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

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ALSO IN THIS ISSUE Promoting A Implementing Healthy Hydration Green Policies Message That Work

Supporting Drink Up

BOTTLED WATER REPORTER | NOV/DEC 2014

Why Science Matters–and How Journalists Often Get It Wrong A BPA Case Study Follow the Bottle From Preform to Product Innovation

THE ART OF THE LABEL HOW TO GET IT RIGHT

Bottled Water Facts Worth Sharing Healthy Hydration for the Holidays

A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION


VOL. 54 • NO. 6

COLUMNS GOVERNMENT RELATIONS

22 | Here’s to Your Health Celebrating IBWA’s work with Drink Up COMMUNICATIONS

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26 | How 2014 Efforts Can Inspire 2015 Success Working together, we can spread bottled water’s healthy hydration message TECHNICAL UPDATE

28 | Sustainability in Business Makes “Cents” Implementing green policies can benefit your business VALUE OF IBWA MEMBERSHIP

32 | IBWA: The One-Stop-Shop for Industry Learning Eric Amann (3M-Food Safety Division) tells Bottled Water Reporter how IBWA has helped staff at his organization quickly learn about the bottled water industry and stay up to date on important industry issues.

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

TABLE OF CONTENTS CONTENTS

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

10 | The Art of the Label: How to Get It Right

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

Bottlers spend numerous hours and thousands of dollars to craft a label that’s enticing to consumers—but does your label meet the U.S. Food and Drug Administration label requirements? This article presents all the need-to-know information to help ensure your product labels stand up to a regulatory examination. By Bob Hirst

16 | Umberto Eco, BPA, and the Need for Real, Cause-Effect Science Umberto Eco, the popular Italian essayist, once asked in “Science, Technology and Magic,” what is magic but “the assumption that it is possible to go from cause to effect without taking intermediate steps?” Unfortunately, journalists have taken to describing scientific studies as if they are performed by magic: conclusions are reached—and published—without detailing the slow, difficult slog that is science. This article uses recent bisphenol A (BPA) research and corresponding news stories to explain why that’s a problem. By Trevor Butterworth

CEU QUIZ .........................................................30 ADVERTISERS.COM...........................................31 CLASSIFIEDS ....................................................31

CONNECT WITH IBWA

BOTTLED WATER REPORTER, Volume 54, Number 6. 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, www.bottledwaterreporter.org. 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.


IBWA

International Bottled Water Association OFFICERS

CHAIRMAN’S COMMENTARY A FINAL CALL TO ACTION

Chairman Breck Speed, Mountain Valley Spring Company, LLC Vice Chairman Vacant Treasurer Bryan Shinn, Shinn Spring Water Company Immediate Past Chairman William Patrick Young, Absopure Water Co., Inc.

BOARD OF DIRECTORS

It has been an interesting year to serve as the chairman of IBWA, and I’ve learned a great deal from the experience. If you are a member of this great organization, I highly recommend that you volunteer to work with the IBWA staff. I guarantee you receive far more than you give in time and expense. Our Association has an enormous collection of talent and experience—and all you have to do to access those resources is show up and participate. I’ve personally used the connections I’ve forged within IBWA to help my company solve problems and create new revenue opportunities. (If you can learn from the hard-won experience of others, there’s no reason to make all the mistakes yourself!) We are riding a fairly solid wave of consumer demand for healthy beverages right now, and it appears the trend will sustain itself for the foreseeable future. But with great success comes predictable challenges. If one reaches the pinnacle in any field or industry, it is the great American, free market way for such success to create competition. Beverage companies—large and small—will crowd this good-for-you market space, and try to steal the thunder and market share of bottled water. Gird you loins! In addition, success makes any market leader a target for groups with agendas other than selling liquid refreshment. Environmental groups, recycling advocates, water use skeptics, and taxing authorities have already beset the bottled water industry, and such scrutiny will not abate as bottled water becomes the No. 1 beverage category in the next 12-18 months. We would be well advised to listen to those groups. Because after digesting carefully their criticisms, our industry, represented by IBWA, can thoughtfully adapt as necessary and push back vigorously where required. Thanks for the opportunity to serve as your chairman. I look forward to continuing to work with IBWA for years to come!

Breck Speed IBWA Chairman

Get Involved

Scan this QR code to connect with IBWA through Facebook and help us share bottled water’s healthy hydration message. 2

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Shayron Barnes-Selby, DS Services Joe Bell, Aqua Filter Fresh Philippe Caradec, Danone Waters of America Andy Eaton, Eurofins Eaton Analytical Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Dave Holdener, Nicolet Forest Bottling Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Greg Nemec, Premium Waters, Inc. Heidi Paul, Nestlé Waters North America Chris Saxman, Shenandoah Valley Water Co. Bryan Shinn, Shinn Spring Water Company Robert Smith, Grand Springs Distribution Breck Speed, Mountain Valley Spring Company, LLC Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chairman, Breck Speed, Mountain Valley Spring Company, LLC Joe Bell, Aqua Filter Fresh Philippe Caradec, Danone Waters of America Tom Harrington, DS Services Henry R. Hidell, III, Hidell International Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Heidi Paul, Nestlé Waters North America Chris Saxman, Shenandoah Valley Water Co. Bryan Shinn, Shinn Spring Water Company William Patrick Young, Absopure Water Co., Inc.

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


IBWA

International Bottled Water Association

PRESIDENT’S MESSAGE PACKAGED WITH CARE

In this issue of Bottled Water Reporter, we tackle some important packaging issues.

IBWA STAFF President Joseph K. Doss jdoss@bottledwater.org Vice President of Education, Science, and Technical Relations Robert R. Hirst bhirst@bottledwater.org

Our second feature article,“Umberto Eco, BPA, and the Need for Real, Cause-Effect Science” (p.16), is by Trevor Butterworth, director of Sense About Science USA. Like Eco, Butterworth is disappointed by the public’s seeming acceptance that it is possible to jump from cause to effect without detailing—or even acknowledging—the steps in between. When discussing an issue as important as bisphenol A (BPA) and any suggested health effects, journalists—and consumers—really do need to understand that science is a process of many steps (and a process that must be replicated).

Chief Financial Officer Michelle S. Tiller mtiller@bottledwater.org

I hope you enjoy the articles in this issue of Bottled Water Reporter. As always, feel free to contact IBWA Publications Manager Sabrina Hicks (shicks@bottledwater.org) if you have any topics you’d like us to cover in 2015.

Joe Doss IBWA President

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International Bottled Water Association 1700 Diagonal Road, Suite 650 Alexandria, VA 22314-2973. Tel: 703.683.5213 Fax: 703.683.4074 www.bottledwater.org

Our cover story, “The Art of the Label: How to Get It Right” (p.10), written by Bob Hirst, IBWA’s vice president of education, science, and technical relations, is a handy resource bottlers can refer to when making important decisions about their labels. Sure, you want your label to appeal to current and prospective customers, but it must also meet certain U.S. Food and Drug Administration (FDA) requirements. This article delves into those particulars, as well as reports on FDA’s regulatory review of nutrition labeling.

In an effort to ensure consumers hear more positive messaging about bottled water— and the many benefits of staying well hydrated—IBWA supported in 2014 (and will continue to support in 2015) Drink Up, the pro-water initiative resulting from a collaboration between the Partnership for a Healthier America (PHA) and its honorary chair, First Lady Michelle Obama. Our Government Relations column (p.22) reviews the influence that initiative has had on the drinking habits of Americans. While Drink Up was successful, it wasn’t the only cause IBWA stood behind in 2014, and the Communications column (p.26) highlights some of the other efforts (e.g., Bottled Water Quality Information Act) we’ve promoted to tell the good story of bottled water. There’s more good news in the Technical Update column (p.28), where we illustrate how IBWA continues to invest in learning about new environmental sustainability strategies we can share with members.

