W W W. B O T T L E D W AT E R . O R G
IN THIS ISSUE When Your Why Share How to Host Bottled Water a Plant Tour Business Must Comply With FSMA Facts and Figures
BOTTLED WATER REPORTER | NOV/DEC 2015
More Bottled Water Containers Lightweighted, Using rPET How Bottled Water Bottles Stack Up Against Other Common Drink Packages A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION
VOL. 55 • NO. 6
COLUMNS GOVERNMENT RELATIONS
24 | Enlighten Elected Officials: Invite Them to Tour Your Plant Host a plant tour using these 10 easy steps.
28 | How to Kill a Negative Bottled Water Story Introduce facts and figures. TECHNICAL UPDATE
32 | FSMA’s Long-awaited Final Rule on Preventive Controls Published Find out when your company needs to comply. VALUE OF IBWA MEMBERSHIP
36 | Don’t Reinvent the Wheel Bob Riefer (Maumee Valley Bottlers, Inc.) tells Bottled Water Reporter how IBWA membership shortens the learning curve for new bottlers.
CONTENTS TABLE OF CONTENTS 10 | The Effect of Bad Science on the Bottled Water Industry Behind anxiety-inducing headlines is research that has been analyzed to throw up an interesting finding. The bottled water industry has seen studies of bisphenol A (BPA) fall victim to such hijinks. However, most BPA research that suggests a health risk falls apart when reviewed by a statistician. By Trevor Butterworth
CHAIRMAN’S COMMENTARY................................2 PRESIDENT’S MESSAGE.......................................4 WATER NOTES.....................................................6 CEU QUIZ..........................................................34 ADVERTISERS....................................................35 CALENDAR........................................................35
CONNECT WITH IBWA
16 | What’s Really Clogging Up the Landfills? Hint: It’s not bottled water containers. On social media and in the blogosphere, reports continue to errantly perpetuate the idea that bottled water packaging is clogging up landfills. But what is the truth? By Jill Culora
20 | Water Bottles: Recycled Content Up, Weight Down The rare beverage category that uses a package type as part of its name, bottled water intrinsically values its container. Beverage Marketing Corporation’s latest analysis of bottled water bottles shows that more bottlers are using recycled content and decreasing the weight of their bottles. That’s a significant contribution, as the numbers of bottles sold in the United States continues to increase each year. By John G. Rodwan, Jr.
BOTTLED WATER REPORTER, Volume 55, 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.bottledwater.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.
CHAIRMAN’S COMMENTARY ON TO THE NEXT CHALLENGE As I write this, I’m preparing to travel to Washington, DC, for the 2015 IBWA Annual Business Conference and Trade Show. The conference will be my swan song as your IBWA chairman, but I couldn’t be more proud of our achievements this year. IBWA’s work to ensure that water consumption plays a more important role in the soon-to-be published 2015 Dietary Guidelines for Americans has been impressive. We traveled to the White House to meet with decision makers from the U.S. Department of Agriculture and Department of Health and Human Services, the agencies responsible for developing the guidelines; provided scientific research detailing the health benefits of water consumption; testified at hearings; and formed new, helpful relationships with likeminded water advocates. We don’t yet know if the guidelines will promote more water consumption, but we do know we have made great strides in ensuring that those responsible for setting policy are aware of how bottled water can help the health crisis in America. On July 7, 2015, our legislative educational efforts were rewarded when IBWA won a vote on the floor of the U.S. House of Representatives. An amendment, sponsored by Rep. Keith Rothfus (R-PA), passed that halts a National Park Service (NPS) policy allowing park units to ban the sale of bottled water. This first step would not have been possible if we had not continuously worked to educate legislators about the benefits of water consumption and the recyclability of our products. IBWA’s foresight to provide email updates, e-newsletter and Bottled Water Reporter articles, and in-person educational sessions and webinars on the Food Safety Modernization Act (FSMA) is commendable. The membership has been kept informed about how the new regulations will have a significant impact on our businesses. Although compliance dates may be a year or more away for some, IBWA’s efforts help to ensure our companies are ready to comply with all FSMA requirements. While significant, those aren’t the only advancements we’ve made this year: we’ve educated members of Congress about industry issues, participated in grassroots outreach efforts with influential associations, promoted the truth about bottled water and water scarcity issues, donated bottled water to emergency relief efforts, and increased production of education materials members can use on their social media sites to help educate consumers. But none of that would have been possible without the dedication of IBWA members and staff. I want to thank each of you for helping me navigate this past year. It has been educational, delightfully overwhelming, and inspirational. I can’t wait to see what we accomplish together next year.
International Bottled Water Association OFFICERS Chairman Bryan Shinn, Shinn Spring Water Company Vice Chairman Joe Bell, Aqua Filter Fresh Treasurer Shayron Barnes-Selby, DS Services Immediate Past Chairman William Patrick Young, Absopure Water Co., Inc.
BOARD OF DIRECTORS Shayron Barnes-Selby, DS Services Joe Bell, Aqua Filter Fresh Philippe Caradec, Danone Waters of America Andy Eaton, Eurofins Eaton Analytical Brian Grant, Pure Flo Water, Inc. Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Greg Nemec, Premium Waters, Inc. Heidi Paul, Nestlé Waters North America Bryan Shinn, Shinn Spring Water Company Robert Smith, Grand Springs Distribution Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.
IBWA EXECUTIVE COMMITTEE Chairman, Bryan Shinn, Shinn Spring Water Company Shayron Barnes-Selby, DS Services 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 William Patrick Young, Absopure Water Co., Inc.
COMMITTEE CHAIRS Communications Committee Damon Grant, Pure Flo Water, Inc. Jane Lazgin, Nestlé Waters North America Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee Philippe Caradec, Danone Waters of America Jeff Davis, Blackhawk Molding Co. Government Relations Committee Shayron Barnes-Selby, DS Services Lynn Wachtmann, Maumee Valley Bottlers, Inc. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, DS Services State and Regional Associations Committee Joe Cimino, ChoiceH2O Ross Rosette, H2Oregon Supplier and Convention Committee Brian Grant, Pure Flo Water, Inc. Dan Kelly, Polymer Solutions International Technical Committee Andy Eaton, Eurofins Eaton Analytical Kevin Mathews, Nestlé Waters North America
Bryan Shinn IBWA Chairman 2
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International Bottled Water Association
PRESIDENT’S MESSAGE MESSAGE IN THE PACKAGING
BOTTLED WATER REPORTER is published for: International Bottled Water Association 1700 Diagonal Road, Suite 650 Alexandria, VA 22314-2973. Tel: 703.683.5213 Fax: 703.683.4074 www.bottledwater.org
In this issue of Bottled Water Reporter, we discuss the many different ways that bottled water packaging matters. Our cover story, “The Effect of Bad Science on the Bottled Water Industry” (p.10) written by Trevor Butterworth, director of Sense About Science USA, addresses the surprisingly frequent practice of faulty research leading to inaccurate, and often scary, headlines. The bottled water industry has often observed this phenomenon when the media covers bisphenol A (BPA), a well-studied chemical compound approved by the U.S. Food and Drug Administration (and other regulatory agencies worldwide) to manufacture polycarbonate plastic—a common material of choice for food and beverage product containers. According to Butterworth, ending the senseless clamor about the safety of BPA could lead scientists to focus on real environmental chemical risks. In “What’s Really Clogging Up the Landfills?” (p.16), we present an infographic inspired by our investigation into how PET plastic, single-serve bottled water products compare with the environmental effects of the eight most common drink packages. Perhaps by sharing that infographic through social media we can encourage more recycling—of all beverage packages. In “Water Bottles: Recycled Content Up, Weight Down” (p.20), we take a moment to acknowledge the impressive efforts the bottled water industry has made to decrease its environmental footprint. In short, bottled water bottler use of rPET is up (the average rPET content for companies that use rPET is 20 percent per container), and we are also assertively lightweigthing bottles—the average weight now stands at 9.25 grams, a 51 percent drop since 2000. These two articles help to show that when people choose bottled water, instead of any other canned or bottled beverage, they are choosing less packaging, less energy consumption, and less use of natural resources. In the Communications column (p.28), we explain why it’s best to combat negative bottled water stories with facts and figures (such as the data provided in this issue of Bottled Water Reporter). Our Government Relations column (p.24) details how hosting a plant tour for elected officials is a great way to educate them about the bottled water industry. Finally, the Technical Update column (p.32) continues the focus on bottler plants, as we review how the Preventive Controls Rule of the Food Safety Modernization Act (FSMA) will impact the bottled water industry. I hope you enjoy the articles in this issue of Bottled Water Reporter. As always, feel free to contact IBWA Publications Manager Sabrina Hicks (firstname.lastname@example.org) if you have any topics you’d like us to cover in the New Year.
