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


IN THIS ISSUE How to Create a What You Hearts-and-Minds Need to Know PR Campaign About FSMA

Why the 2016 Elections Matter


Source Management

The Environmental Sustainability Issue Recycling ALSO:

Container Design

IBWA’s 2015 Annual Business Conference In Pictures Meet Joe Bell: IBWA’s 2016 Chairman A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

VOL. 56 • NO. 1


28 | Politics and the 2016 Elections Matter to Your Business Reviewing the political landscape of the 2016 election year. COMMUNICATIONS

30 | Creating a Hearts-and-Minds PR Campaign on a Budget Introducing bottled water facts into the water scarcity discussion. TECHNICAL UPDATE

32 | The FSMA Preventive Controls Rule: Supply-Chain, Records, and Training Understanding these sections of the PC Rule. VALUE OF IBWA MEMBERSHIP

36 | Bottled Water Born, IBWA Bred IBWA Chairman Joe Bell (Aqua Filter Fresh, Inc.) tells Bottled Water Reporter how he was born into the bottled water industry and how relationships formed through IBWA have helped his family business.

CONTENTS TABLE OF CONTENTS 12 | Water Source Management in the 21st Century Managing your water source in the 21st century is a multifaceted endeavor that requires knowledge of environmental changes, purposeful public outreach and education, and watershed specific actions that can be implemented to assure the protection of your water sources. By Louis F. Vittorio


CHAIRMAN’S COMMENTARY................................2 PRESIDENT’S MESSAGE.......................................4 WATER NOTES.....................................................6 CPO QUIZ..........................................................34 ADVERTISERS....................................................35 CALENDAR........................................................35


20 | Becoming a Greener, Smarter Business Find out how assessing your packaging materials and shipping logistics could decrease your environmental footprint—and save you money too. By Amanda Pike

24 | Challenges to Effective Recycling PET bottled water containers are one of the most recycled products among all consumer goods, but recycling challenges exist. This article details a few simple steps bottlers can take to help improve the quality of recycled PET plastic. By John Standish

BOTTLED WATER REPORTER, Volume 56, 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.


International Bottled Water Association


Thank you to the membership for granting me the distinct honor to serve as your chairman for 2016. I appreciate the opportunity to represent an industry that I’m very proud to be a part of. And why shouldn’t I be proud? We provide healthy hydration in a convenient package that our consumers can use as a vital tool in helping them lead healthier lives. Today, the reasons to drink more bottled water have never been more apparent. Statistics published by the Center for Disease Control and Prevention state that 69 percent of U.S. adults (20 years old or over) are overweight—and 35 percent of those people are obese. For children, the news isn’t much better: 20 percent of kids aged 12-19 and 17 percent of kids aged 6-11 are obese. There’s a health crisis in America, and the bottled water industry has a role to play in promoting healthier lifestyle choices. Fortunately, consumers like bottled water. In fact, they like us so much that we are on track to outpace carbonated soft drinks as the No. 1 packaged beverage by volume by the end of this decade. Why? Because bottled water is a better healthy hydration choice than sugar-sweetened beverages, and it comes in convenient packaging options, perfect for today’s on-the-go society. Still, we know the bottled water industry will face challenges in 2016. One way to beat back any obstacles to our success is to share bottled water’s great story. That’s where IBWA comes in. IBWA’s staff works hard to maintain favorable business, regulatory, and public affairs environments for the bottled water industry, but they can’t do it alone. IBWA needs active members who will serve on committees and task forces; members who are dedicated to sharing bottled water facts with consumers, media, and elected officials; members willing to travel to Washington, DC, to educate members of Congress about industry issues; members who are willing to invest a little time to advance IBWA’s mission of championing bottled water. I challenge all of you to make a visit to Capitol Hill and meet with your representatives. Don’t just wait for IBWA’s Hill Day in June. Your individual impact of making multiple trips to Washington, DC, will keep our message fresh and in the minds of elected officials throughout the year. Please let IBWA know if you can participate on any of the following dates in 2016: January 27, February 24, March 17, April 20, June 8 (as part of IBWA’s June Board of Directors and Committee meetings), July 14, and September 13.




Chairman Joe Bell, Aqua Filter Fresh, Inc. Vice Chair Shayron Barnes-Selby, DS Services Treasurer Lynn Wachtmann, Maumee Valley Bottlers, Inc. Immediate Past Chairman Bryan Shinn, Shinn Spring Water Company

BOARD OF DIRECTORS Shayron Barnes-Selby, DS Services Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America Andy Eaton, Eurofins Eaton Analytical Brian Grant, Pure Flo Water, Inc. Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Greg Nemec, Premium Waters, Inc. Bryan Shinn, Shinn Spring Water Company Robert Smith, Grand Springs Distribution Louis Vittorio, Jr., EarthRes Group, Inc. Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chairman Joe Bell, Aqua Filter Fresh, Inc. Shayron Barnes-Selby, DS Services Philippe Caradec, Danone Waters of America C.R. Hall, Hall’s Culligan Tom Harrington, DS Services Henry R. Hidell, III, Hidell International Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

COMMITTEE CHAIRS Communications Committee Damon Grant, Pure Flo Water, Inc. Jane Lazgin, Nestlé Waters North America Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee Philippe Caradec, Danone Waters of America Jeff Davis, Blackhawk Molding Co. Government Relations Committee Shayron Barnes-Selby, DS Services Lynn Wachtmann, Maumee Valley Bottlers, Inc. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, DS Services 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

I hope to see you there.

Joe Bell IBWA Chairman


Learn more about IBWA Chairman Joe Bell and his long history with the bottled water industry by reading this issue’s “Value of IBWA Membership” profile on page 36.

Technical Committee Andy Eaton, Eurofins Eaton Analytical Kevin Mathews, Nestlé Waters North America

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Promoting an environmentally responsible and sustainable industry is so important to IBWA that it’s part of our mission statement. In this issue of Bottled Water Reporter, we present articles that offer insight into how bottled water companies can continue to improve their environmental footprints. According to the U.S. Geological Survey, the bottled water industry uses less than 0.011 percent of all water used in the United States. Our critics, however, seem not to believe the research because they often attempt to blame bottled water for water scarcity issues, as was recently seen in California. As the news will continue to focus on environmental changes in 2016, our first feature, “Water Source Management in the 21st Century” (p.12), reviews the many factors that have an effect on groundwater sources and presents watershed protection measures that you can implement to ensure the long-term viability of your water sources. In “Becoming a Greener, Smarter Business” (p.20), we address the fact that bottled water is sometimes mistakenly viewed as a product with a large impact on the environment. Research shows, however, that bottled water actually has the smallest environmental impact of any packaged beverage. This article emphasizes the importance of having data to refer to when making environmental sustainability claims—and encourages IBWA bottlers to participate in our life cycle assessment study planned for 2016. Everyone can recycle their empty beverage containers to help lower their personal environmental footprint, but bottlers have an opportunity to make an even greater impact on the recycling process. Bottlers can design plastic containers that will have a positive impact on the quality of recycled PET produced—plastic that will go on to be used not only in rPET bottles but also in fibers to make rPET fabric. Those decisions are detailed in “Challenges to Effective Recycling” (p.24). This issue’s Government Relations column (p.28) reviews the 2016 political landscape as we move into this election year and encourages all IBWA members to get involved in the political process. In Communications (p. 30), we review the positive impact IBWA’s Hydrate California campaign had on ensuring that facts about bottled water were inserted into coverage of the state’s 2015 drought. Finally, the Technical Update column (p.32) continues to focus on the Preventive Controls Rule of the Food Safety Modernization Act (FSMA), this time reviewing sections of the final rule that deal with the supply-chain programs, recordkeeping requirements, and new regulations for training. I hope you enjoy the articles in this issue of Bottled Water Reporter. Please let us know if you implement any of the suggestions outlined in this issue. We’d love to hear from you.

