BOTTLED WATER REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY WATER SUPPLY DIVISION ------- 15453 BOTTLED WATER STUDY A PILOT SURVEY OF WATER BOTTLERS AND BOTTLED WATER WATER SUPPLY DIVISION ENVIRONMENTAL PROTECTION AGENCY September, 1972 ------- TABLE OF CONTENTS INTRODUCTION CONCLUSIONS AND RECOMMENDATIONS . BACKGROUND SCOPE OF PILOT SURVEY Purpose of the Survey Selection of Bottled Water Plants Survey Procedure Bottling Plant Construction, Sanitation and Operation Analytical Quality Control Sampling and Analysis FINDINGS AND DISCUSSION OF RESULTS . Bottling Facilities, Operations and Quality Control Bacteriological and Chemical Quality PARTICIPANTS APPENDICES I II III IV V VI VII 1 I 2 3 3 3 3 3 3 3 4 4 5 12 13 19 23 25 27 35 4 5 6 7 7 8 10 A. American Bottled Water Association — Good Bottling Practices Guidelines. B. State Regulations Pertaining to the Quality of Bottled Water, 1971 C. Geographical Distribution of Water Bottlers in the U.S., by State . D. Bottlers Visited E. Survey Form F. Treatment Processes, Water Sources, Products and Quantity LIST OF TABLES Laboratory Control of Bottled Water and Source Water . . Evaluation of Bottling Facilities and Procedures Results of Chemical Analyses of Bottled Water Results of Chemical Analyses of Water Sources Fluoride Determination of Bottled Water Samples Bacteriological Results After Less Than 30 Hours Storage. Effect of Storage on the Standard Plate Count of Bottled Waters ------- BOTTLED WATER STUDY INTRODUCTION Although piped water is available to at least 75 percent of the nation’s population, the production and sale of bottled water has become an established and growing industry. In some parts of the country, particularly in those areas where the only available natural water is heavily mineralized, bottled water has always been an important source of drinking water. Since the recently aroused interest in our environment, the use of bottled water has rapidly increased. Fears regarding the pollution of city water supplies, whether or not founded on fact, have caused people to distrust the quality of the product issuing from the faucet. In addition, a dissatisfaction by the public with the taste and odor of their drinking waters has influenced the increase in the use of bottled waters. Rising affluence has also had a part, since people could now afford to purchase a deluxe product, supposedly much superior to the every day waters that the city water system provided. When, in 1970, a study of Community Water Supplies was published by the Water Supply Division, Environmental Protection Agency (then the Bureau of Water Hygiene, United States Public Health Service), the bottled water industry received an unexpected (and unintentional) boost. The study revealed shortcomings and potential hazards in many community water supplies, and the immediate reaction of the public was distrust of piped water and an increase in sales of bottled water. The Water Supply Division recognized the importance of this increase in the use of bottled waters by the public and was interested in determining the quality and health surveillance being provided by the manufacturers. To determine existing conditions a small pilot survey was undertaken. CONCLUSIONS AND RECOMMENDATIONS While the pilot survey was limited in scope and represented less than five percent of the bottling firms in this country, it is evident that there are deficiencies in surveillance, facilities and their operation, and plant quality control. These deficiencies result in the production of bottled water whose quality does not comply with the 1962 U.S. Public Health Service Drinking Water Standards. While the water quality violations are not widespread, they are of sufficient significance to warrant corrective action. The pilot survey of 25 bottling establishments, and bacteriological and chemical examination of approximately 50 bottled water products revealed the following: 1. Eight percent of the bottled water samples examined evidenced the presence of the coliform organism, which is an indicator of the potential presence of pathogenic bacteria. High standard plate counts gave additional evidence of contamination. 2. Gross changes in the standard plate counts were noted in the 25 samples that were examined during a 63-day storage test. While the bacteria counts of six samples remained at or near zero for the entire test period, four rose to levels which had to be classified as “too numerous to count,” while the remainder fluctuated widely with no definite, discernable pattern. 3. While only one sample exceeded a mandatory Drinking Water Standard limit for chemicals, discrepancies were found between the actual chemical composition and that stated or implied by the label in several cases. 4. Quality control measures were generally deficient in that bacteriological and chemical analyses of the bottled water were not regularly performed. Bacteriological surveillance was judged inadequate in more than half of the firms inspected while chemical surveillance was inadequate in almost all cases. a. Only 11 of the 25 bottlers collected four or more bacteriological samples per month. Jhree bottlers did not collect any samples for bacteriological analysis, and eight others collected only one sample per month. b. None of the 25 bottlers reported ever having a complete chemical analysis of their bottled water. Only 12 bottlers reported a partial analysis for chemical constituents. Only four of these 12 reported a partial analysis more frequently than once per year. 5. Based upon criteria covering eight sanitation categories (Appendix E, Pg. 59 and 60), it was found that in many cases bottling was not performed under sanitary conditions. While deficiencies were found in all facilities surveyed, one-half of the firms failed to comply with five or more of the eight categories examined. On the basis of these findings, the following recommendations are made to the appropriate Federal and State regulatory agencies. 1 . Uniform regulations should be developed and applied to all bottling plants and products. The regulations should include minimum quality control procedures. 2. Bottling plants should be subjected to regular 1 ------- survefflance to assure compliance with the regulations. 3. The significance and control of bacterial populations during production and growth during storage, as evidence by Standard Plate Counts of wide range and cyclic behaviour, should be investigated further. In addition, the firms engaged in the bottling of water should make the following improvements in their operations: 1. Effective quality control procedures should be established and carried out. 2. Sanitation of bottling plants, facilities, and particularly plastic bottles should be improved. 3. Disinfection practices should be improved. Because there are no nationwide standards for chemical and bacteriological quality of bottled water, it is specifically recommended that: 1. The quality of all bottled water meet the mandatory chemical and biological constituent limits of the current U.S. Public Health Service Drinldng Water Standards, and 2. The level of sanitary and operational surveillance of bottling plants be raised to meet the requirements of those Standards. BACKGROUND The growth of the bottled water industry has not escaped the notice of the Federal Government. A bill was introduced in the House of Representatives, 91st Congress, that would have directed the Secretary of Health, Education, and Welfare to establish and carry out a bottled drinking water control program. This bill, with modifications required by the reorganization which placed some parts of the Public Health Service, DHEW, in the newly-created Environmental Protection Agency, was reintroduced in the 92nd Congress. This bill, if passed, would regulate only that bottled water marketed in interstate commerce, but it also contains a provision in regard to State regulations, requiring them to be at least as restrictive as the Federal standards. In addition, Safe Drinking Water Legislation, relating to public drinking water systems, under development in both the House and the Senate, would also extend the Environmental Protection Agency’s jurisdiction to include bottled water. There is some question as to the necessity for a law for the specific purpose of establishing quality standards and controls for bottled water. The Food and Drug Administration, by virtue of the Food, Drug, and Cosmetic Act, has jurisdiction over “Articles used for food and chink for man or other animals” when such products are sold in interstate commerce. This Act has been interpreted as giving the Food and Drug Administration power to establish standards of quality and to take action against purveyors of impure products. However, to date, the Food and Drug Administration has not established uniform standards of quality, nor does it have a routine program of surveillance of the bottled water industry. Drinking water used by interstate carriers is subject to Federal quarantine regulations and must conform to the 1962 U . S. Public Health Service Drinking Water Standards. However, while these Standards define limits for various chemicals and other substances, as well as standards for bacteriological quality, the opinion of the legal staff of the U.S. Public Health Service is that the Federal government can enforce only the latter criteria. The American Bottled Water Association, which represents a large proportion of the producers of bottled water, has minimal standards for the production, processing and distribution of bottled water. (See Appendix A.) Its minimal standards for the quality of drinking water are the 1962 Public Health Service Drinking Water Standards. The American Bottled Water Association has no powers of enforcement but can withdraw its voluntary certification of a bottling plant when standards are not met. Loss of certification will not halt operations of the plant since the Association is a wiluntary organization of companies. In essence, then, the regulation of the quality of water sold in bottles is a function of each of the States. Just as there are 50 states, there are 50 different sets of regulations. Of these, some appear to be excellent, clearly defining standards of quality. Others are as vague as the criteria used by FDA, and in some cases there are no specific written regulations at all; the state may ignore the bottling of water or may interpret its Pure Food or other laws to include bottled water. Appendix B is a tabulation of State regulations, with brief summaries of that portion of each which deals with water quality. Also included is similar information for Guam, Puerto Rico, the Virgin Islands and the District of Columbia. Appendix B, compiled in early 1971, includes 22 States which have no specific regulations, 24 which define the quality standards vaguely for bottled water, and eight which spell out definite standards for bacteriological and chemical quality. Some of the States cite the absence of water bottlers within the State as being the reason for lack of definitive water bottling regulations. Yet, when an investigation into the extent of the bottling industry was made (Appendix C), bottlers were found in almost every State, and in no case was it definitely established that a State had no bottlers within its boundaries. In summary, the present status of bottled water regulation consists of limited application of the Public Health Service Drinking Water Standards, the similarly limited criteria and their application by the Food and Drug Administration, the unenforceable criteria and incomplete application of the American Bottled Water Association’s guidelines and State regulations which are at best widely varying in scope and at worst are non-existent. 