Bottled Water Reporter (March/April 2021)

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

BWR

IN THIS ISSUE Tips for Building a Tackling Recycling IBWA Revises the Strong Grassroots Issues Through Bottled Water Code Program Partnerships of Practice

BOTTLED WATER REPORTER | MAR/APR 2021

RECYCLED CONTENT REALITY CHECK Do your legislators know the facts?

Also Inside:

Focus on Plastic Waste (Not Plastics) Recycling Social Media Posts You Can Use Today A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

VOL. 61 • NO. 2

COLUMNS GOVERNMENT RELATIONS

24 | Building a Strong and Lasting Grassroots Program: 3 Keys to Success Affecting legislative change takes motivated and knowledgeable volunteer advocates.

COMMUNICATIONS

26 | Spreading Recycling Education Through Partnerships Never underestimate the value of partnerships—and the access they give you to quality educational materials.

TECHNICAL UPDATE

28 | Revised IBWA Bottled Water Code of Practice Covers FDA’s PC Rule and More IBWA’s revised “Code” became effective January 2021. Are you aware of how the revisions affect you?

BY THE NUMBERS

32 | A Plastics Education PET and HDPE plastic packaging statistics worth knowing.

TABLE OF CONTENTS 10 | Recycled Content Reality Check Implementing realistic recycled content policy is possible—if legislators know the facts. That’s where IBWA has a role to play. Prepared with recent research conducted for the association by Resource Recycling Systems, IBWA can ensure policymakers are aware of the supply issues facing recycled content mandates and commitments.

By Christine Umbrell

17 | Why the Focus Should Be on Plastic Waste—Not Plastics For decades, plastic has been a popular packaging option for food and beverage producers. But its critics have recently become more aggressive in their demands that manufacturers stop using plastic. Find out why their efforts are misguided— and why the focus should be on improving recycling rates and the U.S. waste management infrastructure. By Chris Torres

CHAIR'S COMMENTARY ......................................2 PRESIDENT’S MESSAGE ......................................4 WATER NOTES ....................................................6 CPO QUIZ .........................................................30 ADVERTISERS ...................................................31 CALENDAR .......................................................31

CONNECT WITH IBWA

BOTTLED WATER REPORTER, Volume 61, Number 2.

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CHAIR’S COMMENTARY NOT ALL PLASTIC IS CREATED EQUAL

We, as bottled water professionals, face an imperative: how can we provide convenient, environmentally sustainable packaging options for bottled water that advance not only the health of individuals but also the health of our planet?

Plastic remains an important and convenient means of delivering bottled water and other food products to consumers—with many relying more on plastic packaging for health and safety reasons as a result of the pandemic. Yet, the urgent problem of plastic waste is not going away, nor is it improving. While no one industry can tackle and address every issue when it comes to the problem of plastic pollution, there are many things the bottled water industry can do to be part of the solution.

For starters, design packaging for recyclability. Every single piece of the product design impacts recyclability—from the material that’s used for containers and caps down to the glue that holds labels in place. If we take recyclability into account from sourcing and product development to the consumer’s last sip and disposal of the bottle, it marks a critical step in helping to take the “single” out of “single” use plastic. I know such design considerations are already top of mind with all of you because, between 2000 and 2014, we decreased the average weight of a 16.9-ounce polyethylene terephthalate (PET) plastic bottled water container 51 percent (bottledwater.org/environmental-footprint).

Next, remember not all plastic is created equal. While plastic has gotten a bad reputation, PET plastic, used for most water bottles, is not only safe, lightweight and durable, but it is also highly recyclable and has a smaller environmental footprint compared to other packaging materials, such as glass and aluminum. As such, it has potential. Its life should not end with a single use. This plastic can—and should be—recycled, used to make new bottles and brought back through the recycling loop.

While it’s discouraging that fewer than 30 percent of PET plastic bottles are currently recycled (napcor.com/news/4970-2), we can help increase that recycling rate through our action and advocacy: support infrastructure that makes it easier for people to recycle and improves curbside pickup, educate consumers about proper recycling practices to help create an end market for recycled plastic, and work with lawmakers to modernize laws to stay in step with the evolving packaging and distribution landscape, as well as demonstrate our willingness to support policies that not only increase the demand for recycled plastic but also improve the effectiveness of collection and recycling systems.

With this in mind, on April 22, we celebrate Earth Day, and this year’s theme is “Restore Our Earth.” I’m hopeful that together we can contribute to that restoration of our Earth by taking steps to rescue recyclable plastics from places like landfills (where they were never meant to go), looking for new technologies and packaging solutions that promote our continuing efforts to minimize the environmental footprint of our products, and leading the way when it comes to convenient and environmentally sustainable packaging for water—whether plastic or other packaging alternatives.

IBWA

International Bottled Water Association OFFICERS Chair Tara Carraro, Nestlé Waters North America Vice Chair C.R. Hall, Hall's Culligan Treasurer Brian Hess, Niagara Bottling LLC Immediate Past Chairman Robert Smith, Grand Springs Distribution

BOARD OF DIRECTORS Shayron Barnes-Selby, Primo Water North America Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America Tara Carraro, Nestlé Waters North America C.R. Hall, Hall's Culligan Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Dan Kelly, Polymer Solutions International Kari Mondt, Allied Purchasing Greg Nemec, Premium Waters, Inc. Jillian Olsen, Cherry Ridge Consulting LLC David Redick, Steelhead, Inc. Robert Smith, Grand Springs Distribution Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chair Tara Carraro, Nestlé Waters North America Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America C.R. Hall, Hall’s Culligan Brian Hess, Niagara Bottling LLC Henry R. Hidell, III, Hidell International Dan Kelly, Polymer Solutions International Dave Muscato, Primo Water North America Robert Smith, Grand Springs Distribution William Patrick Young, Absopure Water Co., Inc. Lynn Wachtmann, Maumee Valley Bottlers, Inc.

COMMITTEE CHAIRS Communications Committee Julia Buchanan, Niagara Bottling, LLC Maureen Hendrix, Primo Water North America Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee John Cook, Niagara Bottling LLC Martie Curran, Nestlé Waters North America Government Relations Committee Viola Johnson Jacobs, Primo Water North America Derieth Sutton, Niagara Bottling LLC. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, Primo Water North America State and Regional Associations Committee Robert Smith, Grand Springs Distribution Supplier and Convention Committee Joe Bell, Aqua Filter Fresh, Inc. Dan Kelly, Polymer Solutions International Technical Committee Glen Davis, Absopure Water Co., Inc. Ryan Schwaner, Niagara Bottling, LLC

Tara Carraro IBWA Chair 2 • BWR • WWW.BOTTLEDWATER.ORG

ADVERTISE WITH US IN 2021 Visit bit.ly/AdvertiseWithIBWA for more info or email stephanie@bottledwater.org.

PRESIDENT’S MESSAGE THE FACTS SPEAK FOR THEMSELVES Every day, we encounter a lot of misinformation published online and on social media.

For those of us in the bottled water industry, this is particularly troublesome because we see the negative influence that incorrect information can have—on opinions and policy. All too often, we read articles disparaging bottled water because of the plastic packaging materials we use. In this Environmental Sustainability issue of Bottled Water Reporter, we provide examples of how our industry is working hard to ensure bottled water continues to have the smallest environmental footprint of any packaged beverage.

In “Recycled Content Reality Check” (p.10), we present findings from a 2020 study conducted by Resource Recycling Systems—“Analysis of Food Grade rPET and rHDPE in the United States”—that looks into the availability of recycled PET (rPET) and recycled HDPE (rHDPE) for bottled water. We expect many states to consider recycled content mandates for plastic packaging this year, following the lead of the California legislature which passed its bill in 2020. However, many state policymakers don’t currently have an adequate understanding of what the recycled content market looks like. We discuss the hurdles legislators and industry will face if unrealistic goals are set.

Critics of bottled water often misrepresent America’s waste and recycling infrastructure issues as a plastics issue. On this topic, I echo the sentiment of Joshua Baca, the vice president of plastics at the American Chemistry Council: “We have a plastic waste problem. We don’t have a plastic problem.” In “Why the Focus Should Be on Plastic Waste—Not Plastics” (p.17), we discuss why food and beverage producers find plastic such a popular packaging option and review the science that shows the futility of banning one product (i.e., bottled water) because it is packaged in plastic. Plastic waste is a global issue—and it’ll take a global effort to solve the problem. We can all agree on one thing: More recycling education is needed for policymakers and consumers alike.

To that end, our Communications column (p.26) highlights the partnerships IBWA has established with Keep America Beautiful and The Recycling Partnership, and informs members about the recycling educational materials they have available. Affecting legislative change takes more than quality educational materials—you need a strong grassroots program. We discuss the principles that ensure your grassroots efforts are a success in the Government Relations column (p.24). And in our Technical Update column (p.28), we respond to member inquiries about the recent updates made to the IBWA Bottled Water Code of Practice by briefly describing them and letting you know who to contact for more information.

The first quarter of 2020 isn’t over yet, and we’ve already seen a lot of activity on environmental issues. Help us share bottled water's great environmental stewardship story by posting our science-based facts on your company's social media.