IBWA President 4




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 Communications Chris Hogan Vice President of Government Relations Kristin Pearson Wilcox Chief Financial Officer Michelle S. Tiller Director of Conventions, Trade Shows, and Meetings Michele Campbell Director of Government Relations J.P. Toner Director of Science and Research Vacant Manager of Publications and Special Projects Sabrina E. Hicks Manager of Member Services Vacant 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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A Picture (Online) Is Worth a Thousand Words IBWA has created a series of online images and infographics that members can easily use to visually promote important bottled water messages. Called “social media posters,” these educational materials resemble classic public service posters that convey a single, important message. Members can find the collection of posters on the Image Library of IBWA’s website: IBWA members are encouraged to download the images and use them with their efforts to promote bottled water facts on social media (Facebook, Pinterest, Twitter, Instagram, etc.). The posters highlight the positive role of bottled water in the areas of healthy hydration, recycling, convenience, and cognitive performance. These great visuals aren’t meant to live solely on the Web. One IBWA member company recently requested high-resolution versions of a few posters and infographics and printed them out to use at a public event. If you have similar needs, contact IBWA Vice President of Communications Chris Hogan:


Clay Bell Named President of the Southeastern Bottled Water Association On November 16, 2015, the Southeastern Bottled Water Association (SEBWA) announced that Clay Bell, vice president and general manager of Melwood Springs Water Company and former first vice president of SEBWA, assumed the office Clay Bell of president of the board of directors pursuant to SEBWA bylaws upon the resignation of former President Glen Sanders (DS Services of America). Remarking on his new position, Bell said, “I am honored to lead [SEBWA] forward, working closely with the board of directors, to provide value-added benefits and services to our members and support for our industry. I encourage all our members to join a committee and work together to move the bottled water industry in the Southeastern region forward.” Bell oversees daily operations and sales for the Melwood Springs’ Blue Ridge, Georgia facility. His experience includes 32 years in the beverage industry with Shasta Beverage, Pepsi Cola, and Melwood Springs. He is an IBWA member and a certified plant operator (CPO) and has previously served on the SEBWA board as a board member, second vice president, and first vice president. He lives in Blue Ridge with his wife, Tamme, where they enjoy their animals and the outdoors. For more information about SEBWA, go to


DWRF Thanks Its 2015 “Keys for a Cause” Sponsors

The Drinking Water Research Foundation (DWRF) held its “Keys for a Cause” fundraiser at Bobby McKey’s Dueling Piano Bar in National Harbor, Maryland, on November 2, 2015. The event was held as part of the 2015 IBWA Annual Business Conference. As the only dueling piano bar in the Washington, DC, area, this venue offered a unique entertainment experience: two piano players worked as teams, taking song requests and keeping the crowd singing. At the end of the night, DWRF administrators used the admission tickets from the 80 guests to raffle off terrific prizes for three lucky winners. It was a wonderful evening and could not have happened without the support of DWRF sponsors and guests. All money raised during the 2015 fundraiser will go toward helping to fund vital research impacting the future of the bottled water industry.




DWRF would like to thank the following event sponsors: Platinum Sponsors

Gold Sponsors

Silver Sponsors



IBWA Hosts Successful Environmental Sustainability Education Tour Group, a conventional redemption center that collects plastic, aluminum, and glass for redemption; Big Deal Supermarket, where the process of reverse vending systems was described; PolyQuest Recycling in Long Island, where participants observed how the company processes PET material and converts it into clear flake for postconsumer or post-industrial usage; and Sims Recycling’s Sunset Park Material Recovery Facility, a state-of-the-art facility that recycles curbside commingled material from the New York metro area. In addition to touring the facilities, IBWA President Joe Doss briefed attendees on IBWA’s environmental goals, the challenges the bottled water industry faces in accomplishing those goals, and the many studies IBWA has undertaken that help to

IBWA Environmental Sustainability Tour participants at the DRC Group facility.

provide the facts about the bottled water industry’s very small environmental footprint. A dinner was hosted by Sustainable Decarbonization Services (SDS), a company that provides recycling services, where attendees heard from a representative of Philadelphia-based American Box and Recycling Company, “the nation’s largest supplier of once used boxes.” IBWA would like to thank all attendees who participated in this event, as well as the New York facilities that hosted tour attendees. In


IBWA Infographic Shows Bottled Water Containers Have Small Landfill Footprint

IBWA has published an infographic showing that bottled water containers make up just 3.3 percent of all beverage containers in landfills. On social media and in the blogosphere, reports continue to errantly perpetuate the idea that bottled water packaging is clogging up U.S. landfills. IBWA decided to put bottled water packaging to the test, comparing our packaging, side-byside, against the other most common types of beverage container packaging. Research shows that bottled water containers, measured in tons of landfill space, make up just 3.3 percent of all beverage containers that end up in landfills. The waste percentage numbers are much higher for other items that end up in landfills, e.g., glass (66.7 percent) and soda bottles (13.3 percent) and aluminum cans (7.9 percent). Visit to read the press release IBWA issued when the infographic was published. For more details, read “What’s Really Clogging Up the Landfills,” in the Nov/Dec 2015 issue of Bottled Water Reporter magazine:

addition, a special thank you to PolyQuest Recycling for providing boxed lunches, to SDS for sponsoring the dinner reception, and to Environmental Sustainability Committee member Phyllis Rokus for helping IBWA organize such a successful and educational event. If you are interested in attending an environmental sustainability tour in 2016, please inform IBWA Vice President of Education, Science, and Technical Relations Bob Hirst: bhirst@

Re-think Your Drink Packaging & ALWAYS Recycle!

Did you know almost 70% of what people drink these days comes in a package?

Drink Packaging in U.S. Landfills (in tons as a % of all packaged beverages)

Nearly all drink containers are easily recyclable, yet 10 million tons were not recycled last year. And despite what some people hear about bottled water containers filling up landfills, PET bottled water containers make up only a small percent of all drink packaging that isn’t recycled. Here’s a look at the environmental impact of the eight most common drink packages.

Aseptic Box


Foil Pouch


Sources: Container Recycling Institute, 2013; Beverage Marketing Corporation, 2011; and National Association for PET Container Resources, 2011

The(in 8 most common DR IN K packages order of overall environmental impact, rom most to least*) HDPE Common containers: Nalgene, juice, milk & water jugs.


Aluminum Can Common drinks: soda, beer and juice.






252.8 g Glass Drink containers: soda, beer & wine bottles. 23.9g PET Plastic (carbonated drinks) Same as bottled water but weighs more due to strength demands of carbonation. 30g Gable Top Carton A layer of cardboard sandwiched between two very thin layers of plastic.

Aseptic Box Made from multiple laminated layers: plastic, paper & foil.




591 83.6


889 28.0






5g Foil Pouch Multiple layers of different types of plastics and aluminum all laminated together.



218 22.0

9.9g PET Plastic (bottled water) 61.4% 262 Stands for “polyethylene terephthalate” - a form of 12.0 polyester.

BTUs / container - BTUs are British Thermal Units, a unit for measuring energy use. Figures show how many BTUs are used to make one container – averaged from all sizes within container type. Metric Tons of CO 2 equivalent /1,000,000 containers - The amount of greenhouse gases emitted by producing 1,000,000 containers. Percentage of packaging “landfilled” instead of recycled. Not all beverage packaging is recyclable.



Packaging weight in grams (average weight for a single serve container.)

Have you ever been curious about what really happens to PET bottles after they have been recycled? On October 19-20, 2015, 12 IBWA members and staff had the opportunity to find out when they participated in a oneand-a-half day tour and educational recycling program. The tour focused on redemption facilities and processors of recyclable materials in the New York metro area, with an emphasis on how PET is separated from other materials and eventually reused for other products, including rPET bottles. The educational tour began at Arbor Recycling in New York City’s Bronx borough. This large pick-up agent receives plastic and aluminum recyclables from redemption centers and then bales the material. Tour participants also visited DRC

Least environmental impact!

Sources: U.S. Department of Agriculture (Food Surveys Research Group), Container Recycling Institute, PET Resin Association, Beverage Marketing Corporation, National Association for PET Container Resources, International Bottled Water Association, Planet Ark,, Recycle USA Inc., and the Glass Packaging Institute * Using 2010 data

JAN/FEB 2016




Kim Knoll, Joe Cimino, Ross Rosette, Allen French, Debbie Martinez

IBWA President and CEO Joe Doss, IBWA Immediate Past Chairman Bryan Shinn, IBWA member Phyllis Rokus, Rep. Keith Rothfus (R-PA), IBWA Chairman Joe Bell, IBWA Vice Chair Shayron Barnes-Selby, and IBWA Board Member Lynn Wachtmann

Learning and Networking at IBWA’s 2015 Annual Business Conference Christina Hecht, PhD, senior policy advisor at the Nutrition Policy Institute, University of California

More than 1,100 people attended the 2015 IBWA Annual Business Conference and Trade Show, which was held November 2-5 at the Gaylord National Resort and Convention Center, near Washington, DC. IBWA co-located its conference with NAMA’s CoffeeTea&Water show—a partnership that offered an expanded educational program focusing on issues important to the bottled water, coffee, and tea industries. IBWA’s education sessions included workshops on the regulations being implemented as part of the U.S. Food and Drug Administration’s Food Safety Modernization Act (FSMA). Other course offerings presented the latest information available on sales trends, healthy hydration, environmental sustainability, recycling,

IBWA Vice President of Technical Relations Bob Hirst (left) and Joseph Levitt, Esq., lead a FSMA education session.

Lou Vittorio (center) with Janis and Felix Graham-Jones


Chairman Joe Bell addressed the membership during the General Session.

Jack West and Steve Edberg, PhD, enjoying the DWRF fundraiser.