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BOTTLED WATER REPORTER is published for:

WWW.BOTTLEDWATER.ORG

Vice President of Communications Chris Hogan chogan@bottledwater.org Vice President of Government Relations Kristin Pearson Wilcox kwilcox@bottledwater.org

Director of Conventions, Trade Shows, and Meetings Michele Campbell mcampbell@bottledwater.org Director of Science and Research Tamika Sims, PhD tsims@bottledwater.org Director of Government Relations J.P. Toner jtoner@bottledwater.org Manager of Publications and Special Projects Sabrina E. Hicks shicks@bottledwater.org Manager of Member Services Dennis Carpenter dcarpenter@bottledwater.org Education and Technical Programs Coordinator Claire Crane ccrane@bottledwater.org Executive Assistant Patrice Ward ibwainfo@bottledwater.org 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

IBWA members and staff pose in front of bales of plastic bottles ready to be recycled at Global PET.

ENVIRONMENTAL STEWARDSHIP

IBWA Members “Follow the Bottle” Annual Environmental Sustainability Education Tour illustrates how a bottle of water is packaged, recycled, and manufactured into something new On September 24, 2014, IBWA held its third Environmental Sustainability Education Tour. This year, 17 IBWA members and staff traveled to Ontario, California, for the “Follow the Bottle” tour, which taught participants about the steps involved in not only creating and recycling a PET bottle but also transforming it into other products. Starting at IBWA member Nestlé Waters North America’s (NWNA) Ontario plant (www.nestle-watersna.com), participants learned about how water from Arrowhead Springs is pumped or tanked into the facility for bottling. At NWNA, the company’s corporate responsibility focus includes water recycling, recycling materials, rPET use, 6

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water donations, emergency response, and being a longterm community employer. NWNA is on a “path to zero waste,” which means all aspects of its product manufacturing, including the community in which it produces and sells bottled water, have to be supported and addressed in order to attain that goal. CarbonLITE (www. carbonliterecycling.com), a bottle-to-bottle PET recycling facility, was the next stop on the tour. This company washes and grinds PET bottles to produce clean rPET flake and rPET pellets. Those pellets are then used to produce preforms, which in turn make rPET bottles. CarbonLITE’s 220,000-square-foot PET recycling plant processes more

than 2 billion plastic bottles annually. Each year, CarbonLITE recycles 20 percent of the plastic containers collected from the state’s curbside recycling programs. The company also promotes recycling in the state by offering tours of the Ontario facility to school-aged children for, as they say, a “positive attitude about recycling starts with children.” The tour included a visit to two Global PET recycling facilities (www.globalpetinc. com). This company recycles PET bottles to form PET sheets that can be made into food containers (e.g., plastic clamshells). Recently, the company started using its rPET to manufacture protective plastic shells for new consumer electronics (e.g., video

game controller packaging). Global PET is proud that its innovative use of cutting-edge technology has a notable place in the recycle stream. The tour’s last stop was at Republic Services (www. republicservices.com), a nation-wide, curbside solid waste and recycling collection organization. The company lists its business priorities as safety and compliance, targeted profitable growth, customer experience, durability, and its team of employees. One of the company’s goals, as displayed at the California office, is to “deliver total waste stream solutions and provide environmental confidence for Republic’s customers, while doing [its] part in stewardship of the planet’s resources.”


WATER NOTES

During a lunch break, participants heard from Vahe Manoukian, a Moore Recycling representative, who has worked in the recycling industry for more than 20 years, and IBWA Vice President of Education, Science, and Technical Relations Bob Hirst. Manoukian discussed trends in PET recycling and postconsumer bottle collection; Hirst provided an update on the U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) supplemental proposed rule on preventive controls. This successful event would not have been possible without the California facilities that hosted tour attendees. IBWA would like to thank IBWA members Polycycle Solutions for sponsoring tour transportation and Niagara Bottling for

Kelley Goshay (DS Services) and Tamika Sims, PhD, (IBWA) inspect PET flake.

sponsoring a dinner reception at the end of the tour, and Environmental Sustainability Committee member Phyllis Rokus for helping organize such a successful and educational event. If you’d like to host an IBWA Environmental Sustainability Tour in 2015, please contact IBWA Director of Science and Research Tamika Sims, PhD: tsims@ bottledwater.org.

IBWA tour participants learn about the recycling sorting process.

Bales of plastic bottles are ready to be recycled.

millions of gallons

Bottled Water Helps People choose fewer soft drinks...

Source: BMC For more, visit bit.ly/BWinfographic1.

Bottled Water

Soft Drinks

Sales volumes 2000-2013 NOV/DEC 2014

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WATER NOTES

DWRF PROGRAM

Kristin Safran College Scholarship Awarded to Lauren Diss Georgia Southern University freshman Lauren Diss is the 2014 recipient of the Kristin Safran College Scholarship. Lauren, whose step-father Troy works for DS Services as director of transportation, began her studies at Georgia Southern this fall and plans Lauren Diss to obtain a Bachelor of Science in biology. Her future plans include earning a doctorate in teaching, so she can teach at a high school or college level. Lauren graduated from River Ridge High School in Woodstock, Georgia. Ranked in the top 5 percent of her class, Lauren has a transcript that is filled with Honors and Advanced Placement level coursework. She earned a spot on the Honor Roll all four years of high school and was a

DID YOU KNOW?

Bottled water is comprehensively regulated by the U.S. Food and Drug Administration as a packaged food product, and it provides a consistently safe and reliable source of drinking water.

recipient of the U.S. Presidential Academic Excellence Award from 2012-2014. Lauren was also a member of the National Honor Society and Beta Club. Along with her heavy course load and extracurricular activities, Lauren volunteered in her community with the Homeless Ministry, Vacation Bible School, and Ministry Summer Lunch Program. During the judging process, the Kristin Safran Selection Nomination Committee, made up of Drinking Water Research Foundation (DWRF) Trustees Jack West and Stew Allen, and Kristin’s widower, Russ Safran, blindly reviewed applications from children or grandchildren of IBWA members (i.e., judges did not know the names of the children or parents, or the company the parents work for when reviewing applications). DWRF created the Kristin Safran College Scholarship Fund in February 2010 in honor of former IBWA Board of Directors member Kristin Safran (ARK Specialty Services), who passed away in 2009. The scholarship was established to help high school seniors pursue their college studies.

Bottled Water is

a very small water user

Bottled water uses less than 0.004% of all water in the U.S.

LIVESTOCK < 1% DOMESTIC USE 1% MINING 1% AQUACULTURE 2% INDUSTRY 4%

PUBLIC SUPPLY 11%

IRRIGATION 31%

THERMOELECTRIC POWER 49%

For more, visit bottledwater.org.

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Source: USGS For more, visit bit.ly/BWinfographic1. WWW.BOTTLEDWATER.ORG


WATER NOTES MEMBER ACTION

SOCIAL MEDIA TIPS

Healthy Hydration for the Holidays

It’s the most wonderful time of the year—and it’s also a big season for feasting on highcalorie holiday dishes and celebratory cocktails. But the holidays don’t have to be a time for unrestricted debauchery! Remind merry-makers that bottled water is here to help them balance their diets during the Yuletide season. Below are a few example messages you can tweet out from your business’ Twitter account—or just use them for inspiration and write your own. • Flying to join family this holiday? Don’t forget to carry or ask for bottled H2O on your flight! bit.ly/BottledWaterYesPlease • Stay cheerful during the holidays by opting to consume water between alcoholic drinks. bit.ly/GoOneForOne • Santa says be good this holiday season! Drink bottled water and be the designated driver! • Party without pain, here’s how. First tip: Keep bottled water handy. bit.ly/PartyWithoutPain • “Shape” mag says sipping water is the #1 thing to do to minimize holiday weight gain. bit.ly/NoBowlFullofJellyTummyHere • DYK when it’s cold outside, you’re more likely to be dehydrated b/c yr body isn’t releasing sweat like it does in hot weather? bit.ly/DehydrationAndColdWeather • 6 reasons to resolve to drink more bottled water in the New Year: bit.ly/MoreH2Oin2015

DID YOU KNOW?

