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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 a Podcast When Meeting With Legislators Can Educate Consumers About Is Crucial Bottled Water



The Sweeping Reform of FSMA Affects All Bottlers Are You Prepared?

Also Inside:

Using #FastFacts to Spread the Truth About Bottled Water on Social Media A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

Why FSMA Impacts IBWA's Audit Checklist

VOL. 58 • NO. 3


24 | The Business of Advocacy How to sell policy products through engagement. COMMUNICATIONS

26 | The Thirsty Business of Podcasting Discover why IBWA launched “H2O in the Know,” a podcast that discusses all things water, especially bottled water. TECHNICAL UPDATE

28 | Changes Are Coming to the IBWA Audit Program Learn how FSMA’s Preventive Controls Rule affects IBWA’s audit checklist.

Are You Posting #FastFacts? Turn to p.32 to learn about IBWA's latest social media campaign.

TABLE OF CONTENTS 10 | HOD Trucking: What’s on the Road Today As the home and office delivery (HOD) segment of the bottled water industry continues to grow, truck innovations continue to be highly sought-after by bottlers. This article reviews recent improvements to HOD truck design, including alternative fuel options. By Chris Torres

18 | FSMA: A Tough Act to Follow? Now that the U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) is well on its way to being fully implemented, what can bottlers expect from FDA inspections and what has IBWA done to help members prepare? Read this article to find out. By Kim Wheeler

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


BOTTLED WATER REPORTER, Volume 58, Number 3. 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.


Lately, I’ve been traveling to a few regional bottled water meetings to tout the work of IBWA and encourage membership in this great association. My presentations provide a lot of information about the issues currently top-of-mind for IBWA. One such issue, which is also covered in this issue of Bottled Water Reporter, is the importance of the Food Safety Modernization Act (FSMA) to the bottled water industry. This sweeping reform of the nation’s food safety system shifts the focus from responding to foodborne illness to preventing it. For years, IBWA has been working to help our members prepare for the changes brought about by FSMA. We've offered webinars, confer­ence sessions, articles in this magazine and the association’s e-newsletter (Splash), guidance documents, and other resources. Those educational tools were developed to help members prepare for the U.S. Food and Drug Administration inspections that are sure to follow now that, as of August 30, 2018, all bottled water bottlers—no matter your size—must have FSMA-compliant preventive controls in place. But FSMA isn’t the only topic we’re focusing on. In recent years, we’ve noticed an increase in the attempts by anti-bottled water groups to prevent bottled water companies from siting, permitting, and re-permitting their plants in the United States. While the actions of those groups are often aimed at large bottled water companies, many of their proposals would also impact small and mid-size bottlers. For example, the 2016 Cascade Locks ballot initiative enacted in Oregon prevents bottled water companies that are using more than 1,000 gallons per day from operating in the county—that would impact even the smallest bottlers. IBWA has worked with both large and small bottlers to help them defend against these onerous attempts to keep them from providing America’s favorite packaged beverage to consumers: bottled water. We’ve formed a special working group of IBWA members to develop strategy; opposed state and local legislation that would prevent our members from siting, permitting, or re-permitting their plants; developed resources to address issues raised when communities object to a bottled water plant; drafted a water stewardship code of practice; and identified allies and third-party organizations that can support our efforts. We’ve crafted that information and made those partnerships because our mission is “to serve the members and the public by championing bottled water as an important choice for healthy hydration and lifestyle, and promoting an environmentally responsible and sustainable industry.” And we want to do the same for you. If you aren’t currently an IBWA member, won’t you join us?

Lynn Wachtmann IBWA Chairman 2




International Bottled Water Association OFFICERS Chairman Lynn Wachtmann, Maumee Valley Bottlers, Inc.. Vice Chair Vacant Treasurer Brian Hess, Niagara Bottling LLC Immediate Past Chairwoman Shayron Barnes-Selby, DS Services of America, Inc.

BOARD OF DIRECTORS Shayron Barnes-Selby, DS Services of America, Inc. Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America Tara Carraro, Nestlé Waters North America Andy Eaton, Eurofins Eaton Analytical Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Kari Mondt, Allied Purchasing Greg Nemec, Premium Waters, Inc. Dennis Rivard, Crystal Mountain Products, Inc. Bryan Shinn, WG America 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 Lynn Wachtmann, Maumee Valley Bottlers, Inc. Shayron Barnes-Selby, DS Services of America, Inc. 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 Henry R. Hidell, III, Hidell International Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Bryan Shinn, WG America Company William Patrick Young, Absopure Water Co., Inc.

COMMITTEE CHAIRS Communications Committee Julia Buchanan, Niagara Bottling, LLC Audrey Krupiak, WG America Company Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee Jeff Davis, Blackhawk Molding Co. Government Relations Committee Derieth Sutton, Niagara Bottling LLC Viola Johnson Jacobs, DS Services of America, Inc. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, DS Services of America, Inc. State and Regional Associations Committee Joe Cimino, ChoiceH2O Supplier and Convention Committee Dan Kelly, Polymer Solutions International Technical Committee Andy Eaton, Eurofins Eaton Analytical Kevin Mathews, Nestlé Waters North America


NOV/DEC 2016




According to preliminary numbers from Beverage Marketing Corporation, the home and office delivery (HOD) segment of the bottled water industry has grown 16.2 percent since 2012. That’s good news for the majority of IBWA bottler members because most work in HOD. The customer service aspect of HOD is often talked about; IBWA even has a Route Salesperson of the Year award (for more on this, turn to p.7). However, we don’t often take the time to discuss the vehicles that make the “delivery” of “home and office delivery” possible. In this issue of Bottled Water Reporter, we look at some of the innovations in truck design. Our cover story, “HOD Trucking: What’s on the Road Today” (p.10) by IBWA Communications Coordinator Chris Torres, highlights the emergence of propane autogas as an alternative fuel option for bottlers. We also review the improvements to the everyday functions of HOD trucks that are making the job of being a route salesperson a little easier. In our second feature, “FSMA: A Tough Act to Follow?” (p.18), author Kim Wheeler discusses with IBWA Vice President of Education, Science, and Technical Relations Bob Hirst the changes bottlers can expect now that the U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) is well on its way to being fully implemented. (Hint: There’s an increased emphasis on records and recordkeeping.) Wheeler also reviews the many FSMA resources IBWA has developed—including guidance documents, webinars, and workshops—to help members prepare to be FSMA compliant. FSMA has been described as “the most sweeping reform of our food safety laws in more than 70 years,” so I’m sure this is an article you’ll want to read. The focus on FSMA continues in our Technical Update column (p.28), where we discuss how the Act, particularly the Preventive Controls Rule, impacts IBWA’s audit program. In our last issue, the Communications column (p.26) announced that IBWA has partnered with Keep America Beautiful to increase the reach of our pro-bottled water, pro-recycling messaging. We have another exciting announcement for this issue: IBWA is launching a podcast, “H2O in the Know,” as yet another platform to help us spread the good news about bottled water. Lastly, our Government Relations column (p.24) discusses the business of advocacy and explains why it is important for IBWA members to engage with their elected officials—because if you don’t teach them about the bottled water industry and how their policy decisions impact your business, who will? I’d like to close by inviting all IBWA members to join us in Alexandria, Virginia, June 4-7, for the June Board and Committee Meetings. We’ll be sure to continue the discussions started in this issue of BWR—and more!