Joe Doss IBWA President
President Joseph K. Doss email@example.com Vice President of Education, Science, and Technical Relations Robert R. Hirst firstname.lastname@example.org Vice President of Communications Chris Hogan email@example.com Vice President of Government Relations Kristin Pearson Wilcox firstname.lastname@example.org Chief Financial Officer Michelle S. Tiller email@example.com Director of Conventions, Trade Shows, and Meetings Michele Campbell firstname.lastname@example.org Director of Science and Research Vacant Director of Government Relations J.P. Toner email@example.com Manager of Publications and Special Projects Sabrina E. Hicks firstname.lastname@example.org Manager of Member Services Vacant Education and Technical Programs Coordinator Claire Crane email@example.com Executive Assistant Patrice Ward firstname.lastname@example.org Bottled Water Reporter Layout and Design Rose McLeod email@example.com Tel: 315.447.4385 Editor Sabrina E. Hicks firstname.lastname@example.org Advertising Sales Stephanie Schaefer email@example.com
The press lined up to cover Assemblymember Devon Mathis (right) and Donna Johnson (left), thanking the bottled water industry for the donated water.
EMERGENCY RELIEF DONATIONS
IBWA Members Deliver More Than 15,000 Gallons of Bottled Water to Town Without Water
On September 21, 2015, IBWA, though its Hydrate California campaign, coordinated the delivery of more than 15,000 gallons of bottled water—the equivalent to more than 100,000 16.9 ounce PET bottles— to the residents of East Porterville, California. IBWA members Absopure,
CG Roxanne, DS Services of America, and Nestlé Waters North America participated in the donation event. The donation was gratefully received by California Assembly member Devon Mathis, the Tulare County Office of Emergency Services, and residents of Porterville.
If you have recently donated bottled water products to a community in need, please let IBWA know about it. Send photos and donation details to IBWA Vice President of Communications Chris Hogan: firstname.lastname@example.org.
DWRF Awards Kristin Safran College Scholarship to Samantha Seay Virginia Tech freshman Samantha Seay is the 2015 recipient of the Kristin Safran College Scholarship. Samantha, whose father Derek works as a route sales representative for DS Services, began her studies at Virginia Tech this fall and plans to become a certified clinical nutritionist. Samantha graduated from Bassett High School in Bassett, Virginia, with a 4.0 GPA. Her transcript is filled with Advanced Placement level coursework, and she also graduated with an associate’s degree from Patrick Henry Community College. Samantha’s academic achievements earned her the Henry County Academic Excellence Award, and she was a member of the National Honor Society and Beta Club. In addition to excelling academically, Samantha Seay Samantha was active in many school organizations, including Student Council Association and Spanish Club, participated in the freshman mentor program, and played for the varsity tennis and volleyball teams, serving as captain of the tennis team her senior year. 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. For more on DWRF, visit www.thefactsaboutwater.org.
WATER NOTES Rep. Keith Rothfus (R-PA) stands by HOD bottles manufactured by Polycycle Solutions.
Benefits of a Plant Tour Education Last June, IBWA Government Relations (GR) Committee Member Phyllis Rokus (Polycycle Solutions) hosted a plant tour at Polycycle’s California facility for Rep. Keith Rothfus (R-PA). During that tour, Polycycle employees were able to chat with Rep. Rothfus about the inner workings of a bottled water plant and discuss industry challenges. Rep. Rothfus went on to champion an amendment on the floor of the U.S. House of Representative on July 6, 2015, which helped to end the ban on the sale of bottled water in the National Parks. Rep. Rothfus’ support was critical to the industry’s success on what IBWA’s GR Committee has deemed a priority issue. Niagara Bottling’s Coweta County Plant Director Jeremy Derk facilitated a plant tour for Rep. Lynn Westmoreland (R-GA) in August 2015. According to Derieth Sutton, Niagara’s Director of Economic Development & Government Relations and a member of IBWA’s GR Committee, “By the time Jeremy got [Rep. Westmoreland] out on the floor, his ‘I only have 15 minutes for a tour,’ turned into 45 minutes of questions and answers.” In addition to the time spent on the company and plantspecific overview, the congressman was engaged, laughing, and making jokes. Rep. Westmoreland even commented that he had never seen anything like Niagara’s plant and that he was “extremely impressed with the efficiency and technology.” In addition, last October DS Services hosted Florida Governor Rick Scott (R) at its new Lakeland, Florida Customer Care Center. The governor used that occasion to report a reduction in the state’s unemployment rate. DS Services employs about 350 associates at
DS Services CEO Tom Harrington (right) greets Florida Governor Rick Scott (left) at the new DS Customer Care Center in Lakeland.
the Lakeland Customer Care Center and plans to hire an additional 100 associates in the near future. To learn how your company can host a successful plant tour, read this issue’s Government Relations column, “Enlighten Elected Officials: Invite Them to Tour Your Plant,” on page 24.
Congressman Lynn Westmoreland (fourth from right) visits with Niagara’s Team Coweta County.
WATER NOTES AWARDS
Winners Announced for 2015 Global Bottled Water Awards The winners of the 2015 Global Bottled Water Awards were announced during a gala dinner on October 21 in Lisbon, Portugal. The awards were a highlight of the 12th Global Bottled Water Congress and were organized in conjunction with media partners BeverageDaily.com, Beverfood, and IBWA. More than 100 entries from 22 countries for the award program’s 11 categories were submitted, all of which demonstrated creativity, innovation, marketing, community initiative, and environmental best practice. Listed below are the award winners in each of the 11 categories. For a complete list of finalists and winners, visit zenithinternational.com. Best Natural Water Iceberg Water – Concept Spirits BV
Best Cap or Closure LifeTop – CapAble AB
Nestlé Waters MT’s 1L San Pellegrino Magnum Bottle won Best Bottle Design.
Best Marketing including Social Media Buxton London Marathon Campaign – Nestlé Waters MT
Pedras Salgadas – Unicer SA Best Flavored Water Nuva Spring Water with a Kiss of Extracts – Nuva Ltd
Best Sustainability Initiative ECO-Flex – Coca-Cola HBC Greece
Best Functional Water POW Sparkling Energy Water – The Powerful Water Company
Best Community Initiative Hope in a Bottle – Friends of Hope Inc
Best New Water Concept Font Vella Mascot – Danone Waters Best New Brand Hope in a Bottle – Friends of Hope Inc Best Bottle Design San Pellegrino Magnum – Nestlé Waters MT Best Label Font Vella Mascot – Danone Waters
Danone Waters’ Font Vella’s Mascot label won the Best Label category.
CapAble AB accepted the award for Best Cap or Closure for its LifeTop Cap.
Compliance Dates for FSMA’s Preventive Controls Rule
On September 24, 2015, the U.S. Food and Drug Administration (FDA) issued the final rule for Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food (i.e., “Preventive Controls Rule”). The long-awaited rule will be the most impactful of the seven primary Food Safety Modernization Act (FSMA) rules for the bottled water industry. The effective date of the final rule is November 17, 2015. But is that when you have to be in full compliance with the rule? No. The compliance dates are as follows: • very small businesses: September 17, 2018 • small businesses: September 18, 2017 • all other businesses: September 19, 2016 Are you a very small business? A small business? A qualified facility? None of the above? Read this issue’s Technical Update column, “FSMA’s Long-awaited Final Rule on Preventive Controls Published,” on page 32 to find out.
WATER NOTES ENVIRONMENTAL SUSTAINABILITY
What We Need Is a Recycling Revolution
In “The Reign of Recycling,” an op-ed by columnist John Tierney recently published in the New York Times Sunday Review, recycling is presented as “wasteful,” “ineffectual,” and “costly.” Not surprisingly, the broader recycling industry does not agree. According to Keep America Beautiful, its primary concern about the piece, and other articles with similar themes, is that it may discourage Americans from recycling. In the United States, recycling is an important part of our national solid waste infrastructure. It’s an effective and currently irreplaceable means of reducing disposal and transforming “waste” into valuable materials that can be manufactured into new products.