2 ------- SCOPE OF PILOT SURVEY Purposes of the Survey In view of the role that the Environmental Protection Agency may acquire in regulating bottled water, it was concluded that a pilot study of water bottlers and bottled water should be untertaken to obtain background information. The purposes of the survey were (1) to determine the adequacy of source protection, treatment, bottling procedures and quality control at the bottling plants; (2) to determine the quality of bottled water as sold to the public; and (3) to determine the extent of bacterial growth in bottled water during the interim between bottling and ultimate consumption. Selection of Bottled Water Plants Twenty-five bottlers were selected from states to provide geographic distribution. The selection was based on a number of criteria: the state must have a significant number of bottlers from which to choose; the bottlers must be on or near a direct air route to one of the Water Supply Laboratories so that water samples for bacteriological examination would be received promptly; the state involved must be willing to cooperate; both members and non-members of the American Bottled Water Association would be represented; and states having good bottling regulations and those having relatively poor regulations would be included. After selection of the bottlers, an individual or team from Water Supply Division headquarters would travel to the area, meet with Regional and/or State personnel, and then proceed to each c?f the selected bottlers. The states selected were California, Connecticut, Ohio and Texas. Selection of individual bottlers from each State was made chiefly by geographic location. In Connecticut, proximity to the Northeast Water Supply Laboratory at Narragansett, Rhode Island, was the principal criterion. Ohio bottlers were selected in the area near the Cincinnati Laboratory. Because of limitations imposed by airline connections to the Gulf Coast Laboratory, Texas bottlers were selected only from the Houston-Galveston area. California bottlers to be surveyed were selected by the California State Health Department, but the selection followed the same pattern. The Los Angeles area provided the best airline connections to the Northwest Water Supply Laboratory at Gig Harbor, Washington. The plants visited are listed in Appendix D. Survey Procedures A comprehensive inspection of each bottling plant was performed. The plant survey form (Appendix E) was evolved from elements of forms used in the Interstate Carrier Water Supply Program and the guidelines of the American Bottled Water Association. Among the facets of the bottling operation covered were: water source, treatment, plant facilities and sanitation, employee sanitation, water handling equipment, water storage facilities and bottle handling sanitation. Connecticut was visited the week of November 29 — December 3, 1971; Ohio, December 13—17; California, January 3—7, 1972; and Texas, January 10—14. Six bottling plants in Connecticut were surveyed, five in Ohio, eight in California and six in Texas for the total of 25. Bottling Plant Construction, Sanitation and Operation The criteria for evaluating bottling plant construction, sanitation and operation closely followed the survey from (Appendix E). If a plant inspection revealed that “Yes” answers to each of the questions in sections A through E and G through H were applicable, the respective items were judged to be satisfactory. In section F, “Yes” answers to questions 1, 2 and 4 were expected, while question 3, “Are there any cross-connections,” should have received a “No” answer if a satisfactory rating was to be given for the section on Storage Tanks and Piping. Analytical Quality Control Because of the wide variations in the size of bottling operations, nature of the source, and the extent ot treatment, evaluation of the adequacy of analysis of the “finished” water was somewhat subjective. However, bacteriological control was judged to be adequate if a sample was tested at least weekly for the smallest plant, while the large, full-time operations were expected to perform daily tests. Judgment of the adequacy of chemical control, for a particular bottling plant, was based on both the analytical frequency and completeness. If the analysis included only pH, or an estimation of ozone level by odor, for example, credit for partial analysis only was given. If the chemical analyses, however complete, were performed at intervals of a year or more, control was judged inadequate. Analysis of source water composition was judged on the basis of criteria similar to those used to judge control of “finished” or product water. Bottlers using a municipal water supply as a source were not considered in this latter aspect of the evaluation, on the basis that this aspect of quality control is a responsibility of the municipal system. Sampling and Analysis At the time of the plant inspection water samples were collected for subsequent laboratory analysis. Samples of the source water were taken for both chemical and bacteriological analyses. If the composition of the water was changed as part of the processing scheme (any treatment process other than disinfection), an additional sample of the processed water was taken for chemical 3 ------- analysis. Additional bacteriological samples were taken from the filling line, and a case of 1 -gallon bottles or one 5-gallon bottle was collected from that day’s run for storage tests. Chemical analyses included “wet chemistries” (turbidity, color, total dissolved solids, chloride, sulfate, nitrate, arsenic, selenium, boron, cyanide, specffic conductance, pH, surfactants) and metals (chromium, copper, manganese, lead, iron, cobalt, cadmium, zinc, nickel and mercury). Bacteriological analyses included coliforms, fecal coliforms and standard plate counts, as well as tests for Pseudomonas aeruginoai. All chemical analyses were performed at the Northeast Water Supply Laboratory, Environmental Protection Agency, while bacteriology was done at the nearest Environmental Protection Agency Water Supply Laboratory. The storage tests included results after 1,3, 5,7, 10, 14, 21, 28, 35,49 and 63 days. FINDINGS AND DISCUSSION OF RESULTS Bottling Facilities, Opa ations, and Quality Control A wide assortment of water treatment processes were encountered and are summarized in Appendix F. Ozone and ultraviolet disinfection were preferred by bottlers over chlorination because of the taste characteristics of the latter. Laboratory control data revealed virtually complete lack of source water testing or chemical analysis of finished water. This aspect of bottled water compares most unfavorably with community water supplies, where at least some chemical constituents are routinely determined in the finished water, and where at least surface water sources are frequently subjected to chemical analysis. Only the large, full-time bottling operations provided for bacteriological analyses of the finished water on a regular basis, and essentially these were the only ones who checked the disinfectant level in the water. Table I summarizes the analytical quality control found at the 25 plants that were inspected. Sanitation of the physical facilities covered the range from unwashed floors and run-down equipment to sparkling cleanliness and modern automated equipment. The most common failing was lack of proper ventilation or the absence of screens on windows and doors, Failure TABLE I - Laboratory control of bottled water and source water. (A = Adequate, X = Inadequate, Part = Partial Analysis NA = Not applicable because public supply used as source. See Text.) B Finished water Source Bactexiological Chemical Bacteriological Chemical A X X X 2 X X X X 3 X X X X 4 A Part NA NA 5 x x x x 6 7 8 9 10 X Part X X A X X Part X Part X NA X NA X X NA X NA X 11 12 13 14 15 X X X X Part X X X X X X X X NA X X X X NA X 16 17 18 19 20 Part X A A X X X A A X X NA A A NA X NA A A NA 21 22 23 24 25 A A Part Part Part Part Part X Part X X X X X NA X X X X NA 4 ------- TABLE II — Evaluation of bottling facilities and procedures. (S Satisfactory; X = Deficiencies. See Text.) Bottler Floors Walls and ceiling Vent and light Toilets Employee sanitation storage Equipment maintenance Bottle filling and labeling I 2 3 4 5 X X X X X X X X X S X X X S X S S S S X S X X S X S S X S S X S X X X X S X S X 6 7 8 9 10 X X X X S X S X S S X X X X S S S X X S S S X X X S S S S S S S X X S X S X X S II 12 13 14 15 S X X X X S X S X X X X X X X S X X S X X X X X X S S X S S X X X S X X X X X 16 17 18 19 20 X X S X X S X S S X X X S S X X X S S X X X X X X S S S S S S X S S X X X S S X 21 22 23 24 25 S S S X X S S S S S S X X X X S S S S X X X X X X S S S X S X S X X S S S S S S to require employees to receive regular physical examinations was common. For the most part, bottles were sanitized and bottle filling was done under sanitary conditions. The major exception was the handling of plastic bottles. These arrived at the plant in cardboard cartons and are shipped without caps, thus the interiors are exposed to airborne contamination, and the presence of foreign matter. Yet, these bottles are presumed by the bottlers to be sanitary enough to be filled without even rinsing. Glass bottles are usually washed with hot caustic solution, but the temperature or strength of the caustic solution is seldom monitored. Bottle caps are sometimes used directly from the package in which they are received, sometimes (but not always) disinfected and frequently placed on by hand. The significance of employee sanitation and facilities maintenance is that the product (water, in this case) is subject to contamination, not only from the containers, but also from the physical surroundings and the people who come in contact with any part of the bottling operation. Table II summarizes the adequacy of the bottling