Mitch Turnipseed, Bill Saxman, and Todd Price

IBWA President Joe Doss

Kelley Goshay, Andy Eaton, Terry Clark, and Shayron Barnes-Selby

workforce issues, and plant procedures. IBWA was also honored to have special guests during committee meetings, e.g., Rep. Keith Rothfus (R-PA); Christina Hecht, PhD; and Harold Goldstein, DrPH. Learning continued on the trade show floor, where 142 supplier companies showcased their products and services. Attendees enjoyed talking face-to-face with exhibitors, as well as the chance to taste some of the new coffee and tea products on the market. Networking occurred not only on the trade show floor but also at organized activities, such as the IBWA/NAMA Welcome Reception, the Drinking Water Research Foundation’s “Keys for a Cause” Fundraiser at Bobby McKeys Dueling Piano Bar, and, for the first time ever, a walk/run fundraising event. This year, IBWA will hold its annual business conference at the Gaylord Opryland Hotel in Nashville, Tennessee, November 7-11. IBWA hopes you plan to join us there for more learning, networking, and fun!

Keynote Speaker Trevor Butterworth, director of Sense About Science USA

DWRF’s “Keys for a Cause” Fundraiser

Immediate Past Chairman Bryan Shinn shares a joke with Chairman Joe Bell.

Viola Jacobs, Sophia Liang, Linda Geddes

Immediate Past Chairman Bryan Shinn JAN/FEB 2016 • BWR • 9


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CLIMATIC CONDITIONS, INCLUDING DROUGHTS AND GLOBAL WARMING CONCERNS, CONTINUE TO BE FEATURED ON THE NEWS AS DEVELOPMENT PRESSURES INCREASE FROM POPULATION GROWTH. That’s especially true in the Southwest region of the United States, where Census data shows that region has been experiencing significant growth over the past decade. In addition, the sustainability of agricultural withdrawals and the expansion of the oil and gas industry into areas not previously known for fossil fuel extraction have added to concerns over the protection of water quality and quantity. Increasing regulations and public perception of those issues has made source expansion and new source development increasingly difficult. This article briefly reviews these issues and presents watershed protection measures that owners and managers can implement to ensure the long-term viability of their water sources.

Climate and Precipitation Changes Since then-Vice President Al Gore first championed the cause of global climate change in 1993, hardly a week has gone by without an article on the subject in the mainstream news media. But what does global climate change mean for your water source? The “Climate at a Glance” page of the National Oceanic and Atmospheric Administration’s (NOAA) website ( provides an overview of precipitation and temperature data across the United States for the past century, dating back to about 1895 when climate records at numerous U.S. stations began being collected. As a geologist, I’m a bit wary of the short-term nature of the data set and conclusions that the data points to manmade global warming. I am quite certain that the one-mile thick ice sheets that existed 10,000 to 15,000 years ago, which sculpted the Great Lakes, New England, and Long Island, were not melted by industrial smoke stacks. Nevertheless, the earth’s climate is changing as it has done many times in the past, and the reliable NOAA data set shows that the United States has been getting warmer and wetter

over the past 120 years. Data extracted from NOAA are presented in Table 1 for the nine U.S. climatic regions. (See page 14.) Areas of the Western and Southwestern United States are the exception; they are warming and showing a drying trend. Why is that important? Because the desert West has experienced population growth during the past several decades and, therefore, water development pressures have increased as well. Figure 2 presents data from the Northeastern United States and shows similar trends in other U.S. regions. However, the increase in precipitation in the Northeast during the last century is significant at 9.8 percent. Looking at the Northeast climate data, you can see the Dust Bowl droughts of the 1930s and the significant drought experienced in the 1960s. Also evident is an increasing trend in precipitation and anomalous annual changes since the 1970s. Overall weather patterns (on an annual basis) appear more extreme, and rainfall events have increased in intensity. That is shown in the data most recently from 2011, when several major storms provided up JAN/FEB 2016







SINCE 1895











































Source: “Climate at a Glance” page of NOAA Website:


Source: Karl and Koss, 1984; 14





Source: “Climate at a Glance” page of NOAA Website:

to 20 inches of rain in late August and September of that year, setting records for those months and subsequently making 2011 the wettest year on record (over 56 inches of precipitation, which is approximately 14 inches above normal). More recently, areas of Charleston, South Carolina, experienced severe flooding, receiving up to 24 inches of precipitation over a five-day period in October 2015. Weather experts have labeled that occurrence as a 1,000year storm (indicating the probability of its recurrence). The Southwest and West are the only two climate regions in the continental United States that have experienced a decrease in average annual precipitation over the past 120 years. However, the observed decrease in precipitation during the last century is between 0.8 percent and 1.5 percent. In the Western United States, including the states of California and Nevada (Figure 3), annual precipitation has always been significantly less than in the midwestern and eastern regions of the United States, receiving approximately 17 inches of annual precipitation. The pattern of more extreme events is also noticeable since 1970, culminating in the current and significant drought being experience in California. Overall, the trend in precipitation is flat, showing a decrease of 0.13 inches per century. This year, a stronger-than-average El Niño is predicted that will likely ease the drought conditions. However, with the predicted rainfall may come flooding and

landslides, as observed during the El Niño events of 1983 and 1998. Those events are easily discernible on Figure 3 as anomalies of increased precipitation.

Water Source Management Due to changes in climate and precipitation, water source managers will be faced with potential source changes and/or depletion. Sources for bottled water should be developed in full consideration of drought conditions to ensure that investment in the source is realized over a long term, as peak source use typically corresponds with drier and hotter summer months. Based upon bottled water use data and in comparison to provided U.S. Geological Survey (USGS) water use statistics (, the overall use of water sources for bottled water products is actually insignificant when compared to agricultural, industrial, recreational, and potable uses. Still, the drumbeat of climate change and environmental awareness in the media continues to bring bottled water use inexplicably to the forefront, as seen recently in California. In this “climate,” a public relations campaign is a key part of water source management. Providing quick access to data and ready answers to consumers is crucial. Industry groups (such as IBWA and the Drinking Water Research Foundation), the USGS, and regional water JAN/FEB 2016




Source: “Climate at a Glance� page of NOAA Website:

authorities are clearinghouses for useful information to share, including water use statistics. Although the NOAA data show an overall increase in precipitation (and subsequent source water recharge) is occurring, the extreme swings in precipitation can be problematic to water source managers. Higher intensity precipitation events, which have been realized during the past 40 years, can result in increased turbidity for spring and borehole sources. Flooding and erosion from those events may manifest in short-term surface water influence and water quality problems. In springs and boreholes sourced in carbonate aquifers, sinkhole development typically occurs after high-intensity rainfall events. Sinkholes near a spring source can open pathways for contaminants and sediments to enter the aquifer. Managers of sources in coastal areas need to be cognizant of sea level rise due to climate change; however, a more immediate and pressing problem to consider is seasonal aquifer overuse. During the summer months, coastal populations in resort areas grow significantly, causing peak water demands and decreasing aquifer levels. The potential for salt water encroachment is increased at such times and sentinel well monitoring (discussed later in this article) may be a prudent source management option. 16



Despite the very small use of fresh water sources for bottled water products, the development of new sources in the West and Southwest is problematic due to the lower precipitation amounts, competition for available resources, and declining water levels. In the Northeastern United States, where increased precipitation recharge is favorable for source development and longevity, there is also an increasing population and numerous regulations to navigate in order to bring a new source to the market. Therefore, water source conservation and protection should be vital components of any source management program to help ensure the viability of sources into the future.

Water Source Conservation and Protection Measures In light of the changes described above, water source conservation and protection measures are vital to maintain or develop additional sources. Many of those measures can be gleaned from public well and watershed protection programs enacted by water authorities and regional water management authorities. While such programs, and the funding for them, are usually not available to sources used for bottled water products, the following practices can, and should, be implemented to protect your sources and long-term investments.


Delineating your water source recharge area. The first step is to know and learn as much as possible about the watershed from where your water is sourced from precipitation recharge. In general terms, your watershed can be determined by the “Water Drop Method,” which is illustrated below (Figure 4). Rain falling on the ground surface (water drops) will flow overland based upon topography and downslope toward a source. Alternatively, rain falling on areas across a topographic divide will flow away from and not contribute to source replenishment. As shown in Figure 4, all water drops falling within the marked boundary of the topographic divide ultimately discharge from the basin as surface and groundwater flow. There is a continual cycle of recharge in and water flow out of a basin. In general, the surface water basin of a source will correspond to the groundwater basin, although out of basin groundwater inflow is not uncommon and should also be assessed. Data used to identify the topographic divides surrounding both a source and watershed may already be publically available to download through geographic information system (GIS) database servers. You can also delineate the watershed yourself using a topographic map to draw lines connecting the elevated ridges that surround your site.