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300 billion calories and 6.4 billion gallons of water are saved each year by switching from soft drinks to bottled water. Source: bit.ly/BWinfographic1

pacificozone.com

NOV/DEC 2014

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COVER STORY

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THE ART OF THE LABEL

HOW TO GET IT RIGHT

All you need to know to ensure your bottled water labels adhere to FDA regulations By Bob Hirst

As a bottler, you already know that a label says a lot about your product. You spend many hours and thousands of dollars to craft a label that will entice consumers to purchase your bottled water. Some labels reflect the tradition behind the product, with timeless designs that still grab customers’ attention. Other labels employ eye-catching, imaginative artwork. In between, you’ll find labels that are all business—providing the need-to-know information in a clean, easy-to-read format. Sure, consumers are often drawn to the best-designed labels, but they are also looking for the details about your product: brand name, company name, company location, water type, etc.

It’s good to remember that perfecting your product label requires more than just good design. A number of regulatory requirements exist that explain what information you must include on your bottled water label. Moreover, some states add to the challenge of designing the perfect label with additional information requirements of their own (e.g., plant permit numbers and deposit information). Bottlers eventually find the balance between an attractive label and one that provides consumers the information required by law. In this article, we’ll focus on the U.S. Food and Drug Administration’s (FDA) label requirements for bottled water products.

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Label Contents

“Mineral Water”

The label on a bottle of water consists of two basic components: the principal display panel (PDP) and the information panel.

“Purified Water”

“Sparkling Bottled Water”

“Spring Water”

“Well Water.”

Principal Display Panel. According to FDA, the PDP is “the part of the label that is most likely to be displayed, presented, shown, or examined under customary conditions of display for retail sale.” In other words, it is the part of the label the consumer will first see when the product is displayed on the store shelf. The PDP must be large enough to include all mandatory label information “with clarity and conspicuousness and without obscuring design, vignettes, or crowding,” according to FDA regulations. Information required to be displayed on the PDP includes identity labeling, a principal feature of the panel. For bottled water, the identity labeling is consistent with the FDA Standard of Identity in 21 CFR § 165.110(a): •

“Bottled Water” or “Drinking Water”

“Artesian Water” or “Artesian Well Water”

“Ground Water”

If fluoride or minerals are added, the identity statement should include the following: •

“Spring Water with Fluoride Added”

“Purified Water with Minerals Added.”

Of course, some variations of the above are permitted. The graphic below (“Bottled Water Identity Types”) illustrates an order for the various bottled water identity statements. The identity statement must be parallel to the base of the container, even if the brand name or other information is aligned vertically or in any other orientation. The type size must be relative to the most prominent features on the PDP.

BOTTLED WATER IDENTITY TYPES

This graphic shows various types of bottled water identity statements. Bottled Water Drinking Water

Natural Waters Spring Water

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Purified Water

Artesian Well Water

Reverse Osmosis

Ground Water

Distilled Water

Mineral Water

Deionized Water

Sparkling Water

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Processed Waters

WWW.BOTTLEDWATER.ORG

Remineralized Water


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Information Panel. FDA permits additional required information to be displayed on either side of the PDP, known as the information panel. FDA identifies the information panel as “that part of the label immediately contiguous and to the right of the principal display panel as observed by an individual facing the principal display panel….” Although permitted to be displayed on either the PDP or information panel, most of the following information required by FDA to be on the label is typically found on the information panel: •

Ingredients. For bottled water, an ingredients list is not required if nothing has been added to the water. However, if sodium fluoride or mineral salts are added, they must be listed under “Ingredients.” Ingredients are listed in descending order of predominance.

Name and place of business of manufacturer, packer, or distributor. If a manufacturer, packer, or distributor has a phone book or Yellow Pages listing, it is only required to list the company name with corresponding city, state, and zip code. If the manufacturer, packer, or distributor does not have a phone book or Yellow Pages listing, a full company name and street address is required. Bottlers may also opt for listing any combination of the three companies, but typically either the manufacturer or distributor is listed on the information panel. If the product is not manufactured by the company named on label, the label statement must be preceded by either “Manufactured for _____” or “Distributed by _____.”

Nutrition Facts label. For bottled water, FDA does not permit nutrition claims beyond hydration and variations of “healthy” for bottled water. However, any claim of sodium content will trigger the requirement for a nutrition facts panel. It is important to note that bottlers are not required to include a Nutrition Facts panel unless a claim of sodium content is included on the PDP or information panel. (Additional information on nutrition labeling is discussed below.)

FDA states that it considers bottled water to have no significant nutritional value. Thus, bottled water can make no nutrition claims other than touting the benefits of hydration. “Contains excessive lead” would be required on the label. Considering that consumers would probably not purchase such an adulterated product, one would not expect to see such a statement on a label of bottled water. All items listed above must appear on the label “prominently and conspicuously.” In no case may letters and numbers be less than 1/16 inch in height unless an exemption is granted by FDA. FDA has approved label exemptions specific to the bottled water industry. The name and place of business, nutrition information (which is not required if no nutritional claims are made on the label), and statement of ingredients are not required to be included on the cap label of 4- or 5-gallon containers if the information is located on the body of the container.

Nutrition Facts Labels

Nutrient content claims. As mentioned above, any claim of sodium content in bottled water may be included on either the PDP or information panel. Claims of sodium content are optional, not mandatory.

Sparing readers from a review of the complexities of the Nutrition Labeling and Education Act (NLEA), which has been a part of food labeling since the early 1990s, below we’ll focus on what triggers some NLEA requirements for bottled water. (To review the NLEA, visit bit.ly/ NLEArequirements.)

Food label warning and notice statements. As you may be aware, when a food product contains a contaminant that exceeds a regulatory limit or the product is otherwise adulterated, FDA requires warning and notice statements on the label. For example, if a bottled water product contains lead in excess of the FDA standard of quality of 5 ug/L, a statement such as

In the NLEA final rule’s preamble, FDA states that it considers bottled water to have no significant nutritional value. Therefore, bottled water can make no nutrition claims other than touting the benefits of hydration. However, because the sodium content of any food is important to people who are on restricted diets, any claims about sodium are addressed by NLEA. Regarding bottled water, NOV/DEC 2014

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Letters and numbers on any part of the label cannot be smaller than 1/16 inch.

Information Panel

Name and place of business of manufacturer, packer, or distributor

Identity labeling must be parallel to the base of the container

for example, if “no sodium” or “sodium free” is claimed on the label, a Nutrition Facts panel is required. Acceptable NLEA terms include the following:

Information Panel

Nutrition panel is not required of bottled water unless a claim of sodium is on PDP or information panel. Claims of sodium content are optional.

“Sodium Free” if the water contains less than 5 mg per serving.

“Very Low Sodium” if the water contains between 5 and 35 mg per serving.

current NLEA does not always adequately address those new beverages, but, in some cases, if vitamins or minerals are added that result in 50 percent or more of the reference daily intake (RDI), the beverage may be considered a food for special dietary use. The addition of anything to bottled water other than fluoride or any suitable antimicrobial agent (e.g., ozone, chlorine, or chlorine dioxide) renders the product a water-based or other type of beverage, not a “bottled water” by FDA standards.