Joe Doss IBWA President 4 • BWR • WWW.BOTTLEDWATER.ORG

IBWA

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 www.bottledwater.org

IBWA STAFF President Joe Doss jdoss@bottledwater.org Senior Vice President of Education, Science, and Technical Relations Robert R. Hirst bhirst@bottledwater.org Vice President of Communications Jill Culora jculora@bottledwater.org Vice President of Government Relations Cory Martin cmartin@bottledwater.org Director of Conventions, Trade Shows, and Meetings Michele Campbell mcampbell@bottledwater.org Director of Government Relations J.P. Toner jtoner@bottledwater.org Director of Science and Research Al Lear alear@bottledwater.org Director of Communications Sabrina E. Hicks shicks@bottledwater.org Manager of Member Services Cheryl Bass cbass@bottledwater.org Communications Coordinator Chris Torres ctorres@bottledwater.org Education and Technical Programs Coordinator Linda Amar lamar@bottledwater.org Executive Assistant Vacant Bottled Water Reporter Layout and Design Rose McLeod rozmack@gmail.com Tel: 315.447.4385 Editor Sabrina E. Hicks shicks@bottledwater.org Advertising Sales Stephanie Schaefer stephanie@bottledwater.org

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WATER NOTES

for an exclusion from the tariffs. Unfortunately, that process did not occur in 2020; thus, the bottled water industry faced tariffs on imported water coolers from China starting January 1.

The Senate Finance Committee is expected to hold a hearing in March to discuss the nomination of Katherine Tai, President Joe Biden’s pick to become the next USTR. Once Ms. Tai is confirmed, USTR is expected to review the tariff situation. IBWA will immediately ask that the exclu-

ECONOMICS

IBWA Updates Congress on the Negative Economic Impact of Tariffs Imposed on Water Coolers In February, IBWA met virtually with several congressional offices to discuss the need to reintroduce exclusions for water coolers imported from China now that tariffs have been imposed. Since January 1, 2021, bottled water companies have had to pay 25 percent tariffs at the U.S. port of entry. IBWA members and staff provided legislators with examples of how the tariffs are having a direct negative economic impact on U.S. bottled water companies and the American citizens they employ. In addition, IBWA previously co-signed a letter to all members of the 117th Congress, with 164 other trade organizations, encouraging them to extend 6 • BWR • WWW.BOTTLEDWATER.ORG

the product exclusions that expired in 2020.

If the imposed tariffs on water coolers from China are in place for the entire 2021 calendar year, it will total $234 million in increased costs for the bottled water industry, per an analysis by John Dunham and Associates. The tariffs, combined with reduced revenue the industry has incurred due to lost business because of the COVID-19 pandemic, are detrimental to American bottled water manufacturing and jobs reliant upon the home and office delivery sector of the industry.

During the Trump Administration, the bottled water industry was excluded from having to pay 25 percent tariffs on

sion process be opened again, and that our products receive an exclusion.

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cmartin@bottledwater.org.

Are You Receiving IBWA's Emails?

In mid-February, IBWA started using a new email marketing service to help ensure members receive the IBWA News Splash e-newsletter and other important communications from the association in the most seamless way possible. Here's what you can do to make sure IBWA's emails don't get blocked or filtered: Ask your IT teams to safelist emails from “@bottledwater.org,” "@in.constantcontact.com," and "@in.confirmedcc.com."

By safelisting those domains, you help ensure that IBWA emails don’t end up in your spam or clutter folders.

WATER NOTES

DIGITAL ADVOCACY

Download IBWA’s App to Participate in Federal and State Advocacy Efforts Don’t miss out on bottled water industry advocacy news or activities! Download IBWA’s advocacy app: VoterVoice. This app provides IBWA members one-touch access to grassroots letters, industry advocacy events, and news regarding the association’s efforts in Congress and the states.

You can download the app in three easy steps: 1. Search for “votervoice” (one word) in your cellphone’s App store, or you can use one of these links: Google Play (bit.ly/VoterVoice_Google) or iTunes (bit.ly/Voter Voice_iTunes).

2. After downloading the app, you will be prompted to enter your email address. A verification code will be sent to that email account.

3. After verifying your email, you will land on the app’s “Find Association” page. Start typing “International Bottled Water Association,” and an option for

“International Bottled Water Association” will appear directly below where you were typing.

Click/touch the association name, and you’ll then have access to the new mobile app.

If you have any questions regarding this app or IBWA’s advocacy efforts, please contact IBWA Vice President of Government Relations Cory Martin: cmartin@bottledwater.org.

SPECIAL ANNOUNCEMENT

Berkeley Springs International Water Tasting Postponed Until June 3–6, 2021 The 31st annual Berkeley Springs International Water Tasting, held annually in Berkeley Springs, West Virginia, has been postponed until June 3-6, 2021. Registration began March 1, 2021. The entry deadline for candidates is May 15, 2021.

Produced by Travel Berkeley Springs, this award-winning event is the largest and longest running of its kind in the world, acclaimed by media as the world's most prestigious water tasting. If you have not entered in a while, make 2021 the year your water is spotlighted in this event. Winners will receive global press coverage, the opportunity for potential water deals and new distributors, along with adding the prestigious Berkeley Springs water medal to their bottle labels like dozens of predecessors.

With three decades of experience, organizers know that winning waters are guaranteed thousands of dollars in marketing benefits and exposure. The cost to enter is only $45, plus the cost of shipping waters to be tasted.

Enter your water in one of these four categories: Municipal, Bottled Non-carbonated, Purified Drinking Water, and Bottled Sparkling. In addition, anyone may also enter the People's Choice Package Design. For more information, call 1.800.447.8797 or visit www.berkeleyspringswatertasting.com.

MAR/APR 2021 • BWR • 7

WATER NOTES

COVID-19

Educate Essential Workers About the COVID-19 Vaccines Using the CDC's Employer Toolkit

The U.S. Centers for Disease Control and Prevention (CDC) created a toolkit for employers of essential workers to help educate employees about COVID-19 vaccines, raise awareness

about the benefits of vaccination, and address common questions and concerns. The toolkit contains a variety of resources that can be used virtually or in person, including key messages,

posters, slides, newsletters, social media content, and more. To access the CDC toolkit, go to www.cdc.gov/ coronavirus/2019-ncov/ vaccines/toolkits/essentialworkers.html.

Winter Storm Uri Relief Efforts

In addition, IBWA has created a one-page document members of the association can use to help educate healthcare professionals about the fact CDC guidelines have identified bottled water industry professionals as eligible for Phase 1b allocation of the COVID-19 vaccine. Once edited to include specific information on your state’s vaccine distribution plan, this document can be provided to employees as they set up appointments to receive a vaccine. IBWA members can find the “Certification of Essential Worker Status for COVID-19 Vaccination” document at www. bottledwater.org/covid-19information-resources by clicking on the “Answers for Bottled Water Industry Professionals” tab.

On February 19, IBWA informed members that the American Logistics Aid Network (ALAN) had reached out to the association to provide an official notice of the urgent need for bottled water throughout Texas and Oklahoma, due to power outages at public water system plants and depleted grocery store stock in the wake of Winter Storm Uri. While the Federal Emergency Management Agency (FEMA) was also supplying bottled water, many areas did not have access to those supplies.

Niagara Bottling donated bottled water IBWA knows that a lot of our member companies responded to the across the south-central states affected by call for bottled water donations from those impacted by Winter Storm Uri. Pictured is Dallas, Texas Park Board President Calvert Collins-Bratton with Uri. If your company was able to assist in the relief efforts, please let Niagara volunteers.

IBWA know by sending an email to IBWA Communications Coordinator Chris Torres: ctorres@bottledwater.org. Additional information, such as delivery locations and photos, can be included in your emails. IBWA may be able to incorporate those images into our social media efforts and bottledwater.org

8 • BWR • WWW.BOTTLEDWATER.ORG

WATER NOTES

HOD SEGMENT

IBWA Provides Support For and Seeks Further Changes to ENERGY STAR 3.0 Specifications for Water Coolers In January, IBWA responded to a request for comments from the U.S. Environmental Protection Agency (EPA) regarding the second draft of its ENERGY STAR 3.0 specifications for water coolers. Our comments provided support for EPA’s work to adopt several recommendations made by IBWA, including creating a higher energy use specification for high-capacity coolers.

After several months of discussion between members of the IBWA ENERGY STAR Working Group and EPA staff, the agency decided to create two separate energy use specifications for high- and low-capacity coolers. In the first draft of specifications, EPA made the suggestion of 0.70 kWh/day, which IBWA argued would be detrimental to the bottled water industry and could result in consumers choosing to purchase non-ENERGY STAR compliant products that meet their expectations. EPA heeded that advice and is now suggesting 0.80 kWh/day for high-capacity coolers and 0.68 kWh/day for low-capacity coolers.

IBWA also noted the benefits of EPA further revising the definitions included in the second draft regarding high- and low-capacity water coolers that dispense cold water. The second draft included a suggestion from EPA that high- and low-capacity cold water coolers dispense 0.61 gallons per hour (i.e., dispense cold water that meets the requirement for temperature). IBWA asked EPA to amend that definition to 0.50 gallons per hour, as that would be in line with the Air-Conditioning and Refrigeration Institute (ARI) guidelines the industry has referenced for many years.

IBWA also sought clarification in the definitions of both high- and low-capacity coolers, as current wording reads as if both capacity coolers will have the same baseline of 0.61 gallons per hour (or 0.50 gallons per hour, should EPA adopt IBWA’s suggested change).