facilities and procedures. The last step in the bottling operation, the affixing of labels, showed some instances of failure to conform to factual labeling practice. At least two well waters were identified as being springwater, and there were instances of deionized water being labeled as distilled water or vice versa. Bacteriological and Chemical Quality’ The results of chemical and bacteriological analyses of bottled and source waters are summarized in Tables III through VI. Chemical analyses (Table III) revealed one sample of bottled water with a lead concentration above the mandatory 1962 U.S. Public Health Service Drinking Water Standards limit. The corresponding raw water contained a much lower lead concentration, but the source of the lead could not be ascertained. The recommended limit on Total Dissolved Solids was exceeded in three samples, and the recommended limit on copper exceeded in one sample of bottled water. One water, reconstituted from distilled water, contained an intentionally high concentration of iron. Polyphosphates were added to this water to sequester the iron. Arsenic concentrations were reported as containing less than 0.03 ppm because of limitations of the analytical method used. 5 ------- TABLE ifi — Results of chemical analyses of bottled water, in parts per million. It is worth noting that in some cases labeling of bottled waters did not correspond with the contents as revealed by chemical analysis. One water, labeled “distilled,” contained over 400 ppm Total Dissolved Solids and 0.044 ppm lead, and another labeled “deionized” contained over 500 ppm Total Dissolved Solids. Other waters, labeled “distilled,” “deionized,” or “USP. Purified,” contained more than the 5 ppm Total Dissolved Solids which, by definition in the ABWA guidelines, is the appropriate limit for such waters. Bacteriological analyses (Table VI) show that four bottled waters gave positive tests for coliforms, and one of these gave a positive test for fecal coliforms. None of the bottled water showed evidence of the presence of Pseudomonas aouginosu, and Standard Plate Counts showed wide variations. In regard to the latter, no attempt was made to relate high plate counts to a specific type of treatment because of the limited data. However, it seems apparent that these high plate counts occurred in water subjected to filtering or distillation, as (Figures in parentheses represent PHS drinking water standards limits * = recommended, ** = mandatory.) Sample no. TDS (500)* Cl (25O) SO 4 (250) NO 3 (45)* Cu (1.O) Mn (o.OS)* Pb (O.O5)** Fe (O.3)* Zn (5.O)* Hg(d) (O.O1) AS(O.05)** 13287 13289 13291 13282 13283 382 18 39 18 14 7 5(a) 5 5 5 38 1(b) 1 1 1 25.8 0.7 0.1 04 0.4 0.009 0.236 0.008 0.021 0.016 0.002 0.001 0.000 0.001 0.001 0.025 0.008 0.010 0.019 0.019 0.016 0.010 0.013 0.013 0.010 0.049 0.123 0.044 0.044 0.047 0.5714 0.1918 0.1865 0.0355 0.0000 0.00 0.00 0.00 0.00 0.00 13285 13294 12094 12097 12098 326 556 8 112 12 5 5 5 5 5 122 67 1 5 1 0.7 19.5 0.1 0.2 0.1 0.054 0.021 0.032 0.056 0.033 0.002 0.001 0.001 0.031 0.001 0.028 0.015 0.002 0.008 0.065 0.014 0.020 0.021 0.057 0.055 0.075 0.014 0.034 0.029 0.009 0.0421 0.0329 0.0640 0.0000 0.0000 0.00 0.00 0.00 0.00 0.00 14801 14804 14807 14811 14816 350 11 410 18 176 29 5 140 5 14 1 1 1 1 33 0.3 0.1 0.2 0.8 1.2 0.045 0.031 0.125 0.480 0.021 0.002 0.001 0.011 0.002 0.003 0.008 0.000 0.044 0.034 0.012 0.014 0.013 0.068 0.046 0.035 0.064 0.010 0.199 0.130 0.079 0.0000 0.0640 0.0000 0.0000 0.2933 0.00 0.00 0.00 0.00 0.00 13310 13311 13313 13314 13315 166 11 102 6 19 18 5 5 5 5 36 1 1 1 1 17.7 1.0 34 0.9 0.8 0.053 0.033 0.045 0.064 0.061 0.001 0.000 0.000 0.000 0.000 0.010 0.004 0.006 0.005 0.003 0.016 0.014 0.017 0.014 0.011 0.049 0.012 0.015 0.015 0.014 0.0000 0.0000 0.0000 0.0000 0.0000 0.03(c) 0.00 0.00 0.00 0.03 13300 13301 13302 13316 13317 18 509 7 12 190 5 20 5 5 15 1 100 1 1 4 1.4 32.8 0.2 0.7 0.8 0.730 0.160 0.045 0.113 0.064 0.001 0.004 0.000 0.000 0.001 0.005 0.018 0.004 0.005 0.009 0.009 0.028 0.016 0.013 0.021 0.198 0.068 0.012 0.032 0.012 0.0000 0.0000 0.0000 0.0000 0.0068 0.03 0.03 0.03 0.03 0.00 13318 13319 13323 13325 13326 58 7 257 591 16 5 5 10 11 5 1 1 35 145 1 1.0 0.7 12.4 44.3 0.8 0.071 0.052 0.030 0.198 0.187 0.009 0.000 0.003 0.000 0.005 0.003 0.009 0.030 0.007 2.750 0.016 0.013 0.021 0.020 0.044 0.012 0.176 0.027 0.026 0.0000 0.0000 0.0000 0.0000 0.0000 0.00 0.03 0.03 0.03 0.03 9341 9345 9348 13249 13250 491 165 180 189 16 40 5 5 10 5 1 26 14 17 1 2.3 32.8 9.8 2.7 0.8 0.122 0.011 0.014 1.060 0.016 0.002 0.002 0.001 0.040 0.002 0.016 0.012 0.012 0.024 0.004 0.019 0.035 0.001 0.037 0.060 0.033 0.159 0.039 0.099 0.016 0.0171 0.0267 0.0000 0.0000 0.0000 0.00 0.00 0.00 0.00 0.00 13251 13254 15 66 5 5 1 11 09 7.1 0.014 0.400 0.002 0.003 0.004 0.012 0.103 0.010 0.017 0.203 0.0000 0.0000 0.00 0.00 6 ------- TABLE IV — Results of chemical analyses of water sources, in parts per million. Sample TDS C l SO 4 NO 3 Cu Mn Pb Fe Zn Hg(d) As 13290 13284 13293 12093 12096 284 1077 527 319 441 5 11 6 25 12 99 280 69 10 2 3.8 0.7 21.6 0.1 0.2 0.013 0.023 0.015 0.070 0.184 0.002 0.691 0.063 0.013 0.047 0.023 0.063 0.033 0.011 0.010 0.018 7.160 0.088 0.580 0.322 0.043 0.065 0.078 0.023 0.361 0.2338 0.0171 0.1314 0.0000 0.0000 0.00 0.00 0.00 0.00 0.00 14802 14806 14810 14815 9340 173 864 863 174 390 10 105 90 11 9 38 1 1 37 48 1.7 0.1 0.1 1.2 44.5 0.029 0.093 0.049 0.028 0.109 0.004 0.040 0.020 0.005 0.004 0.004 0.012 0.012 0.005 0.022 0.030 0.088 0.046 0.082 0.046 0.010 0.552 0.056 0.035 0.03 1 0.0000 0.1760 0.0000 0.0000 0.0123 0.00 0.00 0.00 0.00 0.00 13252 59 5 15 1.0 0.060 0.043 0.013 0.187 0.014 03256 0.00 TDS — Total dissolved solids a) — 5 ppm chloride OT less b) — 1 ppm sulfate or less c) — 0.03 ppm arsenic or less d) — Mercury reported in parts per billion Bottler no. 1 2 3 4 5 12 12 13 14 14 15 15 16 17 18 19 19 21 22 23 24 25 well as in those subjected to any of the forms of disinfection commonly used in the bottling industry.* The storage tests (Table VII) show cyclic variations of Standard Plate Counts. Samples which showed an apparent negative test when first bottled sometimes exhibited rapid bacterial growth, followed by apparent die-off and subsequent re-growth. Other samples started with high counts followed by die-off, and still others remained essentially bacteria-free. No significant number of Pseudomonas aeruginosa were found in any of the stored bottled waters. * Examination of bottled water by the Food and Drug Administration showed similar results, Of 85 samples tested in the last fiscal year, eight contained organisms from the Coliform group. The standard plate count on these same samples ranged from 0 to 54 million. FDA’S examinations were limited to bacteriology, pesticides and trace metals. (Unpublished data.) TABLE V — Fluoride determination of bottled water samples. Sample no. F, mg/liter 13255 0.095 9347 0.077 9350 0.155 13253 0.070 9344 0.095 12005 0.130 12099 0.120 12095 0.095 14805 0.250 14808 0.370 14813 0.095 14817 0.125 14819 0.110 14809 0.071 13321 0.340 13308 0.125 13322 0.180 13309 0.280 13312 0.260 13328 0.370 13303 0.510 13324 0.660 7 ------- Raw Bottled 2 Raw 4 Raw Treated, bottle Treated Treated, bottle 5 Raw Treated, tap Treated, bottle 6 Treated, tap 7 Raw 8 Raw Treated, tap Treated, tap Treated, bottle Treated, bottle 10 Raw Treated, bottle Treated 11 Raw 12 Raw Treated, tap Treated, bottle Treated, bottle Treated, bottle 13 Raw 14 Raw Treated, tap Treated, bottle Treated, bottle TNTC = too numerous to count oz. = ozone treatment UV ultraviolet treatment Deionized + carbon filter + oz. Deionized + mm + carb. flit + oz. Deionized + mm + carb. filt + oz. Deionized + carbon filter Deionized + carbon filter Fiber filter Filter + UV Distillation + ozone Filter + UV Distillation + ozone Soften, filter, ozone, blend Soften, filter, ozone,blend Chlorine + filter Chlorine + filter Deionized + ozone Deionized + ozone Distillation Distillation Unknown 1 0 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 60 0 0 2 0 0 0 0 0 0 0 0 o o 0 0 0 0 0 0 0 0 0 0 0 0 0 4 4 4 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o 0 0 0 0 1 1 0 1570 630 0 800 670 0 0 9 0 0 2 126 3 230 1180 19 0 11 2 14 0 0 0 0 0 0 52 2 4 0 0 0 TNTC 5 0 0 TNTC 1 8 8 TNTC 700 3000 TABLE VI — Bacteriological results after less than 30 hours storage. Bottler no. Sample Treatment Organisms per 100 ml Standard plate count per ml Colif. F. Colif. Pseudo 1 None Treated, tap Fiber filter Treated, bottle Fiber filter 3 Raw Treated, tap Ozonation Treated, bottle Ozonation Treated, tap Deionized + UV Treated, bottle Deionized + UV 9 Treated, bottle” Ion exchange Treated, bottle Distillation + ozone Treated, bottle ton exchange Treated, tap Soften, ion exchange, ozone Treated, bottle Soften, ion exchange, ozone 8 ------- TABLE VI — Bacteriological results after less than 30 hours storage. (Concluded) Bottler no. Sample Treatment Orga nisms per 100 ml Standard plate count per ml Colif. F. Colif. Pseudo 15 Raw Bottled Treated, bottle Treated, bottle None Distillation, ozone + carbon Distillation + ozone 0 0 0 0 0 0 0 0 0 0 0 0 250 1 300 2 16 Raw Treated, tap Treated, bottle Soften, distill, minerals, ozone Soften, distill, minerals, ozone 0 0 0 0 0 0 0 0 0 0 0 0 17 Raw Treated, tap Treated,bottle Distillation Distillation 0 0 0 0 0 0 0 0 0 0 300 1100 18 Raw Treated,bottle Treated, bottle Treated, bottle Deionized + ozone Deionized, ozone, fluoride, mineral Deminerahzed + ozone 0 0 0 0 0 0 0 0 0 0 0 0 740 0 3 0 19 Treated,bottle Distillation,fluoride,ozone 0 0 0 0 20 Treated, tap Deionized, ozone 0 0 0 0 21 Treated,bottle Treated, bottle Ozone Distillation + ozone 0 0 0 0 0 0 0 2 22 Treated,bottle Treated, bottle Carbon + ozone Distillation, fluoride, ozone 0 0 0 0 0 0 0 1 23 Raw Treated, bottle Treated, bottle Distillation, UV, fluoride Filter ÷ UV 0 0 0 0 0 0 0 0 0 210 4000 770 24 Raw Treated, bottle Treated, bottle Distillation + UV Ozone 0 0 0 0 0 0 0 0 0 38 0 0 25 Treated, bottle Softened, UV 0 0 0 3 TNTC = too numerous to count oz. = ozone treatment UV = ultraviolet treatment 9 ------- TABLE V I I — Effect of storage on the standard plate unt* of various bottled waters. Storage period (days) Bottler no. 1 2 3 4 5 7 8 8 Sample no. 13255 9347 9350 13253 9344 13298 13183 13184 1 630 670 9 126 1180 4 2 3 3 370 2160 1000 5000 143 20,000 350 18 , 000 5 630 210 2500 47,500 150 52,000 250 21,000 7 1120 360 6100 40,000 146 43,000 1300 11,000 10 379 5300 9000 32,100 129 76,000 670 70,000 14 1380 3900 2380 31,200 95 47,000 710 18,000 21 1440 9000 1430 43,000 11 40,000 1700 13,000 28 760 17,700 1010 32,000 71 35,000 2100 2200 35 460 41,200 690 14,200 59 33,000 1400 1400 49 550 2300 510 6000 70 48,000 4900 660 63 430 1700 430 11,700 13 61,000 1200 490 Storage period (days) Bottler no. 9 9 10 12 12 13 18 19 Sampleno. 