but you need to keep in mind how the consumer is going to view that claim. If you identify “10 percent less plastic,” does that mean 10 percent less plastic from your previous product? Does it mean 10 percent less plastic than your leading competitor? Ten percent less plastic than the indus-


of a resin identification code, such as on the bottom of the container, would not be viewed as a recycling claim.

IBWA MEMBERS: DOWNLOAD BONUS GREEN GUIDE EXPLANATION DOCUMENT Although the FTC has a 300-page explanation of the Green Guides, IBWA’s Green Guides subcommittee, which is made up of members from the Government Relations and Environmental Sustainability Committees, has produced a 36-page explanation that walks through a number of examples specific to the bottled water industry. Use this document to become familiar with what the FTC requirements are—because they are not always intuitive and can differ from what you might expect. IBWA members can download this document from the IBWA website (www. Simply login to the IBWA “Members Only” section of the website, go to the Government Relations or Environmental Sustainability page, and click on “IBWA Green Guides Document” to download.

try average? If there’s no qualification, the FTC would expect all three of those to be substantiated.

Managing Legal Compliance The Green Guides were not intended to silence environmental marketing, but they should cause advertisers to step back and carefully evaluate any claims they want to make. Always consider the legal and business ramifications of making “green” claims. FTC investigations, class action lawsuits, and state attorney general investigations are expensive to defend against and can lead to significant civil penalties or settlement amounts. FTC consent decrees have long lives and can affect a company’s marketing efforts for many years. If you want to highlight the environmental benefits of your products, consider establishing internal procedures for reviewing and clearing those claims: identify the substantiation for the claim, make sure the claim tracks that substantiation, review the claim in light of FTC’s guidance, identify any limitations on the claim, and consider

what qualification may be needed. And remember, context matters: a claim might be appropriate in one context but not in another. Once the claim is cleared, establish a file documenting the substantiation. Multiple people may need to be involved in this process, including technical experts and legal counsel. If you plan on making a lot of green claims, consider putting together standardized substantiation procedures and a master claims list of cleared environmental claims. Remember to periodically review that list, as changes to suppliers, manufacturing processes, and competitors’ products can affect the accuracy of claims.

Brian Eyink practices law in the area of food and agriculture with Hogan Lovells in Washington, DC. He represents clients regulated by the Food and Drug Administration, Department of Agriculture, the Federal Trade Commission, and other health and safety and advertising organizations at both the federal and state level.




Niagara Bottling, LLC President and CEO Andy Peykoff, II (left); Ohio Governor John Kasich (center); and Niagara Bottling Founder and Chairman Andrew D. Peykoff, Sr.


Meetings on Familiar Turf By James Toner, IBWA Director of Government Relations

Home cooking. Home field advantage. Home is where the heart is. Home— there’s no place like it—and when we can use it to our political advantage, all the better. When you’re trying to convey important industry messaging to elected officials, where do you think you’d be most comfortable conversing about those issues? It’s natural to feel more comfortable and at ease when you have those discussions at a place you consider “home turf.” In recent Government Relations columns, we’ve stressed the importance of meeting with your state and federal 22



legislators. But we’ve also conceded that traveling to Washington, DC, or a state capital can be a stressful experience—not to mention the time and cost involved. What if we were to flip the paradigm? How would you feel about hosting elected officials at your place— where you are more at ease? Envision the two scenarios: You travel to Washington, DC, in your best suit to meet with your member of Congress (if you are lucky) and his or her staff, while lobbyists and other industry professionals hover around also trying to get time with the lawmaker—or you make your

way over to the hometown coffee shop for a planned meeting with your elected official surrounded by friends, family, and coworkers. Which scene offers the best opportunity for you to speak your mind? Which meeting would be more conducive to an open discussion? We sometimes forget that elected officials come from all walks of life, and they too have a place they call “home.” Lawmakers usually spend a good amount of time back in their home districts. When your government representatives are at home, they aren’t off the clock; they’re always working for


LAWMAKERS IN THE HOUSE If you are thinking of hosting an elected official at your facility, know that you can depend on IBWA to help. IBWA staff can provide you with a checklist to help you prepare for the event—or any other support you may need. For more information, contact IBWA Director of Government Relations James Toner: Stir up a little home cookin’ and see what happens!

their constituents—and always looking for input. If you are assertive enough to reach out to their offices to schedule an appointment, you’ll find you have a great opportunity to take advantage of that home visit.