EPA is expected to finalize the draft ENERGY STAR 3.0 specifications in the next few months, with new specifications being implemented at the beginning of 2022.

INDUSTRY NEWS

Nestlé Waters North America Acquired By One Rock and Metropoulos & Co. On February 17, 2020, Nestlé S.A. announced it had reached an agreement to sell its North American water unit to One Rock Capital Partners, in partnership with Metropoulos & Co., for $4.3 billion. The agreement follows Nestlé's announcement last year that it would conduct a strategic review of parts of the North American waters division and sharpen the focus of its global water portfolio.

The sale includes the following brands in the United States and Canada: Poland Spring, Deer Park, Ozarka, Ice Mountain, Zephyrhills, Arrowhead, Pure Life®, and Splash.

It also comprises the U.S. home and office delivery service ReadyRefresh®.

Metropoulos & Co. founder Dean Metropoulos, who will become NWNA’s chairman and interim CEO after the transition, said, “I am pleased to have the opportunity to lead NWNA as it enters the next phase of evolution.

“This is an important inflection point for the business as it transitions to an independent company, and I look forward to collaborating with One Rock and NWNA’s management team to deliver unparalleled value to our customers.”

Subject to customary closing conditions, the transaction is expected to be completed in the spring.

Nestlé’s international premium brands, including Perrier, S.Pellegrino, and Acqua Panna, are not part of the deal.

Have You Renewed Your IBWA Membership?

All IBWA members have been mailed a 2021 membership renewal package and notified via email to renew their association memberships for the year. By renewing your membership, you will help ensure that IBWA continues to aggressively defend the bottled water industry against all negative proposals and proactively communicate the facts about your products to consumers, the media, government officials, and activist groups.

If you have not received your company’s 2021 renewal packaged, please contact IBWA Manager of Member Services Cheryl Bass: cbass@bottledwater.org.

MAR/APR 2021 • BWR • 9

COVER STORY

RECYCLED CONTENT REALITY CHECK implementing realistic recycled content policy is possible—if legislators know the facts. that's where ibwa members have a role to play.

By Christine Umbrell

It should come as no surprise to bottled water professionals that “supply” is the biggest hurdle to meeting mandates and voluntary commitments to increase the amount of recycled content in plastic beverage bottles in the coming years. While IBWA supports recycled content mandates that are reasonable and have achievable effective dates, the supply issue is well-supported by research—including the “Analysis of Food Grade rPET and rHDPE in the United States,” a 2020 study investigating the availability of recycled polyethylene terephthalate (rPET) and recycled natural high-density polyethylene (rNHDPE) for bottled water, commissioned by IBWA and conducted by Resource Recycling Systems (RRS), a sustainability and recycling consulting firm.

Gross tonnage of recovered PET bottles remained relatively flat between 2012 and 2019, at about 30 percent, and then fell about 1 percent last year, according to the National Association for PET Container Resources’ (NAPCOR) latest “PET Recycling Report.” That level of recovery supports a food-grade rPET recycled content rate of about 9 percent for beverage bottles. That modest percentage is attributed to the fact that rPET is also highly sought after by other industries, such as the fiber, thermoform packaging, and strapping industries. According to the authors of IBWA’s rPET/rHDPE report, “The use of rPET in bottles will be competing with these other uses into the foreseeable future.”

MAR/APR 2021 • BWR • 11

to meet recycled content goals, stakeholders need to work together to boost supply of recycled content and improve the recycling infrastructure.

Al Lear, IBWA’s director of science and research, notes that the rPET/rHDPE study was conducted primarily to investigate the “universe of recycled materials” and find out how much food-grade recycled content is—and will be—available. RRS researchers analyzed data provided by NAPCOR, the Association of Plastic Recyclers (APR), the American Chemistry Council (ACC), the Beverage Marketing Corporation (BMC), and IBWA, according to Bryce Hesterman, an RRS consultant and project manager of the report.

In seeking to determine the feasibility of meeting future mandates, voluntary commitments, and policies surrounding recycled content in plastic water bottles, the research-

ers found that—while it will be possible to increase the amount of recycled content in water bottles within the next few years—stakeholders will need to work together to boost supply of the material and improve the recycling infrastructure to meet increased content goals.

Supply and Demand Recognizing the demand for recycled content is the first step in understanding the importance of boosting supply, says Hesterman. He explains that both potential state mandates and voluntary commitments by companies pledging to use specified amounts of recycled content in their plastic packaging will drive the need to ensure adequate collection and processing to turn plastic waste into recycled content. “Both these scenarios are contingent on having the supply,” Hesterman says, “so the rPET/ rNHDPE study looks at these commitments, and where the policy conversations are taking place, and evaluates whether these are realistic commitments.”

The report details critical information that IBWA members can share with legislators and regulators to help educate them on this complex issue and ensure they make educated policy decisions. Before commissioning this project, IBWA leadership and members already knew it “would be difficult to reach some of the proposed mandates, based on member data and an understanding of

BOTTLE DEPOSIT PROGRAMS: A GOOD IDEA THAT CAN GET BETTER Similar to other systems like curbside collection or other types of extended producer responsibility programs, bottle deposit programs have played an important role in controlling littering and incentivizing recycling. IBWA recently adjusted its position on bottle deposit bills. While not all programs are created equal, IBWA does see the value in bottle deposit programs that: • are administratively designed for greater efficiency • reduce contamination for better quality recycled materials • implement proper controls to reduce fraud and abuse • structure fees to support a program’s effectiveness • intelligently invest unclaimed deposits back into the system

A bottle from a curbside bale (left) and a bottle bill program (right).

With that in mind, IBWA updated its legislative stance on “bottle bills.”

Learn more at www.bottledwater.org.

12 • BWR • WWW.BOTTLEDWATER.ORG

RECYCLED CONTENT the current U.S. recycling market,” explains Cory Martin, IBWA’s vice president of government affairs. He notes that the rPET/rNHDPE study offers “real data our members can give to policymakers to illustrate how their mandate goals are not realistic or how any reasonable plan still needs to make sure the infrastructure is in place—and the programming exists—to ensure enough postconsumer materials are available to meet recycled content mandates.”

RRS researchers found that, in addition to a flat recycling rate, the bottled water industry faces a shortage of rPET because “a lot of what is being recovered now is going toward fiber, for carpet and textiles” (42 percent of the supply) rather than back into bottles, says Hesterman. To have enough recycled content to meet mandates and voluntary commitments, more bottles will need to be recovered. Hesterman suggests that can be accomplished via an increase in bottle deposit programs, increased access to curbside recycling, and more education and messaging at the community level. (To learn how you can educate consumers about recycling, read "Why the Focus Should Be on Plastic Waste–Not Plastics" on p.17.)

Bottle deposit programs are currently making more of an impact than curbside recycling, according to the rPET/ rHDPE study. Researchers found that 27 percent of the U.S. population lives in a state that has bottle deposits—and those same states represent 45 percent of the PET bottles recovered. Adopting more robust bottle deposit programs, according to Hesterman, may drive higher numbers of available recycled content. “Some states might have bottle deposit programs already that don’t include noncarbonated beverages, and so expanding that could drive more PET

To meet a 25 percent recycled content target by 2025, each person in the United States would have to recycle 273 PET bottles each year. recycling,” he says. Another option to boost rPET supply: Implementing bottle deposit programs in states that currently don’t have them.

“Data show that bottle deposit programs typically yield higher recycling rates, and typically a cleaner product, so the returned plastic bottles are less contamination than what you find in curbside,” says Martin. He notes that IBWA recently adopted the position of supporting bottle deposit programs if they’re implemented correctly, and if they are not associated with fraud or contamination issues.

(See sidebar on p.12.)

More robust curbside recycling programs also may drive higher collection rates, says Martin. “Curbside has a lot of functionality—mainly because, if people have access to such programs, they usually participate” he says. Martin suggests that greater investment in the infrastructure might help ensure curbside facilities and recycling centers “can adequately sort the product and have it prepared in a way that lessens contamination and yields a better end product.”

rPET Modeled Scenarios rPET Demand for Other Applications

Additional rPET* Needed to Meet Target

PET Bottle Recovery Rate to Meet Target

Increase in PET Bottle Recovery Rate

Scenario

Total rPET Demand

rPET Demand for Beverage Bottles

25% by 2025: U.S.

2.8 billion lbs

1.3 billion lbs

1.5 billion lbs

1.2 billion lbs

52%

+23%

50% by 2030: U.S.

4.5 billion lbs

2.8 billion lbs

1.7 billion lbs

2.9 billion lbs

82%

+53%

75% by 2030: U.S.

5.9 billion lbs

4.2 billion lbs

1.7 billion lbs

4.3 billion lbs

110%

+81%

*Needed to meet national target while also maintaining competing end uses. This assumes that the rate of growth for US PET bottle sales and end use of rPET remains consistent with historical data between 2010 and 2018.

Source: “Analysis of Food Grade rPET and rHDPE in the United States,” RSS/IBWA, 2020 MAR/APR 2021 • BWR • 13

many state policymakers who are considering imposing recycled content mandates currently don’t have an adequate understanding of what the market really looks like in their area, region, or state.

