National Drinking Water Clearinghouse
West Virginia University
PO Box 6893
Morgantown, WV
26506-6893


Can Public Water Utilities Compete with Bottled Water?

by Michelle Moore
NDWC Associate Editor
michelle.moore@mail.wvu.edu

Photos by Chris Metzgar

What would you do if you found out the health department cited your favorite restaurant? Would you stop eating there? If you heard that another restaurant in another state had been cited for a more serious violation, would you vow never to eat out again? Imagine what would happen to the restaurant business if people reacted that way.

That’s exactly what the public drinking water industry is up against. Isolated water contamination incidents have turned people off from turning on their taps to enjoy a drink of water.

Water coolers, once the central station for office gossip, are now found in home kitchens. Joggers, walkers, hikers, and bikers carry plastic bottles, chugging store-bought water instead of water from home. Recent surveys show that almost 70 percent of Californians, for example, drink bottled water. National market research from 2002 showed that water bottlers’ sales grew more than 13 percent in the last five years, making it a $6 billion-plus industry. At this rate, bottled water is quickly becoming second only to soft drinks in popularity.

Part of the reason we’re drinking all of this water is that many of us have become more health conscious. When people are out, and they’re thirsty, they’d rather buy a bottle of water than a sugary soft drink. In our convenience-oriented culture, grabbing a bottle of water at the store is easier than filling a bottle with water at home.

Besides convenience, the aforementioned mistrust of public water also drives bottled water sales. News of water contaminations hasn’t helped: In the spring of 2000, drinking water supplies for 200,000 residents in New Jersey contained excess radium. Seventeen water companies had to lower the level of the naturally occurring radioactive element.

The gasoline additive methyl-tertiary butyl ether (MTBE) has been found in groundwater and drinking water reserves across the country. Another fuel ingredient, perchlorate, also is polluting groundwater. Studies show that even trace amounts of perchlorate may be a health hazard.

With reports like these, people are afraid the water pouring from the faucet is a toxic cocktail that may cause any number of physical maladies. Water system personnel have a tough time convincing the public that they can, and do, provide safe drinking water.
Not everyone blindly accepts the superiority of bottled water, which is fortunate for public water purveyors. People on limited budgets find the cost of replacing their tap water with bottled water to be extraordinary—costing over a thousand times more than tap water. Individual servings of bottled water can easily be $1.50 or more.

People have valid questions about bottled water. Is it safe? Is it regulated? Who regulates it, and what are the regulations manufacturers and distributors must follow? And most importantly, is bottled drinking water really any better than tap or has the industry created a very convincing illusion?

Bottled Water: Myths and Facts
Whether bought in bulk or as individual servings, bottled water has replaced tap water for a growing number of skeptics. Bottled water is marketed—and marketed very well—as clean and pure. Words such as “premium,” “mountain water,” and “natural” influence consumers.

Bottled water advertisements are commonplace. They show happy, healthy people in pristine outdoor settings where water flows from clear, mountain springs. These images help form the impression that water sold in plastic bottles comes from fresh, fantastic sources—no bugs, sticks, or animal dung soiling the drink. Advertising, plus the increasing aversion to tap water, is helping make bottled water one of the fastest-growing industries in the country.

To be fair, some bottled waters do come from mountain springs. Some come from mountain wells. But others may come from the same source as your community tap water, whatever that may be. And what might be more surprising is that local bottled water could be drawn directly from a municipal water treatment facility. In fact, about a fourth of all bottled water actually does come from municipal suppliers.

When this is the case, the bottle might state “from a community water source” or “from a community water system” on the label. The bottler may use additional treatment processes, but they may not have to, depending on what regulations apply.

Nearly all bottled water undergoes some kind of disinfection or filtration or both. It’s almost never sold straight from the ground. Testing may be done at the source, during production, and as a finished product, according to the International Bottled Water Association (IBWA), the industry’s trade organization.

Chlorination is rarely the disinfection method used because the taste of residual chlorine in public water is one reason people turn to bottled water. Ozonation is a preferred disinfection treatment, but reverse osmosis, ultraviolet light, distillation, activated carbon filtration, cation exchange, and micro-filtration are also used.