The Local Edge You’ve probably seen news articles about lawmakers stopping at the local diner or coffee shop. Those events are more than just photo ops; they’re real opportunities for elected officials to demonstrate a connection to their communities. Such occasions also present constituents with the chance to get some face time with elected officials. Inviting a lawmaker to a local establishment where you, your coworkers, and your neighbors regularly visit is a win-win for both you and the lawmaker. A legislator will relish the chance to rub elbows with locals, show his concern for community issues, and take a few quick pictures with constituents. For you, because you’re operating from your home base, you and your employees or coworkers will feel comfortable discussing your issues without the pressure that can sometimes be felt if a meeting is held in DC or a state capital. The


The Site Visit During the 2013 IBWA Annual Business Conference in Nashville, Tennessee, November 11-15, attendees of the educational session “Fantastic Facility Tours” learned firsthand how to organize a successful visit from an elected official to their place of work. While the objective remains the same—educating the lawmaker about your business and industry—the structure behind such an event differs from a visit to Capitol Hill or your local, public venue. While the planning required for setting up a site visit is extensive, it can lead to great results. After extending the invitation, you have to address a host of questions before the meeting takes place at your facility: • Who will lead the tour and what will he/she say? • What issues do you want to make sure your visitor is aware of? • What do your employees need to know about the event and your guest? • Is your facility properly prepared for this visit? The most important objective when bringing elected officials into your facility is to give them a true feeling for what you and your employees do every day.

Lasting Impression I had the unique opportunity to be on a conference panel with a former member of Congress a few years ago.

During the Q&A session with the audience, the congressman told a story about how he was once invited by UPS to visit its local facility. He arrived early in the morning, and, much to his surprise, they suited him up in their trademark brown uniform and sent him out with a driver in one of their trucks. He said that experience gave him a complete and clear understanding of what those employees do every single day. Whenever industry-specific issues would arise, he admits he always referred to that experience. Your goal should be to do the same for the bottled water industry.


Take Advantage of Special Incentives When Renewing Your IBWA Membership IBWA bottler, supplier, and distributor member companies that pay their membership dues in full (plus inspection fees) by January 31, 2014, can deduct hundreds of dollars from their dues payments. To learn more, visit www. dues-renewal or contact IBWA Manager of Member Services Dennis Carpenter: dcarpenter@




An Industry Thinking Ahead About Environmental Issues By Chris Hogan, IBWA Vice President of Communications

In October 2013, IBWA released results from its inaugural Water Use Ratio Benchmarking Study, which provides an analysis of the amount of water used to produce 1 liter of finished bottled water product. At 1.39 L/L, bottled water has the lowest water use ratio of any packaged beverage. To put that in perspective, carbonated soft drink producers require, on average, 2.02 liters of water to produce 1 liter of soda; one liter of beer uses 4 liters of water; 4.74 liters of water is required for 1 liter of wine; and hard alcohol requires a whopping 34.55 liters of water per liter of finished product. This significant news—that bottled water has a highly efficient water use ratio footprint compared to any other packaged beverage product—was some24



what lost amid the din of condemnation from bottled water opponents. They oppose the bottled water industry having any water use footprint at all, including the water in the bottle. IBWA’s study was produced by Antea Group, an independent, third-party consultant. The study identifies some of the significant process improvements the North American bottled water industry has made to reduce water use, including the following: • improved flow management to decrease product waste during changeovers • optimized cleaning/sanitizing units through automated timers, selection of cleaning chemicals, flow control, air rinsing, etc.

• •

recognized production schedule efficiencies reuse/reclamation of water for nonproduct contact or gray-water applications (such as on-site landscaping).