In fact, “giving garbage another life” is a theme behind the successful Keep America Beautiful/Ad Council “I Want To Be Recycled” public service advertising and awareness campaign. Research conducted for the development of the campaign by C+R Research was clear: Americans want to recycle. Approximately two-thirds of respondents said recycling is a very/extremely important issue, citing its potential positive impact on the economy, public health, the environment, and waste reduction, among other benefits. (The C+R survey was conducted online from August 28 – September 15, 2014, with 1,000 Americans age 18-64.)
When Tierney focuses on certain negative details, he sends the wrong message, effectively discouraging people from recycling altogether. Keep America Beautiful suggests that we educate, motivate, and activate people to better understand the “how, what, where, and why” of recycling today and in the future. For its part, Keep America Beautiful will continue to partner with other leading recycling industry organizations to showcase the enormous environmental and economic benefits of recycling. The nonprofit organization suggests we focus on what works; address the challenges; better engage the public on what to recycle; and develop the processes, technologies, and markets needed to expand robust, sustainable recycling. According to Keep America Beautiful, turning our backs on recycling altogether now would significantly hurt the U.S. balance of trade, the recycling industry, manufacturing that has come to rely on recyclables as a feedstock, the environment, and sustainable materials management. That would be a major step backward for our country and the health of our planet. IBWA encourages all members to educate their consumers and legislators about the benefits of recycling. Visit kab. org to find out how you can help Keep America Beautiful.
10 • BWR • WWW.BOTTLEDWATER.ORG
The Effect of
Bad Science on the Bottled Water Industry By Trevor Butterworth
How faulty research leads to inaccurate—and often scary— headlines that impact bottled water.
NOV/DEC 2015 • BWR • 11
An experiment must be designed so that it generates the right kind of data to answer the question you are interested in; otherwise, science becomes akin to interrogating the wrong suspect until you find “proof” that he or she committed a crime. Statistics are not what come after lies and damned lies; they are what come—or should come—before any data is collected. That may seem counterintuitive. The popular notion of statistics is that they are what you do, or what a statistician does, when the experiment has been finished. They provide the shazaam!—the “statistically significant” finding that will grow into a career-making headline for the scientist, bringing in future grants, TV appearances, and honors: “Daily consumption of kale improves beard growth.” Or—as is more likely—“your sofa/window blind/sunscreen/lawn mower/teddy bear/granite counter top/toothpaste/toilet paper/water bottle/daily consumption of X/failure to consume enough Y might be giving you cancer.” Now, undoubtedly, this is what actually happens with many of the scientific studies behind the anxietyinducing headlines that are a staple of the daily news. The data collected in those experiments is analyzed after the experiment has been done—and sometimes analyzed and analyzed and analyzed until it throws up an interesting finding. The problem, according to statisticians, is that many doctors and scientists have failed to understand that statistics is the science of experimental design and not just that of experimental analysis. You have to design your experiment so that it generates the right kind of data to answer the question you are interested in; otherwise, science becomes akin to interrogating the wrong suspect until you find “proof ” that he or she committed a crime. 12
If this seems obvious, it isn’t—as is evidenced by a host of recent initiatives, studies, and news stories looking at why many medical and psychological studies cannot be replicated. Or by talking to statisticians about the times they have been approached by a researcher looking for help analyzing data only to discover that because of poor experimental design, the data is useless. How much of an issue might this be in research on bisphenol A (BPA), the chemical compound used to manufacture polycarbonate plastic for food and beverage product containers (among many other items)? One example—a 2011 study that appeared in the journal Pediatrics—suggests that it might well be a huge problem. The study was reported widely in the news media with headlines that could not have failed to alarm parents. “Plastics Chemical Tied to Aggression in Young Girls,” ran the headline on ABC News. “The research showed that hyperactive, anxious, aggressive and depressed behavior was more common in 3-year-old girls who were exposed in the womb to bisphenol-A than in boys of the same age.” Girls were more sensitive to the chemical in the womb than boys, maybe because BPA mimics the female hormone estrogen, which is thought to play a role in behavioral development,” the Washington Post hypothesized. “It was the mother’s exposure that was the critical window,” Linda Birnbaum, director of the National Institute of Environmental Health Sciences (NIEHS) told Bloomberg Business. “That suggests that a pregnant woman, if she can, be careful of what she’s exposed to because it might have consequences to her children.” Criticism of the study’s methodology was mostly confined to spokespeople from the chemical industry, which never has the same scientific credibility as that of independent scientists or, as with NIEHS’s Birnbaum, the head of one of the National Institutes of Health. Moreover, when asked about whether the study had methodological shortcomings, Birnbaum told the Washington Post that the sample size was reasonable and the results supported studies that show similar effects in animals.
Significance of the Unmentioned There were, however, several standout issues that Birnbaum, the authors of the study, and certainly the news media all failed to note as they played up the significance of the research. According to the data reported in the study, the more boys were exposed to BPA in the womb the more their behavior improved. Why did such an astonishing result go unmentioned?
How many of the hundreds of alarming BPA studies have been burnished by spin into pseudo significance? The answer might well be many or most. Presumably, at least with the press, because the journalists didn’t check the data out; they simply took the scientists’ explanation of the study at their word. But that finding should have called the entire study into question, should have called for critical scrutiny of its results and design. When we (at Sense About Science USA) asked one of our statistical advisors about this anomaly, the study simply fell apart. It was a textbook example of poor statistical practice. The validity of the effect depended on cases of babies exposed to BPA being contrasted with those not exposed to BPA—yet there were no such counterfactuals in the model. Plus, the researchers only analyzed about 50 percent of their original sample and didn’t address how the excluded data might have affected the results. Then, the effects they found were skewed by a handful of cases in both boys and girls that weren’t adjusted for using the correct statistical techniques. In short, the study couldn’t answer the question it set out to answer, and the effects it found were trivial and meaningless. The question is, if such obvious flaws were so easily transmuted into dramatic findings by the authors, the head of a government agency, and the media, how many of the hundreds of alarming studies on BPA have also been burnished by spin into pseudo significance? Given the failure of the Environmental Protection Agency (EPA), the Food and Drug Administration (FDA), and agencies all over the world to replicate the low-dose adverse findings on BPA, the answer might well be many or most. Attempts to explain this disconnect have been cast, most recently, as a fundamental disagreement between toxicology and endocrinology over whether low-dose effects are real, but neither field can escape the gravitational pull of statistical rigor in study design or analysis. To measure a dose response to a chemical requires at least 50 observations, which is to say 50 experimental subjects; to find a small or subtle effect—a low-dose response—may
WHAT IS BPA?
The American Chemistry Council (ACC) describes bisphenol A (BPA) as “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 the material of choice for food and beverage product containers because it is lightweight, highly shatterresistant, and transparent. Some bottled water companies use polycarbonate plastic for their 3- and 5-gallon watercooler bottles, and it is also used to manufacture other everyday items, such as eyeglasses, compact discs, and DVDs. Is BPA safe? According to the ACC’s factsaboutbpa.org website, “Based on government research, along with results from other studies, the U.S. Food and Drug Administration (FDA) recently answered the question ‘Is BPA Safe?’ with a clear answer - ‘Yes.’ In the last several years, U.S. federal government scientists have been conducting in-depth studies to answer key questions and clarify uncertainties about the safety of BPA. To date, more than 20 of these studies have been published in the peer-reviewed scientific literature. Taken together, the results of these studies provide strong support for the safety of BPA.” Other regulatory agencies, such as Health Canada and the European Food Safety Authority, agree that dietary exposure to BPA does not pose a health risk. For more on BPA, watch the ACC’s “What Is BPA?” video: bit.ly/What_Is_BPA.
Will the intense scientific focus on the problem of replication in the biomedical sciences at large expand to include BPA? need up to 200 subjects. Indeed, the oft-repeated claim that BPA’s effects are subtle simply means that the way findings can be skewed are just as subtle and difficult to control. Meanwhile, the economic reality uniting toxicology and endocrinology is that few studies are well funded enough to scale to these numbers, least of all academic studies in universities. The histopathology (i.e., the microscopic examination of tissue in order to study the manifestations of disease) costs for 600 animals—a three-dose study—are eye watering.