Safety issues with bottled water, as with tap, are rare. The IBWA says, “the Centers for Disease Control and Prevention has never linked an outbreak of illness or disease in the U.S. to bottled water.” Water bottlers are manufacturers creating a product for profit. They don’t want to risk lawsuits or financial losses, the same as any other business. It’s in the companies’ best interest to produce a product that is safe for consumers.

But, that doesn’t mean that quality problems haven’t occurred. Since so many people are substituting bottled water for their tap water, critics say the industry should have to follow strict rules.

Regulations Differ for Tap and Bottled Water

Every time a municipal water system has a contamination incident, rare as they may be, water bottlers win. No matter the reason or scope of the problem or how distant the town, some people will grow more suspicious of their own tap water.

Bottled water businesses, considering the explosive growth of the industry, thrive on reports of these incidents. Public water’s loss of consumer confidence is bottled water’s gain. Dr. Mel Suffet from the Department of Environmental Health Sciences at UCLA says: “Bad press in the public drinking water industry appears to be good press for the bottled water industry. In fact, the bottled water industry has an ally in the press, as any violation of U.S. Environmental Protection Agency (EPA) drinking water regulations must be reported to the press to inform the public, no matter how minor. The bottled water industry benefits from this free negative advertising.”

Bottled water and publicly supplied drinking water are controlled under different government offices. The EPA regulates water distributed by a community water treatment plant. EPA’s Office of Ground Water and Drinking Water sets regulations on production, distribution, and drinking water quality, plus controls for source water protection and treatment processes.

Public water supplies are tested

for about 95 different contaminants. Treatment facilities in West Virginia, for example, have to test their water at two-hour intervals throughout the day, totaling thousands of water quality tests per year. All other states have similar EPA-mandated requirements.
Health concerns are addressed through primary drinking water standards, which set maximum contaminant levels (MCLs) to limit biological and chemical contaminants that may be present. Secondary drinking water standards control aesthetic factors, such as taste and odor.

If a contaminant standard is exceeded or discovered in a drinking water facility, the public must be notified within a set time via television, radio, posting, or hand delivery to customers, depending on the severity of the violation.

The Food and Drug Administration (FDA) is the federal agency that regulates the quality of bottled water sold across state lines. In other words, bottled water is considered a food product, and the FDA’s rules only come into play when that product is sold outside of the state where it is produced. Similar standards to EPA’s govern limits of biological and chemical contaminants that may be present in bottled water, and the FDA ordinarily accepts new MCLs set forth by EPA. But the fact remains that FDA’s jurisdiction only applies with a food’s, in this case bottled water’s, interstate trade.

EPA’s standards are stricter for some microorganisms, such as Giardia, Legionella, and viruses, and for some 22 metals and trace organic chemicals. FDA is stricter than EPA for copper, fluoride, and lead. They have established limits for more than 75 contaminants. States can set their own standards, which may be higher or lower than FDA’s, and IBWA-member bottlers may have further standards they set for themselves.

Regulations always can be updated and amended. The FDA is in the process of establishing a contaminant level for uranium, a previously unregulated element. Also, in 2001, FDA set a limit for bromate, a potentially carcinogenic byproduct created when ozone is added to drinking water containing bromide.

FDA lists several kinds of bottled water (spring, artesian well, mineral, purified, sparkling, etc.), and the type is listed on the bottle. Seltzer water and club soda aren’t bottled water; they are soft drinks. Nutritional information is listed on the label, which in the case of water, means very little. Total calories, calories from fat, sugars, protein, and fiber don’t really apply to water.

FDA also has what are called “current good manufacturing practice” regulations for processing and bottling drinking water. These regulations stipulate that the water must be processed, bottled, stored, and transported under sanitary conditions. The bottlers have to keep records for government inspectors. No one, meaning the general public, is entitled to see these records, and the records can be discarded after a couple of years. Contrast that to the scrutiny public water facilities are under. FDA requires that bottled water plants be subject to random, yearly inspections. When it comes to safety concerns, FDA inspects bottled water plants and their products the same way it does other foods. A report called Bottled Water Regulation and the FDA states that “because FDA’s experience over the years has shown that bottled water has a good safety record, bottled water plants generally are assigned low priority for inspection,” noting that violators are inspected more frequently “depending on the number, significance, and recurrence of violations.” Also, FDA field officials “follow up on consumer and trade complaints and other leads, as appropriate.”