The IBWA study’s findings are consistent with a 2012 annual industry benchmarking report released by the Beverage Industry Environmental Roundtable (BIER), which found that, on average, about 1.47 liters of water is used in the production of 1 liter of bottled water. In fact, BIER found the bottled water industry’s water use ratio to be the smallest of all beverage production operations it tracks, which includes beer, bottled water, carbonated soft drinks, distilled spirits, and wine. For more information

COMMUNICATIONS about BIER’s study, visit BIERbottledwater2012.

The Good News Your legislators, regulators, and current and prospective customers need to hear about the results from IBWA’s 2013 water use ratio study. But that can only happen if we take action: we have facts we can celebrate, share, and defend. Still, there are only so many ways you can tell consumers, “At 1.39 L/L, bottled water has the lowest water use ratio of any packaged beverage.” Below are a few examples of other bottled water industry “good news items” we encourage you to share. Water—its protection and preservation—are core to the very existence of the bottled water industry. Without question, water is our No. 1 resource and ensuring that safe supplies and sustainable resources of water are protected and preserved is vital to our industry and, frankly, to our planet. Although bottled water critics often portray us as anti-environment, IBWA member companies have a rich history of proactive environmental stewardship, recycling advocacy, and water resource management—and we continue to develop environmentally innovative and sustainable packaging. While detractors may prefer to blame the bottled water industry for causing stress to aquifers, the facts are without question against them. Annual bottled water production accounts for less than 2/100 of a percent (0.02 percent) of the total groundwater withdrawn in the United States each year.

BOTTLED WATER HAS THE LOWEST WATER USE RATIO OF ANY PACKAGED BEVERAGE. Drinking water is always the right decision and opting for bottled water is the best healthy choice. Bottled water’s healthful qualities are indisputable. For those who need clean, safe water for any reason, in many cases bottled water is not simply a convenience, it is an absolute necessity. Bottled water is an important, healthy beverage choice that must remain available to consumers wherever packaged beverages are sold. Banning or restricting access to bottled water in the marketplace directly impacts the right of people to choose the healthiest beverage on the shelf. And for many, bottled water is a critical alternative to other packaged beverages, which are often less healthy. Bottled water must therefore be available wherever packaged beverages are sold. IBWA members do their part every day to show through action and advocacy that the bottled water industry is thinking and acting for the future. We play an important role in responsibly managing and protecting water resources, preserving the natural environment for generations to come, and supporting recycling efforts across the country. We are proud of our healthy products, our companies, and our commitment to the environment.

Spread the Word Despite the bottled water industry’s size and continued growth, the amount of water actually sold is relatively tiny, compared to tap water volumes. To put it in context, the entire U.S. bottled water market is 9 billion gallons; New York City goes through that amount of tap water in one week.

The bottled water industry is fortunate to have such a positive message to share: we have a documented history of progressive environmental stewardship; we produce the healthiest packaged beverage on the market shelf; and we are relentless in our efforts to continue to better our industry for both consumers

and the environment. Telling the story of bottled water should be a priority not only for the Association but also its members. We will continue to look for ways to better educate legislators, consumers, and the media about our products—where they come from and their role in our world today and tomorrow. We encourage you to do the same.


2014 Marks the Return of IBWA Award Season

Since 1961, IBWA has recognized the contributions and achievements of bottled water professionals through its awards program. We know that without the dedication of our member companies and their staffs, the bottled water industry would not enjoy its past or current success. Thus, IBWA announces that this year it will again hold its awards program to acknowledge and celebrate the commitment of individuals and companies to the bottled water industry with the following awards: Route Salesperson of the Year Plant Manager of the Year Supplier of the Year IBWA/Kristin Safran Directors’ Award Environmental Stewardship Award 2012 Bottled Water Hall of Fame For more information, visit JANUARY/FEBRUARY 2014



What IBWA Thinks of FDA’s Proposed CGMP and Preventive Controls Rule By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations

Last November, IBWA submitted a 15-page letter to the U.S. Food and Drug Administration (FDA) that contained the bottled water industry’s comments on FDA’s proposed rule for Current Good Manufacturing Practice (CGMP) and Hazard Analysis and Risk-Based Preventive Controls for Human Food. To summarize, FDA’s proposed rule revises the CGMP regulations and intends to build a food safety system for the future that makes modern, science-, and risk-based preventive controls the norm across all food sectors, domestic and foreign. IBWA’s comments are the result of an abnormally lengthy review period of the 26



proposed rule (since January 4, 2013), during which time IBWA and other food industry groups attended numerous meetings with FDA, other trade associations, and several coalitions to learn more about FDA’s thoughts on the rule. In our comments, IBWA urges FDA to maintain rules that are risk-based and promote food safety, yet we discourage requirements that are prescriptive, thus making it difficult for industry to establish food safety systems that are the most effective for their respective processes and products. We encourage FDA to propose rules that are true to the original legislation and focus on protecting public health. In addition, FDA’s new

rules should be enforced consistently and appropriately with adequate and welltrained staff. To that end, IBWA and other organizations support the work of the Food Safety Preventive Controls Alliance to establish standardized training programs for both FDA and the regulated community.

Environmental Monitoring Currently, it’s not clear whether bottled water companies will be required to develop and implement environmental monitoring (EM) programs, but, in our comments to FDA, IBWA covers both scenarios. If required, IBWA is advising

FDA that its focus on monitoring for Listeria monocytogenes and Salmonella have little relevance to safety in bottled water products. We suggest that total coliform bacteria, and, more specifically, Escherichia coli (E. coli) be monitored in bottled water. FDA has also promulgated standards of quality for total coliform and E. coli in bottled water, which makes their application more appropriate. While FDA considers EM for bottled water, IBWA requested that FDA clarify in the rule’s preamble that compliance with 21 CFR §129.80(f ) would meet the requirements under the Food Safety Modernization Act (FSMA) for EM in a bottled water facility. If FDA agrees that the industry’s containers and closures monitoring program satisfies FSMA’s EM requirements, it would remove a significant burden for bottled water companies.

Source Registration and Food Safety Plans Perhaps an even more significant reduction in burden for bottled water is FSMA’s applicability to natural water sources. A first reading of the proposed rule would imply that raw source waters that are treated on-site would need to be addressed in a facility’s food safety plan, and FDA has preliminarily considered that to be true. However, there is an exemption in the proposed rule for raw agricultural commodities (RACs) that, although treated in some manner while in storage prior to processing, are processed in such a way as to replicate any treatment done while in storage prior to processing. The same could be said about raw natural waters (i.e., even if water is filtered and disinfected at the source site, that treatment is repeated during processing and bottling at the bottling facility). IBWA has suggested to FDA that the RAC exemption should also apply to raw natural waters, thereby


IBWA URGES FDA TO MAINTAIN RULES THAT ARE RISK-BASED AND PROMOTE FOOD SAFETY, AND WE DISCOURAGE REQUIREMENTS THAT ARE PRESCRIPTIVE. relieving bottlers of developing a HACCP program for their source waters. In addition, the RAC exemption could also excuse bottlers from being required to register raw water sources with FDA under the Bioterrorism Act of 2002. However, the proposed rule for intentional adulteration (a.k.a., food defense) will address natural water source protection from intentional adulteration when published and enacted. Finally, these natural water sources are all regulated and licensed by state authorities, generally either the state water control authority or state environmental authority, which have extensive expertise in source water regulation. And, FDA’s own GMP regulations for bottled water in 21 CFR Part 129 defer to the state agency of jurisdiction for the regulation of source water, so application of the preventive controls rule would be a duplication of source regulation.

More Guidance Due to the extensive nature of IBWA’s comments to FDA, the following summarizes those comments on other aspects of the preventive controls rule. Good Manufacturing Practices. Within IBWA’s membership, general support exists for FDA’s proposed revisions to the food GMPs. We support making training a requirement, as recommended by the GMP Coalition, provided the regulatory requirement is