Joe Doss IBWA President





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

IBWA STAFF President Joe Doss Vice President of Education, Science, and Technical Relations Robert R. Hirst Vice President of Communications Jill Culora Vice President of Government Relations Cory Martin Director of Conventions, Trade Shows, and Meetings Michele Campbell Director of Government Relations J.P. Toner Director of Science and Research Al Lear Director of Communications Sabrina E. Hicks Manager of Member Services Cheryl Bass-Briscoe Education and Technical Programs Coordinator Claire Crane Communications Coordinator Chris Torres 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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IBWA members Plastipak, Roush CleanTech, and Absopure hosted an event for Michigan Governor Rick Snyder (center) on February 2, 2018. During the event, Governor Snyder announced the state’s goal to increase overall recycling from 15 percent to 45 percent.


IBWA Webinar Explains How to Be a Successful Advocate On April 10, 2018, IBWA hosted a webinar that examined the current makeup of Congress, explained how to connect with members of Congress and their staff, and reviewed what actions IBWA members can take now to later influence policies at the state and federal levels. IBWA Vice President of Government Relations Cory Martin led the webinar. Key takeaways from the lesson included the following: • Many members of Congress and their staff have little to no experience in manufacturing, much less bottled water production. 6



Therefore, it is crucial that IBWA members spend time educating officials and staff on the industry. • Personal contact with elected officials is best when forging relationships and influencing action. • While the first meeting is important, follow-up is critical to maintaining relationships with elected officials. IBWA members who missed the webinar but would like to view a copy of the presentation can contact Cory: cmartin@bottledwater. org. For more on how to develop relationships with

IBWA Launches PAC Webpage IBWA recently launched a publicfacing webpage dedicated to providing information about the IBWA Political Action Committee (PAC). This webpage includes information on what the IBWA PAC is all about and explains how it helps the industry, how to become a PAC Program Sponsor, and more. It also houses a link to the IBWA PAC member-only website, which contains more specific information on PAC news, strategies, and events. Visit for more information.

elected officials, read this issue’s Government Relations column on page 24.



USDA and HHS Request Comments on Dietary Guidelines; IBWA Responds IBWA provided written comments on March 30, 2018, to the U.S. Departments of Agriculture (USDA) and Health and Human Services (HHS), regarding the topics and questions to be examined in the review of scientific evidence supporting the development of the 2020-2025 Dietary Guidelines for Americans (DGAs). The written comments supplemented previous oral comments by IBWA, given at a USDA 2020 Dietary Guidelines for Americans listening session held November 28, 2017. All comments submitted to the docket are available at docket?D=FNS-2018-0005. During a webinar in late February, USDA Acting Deputy Under Secretary Brandon Lipps said that USDA and HHS were requesting comments on the proposed topics and supporting questions as a new step in the dietary guidelines development process. This change was made to enhance transparency, increase opportunities for public participation, respond to recommendations and feedback, and

help identify the expertise required on the Dietary Guidelines Advisory Committee (DGAC). The proposed topics and scientific questions for comment were grouped by life stage: • Pregnancy and lactation • Infants and toddlers from birth to 24 months (healthy, full-term infants) • Children and adolescents, ages 2-18 years old (with data reviewed by age group) • Adults, ages 19-64 years old (with data reviewed by age group) • Adults, ages 65 and older. In our comments, IBWA supported the USDA/HHS inclusion of water as part of complementary beverages and beverages in the topics for each of the life stages. IBWA also requested that the specific hydration needs related to adults ages 65 and older also be considered. Proper hydration is an important consideration for the wellbeing of everyone, but it is of increased importance for older adults.

IBWA’s proposed MyPlate revision, shown here, includes water.

An additional category titled “Consumer Education on the Dietary Guidelines for Americans” was also recommended by IBWA. That category would determine if the MyPlate nutritional graphic that is used today reflects the current science on the role of food and beverages (including water) in a healthy diet. In particular, IBWA requested that the DGAs recommend that water be added to the MyPlate graphic. Additional information is available on the 2020-2025 Dietary Guidelines for Americans webpage: www.cnpp.usda. gov/dietary-guidelines.


The IBWA Awards Program Is Back for 2018 IBWA announces that this year it will again hold its awards program to acknowledge and celebrate the commitment of individuals and companies to the bottled water industry with the following awards: • Route Salesperson of the Year • Plant Manager of the Year • Supplier of the Year • Environmental Stewardship Award • Product Innovation Award • IBWA/Selby Advocacy Award (“The Selby”) • IBWA/Kristin Safran Directors’ Award • Bottled Water Hall of Fame

Since 1961, IBWA has recognized the contributions and achievements of bottled water professionals through its awards program. We know that without the dedication of our member companies and their staffs, the bottled water industry would not enjoy its past or current success. That’s why we encourage all IBWA members to participate in this program to recognize the valuable contributions of your employees and executives. Nominations will be accepted until June 22, 2018. Award winners will be recognized during the General Session of the 2018 IBWA Annual Business Conference and Trade Show, being held November 12-15 at the Hyatt Regency in New Orleans, Louisiana. For more information, please refer to






IBWA Board and Committee Meetings to Be Held in Alexandria, VA: June 4-7

The IBWA Board of Directors and Committee Meetings will be held June 4-7, 2018, at the Hilton Old Town in Alexandria, Virginia. All current IBWA members in good standing are invited to attend and participate in the committee meetings. Verification of current IBWA membership will be made at the time of registration. Important Deadlines • Monday, May 14: Hotel reservation cut-off • Tuesday, May 15: Meeting registration due to IBWA

• Tuesday, May 15: Exhibit application for tabletop • Friday, May 18: Capitol Hill registration due to IBWA IBWA members can register online at June_Registration. Please note that the IBWA room block may be subject to sellout prior to the deadline, so book early. Questions? Contact IBWA Director of Conventions, Trade Shows, and Meetings Michele Campbell:


DWRF Accepting Applications for the 2018 Kristin Safran Scholarship The Drinking Water Research Foundation (DWRF) is currently accepting applications from high school seniors for the 2018 Kristin Safran College Scholarship. Criteria includes the following: • Entrant must be the child or grandchild of an IBWA member employee. • Entrant must be a high school senior ranked in the top 20th percentile of his/ her class. • Entrant must plan to attend an accredited undergraduate two-year or four-year college/university. Note: The option of entrants attending a two-year college is new; however, the applicant must plan to transfer to a four-year college. High school graduates are choosing this option more often as a way of having a more affordable college education and graduating with less debt, as community college is much less expensive than four-year colleges/universities. DWRF plans to announce the winner on or about September 30, 2018. View the application on the DWRF website at Application deadline is June 30, 2018.