BPA and the Question of Replication So, now the question is this: will the intense scientific focus on the problem of replication in the biomedical sciences at large expand to include BPA? In following this issue for about eight years, the failure of the media (apart from National Public Radio) to look under the hood of BPA research and ask why is it that the EPA, FDA, and others keep rejecting research claiming adverse effects has been extraordinary. Can that remarkable lack of interest in the other side of the issue be sustained when the clamor over replication has become so widespread in science? As Francis Collins and Lawrence Tabak—director and principal deputy director of the U.S. National Institutes of Health, respectively—noted in Nature last year, “[a] growing chorus of concern, from scientists and laypeople, contends that the complex system for ensuring the reproducibility of biomedical research is failing . . . Factors include poor training of researchers in experimental design; increased emphasis on making provocative statements rather than presenting technical details; and publications that do not report basic elements of experimental design.” Initiatives and studies drawing attention to or suggesting fixes for flawed or unreproducible scientific research have increased and have increasingly captured media attention. In August 2015, Brian Nosek, who runs the Center for 14
Open Science at the University of Virginia, released the initial results of a massive expert crowdsourcing project to try and replicate the results of 98 papers from three top psychology journals. They ended up conducting 100 experiments. While 97 percent of the original studies reported statistically significant results, only 36 percent of the replicated studies did; more problematic, effect sizes—the measure of the strength of the findings—were halved. The shocking results were widely covered. Controversy in the pharmaceutical world has also drawn increasing attention to misleading results and the need for data transparency. The fear that flawed studies have hurt patients through the prescription of unsafe drugs has been heightened by controversies over antidepressants driving suicidal thoughts in teens—and the recent revelations from newly uncovered data that such problems were identifiable and might have been avoided. The intertwining of all those elements—statistical analysis and data transparency—within collaborative ventures like Nosek’s Reproducibility Project may well be undermining our naïve faith in peer-reviewed research, but the upside is a brave new critical world. The benefit of realizing that scientific research is hard and that much of what we read in the press—at least with respect to health—may not be valid is that science is being renewed and fundamental problems are being tackled. As for BPA, the final round of government-funded BPA research will not be completed and analyzed for another two years. Asking hard questions about the design and interpretation of the studies that have driven this 18-year research controversy is vital—and not just to ensure the integrity of scientific research or even to ensure that our money, as taxpayers, has not been squandered on nonsense. We need to prioritize environmental chemical risks by focusing on those that are likely to be real rather than those stuck in the nether statistical world of the hypothetical. The endless media clamor—the unthinking, unquestioning, uninformed reporting of new studies with alarming findings—is leading to BPA being replaced. The public has been told so often that BPA is dangerous that it seems almost impossible to explain why it looks otherwise. But how do we know we are not about to trade something that’s safe for something—or many different things—that are less safe? We don’t know. That is why we need statistics.
Trevor Butterworth is director of Sense About Science USA (www.senseaboutscienceusa.org.)
SENSE ABOUT STATISTICS, DATA TRANSPARENCY
In 1904, the legendary newspaper publisher Joseph Pulitzer wrote the following in the North American Review: “You want statistics to tell you the truth. You can find truth there if you know how to get at it, and romance, human interest, humor and fascinating revelations as well. The journalist must know how to find all of these things—truth, of course, first.” Undoubtedly, Pulitzer would have been astonished by the complexity of today’s statistics— he was, after all, writing before statistics would transform scientific research through the work of Sir Ronald Alymer Fisher in the 1920s. Nevertheless, Pulitzer’s belief that journalism should aspire toward the rigor of scientific inquiry leads us to a problem: To find the truth in statistics today would require a journalist to be a statistician or a statistician a journalist; yet the probability of combining both sets of skills in a newsroom is unlikely. Which is why Sense About Science USA (SAS) has devised a solution in its project with the American Statistical Association to improve statistical literacy: STATS. The organization launched an advisory board of statisticians around the United States who have volunteered to help journalists “find the truth” in statistics before they write their story on the latest study. At the time of writing, SAS has fielded more than 50 requests. SAS USA is also running the AllTrials campaign in the United States. AllTrials calls for all trials to be registered and all results reported. Why? Because you can’t do good statistical analysis if half the data is missing—and it has been estimated that, historically, about half of all the clinical trials that have been conducted have never been published. Of course, it isn’t just about good statistics: patients and doctors need the best evidence possible for the effectiveness of treatments, and people who volunteer for clinical trials—people who give their data for the improvement of medicine—should see that data published. Worldwide, the AllTrials campaign has been endorsed by more than 600 patient groups, professional societies, and institutions, and it has led to European law mandating the registration and reporting of results from new drug studies.
WHAT’S REALLY CLOGGING UP THE LANDFILLS? [ Hint: It’s not bottled water containers. ] By Jill Culora
On social media and in the blogosphere, reports continue to errantly perpetuate the idea that bottled water packaging is clogging up U.S. landfills; the posted articles are too numerous to count. Such stories are fueled by campaigns of misinformation organized by anticorporation adversaries. Here’s one example of a recent tweet shared with the online masses: “In 2005, 2 million tons of plastic water bottles ended up clogging landfills instead of getting recycled.” Well, when you say it that way, it does sound bad. But is it true?
Numbers Under Review IBWA decided to put bottled water packaging to the test. We compared our
16 • BWR • WWW.BOTTLEDWATER.ORG
packaging, side-by-side, against the other most common types of beverage container packaging: PET for carbonated beverages, aluminum cans, glass bottles, cardboard cartons, foil pouches, aseptic boxes, and HDPE jugs and reusable containers. First, we examined the “tons” of mismanaged packaging—i.e., the containers that go into landfills instead of being recycled. According to the most current data from the Container Recycling Institute’s (CRI) signature analysis of beverage container sales and recycling rates, Bottled Up (2000-2010): Beverage Container Recycling Stagnates, 9.315 million tons of beverage container packaging was “wasted”—i.e., ended up in landfills—in 2010. But within that
number, PET containers for bottled water, with an average weight of 9.89 grams, make up only 0.308 million tons. PET for carbonated drinks packaging weigh considerably more (23.9 grams) due to the need to use heavier plastic for carbonation—and thus totaled 1.239 million tons. (In October 2015, Beverage Marketing Corporation published data showing that between 2000-2014 the average weight of a 16.9 ounce singleserve PET plastic water bottle declined 51 percent to 9.25 grams. For more, read “Water Bottles: Recycled Content Up, Weight Down” on page 20.) Take a look at the entire picture (on page 19), and you’ll see that bottled
We suspect the “2 million tons” figure tweeted out by our adversary evolved when the source miscalculated. They seem to have erroneously combined the number of soda and water containers, then used the soda gram weight (23.9 grams) instead of water (9.89 grams) to arrive at 2 million tons—and then attributed that number solely to bottled water.
Facts on Environmental Factors Bottled water’s adversaries also commonly misrepresent environmental facts when they want to disparage bottled water products. In one often-seen example, they cite energy use and greenhouse gas emissions numbers, comparing bottled water packaging to oil use and car emissions. Again, we researched the facts to compare bottled water’s PET containers against the previously identified seven most common drink packages. The quest was to determine
Bottled water professionals must ensure factual and researched information is available to consumers, so they can make informed choices about their packaged beverage products. the environmental impacts of each packaging type. Using the CRI report, we discovered that PET plastic for bottled water containers has the smallest footprint when you consider energy used to make the container, greenhouse gas emissions, and recyclability rate. While foil pouches and aseptic boxes use slightly less energy to make, both of those packaging types are not easy to recycle—and in some locations they are impossible to recycle, sending nearly all of these post-consumer drink packages to the landfill. Thus, the chart on pages 18-19 makes a very slight “environmentally unfriendly” adjustment for foil pouches and aseptic boxes.
water containers make up just 3.3 percent of all beverage containers that end up in landfills. The waste percentage numbers are much higher for the glass, aluminum, and soda bottles that end up in landfills.
Call to Action Adversaries of bottled water do not hesitate to push out information that is incorrect and misleading. IBWA has always held to a higher standard, and we hope that you will help us spread the truth about bottled water’s recyclability and environmental impact. Please share this data and the corresponding infographic on the next page with your customers, legislators, and the media. If we are to make a difference, if we are to enlighten the public, we need to work together as a team. Bottled water professionals must ensure factual and researched information is available to consumers, so they can make informed choices about their packaged beverage products.
NOV/DEC 2015 • BWR • 17
Re-think Your Drink Packaging Did you know almost 70% of what people drink these days comes in a package?
Common containers: Nalgene, juice, milk & water jugs.