John J. Cook, MBA, PhD, ISSP-CSP, director of sustainability for Niagara Bottling and co-chair of IBWA’s Environmental Sustainability Committee, notes that it will take a collaborative effort to increase the recovery of recyclable material, in a higher quality state. “The contamination that happens through materials recovery facilities (MRFs) is inevitable, so the infrastructure of curbside collection needs to be improved,” he says. “Or a second layer of recovery—a plastics recovery facility (PRF) or a secondary MRF—needs to be introduced” that would consolidate plastic recovery to ensure high-volume and high-quality yield.

National and State-Specific Targets

that goal locally. However, they add one caveat: the recycled content recovered would need to be food-grade quality, so that the rPET and rHDPE could be reused to produce new bottles.

It’s no surprise that California is cited by many as the state most likely to meet recycled content targets. The California legislature recently passed a bill that requires all plastic bottles covered by the state's container redemption program to average no less than 15 percent postconsumer recycled plastic per year, beginning January 1, 2022; no less than 25 percent beginning January 1, 2025; and no less than 50 percent beginning January 1, 2030. “California’s mandate has been signed into law. They are now putting together the regulatory regime for what that mandate will look like,” explains Martin.

Washington, New York, and New Jersey are among the states expected to debate similar bills in the coming months. Some of those bills focus on mandates; some focus on extended producer responsibility (EPR)—a policy approach under which producers are given a significant responsibility for the treatment of disposal of postconsumer products. “Several states have been looking at setting recycling content mandates [similar to California’s], but there’s a gap [in available recycled content] to meet those states’ proposed mandates,” says Lear.

The study’s “rPET Modeled Scenarios” table (see p.13), which quantifies how much PET bottle recovery would have to increase to meet specific targets in 2025 and 2030, presents some of the most eye-opening information from the RRS research.

“One of the biggest takeaways from IBWA’s rPET/rHDPE report is that many of the states that have considered imposing recycled content mandates don’t have an adequate view of what the market really looks like in their area, region, or state,” says Martin.

A “significant increase in the required use of recycled content for PET bottles on a national level would be challenging,” the study notes. “Meeting a 25 percent target nationally by 2025 would require the recovery rate and reclamation capacity to nearly double.” (NAPCOR’s research identifies the current PET water bottle recycling rate is 33 percent; the overall PET recycling rate is lower, 29 percent.) RRS researchers suggest that a whopping 273 bottles would have to be recycled by each person in the United States each year to meet the 25 percent recycled content target by 2025. While possible, that would require strong policy intervention involving optimized container deposit programs and mandatory recycling and automatic curbside/parallel access programs, according to the study’s authors.

Impact of Voluntary Commitments

Hesterman, Lear, and Martin don’t believe the 25 percent target will be realized across the country by 2025, but they do think some states or regions might achieve 14 • BWR • WWW.BOTTLEDWATER.ORG

Even before state legislatures began considering recycled content proposals, bottled water companies were already pledging to increase the amount of recycled content in their packaging. In fact, several bottlers that have made their voluntary commitments public were included in the rPET/rHDPE report: •

Nestlé Waters North America: 50 percent of its entire portfolio by 2030

•

Danone: 50 percent of water and beverage bottles by 2025

•

Walmart: 20 percent of all U.S. private brand packaging, including water bottles, by 2025

•

Coca-Cola: 50 percent of all packaging by 2030

•

PepsiCo: 33 percent of PET beverage bottles by 2025

Lear is optimistic that these larger companies will be able to meet their self-determined goals. Many of them operate

RECYCLED CONTENT

rHDPE and Bottled Water While PET represents 92 percent of the total plastic packaging for bottled water, the IBWA/RRS “Analysis of Food Grade rPET and rHDPE in the United States” report also examined rHDPE, as it represents the other 8 percent of plastic bottle water packaging and many IBWA bottlers use HDPE. Most consumers will be familiar with HDPE as a common plastic used in 1- and 2.5-gallon plastic jugs.

HDPE Bottle Recovery Rate to Meet Target

Increase in HDPE Bottle Recovery Rate

107 million lbs

38.5%

+9.5%

411 million lbs

184 million lbs

46%

+17.5%

411 million lbs

232 million lbs

50.4%

+21.6%

rHDPE Demand rHDPE Demand for Water for Other Bottles Applications

Additional rHDPE* Needed to Meet Target

25% by 2025: 429 for all million lbs states

43 million lbs

386 million lbs

50% by 2030: 507 for all million lbs states

96 million lbs

75% by 2030: 555 for all million lbs states

144 million lbs

Scenario

Total rHDPE Demand

* Needed to meet national target while also maintaining competing end uses. This assumes that the rate of growth for US HDPE bottle sales and end use of rHDPE remains consistent with historical data between 2010 and 2018.

The new study offers some important insights on rHDPE specifically, according to Al Lear, IBWA’s director of science and research. “Most of the postconsumer uses for rHDPE are non-food containers,” he says. But he expects demand to grow for food-grade rHDPE in packaging, as recycled content commitments proliferate. Meeting HDPE demand in the future is “as much of a technical feasibility as a supply quantity issue,” according to the rPET/rHDPE report.

Although the increase in required feedstock for HDPE targets is not as high as for PET targets, meeting rHDPE goals will still be challenging to achieve, due to the technical issues—such as the fact that rHDPE has stricter input requirements than rPET, lower volumes available, high costs, and reported residual odor or taste as recycled content increases beyond 25 percent, according to the study.

internationally, “and the global market is already pushing” for more recycled content in packaging. Plus, Lear says, “It’s always about the consumer—and consumers are looking for sustainable products.”

In addition, “a lot of these companies have agreements in place that give them access to some of their product that’s been out in the market—and they can get that back in the recycling stream, to help reach some of the use and recycled content goals they’ve made,” adds Martin. But he cautions that voluntary commitments and mandates “raise the level of competition for a finite resource”—so smaller bottlers may find it hard to secure an rPET or rHDPE feedstock. Hesterman explains that even larger bottlers may encounter challenges in reaching portfoliowide commitments, but there’s a positive side: “When you have an aggressive target, that pushes you—and also pushes the industry. So, whether or not they meet these targets . . . it’s driving the movement forward and pushing the industry to improve.”

it’s important that all bottled water bottlers—no matter what their size—participate in recycling discussions to ensure all stakeholder voices are heard.

Competing Interests As the rPET/rHDPE study points out, there are additional obstacles to boosting the pools of recycled content.

As U.S. companies seek to acquire more rPET for their packaging, they are facing reduced access to international markets and increased competition within the U.S. borders. “Overseas suppliers of rPET to U.S. companies are starting to disappear in Europe and elsewhere,” says Cook.

MAR/APR 2021 • BWR • 15

IBWA members can review the IBWA/RRS “Analysis of Food Grade rPET and rHDPE in the United States” study by logging on to the association’s website (bottledwater.org) and selecting the Resources tab on the Member Dashboard.

“It’s easier for them to sell closer to home, so we’re now more reliant on U.S. sources for rPET.” In addition, because food-grade rPET end uses compete with fiber and sheet end markets, existing commitments for polyester textiles may exacerbate the demand gap.

“More people are requesting recycled content in their clothing,” notes Cook, “which puts even more pressure on the suppliers. If all the recycled rPET went back into bottles [and not other uses], we’d be a lot closer” to meeting targets. Cook explains that “if textiles were recyclable and recycled more—if they could re-use their own materials—that would be something else.” But such advanced recycling of non-bottle PET and textiles is unproven at scale, according to the report.

Another complicating factor is the cost of virgin PET compared to recycled content. Current prices of virgin materials are low, given historically low oil prices. And collecting recycled PET is more complicated than acquiring virgin; recollecting used plastic and producing it in a way that’s cost-effective can be challenging. Cook explains: “You have to sort, combine, and hope you have enough material to warrant a recycling center/processor to turn this material back into food-grade plastic than can be reused.”

Arming Bottlers With Information Bottled water companies will benefit from paying close attention to regional and statewide mandates, voluntary commitments by other beverage companies (and other industries), and any federal bills that begin to move through the U.S. Congress. That advice holds true for smaller bottlers too, says Hesterman. He emphasizes the importance of those companies participating in recycling discussions: “ The small business concern is very important, and sometimes that voice gets lost when there are these big brands and policymakers having these conversations. The smaller companies may be subject to the outcomes—even though their voice may not have been heard within the process. We advocate that all relevant stakeholders are at the table. This is a

16 • BWR • WWW.BOTTLEDWATER.ORG

collaborative, ideally consensus-driven process, where everybody has a voice.”

“It shouldn’t be a shock to anyone that states are moving forward with recycled content mandates,” says Martin.

“IBWA staff want to ensure our members know what legislatures are contemplating and are in a position to provide policymakers with a reality check. That’s why we’re providing them with our rPET/rHDPE report. We want to make sure members are fully prepared for what is on the horizon, so they can plan for their futures.” Martin stresses that, spurred by California’s efforts, other “states are also focused on recycling and recycled content, and there could be more mandates down the road.”

IBWA’s government relations staff have already been sharing data from the rPET/rHDPE report with regulators and members of Congress—and will continue to do so.

“We need any policy to be based on realistic goals and data, data that still pushes all of us—government, industry, recycling communities, and consumers—to do better,” says Martin. “The rPET/rHDPE study’s data shows what is achievable and can help legislators implement policy based on realistic outcomes.”