“Low Sodium” if the water contains between 36 and 140 mg per serving.

Changes = Improvements?

Any claim regarding sodium in bottled water also triggers a requirement for a Nutrition Facts panel. For a bottled water label, the Nutrition Facts panel typically includes the following: •

Calories

Total Fat

Sodium

Total Carbohydrates

Protein.

All of the above are listed as amounts per 8 ounce serving, which is about one-half the volume of a 0.5 liter (i.e., 16.9 ounce) bottle. During the past several years, the market has experienced a proliferation of new beverages with nutrients added. The 14

Principal Display Panel (PDP)

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Currently, FDA’s regulations on nutrition labels are under revision. IBWA has reviewed and submitted comments to FDA on the proposed revisions, as there are points of concern for the bottled water industry in a few of the sections of the revised rule. Here’s an example. Some bottled waters contain added fluoride, and proposed updated serving size requirements and new labeling requirements for certain size packages would affect how fluoride content is declared on a bottled water label. Although fluoride labeling is not required, any company that adds fluoride is doing so for the health benefit (reduced dental caries) and would usually elect to include fluoride information on its label. FDA proposes to change the serving size requirements to reflect how people eat and drink today, which has changed since serving sizes were first established more than 20


LABELS

years ago. By law, the label information on serving sizes must be based on what people actually eat or drink, not on what they “should” be eating or drinking. The revised rule would require that packaged foods, including drinks, that are typically consumed in one sitting be labeled as a single serving and that calorie and nutrient information be declared for the entire package. For example, a 20 ounce bottle of soda or 16.9 ounce bottle of water, which are typically consumed in a single sitting, would be labeled as one serving rather than as more than one serving. For certain packages that are larger and could be consumed in one sitting or multiple sittings, manufacturers would have to provide “dual-column labels” to indicate both “per serving” and “per package” calories and nutrient information. The dilemma. The changes in serving sizes as proposed will have a negative impact on fluoridated bottled waters. If “mg per serving” is used as the unit, some servings (like 4 ounce servings of nursery bottled water) would be declared as containing 0 mg fluoride, even when they contain a meaningful amount of fluoride from a public health perspective on an “mg/L basis.” That’s because of FDA’s suggested provision: “when fluoride content is declared, it must be expressed as zero when a serving contains less than 0.1 mg of fluoride, to the nearest 0.1 mg increment when a serving contains less than or equal to 0.8 mg of fluoride, and the nearest 0.2 mg when a serving contains more than 0.8 mg of fluoride....” The Centers for Disease Control and Prevention (CDC) and the American Dental Association (ADA) call for an optimum level of 0.7 mg/L of fluoride in fluoridated bottled water. When the serving size on the label is 0.5 liter (approximately 16 ounces), the amount of fluoride would be 0.35 mg, so the amount stated on the label would be 0.4 mg of fluoride, rounded to the nearest 0.1 mg. However, when the serving size is 4 ounces, the amount of fluoride would be less than 0.1 mg, so the rule would require that, if nutrition labeling is used, the stated fluoride content would be 0 mg. If companies, using the “mg per serving” requirement, had to declare fluoride as “0,” this would discourage bottlers from producing products that include the addition of fluoride. As we all know, FDA recognizes that fluoride reduces the risk of dental caries; thus, a market that doesn’t include fluoridated water limits consumer choice. IBWA’s recommendations. To resolve that issue, IBWA has recommended to FDA that the amount of fluoride should be declared, as is the current practice, as mg/L rather than mg per serving. Consumers are used to seeing fluoride values in mg/L and the CDC and ADA recommendations on fluoride are always issued in mg/L.

Also, the mandatory FDA Standard of Identity statements for bottled water with added fluoride (e.g., “with fluoride added”) should not be treated as “claims” about fluoride that trigger the mandatory fluoride labeling requirements under the proposed revised NLEA. Here’s another example, this time about sodium: The revised serving size requirements would also impact sodium labeling for bottled water. When the serving size is increased, many waters that currently qualify as sodium free will no longer qualify. For example, if a container has 4 mg sodium per 8 ounces, it will have 6 mg per 12 ounces— and will no longer qualify as sodium free. For those reasons, IBWA is opposed to dual-column labeling as it is proposed to apply to water. There remains a question about whether data supports that consumers drink 24-48 fluid ounces of water in one eating occasion. In many cases, there is no room on a bottled water label for dual-column labeling, as bottled water companies have been systematically reducing packaging due to environmental concerns. In addition, there are questionable benefits of dual-column labels for a product like water, as most values would be “0.” Ironically, the negative impacts on bottled water labeling discussed above are the reasons why we promote bottled water as a healthy alternative to sweetened soft drinks. The new FDA NLEA seeks to provide the public with truthful information about the sugar and calories being consumed in larger servings of those soft drinks. So, what’s the solution? In comments IBWA submitted to FDA on August 1, 2014, we requested an exemption from most parts of the revised FDA nutrition labeling regulation to avoid useless provisions that don’t improve bottled water’s communication of nutrient information to consumers. (We are still awaiting a response, as it can take anywhere from six months up to a year before a final rule including a preamble with responses to our comments is available.) IBWA also requested that bottled water be allowed to provide useful information about fluoride and sodium content in line with current means of communicating that information, which for consumers, is easier to understand. And isn’t truthful information in an easy-to-understand format the real objective for bottled water anyway?

Bob Hirst is IBWA’s vice president of education, science, and technical relations. Contact him at bhirst@bottledwater.org. NOV/DEC 2014

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UMBERTO ECO, BPA, AND THE NEED FOR REAL,

CAUSE-EFFECT SCIENCE

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CAUSE-EFFECT

Why science matters—and how journalists often get it wrong: A BPA Case Study By Trevor Butterworth

A story at the tail end of last summer captured, perhaps, almost everything wrong with the state of reporting on chemical risks. Predictably, it concerned what must be now the most famous chemical in the world, bisphenol A (BPA); predictably, it had an alarming headline—“In Plastics and Cans, a Threat to Women”; and, predictably, it elicited comments from readers that made one question whether something has gone terribly wrong in the teaching of science and whether the media was helping to usher in a new dark age of unlearning. The article (more on that shortly) left me thinking of a luminous, persuasive essay by the brilliant Italian thinker and author, Umberto Eco: “Science, Technology and Magic.” In his essay, Eco diagnosed why darkness persists in our supposedly clarifying scientific age. Although we defer, in theory, to the dominion of science and reason, in practice, we tend to think of science as technology and to understand technology as a disguised form of magic. What is magic, Eco asks, but “the assumption that it is possible to go from cause to effect without taking intermediate steps?” We may deride the alchemical fantasies of turning iron into gold with nothing more than an incantation, or the idea that a pinpricked voodoo doll could inflict real pain; but do we really know why our own pains disappear after taking a pill, or what actually happens when we turn on our computer and see a dazzling screen? We see causes and effects; we do not see the processes where one leads to the other or review the slog of history to find this out. And that is what science really is: a long, slow, difficult slog of hypotheses, elaborately controlled experiments, wrong turns, flashes of insight, falsifications, and replications. Science is a process. To understand why a claim is scientific— which is to say, why it should have a special kind of authority over us—one must see the process, and examine it critically.