Nearly all drink containers are easily recyclable, yet 10 million tons were not recycled last year. And despite what some people hear about bottled water containers filling up landfills, PET bottled water containers make up only a small percent of all drink packaging that isn’t recycled. Here’s a look at the environmental impact of the eight most common drink packages.
The 8 most common DR IN K Aluminum Can
Common drinks: soda, beer and juice.
(in order of overall environmental impact, from most to least*)
Drink containers: soda, beer & wine bottles. 2225
PET Plastic (carbonated drinks)
Same as bottled water but weighs more due to strength demands of carbonation.
Gable Top Carton A layer of cardboard sandwiched between two very thin layers of plastic.
70.9% 252.8 g
and ALWAYS Recycle! Drink Packaging in U.S. Landfills (in tons as a % of all packaged beverages)
Sources: Container Recycling Institute, 2013; Beverage Marketing Corporation, 2011; and National Association for PET Container Resources, 2011
Least environmental impact!
Made from multiple laminated layers: plastic, paper & foil.
Multiple layers of different types of plastics and aluminum all laminated together.
Stands for “polyethylene terephthalate” - a form of polyester.
PET Plastic (bottled water)
Legend BTUs / container - BTUs are British Thermal Units, a unit for measuring energy use. Figures show how many BTUs are used to make one container – averaged from all sizes within container type. Metric Tons of CO 2 equivalent /1,000,000 containers - The amount of greenhouse gases emitted by producing 1,000,000 containers. Percentage of packaging “landfilled” instead of recycled. Not all beverage packaging is recyclable. Packaging weight in grams (average weight for a single serve container.)
Sources: U.S. Department of Agriculture (Food Surveys Research Group), Container Recycling Institute, PET Resin Association, Beverage Marketing Corporation, National Association for PET Container Resources, International Bottled Water Association, Planet Ark, waste360.com, Recycle USA Inc., and the Glass Packaging Institute * Using 2010 data
WATER BOTTLES: RECYCLED CONTENT UP,
WEIGHT DOWN By John G. Rodwan, Jr.
As the rare beverage category that uses a package type as part of its name, bottled water has a story very much about bottles, and that story has changed significantly during the last decade or so. The number of bottles sold in the United States each year continues to grow. In 2014, more than 59 billion bottles of water were sold, up from about 42 billion five years earlier, and nearly 97 percent of those bottles were made of plastic. Yet each year, those bottles are made of less and less material, and more and more of that material consists of recycled content. The percentage of bottled water packages containing recycled polyethylene terephthalate (rPET) moved from the low single-digits to more than one-fifth in just a few years. In 2008, 3.3 percent of bottled water packages contained rPET. By 2014, that figure had reached 20.8 percent.
USAGE OF rPET INCREASING IN BOTTLED WATER PACKAGING 25% 20.8%
% OF PACKAGE CONTAINING rPET Source: Beverage Marketing Corporation NOV/DEC 2015
BOTTLED WATER CONTAINER FACTS
All bottled water containers are 100-percent recyclable. Of all the plastics produced in the United States, PET plastic bottled water packaging makes up only 0.92 percent, less than 1 percent. Moreover, data derived from U.S. Environmental Protection Agency figures demonstrates that plastic water bottles make up less than one-third of 1 percent of the U.S. waste stream. Plastic 3- and 5-gallon bottled water containers are reused between 30-50 times before being recycled, and the bottled water industry continues to support strong community recycling programs.
The overall amount of rPET used in bottled water packages also increased during that timeframe, from 0.2 percent in 2008 to 4.1 percent in 2014. For companies that use rPET, the average rPET content is 20 percent per container. Certain companies used even greater quantities of recycled plastic. For example, Nestlé Waters North America (NWNA) in 2009 introduced Resource, a brand with a bottle made with 50 percent rPET. It subsequently upped the amount of recycled material to 100 percent (excluding the cap). Is use of all this recycled content important? The National Association for PET Container Resources (NAPCOR) has noted that producing new products from rPET uses two-thirds less energy than what is required to make products
from raw virgin materials. It also reduces greenhouse gas emissions.
Less Is More At the same time, the industry has moved assertively to lightweight its bottles. Today’s single-serve containers weigh far less than their predecessors, which results in appreciable reductions of waste. Beverage Marketing Corporation (BMC) has analyzed the weight reduction of 16.9 ounce (half-liter) single-serve PET bottles and found that between 2000 to 2014 the weight of those bottles dropped by 51 percent: from 18.9 grams to 9.25 grams. Weight reductions occurred every year during that 14-year period. In addition, the number of pounds saved has swelled considerably since
AVERAGE rPET CONTENT IN BOTTLED WATER CONTAINERS INCREASES 5% 4.1%
WEIGHTED AVG rPET CONTENT % PER BOTTLE FOR ALL BOTTLES Source: Beverage Marketing Corporation
BMC predicts that bottled water will become the largest beverage category, by volume, in the United States by the
end of the decade. Thus, the benefit of industry efforts to reduce its environmental impact is obvious. According to IBWA Vice President of Communications Chris Hogan, “From an environmental standpoint, when people choose bottled water instead of any other canned or bottled beverage, they are choosing less packaging, less energy consumption, and less use of natural resources. What’s more, recycling the bottle can cut that impact by an additional 50 percent, if it is re-used to replace virgin PET plastic.”
the turn of the century. In 2001, the shaving of grams off PET bottles resulted in the equivalent of 6.9 million pounds of plastic saved. In 2014, almost 1.1 billion pounds of plastic were saved as a result of lightweighting. In total, nearly 6.2 billion pounds were saved during this 14-year period as a consequence of the industry effort to lower the weight of its packages. Packages like NWNA’s Eco-Shape, PepsiCo’s Eco-Fina, and comparable ones from other companies have all been a part of this ongoing process to make the bottled water industry’s story an environmentally friendly one.
John G. Rodwan, Jr., is editorial director at Beverage Marketing Corporation, a New York-based research, consulting, and financial services firm dedicated to the global beverage industry. Beverage Marketing publishes numerous market reports on bottled water and other beverages.
Enlighten Elected Officials: Invite Them to Tour Your Plant How to host a plant tour in 10 easy steps By Kristin Pearson Wilcox, IBWA Vice President of Government Relations
If the bottled water industry is going to sustain its current success, it’s critical that IBWA members regularly visit with legislators—both in-state and on Capitol Hill—to educate them about our businesses. Such meetings provide a great opportunity for relaxed conversations with members of Congress about industry issues and the pros and cons of bottled water regulations. But there’s another, perhaps even more helpful, way to illustrate all it takes to run a bottled water business: invite elected officials to tour your plant. Plant tours reinforce our industry messages and personalize the bottled water story—and offer a unique way to connect with lawmakers. When 24
members of Congress tour your plant, they get a firsthand look into how the bottled water business works and how your company has a positive effect on your community. A tour gives elected officials the chance to interact with employees—which is important because that way legislators can observe for themselves how your company, located in their district, helps improve the lives of their constituents—providing water, jobs, and economic growth. If you are interested in hosting a plant tour but don’t know where to begin, IBWA can help. Provided below is a handy step-by-step guide on how to organize a successful plant tour.