Identify and prioritize all potential contaminant sources and development threats. Once a watershed has been delineated, evaluate the land uses surrounding a source and assess potential sources of contamination due to that land use. Allowable land uses can be determined from zoning maps available from the local municipality. You should also conduct a public database search to determine potential sources of contamination that may exist (e.g., leaking tanks, industrial sites, etc.). Several Internet services can be used to accomplish that analysis, ranging in costs from free to approximately $200 (e.g.,,, or The U.S. Environmental Protection Agency (EPA) provides free online tools that enable you to “surf ” your watershed and assess potential impacts (e.g., cfpub. and Various states have similar online tools for assessment, and you may also find that your water source is located within a public watershed that has a published well head protection program. If potential sources of contamination or contrary land uses are found, you should engage the local authority and regulators to see what can be done to protect your source.

Delineation of well head protection zones and implementation of site controls. On your site, you control what is directly near your spring and borehole


Assessing your watershed enables you to make sound management and investment decisions toward long-term source protection. Source: Modified from

JAN/FEB 2016



The overall use of water sources for bottled water products is insignificant when compared to agricultural, industrial, and potable uses.

Source:, based on USGS and Beverage Marketing Corporation data

source. It is recommended that site activities and land disturbance be minimized in those areas. A buffer around a borehole or spring—a place where no activity, development, or potential contaminant sources should be located—is typically 400 feet in radius. Larger well head zones provide water flow to your source beyond this buffer (e.g., zones of recharge, contribution, and capture), and those zones should be determined by your water source professional to enable sound land use and planning. Enhanced monitoring and sampling. Upon assessing your watershed, you may wish to consider enhanced water quality sampling or installing perimeter monitoring wells. Evaluating how your source responds to seasonal rain events and determining if potential contaminants are coming on to your site may be desirable based upon your findings. Coastal water sources may be susceptible to sea level rise and seasonal aquifer overuse. Source managers in those areas may decide to install sentinel wells to measure water level and salinity trends surrounding their sources. Knowledge of potential impacts before they happen will allow time to implement contingency measures, if necessary. Erosion and sedimentation evaluation. With the increase in the intensity of storm events as previously discussed, managers should evaluate the runoff effects in the basin due to storm events. You can do that using watershed computer programs and by observing your 18



basin (from the safety of your car) during storm events to evaluate stormflow and runoff. Questions to ask during such events include the following: Where are sediment and/or muddy waters crossing your site? Are storm drains and road culverts effective in controlling storm flow? Is runoff from an upgradient site particularly noticeable? Is flooding a problem? Is runoff effectively captured or diverted off of your site? Choosing and implementing management and protection strategies. Upon completing the assessment of your watershed using the above steps, you will be better able to make sound management and investment decisions toward long-term source protection. Strategies to consider may include the following: •

Limit site development to limit activities and improve stormwater management near your borehole or spring.

Develop a program of enhanced monitoring and sampling that will provide fair warning and enable implementation of contingencies to protect your source.

Develop an outreach and education program geared towards the public, local businesses, and elected officials.

Affect changes to future zoning and land use. Forming and/or or sitting on a local watershed advisory committee with other area stakeholders is a good way to keep abreast of ongoing development and activities in your watershed.


public outreach and education, and watershed specific actions that can be implemented to assure the protection of your water sources.

Engage with public officials to abate any potential threats of contaminants identified in your watershed evaluation.

Develop a local road signage program (which will likely entail approval from the municipality) to raise awareness of watershed protection.

Purchase additional properties within crucial areas of your watershed to enable increased protection of your source.

Develop contingency plans to be used in the event of an area spill or release, or when monitored water quality data signifies the need for action to protect your sources.

Throughout this process, you should be assessing the potential threats to your sources and subsequently determining how to rank and address those threats in a timely and cost-effective manner. Overall, management of your water source into the 21st century is a multifaceted endeavor that requires knowledge of environmental changes, purposeful

Louis F. Vittorio, Jr., P.G., vice president of EarthRes Group, Inc. and an IBWA board member, received his B.S. in geology/geophysics from the University of Pittsburgh and his M.S. in geology from Lehigh University. He has more than 20 years of experience in the bottled water industry, and his education and experience have enabled him to integrate geological, hydrogeological, and geophysical investigations targeted at spring and groundwater resource development and sustainability. He has served as an expert at local hearings related to water extraction and has provided expert testimony for numerous water related projects.

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JAN/FEB 2016





HOW ASSESSING YOUR PACKAGING MATERIALS AND SHIPPING LOGISTICS COULD DECREASE YOUR ENVIRONMENTAL FOOTPRINT—AND SAVE YOU MONEY TOO The important role bottled water plays in supporting a healthy lifestyle is well documented, but factual and researched material available about the product’s effect on the environment is less available. As the water industry has increasingly come under scrutiny regarding the environmental impact of its products, having research to refer to when making environmental sustainability claims is invaluable. Bottled water professionals can use that information 20



to communicate to interested parties the care and concern the industry takes to support productive interactions between their businesses and the environment—and also help ensure a good public image. Industry should take advantage of opportunities to improve any environmental impact that occurs in the bottled water system and learn how to translate those improvements into effective messaging.

Most people are familiar with the term “sustainable” and can broadly define the term, but what does it mean to be sustainable and how does an industry get there? How can bottlers make decisions that move them in the right direction? That is a more challenging question. Oftentimes, the answer is to consider certain attributes of a product or system that are in some way considered synonymous with sustainability: biodegradability, recycled content, bio-based, energy efficient, etc. While there may be some environmental benefit to those characteristics, they say nothing about actual “impact” on the environment. To answer the question of sustainability, it is important to quantify all of the environmental processes (impacts) rather than just looking at an attribute (e.g., recyclability). It is also important to consider the whole system—not just what we see at face value. That is where life cycle analysis and life cycle thinking (LCT) can play an important role.


Defining LCA and LCT

It is important to quantify all of the environmental processes (impacts) rather than just looking at an attribute (e.g., recyclability). additional production of electricity, which in the United States typically means greater use of fossil fuels. Conducting an LCA would allow you to understand the trade-offs between electric and conventional cars.

The benefit of using a life cycle approach means that negative impacts are minimized while avoiding the transfer of those impacts from one life cycle stage to another. When applied to product


LCT takes a holistic view of the production and consumption of a product or service and assesses its impacts on the environment throughout the entire life cycle. At each life cycle stage, there is resource and energy consumption, as well as pollution to the natural environment, that creates impacts from cradle to grave. Life cycle assessment (LCA) is a rigorous, quantitative approach to catalogue those impacts at each stage of the life cycle and can be used to both understand the impact of a given product and make comparisons between products. Take, for example, the electric car. If you are interested in decreasing your personal environmental footprint, it appears to be the better car choice because tailpipe emissions are minimized. However, it also requires

Proportion of beverages by volume consumed by the typical American consumer and percent contribution to the climate change impact from beverage consumption. Beverages with a disproportionately large contribution impact relative to volume and shown with red lines and those with a smaller impact are shown with green lines.

Source: Quantis, JAN/FEB 2016



IBWA’s 2009 life cycle assessment provides a roadmap for the best strategies to help reduce the impact of your bottled water products until the 2016 assessment is published. design and decision making, LCT is a beneficial strategy for crafting and implementing successful sustainability strategies, as well as communicating them to others.

Reducing Environmental Impacts—and Documenting the Change Bottled water is sometimes mistakenly viewed as a product with a large impact on the environment; however, research has shown that bottled water has the least impact of any packaged beverage relative to volume. (See Figure 1 on page 21.) In addition, bottled water manufacturers continuously work to improve the environmental aspect of their products. Finding the right strategies for shrinking the environmental footprint of bottled water products requires a good understanding of where those impacts occur and investigating what the potential options are for mitigating them. In 2009, IBWA conducted an LCA of the bottled water industry to understand and set a benchmark for the environmental footprint of bottled water products sold on the U.S. market. That work is currently being updated with an intention of publishing results in 2016. Although the industry’s new LCA is still in progress, IBWA’s 2009 LCA and several similar assessments made by

others provide a roadmap for the best strategies to help reduce the impact of bottled water products. Due to the large amount of variation in the bottle water market, the relative importance of, for example, packaging to manufacturing to transportation will vary from one product to another. However, the range of LCAs conducted on bottled water products agree that, in most cases, the packaging and transportation combine to create most of the environmental impact of those products. If we track pollutants (e.g., greenhouse gases at each stage of the product life cycle), we find that most emissions usually occur when producing the materials for packaging and when shipping the water to market. Of course, both are highly variable: there are a wide range of packaging options on the bottled water market and the distances products travel to reach U.S. markets vary greatly. By focusing on these two areas, we can implement improvements that may have the biggest impact.