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WHAT IS BPA? Bisphenol A (BPA) is an extraordinarily well-studied, building-block chemical used primarily to manufacture durable epoxy resins and strong, clear polycarbonate plastic. For nearly 50 years, polycarbonate plastic has been used for food and beverage product containers because it is lightweight, highly shatter-resistant, and transparent. It is widely used in various food containers and many other everyday items, such as eyeglasses and compact discs. Many bottled water companies use polycarbonate plastic for their 3- and 5-gallon water cooler bottles. However, it is not used in any retail-sized PET bottled water containers. In recent years, a great deal of attention has focused on BPA as it is used to make materials that come in contact with food, which are approved by the U.S. Food and Drug Administration (FDA). In June 2013, FDA updated its perspective on BPA, stating that “BPA is safe at the very low levels that occur in some foods” and “the use of BPA in food packaging and containers is safe.” It is important to note that scientific experts at FDA, and other regulatory bodies, review the full weight of the scientific evidence when making decisions about safety.

If readers had clicked on the link provided in the New York Times BPA story and reviewed the actual study, they would have discovered that the writer’s shortcut leapt over a critical step.

Sources: www.bottledwater.org/health/container-safety/what-is-bpa and factsaboutbpa.org/bpa-safety/bpa-basics

Journalism Shortcuts We may, of course, profitably use our computers and take pills for our headaches without needing to understand the chain of cause and effect, but what of claims that challenge our understanding of reality? What about those claims that—as illustrated in the opening news story—suggest there is something monstrous lurking in a plastic bottle or can that threatens women’s fertility. Surely, a frightening thought. Should we defer to the authority of journalism as an intermediary—a practice that can legitimately take the kind of shortcuts that a study written for scientists can’t? Consider a key explanatory section from the story, which focuses on the research of Jody Flaws, PhD, at the University of Illinois: ...for a month, Dr. Flaws dosed young female mice with a BPA solution at a level comparable to estimated human exposure in the United States. She then examined their ovaries, focusing on the follicles, which contain the eggs. 18

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The effect of the BPA was immediately obvious. Compared with normal mice, the follicles of the treated mice were fewer and smaller. Further analysis showed that estradiol, the sex hormone essential for normal reproductive development, was not being produced at normal levels. BPA, it seemed, interferes with enzymes essential in the production of such hormones. The writing is clear; the explanation seems compelling. We are led from cause to effect, and the effect is troubling. But if you were to have clicked on the link provided in the story and reviewed the actual study, you would have discovered that the writer’s shortcut had leapt over a critical step. Flaws did not actually dose the mice with levels of BPA comparable to human exposure, as per a feeding study; instead, she euthanized the mice, extracted their ovaries, extracted the relevant cells and exposed the cells to BPA in a petri dish. That was, in other words, an in vitro and not an in vivo study. The toxicological

and regulatory literature on in vitro studies is clear: you cannot establish a relationship between a cause (ingesting BPA by way of eating food from a can) and an effect (a threat to women’s fertility) by a method that exposes cells to chemicals in a way that bypasses the real-world ways the body metabolizes, absorbs, and excretes ingested chemicals. So, one might ask, are there any studies that have tried to establish an in vivo connection between BPA and the same ovarian effects, and thus demonstrate that the effects Flaws found are relevant? Yes, there is. Researchers at the National Center for Toxicological Research published a study (Delclos et al.) earlier this year that examined the same ovarian endpoints in a massive feeding study of rats. Did they find similar effects? Yes, they did; but only at an exposure of 300,000 ug/kg/body weight/day. But that rate of exposure is not remotely close to human exposure. If we look at actual real-world BPA intake according to the main U.S. dietary survey


Disguised Magic The erroneously titled “In Plastics and Cans, a Threat to Women” article did not mention the Delclos et al. study. Which is rather unwise as Delclos et al. is one of the largest and most sophisticated studies of its kind, one which regulatory agencies will base their risk assessment of BPA on. It seems absurd that readers weren’t told about it—although from an editorial perspective, it negates any reason for writing about Flaw’s research. Readers were presented instead with an example of science news as disguised magic: a cause and the illusion of a logical, scientific path to a dramatic conclusion. What was surprising and dispiriting was that this story appeared in the New York Times and was written by Deborah Blum, a Pulitzer Prize winning science reporter. Unfortunately, if we look at the coverage of BPA in the news, the overwhelming majority of stories follow a similar pattern. Basic science studies are reported breathlessly, as having immense significance, while the regulatory response— the massive studies that attempt to replicate the findings—are ignored, even as those studies pile up detailed, robust evidence that there is no risk to consumers. Even against a background where the National Institutes of Health have warned about an epidemic of unreplicable basic research, journalists repeatedly fail to ask themselves whether alarming findings have been replicated in such a way that we can have confidence in their validity.

CAUSE-EFFECT

(the National Health and Nutrition Examination Survey), the median adult BPA aggregate intake is ~0.04 ug/kg bw/d. That means ovarian effects similar to Flaws’ in vitro study occurred in the rats in vivo at 7,500,000 times the median exposure among people in the United States to BPA. The conclusion one would take from this study is that there is no evidence of a threat to women’s fertility.

You cannot establish a relationship between a cause (ingesting BPA by way of eating food from a can) and an effect (a threat to women’s fertility) by a method that exposes cells to chemicals in a way that bypasses the real-world ways the body metabolizes, absorbs, and excretes ingested chemicals. Undoubtedly, this is partly due to the degree to which some scientists have promoted their work on BPA in the most alarmist and sensationalistic way possible, but it is also due to chronic one-sided reporting. At last year’s meeting of the Society of Risk Analysis, Jason Aungst told an audience that, while he regularly speaks to reporters and tries to explain the latest U.S. Food and Drug Administration (FDA) research findings, his quotes rarely make it into the final article.

Check the Source Formal analysis of the news media coverage of BPA gives us some idea of the scale of this asymmetry. One review of a year’s worth of media coverage between 2011 and 2012, conducted by Dan Amundson at George Mason University’s Center for Media and Public Affairs, found that FDA sources only accounted for 8.4 percent of expert sources cited in a sample of print media (CNN, Chicago Sun Times, New York Times, Oregonian, Pittsburg Post Gazette, St. Paul Pioneer Press, San Francisco Chronicle, USA Today, and Washington Post). By contrast, among those sources critical of BPA—and the FDA—15.4 percent were scientists and 15.2 percent were from activist groups. There were hardly any scientists quoted who were independent yet neutral or supportive of BPA and the FDA’s regulatory position (1.2 percent).

In terms of how the story was framed, it was the FDA and industry (20.4 percent of expert sources) on one side, and the remaining 79.6 were independent scientists, other government agencies (e.g., the National Institute of Environmental Health Sciences and Centers for Disease Control), journalists, chefs, and mommy bloggers on the other. The “problem” with the FDA being on the same side as industry was driven home by a 2011 New York Times story on the threat of BPA from thermal paper cash receipts, which cited Sonya Lunder of the Environmental Working Group: “Ms. Lunder said that studies financed by BPA-producing industries often indicate that the chemical does not cause any adverse effects in animals, while those undertaken by private scientists show the opposite.” Once again, it didn’t seem to occur to the New York Times reporter to check this out. Thus, readers failed to discover that the most significant research on BPA—the research failing to find adverse effects, the research driving regulatory decisions—was funded and conducted by the FDA, the Environmental Protection Agency (EPA), and the European Food Safety Authority (EFSA), not industry. On the few occasions when reporters mentioned risk assessments such NOV/DEC 2014

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CONSUMER EXPOSURE TO BPA IS EXTREMELY LOW A consumer would have to ingest more than 1,300 pounds of food and beverage—that have been in contact with polycarbonate plastic—each day to reach the BPA “safe exposure level” established by government bodies in Europe and the United States. Consumer exposure to BPA from all sources is minute and well below safety standards set by government regulatory agencies around the world. Extensive data from biomonitoring studies conducted by the U.S. Centers for Disease Control and Prevention (CDC) show that typical human exposure to BPA from all sources is approximately 1,000 times below the safe intake level recently set by the European Food Safety Authority (EFSA). Source: plastics.americanchemistry.com/ Product-Groups-and-Stats/ PolycarbonateBPA-Global-Group/ About-BPA.pdf

as those conducted by the FDA and EFSA, they were embedded in quotes from industry sources: •

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“Bryan Iams, a spokesman for Bayer, the second-largest U.S. producer, said assessments by the FDA and the European Food Safety Authority show BPA is safe,” said a news story in the Pittsburg Post Gazette.