Scholarship Donations Wanted

DWRF is looking to increase donations to the Kristin Safran College Scholarship. Foundation trustees are grateful for the funds donated so far for the scholarship, but it is still in its “growing stages,” and DWRF needs your contributions. If you are interested in making a tax-deductible gift to the DWRF Kristin Safran College Scholarship Fund, please go to uploads/2017/05/Kristin-SafranContribution-Form.pdf or make your checks payable to the following: DWRF Kristin Safran Fund 1700 Diagonal Road Suite 650 Alexandria, Virginia 22314


Before, during, and after any physical activity, kids need to drink plenty of water, especially in hot weather, says sports-and-performance/hydrate-right/ water-go-with-the-flow

for new opport unities to conn ect with educate them about bottled w share any of th ater issues, feel e following on yo free to ur social media sites during May and June—or b e inspired and write your own!

consumers and

May is National Physical Fitness and Sports Month. According to the Physical Activity Guidelines for Americans, adults should aim for 2 hours and 30 minutes of moderate aerobic activity each week. Examples of moderate activity include walking fast, dancing, swimming, and mowing the grass. To help keep you refreshed and motivated, make sure to drink water before, during, and after your workouts!

According to the Institute of Medicine, the total water intake for adult men (>19 years) is set at 3.7 liters per day. Knowing that foods contribute for 20-30%, the more practical guidelines in the United States for adults are that men should drink 3 liters of water per day. For more info, visit bwrjanfeb2017_final/16.

June Is Men's Health Month

National Campaigns May: National Physical Fitness and Sports Month, National Barbecue Month, National Bike Month, American Stroke Month, Drinking Water Week (May 6-12), Hurricane Preparedness Week (May 6-12), National Bike to Work Week (May 14-18), National Women’s Health Week (May 13-19), Cinco de Mayo (May 5), Thank a Teacher Day (May 8), Mother's Day (May 13), National Bike to Work Day (May 18), Annual Kids to Parks Day/National Day of Outdoor Play (May 19), Memorial Day and National Hamburger Day (May 28), National Senior Health and Fitness Day (May 30) June: Great Outdoors Month, Men's Health Month, National Safety Month, IBWA June Board & Committee Meetings (June 4-7), National Men's Health Week (June 11-17), National Doughnut Day (June 1), World Environment Day (June 5), National Running Day (June 6), World Oceans Day (June 8), Best Friends Day (June 8), National Get Outdoors Day (June 9), Father’s Day (June 17), First Day of Summer (June 21), National Selfie Day (June 21), Take Your Dog to Work Day (June 22), National Sunglasses Day (June 27), National Handshake Day (June 28)

What should be in your hurricane kit? #HurricanePrep #HurricaneStrong Download:

How much water should your kid drink? pin/414964553160415196

(Post on May 19) On this National Day of Outdoor Play, grab your kids and some bottled water–America's favorite packaged beverage–and visit your favorite park! If you need help picking an outdoor activity, use this guide, courtesy of uploads/2018/03/30Things.pdf.

Bike to Work Day–May 18–is an annual celebration of active transportation. Join others who have helped to grow the biking community–just don't forget to take along bottled water for hydration– and recycle it at the end of your ride!

May 18 is Bike to Work Day! Download:

Adequate water intake can be a real challenge for older adults. These tips can help!

Hurricane Preparedness Week: May 6-12 starts Pacific hurricane season e May 15; Atlantic hurrican season starts June 1.

[Post May 13-19, National Women's Health Week] When mildly dehydrated, women report headaches, increased task difficulty, and loss of concentration. #DrinkMoreWater

(Post on June 8, World Oceans Day) By ALWAYS recycling your empty bottled water containers, you are doing your part to help keep plastic out of our oceans. Always #PutItInTheBin fastfacts

HOD TRUCKING WHAT’S ON THE ROAD TODAY? Many of today’s home and office (HOD) delivery trucks drive smoother, sound quieter, require less maintenance, and are more environmentally friendly than in years past. More are using alternative fuels that release fewer emissions than diesel and gasolinepowered trucks. Some bottled water companies are turning to propane-powered vehicles to make their daily deliveries. In addition, trucks on the road today are equipped with advanced technologies such as back-up cameras and keyless side panels that are able to be locked and unlocked at the push of a button.





The purpose of these technological upgrades is to make the job of the route salesperson easier. But delivery vehicle improvements are not the only way that the bottled water industry is pushing for innovation and reform. The industry is also advocating for safer and improved roads and contemplating increases in truck weight limits, which would ultimately mean fewer trucks are on the road. Until such changes happen, the industry continues to make improvements in other areas to do less harm to the environment. One improvement involves the use of propane fuel.

The Emergence of Propane Autogas IBWA supplier member Roush CleanTech began using propane autogas technology in 2006 and has developed propane vehicles for school districts, public transportation, airports, as well as the bottled water industry, among others. NestlÊ Waters North America and Absopure Water Company are two bottled water companies currently using Roush’s propane autogas vehicles. NestlÊ currently operates 600 of the vehicles for its ReadyRefresh delivery service, which is about 30 percent of its North American fleet.




STATE OF THE BEVERAGE FLEET In September 2017, Beverage Industry magazine published the results of its fifth annual fleet survey. That data presents the latest information on the size and makeup of current beverage delivery fleets, as well as operational concerns and strategies. The charts provided throughout this article show which operations are having the greatest impact on beverage fleets.

Among the most highly touted qualities are the vehicles’ cost efficiency and reduced emissions compared to diesel vehicles. Propane fuel is 30 to 40 percent cheaper than standard gasoline, and it is about 50 percent less than diesel fuel, says Gregg Voss, a Roush CleanTech spokesperson. The propane fuel also emits 25 percent fewer greenhouse gases, 20 percent less nitrogen oxide, up to 60 percent less carbon monoxide, and 40 percent fewer smog-producing hydrocarbons. The engines used are 75 percent cleaner than the current U.S. Environmental Protection Agency (EPA) standard, and 99 percent cleaner than diesel vehicles built prior to 2007. According to Todd Mouw, president of Roush CleanTech, “The newer diesel technology has been better, but the propane engine technology that we have now is definitely quieter than a diesel truck. It’s noticeable compared to an older diesel, like a pre2010 vehicle, and even with the current diesel, it’s definitely quieter as well.”