Focus on Packaging When evaluating packaging, you have two main considerations: what material to package the water in and how much of the material to use. It makes no sense to try to reach such conclusions as “glass is better than plastic” or vice-versa without first considering the context of

If you are a bottler and you are interested in participating in the 2016 IBWA Life Cycle Assessment for the North American bottled water market, or would like to learn more, please contact 22



how much is used in a given application. Material comparisons can be challenging, especially given the typical bottle weights used in bottled water and other beverage products. Most LCAs have found, however, that PET bottles will allow for a lesser footprint than glass in bottled water products. Regardless of the type of material used, a consistent strategy for improving environmental performance of packaging (and usually reduce cost) is to reduce the amount of material used. Selling a 500ml bottled water in 10 grams of PET will have a much lesser impact than in 20 grams of PET. Regardless of what your packaging format currently is, it is worth exploring whether some of the weight can be taken out without sacrificing integrity. You have other elements to consider when developing your packaging. New options are increasingly available for materials that are able to be recycled or for plastics that are derived from plant matter (rather than petroleum). When considering the wide range of materials available for packaging your bottled water product, it can be useful to refer to existing LCA information or consult an expert in this field for advice. Even though some materials might have a “green” sounding tagline, they may not present a better overall profile than more traditionally used materials like PET, which has the advantages of being able to be used in very light weights for bottle applications and is accepted by recycling programs throughout the country.

Focus on Shipping In addition to packaging, how far any product travels to enter the market has a major impact on its overall environmental footprint. Less is obviously better when discussing distance traveled, and any miles that can be shaved off of transport routes saves on not only fuel costs

Regardless of how far the product is shipped, you may find some improvements in shipping efficiency. If working through a carrier, ask what that company is doing, or has done, to improve the efficiency of its transportation. If managing your own fleet, look for ways to improve fleet efficiency. The U.S. Environmental Protection Agency’s SmartWay program ( is an excellent resource. As described on its website, “SmartWay aims to accelerate the availability, adoption and market penetration of advanced fuel efficient technologies and operational practices in the freight supply chain, while helping companies save fuel, lower costs and reduce adverse environmental impacts.” It presents a lot of great information about best practices in routing and shipping. Many companies have found that joining programs like SmartWay can help them improve efficiency. In addition to getting the most efficiency from each mile transported, many companies are finding hidden ways to reduce transport miles by finding creative ways to reconfigure their distribution network. Innovative companies are also working with other companies that share common distribution legs and are sharing space on vehicles traveling at less than their full capacity.

Importance of Plant and Market While packaging and shipping are the major areas of environmental impact for the bottled water industry, that doesn’t


but also the emissions from the fuel. The U.S. bottled water market includes products that are bottled and shipped regionally, perhaps averaging 500 miles or less, as well as products that are bottled overseas, brought thousands of miles by ocean freight, and then hundreds or thousands of miles by truck. Clearly, looking for options to bottle domestically, and regionally where possible, will have a large effect on the environmental performance of the product.

Many companies have recently moved to on-site renewable energy (e.g., solar or wind power) or renewable energy purchasing agreements. mean you can ignore what happens within your facilities. Continuous efficiency improvement efforts in your manufacturing might allow for less energy and material use in activities such as filtration, bottling, and material handling. Look for opportunities to discuss with peer companies about where they’ve had success. Many companies have recently been moving aggressively to on-site renewable energy (e.g., solar or wind power) or renewable energy purchasing agreements. The solar and wind options have become increasingly cost-competitive in recent years. In fact, new businesses have entered the market that make adding those technologies on-site easier because they manage the installation and maintenance efforts through innovative business models. Mars, for example, has invested heavily in a renewable energy project that will soon provide all its U.S. electricity needs. Such deals are now being viewed as good economics, in addition to having environmental benefits. The final stages in the cycle of environmental impact occur at the retailer and with the consumer. In addition to energy that might be

used to chill or store the product, the consumer has the very important role of managing the bottle they purchase. Packaging litter is clearly the most visible way that bottled water effects the environment—the same is true for all beverages packaged in recyclable materials. Manufacturers need to work with consumers and their communities to ensure that bottles not only make their way into the waste stream rather than the streets and forest, but hopefully that an increasing number of bottles make it into the recycling stream to take on another life as a new bottle or other product. In addition to telling the consumer about the strides you are making on the environment, it is important to also remind them to do their part by making sure their bottle finds its way into the recycling stream. Amanda Pike is the director of U.S. operations at Quantis. She works with a wide range of leading companies, governments, and industry associations to put meaningful and credible metrics and insights behind their sustainability work. Contact her at amanda.

About Quantis Quantis is a global consulting team that focuses on helping clients put metrics on sustainability and translating those into meaningful action. The company works with a wide range of leading private sector companies, as well as governmental authorities and not-for-profit organizations, and has been supporting IBWA members in their sustainability efforts for a number of years. Quantis combines globally-leading expertise on the topic of life cycle assessment and footprinting with outstanding communications, strategy, and client delivery work to provide successful solutions. For more, visit

JAN/FEB 2016



Challenges to Effective Recycling* By John Standish

Polyethylene terephthalate (PET) bottled water containers are one of the most recycled products among all consumer goods, but recycling challenges exist. As bottled water producers, there are a few simple steps you can take to help improve the quality of recycled plastic. To understand how the decisions that bottlers make about container design affect recycling, you must first be familiar with the recycling process.


* This article is based on the transcription of John Standish’s “Challenges to Effective Recycling” November 3, 2015, education session, presented during the 2015 IBWA Annual Business Conference.

The Importance of Label Design to rPET

When PET plastic beverage bottles reach a recycling facility, one of the first steps in the recycling process is for the bottles to go through the granulator. This is a big machine that grounds up bottles, labels, and closures into flake. In the recycling world, “flake” is the commonly used term to describe the pieces of plastic that result from grinding up recycled bottles.

Label design is hugely important to the recycling process, so you want to use labels that are recycle-friendly. If you are involved in designing or purchasing labels for your PET water bottles, here are a few questions you should ask your label suppliers:

A granulator works at high speeds and can grind down about 6,000-7,000 pounds of plastic bottles per hour. It is a complex, high-volume process. After the recycled bottles, labels, and closures are ground into flake, that flake goes into a wash tank. In the wash tank, recycled material is washed in water at temperatures of 85-95 degrees centigrade under a high degree of agitation and friction. (Remember: water boils at 100 degrees centigrade.) The flake then passes into a big tank of water called a float/sink tank, which is a remarkably simple, but important, step in the recycling process. Because PET is more dense than water, PET flake sinks to the bottom of the float/sink tank. Polyethylene (PE) closures, which are typically used on water bottles, are less dense than water, so PE flake floats in water. Thus, the float/sink tank is the most important tool that a recycler can use to separate the PET (which we want) from the PE. Both PE and PET have recycle value, but we do not want to mix the content. If there’s unwanted material in the flake (e.g., paper fibers), and it isn’t washed off effectively and isn’t adequately separated in the float/sink tank, it becomes a contaminant to the PET and reduces the quality of the recycled PET (rPET). Once PET flake is dried, the unwanted material is trapped in the PET forever as a contaminant. Photo A shows what dried PET flake should look like.

What happens to the ink in your labels when the bottles are recycled? Does the ink stay on the label or does it come off with the wash water?

What happens to paper labels? Does the paper interfere with the recycling process? (The answer is, Yes.) How much does a paper label interfere with the recycling process?

If you use a pressure-sensitive label (a label that has adhesive spread all over the back and is smashed on the bottle), what happens to the adhesive? Does it wash off and separate cleanly from the PET or does that adhesive stay stuck on the bottle, not wash off, not separate in the float/sink tank, and become a contaminant? Will a pressure-sensitive label float or sink in water? Do you have test data that shows the label’s qualities?

Does paper interfere with the PET recycling process? Yes.


The ABCs of Plastics Recycling

The photos on page 26 illustrate how inks wash off of labels. Photo B presents is an image of an ingredients label from a full, shrink-sleeve label removed from a beverage bottle that was exposed to the hot wash solution used during the recycling process. You can barely read the ingredients panel because the ink started flaking off during the wash cycle. Photo C shows a thermoformed PET packaged that has a pressure-sensitive label on it. In the laboratory, we can grind up packages to flake, just like we do during the recycling process. On a laboratory scale, we can subject the flake to a wash cycle and a float/sink process to find out how the label impacts recycling. After this particular pressure-sensitive label goes through the wash cycle, you can see the wash color turns a brownishyellow color (Photo D). Notice how the brownish-yellow color of the wash water looks suspiciously like the brownishyellow ink on the label.

Photo A: PET flake. JAN/FEB 2016



Photo F: Laboratory scale float/sink tank.