Of course, disruption in the recycling industry could impact the scenarios and predictions included in RRS’ report. “Technological development can shift things,” Hesterman explains, “if different materials—such as fiber and textiles—can be brought in [and recycled].”

He notes that, if these advanced recycling technologies get to a point of reaching scale, and fiber from carpet and textiles is turned into food-grade recycled content, it will be a “game-changer.” But that technology may be several years away.

While there is a lot of work to do to achieve higher recycled content goals, the good news is that, compared to some other industries, the bottled water industry “is light years ahead in terms of recycling,” says Martin. “We’ve been leading the way, especially in food packaging, because we already produce products that are 100 percent recyclable and we already use a lot of recycled content.” BWR

Christine Umbrell is a freelance writer based in Herndon, Virginia. Email her at christineumbrell@gmail.com.

WHY THE FOCUS SHOULD BE ON PLASTIC WASTE— NOT PLASTICS

By Chris Torres

Joshua Baca, the vice president of plastics at the American Chemistry Council (ACC) minces no words when responding to questions about recent efforts to implement sales bans on products made of plastic: “We have a plastic waste problem. We don’t have a plastic problem.”

For decades, plastic has been a popular packaging option for consumers, food producers, and beverage bottlers for many reasons. It is shatterproof, hygienic, safe, easy to transport, and resealable; releases less CO2 than other

packaging options; and, very importantly, is recyclable. Plastic bottles are 100 percent recyclable (even the caps)—and, thanks to modern technology, they can be recycled again and again to create new products. Plastic uses less water and less energy to manufacture than other packaging options, and, because it is so lightweight, less fuel is necessary to transport it. Lately, more and more scientists are highlighting the fact that the use of other packaging options in place of plastic would be significantly worse for the environment.

MAR/APR 2021 • BWR • 17

Why is plastic so popular?

Lightweight

Easy to Transport

Less CO2

Shatterproof

Hygienic & Safe

Recyclable

Uses Less Water

Uses Less Energy

Resealable

18 • BWR • WWW.BOTTLEDWATER.ORG

But those facts don’t discourage critics of bottled water from misrepresenting America’s plastic waste issue as a plastics issue. They often exaggerate or misrepresent research concerning recycling rates and ocean plastics to promote sales bans on bottled water packaged in plastic. Towns along Cape Cod, Massachusetts, for example, have adopted bottled water sales bans backed by a group falsely claiming that recycling is “of little help.” In 2019, the San Francisco International Airport (SFO) banned the sale of single-serve bottled water; however, SFO leadership unfairly allowed sugar-sweetened beverages to remain available. Apparently, those policymakers were unaware that sodas and other less healthy drink options are also packaged in plastic—in fact, they are packaged in more plastic due to production processes (e.g., hot fill) and the need to ensure any carbonation doesn’t leak out. While

well-intentioned, such policies are futile because banning one product that is packaged in plastic will not solve America’s waste management issues.

Plastic waste is a complex issue; however, a strong effort is being made to remedy the problems facing the U.S. recycling infrastructure. Waste collectors, plastic manufacturers, government officials, and others are trying to find ways to improve the recycling rate for plastic. According to the U.S. Environmental Protection Agency, “the amount of recycled plastics is relatively small—three million tons for a 8.7 percent recycling rate in 2018,” but the recycling rates for specific types of plastic, like PET and HDPE which are commonly used for bottled water containers, are more significant. In 2018, the PET recycling rate was 29.1 percent; HDPE was 29.3 percent (bit.ly/EPA2018recyclingrates). Baca explains, “We’re essentially trying to create a much more robust waste management system domestically, and across the world, so that we are creating a more circular system for plastics that allow us to recover, recycle, and eventually reuse some of that plastic.”

A Sea of Misinformation Any discussion of plastic waste includes the topic of ocean plastics. While ocean plastic pollution is obviously a global issue, bottled water critics continue to embrace the negative narrative that the United States is a top contributor, regularly using it to drive an agenda for anti-plastic legislation.

In 2020, for example, California’s Senate Bill 54, which focused on waste reduc-

tion in the state, included estimates for total plastic pollution mass in the ocean by 2050 (bit.ly/CA_SB54). New legislation has been introduced for 2021, and the expectation is that the bill’s language will again include that reference.

And Hawaii’s Senate Bill 522, which sought to prohibit the purchase, use, sale, or distribution of single-use plastic beverage containers by state or county agencies, refers to the Great Pacific Garbage Patch (GPGP) as part of the reason why that legislation needed to be

adopted—but never once did it mention that the GPGP is mostly (52 percent) made up of plastic lines, ropes, and nets related to fishing activity (bit.ly/plasticfishingnets). SB 522 also didn’t mention that a 2018 study of the GPGP “found 386 objects with recognizable words or sentences written in 9 different languages.

One third had Japanese inscriptions (115 objects) and another third had Chinese (113 objects) (bit.ly/LebretonGPGP).

Neither bill passed in its original form, and Hawaii’s bill ultimately halted with the creation of a study group.

The issue of ocean plastics is a valid concern. But efforts to establish antiplastic measures–such as banning the sale of bottled water, particularly in a country like America that does a very effective job of waste management—are not the solution to the problem. To understand why, you have to understand the true causes of ocean plastic.

PLASTIC WASTE: A GLOBAL ISSUE Working to mitigate plastic waste globally, the American Chemistry Council (ACC) helped to create the Alliance To End Plastic Waste. The Alliance consists of 80 member companies, project partners, and other groups, which share a mission to eliminate ocean plastics and waste issues around the world. The organization initially focused its work on Southeast Asia and has since spread to other parts Alliance To End Plastic Waste: endplasticwaste.org of the world.

ACC and its members have also established a goal to reuse, recycle, or recover all plastic packaging by 2040 through its “Roadmap to Reuse” framework.

In addition, the U.S. Congress addressed the ocean plastics issue in December 2020 by passing the Save Our Seas Act 2.0, which builds on the 2018 bill that will increase collaboration internationally to address plastic waste and help scientists and agencies research new ways to repurpose used plastics. The month before, the House of Representatives passed the PLASTICS Act, which aims to reduce marine debris and plastic waste in the ocean by leveraging U.S. leadership and resources to support waste management systems in developing countries.

MAR/APR 2021 • BWR • 19

PLASTICS

“If North America [and] Europe were to completely eliminate plastic use, global mismanaged plastic would decline by less than 5 percent.”

RECYCLING ACTIONS AT THE FEDERAL LEVEL According to the U.S. Environmental Protection Agency (EPA), the national recycling rate for municipal solid waste was 32.1 percent in 2018 (bit.ly/EPA_USrecycling). To improve that figure, EPA is seeking comments on a draft national recycling strategy that would address the following: consumer confusion about what materials can be recycled, a recycling infrastructure that hasn’t kept pace with today’s diverse and changing waste stream, reduced markets for recycled materials, and varying methodologies to measure recycling system performance.

In December 2020, IBWA submitted comments to EPA, suggesting that contamination of the recycling stream be a top priority for the agency. IBWA noted that reducing contamination of recycled materials is essential to making any program valuable to everyone within the recycling stream. IBWA also mentioned the critical importance of providing consumer education on recycling, arguing that identifying what packaging can be recycled and providing information about the proper disposal of packaging will help ensure that all recyclable materials are recycled and reused.

An increase in consumer access and participation in convenient recycling options is also important and would help improve U.S. recycling rates.

EPA’s interest in recycling could foreshadow more federal policy on the horizon. Congress, at some point during its 117th session, is expected to pass legislation that will impact recycling, whether it’s a bill to improve infrastructure or create extended producer responsibilities for manufacturers, according to IBWA Vice President of Government Relations Cory Martin. Additional actions that Congress could take on this year include recycled content mandates and educating consumers about the need to participate in recycling programs.

“What will gain support and eventually receive votes is up for debate,” Martin says.

20 • BWR • WWW.BOTTLEDWATER.ORG

Ocean Pollution Inputs Rivers are a key input for ocean plastics, and they can transport waste from further inland to the coast. According to research published in 2017, the top 20 rivers that transport plastic into the oceans are mostly in Asia (86 percent), along with a few in Africa (7.8 percent), and South America (4.8 percent) (bit.ly/PlasticOceanInput_Top20Rivers).

Minimal contributors include Central and North America at 0.95 percent, Europe at 0.28 percent, and AustraliaPacific at 0.02 percent (bit.ly/Oxford_ MismanagedPlastic).

“If we aim to address the ocean plastic problem, an understanding of this global picture is important,” Hannah Ritchie notes in her article “Plastic Pollution,” found on the Oxford University website ourworldindata.org. “It highlights the fundamental role of waste management in preventing ocean pollution; whilst countries across North America and Europe generate significant quantities of plastic waste (particularly on a per capita basis), well-managed waste streams mean that very little of this is at risk of ocean pollution. In fact, if North America [and] Europe were to completely eliminate plastic use, global mismanaged plastic would decline by less than 5 percent.”

What the top contributing rivers have in common is that they are located in areas that lack adequate waste management systems. In countries located in South Asia and Sub-Sahara Africa, between 80-90 percent of plastic waste is inadequately disposed of—stored in open or insecure landfills—putting it as risk of polluting rivers and oceans.