general in nature so company training programs can be tailored to meet individual company needs. IBWA’s opinion is that the only way to implement FSMA successfully is to train FDA and state inspection staffs to ensure consistent enforcement. Preventive Controls. IBWA supports the preventive controls provision of FSMA (§ 103), but seeks significant modifications to the proposed rule. Rather than trying to retro-fit FSMA preventive controls into a regimented seafood/juice HACCP model, the regulations should follow the FSMA statutory language to provide for the following: • consideration of “known or reasonably foreseeable” hazards (as opposed to hazards that are “reasonably likely to occur”) • implementation of a range of preventive controls—not just at critical control points (CCPs)—as needed to control those hazards • gradations in the level of rigor used to manage this range of preventive controls should be commensurate with the nature of the ri≠sk and the type of controls being used (i.e., a sliding scale), with only CCPs receiving the most rigorous management oversight. In conducting a hazard analysis, consideration should be given to the benefits derived from existing prerequisite programs, such as GMPs. IBWA supports FDA’s on-site access to records JANUARY/FEBRUARY 2014



for all preventive controls, but we oppose off-site, remote access to records.

ing as a final means of verification of the safety of our products for many years.

Testing. The proposed preventive controls rule calls for finished product testing as a means of verification of the food safety plan. Although most of the food industry opposes finished product testing, bottled water companies are required by existing FDA regulations in 21 CFR 129 to monitor for and meet standards of quality for an extensive variety of microbial, chemical, physical, and radiological contaminants. We believe the testing already mandated for bottled water fully satisfies all testing requirements proposed in the proposed rule. No other food industry segment can currently claim this to be true about their product quality requirements. The bottled water industry has viewed test-

Modified Requirements for Warehouses. IBWA strongly supports the proposed exemption for warehouses where the food is not subject to Time/ Temperature Control for Safety (TCS). This will also reduce the regulatory burden for most bottlers. Records. IBWA strongly opposes the following: • the concept of requiring submission of facility profiles with hazards and controls information • any requirement to provide FDA with remote access to company manufacturing and related records. Both concepts are clearly outside FDA’s statutory authority under

TECHNICAL UPDATE FSMA. IBWA’s opinion is that FDA’s access to company records must be conducted on-site in the course of an authorized inspection, so that FDA may understand the full context of what the records show.

Looking Ahead IBWA has developed comments for two additional FSMA proposed rules: foreign supplier verification programs (FSVP) and third-party accreditation. Comments on those rules are due to FDA on January 26, 2014. We expect FDA to publish two additional proposed rules for intentional adulteration and food testing laboratory accreditation. IBWA will continue to keep members updated on these proposed rules.

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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_ _________________________________________________



State/Province_ _____________________________________________

ZIP/Postal Code_ ___________________________________________

Check your selection for each question


_____ is a measure of hydrogen radical concentration expressed as a number from 0 to 14 and indicates whether the water is acidic or basic (alkaline).


alkalinity pH acidity hardness


FDA’s proposed rule for preventive controls includes a possible requirement for environmental monitoring (EM). The organism(s) most appropriate for EM at bottled water plants is/are _____.


total coliform and E. coli Shigella Listeria monocytogenes and Salmonella Pseudomonas aeeruginosa


IBWA believes that the only way to implement FSMA successfully is to train _____ to ensure consistent enforcement.


third-party audit company personnel FDA and state inspections staffs trade association staffs plant QA personnel


Under the Food Safety Modernization Act (FSMA), HACCP is referred to as _____.


HACCP risk-based preventive controls environmental monitoring risk assessment


The proposed preventive controls rule calls for finished product testing as a means of _____ of the food safety plan.



validation confirmation verification certification



In the IBWA Bottled Water Code of Practice, the IBWA SOQ for perchlorate is _____ due to a state standard enforced in _____.


1 ppb / California 0.5 ppb/ New Jersey 10 ppb / Iowa 2 ppb / Massachusetts


Which of the following is not known to adversely affect the taste and odor of bottled water?

OO amine tastes from anion resins used in ion exchangers OO inadequate flushing of certain cartridge-type filters OO addition of sodium fluoride OO decomposing organic matter


According to IBWA comments submitted to FDA, in conducting a hazard analysis, consideration should be given to the benefits derived from existing prerequisite programs, such as _____.




refers to the tendency of all metals, when exposed to the environment, to revert back to the more stable forms found in the earth’s crust.