13279 13280 13292 12005 12099 12095 13321 13308 1 1 1 3 60 1 14 0 0 3 5 3 4 140 0 15 3 0 5 31 39 4 250 2 110 34 0 7 36 25 69 1500 0 150 24,000 0 10 130 7 2700 1200 0 130 160,000 0 14 1100 39 29,000 1200 0 140 130,000 0 21 2200 1200 100,000 1500 0 140 49,000 0 28 1200 1300 53,000 750 0 310 44,000 0 35 690 880 56,000 600 0 100 18,000 1 49 700 1100 46,000 500 0 85 13,000 0 63 240 360 44,000 600 0 85 5800 0 Average counts per ml, calculated from replicate plates, incubated for 48 or 72 hours at 35°C, using plate count agar. 0 = <1 LA = Laboratory acadent TNTC = Too numerous to count, at 0.01 dilution 10 ------- TABLE VII — Effect of stor age on the standard plat e count* of various bott led waters. (Concluded) Storage period (days) Bottler no. 14 14 15 15 16 17 Sample no. 14805 14808 14813 14817 14819 14809 I TNTC 625 0 550 0 TNTC 3 TNTC 240 0 800 0 TNTC 5 TNTC 150 0 TNTC 0 TNTC 7 640 400 0 TNTC 0 1100 10 200 750 0 TNTC 0 1100 14 140 TNTC 0 TNTC 0 950 21 90 TNTC 0 TNTC 0 1000 28 35 TNTC 0 TNTC 0 800 35 50 TNTC 0 TNTC 0 915 49 65 415 0 1300 0 520 63 70 510 0 720 0 400 Storage pefiod (days) Bottler no. 19 21 22 23 24 25 Sampleno. 13322 13309 13312 13328 13303 13324 1 0 1 0 1300 1 350 3 0 1 LA 3300 0 160,000 5 0 2 0 19,000 4 400,000 7 0 1 0 29,000 3 550,000 10 0 5 0 33,000 2 480,000 14 0 10,000 0 31,000 180 370,000 21 0 15,000 0 28,000 5100 260,000 28 0 5500 0 27,000 5300 170,000 35 0 4600 0 11,000 2500 110,000 49 0 2200 0 5600 3800 57,000 63 0 130 0 7000 1500 67,000 *Avemge counts per ml, calculated from replicate plates, incubated for 48 or 72 hours at 35°C, using plate count agar. o = <1 LA = Laboratory accident TNTC Too numerous to count, at 0.01 dilution 11 ------- Headquarters Staff: Ervin Bellack, Chemist, Criteria and Standards Development Branch C. B. Kelly, Chief, Criteria and Standards Development Branch Roger Lee, Chief, Surveillance and Technical Assistance Section, Program Operations Branch Field Evaluation Team: Peter Karalekas, Staff Engineer, Surveillance and Technical Assistance Section, Program Operations Branch James Warren, Staff Engineer, Surveillance and Technical Assistance Section, Program Operations Branch Regional Liasson: Thomas Lothrop, Water Supply Consultant, Region I Donald Maddox, Regional Representative, Region V Henry M. Holman, Water Supply Consultant, Region Vt Oliver T. Love, Water Supply Consultant, Region IX Mark McCammish, Staff Engineer, Region VI State Representatives: Armand Lamberti, Senior Inspector, Food Division, State of Connecticut, Department of Consumer Protection Frederick C. Brown, inspector, Division of Foods, Dairies and Drugs, Ohio Department of Agriculture James P. Garties, Engineering Division, State of Ohio, Department of Health R. L. Sherry, State Food and Drug Inspector, Texas State Department of Health, Division of Food and Drugs I3url 0. Hetherington, Sanitary Engineer, State of California, Department of Public Health Labocatory Support: Gulf Co a at Water Supply Laboratory, Richard Hammerstrom, Director Northeast Water Supply Laboi’atory, B. J. Pringle, Director Northwest Water Supply Laboratory, John Hoff, Director Cincinnati Water Supply Laboratory, Gordon Robeck, Director PARTICIPANTS 12 ------- APPENDIX A The members of ABWA are joined as an association for the purpose of the advancement of the operations of the member companies, and the continuing improvement of service and products to the public. The Good Bottling Practices Guidelines Program is being instituted to improve quality and service, and to inform the buying public of the high standards of quality and excellence that are to be maintained. The Guidelines will be the basis of the production, processing, and packaging qualifications and the basis for plant approval upon recommendation by the Production Consultant. The first survey will be on the basis of satisfactory compliance with the Guidelines that control mineral content, cleanliness, sterility, and labeling of the packaged products. As the program progresses, additional guidelines may be added to the list governing approval. The Production Consultant will recommend approval when the annual survey reveals justification. Approval will be continued as long as a plant meets the guidelines. Whenever a plant fails to pass survey, the approval may be withdrawn. All approvals and withdrawals will be authorized by the ABWA Board of Directors. The Consultant has authority to recommend to the Board only. He has no authority to issue the seal of approval, nor to withdraw the seal of approval. I. PERMITS A. No person shall bottle or package water to be sold or distributed without first having obtained a permit therefor from the appropriate governmental agency. This could be state, county, or city, or a combination thereof. Local regulations will dictate the need. This does not apply where no permit is required. B. No water bottled or packaged in other states shall be sold, offered, or exposed for sale, or held in possession with intent to sell within a state unless the same is first inspected and registered and a proper permit obtained from the regulatory authorities. II. WATER A. Source: All natural waters to be bottled or packaged, or to be distilled or deionized must be procured from a source approved by the governmental agency issuing the permit, or the agency with jurisdiction. B. Bottled or Packaged: 1. These products are to include natural spring, well, or other water, distilled water, deionized water, or any of the foregoing to which chemicals have been added, which is placed in sealed bottles, packages, or other containers to be sold for culinary or other domestic purposes involving a likelihood of the water being ingested by human beings. 2. All of the products that are described in B-I are to comply with the Thinking Water Standards of the U. S. Department of Health, Education and Welfare, Public Health Service. Where local regulations are more stringent, they will take precedence in those particular stipulations. At all times, the strictest articles of regulations shall be observed. A complete quantitative chemical analysis of each type of water to be sold shall be made semiannually by an approved laboratory. 3. The ABWA Guideline for demineralized water by distillation, deionization, or other method is that it shall contain no more than 5.0 ppm of total solids. 4. U.S.P.H.S. Drinking Water Standards will be the basic bacterial standards for all bottled and packaged waters that are distributed for human consumption in the U.S.A. 5. The ABWA Guideline for waters offered for sale shall be that they are free from coliform organisms and have plate counts of less than 100 per milliliter. The standard plate count may not be exceeded in more than ten (10) percent of the samples collected. 6. Unopened bottles or packages will be delivered to a governmental laboratory or an independent laboratory having the approval of the governmental agency which issues the permit to the plant, or such agency may obtain samples with their own personnel direct from plant or truck. When samples are to be tested by governmental laboratories, it is preferable but not mandatory to have the samples collected by representatives of the respective laboratories. Samples will be taken from the containers in the laboratory by the laboratory technician. Samples may not be transferred from company bottles to laboratory sample bottles on the street or in other locations where the air is unsanitary. A minimum of one bacterial test will be made of each package once each month. 7. Member companies may perform the tests that are stipulated in the last sentence of B-6, using the Millipore system or other method approved by the Board. Sampling of each package should be performed at least semiannually by a certified commercial laboratory. 8. To be eligible for the Good Bottling Practices Seal of Approval, a plant must have complied with the ABWA Guidelines as stated in B-2, 3, 5, 6 and 7 for a period of one year or since the most recent previous survey. It is assumed that governmental agencies will AMERICAN BOTFLED WATER ASSOCIATION GOOD BOTFLING PRACTICES GUIDELINES (INTERIM) BOTFLED OR PACKAGED DRINKING WATER PRODUCTION, PROCESSING AND PACKAGING Rev 6/1/71 13 ------- continue to sample the products and that results of these tests will comply with ABWA Guidelines. These agencies wifi not be required to test for total counts. 9. When ozone is used as a sterilant of bottled water, the water in glass bottles should have an ozone residual of not less than 0.05 ppm when the bottles are closed and in plastic bottles not less than 0.07 ppm. C.Frocessing: Water to be used in a plant for bottle washing, hand washing, plant cleanup, and other sanitary purposes shall be delivered to the operating areas of the plant, under pressure, from a source that is approved by the governmental agency with jurisdiction control, or the one issuing the permit for the plant operation. This water will be tested monthly so that the owner may know that its use as a bottle rinse and for other critical purposes will not contribute bacteria to the products. III. BOTTLING PLANT CONSTRUCTiON AND SANITATION A. The floors of all rooms where bottled water or packaged water is processed or bottled, or in which bottles are sanitized shall be smooth, impermeable, and rodent..proof. They may be constructed of ceramic or fire clay tile, cement, concrete, or other impervious material. All wet processing areas shall have floors impervious to water and all new floors shall have adequate and sufficient floor drainage to permit thorough cleaning without becoming flooded. Existing floors without proper drainage will be acceptable provided that portable walking surfaces, on which workmen will stand and walk, are used. The walking surfaces are to be removed daily so that puddles may be removed and floors properly cleaned. The floors will be subjected to daily cleaning, followed by sanitizing with water of 200 ppm strength of chlorine or quaternary ammomum compound. The latter may be applied by mop or spray. B. The walls and ceilings of all rooms in which bottled water or packaged water is processed shall have smooth and washable surfaces, and shall be finished in a color sufficiently light to give good light reflection. The minimum height for ceilings in such rooms shall be eight (8) feet. The walls and ceilings are to be cleaned semiannually by scrubbing, using a suitable soap or detergent. Where bottling rooms do not exist and there are no ceilings, the inner surface of the roof supports shall be cleaned at regular intervals and kept free from accumulations of dust and dirt. C. All rooms hi which bottled or packaged waters are prepared, produced, or stored, or in which utensils are washed shall be ventilated so as to prevent excess condensation and corrosion. The ventilation system so