Step 1: Establish a relationship with members of Congress who represent the districts of your company plants, headquarters, or distribution facilities. While time and travel costs are involved in this effort, building a relationship with your elected officials is easier than you think. Legislators love to hear from their constituents. Step 2: Email a letter of invitation to your member of Congress. Members of Congress receive a lot of event invitations, so you’ll need to make sure to submit your request as soon as possible if you have a particular date in mind for your tour. (Provided at right is a sample invitation email.) When you
GOVERNMENT RELATIONS email your invitation, be sure to copy IBWA Vice President of Government Relations Kristin Pearson Wilcox (email@example.com) so that IBWA is aware of your plans and can schedule time to assist, if needed. Step 3: Follow up. A day or two after you send your email invitation, call the elected official’s Washington, DC, office and ask to speak to the scheduler. If your elected representatives cannot attend, and your tour date is not flexible, invite his or her chief of staff or district director to attend the plant tour. (If your tour date is flexible, ask the scheduler what date would suit the congressman/congresswoman.) If you don’t know your legislator’s office phone number, contact the U.S. Capitol switchboard at 202.224.3121. A switchboard operator will connect you directly with the office you request. Step 4: Set the date and inform IBWA and your employees. Once the scheduler has confirmed the day and time of your plant tour, notify IBWA (firstname.lastname@example.org) of that date and let us know if you require any additional information, such as issue briefs. Let your employees know their elected representative will be visiting. You may want to invite key employees to help lead the tour. Make sure your tour guide is informed about all operational procedures and is comfortable speaking in front of a small group. Step 5: Coordinate the logistics. Prepare an event schedule, including the legislator’s arrival and departure times, plant tour details (start and end times), and, if possible, opportunity for the elected official to speak with employees. Arrange for a photographer to take photos of the legislator during the tour, and use those photos on your social media platforms and provide them to your local news outlets. Step 6: Prepare a press release (optional). Having an elected official visit your plant is a great opportunity to
SAMPLE PLANT TOUR INVITATION [DATE] The Honorable [NAME] U.S. House of Representatives/U.S. Senate [ADDRESS] Washington, DC 20515 Dear Representative/Senator [LAST NAME]: I am writing to invite you to tour [COMPANY] located in [CITY]. As members of the bottled water industry, we provide one of the healthiest and most environmentally sustainable products Americans can consume to live a wholesome lifestyle and maintain manufacturing jobs here in [STATE]. [COMPANY] would be honored if you would join us for a plant tour and discussion of the issues affecting our industry here in [STATE]. We would like to invite you to join us from [TIME, e.g. 8:00 a.m.-9:30 a.m.] on [DATE], but we are flexible if there is another time that works better for your schedule. We would give you a tour of our facility and provide time for you to meet some of our employees. I will follow up this request with your office or you may reach me at [PHONE/EMAIL]. Thank you for your attention, and we hope to see you here soon. Sincerely, [YOUR NAME] [TITLE] [COMPANY] cc: email@example.com
SAMPLE PRESS RELEASE For Release: [DATE] Contact: [YOUR NAME, TITLE, PHONE NUMBER]
[COMPANY NAME] Welcomes Senator/Representative [NAME], Urges Support of Local Manufacturing Jobs [CITY, ST.] Today, [COMPANY] welcomed our local congressional representative, [REP./SEN. NAME] for a tour of our facility and a discussion of the issues affecting our company and our community’s workers. [COMPANY] is committed to civic involvement. Too often, politicians in Washington make decisions that affect employees and employers in our community without a real understanding of the impact those decisions will have here at home. [COMPANY] expressed to [REP./SEN. NAME] the importance of balanced health and environmental policies that include creating opportunities for consumers to live a healthy lifestyle through the consumption of water (in all forms) and promoting sustainability polices that protect the environment and job growth in our community. [COMPANY] is committed to making a difference for our community through our involvement in the democratic process, and we appreciate [REP./SEN. NAME] taking the time to hear our concerns about the challenges our industry has faced during [IDENTIFIED EVENT]. [INSERT COMPANY DESCRIPTION HERE]
Polymer Solutions International, Inc.
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GOVERNMENT RELATIONS show off your company. Ask the scheduler if it’s okay for you to submit a press release to your local paper. If so, the scheduler may also provide the names of his or her local media contacts, so you can send them the press release as well. (A sample press release is provided at left.) Step 7: Day before your plant tour, review logistics. Get with your employees to confirm plans with the elected officials’ scheduler. Review the IBWA priority issue talking points (which you would have received when you let IBWA know about your scheduled tour). Think about the issue most affecting your business and how you can best explain it. Gather data about
your company to share with the elected official (e.g., number of employees, revenues/impact on local economy, unique or innovative onsite programs for employees, new production techniques, etc.). Don’t forget to take a moment to review your legislator’s biography—you may discover points of common interest to discuss along the tour. Step 8: Day of plant tour, speak up! Tell your elected representative how your business is doing and what you find to be your greatest challenges. Step 9: Day after plant tour, follow up. Send thank you letters to the elected official and others who participated. (See sample letter below.) If you take photos during the tour, please
email them to IBWA. We’d love to feature your photos in IBWA publications. Step 10: Keep in touch. Hosting a plant tour for a member of Congress is just the beginning of what can be a valuable and productive relationship. Maintain that relationship by communicating with him or her several times throughout the year. By staying in constant contact, you help to ensure that your legislator is up-to-date on important bottled water industry issues. For assistance with setting up and conducting a plant tour, contact IBWA Vice President of Government Relations Kristin Pearson Wilcox: email@example.com.
SAMPLE THANK YOU LETTER [DATE] The Honorable [NAME] U.S. House of Representatives Washington, DC 20515/20510 Dear Representative [NAME]: Thank you [AND STAFF NAME, IF APPROPRIATE] for visiting our plant on [DATE]. We were honored that you took the time to visit with us, and we hope it was as enjoyable for you as it was for all of us here at [COMPANY]. As we discussed, bottled water is on track to be the No. 1 packaged beverage by the end of the decade. The average person in the United States now consumes more than 35 gallons of bottled water per year, according to data from market research firm Beverage Marketing Corporation. That’s about 270 single-serve bottles—and more than twice as much as what people drank 15 years ago. And that number is only going to go up: By 2017, the average American is expected to drink almost 300 bottles annually. We encourage your support for health and environmental policies that allow Americans to have access to water in all forms and enable us to continue manufacturing here in [CITY, ST.]. [Add brief comment about impact of issue(s) to your company.] We appreciate your support, and we will stay in touch as relevant legislation progresses in Congress. We hope to see you again soon. Sincerely, [NAME] [COMPANY] cc: firstname.lastname@example.org
How to Kill a Negative Bottled Water Story Just introduce facts and figures By Chris Hogan, IBWA Vice President of Communications, and Sabrina Hicks, IBWA Publications Manager 28
In the movie Gone Girl, there’s a scene in which the protagonist (Ben Affleck), who is unjustly accused of killing his wife, is advised by his shrewd lawyer (Tyler Perry) about the need to “realign the public’s vision” to ensure his version of the story—the truth—is heard. For whatever reason, humans gravitate toward sensationalized stories (as newspapers have known for decades). Add social media to the broadcast mix, and you’ll find any story that grabs the public’s attention is harder to squash. Those of us in the bottled water industry are particularly familiar with how an untrue story can sprout legs and run wild, especially on Web platforms. It becomes our task to nullify those inaccurate and misleading stories, to ensure that consumers have access to the truth about the bottled water industry and our products. In 2015, we’ve seen media outlets publish an abundance of stories that attempt to damage people’s perception of bottled water: misleading journalism suggesting the bottling water industry is a major contributor to the California drought, false articles implying that bottled water containers are the main component of ocean waste, and erroneous narratives attempting to justify bans on the sale of bottled water. Our adversaries like to conveniently use bottled water as the scapegoat, regardless of facts. Fortunately for us, when we set about realigning the vision of bottled water for anyone who might be taken in by those misleading stories, the facts are on our side.
Doubt Within the Drought Take, for example, the California drought. Contrary to some media reports, bottled water has little to no effect on the state’s groundwater levels, according to the U.S. Geological Survey. In fact, the bottled water industry accounts for only 0.02 percent of all
COMMUNICATIONS water used in California. To put that in context, municipal water use figures from the Los Angeles Department of Water and Power show that Los Angeles uses in three weeks the amount of water the bottled water industry in California uses in one year. If you compared our water use numbers with those from other industries, you’d find that bottled water companies use a very small amount of water. According to research conducted by the Antea Group, bottled water has the lowest water (and energy) use of all packaged beverages. Perhaps Felicia Marcus, chair of California’s State Water Resources Control Board best explained it to the Sacramento Bee, for a May 16, 2015 article: “. . . to pick on bottled water vs. soda, which may take more water, or beer would be a good example, it may take less water to do bottled water because the processing is different. So picking on particular economic uses is something that’s a little perilous.” Like the majority of California businesses, bottled water companies are dedicated to responsibly protecting and preserving the state’s vital water resources. Sustainable water sources are the single most important aspect of our business. So, even before the state’s “Sustainable Groundwater Management Act of 2014,” bottled water companies were making water conservation a priority by implementing a variety of water conservation strategies.