The propane is also sourced domestically, as 90 percent of it comes from the United States. “This vehicle should last just as long as a gasoline or diesel vehicle, if not maybe longer because of the complexity of the engine,” Mouw says about the propane autogas technology. “It’s a really solid, well-built base engine from Ford that’s prepared for propane. Propane burns cleaner than traditional fuels. There’s less carbon content, so ultimately it should be the same—if not better—so from a modeling perspective, we’re not asking anyone to compromise.”

Where to Find It, and What It Can Do Companies interested in using the propane engine vehicles can elect to have a propane fueling station constructed, Mouw says. Once a company decides on having a propane station constructed, Roush brings a propane company into the process.



Owned by your company

Provided through a finance-only lease

Provided through a full-service lease



Source: BNP Media’s Market Research Division, Fleet Study 2017. For more, /90527-the-state-of-thebeverage-fleet-industry. *


Numbers might not equal 100 due to rounding.




“We’ll go to meetings, we’ll start to understand the number of vehicles the company is employing and the location they’re deploying in,” says Mouw. “The propane companies will start to do site evaluations, understand how many vehicles they’re going to have, how much fuel they’ll burn, how much real estate they’ll have to work with, look at all the different permitting requirements of that area, and then they’ll make a recommendation for installing the fuel station.” It’s less expensive to construct a propane station than a gasoline station, according to Mouw, and propane isn’t a ground contaminant risk like gasoline or diesel. And if you think that installing a propane station is cost-prohibitive for your company, Voss explains that many propane providers will install a station at no cost with a fuel contract. The technology is ideal for bottled water companies, as propane gas and engines would not impact the job required for HOD trucks, and there is no impact on bottle or payload amounts.


It’s less expensive to construct a propane station than a gasoline station.







Drivetrain 4% 11%

13% 16%

Paint/graphics 7% 7%


Collision repairs 7% 7%


29% 20%





31% 27% 25%

First Second Third

Source: BNP Media’s Market Research Division, Fleet Study 2017. For more, /90527-the-state-of-thebeverage-fleet-industry. MAY/JUNE 2018



TOP SOURCES OF UNPLANNED DOWNTIME/REPAIRS Engines Drivetrain Collision repairs Tires Brakes

44% 15%




8% 10%





26% 26%






Paint/graphics 3%5%



First Second Third


Source: BNP Media’s Market Research Division, Fleet Study 2017. For more, /90527-the-state-of-thebeverage-fleet-industry.

Keyless entry is a new feature that drastically reduces the number of times route salespeople have to open and close truck doors. It also significantly diminishes the probability of theft. Propane-powered vehicles also have another big advantage over diesel during a particular time of year—the winter. In extreme cold temperatures, diesel fuel can gel overnight while sitting unused. This clogs fuel lines and makes the engine incapable of starting. To prevent gelling, winter-time fuel additives must 14



be added to the fuel, or the vehicles must be stored in a heated garage. “The liquid propane technology thrives in severely cold weather,” says Mouw. “The colder, the better to be honest with you. You’re not having to go out there to start trucks early and warm them up. Propane and the cold are a great combination.”

Mouw said dealing with the cold is a big reason why many school districts across the United States have shifted to propane autogas technology for their school buses, which is a huge market for Roush. Almost 14,000 buses in nearly 850 school districts in 48 states use Roush’s vehicles. The food and beverage industry is the next biggest user of the technology. Other industries using Roush vehicles are public transportation, notably for para-transit buses, the energy market, and airports.

Improving Designs In addition to advances in fueling, there has also been progression in terms of design and everyday functions of HOD trucks. One of the industry’s focal points in the HOD segment is safety and convenience for route salespeople, and steps have been taken to make the job a little easier for them every day.




Route optimization


Replacing older trucks Hybrid technology


Fuel management software


Alternative fuels Driver training/ coaching

2% 0%

Source: BNP Media’s Market Research Division, Fleet Study 2017. For more, /90527-the-state-of-thebeverage-fleet-industry. *Numbers might not equal 100 due to rounding.

Besides lifting and carrying HOD bottles, another task an HOD salesperson does frequently is open and close doors. From the driver’s side door, to side panels on their trucks to grab products, and doors to the homes and offices of customers, a driver is opening and closing doors dozens—if not more—times per day.

There is now technology available for HOD drivers that drastically reduces that number. Mickey Truck Bodies, based in High Point, North Carolina, uses an electronic lock system for its side roll-up doors, providing numerous benefits. First, a keyless entry means there’s no physical lock on the doors, which

significantly diminishes the probability of theft. According to Mickey Truck Bodies, the average theft per truck is estimated at about $1,000 per year. Second, without a lock, there’s no cause for concern about broken handles or frozen locks during the winter. Drivers can open and close the doors with a key fob or at the press of a button inside the



Vehicle lifecycle costs Fuel price volatility Regulatory compliance costs Regulatory Instability Environmental impact




21% 12%



9% 5%5% 7% 7%




21% 23%





43% First Second Third

Source: BNP Media’s Market Research Division, Fleet Study 2017. For more, /90527-the-state-of-thebeverage-fleet-industry. MAY/JUNE 2018



vehicle. This eliminates the worry of lost keys if there’s a need to open any of the side doors. A manual bypass system is also available to open the doors in case of a power failure.

trucks operate successfully. “That speaks to a lot of things—driver safety, fleet profitability, durability, so the overriding trend I would say would be ease-of-use and structural strength.”

“It takes a lot of the labor away from some of these everyday functions,” says Tim Davis, senior director of corporate communications at Mickey Truck Bodies. “These are functions that the drivers go through hundreds of times a day when making routine deliveries.”

Pushing for Better Travel

As for the truck body, today’s standard truck is made from aluminum, which is more eco-friendly than steel. It weighs less, resulting in reduced strain on tires and fuel than a steel body would have. Aluminum bodies are also rust and corrosion-resistant. “The designs have to be driver-friendly,” says Davis on what makes today’s

One issue that Davis says the industry is trying to address—but is not in its control—is America’s roads. Roadway infrastructure is critical for transporting operations. “If you look at the condition of our roads, the bodies and trailers have to be able to stand up to all kinds of driving conditions and weather, so durability is important,” says Davis. “That’s one of our hallmarks.” The industry is taking action to address such transportation issues. IBWA is working with the Safer Hauling and Infrastructure Protection (SHIP) Coalition to support a voluntary 10-state program that would study the impact

of increasing truck weight limits from the current 80,000-pound limit to 91,000 pounds with a sixth axle. IBWA believes that increasing truck weight limits would not only decrease the number of trucks on the road, saving fuel and shipping costs, but would also substantially decrease the industry’s carbon footprint. In addition, evidence shows that 91,000-pound, 6-axle trucks provide for greater breaking power than 80,000-pound, 5-axle trucks, and cause less wear and tear on roadways.    