designed and used must be located to preclude the intake of dust-laden air. D. Adequate means shall be provided to exclude crawling insects and rodents from the entire plant and to exclude flying insects from bottling rooms or areas where bottle washing, filling, and closing operations are performed and from cooler processing rooms. E. The entire premises, including floors, walls, ceiling, apparatus, devices, machines, counters, shelves, tables, and other parts of bottling works or facilities, equipment, etc. shall be so constructed and so located as to facilitate easy cleaning, and shall be kept clean and in sanitary condition. it is recommended that all new floors be coved to a height of six inches at junctions with all walls and the radius of the cove be one inch or more. All plans for alterations of existing facilities or for new construction must be reviewed and approved by the governmental agency issuing the permit for the plant and it is suggested that the plans be submitted to the ABWA Production Consultant for review and recommendations. F. Adequate and convenient toilets shall be provided which shall be separate and apart from any room or rooms where bottled or packaged waters are processed, or where bottles or packages are sanitized. Toilet rooms shall be provided with self-closing doors. No toilet room shall be used for the storage of garments, food products, utensils, or packaging and/or wrapping materials. Toilets shall have separate ventilation flues or adequate windows to the outside air. Lavatories shall be provided with soap (preferably powdered or liquid soap from dispensers — bar soap becomes unsanitary), hot and cold running water, and approved one-use sanitary towels, and shall be maintained in clean and sanitary condition. Toilet room floors shall be of nonabsorbent and impervious material. Floors and fixtures will be cleaned and sanitized daily. Sanitizing materials will be as stated in Ill-A. Walls and ceilings will be kept clean. G. hi all rooms in which bottled or packaged waters are produced or prepared, or in which coolers or utensils are washed, sufficient natural or artificial lighting shall be provided to produce an intensity of not less than fifty (50) foot candles at inspection areas, thirty (30) foot candles in work areas, and five (5) foot candles in storage areas. H. Every bottling plant shall have an approved sewage disposal system for all sewage and waste water. I. All tanks used to store product water and all piping used to conduct water to the filling operation shall be of a type which can be cleaned easily, which is non-corrosive, and which will prevent toxic materials in excess of quantities permitted by the U. S. Department of Health, Education and Welfare, Public Health Service Drinking Water Standards from entering the water being transported. If more than one source of water is available in the plant, no cross connections shall be permitted between two different water supplies unless approved in writing by the governmental agency having jurisdiction. Tanks will be tightly enclosed to exclude all foreign matter. Tanks will be vented through inverted air filters. 1. While engaged in the work of processing bottled or packaged water, or sanitizing bottles or packages, employees shall wear clean,washable outer garments and 14 ------- paper caps. Rooms shall be provided for the changing and hanging of street apparel apart and separate from the work areas, and such rooms shall be kept clean at all times. All clothes shall be removed from such rooms at intervals to allow thorough cleaning of the room. K. Tobacco will not be used in any product processing room. Expectorating will not be permitted except into receptacles provided for waste or sewage. L. Before beginning the work of preparing, mixing, or handling the ingredients used in bottling and packaging, and immediately after visiting a toilet, every person shall wash his hands and arms thoroughly and rinse them in clean water. Appropriate notice to this effect shall be posted in each toilet and dressing room. M. No employee or other person affected with a disease or infection in a communicable or transmissible stage shall be permitted to work in any bottling or packaging plant, or to handle any of the products or equipment. Health certificates shall be obtained as required by governmental agency with jurisdictional control. N. No work or storage areas of any bottling or packaging plant shall be used for sleeping or other household purposes. 0. No animal or fowl shall be kept or allowed in any bottling works or other place where bottled waters are produced. IV. SANITIZING OF STORAGE AND BOTTLING EQUIPMENT Product storage tanks, piping, filling equipment, bottle washers, crowners, and other equipment used to store, transport, and package the products sold by members of the Association must be maintained in clean and sanitary condition. A schedule of maintenance, cleaning, and sanitizing is a necessity. This activity is one of the most important in the production of high quality products at reasonable cost. Records shall be kept by approved plants of all work performed as required by Sections B 2 and 3 so that the information will be available to the ABWA surveyor when he makes the annual survey. A.Maintenance: This is an activity that must be scheduled by each plant operator as the plan must be tailored to the equipment and operating conditions of each plant. The Consultant will advise and counsel. B. Periodic Cleaning and Sanitizing: The Guidelines would be excessively voluminous and complex if an attempt were made to create exact standards to cover all types of equipment presently in use. A generalization will be made, with a recommendation that each plant operator expand the program to fit the needs of his plant. As the program progresses, more exact and detailed guidelines can be produced. 1. Semiannual: a. Product lines will be inspected for evidence of the formation of scale and, the occurrence of oxidation. If conditions justify, the lines will be disassembled, cleaned and reassembled. b. Fillers will be completely cleaned. c. Softeners, charcoal filters, ozone tanks and equipment, soft water tanks, and other associated equipment other than product storage tanks will be opened, disassembled, cleaned, and reassembled as necessary. d. All of the above equipment may be sterilized through the use of chlorinated water of 250 ppm strength with an exposure time of fifteen minutes minimum. Sterile water will be used as rinse water. Ozone treated water will do an effective job of sterilizing tanks, piping, and fillers. The ozone residual in the water should be 0.1 ppm minimum. When piping is sterilized, a residual of 0.05 ppm should be in the water at all discharge points. Sterilization of softeners and charcoal filters will be limited by the recommendations of the manufacturers of the materials. 2. Tanks: The types of water that are stored and the linings of the tanks will govern the frequency of cleaning of the tanks. In some cases, weekly scrubbing and cleaning will be necessary. Other conditions will justify longer periods between cleanings. Basically, the tanks will be kept clean and sterile. Each tank will be sterilized monthly by application of chlorinated water with a strength of 100 ppm and an exposure time of twenty (20) minutes or more. Sterile water will be used to rinse the tanks until they are chlorine free. Records will be kept of cleaning and sanitizing activities. 3. Daily: a.Mechanical hydro bottle washers must be properly timed always. The jets must be kept cleared of paper pulp and other obstructions. The washers should be kept as free of label pulp as possible. Outside sprays will be kept in full operation. b. All product lines between product storage tanks and fillers, and all fillers will be sterilized by steam or chlorinated water of 200 ppm strength. Product water will be used to rinse the lines until they are chlorine free. Ozone treated water may be used to perform this sterilization as described in IV, B, 1-il. c. All other bottling equipment such as crowners, filters, etc. will be sterilized by chlorinated water of 200 ppm strength. d. The use of sponges in containers of quaternary ammonium compound solution of 200 ppm strength is recommended for placement at all operating stations in the bottling or packaging area. The hands of operators can be kept sterile through use of this solution. The solution does not irritate the skin as chlorine does. V. SANITIZING AND FILLING BOTTLES A. Sanitizing: Before filling, all bottles shall be thoroughly cleaned by washing with an effective cleansing agent in water, the temperature of which is not less than 120°F, and shall, in addition, be subjected to an effective bactericidal process. A final rinsing of the 15 ------- inside of bottles, using product water, may be used to remove traces of sterilants. The following bactericidal processes are considered to be effective: 1. Contact of the interior surface of the bottle for at least one-half minute with a chlorine solution containing at least one hundred parts per million free chlorine. 2. Contact of the interior surface of the bottle for at least two minutes with a solution containing at least 200 parts per miffion of an approved quaternary ammonium compound. II the detergent used in the cleaning process is a type which would neutralize the quaternary ammomum compound, then a clear water rinse shall be used before application of the quaternary ammonium compound. 3. Contact of the interior surface of the bottle for at least one minute with 2-1/2 percent caustic maintained at a temperature of at least 120° F, followed by a rinse with a chlorine solution containing at least ten (10) parts per million of free chlorine. If caustic is discharged into the bottles through high velocity jets, the preceding procedure shall be considered to constitute both cleaning and bactericidal treatment. 4. A wet method whereby the interior surface of the bottle is maintained at a temperature of not less than 170°F for a period of not less than 15 seconds. 5. Where automatic bottle washers in which caustic is discharged into the bottles through high velocity jets, commonly known as “hydro” type, or of the soaker type are used, such will be considered to constitute both cleaning and bactericidal treatment provided all surfaces of the bottles are exposed for at least five (5) minutes to a solution containing at least two and one-half (2-1/2) percent caustic and maintained at a temperature of at least 120°F, followed by rinse with clean water. 6.Any other method that is approved by the governmental agency issuing the permit, or having jurisdictional control. 