Photo E below shows a beaker of water. That is my laboratory scale float/sink tank. You can see that the PET is at the bottom of the water, where it should be. But notice the white particles alongside the PET. That’s the label. The label and adhesive did not cleanly separate from the bottle, so the polyethylene label sinks with the PET. Now, the label and the adhesive become contaminant when that PET is recycled. And the ink, to the extent that it stains the PET and can’t be rinsed out, becomes a source of contamination as well. Above, in Photo F, is another example from my laboratory-scale float/sink tank. This one shows a collection of bottles that had pressure-sensitive labels on them, which have gone through the hot wash step. The good

news about these labels is that the ink survives the hot wash step and has no negative impact on washing. Some of the label has separated and is floating at the top of the float/sink tank—and that’s what you want to see. However, a lot of the label did not separate from the PET. So now, the label, substrate, ink, and adhesive together become a source of contamination for the recycled product.

From a recycler’s point of view, paper labels are very undesirable. If you take bottles that have paper labels, grind them up, and put them through the wash tank (with its 85-95 degrees centigrade wash water), the wood fibers turn into pulp. Notice the beaker on the left in Photo G on page 27. It contains the wash water that results from washing PET packaging with paper labels. That gray mass at the bottom of the beaker is the paper fibers that have turned into pulp in the hot wash system. While wood floats in water, the individual fibers derived from wood to make the paper label are more dense than water and sink.

Are Paper Labels Better?

Photo H on the next page shows the steel grating floor drain of a recycling facility. The big pile of gray matter is paper label residue that has to be regularly cleaned out of the wash tank. That paper residue gets scooped up, put into a dumpster, and is taken to a landfill. What I want to emphasize here is that the labels are not recycled. Currently, there is no such thing as a recyclable label. Most labels end up in landfills.

Some bottlers think that a paper label on a PET package is a good thing for recycling because paper is a renewable material. Wood floats in water, and the label floats in water, so one would think that’s a good thing. But is it? The answer is, No.

Photo I presents four square plaques that are injection molded plaques of polyester resin that would be used to make a PET or rPET bottle. The three injection molded plaques on the bottom are plaques made from PET containers with paper labels. You can see the dis-

Photo E: Laboratory scale float/sink tank. Photo C: Thermoformed PET package.

Photo D: Wash water.

Photo B: Ingredients label.




Forewarned Is Forearmed Every one of the problems mentioned above is preventable. Following are the simple steps bottlers can take to improve the quality of rPET. Step 1. Refer to the Association of Plastic Recyclers (APR) Design Guide for Plastics Recyclability, which is located at As noted in the guide, many single-serve bottles have a wrap-around label that is adhered with just a very thin line of hot-melt glue. This is an APR-preferred design because a minimal amount of adhesive has been used and the adhesive selected washes off cleanly from the PET. Generally, the wrap-around label is a polypropylene label, which will readily float in water. Often, the ink is reverse-printed, which means it is laminated between two layers of plastic. Thus, the ink can’t be exposed to the hot wash water and stain the wash water.

it is used in recycling. You can also ask whether the labels they offer meet APR Critical Guidance Recognition standards. In order to meet APR Critical Guidance Recognition, a company must have tested its material in rigorous, laboratory-scale recycling tests and passed those test successfully. If a company receives this recognition, they can use it on their sales and marketing efforts. Step 3. Avoid paper labels. The APR understands that there are sometimes business reasons for choosing to use paper labels. However, paper labels are detrimental to PET recycling. As a representative of PET recyclers, I have to advise you against using paper labels unless there is some compelling business reason for you to do it. If you must use a paper label, be aware that some paper labels are better than others in the recycling process. The composition of the paper, the composition of the ink, and the composition of the adhesive can be selected to have less impact on recycling than those labels that aren’t tested and developed for good recycling performance. So, find a company that offers better labeling materials.


tinctly darker color and the greater level of haze that results from recycling PET with paper labels. In No. 11, you can see little black specs. Those are thermally degraded paper fibers that couldn’t be rinsed from the PET.

What Is APR? The Association of Plastic Recyclers (APR) is the “Voice of Plastics Recycling®.” As the international trade association representing the plastics recycling industry, membership includes independent recycling companies of all sizes, processing numerous resins, as well as consumer product companies, equipment manufacturers, testing laboratories, organizations, and others committed to the success of plastics recycling. APR advocates the recycling of all plastics. Visit www. for more information.

John Standish is the technical director for the Association of Plastic Recyclers (APR). Contact him at

Step 2. If you decide to use a pressuresensitive label or a sleeve label, ask your label suppliers if they have test data showing the impact of that label when

Photo H: Steel grating floor drain of recycling facility after paper label residue cleaned out of wash tank.

Photo G: Wash water, after washing PET packaging with paper labels.

Photo I: Four square, injection molded plaques used for PET or rPET bottles (top) and three injection molded plaques made from PET containers with paper labels (bottom). JAN/FEB 2016



Politics and the 2016 Elections Matter to Your Business By James Bayot and Nancy McNally

Before Americans rang in the New Year, toasting with a glass of sparkling water, one branch of the U.S. government went through a seismic shift. Congressman Paul Ryan (R-WI) was elected the 54th Speaker of the House of Representatives, replacing Speaker John Boehner (R-OH) who retired in October 2015 due to political strife within the Republican Party. As one of his last legislative actions before leaving office, Speaker Boehner brokered a bipartisan deal to suspend the debt limit and increase the budget caps for federal discretionary spending for two years to prevent a government shutdown. 28



In his new leadership post, Speaker Ryan will shape the congressional agenda for 2016, and he will draw on his experience leading the Budget Committee and the Ways and Means Committee to focus on tax reform, budget issues, and other fiscal policies. His legislative success could impact both the congressional and presidential elections and could be good news for businesses. In other good news, Speaker Ryan is no stranger to the bottled water industry. Last March, he toured the Niagara Bottling LLC bottled water plant in Pleasant Prairie, Wisconsin, and has visited with IBWA Vice President of Govern-

ment Relations Kristin Pearson Wilcox and Derieth Sutton, Niagara Bottling’s director of Economic Development and Government Relations.

House Elections With the presidency and control of Congress up in the air in 2016, election politics will dominate the news cycle, and the bottled water industry needs to know the state of play. All members of the House of Representatives are up for re-election, and Republicans control 247 seats, while the Democrats currently hold 188 seats. Although Democrats are unlikely to

GOVERNMENT RELATIONS win the 30 seats needed to take control of the lower chamber, the Republican majority is expected to shrink. Due to retirements or other House members running for higher office, there are already 27 open seats with more retirements expected in the coming months.

Senate Elections In the Senate, the stakes could not be higher. Republicans have the difficult task of defending 24 seats compared to the 10 seats Democrats will try to protect. In order for Democrats to retake the majority, which they lost in the 2014 election, they need to hold their 10 seats and flip at least five GOP-held seats. Sen. Mark Kirk (R-IL), considered the most vulnerable incumbent, faces a tough race against Congresswoman Tammy Duckworth (D-IL). In a rematch of the 2010 election, Sen. Ron Johnson (R-WI) squares off with former Sen. Russ Feingold (D-WI). Sen. Kelly Ayotte (R-NH) is being challenged by Governor Maggie Hassan (D-NH), and election analysts predict tough re-elections for Sen. Rob Portman (R-OH) and Sen. Patrick Toomey (R-PA) due to increased Democratic voter turnout in Ohio and Pennsylvania for the presidential election. IBWA members will recall Sen. Toomey joined the association at its June 2015 Capitol Hill Day, and he shared his views on the role Congress plays in creating a legislative and regulatory environment that encourages the growth of business and protects consumers. Even if Democrats win these hotly contested seats, they would need to retain the 10 seats they currently hold. Sen. Barbara Boxer (D-CA), a longtime critic of the use of bisphenol A (BPA) in consumer products, and Sen. Barbara Mikulski (D-MD)

IBWA CAN ASSIST YOU WITH HOSTING A PLANT TOUR, VISITING YOUR MEMBERS OF CONGRESS, AND ENCOURAGING YOUR EMPLOYEES TO VOTE. will not seek re-election in 2016, and those seats are likely to remain Democratic. Senate Minority Leader Harry Reid (D-NV) also has decided to retire this year. Sen. Michael Bennet (D-CO) has been considered the most vulnerable Democratic incumbent, but the GOP is having trouble recruiting a challenger for the seat.

Presidential and Gubernatorial Elections The presidential election season kicked into high gear in February 2015 with the Iowa Caucus and the primary in New Hampshire. The Democratic nomination will come down to former Senator and Secretary of State Hillary Clinton and Sen. Bernie Sanders (I-VT). The race for the Republican nomination is wide open with several candidates, including Sen. Marco Rubio (R-FL), former Governor Jeb Bush (R-FL), Donald Trump, Ben Carson, Carly Fiorina, Governor John Kasich (ROH), Sen. Rand Paul (R-KY), and Sen. Ted Cruz (R-TX) vying for the chance to represent the GOP. But that is not all—there are several gubernatorial races in 2016: Delaware, Indiana, Missouri, Montana, New Hampshire, North Carolina, North Dakota, Oregon, Utah, Vermont, Washington, and West Virginia.

