If there is parity between testing of public drinking water and bottled water, why do we hear claims like “public drinking water is tested for more contaminants than bottled water?” In most cases, it’s because the EPA follows a well-defined framework for determining occurrence, developing standards, and monitoring requirements for emerging, unregulated contaminants that include requirements for testing for these emerging contaminants in public drinking water. In fact, the Safe Drinking Water Act (SDWA) requires that the EPA conduct a review of drinking water contaminants every six years. The SDWA also includes a process that the EPA must follow to identify and list unregulated contaminants, and to determine which of those contaminants, based on occurrence and potential adverse health effects, should be regulated in the future. This article explains the rationale behind any recommendations for special testing by the IBWA Technical Committee.
Determining Contaminants to Regulate
How Does an Unregulated Contaminant Become Regulated? By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations
A list of contaminants that are currently regulated in bottled water by the U.S. Food and Drug Administration (FDA) is found in Appendix A of IBWA’s Bottled Water Code of Practice. Appendix A also includes biological and chemical contaminants required to be tested in 40
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public drinking water. Effective since 1995, the Federal Food, Drug, and Cosmetic (FD&C) Act requires that FDA review all Environmental Protection Agency (EPA) standards for public drinking water and determine if they will also be regulated in bottled water.
The EPA must periodically publish a list of emerging unregulated contaminants, known as the Contaminant Candidate List (CCL), and decide whether to regulate at least five or more contaminants on the list. The EPA also uses the CCL to prioritize research and data collection efforts to help the agency determine whether it should regulate a specific contaminant. The SDWA requires the EPA to consider three criteria when making a determination to regulate: • The contaminant may have an adverse effect on the health of persons. • The contaminant is known to occur, or there is a high chance that the contaminant will occur, in public water systems often enough and at levels of public health concern.