“Steven Hentges, a spokesman for the American Chemistry Council, says the study’s ‘conclusions are of unknown relevance to public health.’ He notes that regulators in Europe, Japan and the USA have ‘reviewed hundreds of studies on BPA and repeatedly supported the continued safe use of BPA,’” said a news story in USA Today.

Why shackle independent risk assessments to spokespeople from the chemical industry? The framing effect undermines both science as a process and regulation as something independent that follows more rigorous scientific procedures. Of course, it’s arguable that regulatory risk assessments wouldn’t be mentioned at all if industry sources didn’t remind reporters that they exist. An earlier study of five years’ worth of media coverage of BPA (between 2006 and 2011) by Amundson found that just 6.4 percent of stories mentioned the EFSA risk assessment and its repeated updates (35 out of 551 stories). The media sample was even bigger than the previous study.

of the sample indicated that headlines on science stories are misleading (82.4% agreed),” they wrote, “and that information crucial to the understanding of research results often is omitted from news stories (76.3% agreed).”

CAUSE-EFFECT

Ovarian effects similar to Dr. Flaws’ in vitro study occurred in the rats in vivo at 7,500,000 times the median exposure among people in the United States to BPA. The conclusion one would take from this study is that there is no evidence of a threat to women’s fertility.

This was an era when most newspapers had dedicated science reporters who had time and space to report a story. Now the pressure to churn out short, simple stories with dramatic headlines seems to confirm Eco’s belief that the media are a lost cause when it comes to science “because the relationship they draw between cause and effect every day is of a magical nature.” Once BPA was ensconced as a story of good, independent scientists saving the world from a deadly industrial chemical—either because most journalists couldn’t see how to report it any other way or lacked the capacity to understand the complexity of the science—all was lost. But. There is one news organization that has repeatedly bucked all these failings, one that has focused on the issues of replication and risk assessment as being central to understanding the BPA controversy: National Public Radio (NPR). Someone who listened to NPR and avoided the rest of the media would have a completely different understanding of BPA based on the stories written by its science reporters. It sought out the scientists who did the studies that failed to replicate the adverse effects reported by the rest of the media. And if NPR could do that, so could other news organizations.

Facts Get in the Way of a Good Story The problems in the media’s reporting of science have been long known. In 1974, James Tankard and Michael Ryan published the seminal study on how scientists perceived the accuracy of science coverage in the news. “Large majorities

Trevor Butterwoth is director of Sense About Science USA.

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HERE’S TO YOUR HEALTH! Celebrating the healthy hydration messages of IBWA and Drink Up

By Kristin Pearson Wilcox, IBWA Vice President of Government Relations

Last September, IBWA celebrated its first anniversary supporting Drink Up (www.youarewhatyoudrink.org), the pro-water initiative that is the result of a collaboration between the Partnership for a Healthier America (PHA) and its honorary chair, First Lady Michelle Obama. Drink Up encourages Americans to drink more water (bottled, tap, or filtered) more often, and IBWA has been supporting the campaign since it launched in 2013. Recently, IBWA committed to continue supporting the initiative through 2017. With media reports highlighting the success of Drink Up, those of us in the bottled water industry may be asked how we can measure that success. 22

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Sales Growth In July 2014, the First Lady announced some exciting news for the bottled water industry: Research firm Neilsen Catalina Solutions (NCS) had statistics showing that Drink Up’s online ad campaign “fueled a 3 percent lift in incremental sales of bottled water among those exposed to the campaign” and determined that equated “to almost $1 million in incremental retail sales of bottled water.” IBWA issued a press release in support of that positive development. IBWA President and CEO Joe Doss said, “Drinking safe, refreshing bottled water is one of the best and healthiest choices that nearly everyone can make every day, whether at

home, at work, or on the go.” He added, “It is an easy way to stay hydrated and maintain a healthy diet.” “When it comes to packaged beverages, more and more people are choosing bottled water,” said Doss. “And, as people make the smart decision to choose bottled water, it becomes vital that this safe, healthy, and convenient product remain available where other drinks are sold.” (Read the press release at bit.ly/IBWADrinkUp.)

Engagement In September 2014, Drink Up reported on the success of the campaign’s first year. It has engaged


GOVERNMENT RELATIONS hundreds of millions of people through social media, advertising, events, and celebrity ambassadors. Drink Up reached even more people through online, digital-out-of-home, and mobile advertising; PSAs; and co-branded products. The Drink Up logo and #spreadthewater hashtag were posted in fitness centers in 15 cities across the United States and on bus shelters in key markets (e.g., Philadelphia and Chicago). Drink Up’s list of supporters—which includes more than 60 companies and organizations—continues to grow. IBWA is aware of three member bottlers that are active supporters of the Drink Up initiative: Nestlé Waters North America, Danone Waters of America, and Niagara Bottling. (To find out how your company can

WANT TO GET INVOLVED IN DRINK UP?

EMAIL KWILCOX@BOTTLEDWATER.ORG. become a Drink Up supporter, email kwilcox@bottledwater.org.)

Spread the Water The campaign continues to use Facebook and Instagram to promote its pro-water messaging. Influential people and famous celebrities continue to tout the healthful effects of drinking water on Twitter, including @FLOTUS, @EvaLongoria, @JamesFrancoTV, @kerrywashington, @johnlegend, and

more than 60 supporters across the water community, including IBWA (@BottledH2OBabe, @LuvBottledWater, and @BottledWaterOrg). Months before celebrating its oneyear anniversary, the campaign reported in June 2014 that Drink Up messaging will be on approximately one billion products—everything from outdoor taps, reusable bottles, bottled water and packs, filters, even delivery trucks. The campaign averages 300,000 Facebook impressions each week and 35,000

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GOVERNMENT RELATIONS unique views of its Instagram feed at youarewhatyoudrink.org. Taking advantage of its national and local reach, Drink Up has collaborated with The Food Trust to launch its first city-wide effort: Drink Up Philly. Throughout 2015, the campaign will engage Philadelphians with one simple message: You are what you drink and when you drink water, you Drink Up. To further strengthen its collaboration with IBWA, Drink Up leadership has committed to continue our close working relationship by inviting PHA leaders to address membership at both the 2014 IBWA Annual Business Conference and Trade Show (being held November 10-14 in Dallas) and the 2015 IBWA June Board of Directors and Committee Meetings in Alexandria, Virginia, scheduled for June 1-4. Those presentations will focus

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on how the industry and initiative can collaborate more closely to encourage more Americans to drink more water more often.

Long-term Results IBWA has been an active cheerleader for the cause of healthy hydration. We regularly promote and support Drink Up across our social media and publications platforms, including Facebook (www.facebook.com/ bottledwatermatters and www. facebook.com/hydration-healthhappiness), Twitter (twitter.com/ BottledWaterOrg), Pinterest (www. pinterest.com/luvbottledwater), and Instagram (instagram.com/ bottledwatermatters). Since Drink Up was launched, IBWA has published 12 articles about the campaign (four in Bottled Water

Reporter and eight in Splash, our weekly e-newsletter); tweeted or re-tweeted information about Drink Up 43 times; and posted 20 stories about Drink Up to our Facebook pages. IBWA has also promoted Drink Up by creating a dedicated Pinterest board, posting photos on our Instagram account, and participating in Drink Up Tweetups and webcasts. In the coming years, we will continue to promote Drink Up through our social media platforms and publications, and look for ways to further raise awareness of Drink Upâ&#x20AC;&#x2122;s healthy hydration messaging, push out the campaignâ&#x20AC;&#x2122;s social media hashtags, and encourage others to learn about and support Drink Up.