561,895 volunteers who participated in the 2014 International Coastal Cleanup picked up 16,186,759 pounds of trash from 13,360 miles of beaches worldwide. The items they gathered, items that otherwise may have ended up in the sea, included cigarette butts (2,248,065), food wrappers (1,376,133), plastic bottles—of all beverage types (988,965), plastic bags—grocery and other (489,968 + 485,204 = 975,172), straws/stirrers (519,911), glass beverage bottles (396,121), beverage cans (382,608), and plastic cups and plates (376,479). But research by José G.B. Derraik published in the Marine Pollution Bulletin reminds us that waste from ships is also to blame for the poor state of our marine life. Rubbish thrown from ships includes plastic fishing gear,
synthetic packaging material, and nonbeverage plastic containers. Although the International Convention for the Prevention of Pollution from Ships (MARPOL) was recently amended to restrict the discharge of garbage and plastics from ships, we still observe ship waste contributing to, for example, the Great Pacific Garbage Patch. One way to help decrease the waste found in our oceans is to implement recycling programs that encourage participation. While bottled water continues to be the No. 1 item in curbside recycling, we, and other industries, need to find ways to do more. We need more recycling—but studies show that the best way to increase recycling is to implement programs that prove to participants they are making a difference.
A Gyre of Misinformation A disparaging story that seems resistant to the facts is one that promotes the faulty notion that the waste polluting the world’s oceans is mainly bottled water containers. That is unequivocally not true. In fact, according to the Ocean Conservancy’s “2015 Report: Turning the Tide on Trash” (bit.ly/2015TideTrash),
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INFLUENCE WITH IMAGES A picture is worth a thousand words—and IBWA has a great selection of Web posters to help you tell bottled water’s story. Visit IBWA’s “Image Library” (www.bottledwater. org/bottled-water-visuals), and post the image that best communicates the story you’d like to tell your social media friends and followers.
Monumental Misleading Reports Our national parks provide an example of how recycling practices can improve. Many stories have been printed about the National Park Service’s (NPS) recent stated attempts to reduce plastic in its waste stream. To achieve its vision, the NPS implemented a policy that allows individual parks to ban the sale of bottled water—but consumers are free to buy other less-healthy drinks (soft drinks, sports drinks, juice drinks, and other sugary packaged beverages) that are also packaged in plastic. Unfortunately for the NPS, zero evidence exists to confirm that any waste has been reduced since it implemented the policy. In fact, the NPS’s sustainable practices database is not tracking the impact of the ban. According to a park official, “[F]or those parks that have discontinued the sale of plastic water bottles, they do not report separately on their recycling quantities based on type, e.g. plastic, glass, aluminum, paper etc. As a result they do not have the data available to conduct any post-ban analysis.” That is a concerning admission and contrary to the mandates of the NPS policy directive that permits parks to ban bottled water. Fortunately for the bottled water industry, when countering reports on the NPS ban, we have logic and research on our side. “ The Unintended Consequences of Changes in Beverage Options and the Removal of Bottled Water on a University Campus,” a study published in May 2015 in the American Journal of Public Health (bit. ly/UVMstudyBW), concludes that sales bans such as the one implemented by NPS, have unintended negative consequences. According to the study, a similar ban on the sale of bottled water at the University of Vermont (UVM) resulted in a significant increase (33 percent) in
the consumption of sugary drinks and an increase (6 percent) in the amount of plastic bottles entering the campus waste stream.
Truth in Numbers Even with the abundance of false and misleading articles published about bottled water, consumer demand for our products is strong. Reflecting a clear trend of consumers increasingly choosing healthy, convenient, zerocalorie bottled water, bottled water has increased its share of stomach in the overall beverage market from 14.4 percent in 2009 to 17.8 percent in 2014, according to the Beverage Marketing Corporation (BMC). Carbonated soft drinks currently hold the No. 1 position (with 20.9 percent), but BMC predicts that if current trends persist bottled water will be the largest beverage category, by volume, in the United States by the end of the decade. The bottled water industry has a great—and important—story to tell, but IBWA cannot be the sole spokesperson. We need all members to follow our lead: share these significant facts, figures, studies, and data with friends, family, local media, legislators, and even those who may disagree with our positions. If we are to make a difference in “realigning the public’s vision,” pushing out the truth has to be a team effort.
FSMA’s Long-awaited Final Rule on Preventive Controls Published By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations
On September 17, 2015, the U.S. Food and Drug Administration (FDA) published the final rule for Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive 32
Controls for Human Food (i.e., the “Preventive Controls Rule”). The longawaited rule, which was first published as a proposed rule on January 16, 2013, will be the most impactful of the
seven primary Food Safety Modernization Act (FSMA) rules for bottled water, and it is the first of those rules to be finalized. Below is an overview of the final rule and an explanation of compliance dates by business type. The two principle areas of the final rule that will impact bottled water are the following: 1. The rule presents new requirements for domestic and foreign facilities registered with FDA as food facilities to establish and implement hazard analysis and risk-based preventive controls for human food. This, of course, includes bottled water facilities. This portion of the rule requires those registered food facilities to maintain a food safety plan, perform a hazard analysis, and institute preventive controls for the mitigation of those hazards, unless an exemption applies. Facilities must also monitor their controls, conduct verification activities to ensure the controls are effective, take appropriate corrective actions, and maintain records documenting those actions. The requirements of the final rule, for the most part, follow the principles of a hazard analysis critical control point (HACCP) program. 2. This rule also modernizes FDA’s long-standing current good manufacturing practice (CGMP) regulations regarding the manufacturing, processing, packing, or holding of human food. FDA has updated, revised, and otherwise clarified certain requirements within the CGMP regulations, which were last updated in 1986. The final rule implements the requirements of the original FSMA legislation for covered facilities to establish and implement a food safety system that includes a hazard analysis and risk-based preventive controls. Specifically, the rule establishes requirements for the following:
TECHNICAL UPDATE a written food safety plan hazard analysis • preventive controls • monitoring • corrective actions and corrections • verification • supply-chain program • recall plan • associated records. The last three items in the list above are new to bottlers who have, since 2002, developed and maintained a HACCP program at their bottling facilities. FDA will now require assurance through written supplier programs that food additives and contact materials are safe by requiring that bottlers consider any hazards associated with those materials. Recall plans, which have long been a requirement by FDA and IBWA’s Bottled Water Code of Practice, are now to be integral parts of every facility’s food safety plan. Finally, FDA published new requirements for recordkeeping and records access in the “Bioterrorism Act of 2002.” FSMA now integrates and extends those requirements under the Preventive Controls Rule. • •
Bottler Compliance Although the effective date of the final rule is November 17, 2015, that is not when bottlers have to be in full compliance. Compliance dates are as follows: • Very small businesses: September 17, 2018 • Small businesses: September 18, 2017 • All other businesses: September 19, 2016. Are you a very small business? A small business? A qualified facility? None of the above? FDA defines each of these in the final rule. A “very small business” is defined in the rule as a business (including any subsidiaries and affiliates) averaging less than $1,000,000, adjusted for inflation, per year, during the three-year period
preceding the applicable calendar year in sales of human food plus the market value of human food manufactured, processed, packed, or held without sale (e.g., held for a fee). Very small businesses do not qualify for any exemptions from any part of the Preventive Controls Rule, and they must be in full compliance with the rule by September 17, 2018. For compliance purposes, FDA defines “small business” as a business, including subsidiaries, with fewer than 500 employees. Each employee must work at least 2,080 hours per year, or be “full-time equivalent.” Small businesses do not qualify for any exemptions from any part of the Preventive Controls Rule and must be in full compliance with the rule by September 18, 2017. A “qualified facility” is defined by FSMA as a business with average annual sales of <$500,000 and at least half the sales directly to consumers or local retailers or restaurants (within the same state or within 275 miles). A qualified facility is exempt from the provisions of the hazard analysis and preventive controls portions of the final rule if they meet the criteria listed in this article. However, those qualified facilities will not be exempt from the revised CGMPs portion of the final rule. Of course, qualified facilities may voluntarily comply with the entire final rule, including the preventive controls provisions. Also, FDA has established in the final rule a procedure for withdrawal of that exemption should your product become involved in a contamination incident and/or recall, at which time full compliance would again be required.
Exempted Facilities Some very small members of IBWA, particularly some home and office delivery (HOD) companies that deliver directly to consumers, may qualify for this qualified facility exemption.