Now here’s where things can get a bit tricky. FDA rules don’t apply to a manufacturer who produces bottled water packaged and sold within the same state. Did you get that? FDA’s rules do not apply to in-state sales. States may have their own regulatory systems and standards for production and sales. Or, the bottled water may have no government oversight whatsoever. Bottled water sold in roughly one of five states comes under this category.

Water bottlers in states with regulatory powers are usually controlled through the agriculture or health department. These agencies can enact rules that are stricter than FDA’s, but this isn’t often the case. California is the exception; this state has more control over bottled water production than the federal government’s regulations.

Still question which is better?

The IBWA asserts on its Web site that “tap water can be inconsistent—sometimes it may be okay while other times it is not.” Under the current regulatory system, a bottled water could also be inconsistent, especially the brands that don’t fall under either the FDA’s or the IBWA’s guidance.

Another questionable claim about bottled water’s purity has to do with spring water or artesian well water. As the IBWA says, these waters come from well-protected, underground sources. The processing plants may be sanitary and secured from intruders, but if the aquifer from which the water is drawn is contaminated, the word pure hardly applies.

Leaking underground fuel storage tanks, widespread use of agricultural fertilizers and pesticides, confined animal feeding operations, industrial pollutants, poorly constructed water wells, and malfunctioning septic systems contribute to groundwater contamination across the country.

Take New Hampshire, for instance, a state that boasts plenty of beautiful mountains, springs, and streams. App-roximately 60 percent of the population uses groundwater as their source of drinking water, and about 25 percent use private wells. New Hampshire also is blessed with 18 federal Superfund sites, 15 of which have contaminated bedrock, meaning aquifers may be polluted. According to the Environmental Research Group at the University of New Hampshire in Durham, the state has “approximately 400 hazardous waste sites, 3,000 petroleum sites, and 197 unlined solid waste landfills, some of which are impacting or have the potential to impact bedrock aquifers.”

Water system personnel can use the tight regulatory control of EPA’s water laws to promote their product. Public water systems are required to test their water several times a day and disinfect accordingly, submitting their test results to the EPA. If any problem with excess contaminants is noted in the water, the situation must be reported and broadcast to consumers. Safety is mandated and is foremost since so many people must rely on public water.

Fort Collins, Colorado, came up with a good strategy to battle the impression that bottled is better than their tap water. Along with their municipal water, personnel tested the bottled waters sold in town, then posted the results on their Web site. They also list the price of their water compared to that of bottled water sold at that time (1997). Their municipal water cost 0.002 cents a gallon compared to some bottled waters that exceeded $5 per gallon.

The price of a gallon jug of water sold in grocery stores is about 89 cents. Consumer Reports says that a typical household spends $214 a year for drinking water at that price. Water is fairly heavy to carry, and one gallon doesn’t last very long. So, to avoid the trouble, a family may want to have their bottled water delivered. This convenience will add around $325 or more per year to the bill.
One drinking water professional put it this way: “How can anybody cry about the price of a gallon of gasoline these days when so many are willing to pay exorbitant prices for a mere pint of water?”

CCRs Provide Water Snapshot
Part of a water system’s obligation to its community is to create a consumer confidence report (CCR). These yearly reports outline, among other things,
• the water’s source and its susceptibility to contamination;
• the level of any contaminant found in the water;
• potential health effects of a contaminant detected in violation of an EPA health standard, plus an accounting of the system’s actions to restore the water’s safety;
• the system’s compliance with other drinking water rules;
• an educational statement for vulnerable people about avoiding Cryptosporidium, a disinfection-resistant microorganism;
• educational information about nitrate, arsenic, or lead where these contaminants are detected above 50 percent of EPA’s standard; and
• phone numbers for more information, including the water system and EPA’s Safe Drinking Water Hotline at (800) 426-4791.
EPA says this information “provides customers with a snapshot of their drinking water supply.”