Chris Torres is IBWA’s communications coordinator. Contact him at ctorres@ IBWA Vice President of Government Relations Cory Martin contributed to this article.


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2/14/18 11:31 AM




Submit your nominations for IBWA’s 2018 Awards Program at







A TOUGH ACT TO FOLLOW? NOT FOR IBWA MEMBERS The sweeping reform of FSMA affects all bottlers, large and small, but IBWA resources help ensure your facilities are ready By Kim Wheeler

As the nation’s No.1 packaged beverage and a critical commodity in times of crisis and disaster, bottled water—and its proven record of safety—are more important than ever. Americans look to the bottled water industry to provide healthy hydration they can trust. For IBWA and its members, the safety and quality that consumers expect from their bottled water can only be ensured through diligence, awareness, evaluation, and planning—the same tenets at the root of the U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA).




Signed into law by former President Barack Obama on January 4, 2011, FSMA shifts the nation’s food defense strategy from reacting to food safety issues to preventing them. FSMA places greater responsibility for preventing contamination on food manufacturers— including bottled water producers—by establishing a risk-focused regulatory framework that requires them to analyze potential food safety hazards, implement a food safety plan, verify that it works, and take corrective action when it doesn’t.

from complying with the PC Rule altogether,” explains Bob Hirst, vice president of education, science, and technical relations at IBWA. “ The PC Rule includes provisions that these companies must be able to demonstrate with records during each FDA inspection that they are indeed qualified for the exemption by showing records that document their sales of less than $1 million per year. However, should their product become noncompliant or adulterated, the exemption can be canceled by FDA, and the bottler would be required to immediately comply with the rule.”

Perhaps the most significant of FSMA’s seven final rules for bottled water is the Preventive Controls for Human Food— known as the PC Rule.

For IBWA bottlers that don’t qualify for exemption or opt to comply with the PC Rule despite eligibility, meeting the new PC Rule requirements won’t be a “start from scratch” effort.

Perhaps the most significant of FSMA’s seven final rules for bottled water is Preventive Controls for Human Food (PC Rule), which requires food producers to have a written plan in place to prevent or mitigate potential hazards in five specific areas: process, allergens, sanitation, supply chain controls, and a recall plan. Deadlines for compliance with the PC Rule were staggered based on company size. Larger food manufacturers were the first to become subject to FSMA inspections, with compliance required by September 2016. Food producers that qualified as small businesses were next, with compliance required by September 2017. Now, the deadline for the final producer category fast approaches. Very small businesses—defined by FDA as food processors with less than $1 million in revenues—must have FSMA-compliant preventive controls in place by August 30, 2018.

Rather than developing a new food safety plan, IBWA members can simply expand their well-established HACCP and environmental controls to include the Hazard Analysis Risk-Based Preventive Control (HARPC) requirements of FSMA. Although bottlers may experience startup costs associated with some of FSMA’s new requirements and upgrading the current HACCP plan to a FSMA-compliant food safety plan, Hirst states that starting with an HACCP already in place will save bottlers time, money, and additional resources.

For some bottlers, this may not be an issue. In addition to the longer time frame afforded them to prepare for FSMA compliance, bottlers that meet the FDA definition of a “very small business” may also qualify for modified requirements and exemptions. “Under the PC Rule, very small companies [could] qualify under the definition of ‘qualified companies’ to be exempt 20



“IBWA bottler members have the immediate benefit of being ahead of the curve because of IBWA’s adoption of HACCP in 2002,” Hirst says, referring to the Hazard Analysis and Critical Control Points plan that became a requirement for IBWA membership more than a decade before FSMA was enacted. “Since that time, all IBWA member bottlers were required to have HACCP programs and plans at each of their facilities. Those HACCP plans provide the groundwork for FSMA’s food safety plans, so for most IBWA bottlers…they are building on a plan already in place.”

IBWA adopted HACCP in 2002, and those plans provide the groundwork for FSMA’s food safety plans.


“I believe that IBWA bottlers will experience less in new costs associated with the PC Rule because of our longstanding HACCP program,” he says. “Many companies in the food industry started at ‘square one’ with no HACCP program and a fraction of the records they are now required to maintain. In practice, not much should change in daily bottled water operations that would add to operating costs.”

Some bottlers that have undergone FSMA-based FDA, state, and cooperative inspections report an increased emphasis on recordkeeping. Emphasis on Recordkeeping Documenting these daily operations—and the preventive controls and safety procedures they entail—is another major focus of compliance efforts for many bottlers. Recordkeeping is a regulatory requirement, and FSMA significantly increases FDA’s access to food manufacturers’ records.

According to Hirst, many of the larger bottlers that have already undergone FSMA-based FDA, state, or cooperative inspections of their facilities report that they encountered this increased emphasis on records and recordkeeping. “The FDA and state inspections are more focused on records as evidence of daily compliance with the GMP [good manufacturing practice]and food safety operations at each bottling facility,” he explains. “To stress the importance of good, accurate records and sound records management, IBWA’s outside counsel introduced the phrase, ‘If it’s not documented, it never happened.’” Hirst advises bottlers to keep thorough, detailed records and to ensure that they are complete, orderly, and reflective of daily food safety operations. He also recommends that bottlers automate their recordkeeping systems to make it easier to manage and maintain records that are accurate, accessible, and aligned with FSMA requirements. Developing records maintenance and management skills has been a point of concentration at the Preventive Controls Qualified Individual (PCQI) workshops IBWA began offering in 2016. The workshops help ensure that bottlers have a qualified resource to facilitate their FSMA compliance and enable them to meet the PC Rule requirement that each food manufacturer have a trained PCQI to draft and oversee their company’s food safety plan. Hirst encourages bottlers to consult with their PCQIs and quality assurance staff to identify areas that need improvement. (In 2018, IBWA will offer PCQI training at locations to be announced very soon.) MAY/JUNE 2018



If an FDA auditor determines that a facility needs to be re-inspected, IBWA estimates that the cost of a second visit could be more than $20,000. IBWA Guidance Document a Resource for Members IBWA also offers its members another resource they can use to identify areas needing improvement and prepare for compliance inspections. IBWA developed a PC Rule guidance document and an extended, 16-page audit checklist that bottlers can use to conduct self-audits at their facilities. Hirst explains that the guidance document and checklist were developed based on an “exhaustive” evaluation of the PC Rule and the painstaking pinpointing of every item that FDA or state inspectors could measure against a performance standard. The resulting audit checklist covers almost every area of a bottling facility that can be inspected. “IBWA has always promoted self-audits, and the new guidance and checklist should be a valuable tool in preparing for a regulatory inspection,” Hirst says, adding that he strongly recommends that bottlers take full advantage of both the self-audit checklist and IBWA’s annual audit program. Participation in the annual audit program is not only a requirement for IBWA membership, but also prepares members for FDA and state compliance inspections by identifying possible infractions and deficiencies— before they occur during inspection by a regulatory agency and present the potential for penalties or enforcement actions. Penalties for failure to comply with the new FSMA rules vary depending on the severity of the infraction. Serious infractions could require additional investigation, which could ultimately result in FDA determining that a product is adulterated and mandating a recall. 22