Conversely, in high-income countries with effective waste management systems, like the United States, “almost no plastic waste is considered inadequately managed” (bit.ly/Oxford_managedplasticwaste). For such countries, litter is the main source of plastic waste at risk of entering the environment— and litter is estimated to amount to

approximately 2 percent of total waste generated across all countries.

Waste management has become tougher in recent years due to China’s “National Sword” policy, which banned foreign waste imports beginning in January 2018. China had been importing nearly half of the world’s waste since 1992, according to the United Nations.

Imported waste added about 10-13 percent to China’s waste overall (bit.ly/ UN_ChinaSword). Countries have since moved on to find other ways to manage their waste.

For the United States, China’s ban highlighted the fact that, although America does a good job of waste management, the country’s recycling infrastructure needs repair—and consumers need more recycling education.

Putting the Cart Before the Horse Despite the fact that the U.S. recycling system needs updating in order to better handle the recycling stream, legislators pushed on with other ideas to tackle plastic waste. Critics of plastic have been big advocates of legislation to implement recycled content mandates.

While many states have considered such legislation, last year California

became the first state to implement a recycled content mandate for plastic beverage containers. The law requires beverage containers that are part of the California Redemption Value (CRV) to contain a recycled content minimum of 15 percent beginning in 2022, 25 percent by 2025, and 50 percent by 2030.

IBWA supports reasonable recycled content requirements for plastic water bottles. However, the association notes that any discussion of recycled content mandates needs to address the following issues: (1) the availability of recycled polyethylene terephthalate (rPET) and recycled high-density polyethylene (rHDPE)—especially the limited amount of quality material necessary for bottled water container production and (2) the price volatility of the market.

The reality is that the majority of PET and HDPE bottles that are recycled never make it back into food-grade recycled plastic bottles. Data from the National Association for PET Container Resources (NAPCOR) states that only 1 in 7 post-consumer PET bottles collected for recycling are recycled into new bottles. Most recycled content is used by industries with long-standing contracts with recyclers, such as fiber, thermoform packaging, and strapping.

PLASTICS

“Simply pulling out a [recycled content] percentage requirement out of thin air because it sounds good is folly.”

(For more, read “Recycled Content Reality Check” on page p.10.)

While the Association of Plastic Recyclers (APR) has supported recycled content mandates since 2006, APR President Steve Alexander agrees with IBWA that there needs to be a measured approach based on facts when trying to establish a mandate. “It must be based on what the infrastructure is collecting today, where is that material going, and what is a reasonable goal to ensure that the industry can supply the content as required,” Alexander says. “Simply pulling out a percentage requirement out of thin air because it sounds good is folly.”

Regarding California’s new law, Alexander says APR discouraged the state from going beyond a 25 percent mandate beyond 2025. “We showed them how much more material they need to collect to meet the current requirements as well as future requirements.” Nonetheless, since California passed its law, several other states have introduced legislation that would also seek to impose mandates, including New Jersey, New York, and Washington State. Other states, such as Connecticut, Hawaii, Maine, and Oregon, are also likely to introduce recycled content MAR/APR 2021 • BWR • 21

legislation this year, according to IBWA Vice President of Government Relations Cory Martin.

Encouraging Consumers to “Put It In The Bin” If bottlers are going to meet their previously established pledges to use more recycled content and any current or future recycled content mandates, more post-consumer plastics need to be captured. To do that, two things need to happen: the U.S. recycling system needs an overhaul and consumers need a better understanding of what they can— and can’t—put into recycling bins. But proper recycling can be a complicated issue, as there are thousands of jurisdictions with different rules and standards about what materials their recycling systems can handle.

What consumers must understand is that their plastic containers are “recycling gold,” Alexander says. The current supply of recycled plastics meets just 6 percent of the demand for the most common plastics in the United States and Canada because of technical or market barriers, according to Closed Loop Partners (bit. ly/RecapturedPlastic). Establishing a closed loop system and a circular economy would help increase that number.

But, as Baca explains, consumers would first have to recognize the importance of recycling plastics. “People know instinctively that an aluminum can, for instance, is recyclable,” he says. “We have to educate consumers to know instinctively that not just plastic bottles, but all plastics—wrap, packaging, and food containers also have a value that is infinite and can help us achieve a more circular system. The only way we’re going to do that is through more investments in both mechanical and advanced recycling.”

As bottled water is the No.1 packaged beverage in the United States (by volume), recycling education has always been important to the bottled water 22 • BWR • WWW.BOTTLEDWATER.ORG

Pack It Out: This campaign includes inspirational messages that encourage people to “do the right thing” and always recycled—even when a bin isn’t handy.

View this campaign at putitinthebin.org/ pack-it-out.

Can I Recycle This? Inconsistent and confusing messages about what can, and can’t, be recycled lead to contamination of the recycling stream. To help clear up the messaging for consumers, IBWA created this campaign as a way to “get back to the basics,” and use simple images to show what is recyclable. Learn more at putitinthebin.org/contamination.

Plastic Facts-The Transparent Truth About Plastic: In this campaign, IBWA highlighted the fact that PET, HDPE, and polycarbonate containers are all 100 percent recyclable. It also provided an opportunity to inform consumers about how the bottled water industry has been working harder than any other beverage industry to ensure our packaging supports circularity. Get the facts here: putitinthebin.org/plastic-facts.

Recycling Rex: This video series features Recycling Rex, IBWA’s talking green dinosaur who is both a conservationist and a comical street reporter. As

PLASTICS

industry. To promote the benefits of recycling, IBWA launched its recyclingfocused website, PutItInTheBin.org, and has been developing social media campaigns to help educate consumers. The PutItInTheBin initiative seeks to increase recycling rates by bringing together like-minded partners (IBWA members and non-members) who can harness the power of social media to educate consumers about the value of always putting recyclables in the bin. As part of this project, IBWA has produced the following educational campaign materials that all IBWA members are encouraged to use to help their consumers learn about the important role they play in recycling and establishing a circular economy:

host of these YouTube edu-tainment videos, he educates consumers about the importance of recycling. Recycling Rex talks with students at Emory University about their recycling habits—with the goal of inspiring viewers to not only take action by recycling but also share this video series to help educate their friends about how one small step can have a big impact. Watch the videos at putitinthebin.org/recycling-rex. #YouCan #WeWill: IBWA's most recent recycling campaign includes messages that encourage consumers to recycle their plastic beverage containers, while also educating them about some of the proactive environmental stewardship steps the bottled water industry has taken. Find these messages at putitinthebin.org/youcan-wewill.

The Way Forward Increasing U.S. recycling rates and infrastructure, improving plastic waste management in low-income countries, and developing breakthrough packaging alternatives are complicated issues, but they can be tackled successfully. “We’re not going to solve this problem overnight,” Baca admits. “This is a really difficult, multi-faceted challenge that not just impacts our industry, but impacts consumers and a bunch of others along the way. We acknowledge that more needs to be done, but at the same time we know that we’re on a positive path to having an impact.” BWR

Chris Torres is IBWA’s Communications Coordinator. Contact him at ctorres@bottledwater.org.

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Building a Strong and Lasting Grassroots Program: 3 Keys to Success

By James Toner, IBWA Director of Government Relations

For any association working to impact public policy, you must have an inspired and strategic grassroots advocacy program. You also need to have knowledgeable volunteers who are willing to work with legislators to ensure they understand your issues. IBWA is fortunate; the bottled water professionals engaged in our grassroots activities are some of the best in the business. However, grassroots activation has undergone a significant evolution. Strategies that were pillars of solid grassroots programs five or 10 years ago—such as the threepronged approach of emails, in-person plant tours, and face-to-face meetings in Washington, DC, or state capitals—are 24 • BWR • WWW.BOTTLEDWATER.ORG

no longer the norm. Today’s advocacy efforts connect online and offline initiatives, and rely on educational social media campaigns, scientific research, and virtual meet-and-greets with legislators. However, the following three principles remain the foundation for a functional grassroots program.

1. Know Your Issue A major mistake that many grassroots programs are guilty of is trying to do too much. Any advocacy campaign organizer needs to understand that even passionate, motivated advocates have their limits. If you request too much

from your volunteers, you risk them losing interest and ending their participation in the program. That’s why it’s important for grassroots efforts to focus on a few, high-profile issues that will benefit from advocate participation.

To help ensure success on those issues, you need to provide your volunteers with all relevant information that supports your efforts. The fastest way to deplete your volunteer group is to send them to meetings (whether virtual or in-person) without appropriate and fact-based supporting details. Make it a priority to develop white papers, talking points, infographics, and webpages on any issue of importance to the industry.

GOVERNMENT RELATIONS 2. Know Your Audience Determine your target, then identify your advocates. When you know who your external audience is, you can more easily identify the advocates among your grassroots participants who will have the most influence. But to do that, you need to have an in-depth understanding of your volunteers, the issues that are important to them, their level of comfort working with legislators, and their motivation. One way to reveal such information is by conducting a political inventory survey. The sidebar below provides a few examples of the types of questions that survey should ask potential advocates.

Here’s an example of why such a survey is important. Years ago, when on staff at the Public Affairs Council, I helped numerous corporations develop their grassroots programs. During a major airline’s annual meeting, a trade show was held, and our government relations team staffed a booth. A reservation agent for the airline stopped by to chat with us, and much to our surprise, we learned that this individual was also an elected official in the Texas state legislature. The company had no idea!

