BOTTLED
WATER
REPORT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
         WATER SUPPLY DIVISION

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                                 15453
    BOTTLED WATER STUDY
A PILOT SURVEY OF WATER BOTTLERS
               AND
         BOTTLED WATER
         WATER SUPPLY DIVISION
     ENVIRONMENTAL PROTECTION AGENCY
            September, 1972

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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.
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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

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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
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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.)
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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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