Recycling Recovery Corrosion Decomposition


According to the USGS definition, soft water contains less than _____ mg/l of calcium carbonate.


61 17 100 250

CLASSIFIEDS FOR SALE Cap Snap 5-Gallon Water Line, Model ADAPTA-600, New 2001, Decapper, Bottle Washer, Filler, Capper, Conveyors, Boiler. Phone: 860.567.2011, Email:


IBWA Winter Board of Directors and Committee Meetings Hyatt Regency Long Beach Long Beach, California

MARCH 27 - 29

ADVERTISERS Allied Purchasing . . . . . . . . . . . . . . . . . . . . . . . . . 28 Analytical Technology, Inc.. . . . . . . . . . . . . . . . C3 Blackhawk Molding Co.. . . . . . . . . . . . . . . . . . . C2

South Atlantic Bottled Water Association Annual Meeting and Trade Show Pawleys Island, SC

APRIL 9 - 11

Central States Bottled Water Association 6th Annual Convention and Trade Show Ameristar Casino Resort Spa St. Charles, MO

MAY 14-17

Pacific Ozone Technology . . . . . . . . . . . . . . . . . . . . . . 28 PhoneTree. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Polymer Solutions International . . . . . . . . . . . . . . . . . . . . . 15 Sidel. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Tech-Long. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Quality Truck Company . . . . . . . . . . . . . . . . . . 31

Northwest Bottled Water Association Convention & Trade Show Red Lion at the Park Hotel Spokane, Washington

MAY 19 - 21

California Bottled Water Association Annual Educational Conference and Tabletop Trade Show San Diego, CA

JUNE 9 - 12

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

VALUE OF IBWA MEMBERSHIP FELIX GRAHAM-JONES PLANT OPERATOR BERKSHIRE SPRINGS INC. SOUTHFIELD | MASSACHUSETTS ALL ABOUT FELIX Felix’s favorite job tasks are checking the weirs and going up to the spring house. He trained as a dancer at London’s Rambert Ballet School. When not working, Felix enjoys sailing on Twin Lakes in Salisbury, Connecticut. He’s also 11 years into the restoration of a 1947 William Atkins gaff rig sloop.

One consequence of the sweeping changes coming to the bottled water industry under the FDA’s Food Safety Modernization Act (FSMA) is a renewed appreciation for the educational offerings IBWA provides to its members—large, medium, and small. For Felix Graham-Jones, plant operator at Berkshire Springs, Inc., those learning opportunities help him breathe a sigh of relief. He says he is thankful for the Association’s “education and industry-specific training: there is just nowhere else you are going to find [such extensive programming] except IBWA.” Graham-Jones also finds value in the fact that IBWA has established such a renowned certified plant operator (CPO) program. Graham-Jones, who has been with the company since 2002 and worked as a bottled water distributor for 18 years prior to that, describes Berkshire Springs as the tiniest of operations, producing high-quality, bottled-at-the-source water in 3- and 5-gallon reusable containers and 0.5 liter and 20 oz. single-use bottles: “It is a finished product when it leaves the site where it rose.” He asserts that the water rising at the site is reputed as the closest, high-quality spring water commercially available to New York City. “We are low tech, low impact, people centered. Our survival strategies are nimble and sustainable. People are surprised to learn how many people we co-pack for. It surprises people that our single-source product is seen throughout the Northeast: in New York State, from Albany to Long Island. We also co-pack for people in Connecticut, Massachusetts, New Jersey, Pennsylvania, Rhode Island, and Vermont. It’s funny how a single bottling production, which many would see as a limitation, doesn’t seem to be much of a limit to us.” Still, Graham-Jones realizes the company’s small size does present a few limitations: “I don’t have a big picture view of the industry, and this feeds into why I have fought so hard to get Berkshire Springs back into the IBWA fold. It’s because I recognize the depth of support that the Association can offer, even for a tiny operation, in terms of technical, regulatory, and compliance efforts. And [the benefit] of having a forum for exchanging views and cross-fertilization of perspectives” is incomparable.
































Bottled Water Reporter Environmental Sustainability Issue  

Jan/Feb 2014

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