Conducting a political inventory would identify such people assets early on.

3. Know Your Message While not an easy task, it is vitally important that your grassroots program has a focused message that is repeated by all your advocates. Make every effort to keep any messaging on a specific issue uniform, concise, and on point; however, know upfront that ensuring your advocate volunteers do the same will take extra effort.

The term “like herding cats” comes to mind, but there are ways to manage your communications and keep everyone repeating the same message.

You must make it a priority to provide advocates with issue updates

regularly. That includes sharing the latest talking points and communication tips to ensure they know what to say and how best to communicate the facts to policymakers. When speaking with your volunteers, avoid technical or industry jargon as much as possible.

Lobbyists and advocates who have been on the legislative front lines at state capitals or in Washington, can get carried away using acronyms and insider lingo. It’s better to keep it simple and steer away from government-speak because you want to talk with your advocate team the way you want them to talk with officials. Legislators want to hear real-life stories from their constituents—not someone entrenched in industry and government lingo. Keep in mind that one conversation with a legislator won’t be enough to inspire him or her to support your efforts. For a U.S. senator or representative, it may take more than 100 “touches” to get action; thankfully, the outreach number drops drastically for state and local policymakers.

GRASSROOTS EFFORTS SHOULD FOCUS ON A FEW HIGH-PROFILE ISSUES. One final tip that can make a world of difference: thank your advocates.

Nothing sours a person’s involvement in your grassroots effort more than not being recognized for their time and contributions. You don’t need to give flowery speeches or extravagant gifts. A simple, hand-written thank you note lets your volunteer advocates know their work is appreciated—and that you couldn’t do it without them. BWR

DISCOVER HIDDEN ASSETS WITH A POLITICAL INVENTORY SURVEY Below are a few questions you might elect to use on your next survey of volunteer advocates to identify what motivates them and how they can best help the industry achieve its goals.

• Do you have any prior experience in the political realm?

• Do you have any established relationships with policymakers?

• Have you ever worked on a campaign or run for office?

• Do you belong to any local civic organizations?

• Have you ever contributed to a political action committee (PAC)?

• Have you ever written an op-ed for your local newspaper?

• Do you know anyone who is an elected official? If so, would you be willing to share important industry information with that individual?

• Have you ever volunteered at a polling site?

• Have you ever participated in any of the following: a grassroots campaign (letters, emails, and calls to elected officials); organized meetings with elected officials (fly-ins, plant tours, Capitol Hill days); or volunteered at your local community meetings (city or town, boards, or committees).

MAR/APR 2021 • BWR • 25

Spreading Recycling Education Through Partnerships

By Chris Torres, IBWA Communications Coordinator

To many consumers, recycling sounds easy: look for the chasing arrows symbol and place item in recycling bin. Unfortunately, it isn’t that simple.

Those chasing arrows only indicate that the item is recyclable—not that your local recycling program accepts that material. In fact, you may contaminate the recycling stream by placing an unaccepted recyclable into the recycling bin. What consumers need to know is to look for the number inside the arrows because it refers to the type of material an item is made from, and that’s how they can determine if it will be accepted by their local recycling program. The confusing truth is that 26 • BWR • WWW.BOTTLEDWATER.ORG

one recyclable item may be accepted by your town's recycling facility but not accepted by another town in your state.

Here’s something else consumers need to know: bottled water containers are 100 percent recyclable, even the caps. While there are thousands of jurisdictions setting independent recycling policies and regulations across the United States, no matter where you are you can always recycle your plastic bottled water containers.

However, the general confusion about which materials are and aren’t recyclable—or are and aren’t accepted by a specific recycling program—can frustrate consumers and ultimately

discourage them from recycling.

To ease that frustration, IBWA has partnered with several organizations to help make the recycling process easier to understand.

Aligning With Others to Teach the Importance of Recycling After decades of promoting the importance of healthy hydration, IBWA was thrilled to see bottled water overtake carbonated soft drinks to become the No.1 packaged beverage in the United States (by volume) in 2016—a title it still holds today. What outsiders might not know is that IBWA has also been

COMMUNICATIONS

actively educating consumers about the verifiable truth that bottled water has the smallest environmental footprint of all packaged drinks. The fact that our containers are 100 percent recyclable is just one aspect of our environmental stewardship. But, it’s an important one.

For many years, IBWA has taken on a decidedly larger advocacy role for recycling issues. One reason the association placed itself on the front lines was because critics of bottled water continue to use the confusion surrounding recycling logistics and low recycling rates to fuel their agendas to establish anti-plastic or anti-bottled water legislation. Such proposals are not the answer, and IBWA leadership knows that the collective “we” needs to work on educating consumers more about the importance of recycling and improving the U.S. recycling infrastructure. So, we partnered with the following likeminded organizations.

The Recycling Partnership. IBWA is proud to be an active partner with The Recycling Partnership (TRP). On its website, TRP provides useful resources you can use to educate consumers about recycling.

Its “Recycling 101” webpage presents the “Top 10 Recycling Facts,” such as “Recycle plastic bottles with the cap on,” and includes a brief explanation for each statement (recyclingpartnership.org/ recycling-101). In addition, TRP offers free-of-charge social media kits with materials that can supplement your usual company promotions on social media. TRP’s kits include social media posts on contamination, wishcycling, and recycling best practices.

The most recent kit in TRP’s collection covers recycling during the COVID-19 pandemic. Because the public has been advised to stay safe by staying home, people’s recycling behaviors have changed. TRP’s COVID-19 kit focuses

NEVER UNDERESTIMATE THE VALUE OF PARTNERSHIPS. on pandemic-specific anti-contamination information, including how to properly dispose of masks, gloves, and wipes.

It also has messaging on no-contact recycling, thank you messages for recycling collectors and sorters, and messages about frequently consumed recyclable material during this time of social distancing.

Keep America Beautiful. IBWA has also joined forces with Keep America Beautiful (KAB), another nonprofit seeking to improve recycling rates and combat litter. IBWA promotes KAB’s America Recycles Day (November 15) annually on our social media channels, and both organizations cross-promote recycling education posts throughout the year. Recently, IBWA Vice President of Communications Jill Culora was interviewed by KAB for a Q&A blog post in which she discussed the importance of the partnership, how IBWA encourages consumers to recycle properly, and more (kab.org/qa-with-internationalbottled-water-associatons-jill-culora).

Like TRP, KAB offers content and educational materials that can help IBWA members communicate the importance of recycling to consumers.

KAB’s “Improve Recycling” webpage features articles about sustainability, recycling at work, recycling in public spaces, and more (kab.org/goals/ improve-recycling). KAB recently launched a webinar series discussing how to transition to zero-waste communities. These sessions discuss transformative corporate initiatives, consumer

behaviors, innovations, and other topics relevant to achieving zero-waste communities. Register to attend these KAB webinars at kab.org/happenings/resources/ webinars/zero-waste-communities.

U.S. Alone Can’t Fix a Global Issue Most would agree that advocates for legislation that targets plastic manufacturers and bottled water have good intentions to secure a stable environment for future generations. What they don’t have is an understanding of the facts.

Plastic waste is a global issue—and any proposals that seek to ban the sale of bottled water at local levels within the United States will do little to nothing to solve that global issue. In fact, after reviewing pertinent scientific data, researchers at Oxford University have stated that “[i]f North America [and] Europe were to completely eliminate plastic use, global mismanaged plastic would decline by less than 5 percent” (ourworldindata.org/plastic-pollution).

What can help is an active consumer population that sees the value in recycled plastics and pledges to be active recycling participants. IBWA’s partnerships with TRP and KAB play an important role in developing and distributing pro-recycling content and collateral that help consumers learn the facts about the recyclability of our products and the need to increase recycling rates. If we are to be successful, the bottled water industry needs more such collaborations to ensure our important recycling messages are heard. BWR

MAR/APR 2021 • BWR • 27

Revised IBWA Bottled Water Code of Practice Covers FDA’s PC Rule and More

By Bob Hirst, IBWA Senior Vice President of Education, Science, and Technical Relations

The most recent edition of the IBWA Bottled Water Code of Practice (commonly referred to as the “Code” or “CoP”) was released in November 2020 and became effective in January 2021. The primary objective of this revision was to update the Code to be consistent with the U.S. Food and Drug Administration’s (FDA) new Food Safety Modernization Act (FSMA) regulations, especially the preventive controls rule (PC Rule). In addition, since the Code was previously updated in 2016, there have been other regulatory and technical changes that mandated revisions.

28 • BWR • WWW.BOTTLEDWATER.ORG

Just like the regulatory process, updating IBWA’s technical documents is a time-consuming and deliberate endeavor. Early revisions to the 2016 Code included excerpts and more detail from the FSMA PC Rule, including a copy of the rule in the document’s appendix.

However, those revisions resulted in a Code of Practice that was bulky and less user-friendly, which discouraged IBWA members from routinely using it.

The current document is more streamlined and includes references to sections of the PC Rule. IBWA will include a full version of the PC Rule in Chapter 7 in the upcoming revision to the IBWA

Plant Technical Reference Manual (PTRM). In addition, the appendix of the PTRM includes FDA references used in the Code of Practice.