“FSMA expands FDA’s regulatory authority significantly, and the cost for FDA’s role in investigating a product that is adulterated or presents a risk to the health of the public can be passed on to the food producer,” Hirst warns. “In some cases, FDA may require a recall of product back to the last ‘good test’ of the product. If a week, month, or even a quarter has passed since that last test result, the cost of a recall could increase almost exponentially—not to mention the visible and invisible costs from loss of public confidence in your product.” Ultimately, Hirst says, FDA can remove the facility’s authorization to produce a food product by rescinding the facility’s FDA registration, without which the facility cannot operate legally. Even noncompliance infractions that aren’t serious enough to rate a recall or revoking a facility’s registration can be costly. If an FDA auditor determines that a facility needs to be re-inspected, IBWA estimates that the cost of a second visit to a bottling facility prompted by the findings of an initial inspection could be more than $20,000. Fortunately for IBWA members, the opportunity to use the IBWA self-audit checklist and annual audit program as practice runs for FSMA compliance inspections greatly reduces the likelihood of noncompliance infractions and their corresponding penalties. “Being able to successfully satisfy the IBWA audit checklist and perform well on the annual IBWA audit are the best indicators to a bottler of how they will fare in a regulatory audit,” Hirst says. Employing these IBWA member resources will help all bottlers—large and small—with becoming FSMA compliant. While very small businesses have a few months left to prepare, FDA and state inspections under the PC Rule are already underway and can be expected to continue. The PC Rule states that low-risk facilities must be inspected every five years at a minimum; however, FDA has renewed delegation agreements with all 50 states and most of those states inspect facilities within their respective jurisdictions on an annual schedule. “Bottlers should be prepared for inspections that are at least as frequent as they have been in past years,” Hirst explains. “Those inspections may entail anything addressed in the PC Rule—and anything related to the content of the rule. Bottle water GMPs will continue to be a part of the inspections.” Reports from IBWA members that have undergone FSMA compliance inspections indicate that each inspec-

FSMA tion is unique and that bottlers cannot predict what specific focus FDA and the states will employ.

documents, and FDA publications, as well as a partial list of consultants who specialize in FSMA compliance.

“Reports have demonstrated some inconsistencies between inspections and inspectors,” Hirst says, adding that inspections seem to vary in intensity and length and that many have ironically focused on pre-FSMA bottled water GMP regulations. “Bottlers can gain some knowledge of the new inspection regime through [industry communications], but may not find all bottlers open about their specific experiences due to confidentiality concerns.”

Following the new FSMA Act may seem daunting, but with a wealth of tools and resources at their fingertips, IBWA members can have confidence that their companies will achieve FSMA compliance and that their efforts will result in a stronger, safer bottled water industry.

Whatever the frequency and focus of future inspections, IBWA wants its members to have all the resources they need to get and stay in compliance with the new FSMA rules. On top of the PC Rule guidance, self-audit checklist, annual audits, PCQI certificate training, and a series of live and web-based seminars and workshops for each proposed and final FSMA rule, IBWA is developing a series of webinars to educate newcomers to the various facets of FSMA and provide “refresher training” to FSMA veterans. IBWA members will also continue to have access to its library of technical updates, memoranda, guidance

“As extensive as complying with the new FSMA rules seems for bottled water,” Hirst says, “we are much more fortunate as an industry that we produce a less complex, healthy product with a long record of safety. FSMA will help us maintain a level of confidence the public needs to assure they have available to them a safe and healthy food product.”

Kim Wheeler is a freelance journalist who has written for military publications and special interest groups for more than 10 years.

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P.O. Box 310 • Newtown Square, PA 19073 • (610) 325-7500 •




The Business of Advocacy Selling Policy Products Through Engagement By Cory Martin, Vice President of Government Relations

Do you know the age of most staffers on Capitol Hill? Per a recent survey, the most powerful nation on Earth is largely run by 24-year-olds, and, for many of those individuals, this is typically the first job they’ve ever held. Even a majority of members of Congress lack general business acumen and have little experience outside of politics. These elected officials, who may have very limited real-world experience relating to the issues debated in the Halls of Congress, are then asked to make decisions on myriad issues impacting your business. 24



And who advises members of Congress on issues where they have limited knowledge or life experience? Those previously mentioned 24-year-old staffers who are in their first jobs out of college— who, coincidentally, have even less experience than the members of Congress. While these elected officials and their staff are some of the best and brightest people I’ve had the opportunity to work with, it doesn’t change the fact that many on Capitol Hill have little to no experience working outside of the Beltway Bubble. For that reason, members of Congress, along with state officials,

crave input from constituents to help them overcome gaps in understanding how policies impact the real world. This is where IBWA and its members come in: we help members of Congress and state officials gain a better understanding of how policies impact the bottled water industry. As IBWA members engage in advocacy efforts, elected officials will not only better understand how policies impact bottled water but also will be more willing to take action to benefit the industry.

GOVERNMENT RELATIONS Building Your Business by Educating Elected Officials Think of engaging in advocacy in terms of building your business. You have a fantastic product to sell, and you need people to buy-in to your product in order to grow your business. You cannot assume your customers know everything about you, so you start by educating them on all aspects of your business and why it’s a good move to purchase your product. Advocacy with Congress and state officials is very similar. You have a product to sell: a policy stance or action they need to take on legislation. You will need to gather data necessary to sway an elected official to embrace your product, and then stay constantly engaged to make sure you have a customer for life. While it arguably should be the other way around, where you are the customer to your elected officials, this is not the case. There are hundreds, thousands, or possibly millions of customer constituents that are competing for the attention of your elected officials, so, unless you are engaged in selling your product, you run the risk of others outside of your business and industry dictating to policymakers what is best for your interests.

Effective Engagement There are many ways to engage with your members of Congress and their staff, each with differing levels of success. This includes participating in a grassroots letter campaign led by IBWA, or writing a personal letter or email to your elected officials. A higher level of engagement includes personal phone calls to offices, attending local town hall events, participating in state and national fly-ins, and inviting officials to tour your plant. Research shows that any engagement can make a difference, but face-to-face interactions tend to lead to the best policy outcomes.