In 2000, the FDA recommended that water bottlers provide consumers with water quality information, suggesting that some of the data could be listed on the label and further details could be outlined on a company Web site. FDA is considering future regulation requiring source water, treatment process, and water quality information be available to consumers—something much more helpful than listing water’s nutritional value.

Dr. Suffet of UCLA proposes that if soft drinks and beer have bottling and expiration dates, why shouldn’t bottled water?

“Many people would not drink an out-of-date beverage,” he says. “Why should they drink an aged bottle of water? All beverages that reach the market are subject to potential storage problems, (e.g., hot warehouses). Dates are needed on the shelf life of bottled water to indicate safety.” (The IBWA says that if bottled water is stored unopened in a cool place, it should last indefinitely.)

Suffet says some bottlers do include expiration dates voluntarily. He also suggests putting a statement like “refrigerate after opening” on labels to protect consumers. “Do you leave bottled water in the car after taking a sip, and in the following days drink more of that water?” Suffet asks. “Do you realize that under these conditions in a hot Southern California car, the plastic container can leach chemicals, or bacteria can grow in the bottled water?”

Self-Regulation Is the Norm
In most states, there is little real federal or state oversight of the bottled water industry; manufacturers voluntarily regulate themselves. Many bottlers belong to the IBWA, a trade organization created for the industry’s benefit, and agree to adhere to its guidelines. Bottlers test their product on their own schedules and member companies voluntarily submit to annual testing by NSF International, an independent testing and certification lab, in addition to FDA’s inspection.

FDA requires bottled water labels to state the manufacturer’s or distributor’s name and address, and IBWA members list the company’s telephone number. The FDA also requires that any contaminant in excess of regulated limits must be listed on the labels, but that sounds kind of counterproductive to marketing. Would you buy a bottle of water that stated it had too much lead in it?

Bottled Water Not Faultless
The notion that all bottled water is safer than tap is no longer taken for granted. In July 2002, the New Hampshire Department of Health and Human Services ordered the recall of a bottled water brand sold in New Hampshire and Massachusetts when coliform bacteria was found in test samples. Coliform is not a pretty thing. It lives in the intestines of warm-blooded animals (including humans), and its presence indicates that the water may contain pathogenic organisms.

Another report in the journal Nature told about contamination of several brands of European bottled water with a virus caused by human feces. In April 2002 they stated that these bottled waters (potential imports to the U.S.) still showed signs of a viral contaminant that “causes more than 90 percent of the world’s stomach upsets” a year after initial testing.

Bulk vended water isn’t without fault either. A study done in late 2002 by the Environmental Working Group and the Environmental Law Foundation in Los Angeles showed that a third of one brand’s vending machines exceeded the state limit for trihalomethanes, a disinfection byproduct. In Florida, Michigan, and Illinois, manufacturers have recalled their bulk bottled waters after tests showed bacterial contamination.

The Natural Resources Defense Council (NRDC), ordinarily a public drinking water critic, produced a report a few years ago that encouraged bottled water regulation more like EPA’s oversight of public drinking water. NRDC tested more than 1,000 bottles of 103 brands of bottled water. Most of the waters were high quality, but some brands showed contamination. A third or so of them contained synthetic organic chemicals and bacteria, and one brand contained arsenic levels that exceeded health limits.

These incidents are rare and the exception rather than the rule, but, then again, so are municipal water contaminations. The safety of the plastic and the effect plastic has on the water’s taste are being questioned more. The most common plastic used for water bottles is polyethylene terephthalate (PET). Another plastic, polycarbonate, creates a stronger, rigid container and is used for those five-gallon water cooler bottles. A Consumer Reports test of water sold in polycarbonate bottles showed eight of the 10 left residues of bisphenol A, an endocrine disruptor, in the water. Endocrine disruptors are synthetic or naturally occurring chemicals that interfere with the balance of normal hormone functions in animals, including humans. (Read about endocrine disruptors in the winter 2003 On Tap.)