However, the exemption comes with some conditions, which FDA calls “modified requirements.” If a facility qualifies for the exemption, it must notify FDA about its status, and either (1) notify FDA that it is addressing hazards through preventive controls and monitoring or (2) notify FDA that it complies with applicable non-Federal food safety regulations, and notify consumers of the name and complete business address of the facility where the food was manufactured or processed. The company must present to FDA or its state equivalent inspectors upon request financial evidence to support the company’s exemption qualification during an on-site inspection, or at any other time requested. The FDA qualified facility exemption notification is in the form of an attestation, and it must be submitted every two years, at the same time the facility is required to update its facility registration. The next facility registration period is scheduled for late-2016. IBWA is exploring the possibility of facilitating members to use the IBWA annual inspection program and compliance with the association’s Bottled Water Code of Practice (i.e., a “non-Federal food safety regulation”) to satisfy the requirements of the qualified facility exemptions described above. Compliance with state regulations may also qualify. All other businesses that do not meet the definitions of “qualified facility,” “small business,” or “very small business” must be in compliance with the rule by September 19, 2016.
Preparations IBWA is here to assist member bottlers with implementing the Preventive Control Rules in their facilities. In addition to this article, members can read FSMA updates in the weekly News Splash e-newsletter and in future editions of Bottled Water Reporter. NOV/DEC 2015
certified plant operators (CPOs) are encouraged to complete the following quiz for ½ IBWA continuing education unit (CEU). The questions are derived from material presented in this issue of the Bottled Water Reporter, the IBWA Plant Technical Reference Manual, and the IBWA Bottled Water Code of Practice. Submit this quiz to Claire Crane, IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314. Look for additional quizzes in future issues and earn additional IBWA CEUs! Name______________________________________________________
ZIP/Postal Code_ ___________________________________________
Check your selection for each question
The FSMA Preventive Controls Rule updates a longtime plant standard known as _____.
OO OO OO OO
standard operating procedures current good manufacturing practices health and safety programs employee policies
Prior to implementing a food safety plan, each facility will be required to conduct a _____.
OO OO OO OO
hazard analysis source site evaluation comprehensive audit enforcement inspection
One method of verifying that preventive controls are working as planned is _____.
OO OO OO OO
auditing product testing monitoring recall
FSMA recordkeeping requirements were first promulgated from _____.
OO OO OO OO
Federal Food Drug and Cosmetic Act Safe Drinking Water Act Bottled Water Ground Water Rule Bioterrorism Act of 2002
A bottled water company with fewer than 500 employees is defined by FDA as _____.
OO OO OO OO
large business very small business small business corporation
A “qualified facility” is a facility that is exempt from _____.
OO complying from FDA and state food safety regulations OO hiring qualified employees OO paying FDA user fees OO the hazard analysis and preventive controls portion of the final Preventive Controls Rule
The food safety plan at each facility must be reviewed _____.
OO whenever significant changes are made to processes and equipment OO every time a new employee is hired OO every 3 years at a minimum OO whenever significant changes are made to processes and equipment and every 3 years at a minimum
A qualified facility exemption can be withdrawn by FDA.
OO True OO False
Very small bottling facilities must comply with the Preventive Controls Rule by _____.
OO OO OO OO
September 17, 2018 September 19, 2016 September 18, 2017 October 31, 2021
If a bottler chooses to take the “qualified facility” exemption, it must notify _____.
OO OO OO OO
FBI DHS FDA EPA
ADVERTISERS Analytical Technology Inc. . . . . . www.analyticaltechnology.com . . . . . . . . . . . . 3 Blackhawk Molding Co.. . . . . . . blackhawkmolding.com . . . . Inside Front Cover
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Crystal Mountain Products . . . . www.crystalcoolers.com . . . . . . . . . . . . . . . . 5 Drink Up. . . . . . . . . . . . . . . . . . . youarewhatyoudrink.org . . . . . . . . . . . . . . . . 31 Edge Analytical. . . . . . . . . . . . . . www.edgeanalytical.com . . . . . . . . . . . . . . . 25 Mountain Valley Spring Water. . . email@example.com . . . . . . . . . 7
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Now Available Online: FSMA Preventive Controls Webinar On October 9, 2015, IBWA and Hogan Lovells presented a webinar on the Food Safety Modernization Act’s (FSMA) final Preventive Controls Rule and its impact on the bottled water industry. The webinar provided important information about the following key regulatory provisions: • U.S. Food and Drug Administration’s (FDA) revised current good manufacturing requirements (CGMPs) • new requirements for hazard analysis and preventive controls • recordkeeping • ancillary requirements such as environmental monitoring
impact on IBWA’s annual inspection program. The webinar slides and audio recording can be found on the “Members’ Only” side of the IBWA website (www. bottledwater.org), under the “Education” tab. Certified plant operators (CPOs) who view the entire webinar recording are eligible for 1.5 IBWA CEUs. If you have any questions, please contact IBWA Vice President of Education, Science, and Technical Relations Bob Hirst (email@example.com) or Program Coordinator Claire Crane (ccrane@ bottledwater.org).
CoffeeTea&Water Show) Gaylord Resort and Convention Center National Harbor, MD
MARCH 16 - 18
Central States Bottled Water Association 8th Annual Convention and Trade Show St. Louis, MO
JUNE 6 - 9
IBWA June Board of Directors and Committee Meetings Hilton Old Town Alexandria, VA
NOVEMBER 7 - 11
IBWA Annual Business Conference and Trade Show (co-location with NAMA CoffeeTea&Water Show) Gaylord Opryland Resort and Convention Center Nashville, TN
Help IBWA Push Out Positive Bottled Water Messages Via Social Media IBWA has developed a Social Media Communications Toolkit to help promote positive stories and news items about the bottled water industry. In the toolkit, you’ll find Facebook posts, Instagram images, Pinterest pins, and Twitter tweets (with URLs to YouTube videos) you can share with your customers, legislators, friends, and family to educate them about bottled water. (Or use them as inspiration and write your own!) When more IBWA member companies push out this content, the more IBWA’s pro-bottled water messages will be amplified. If you are an IBWA member and you’d like to receive the toolkit via email, let us know: IBWASocialMedia@ bottledwater.org. If IBWA members and bottled water professionals don’t spread the positive messages about bottled water, who will? NOV/DEC 2015
VALUE OF IBWA MEMBERSHIP BOB RIEFERS GENERAL MANAGER & CO-OWNER MAUMEE VALLEY BOTTLERS, INC. NAPOLEON | OHIO ALL ABOUT BOB When not working, Bob likes to spend time with his family at their Lake Erie cottage. He has a degree in Forestry—and a hobby logging company: Riefers Logging LLC. Bob sits on several IBWA committees, is a board member of the Central States Bottled Water Association, and served as president of the Culligan Dealers of North America, TriState Chapter, in 2015.
When Bob Riefers and six other Culligan employees decided to form a small water bottling company, some people thought they were crazy. The year was 1988, and the fledgling business, Maumee Valley Bottlers, Inc., was a sideline gig to their regular day jobs. Fast-forward 27 years, and today the company’s five owners (four of whom are original) have a thriving business that provides 3- and 5-gallon wholesale water to 50 locations in four states from its modest facility in Napoleon, Ohio. Bob says they started the business “back before bottled water was an accepted norm, by a long shot. People said, ‘Who is going to pay for bottled water?’ But it was pretty good timing by us because we rode the wave clear to the top. Now, most people see bottled water as a necessity.” In 1998, Bob left his full-time Culligan position to take on the general manager responsibilities at the growing bottling company. Maumee Valley Bottlers have been IBWA members since the company’s beginning. According to Bob, “IBWA gave us the guidance we needed to start our business of bottling without having to reinvent the wheel. Without IBWA, it would have been much more difficult, figuring out the regulations and standards and how to implement them into the workplace. “Today, our membership gives us a competitive edge in the marketplace because of the access to training and information, coupled with the audit program. It keeps the plants running and operating within the industry and government standards. Without IBWA, we would be learning lessons the hard and expensive way.” Bob says when the U.S. Food and Drug Administration or Ohio Department of Agriculture knock on his door for an inspection, their reps are flabbergasted by the organized information Maumee Valley Bottlers has readily available thanks to the record-keeping requirements of the IBWA audit. “They are usually very impressed and the inspection is usually not an issue.” Being involved with IBWA supplier members and other member bottlers has also helped Maumee Valley Bottlers over the years. “It’s a value that translates into real dollars,” says Bob. “Being able to network and discuss issues with people in the industry gives you the peace of mind, every day, that you are doing everything right.” Maumee Valley Bottlers is currently doing a booming business, providing four types of water: spring, drinking, purified, and fluoridated. Its 2015 volumes are up by nearly 10 percent, and, last year, the company filled 1.29 million 3- and 5-gallon bottles. The business also sells bulk water by the tanker and bottled water home and office delivery supplies, including coolers, cups, and dispensers.
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