7. When bottles are washed by caustic solution, the temperature of the solution shall be 120°F minimum and the caustic strength of the solution shall be 2-1/2% or more. Tests of these two qualities will be made at least twice daily and a record shall be kept as information for the ABWA surveyor. B. Handling: At all times during the washing, handling, filling, and closing of clean bottles and packages, the bottles and packages shall be handled in a manner that will preserve the sterility of the inner surfaces and the lips of the openings. Handlers may not touch the inner surfaces and lips, allow the lips to contact clothing or other unsterile articles, sneeze or cough on the inner surfaces and lips, or commit unsanitary acts that may contribute bacteria to the products. C.Filling: Immediately after sanitizing, all bottles are to be filled and closed. Accumulations are to be no greater than the capacity of the filler. During the filling and closing processes, all bottles are to be protected from dust, dirt, insects, and other forms of contamination. Hoods over the conveyor from the washer to the filler and from the filler to the capper will protect the open-clean bottles. VI. SEALING OF BOTTLES Immediately after filling, bottles shall be sealed in a manner which will adequately protect the quality of the contents of the bottles and prevent contamination of the end of the bottle necks. A. Corks are subject to bacterial contamination and are not acceptable for use. B. If screw or snap caps are used, they shall be new caps or shall be subjected to a sanitizing treatment equivalent to that required for bottles. C. If crown caps are used, only new caps shall be used. D. New screw, snap and crown caps may be used without prior sanitizing only if received in a condition of known cleanliness and freedom from bacterial contamination and kept until used in a manner which protects them from dust, dirt, insects, and other forms of contamination. Rooms in which caps and crowns are stored will be protected from insects, rodents, and dust. The rooms will be kept clean and samtaiy at all times. VII. LABELING Each container must display information about it and the product that it contains as approved by the governmental agency issuing the permit. This information shall be embossed in the glass or imprinted on a label or closure. A. Types of Water: 1. Demineralized water may be produced by one of several methods. The two principal methods are distillation and deionization. The designation on the labels shall be “Purified Water” by “Distillation” or by “Deionization.” 2. “Spring Water” designates water that issues from the ground naturally. This water may be collected and controlled by pipes, tunnels, etc. 3. “Well Water” is water taken from the ground by drilling. The well may be flowing or one from which water is taken by pumping action. 4. “Drinking Water” may be any water prepared for human consumption. It must meet USPHS drinking water standards. This may be processed or manufactured water. B. The name and location of bottling plants must be designated. C. Net contents must be shown on each bottle. D.Misinformation: This type of statement must not appear on labels: 1. Unsupported claims of medicinal and health giving properties. 2. Reference to bacterial and laboratory examinations made by governmental laboratories. 16 ------- 3. Untrue or misleading statements. VIII. COOLERS All coolers must be cleaned and sanitized in accordance with the Good Bottling Practices Guidelines of ABWA as approved by the Board and the membership at I.as Vegas, Nevada in October 1965. A copy of these Guidelines may be obtained from the ABWA office in Los Angeles, California. IX. SURVEY PROCEDURES A. Plant Operator and Supervisors: It will be the continuing responsibility of the plant operator and the supervisors to maintain the plant in accordance with the Guidelines of ABWA and the controlling governmental agencies. B. Governmental Agencies: Will be encouraged to make regularly scheduled inspections of the plants. Basically, the plant operator is responsible for the establishment of these schedules. C. Consultant or Other Authorized Agent of ABWA: Surveys of plants for initial approval will be requested by members and a survey date will be set up that is convenient for both the member and the surveying agency. Surveys for reapproval will be made annually without advance notice of the time. Reports of the surveys will be prepared and submitted to ABWA Headquarters by the Consultant for review and recommendation of either acceptance or rejection of the plant seal of approval to the ABWA Board of Directors. X. PRODUCT LIABILITY INSURANCE A member company that is to be approved by ABWA will be required to have a product liability insurance policy in the amounts of $100,000 to $300,000 and to maintain this policy throughout the period of approval. XI. LETTER OF AGREEMENT After the survey has been completed, ABWA will send to approved companies a letter granting them the right to use the ABWA “Good Bottling Practices Seal of Approval” and outlining the restrictions and requirements for its use. When the approved company has signed and returned the letter of agreement to ABWA Headquarters, they will then have the right to use the Seal until it is revoked by the American Bottled Water Association. 17 ------- APPENDIX B 1. ALASKA — No regulations specifically pertaining to bottled water. Handled under State Water Supply regulations or general public health powers. 2. ALABAMA — No specific regulations. 3. ARIZONA — No regulations specifically pertaining to bottled water, but handled under State Water Supply regulations and Food statutes. 4. ARKANSAS — The water source must meet the requirement of the Arkansas State Board of Health. (Rules and Regulations pertaining to Bottling Plants, adopted 1962.) 5. CALIFORNIA — Water must be flee from coliforms, fluoride may be added, and label must not be false or misleading. (California Administrative Code, Title 17, Public Health, 1953, and California Pure Foods Act, 1968.) 6. COLORADO — Quality of bottled water shall conform to same standards as required for public water supplies — substantially the same as USPHS Drinking Water Standards, 1962. (Regulations for Quality of Water Supplies to the Public, 1967.) 7. CONNECTICUT “No impure, contaminated or polluted water shall be used . . .“ (An Act Concerning Non-alcoholic Beverages and Apple Juice, and Regulations Concerning Dietary Beverages — Apple Cider and Apple Juice, 1967, Department of Consumer Protection). 8. DELAWARE — No spedfic regulations pertaining to bottled water. 9. DISTRICT OF COLUMBIA — Importation of packaged food forbidden unless it comes from an inspected and approved source. No regulations pertaining specifically to bottled water. (D. C. regulations 8-6:105). 10. FLORIDA — Source must be approved by Florida State Board of Health, Bacteriological quality must be in accordance with Florida Sanitary Code, chemical analysis filed with Board for approval, and the label must give the chemical analysis and a statement of all substances added and treatment processes applied. (The Sanitary Code of Florida, Chapter 1 70C-22.) 11. GEORGIA — Bottlers or importer of waters must register with the Georgia State Health Department and have a bacteriological examination, and chemical analysis, if required, of the water by the State Board of Health Laboratory. At least one bottled sample must be submitted every month for bacteriological examination as to purity. (Rules of Department of Public Health, Chapter 270-5-14, adopted 1928.) 12. GUAM — No regulations specifically pertaining to bottled water. 13. HAWAII — No specific regulations, but the Hawaii Food, Drug and Cosmetic Act applies. The adulteration or misbranding of food is prohibited. (Hawaii Food, Drug and Cosmetic Act, 1967.) 14. IDAHO — No specific regulations, but all water must come from approved sources, and when bottled, meet the USPHS standards for drinking water and be bottled under sanitary conditions. 15. ILLINOIS — Water shall be of sale, sanitary quality from an approved system in conformance with applicable state and local laws, ordinances and regulations. (Food Manufacturing, Processing, Packing or Holding, General Rules and Regulations, with Interpretive Regulations for Bottlers of Soft Drinks and Waters, 1970.) 16. INDIANA — No bottled water offered for sale may show bacteriological or chemical content deleterious to public health. Samples must be submitted for potability and suitability at intervals designated by the state board. (Water Supply, Chapter 157, Acts of 1949 Indiana General Assembly.) 17. IOWA — Iowa Department of Agriculture has jurisdiction, and classes bottled water as a food. Although regulations do not specifically mention water, it is sampled and examined for potability by Iowa Department of Agriculture Laboratory. (State of Iowa Pure Food Laws, 1966.) 18. KANSAS — No specific regulations. Kansas Food, Drug & Cosmetic Act applies. (Similar to Federal FD&C Act.) Unless label indicates industrial or commercial use, drinking water standaids apply. Label must be factual. (Kansas Food, Drug & Cosmetic Act of 1953, with amendments and regulations.) 19. KENTUCKY — No specific regulations, but bottled water must meet same requirements as public water supplies, i.e., chlorination, approval relative to treatment, chemical and bacteriological quality, approval relative to proper labeling, etc. (Kentucky Public Water Supply Regulations.) 20. LOUISIANA — Bottled water must be free from substances deleterious to health and shall conform to standards of the Louisiana State Board of Health for potable water. It must be labeled according to the State Food, Drug, and Cosmetic Act. (Sanitary Code, State of Louisiana, Chapter IV, Bottled Water and other Bottled Carbonated Beverages, 1963, the State Food, Drugs and Cosmetic Act, 1950, and General Regulations and Regulations Pertaining to Foods, 1944.) 21. MAINE — No specific regulations, but Health and Welfare Statute on the sale of water for domestic purposes applies. Samples may be required for chemical and bacteriological examination, and the sale STATE REGULATIONS PERTAINING TO ThE QUALITY OF BOULED WATER, 1971 (Including regulations for Guam, Puerto Rico, the Virgin Islands and the District of Columbia). 19 ------- or distribution of contaminated, polluted or unfit water may be prohibited. (Health and Welfare Statute, Chapter 559, Water for Homes or Schools.) 22. MARYLAND — No specific regulations, but laws pertaining to food and drink apply. Licenses to manufacture soft drinks are required, and may be denied if the water supply is known to be dangerously polluted. (Health Laws, Art. 43.) 