AS IBWA MEMBERS ENGAGE IN ADVOCACY EFFORTS, ELECTED OFFICIALS WILL NOT ONLY BETTER UNDERSTAND HOW POLICIES IMPACT BOTTLED WATER BUT ALSO BE MORE WILLING TO TAKE ACTION TO BENEFIT THE INDUSTRY. IBWA stands ready to help you engage in the advocacy efforts that best suit your interest and abilities. We invite you to participate in the June 6, 2018 IBWA Annual Hill Day, as well as flyin opportunities such as the Hot Dog Lunch on Capitol Hill, which occurs annually in July, and the Fall Fly-in on September 26. While I strongly encourage you to participate in IBWA fly-in activities held in Washington, DC—because your attendance helps show the strength of the industry—if you are not able to make it to those events, IBWA staff will be happy to host you anytime you are able to make it to DC to visit with your elected officials. In addition, we stand ready to help set up meetings with your state officials as well, as relationships with policymakers are critical across the country. We can also help you host your state or local officials at your local plant. Being able to offer a firsthand look at how your company does business is always helpful to policymakers in realizing the real-world impact that legislation and regulation has on constituent businesses. Your elected officials crave constituent connections. They, along with their staff, need input from constituents to understand how policies impact the real world. All that is needed to help build

and maintain these critical relationships with elected officials is a willingness to make a connection. This connection will help bridge the knowledge gap that can exist in Congress, and across the country in state legislatures, and help bring about policies benefiting the bottled water industry and its customers.


Regardless if you are an advocacy veteran or rookie, IBWA looks forward to your participation in our Capitol Hill Days. Below are the events we have scheduled for the rest of the year. Mark your calendars and plan to join us as we visit members of Congress on Capitol Hill! • JUNE 6 Capitol Hill meetings during the IBWA Board of Directors and Committee Meetings, being held in Alexandria, VA, June 4-7 • JULY TBD Annual Congressional Hot Dog Lunch • SEPTEMBER 26 Capitol Hill Fly-In For more information, contact IBWA Vice President of Government Relations Cory Martin:




The Thirsty Business of Podcasting By Chris Torres, IBWA Communications Coordinator

The podcast—a program (as of music or talk) made available in digital format for automatic download over the Internet—is an increasingly popular medium that can be easily consumed at home or on-the-go. According to a recent study by Nielsen (, more than half of all U.S. households—60 million homes—include podcast listeners. 26



That study is of significant interest to the bottled water industry because it specifically highlights bottled water as a key advertising category out of the 300 it examined for the study. Podcast listeners have a $2.8 billion impact on bottled water sales, according to Nielsen. The study points out that 104 million American homes (84 percent) buy bottled water. Of that 104

million, 51 percent are podcast listeners. Within that 51 percent, 12 million are considered “avid” podcast fans and spend $56.16 per year on bottled water; “average” listeners spend $52.33 on bottled water annually. Some podcast genres influence bottled water sales more than others. Listeners of sports and recreation podcasts have the most influence,

COMMUNICATIONS spending an average of $56.74 on bottled water per year. By no means am I a podcast expert, but I would consider myself an avid listener, as I listen to podcasts nearly every day of the week. In fact, I’ve been listening to podcasts for about seven years now, and the library of podcasts I listen to has grown substantially. I’m 30 years old (yes, a millennial), and many of my peers and others are also listening. So, from my personal experience— and the figures cited by the Nielsen study above—I can attest to the fact that podcasting offers the bottled water industry a unique opportunity to ensure consumers know the truth about bottled water. That’s why I’m excited to announce that IBWA is taking a leap into the medium and hosting its own podcast.

healthy hydration and recycling. On a lighter note, in another episode we chat with Mark Kraham, a water tasting judge at the Berkeley Springs International Water Tasting event that was held last February. IBWA encourages members to view the “H2O in the Know” podcast as another tool in their communications toolkit that they can use to share information with their current and potential customers—and help present bottled water facts in a way that is easily digestible. Listeners are bound to learn things they never knew before about bottled water, including facts about bottled water labels, the history of bottled water, the U.S. Food and Drug Administration’s regulations for bottled water, etc. The opportunities are endless.

H2O in the Know

Potential for Audience Growth

IBWA’s podcast, titled “H2O in the Know,” will debut this spring. The podcast will be about all things water, mostly related to bottled water, and provide the association another channel to connect with members and educate consumers. We’ve all experienced how false and misleading information easily spreads online, so it’s more important than ever that we also use the medium of social media to work together to keep consumers aware of the facts about bottled water. The “H2O in the Know” pilot series will include episodes that touch on topics important to the bottled water industry—and some that are just fun. For example, one episode features IBWA Vice President of Education, Science, and Technical Relations Bob Hirst. It focuses on common questions about bottled water and covers everything from the types of bottled water on the market, how bottled water is regulated, how bottled water regulation is different from tap water standards, and why plastic is used in bottled water packaging. Other episodes discuss

As more and more podcasts are becoming available, the podcast audience continues to grow. According to a survey by Edison Research ( wp-content/uploads/2018/03/InfiniteDial-2018.pdf), an estimated 64 percent (180 million) of Americans over age 12 are familiar with the term podcasting, which is up from 60 percent in 2017. Forty-four percent (124 million) of Americans are estimated to have actually listened to a podcast, which is up from 40 percent in 2017. Of those who have listened to a podcast, they listen while at home 49 percent of the time, 22 percent of the time while in their vehicle, 11 percent of the time at work, 4 percent of the time riding public transportation as well as working out, and 3 percent of the time while walking. People are overwhelmingly listening to their podcasts with devices they can easily use on-the-go. According to the survey, people listen on their smartphone, tablet, or other portable device 69 percent of the time, as


The first episode of IBWA’s podcast “H2O in the Know” has been produced and posted on SoundCloud. In this inaugural episode, IBWA Communications Coordinator Chris Torres talks with Bob Hirst about the most frequently asked questions about bottled water—covering everything from the types of bottled water available on the market, how bottled water is regulated, how bottled water regulation differs from tap water standards, and why plastic is used in bottled water packaging. Although this project was begun as a way to reach millennials—an audience that is currently underserved by IBWA’s other social media offerings—ultimately, the object is for members to also promote and share these podcasts to educate their current and potential customers about bottled water. Visit soundcloud. com/user-746400801/in-theknow-on-h2o to listen to the first episode of “H2O In the Know.”

opposed to listening on a computer, which occurs 29 percent of the time. The 69 percent figure is up 4 percent from last year. In the end, IBWA wants people to always be one click away from having the facts about bottled water. Whether it’s by reading the IBWA website, seeing a social media post, or listening to a podcast, we want the correct information at consumers fingertips in any medium they wish to choose. MAY/JUNE 2018



Changes Are Coming to the IBWA Audit Program By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations

The past several years have foretold of changes to come to the field of food safety. The massive new Federal Food Safety Modernization Act (FSMA) was signed into law in 2011, followed by years of rulemaking by the U.S. Food and Drug Administration (FDA). Accompanying that has been a long procession of IBWA seminars, webinars, and workshops to help prepare members for the changes heading our way concerning the production of safe food products. In many ways, bottled water has been a leader in preparing 28



for these new rules. In 2002, IBWA adopted the Hazard Analysis Critical Control Point (HACCP) management system as a means of preventing food safety hazards from occurring, although many in the food industry did not react until the FSMA rules were published. IBWA started FSMA training even before the final rules were published.