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How 2014 Efforts Can Inspire 2015 Success By Chris Hogan, IBWA Vice President of Communications

In 2014, Beverage Marketing Corporation (BMC) published the 2013 statistics of the bottled water industry, and the numbers were pretty impressive. Bottled water consumption and sales growth reflected the continuing trend of more Americans choosing to drink bottled water more often. For the first time ever, in 2013 total U.S. bottled water consumption surpassed 10 billion gallons, increasing to 10.1 billion gallons, a 4.7 percent increase over 2012 numbers. Bottled 26

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water sales grew by 4.0 percent (for a total of $12.3 billion wholesale dollars), and per-capita consumption rose 4.0 percent, with every person in America drinking an average of 32 gallons of bottled water. In fact, the American consumerâ&#x20AC;&#x2122;s thirst for bottled water is so strong that BMC CEO Michael Bellas predicts bottled water will overtake carbonated soft drinks to be the No. 1 packaged beverage sold in the United States by 2020. It currently holds the No. 2 position.

But what makes such growth happen? Why do consumers choose bottled water? What actions have the bottled water industry undertaken in 2014 that will support success in 2015 and beyond?

A Healthful Cause Weâ&#x20AC;&#x2122;re an on-the-go society, and, to accommodate the lifestyles of their consumers, beverage companies provide a wide variety of packaged beverages. In fact, most of what we drink comes


COMMUNICATIONS in a package. So, why—with so many choices on the market shelves—do consumers increasingly opt to drink bottled water? Since 1998, approximately 73 percent of the growth in bottled water consumption has come from people switching from carbonated soft drinks, juices, and milk to bottled water. Data from marketing research firm FRC shows that if bottled water isn’t available, 63 percent of people will choose soda or another sugared drink—not tap water. People continue to choose bottled water for many reasons, including its association with healthfulness, reliable quality, zero calories and additives, convenience, safety, value, and taste.

Partner for Success In 2014, IBWA has been actively supporting Drink Up, an initiative of First Lady Michelle Obama and the Partnership for a Healthier America (PHA), which encourages Americans to drink more water more often—whether from the tap or in a bottle. The effort has been so successful that a 2014 Nielsen Catalina Solutions (NCS) report shows Drink Up’s online ad campaign resulted in a 3 percent lift in bottled water sales (i.e., approximately $1 million in incremental retail sales) among those who saw the advertising. Promoting the many benefits of drinking water is nothing new to IBWA. Still, the NCS findings confirm that the Drink Up campaign is an important and healthful effort that can benefit all Americans, and one that IBWA plans to continue supporting in the future. For more on Drink Up, read this issue’s Government Relations column (p.22) and visit youarewhatyoudrink.org.

Focus on Recycling Recycling continues to be an important issue for our industry—and IBWA constantly reinforces the fact that

BOTTLED WATER IS PREDICTED TO BE THE NO. 1 PACKAGED BEVERAGE IN THE U.S. BY 2020. all bottled water containers are 100 percent recyclable. According to the National Association for PET Container Resources (NAPCOR), the recycling rate for single-serve PET plastic bottled water containers, which now stands at 38.04 percent, more than doubled between 2003 and 2012. In fact, NAPCOR finds that plastic bottled water containers continue to be the most frequently recycled PET beverage container in curbside recycling programs.

when some activist groups urged the National Parks Service (NPS) to ban bottled water completely from America’s national parks, we stepped in. Such a ban would directly impact the right of people to choose the healthiest beverage on the shelf. By not providing bottled water, NPS would neglect to meet the needs of those lovers of nature that have compromised immune systems and rely on bottled water to meet their hydration needs and also limit the beverage selection sold to their patrons.

Concern for Consumers

Tell Our Story

Last June, the Bottled Water Quality Information Act (H.R. 4978), which would provide consumers with uniform information about the quality and safety of their bottled water products, was introduced in the U.S. House of Representatives. A bill such as this—which makes it easier for consumers to obtain clear, consistent, and comprehensive information about the bottled water products they buy—easily garnered support from IBWA. National uniform labeling and bottled water quality reporting standards are good for consumers and build on the extensive product information already provided by bottlers. This important legislation codifies the bottled water industry’s current efforts to ensure transparency and continues our commitment to have the highest quality standards. In our efforts to look out for consumers, IBWA has also been fighting to ensure bottled water is always available where other packaged beverages are sold. For example,

Obviously, the efforts highlighted above shine a light on only some of IBWA’s 2014 activities. We encourage readers to visit www.bottledwater. org to learn more about IBWA and how we support our members and the bottled water industry. We have a great story to tell. Members can help us share that story by taking on an active role in promoting IBWA messaging and the facts about bottled water. If you haven’t already, start following IBWA on Facebook, Twitter, and YouTube; check out our Instagram feed and Pinterest page; and visit our websites: www.BottledWater.org and www. BottledWaterMatters.com. From those sites and sources you can cull a lot of information to share with your consumers, legislators, and local media. Help us spread bottled water’s healthy hydration message!

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Last September, I attended the first annual Sustainable Packaging Coalition (SPC) Advance meeting in Minneapolis, Minnesota. SPC, an industry group dedicated to “a more robust environmental vision for packaging,” organized this event for sustainability professionals across the packaging value chain as a chance to collaborate, learn, engage, and ask questions about the issues that matter most for moving sustainability in their organizations. Sponsored by Minnesota area companies, including 3M, General Mills, and NatureWorks, and planned and developed by, among others, Target and the Minnesota Pollution Control Agency, this meeting offered attendees a look into how different companies tackle sustainability issues. Obviously, I wanted to attend sessions that I thought would benefit IBWA members, and “Learn From the Experts: Integrating Sustainability Into Core Business Practices” easily grabbed my interest. The objective of this session was to learn how a material manufacturer, a converter, and a brand owner each capitalized on sustainability and integrated ambitious objectives into their companies’ business strategies. In other words, these session speakers explained how to integrate sustainability into business practices that result in financial gains. And I’m pretty sure all business owners are interested in that.

Sustainability in Business Makes “Cents” By Tamika Sims, IBWA Director of Science and Research

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Start at the Top First to speak was Gayle Schueller, vice president of global sustainability at 3M (www.3m.com), a materials manufacturing company. Notably, 3M has won the ENERGY STAR Sustained Excellence Award for Energy Management for its comprehensive worldwide energy conservation efforts. The company focuses so much on sustainability that management has


TECHNICAL UPDATE

incorporated it into 3M’s business values, which include the following: • “Satisfy our customers with innovative technology and superior quality, value and service. • Provide our investors an attractive return through sustainable, global growth. • Respect our social and physical environment around the world.” Schueller stressed the importance of adhering to a business philosophy that centers on environmental stewardship, social responsibility, and economic success. At 3M, she says, the company often pauses to examine how its product manufacturing influences natural resources and raw materials supply (e.g., water and energy). 3M also focuses on how its business practices and product manufacturing influence the health and safety of the public. As a product innovator, 3M is continuously reevaluating its products to grow the idea—and part of that growth includes seeing waste as a nutrient that it can incorporate into more products.