23. MASSACHUSETTS — No ingredient or material, including water, shall be used in manufacture or bottling which is contaminated or injurious to health. If the water supply is not a public water supply, a description of the spring and an analysis of the water must accompany the permit application. (Laws and Regulations Pertaining to the Manufacture and Bottling of Carbonated Non-alcoholic Beverages, Soda Water, Mineral and Spring Water. General Laws, Chapter 94, as amended by Chapter 441 of the Acts of 1935.) 24. MICHIGAN — Regulations pertaining to non-alcoholic beverages and food apply. Only reference to water says it must meet USPHS standards for bacteriological purity. (Michigan Department of Agriculture, Regulation No. 549, Non-alcoholic Beverages, Michigan Food Law of 1968, Act 39 of 1968 as amended.) 25. MINNESOTA — Regulations pertaining to non-alcoholic beverages apply. Water used must be of safe, sanitary quality and from an approved source. (State of Minnesota Department of Agriculture Rules and Regulations Relating to Non-alcoholic beverages, Agr 985—994, Non-alcolxlic Beverages Chapter 34.) 26. MISSISSIPPI — No specific regulations (bottling facilities are inspected by local county sarntarians). 27. MISSOURI — Laws and regulations pertaining to soft drinks apply. No material which is not pure, clean or wholesome may be used in manufacture. Water must be from an approved source and of sanitary quality as required by Division of Health standards. No fluorides may be added. (Laws Governing the Manufacture of Soft Drinks and Beverages in Missouri 196.365—196.445, 196J25—196.145, Regulations Governing the Manufacture of Soft Drinks and Beverages in Missouri, Missouri Revised Statutes, 1949). 28. MONTANA — Annual fee for bottling plants, water plant and source shall be inspected at least once each yeai. (Investigation of Water offered for Sale in Bottles and Other Containers, Regulation 79, 1918.) 29. NEBRASKA — No specific regulations, but rules and regulations for public water supplies are interpreted as applicable. Essentially the USPHS Drinking Water Standards of 1946 are the standards for chemical and bacteriological quality. (Rules and Regulations Relating to Public Health, Section XI, Water Supply Systems.) 30. NEVADA — Permit required for bottling or distribution, and permit issued only after compliance with water supply regulations, USPHS Drinking Water Standards and Nevada Food and Drink Establishment Act. (State of Nevada, Department of Health, Water Supply Regulations, 1952.) 31. NEW HAMPSHIRE — No impure water or unsafe source of water supply shall be used. All materials, including water, shall be pure and wholesome. (State of New Hampshire, Division of Public Health Services, Beverage Law and Regulations, 1967.) 32. NEW JERSEY — All water intended for distribution or sale as bottled water shall comply with the potable water standards established by the Department of Health. (Laws and Regulations Governing the Sale of Non-alcoholic Beverages and Bottled Water.) 33. NEW MEXICO — No specific regulations, but New Mexico Food Act applies. Wording similar to Federal Food, Drug and Cosmetic Act. (New Mexico Food Act,Chapter 169, Laws of 1951.) 34. NEW YORK — Bottled water, except mineral water, must comply with New York State Drinking Water Standards, State Sanitary Code for drinking water supplies applies. Bottled water cannot be sold unless the source, equipment and method of handling are approved by the State Commissioner of Health. (New York State Sanitary Code, Part 5, Drinking Water Supplies, 1967, and Public Water Supply Guide, 1971.) 35. NORTH CAROLINA — Bottled water must be safe for consumption and properly labeled. Supplier must take precautions to protect its purity. Samples must be submitted for bacteriological analysis. (North Carolina General Statutes 130—158, 130—131, 160—120 to 160—132.) 36. NORTH DAKOTA — Bottled water cannot be sold until the source of supply, equipment and method of handling have been approved by the State Department of Health. The State Laboratories Department (not connected to the State Health Department) registers companies which sell bottled water. State Health Department regulations do not apply to waters sold in labeled bottles registered by the State Laboratories Department. (State Health Department Regulation No.69.) 37. OHIO — Bottled water classed as soft drink in Agriculture regulation. All water used shall be safe potable water free from pathogenic bacteria. Label must not be misleading. Prepared or compounded waters shall not be described as natural waters. Mineral waters must be of good quality when judged by sanitary chemical analysis. (Ohio Revised Code, Sections9l3.22to 913.28 and Section 91399.) 38. OKLAHOMA — Except for mineralized water, the water shall comply with the USPHS Drinking Water Standards for chemical quality and frequency, of analysis. Not less than two samples per month shall be tested for bacteriological quality. (Oklahoma State 20 ------- Department of Health Rules and Regulations for the Production, Processing and Distribution of Bottled Drinking Water, 1963, Oklahoma Senate Bill No.292, 1961.) 39. OREGON — No specific regulations, but Department of Agriculture food law applies. Bottling plant must meet minimum conditions required for any food processing plant, and water must be potable. 40. PENNSYLVANIA — No bottled water may be sold which is impure, bears evidence of potential pollution, or the use of which svill be injurious or detrimental to the public health. Permit application must be accompanied by a report of bacteriological analysis and sanitary chemical analysis. (Act No. 396 of the Pennsylvania General Assembly, 1929, Commonwealth of Pennsylvania Department of Health Regulations pertaining to the Manufacturing, Bottling, and Selling of Certain Waters, Chapter 4, Article 421, 1959.) 41. PUERTO RICO — Bottled water shall meet the requirements of the Drinking Water Standards adopted by the U. S. Treasury Department for drinking water supplied by common carriers in interstate commerce. Bottled water may be sold only in individual containers duly labeled. (Insular Board of Health Sanitary Regulation No. 115, 1943, Health and Sanitation Laws, 350-1351 to 350-1376.) 42. RHODE ISLAND — Regulations specify sanitary conditions for bottling facilities and bottles, but no quality standards for water. (State of Rhode Island and Providence Plantations pepartment of Health, Division of Food and Drug Control, Chapter 2 1—23.) 43. SOUTH CAROLINA — No specific regulations, but bottled water is included in the definition of “Public Water Supply.” 44. SOUTH DAKOTA — No specific regulations, but State Department of Agriculture laws apply. Foods must not be adulterated or misbranded. All beverages, including bottled water, must meet the same purity standards as food. (South Dakota State Department of Agriculture Laws, 22.0401 to 22.0411, 22.09904 to 22.9905, 22.0901 to 22.0905,22.0916.) 45. TENNESSEE — No specific regulations, but Agriculture Department requires that bottled water meet the USPHS Drinking Water Standards. 46. TEXAS — All water must conform with chemical quality limits prescribed in USPHS Drinking Water Standards. Mineral water, however, need not meet mineral concentrations prescribed in standards. Samples are to be submitted for bacteriological analysis every two weeks. (Texas state Board of Health Minimum Standards for Production, Processing and Distribution of Bottled Drinking Water, 1952.) 47. UTAH — No specific provisions in State Code, but distributors must be licensed and licensing code requires periodic laboratory evaluation to insure that the water meets standards for purity. 48. VERMONT — Bottled water shall meet current USPHS Drinking Water Standards and be free from coliforms. It shall not have total bacteria count of more than 100 organisms per ml in not more than 10% of samples. (Vermont Health Regulations, Chapter 5, Subchapter 12, effective 1/26/61.) 49. VIRGINIA — Specific regulations for bottling plants, but none for water quality. Virginia Food laws prohibit sale of food or drink which is unwholesome or otherwise unfit for human consumption. (Virginia Department of Agriculture and Immigration, 1956, Virginia Food Laws, 1968.) 50. VIRGIN ISLANDS — No specific regulations. 51. WASHINGTON — Bottled water must be of a sanitary quality approved by the State Director of Health. (Rules and Regulations of the State of Washington Board of Health, Chapter 50, 1960.) 52. WEST VIRGINIA — Bottled water must meet the same requirements as public water supplies, which are essentially the same as the USPHS Drinking Water Standards. At least one sample per week must be submitted for bacteriological analysis. (West Virginia State Board of Health Public Water Supply Regulations, 1969.) 53. WISCONSIN — Bottled water classed as Soda Water Beverage by Wisconsin Department of Argiculture. All water used must be pure and free from pollution and contamination. (Wisconsin Statutes, Chapter 97, 1969, Wis con sin Department of Agriculture Statutes, Chapter Ag 41.) 54. WYOMING — Bottled water classed as food by State Department of Agriculture. Food must not be adulterated or misbranded. (Wyoming General Food, Drug and Cosmetic Laws, Vol. 8, Chapter 5, Articles 1—9, inclusive, Wyoming Compiled Statutes, 1957.) 21 ------- APPENDIX C GEOGRAPHICAL DISTRIBUTION OF WATER BOTTLERS IN THE U.S., BY STATE State No. of Bottlers State No. of Bottlers Alabama 0 (c) Montana 8 (c) Alaska Unknown Nebraska 1 (c) Arizona 5 (c) Nevada 6 (c) Arkansas 11(c) New Hampshire 2 (a) California 63 (c) New Jersey 21(a) Colorado 4 (c) New Mexico I (c) Connecticut 17 (a) New York 16 (a) Delaware 2 (c)* North Carolina 7 (c) District of Columbia 0 (c) North Dakota 3 (c) Florida 24 (c) Ohio 50(b) Georgia 2 (c) Oklahoma 13 (a) Hawaii 2 (c) Oregon 4 (c) Idaho 1 (c) Pennsylvania 43 (a) Illinois 50 (b) Rhode Island 4 or 5 (b) Indiana Unknown** South Carolina 0 (c) Iowa Unknown South Dakota 2 (c) Kansas 20—25 (b) Tennessee 1 (c) Kentucky Louisiana 2 (c) 5 (c) Texas Utah 50(b) 1 (c) Maine 15—20 (b) Vermont 1 (c) Maryland Massachusetts 12 (a) 16 (a) Virginia Washington 12 (c) 3 (c) Michigan Minnesota Unknown** 3 (b) West Virginia Wisconsin 8 (c) 5 (b) Mississippi 2 (c) Wyoming 2 (c) Missouri 15 (a) (a) Licensed, registered or certified by the State. b) Estimated by State Health or Agriculture Department or by EPA Regional Office. c) Known according to State to be in operation. (Plus approximately 5 who bottle only in emergencies) ** (Estimated 20—30 Indiana and Michigan combined) 23 ------- APPENDIX D BOTTLERS VISITED Connecticut *Pequot Spring Water Co., Glastonbury *Triple Springs Spring Water, Meriden *Great Bear Spring Co., Hampden *Kel y Spring Water Co., Middletown Granite Springs Beverage Co., Thomaston *Manitock Spring Water Co., Waterford Texas *O7 rl( HOUstofl Inc., Houston Distilled Water Co., Houston *Galyeston Distilled Water Co., Galveston 9’riple XXX Bottling Co., Galveston *Crysta..Pure, Inc., Houston Brazosport Bottling