Questions of Time and Scope It is now 2018, and the first two groups of bottled water facilities (large and

small companies as defined by FSMA) are already required to comply with the Preventive Controls Rule (PC Rule). However, the IBWA Tier 1 annual audit program presently continues as it has since its last update 16 years ago. Many discussions have ensued over the past two years, beginning with the suitability of a new draft audit checklist, developed by IBWA staff with information extracted from the PC Rule. That checklist increased in size from the current eight pages of primarily Good Manufacturing Practice- (GMP)

TECHNICAL UPDATE based items to the proposed 16-page version that encompasses everything in the PC Rule from revised Current Good Manufacturing Practices (CGMPs) to food safety plans to supplier programs to IBWA membership requirements. The process has not been without its trials. While drafting a new request for proposal (RFP) for a new audit contract in 2017, where the revisions to the audit program first became clearer on paper, many began to ask questions: How much time will the new audits require at the plant? How much will it cost? The answer to both questions: More than IBWA members are accustomed to for a Tier 1 audit. It all was going to require more discussion and fact-finding, so the existing Tier 1 audit contract was extended for one year to December 31, 2018. IBWA staff proposed five approaches for implementing FSMA into the audit program and presented them to the Audit Program Evaluation Team (APET) and Technical Committee. Two options emerged from those discussions: 1. An extended audit day. Members of the group stated that audits are currently completed by early afternoon, potentially allowing for an extended audit day to accomplish a full FSMAbased audit. 2. Advance records review. The group recommended investigating the idea of providing auditors with records in advance of the audit to save time on the day of the audit. This option may save time to allow for a full FSMAbased audit in one day. This option would also require consideration for the impact on IBWA’s current “2-day notice policy” and consistency in the types of records shared in advance will need to be resolved. Staff then met with the three current audit contractors, all of whom recommended Option 2, with variations in protocols. The differences are primarily

in the types of records reviewed prior to the on-site audit. Also, the option would necessitate a change in IBWA policy regarding 2-day advance notice of an on-site audit because advance records review would also involve advance scheduling of the on-site audit. As we go to press, APET and the Technical Committee are in discussions about how to proceed with changes to the audit program to accommodate the new PC Rule requirements. But before any decisions are made, another discussion is occurring, one that revisits the mission and scope of the audit program with the following questions: • Are the mission and scope the same as they were 16 years ago? • Are they the same as in 1984, when the audit program was founded? • Do today’s bottlers want a cursory review of their operations, like the current program? • Or do they want a comprehensive audit with a mission to help bottlers prepare for and successfully complete an FDA or state agency audit for compliance with the PC Rule? Those and many other questions are in the process of being answered to facilitate development of a new RFP scope of work for any new audit program that may emerge from the meetings and discussions. This, admittedly, is not an easy transition for many bottlers, but then again neither are the regulatory audits that are forthcoming an easy adjustment. While a substantial upgrade of the existing Tier 1 audit program may cost more, so will the costs of noncompliance with the PC Rule, especially if FDA must return for a return inspection, this time “for cause.” As IBWA has pointed out in seminars throughout recent years, an FDA return could cost $20,000 or more, not including any fines or penalties that may arise. Make no mistake about the process: IBWA is sensitive to the time


and financial concerns of its members. Every step of the audit revision process considers those concerns. The time to debate and decide is now. IBWA urges all bottlers to get involved to help the audit program be what everyone wants it to be—and what it has been since 1984: a major reason for being a member of 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 Claire Crane ( / Fax: 703.683.4074), 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_ _________________________________________________



State/Province_ _____________________________________________

ZIP/Postal Code_ ___________________________________________

Check your selection for each question


“Sodium Free” claims on bottled water labels may be impacted by FDA’s revised rule due to a required change in _____.


serving size amount consumed in one sitting amount of sodium in the water treatment process employed


In the threat assessment process known as “CARVER + Shock,” the “R”s stand for _____. (pick all that apply)


reformation recognizability reconnaissance recuperability


Changes to the IBWA audit program are being considered for _____ audits to accommodate the FSMA preventive controls rule.


BRC Tier 1 SQF Tier 2


To detect an intentional adulteration of bottled water with microbiological pathogens, testing for _____ may detect any threats.


Pseudomonas sp. HPC Yeast/Mold Total coliform/E. coli


Which of the following treatment processes is effective in removing intentionally added chemical contaminants?



Mechanical filtration Reverse osmosis Ozone Ultraviolet light



When an FDA finds major deficiencies during a routine inspection, they can return for more investigation at the bottler’s expense.

OO True OO False


The USEPA has established action levels for two of the following contaminants, but FDA has adopted health-based standards.


copper antimony iron lead


A vulnerability determination during a CARVER assessment means _____.


Ease of identifying a target, Ease of accomplishing the attack. Physical access to the target. Amount of direct loss from an attack.


A _____ recall involves a situation in which the product may cause temporary or medically reversible illness, and where the probability of serious health consequences is remote.


Class III Class I Class II Class IV


To earn an IBWA Excellence in Manufacturing award, the plant must achieve the following:


0 major and 0 minor nonconformances 1 major and < 4 minor nonconformances 1 major and < 10 minor nonconformances 0 major and < 3 minor nonconformances

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MAY 2-5

Convention and NWBWA Trade Show Red Lion Hotel and Event Center Pasco, WA JUNE 4-7 IBWA June Board of Directors and Committee Meetings

Hilton Old Town Alexandria, VA


NEBWA Fall Convention Holiday Inn—East Mountain Wilkes-Barre, PA


IBWA Annual Business Conference and Trade Show Hyatt Regency New Orleans, Louisiana


JUNE 3-6

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

Contact Stephanie: 817.719.6197 / membership MAY/JUNE 2018



Using #FASTFACTS to Spread the Truth About Bottled Water on Social Media

IBWAâ&#x20AC;&#x2122;s newly created #FastFacts social media campaign includes digital posters with evergreen facts members can use to complement their current efforts on social media to educate consumers and others about bottled water. Such easy access will come in handy if members are trying to update their social media profiles regularly but are having a hard time thinking of new ideas for posts. Members can quickly go to the IBWA website and download a post and use it that day. Visit for more.






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Bottled Water Reporter  

Home and Office Delivery Issue May/June 2018

Bottled Water Reporter  

Home and Office Delivery Issue May/June 2018