Implement With Vision David Struhs, vice president of sustainability at the materials converter company Domtar (www.domtar.com), spoke next about the many ways his company strives to do “sustainability the right way”—for all aspects of the business: market differentiation, customer satisfaction, employee engagement, and community investment efforts. The company consistently focuses on understanding practical operation performance and how it relates to sustainability opportunities. Struhs explained that Domtar maps sustainability opportunities, and that process involves considering the company’s overall practices in innovation, initiative, participation, and certification. It also reviews how each of those practices can promote

IMPLEMENTING SUSTAINABILITY PRACTICES IS NOTHING NEW TO THE BOTTLED WATER INDUSTRY— BUT WE KNOW WE CAN DO MORE. a sustainability—and commercial— advantage for Domtar.

Prioritize Your Efforts Last to present was Jerry Lynch, chief sustainability officer at General Mills. Lynch acknowledged that it can be hard for “companies to draw a straight line between sustainability initiatives and business cost saving.” General Mills is well aware that it cannot continue to operate and flourish with an increase in consumer demand (as the population continues to grow) and a decline in the availability of natural resources. As part of its business strategy, General Mills prioritizes its sustainability efforts. Mother Nature has to be a major focus , according to Lynch, because it supplies all companies with the raw ingredients they need for their products. For General Mills, that means considering the carbon and water footprints of its raw materials, which accounts for two-thirds of the company’s carbon footprint and 99 percent of its water footprint. On the General Mills website (www. generalmills.com), it states the company is “committed to sustainably sourcing 100 percent of [its] 10 priority ingredients by 2020—representing more than 50 percent of [its] annual raw materials purchases.” In addition, General Mills has a strong focus on packaging improvement for its products, including packaging weight, recycled content, renewable

content, and truckload efficiency. The General Mills website also states that “59% of [its] packaging volume has been improved since 2009…86% of [its] solid waste was diverted from landfills in 2013. Since 2005, [the company has] reduced [its] waste generation rate by 40%.” That’s pretty impressive.

Learn From Others Implementing sustainability practices is nothing new for the bottled water industry. It is well documented that bottled water has the smallest environmental footprint of any packaged beverage. In addition, results from the 2014 IBWA Water Use Benchmarking Study show that the amount of water used to produce bottled water products is less than all other types of packaged beverages. On average, only 1.32 liters of water is used to produce every 1 liter of finished bottled water product, including the liter of water consumed. But we know we can do more—and the examples from the companies detailed above provide the inspiration to do better. By reviewing the environmental sustainability practices of other companies and industries, such as the ones presented at the SPA Advance meeting, IBWA can create sustainability tools (informational documents, industry alliances, educational seminars, etc.) that can help all IBWA members in their future sustainability efforts.

NOV/DEC 2014

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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 Claire Crane, IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22134. Look for additional quizzes in future issues and earn additional IBWA CEUs!

Name______________________________________________________ Company__________________________________________________ Address____________________________________________________ City_______________________________________________________ State/Province______________________________________________

ZIP/Postal Code____________________________________________

Check your selection for each question

1|

On a label of purified bottled water with minerals added, the mineral salts added are listed on the _____.

OO OO OO OO

principal display panel nutrition facts panel information panel volume contents panel

2|

The process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for food safety and therefore should be addressed in the HACCP plan is called _____.

OO OO OO OO

preventive control hazard analysis sanitary survey risk assessment

3|

Which of the following is not a compliant identity statement on a bottled water label?

OO OO OO OO

Purified water with minerals added Mineral water Artesian water Artesian spring water

4|

A maximum and/or minimum value to which a biological, chemical, or physical parameter must be controlled at a CCP to prevent, eliminate, or reduce to an acceptable level the occurrence of a food safety hazard is called a _____.

OO OO OO OO

critical control point critical limit control limit performance range

5|

Validation is collecting and evaluating scientific and technical information to determine if the HACCP plan, when properly implemented, will effectively control the hazard(s).

OO True OO False 30

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6|

If a bottled water contains 24 ug/l of arsenic, it is illegal to sell the product if it does not contain the following statement:

OO OO OO OO

“Contains excessive arsenic” “Fortified with arsenic” “Contains more than the RDA of arsenic” “A good source of arsenic”

7|

As proposed by FDA, a bottle of a carbonated soft drink larger than 24 fluid ounces would require _____.

OO OO OO OO

a nutrition facts panel dual column labeling a larger label a list of ingredients

8|

Monitoring is conducting a planned sequence of observations or measurements to assess whether a sanitization program is under control and to produce an accurate record for future verification.

OO True OO False

9|

Under current FDA regulations, “very low sodium” can be used on a label if the product contains _____ of sodium.

OO OO OO OO

between 5 and 35 mg per serving less than 5 mg per serving more than 35 mg per serving between 36 and 140 mg per serving

10|

Prerequisite programs are procedures, including Good Manufacturing Practices (GMPs) that address operational conditions and provide the foundation for the HACCP system.

OO True OO False


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FEBRUARY 17 - 20

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

MARCH 27 - 28

Northeast Bottled Water Association Spring Conference Mystic Hilton Mystic, CT

APRIL 16 - 18

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

JUNE 1 - 4

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

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VALUE OF IBWA MEMBERSHIP ERIC AMANN GLOBAL MARKETING MANAGER 3M – FOOD SAFETY DIVISION ST. PAUL | MINNESOTA ALL ABOUT ERIC During his first 10 years at 3M, Eric had 18 different addresses in five countries, moving around as part of the company’s process improvement group. When not working, he devotes his free time to family activities: sports, the outdoors, and scouting with his wife and three children. Eric speaks fluent German, which was his first language when his German parents settled in Chicago.

Eric Amann has spent his entire career at 3M employed in a diverse range of positions, divisions, and locations around the world. He’s worked on process improvement projects in manufacturing plants, product development for the semiconductor industry, and marketing and business development within the company’s Dental Products Division. About five years ago, he was introduced to the bottled water world when he joined 3M’s Food Safety business unit, where he currently holds the title of global marketing manager. For Amann, the value of IBWA membership comes from its distinction as a one-stopshop that can help members quickly learn about the bottled water industry, enabling them to stay up-to-date on industry issues through education seminars, publications, and networking. “Within 3M food safety, we didn’t know much about the bottled water industry when we started expanding the application of our food microbiology products to water testing,” he says. “It was great for us to join an organization and immediately get a feel for the players in the industry, learn about the important industry issues, and start networking with actual bottlers and other companies.” Amann compares the value of IBWA membership with a recent experience he had learning about a new, adjacent segment within the food ingredients industry: “We’re out there visiting customers one by one and talking to a few state-level associations. There was a national organization, but it isn’t as organized as IBWA, so it was more difficult to get a sense of the industry. But with IBWA, we had immediate access.” As an active member, Amann participates regularly at committee meetings, as well as attends IBWA’s annual business convention and trade show. He says he is constantly amazed at the close-knittedness and passion of IBWA members. “Bottlers are incredibly passionate about what they do—their purpose, creating a quality product, and the value it has in society.” Similarly, 3M strives to be the very best at what it does. 3M’s Food Safety business is a leading provider of microbiology testing materials to the food and beverage industry. “We use our expertise in that field to give our customers innovative solutions that help make them more efficient and effective,” says Amann. “It’s not just about the products that we have that we believe are good, solid-quality performing products, but it’s also the expertise that we bring along as a large company. We can provide local technical and sales support to our customers in every part of the world and in every corner of the United States.”

32

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PRSTD STD US POSTAGE PAID DULLES VA PERMIT #382

86% consider Bottled Water

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Bottled Water Reporter By the Numbers*

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Bottled Water Reporter  

Packaging / Innovation November / December 2014

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