Co., Freeport California El Rancho Markets, Inc., San Gabriel *Deep Rock Water Co., Los Angeles *Indjan Head Water Co., Los Angeles *Affowh d Puritas Waters, Orange *Silver Springs, Water, Inc., Orange *Njagara Drinking Waters, Inc., Garden Grove *Mrowh d ..puritas Drinking, Los Angeles *Sparkletts Drinking Water Corp., Gardena Ohio Cedar Hill Farm, Inc., Cincinnati Talawanda Spring, Inc., College Corner *The Crystal Water Co., Dayton Burger Brewing Co., Cincinnati Vanderhaar Bros. Dairy, Inc., Evendale indicates membership in ABWA 25 ------- APPENDIX E BOTTLED WATER SURVEY rII( [ IIII(IflEPAofficeuse___ ___ ___ Date this survey made I 11 [ I I LF I Name of Bottler: Street Address: City, County, State: L I ! I I I zip code Phone: H I 11 I fl - ! I I 11 Person Contacted and title: __________________________________________ Has a permit for operation been issued by the state? [ 11 yes El no Es the Bottler a member of A B W.A ? fl yes no Production: I Average production in gallons per day I I I 1 1 1 . Maximum capacity in gallons per day I i I I I L Number of plant employees L 1 1 1. Containers Used : Number Frequency per Size Type Processed day mo . ear (check one ) ______ Li U ______ LI U Li ______ U Li LI ______ Li ______ ULJU List the trade names of the water produced (i.e 0 spring, mineral, distilled) and attach labels if available. Number of Sourc of Water El surface [ ] well [ Ill spring Eli purchased (list from whoni 27 ------- Treatment provided by Bottler (l:yes 2-no) 1111 disinfection LI coagulation 11111 sand filtration El iron removal Eli settling [ J lime softening El ion exchange Eli distillation L II activated carbon other (list) Type of bottle washing equipment used? Method of sterilizing bottles? Method of Sterilizing process equipment? Coninents: 28 ------- LAB ORATORY CONTROL A. Bacteriological (Finished Water) (1) Mm. iaimber samples recommended per month by PBS DWS IIIL ciii (2) Avg. number/month for last 12 months 1 t I I U (3) Range of least and most monthly from 1 1 Li toll Ii ti samples 68 73 7s (4) Number of months the Drinking Water Standards were not met during the last 12 months for: (a) Quality [ J (b) Number of samples [ ] (c) NONE collected LI (5) Are samples representative of distribution system? Lino (6) Are check samples collected as provided for in the Drinking Water Standards? yes no (7) Are samples requiring check samples reported by telephone? LIllyes Il i1no (8) Is the laboratory certified? yes jjj Jno (a) Within the past 3 years? yes Lll 0 (b) If “yes” to one or both, by whom was it certified? flState EPA (9) Are samples received by lab within 30 hours? Llyes Ei 0 (10) Method of Analysis Thbe method LIJ Membrane filter (11) Analyzed by [ jj] state [ I I] EPA [ II] L ii bottler LI other (specify) local health 29 ------- B. Chemical (finished water only) (1) Samples of finished water are analyzed each month LI year LI 2 years LI years LI infrequently El i never . (2) Type of analysis: Li complete (DWS) LI partial. (3) Date of last chemical analysis I i 1 ! 45mO. day yr. i—, local r (4) Analyzed by LI bottler U state Li EPA Li health Li other. (5) Tests run for operational control and their frequency are: Tests Frequency Less frequently Continuous Each shift Daily Weekly than weekly Alkalinity U [ I. Li El] 111111 Aluminum Li Li H LI Chloride Li Li Li LI Li Chlorine residual Li Li 1] Li Color Li Li LI] LI I Fluoride Li Li H Hardness __ LI H L1 Iron Li L _ H [ Ii Jar tests Li jill ] LI Li LI I Manganese L i [ Ill] ___ [ I] pH 1 1 Li LI I H [ i Taste&Odor r 1 i [ II [ 1 [ IT _ Turb&dity Li L i i [ 1111 Li LI r i 1 r i Zeta potential Li Li I Li LI Other____ Li [ I ] H U Li (,3 ‘7 30 ------- SOURCE, TREATMENT A. Are the following adequate: (1) Source, with respect to the following: NO (a) quantity H /9 (b) bacteriological quality 2F (a) chemical quality (d) physical quality H (e) adequate protection (2) Transmission of raw water L_ L 26 (3) Is the raw water sampled for: (a) bacteriological contamination (b) chemical contamination 33 (4) Treatment, with respect to the following: (a) aeration (b) chemical feed, capacity r (c) chemical feed, stand—by equipment (d) chemical mixing (e) flocculation I (f) settling 44 (g) recarbonation L 47 (h) filtration (i) disinfection, capacity (j) disinfection, stand-by equipment (k) taste & odor control (1) fluoridation L... 57 (5) Records for: (a) disinfection (b) filter runs 7i 7J (a) chemical consumption 7 (d) operational control tests ,‘ (e) bacteriological examinations 31 ------- BOTTLING PLANT CONSTRUCT EON, SANITATION, AND OPERATION A. Floors 1. Are floors smooth, impen 8able, and rodent proof? 2. Do all wet processing areas have adequate floor drainage? 3, Do floors without adequate drainage have portable walking surfaces? 4. Are floors cleaned and sanitized daily? B. Walls and Ceilings 1. Are all 8urfaces smooth and washable? 2. Is the height of ceilings at least 8 feet? 3. Are walls and ceilings cleaned at least semiannual .y? C. Ventilation and Lighting 1. Are process rooms ventilated so as to prevent excess condensation and corrosion? 2. Are process rooms ventilated so as to preclude the intake of dust laden air? 3. Are means provided to exclude insects from all process rooms? 4. Is the lighting adequate? D. Toilet facilities 1. Are adequate and convenient toilet facilities provided? 2. Are these facilities provided with self- closing doors? 3. Are floors and fixtures cleaned and sanitized daily? 4. Are sewage disposal facilities adequate? Liii yes yes El yes El yes El yes El yes yes El yes yes nil yes [ ] yes Dno ono nfl 0 flno nno Th 0 nfl 0 nfl 0 Dno ono LI yes [ J no U yes El no [ 1i1 yes [ III no yes LIII no 32 ------- E. Employee Sanitation 1. Do employees wear clean, washable outer garments and paper caps 2 yes no 2. Are clean separate rooms provided for changing and hanging clothes? yes no 3. Is smoking prohibited in all product processing areas ? yes no 4. Are employees required to wash their hands and arms before work and after visiting the toilet? yes no 5. Are employees examined periodically for any health problems? yes no F. Storage Tanks and Piping 1. Are tanks and piping easily cleanable? yes El no 2. Are they made of non-corrosive material? yes no 3. Are there any cross-connections? yes EEl no 4. Are tanks tightly closed and properly? El yes ITI no C. Maintenance of Treatment, Storage, and Bottling Equipment 1. Is there an adequate schedule of maintenance, cleaning, and sanitizing? yes no 2. Are records kept of all work performed? LI ] yes [ I] no 3. Are product lines, fillers, softeners and other equipment inspected, disassembled, and cleaned as necessary? yes no 4. Are mechanical hydra-washers in proper operation and free from pulp and paper. yes no 5. Are product lines and fillers 8terilized daily? flyes 11. Sanitizing, Filling, and Labeling Bottles 1. Are bottles thoroughly cleaned and sanitized by an effective bactericidal process? U yes no 2. At all times after sterilization are bottles handled in a manner that will preserve the yes no sterility of the inner surfaces and lips of the openings? 33 ------- 3. Are bottles filled and closed immediately after sterilization? yes no 4. Are bottles sealed in a manner which will prevent contamination of the bottle necks or contents? yes no 5. Are all containers labeled properly ? EIII yes El no 6. Are bottle caps properly sterilized? U yes EJ no 34 ------- APPENDIX F TREATMENT PROCESSES, WATER SOURCES, PRODUCTS AND QUANTITY Bottler Treatment process (in sequence) Water source Product Quantity (total) 1 None Spring Spring Water 300 gpd 2 Fiber filter Spring Spring Water 500 gpd 3 4 Ozonation Deionization, carbon filter, ozone Well Public Supply Spring or Bottled Water USP Purified WateT 150 gpd 2500 gpd Deionization, carbon filter + minerals Public Supply Drinking Water 5 Ion exchange, carbon filter Spring Spring Water 500 gpd 6 Fiber filter Wells Unlabeled 15 gpd 7 Ion exchange, carbon filter Public Supply Purified Water 400 gal/wk* 8 Filter, UV (glass bottles) Spring Spring Water 2500 gpd Distillation, ozone Spring Distilled Water Filter, ozone (plastic bottles) Spring Spring Water 9 Ion exchange Public Supply Drinking Water 2500 gpd Distillation, ozone Public Supply Distilled Water 10 Chlorine, lime softening, settling, filter, ozone, blending w/dist. Well Spring Water 2100 gpd Distillation, ozone Public Supply Distilled Water 11 None Wells Well Water 15 gal/wk* Ion exchange Wells Well Water 12 Deionization, ozone Combined Trace Mineral W. 390 gpd Deionization, ozone Combined Distilled Water Chlorinate, carbon filter Imported Spring Water 13 Softening, filter, ion exchange, ozone Public Supply Drinking Water 1800 gpd Softening, filter, ion exchange, ozone Public Supply Distilled Water 14 Add minerals Imported Spring Water 400 gpd None Imported Spring Water Distillation Public Supply Distilled Water 15 None Imported Spring Water 5000 gpd Distillation, ozone Public Supply Distilled Water Distillation, carbon filter Public Supply Drinking Water 16 Softening, distillation, minerals, carbon, filter,ozone, blend w/thst. Public Supply Drinking Water 3300 gpd Softening, distillation, filter, ozone Public Supply Distilled Water 17 Distillation Public Supply Distilled Water 1000 gpd 18 Softening, aeration, minerals, polyphos., ozone Wells Drinking Water 100,000 gpd Softening, aeration, minerals, ozone Deionization, ozone Wells Wells Drinking Water Purified Water 19 Chlorine, sand filter, ion exchange, carbon filter, ozone Springs Spring Water 85,000 gpd Ion exchange, distillation, ozone Public Supply Distilled Water Chlorine, sand filter, ion exchange, carbon filter, fluoride, ozone Springs Fluoridated W. 20 Ion exchange, ozone Ion exchange, ozone Ion exchange, fluoride, ozone Public Supply PUblic Supply Public Supply Drinking Water Purified Water Fluoridated W. 4500 gpd 35 ------- Bottler Treatment process (in sequence) Water source Product Quantity (total) 21 Ion exchange, filter, ozone Well Pure Water 8000 gpd Distillation, ozone Well Distilled Water Ion exchange, filter, fluoride, ozone Well Fluoridated W. 22 Chlorine, sand filter, ion exchange, carbon filter, ozone Springs Spring Water 25,000 gpd Ion exchange, distillation, ozone Public Supply Distilled Water Chlorine, sand filter, ion exchange, carbon filter, fluoride, ozone Springs Fluoridated W. 23 Ultra-violet Spring Spring Water 4,000 gpd Reverse Osmosis, ion exchange or distillation, UV Spring Purified Water Ion exchange or distillation, UV, fluoride Spring Fluoridated W. 24 Distillation, UV Public Supply Distilled Water 14,000 gpd Ozonation Well Drinking Water R.O, ion exchange, ozone Well Purified Water 25 Ion exchange, fiber & carbon filters, Ultra-violet Public Supply Drinking Water 200 gal/wk* lndicatcs bottler operates intermittently gpd gaflons per day 36 ------- |