Call to Action With all this activity, bottled water executives should ask themselves the following questions: • What have I done to get involved in the political process? • What have I done to prepare my company for the new political climate? • Does my member of Congress know me? • Does my governor know me? • Have I marked IBWA’s 2016 June Hill Day on my calendar? (It’s scheduled for June 8, 2016. Please plan to be in Washington, DC, to participate.) There is still time to get involved, and IBWA can assist you with hosting a plant tour, visiting your members of Congress, and encouraging your employees to vote. We are here to help you see what is on the horizon and help bottled H2O get out the vote.

James Bayot and Nancy McNally are partners at Van Ness Feldman, which has been IBWA’s Government Relations counsel since 2007.

JAN/FEB 2016



Creating a Hearts-and-Minds PR Campaign on a Budget By Chris Hogan, IBWA Vice President of Communications

When four tractor trailers turned the corner onto East Isham Avenue and headed down a slight hill toward Iglesia Emmanuel Church and an awaiting gaggle of press, it was a noteworthy highlight in a public affairs campaign reminding people about the important role bottled water plays every day in healthy hydration. The trucks were delivering the equivalent of more than 100,000 16.9-ounce bottles of bottled water to the residents of East Porterville, California, a town that has literally run dry. In addition to being a spiritual home for many of the town’s residents, Iglesia Emmanuel Church is also the de facto headquarters for all local drought-related services, including bottled water distribution, portable showers, and the Tulare County Drought Resource Center, which has set up in church’s parking lot. That fact that this event even took place was the result of an innovative 30



campaign launched by IBWA to counter a false and misleading narrative that was being discussed in the media: that bottled water was partly to blame for the late 2015 California drought. The campaign, Hydrate California, evolved from the work of industry experts and California legwork. It was a fresh and creative take on a hearts-and-minds PR campaign. The East Porterville donation, one component of this landmark effort, was executed through a partnership of IBWA members and staff, Sacramento-based public relations firm 3.14, California Assembly Member Devon Mathis, and Tulare County Office of Emergency Services.

Staying Flexible and Moving Fast When first charged by its board of directors to develop and launch an effort to get the facts about bottled water in front of California consumers, IBWA had very little time to ramp up such a

program. In fact, we really did not know what the campaign should look like, and we had a very small budget with which to pull it together. As the concept of Hydrate California came together, two points remained front and center: everything we say has to be backed up by facts, and we seek to inform and educate, not attack. IBWA had to move quickly to create and stand up the campaign, while simultaneously engaging with California regulators (who were debating water use issues) and media outlets (that were pumping out error-filled stories about bottled water, rainfall, and aquifers). While IBWA staff handled traditional media relations, the 3.14 team established a baseline of who the Hydrate California campaign was trying to reach and what it was seeking to accomplish. A limited budget, small staff, and narrowly defined messages dictated the type of campaign: online, consumer-focused,

COMMUNICATIONS and targeting specific communities throughout the state. We sought out consumers who were predisposed to support, or open to supporting, bottled water and who were influential in their social media circles.

Positive Results, Planning for the Future Built on detailed consumer polling, the results were strong. By connecting with influential individuals, IBWA was able to amplify its healthy hydration, low water use, low environmental footprint, and first responders messaging. Through paid Facebook and Instagram ads, nearly 350,000 click-throughs were recorded to, resulting in an overall reach of 7.3 million consumers, primarily in California. In addition, Hydrate California’s online “Are you a water wizard?” quiz was taken more than 30,000 times. As the average score was 61 percent, the quiz has served as a successful tool in educating Californians about bottled water facts. The campaign’s educational video, “Bottled Water for the Way We Live,” was also promoted through paid ads on social media. (View the video at All of that was generated in three months, from the ground up. Hydrate California is a campaign template that IBWA can continue to refine and deploy in various markets or regions of the country, as needed. The research, advertising, strategies, and resources being developed and employed are transferable to future IBWA consumer-facing campaigns and efforts.

wherever they arise. In California, IBWA has worked to educate audiences about the fact that the bottled water industry is actually a very small and efficient water user. Most consumers have no idea that bottled water uses only 0.01 percent of all water used in the United States—and only 0.02 percent of all water used in California. IBWA’s approach has always been to present a campaign that speaks from a position of facts and data. Our opponents often seek to sway consumers by creating emotional narratives that paint bottled water as a sort of universal evil. While they do concede that bottled water is a vital necessity during emergencies and natural disasters, that point is often a dismissed caveat, with no discussion on how bottled water would manifest itself during such times of crisis. To counter such fear-based rhetoric, our

Hydrate California messaging is factual, informative, friendly, and directed at individuals open to hearing from the bottled water industry.

Keep Moving Forward The Hydrate California campaign is by no means over. In addition to our social media and advertising components, IBWA is placing op-eds written by community leaders in local papers, developing contacts with media outlets, and considering another community bottled water donation. While the bottled water industry may be large and growing—bottled water is set to replace soft drinks as the No. 1 packaged drink in the United States by 2020—as an organization, IBWA is a small and lean operation that’s definitely punching above its weight.

It’s What’s on the Inside That Counts Don’t let a few PPM spoil your day! Deploy Pacific Ozone disinfection systems and test kits to optimize efficiency, reduce energy use and lower production costs. The numbers always tell the truth.

Leading With Facts The larger issue of water scarcity is one that IBWA expects to impact other areas of the country with similar news, social media, and activist coverage. Therefore, our proactive and reactive efforts must be flexible enough to address water scarcity discussions and debates



JAN/FEB 2016



The FSMA Preventive Controls Rule: Supply-Chain, Records, and Training By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations

In the last edition of the Bottled Water Reporter, the Technical Update column provided an overview of the U.S. Food and Drug Administration’s (FDA) new Preventive Controls Rule (“PC Rule”), under the Food Safety Modernization Act (FSMA). Since then, IBWA has published a complete guidance document that covers the entire rule. To become familiar with the requirements of the PC Rule that will impact your bottling facility, contact IBWA for a copy of that document. In this column, we review three parts of the final rule: supply-chain programs, recordkeeping requirements, and new regulations for training.

Supply-Chain Programs FDA has stated that supply-chain controls are a type of preventive control. New requirements for supply-chain 32



programs are addressed under Subpart G of the PC Rule. The rule takes a linear approach to supply-chain management, includes very detailed requirements, and is very record intensive. FDA defines a supplier as the establishment that manufactures/processes the food, raises the animal, or grows the food that is provided to a receiving facility (i.e., your bottling facility) without further manufacturing/processing by another establishment, except for manufacturing/processing that consists solely of the addition of labeling or similar activity of a de minimis nature. Entities like brokers, distributors, or aggregators can engage in supplier verification as a service to the receiving facility. In those cases, the receiving facility must review and assess that entity’s applicable documentation, and document that review and assessment.

Receiving facilities must establish and follow written procedures for receiving raw materials, and must document use of those procedures. Bottlers will need to identify hazards controlled earlier in the supply chain (i.e., before receipt), if any, and the suppliers that control those hazards. You will also need to determine appropriate verification activities and frequency of activities for each supplier. For example, you “must” consider specified factors, including the supplier’s performance, food safety history, and compliance with FDA food safety regulations. Your supplier program will also be required to verify activities associated with the supply chain. Generally, annual audits will be required for hazards identified as “Serious or Adverse Health Consequences or Death to Humans or Animals” (SAHCODHA) to verify that preventive controls for those

TECHNICAL UPDATE hazards are effective. There is no requirement to keep complete audit reports. However, the documentation must include the conclusions of the audit and corrective actions taken in response to significant deficiencies identified during the audit. When the hazards are observed, you must take prompt corrective actions, as needed. As with other parts of the PC Rule, all records must be verified, and all decisions and activities must be documented. This may all be simplified for bottled water as the primary incoming ingredients are mineral salts. Packaging materials are also covered. In determining the need for a supplier program, you should ask “Do any of these suppliers have hazards that need to be controlled? If yes, what level of supplier oversight is reasonably required?”