Provided on the following page are detailed descriptions of the recent revisions IBWA made to its Bottled Water Code of Practice. To help ensure members stay aware of the regulation coverage provided in the Code, IBWA suggests that you download the latest version and have it with you while you review these changes. (See sidebar on p.29 for instructions on downloading the November 2020 revision of the IBWA Bottled Water Code of Practice.)

TECHNICAL UPDATE Board-Approved Policy Changes Because the three revisions below involved a change in IBWA policy, the IBWA Board of Directors had to approve them.

• Rule 3(a) / page 10: Revising the records retention time from 5 years to 2 years to make it consistent with FDA’s requirements for records retention in the PC Rule.

• Rule 4(e) / page 16: Same as in (1) above.

• Rule 5(c) / page 17: Same as in (1) above.

Additional Revisions Other updates IBWA made to its Code of Practice include the following: 1. All references in the revised document to “Model Bottled Water Regulation” or “Bottled Water Model Code” and “Model Code” have been revised to “Bottled Water Code of Practice” and “Code of Practice” or “Code,” respectively.

2. Foreword / page 4: the reference to FDA’s Good Manufacturing Practices (GMPs) has been revised to incorporate the full PC Rule (“Good Manufacturing Practices (GMPs) and preventive controls regulations”).

3. Rule 1(b) / page 6: The cross reference was updated to include more information from the PC Rule.

4. Rule 2(b) / page 9: The reference for mitigation of total coliform and E. coli positive test results was changed to the FDA regulatory cite.

FDA has advised IBWA that the former text in Appendix C did not fully conform to the intent of the 2009 FDA “coliform rule” for bottled water. Therefore, until an acceptable response procedure is developed, the Code will refer members to the FDA regulation for mitigation of contaminated source water.

5. Rule 3(a) / page 10: The reference to the FDA PC Rule (21 CFR 117) was added.

6. Rule 3(b) / page 10: The reference to the FDA PC Rule (21 CFR 117) was added. Also, a list of food safety plan components required by 21 CFR 117 has been added.

7. Rule 4(a)(2) / page 15: “except as is noted in Appendix A” was added to accommodate sampling/testing frequencies other than annual required

by FDA and/or the states.

8. Appendix A / page 22: Added IBWA monitoring/testing/standard of quality (SOQ) requirements for polyfluoroalkyl substances (PFAS).

9. Appendix A / page 24: Added two notes regarding a future revision by FDA of the bottled water standard of quality for fluoride. As of the date of this Code revision, FDA has not published an effective date for its revised fluoride SOQ. So, until that is completed, the existing range SOQs will apply.

10. Appendix C / page 26: The reference for mitigation of total coliform and E. coli positive test results was changed to the FDA regulatory cite. FDA has advised IBWA that the former text in Appendix C did not fully conform to the intent of the 2009 FDA “coliform rule” for bottled water.

Therefore, until an acceptable

ARE YOU AWARE OF FSMA’S PC RULE? response procedure is developed, the Code will refer members to the FDA regulation for mitigation of contaminated source water.

11. Appendix D /page 27: A note was added to advise IBWA members and other Code of Practice users that the revision of the list of state bottled water regulatory agency contacts is underway. To date, response from the states has not been good, but IBWA will continue with its efforts to compile an accurate list.

Questions?

IBWA works to ensure our members are kept up to date on all federal and state regulations affecting the bottled water industry. If you have questions concerning IBWA’s revised Bottled Water Code of Practice, please contact IBWA Senior Vice President of Education, Science, and Technical Relations Bob Hirst: bhirst@bottledwater.org. BWR

DOWNLOAD THE REVISED CODE To get your copy of the revised IBWA Bottled Water Code of Practice, go to bit.ly/IBWA_ CodeOfPractice2020. The new Code became effective January 1, 2021. Notable revisions that require action from IBWA members include the following: • the reduction in retention time for most records from five to two years • added testing requirements for PFAS, which are incorporated into Appendix A of the Code.

MAR/APR 2021 • BWR • 29

CPO QUIZ

IBWA

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 Linda Amar (lamar@bottledwater.org / Fax: 703.683.4074), IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22134. Look for additional quizzes in future issues and earn additional IBWA CEUs!

Name______________________________________________________ Company__________________________________________________ Address____________________________________________________ City_______________________________________________________ State/Province______________________________________________

ZIP/Postal Code____________________________________________

Check your selection for each question

1|

The major policy change included in the 2020 revision of the IBWA Code of Practice was _____.

O Introduction of remote audits O Revision of recordkeeping timeframe from 5 years to 2 years O Addition of PFAS to Appendix A O Adoption of the FSMA Preventive Controls Rule

2|

The new regulatory reference for good manufacturing practices as well as preventive controls is _____.

O O O O

21 CFR 165.110 40 CFR 141.2 21 CFR 117 21 CFR 177

3|

The manganese-zeolite process removes inorganic iron by oxidizing iron/manganese chemically on the filter. The filter is treated with manganese sulfate and _____.

O O O O

Potassium permanganate Sodium chloride Aluminum sulfate (alum) Manganese oxide

4|

A list of state regulatory contacts can be found in _____ of the Code of Practice.

O O O O

Appendix A Appendix B. Appendix D Appendix C

5|

Water can be oxidized by aeration, chlorination, or ozonation.

O True O False

30 • BWR • WWW.BOTTLEDWATER.ORG

6|

___ is the term applied to the measure of a water’s capacity to neutralize acids.

O O O O

Acidity Colligative characteristics Buffering Alkalinity

7|

Which of the following is NOT a common mineral found in natural waters?

O O O O

Potassium Calcium Boron Magnesium

8|

Sugar is _____ and simply exists as molecules of sugar in water solution.

O Ionic O Non-ionic

9|

The chemical symbol for arsenic is _____.

O O O O

Au As Ag Al

10|

The most plentiful element in the Earth’s atmosphere AND crust combined is _____.

O O O O

Nitrogen Hydrogen Oxygen Silicon

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Why We Need a Federal PFAS Standard

AT INGD WATRER YCL BOTTLE RECFOR

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IN THIS ISSUE Three Lessons IBWA's Water for Bottlers From Stewardship Best a Wastewater Practices Guide Treatment Facility

Why Water Should Be Added to MyPlate

E

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IN THIS ISSUE States Consider Responding to Bottled Water PFAS Regulation Myths With Facts

Promoting IBWA Bottlers the Granted Recyclability Labeling Exemption of Bottled Water Containers

BOTTLED WATER REPORTER | NOV/DEC 2019

BOTTLED WATER REPORTER | JAN/FEB 2020

CALCULATING THE

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

IN THIS ISSUE IBWA Establishes Correcting a Coast-to-Coast Misinformation Advocacy Network With Bottled Water Facts

BOTTLED WATER REPORTER | MAR/APR 2020

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

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

BWR B WR

One push, one cup only

THE HEALTHY HYDRATION ISSUE PROVEN STEWARDSHIP How the bottled water industry is a leader in environmental sustainability

DOING OUR PART The positive impact of offering environmentally friendly beverage containers to eco-conscious consumers

Also Inside:

Who Will You Nominate for a 2020 IBWA Award?

IBWA Bottlers Earn "Excellence in Manufacturing" Designation A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

Also Inside:

Why Experts Recommend Water The Case for Water's Continued Inclusion in the Dietary Guidelines for Americans A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

Also Inside:

Why Meeting With Legislators Matters FDA Launches Food Safety Dashboard A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

IBWA’s award-winning, bimonthly magazine, Bottled Water Reporter, is the only trade magazine in the United States that exclusively targets the bottled water industry. IBWA has proudly been offering digital editions of its magazine online since 2009. Issues are mailed directly to IBWA members and nonmember subscribers six times a year. Bonus distribution offered during in-person IBWA Annual Business Conference and Trade Shows. IBWA members can review past issues by logging on at www.bottledwater.org and then selecting Member Dashboard under the Membership tab. Click the "Bottled Water Reporter" button for access to the archive.

Contact Stephanie: 817.719.6197 / stephanie@bottledwater.org.

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BOTTLED WATER: BY THE NUMBERS 8% HDPE

PET Bottle Market 35% water

HDPE Bottle Market 10% water bottles

65%

non-water bottles

bottles

92% PET

The single-serve, gallon, and 2.5-gallon bottled water market uses two types of plastic packaging: PET and HDPE.

90%

non-water bottles

In addition to bottled water containers, PET is a popular packaging material for bottles containing salad dressings, peanut butter, shampoo, liquid hand soap, among other products. Most people recognize HDPE because it is used for milk and bottled water jugs.

CURRENT RECYCLING RATES

PET 28.9%*

* The Current Recycling Rate for PET Water Bottles Is 33%.

HDPE 29.3% Sources: NAPCOR, EPA

273

rPET rHDPE To meet a 25% target for recycled content use nationally, the PET recycling rate would need to be 52% (an increase of 23%); HDPE would need to be 38.5% (a 9.5% increase). While the HDPE target is not as high as the PET target, it faces unique technical challenges, as most rHDPE goes to non-food bottles.

To increase the PET recycling rate to 52%, every American, on average, would need to recycle 273 PET bottles/containers per year.

Source: Unless otherwise noted, data source is “Analysis of Food Grade rPET and rHDPE in the United States,” Resource Recycling Systems (RRS), 2020 32 • BWR • WWW.BOTTLEDWATER.ORG

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