Ozone, as stated earlier, is the disinfection process often used for bottled water. While ozone is a highly effective disinfectant, it is also an aggressive oxidant. Bruce Lewis, an engineer whose firm in Litchfield, New Hampshire, works with small water systems, says that if ozone remains in water that is to be bottled, it can corrode the plastic.

“Depending on where ozone is added to the water during the bottling process,” Lewis says, “if free ozone remains in solution, and this comes in contact with the plastic of the bottle, then a taste may result. This is, in fact, the plastic having been partially dissolved by the ozone and put into solution in the water.”

Lewis said the concentration of the ozone and the contact time for the ozone is critical. “Some companies that manufacture ozone-generating equipment report that greater than 0.2 parts per million (ppm) cause taste. However, at below 0.2 ppm of ozone, disinfection is not assured.”

A bitter taste isn’t necessarily harmful, but many people buy bottled water because they say it tastes better. As mentioned earlier, bromate, a disinfection byproduct regulated by EPA, is produced when water containing bromide is disinfected using ozone.

FDA recently mandated a 10 parts per billion (ppb) limit for bromate in bottled water. In California, whose laws regarding bottled water are more stringent than many other states,’ bromate is listed in the Safe Drinking Water and Toxic Enforcement Act of 1986’s Proposition 65, which lists chemicals suspected of causing cancer or reproductive problems.
The Water Quality Association reported that problems could arise for bottlers in California who might have less than EPA’s 10 ppb limit for bromate. Proposition 65 requires that “consumers be warned of any amounts above a ‘no significant risk’ level—and a ‘no significant risk level’ can be less than the MCL.”

Purified water, one of FDA’s identified bottled water types, is considered safe. Prior to ozonation, it is treated with reverse osmosis, distillation, or deionization, any of which remove bromide, eliminating the possibility of bromates forming. Ozonated spring or mineral water, on the other hand, are less strictly classified and may have a bromate problem that is in violation of the act. Violators can face fines of $2,500 per day until the bromates in tested waters are gone.

Grassroots activists across the country are fighting big bottling companies over ground and surface water supplies. IBWA says bottlers are protective of water resources. They say that the substantial investment needed to process water would make it foolish to deplete water supplies. That logic is questionable, though, when you know a manufacturer is pumping up to 500 gallons per hour and shipping it out of the state or country. When that happens, and it does happen, a heck of a lot of water is leaving the local ecosystem never to return. Compound the issue with a company’s claim that they own the land, and the water under it is theirs to use as they please. No matter that “their” water is part of all the water in the region. It’s easy to see why some folks are concerned for their water’s future.

Other people worry that all those disposable plastic bottles create litter and add to the overflow of solid waste in landfills. The IBWA says bottled water packaging is recyclable. Whether people choose to or have a place to recycle empty bottles is another matter.

How can water systems compete?

How can public water treatment systems begin to compete with this fast-growing, profit-driven business? What creative defense will convince people to trust the water they already pay for every day?

Letting people know that system personnel care is important. Public relations campaigns can really help. Press releases give treatment system personnel the opportunity to brag about the water they deliver. The National Rural Water Association has suggestions for ways to get the message to the public through bill inserts, school presentations, and the local media.

Booths at county fairs, festivals, and other local gatherings offer excellent opportunities for touting the quality of the public water. Of course a public water utilities’ best defense is to produce the highest quality product possible. When you think about it, that’s what treatment facilities are already doing—they just need to make more people aware.

For more information:
If you want to delve deeper into FDA’s rules for bottled water, read more on their Web site at www.cfsan.fda.gov/~dms/botwatr.html.

The IBWA also offers an overview of bottled water regulations on their Web site at www.bottledwater.org/public/BWFactsHome_main.htm

The National Rural Water Association offers 101 PR Tips, Ideas & Pointers for Small & Rural Water Systems to Get Your Wheels Turning, a book to help convey the “commitment and professionalism of rural water in America.” State rural water organizations can also help put together a public relations plan. Contact the NRWA in Duncan, Oklahoma, at (580) 252-0629 or visit their Web site www.nrwa.org.

To read the Natural Resources Defense Council’s report Bottled Water Pure Drink or Pure Hype? visit www.nrdc.org/water/drinking/bw/bwinx.asp.