Record Keeping Under the PC Rule, records must: • Contain the actual values and observations obtained during monitoring and, as appropriate, during verification activities. • Be accurate, indelible, and legible. • Be created concurrently with performance of the activity documented. • Be as detailed as necessary to provide the history of the work performed. • Include: – information adequate to identify the plant/facility – the date and, when appropriate, the time of the activity documented – the signature or initials of the person performing the activity – identity of the product and lot code (if any), where appropriate. Required records must be retained for at least two (2) years after the date they were prepared. Records relating to general adequacy of equipment/processes being used by the facility (e.g., results of scientific studies used for validation) must be retained for two (2) years after their use is discontinued. All records, except for the food safety plan, can be stored

offsite as long as they can be retrieved and provided onsite within 24 hours. Records are exempt from Part 11, which would have required reporting directly to FDA. All required records must be made “promptly available” for official review and copying upon oral or written request. FDA intends to copy records on a case-by-case basis—and primarily when conducting an inspection for cause (e.g., outbreak investigation). Most records obtained or delivered to FDA are subject to disclosure under the Freedom of Information Act (FOIA). In 2015, IBWA raised a concern during a public meeting about the confidentiality of food safety and security plans. FDA is expected to exempt food safety plans from public release as “trade secrets.” Disclosure of verification records, such as the results of product testing and environmental monitoring, would be evaluated on a case-by-case basis.

Training All employees at a bottled water plant must be “qualified individuals.” The definition of “qualified individual” has changed in the final rule. A qualified individual is now defined more broadly, essentially meaning that employees must be qualified to do their jobs. Each individual engaged in manufacturing, processing, packing, or holding food, or in the supervision thereof, must receive training in principles of food hygiene and food safety, including employee health and personal hygiene. That applies to good manufacturing practices (GMPs) and PCs, and facilities must keep records of this required training. In addition, the term “Preventive Controls Qualified Individual” (PCQI) now applies to at least one employee in each bottling facility. A PCQI is a qualified individual who has successfully completed training in the development of risk-based preventive controls at least equivalent to that received under

a standardized curriculum recognized as adequate by FDA or is otherwise qualified through job experience. That person must prepare or oversee certain preventive controls functions. More specifically, a PCQI must: • Prepare the food safety plan. • Validate preventive controls. • Justify validation timeframes. • Justify why determining validation is not required. • Review records. • Justify the timeframe for reviewing monitoring and corrective action records. • Reanalyze the food safety plan. • Determine the timeframe for reanalysis and validation of additional preventive controls. IBWA has a plan to assist members with satisfying the training requirements under the PC Rule. First, IBWA Vice President of Education, Science, and Technical Relations Bob Hirst has been accepted into the FSMA Lead Trainer program and will be certified as such in January 2016. As a lead trainer, he can then train and certify IBWA members as PCQIs. The proposed program will become an extension of the existing IBWA certified plant operator (CPO) program. Two additional rules that will have a minor impact on bottled water, Foreign Supplier Verification Programs (FSVP) and Third-Party Accreditation, were published in November 2015. Early in 2016, we expect to see two additional FSMA final rules that will have some impact on bottled water: Safe Food Transportation (March 31, 2016) and Intentional Adulteration/Food Defense (May 31, 2016). Watch for articles on these final rules in future editions of the IBWA News Splash e-newsletter and Bottled Water Reporter. If you have any questions, contact Bob Hirst at JAN/FEB 2016





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 22314. 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


Under FSMA, _____ are types of preventive controls.


sanitation programs supply-chain controls recall plans all of the above


Under FSMA supplier programs, a facility that bottles water is a _____.


supplier receiver retailer warehouse


All records, except for the food safety plan, can be stored offsite so long as they can be retrieved and provided onsite _____.


within 48 hours immediately within one week within 24 hours


FSMA recordkeeping requirements were first promulgated from _____.


Federal Food Drug and Cosmetic Act Safe Drinking Water Act Bottled Water Ground Water Rule Bioterrorism Act of 2002


Sensitive documents (such as food safety plans) will likely be handled by FDA as _____.

OO trade secrets OO records subject to the provisions of the Freedom of Information Act OO public information OO classified





The Preventive Controls Rule will require that at least one employee at a bottling facility be designated as a _____.


Preventive Controls Qualified Individual (PCQI) Certified Plant Operator Registered Sanitarian Qualified Individual


Each individual engaged in manufacturing, processing, packing, or holding food, or in the supervision thereof, must receive training in principles of food hygiene and food safety, including employee health and personal hygiene.

OO True OO False


Work experience does not qualify one to be a PCQI.

OO True OO False


Employees who undergo training to become a facility’s PCQI must receive education from a _____.


Certified Lead Trainer FDA trainer Plant manager Qualified Individual


Future FSMA final rules include _____.


Intentional Adulteration Safe Food Transport Laboratory Accreditation All of the above

CALENDAR 2016 APRIL 6-8 Central States Bottled Water Association 8th Annual Convention and Trade Show

ADVERTISERS Analytical Technology Inc. . . . . . . . . . . . . . . . . . 3 Blackhawk Molding Co.. . . . . . . . . . . . Inside Front Cover Edge Analytical. . . . . . . . . . . . . . . . . . Inside Back Cover

Eurofins. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Mother Parkers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Pacific Ozone. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

River City Hotel and Casino St. Louis, MO

JUNE 6 - 9

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


IBWA Annual Business Conference and Trade Show (co-location with NAMA CoffeeTea&Water Show) Gaylord Opryland Resort and Convention Center Nashville, TN

PolyCycle Solutions. . . . . . . . . . . . . . . . . . . . 10-11 Quality Truck. . . . . . . . . . . . . . . . Inside Back Cover

82% of BWR readers read the magazine

78% are responsible for researching/

53% have visited an advertiser’s

41% have purchased an advertised

95% consider BWR “must reading”

to learn about new technologies

evaluating products


product or service

2015 Bottled Water Reporter Readership Survey W AT E R .



ISSUE and ALSO IN THIS ess” FSMA Why “Truthin the Supplier Politics: Know Is Not Enough Your Position

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iness Risk Making Bus k for You Wor Management

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


IN THIS ISSUE Advocacy Takes Fact-Checking a Team the Media


ALSO IN THIS ISSUE What Bottlers Can Expect From How Bottled Vending Machine Water Can Help America Mandates ’s Health Crisis


Why Choose

Water Instead of Sugar-Sweetene d Beverages


Consequences of Off-Site Labs


n Helps the

Body Funct



Law for Employment rators Owners/Ope uld Be a Why You Sho mpion Safety Cha

The Management / Marketing Issue Gain Market Share With an Integrated Marketing Approach A PUBLIC ATION





How to Help Drink Up #spreadthe water Understanding Effects of Dehy the dration L BOTTLE



SPECIAL COVERAGE 2015 IBWA Annual Business Conference and Trade Show Info Inside! See page 26.

Call Stephanie Schaefer at


to advertise in the next issue of Bottled Water Reporter JAN/FEB 2016



VALUE OF IBWA MEMBERSHIP JOE BELL VICE PRESIDENT SALES AND MARKETING AQUA FILTER FRESH, INC. PITTSBURGH | PA ALL ABOUT JOE Joe is IBWA’s 2016 chairman. He is not as intimidating as he looks. When not working, Joe loves to play golf, hunt waterfowl, or just spend time outdoors.

In his own words, Joe Bell was born into the bottled water industry. His father, Bill Bell, was working at Polar Water in Pittsburgh when Joe was born, and a few years later—1981—his parents started Aqua Filter Fresh, Inc. Joe grew up washing coolers, loading trucks, and driving forklifts, back when it was expected that children would contribute to the family business. Today, Joe is vice president of sales and marketing at Aqua Filter Fresh, and he is also IBWA’s 2016 chairman. From his unique perspective, Joe has watched the industry grow and adapt to changing business climates throughout the years. What’s amazed him the most is how technical the bottled water industry has become: “We used to measure things in parts per million, and now we are talking parts per billion. The quality of our products is second to no other food product.” A longtime member of IBWA, Joe has developed many friendships within the Association, and those friends have always offered help or answered questions when he has had a business issue that needed resolving. “Because of the way IBWA members have treated us, we have always opened our doors to anyone with questions,” explains Joe. “If we don’t know the answer, we find someone that can help. I believe this makes the bottled water industry different from other industries. The camaraderie is an invaluable benefit of IBWA membership.” Joe suggests that the current, most significant reason that bottlers should invest in IBWA membership is because of the U.S. Food and Drug Administration’s implementation of the Food Safety Modernization Act (FSMA). Through IBWA’s technical educational offerings, IBWA members have been informed of the ways FSMA will affect the bottled water industry—and they have been advised on how to prepare their plants. But if you aren’t an IBWA member, you might be confused by the FSMA regulations. Aqua Filter Fresh’s vision is to be a leading producer and marketer of high-quality products and services in the beverage industry. Joe explains that for his company “success is accomplished through our associates, who are inspired to exceed customer expectations.” The business, which started as a point-of-use (POU) filtration purveyor, diversified into bottled water in 1982 by distributing and bottling the Tyler Mountain Water brand, which experience phenomenal growth in its first 20 years. In 2003, the business diversified once again, expanding into office coffee services. Visit for more about Aqua Filter Fresh, Inc.





Bottled Water Reporter  

Environmental Sustainability Issue January/February 2016

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