Bottled Water University Edition: Standards

Tap and bottled water are evaluated using similar quality standards, but tap water is tested more frequently and has more independent oversight by state and federal environmental authorities (e.g., U.S. EPA and state Departments of Environmental Protection). 

The FDA regulates bottled water quality, but often lacks the capacity to adequately regulate bottled water and largely relies on bottled water corporations to police themselves.  Also, the FDA has little jurisdiction over the roughly 60 percent of bottled water that is bottled and consumed in the same state (Gleick, 2005; NRDC, 1999).

A recent report by the Government Accountability Office (GAO) found that FDA’s regulation of bottled water, particularly when compared with EPA’s regulation of tap water, reveal key differences in the agencies’ statutory authorities.  Of particular note, “FDA does not have the specific statutory authority to require bottlers to use certified laboratories for water quality tests or to report test results, even if violations of the standards are found (GAO, 2009).”

There are several NSF/ANSI standards for drinking water treatment units (e.g., water filters).

Universities can use standards from the Association for the Advancement of Sustainability in Higher Education’s (AASHE) Sustainability Tracking, Assessing and Reporting System (STARS) program to document and report progress on sustainability initiatives.

Tap Water

United States Environmental Protection Agency, Safe Drinking Water Act, 1974 (Amended in 1986 and 1996).
This law gives the EPA power to set monitoring, treatment, and contaminant standards for the drinking water sources and supply of all U.S. public water systems.  Maximum contaminant levels (MCLs) are set for over 90 naturally occurring as well as man-made contaminants.  However, many contaminants are not covered.  State standards must meet or exceed the legal limits set by the EPA and both the EPA and the States are responsible for enforcing compliance with these standards.  Water systems are tested regularly and randomly at various points in the distribution path.  Water suppliers are required to report all violations and remedial actions in Consumer Confidence Reports (see the Cost, Quality, and Supply section of this Guide for more on these reports).

Bottled Water

United States Food and Drug Administration, Federal Food, Drug, and Cosmetic Act, 1938 (FFDCA).
Under the FFDCA, bottled water transported across state lines is regulated as a packaged food product.  Bottled water processed, packaged and sold within a single state is regulated by that state.  Standards applicable to bottled water can be found in the Code of Federal Regulations (CFR).  Title 21 of the CFR defines the various types of bottled water; sets limits for certain contaminants; lists labeling requirements; and establishes processing and bottling regulations under the Current Good Manufacturing Practice. The FDA is required to adopt standards for bottled water that are no less stringent than the EPA’s standards for tap water. However, it is the responsibility of the bottler to make sure its water can pass FDA tests and inspections. However, since “bottled water plants generally are assigned low priority for inspection,” inspectors tend to focus primarily on plants that have received several complaints or have a previous history of violations (Posnick and Kim, 2002). There is no mandated reporting for bottled water companies, and consumers do not have a guaranteed right to know the contaminants found in bottled water.  Furthermore, the FFDCA does not authorize the FDA to require bottles to post test results, even if contaminants have been found.  Instead, inspectors review testing records at bottling facilities; by contrast, the EPA must notify the public within 24 hours of detecting violations in tap water (GAO, 2009).

Drinking Water Treatment Units

A variety of standards are available for verifying the filtration functions of treatment units. After determining which (if any) contaminants need to be removed from drinking water, choose drinking water treatment units (DWTU) certified to remove those contaminants. The following independent, third-party organizations set standards for drinking water treatment units and certify units that are verified as meeting the standards.

NSF is a non-profit organization that “conducts safety testing for the food and water industries” (Rysavy, 2007). “Through a comprehensive consensus process, the NSF Joint Committee on Drinking Water Treatment Units (DWTUs) has developed key standards for evaluation and certification of drinking water treatment units” (NSF, 2004). DWTUs that meet NSF safety standards and remove 93 percent or more of a particular contaminant are eligible to receive NSF certification for that contaminant. NSF also has standards for particular water treatment methods. A listing of NSF-certified drinking water treatment units is available at http://www.nsf.org/Certified/dwtu or 877-867-3435.

NSF standards for DWTUs include:

• NSF/ANSI Standard 42: Drinking Water Treatment Units - Aesthetic Effects
  “This standard covers point-of-use (POU) and point-of-entry (POE) systems designed to reduce specific aesthetic or non-health-related contaminants (chlorine, taste and odor, and particulates) that may be present in public or private drinking water.” (NSF, 2004) This includes commonly-used carbon adsorption filters.
• NSF/ANSI Standard 53: Drinking Water Treatment Unites – Health Effects
  “Standard 53 addresses point-of-use (POU) and point-of-entry (POE) systems designed to reduce specific health-related contaminants, such as Cryptosporidium, Giardia, lead, volatile organic chemicals (VOCs), and MTBE (methyl tertiary-butyl ether), that may be present in public or private drinking water.“ (NSF, 2004) This includes commonly-used carbon adsorption filters.
• NSF/ANSI Standard 58: Reverse Osmosis Drinking Water Treatment Systems
  “This standard was developed for point-of-use (POU) reverse osmosis (RO) treatment systems. These systems typically consist of a pre-filter, RO membrane, and post-filter. Standard 58 includes contaminant reduction claims commonly treated using RO, including fluoride, hexavalent and trivalent chromium, total dissolved solids, nitrates, etc. that may be present in public or private drinking water.” (NSF, 2004)
• NSF/ANSI Standard 44: Cation Exchange Water Softeners
  “This standard covers residential cation exchange water softeners designed to reduce hardness from public or private water supplies. Additionally, this standard can verify the system’s ability to reduce radium or barium.” (NSF, 2004)
• NSF/ANSI Standard 55: Ultraviolet Microbiological Water Treatment Systems
  “This standard establishes requirements for point-of-use (POU) and point-of-entry (POE) ultraviolet systems and includes two optional classifications. Class A systems (40,000 uwsec/cm2) are designed to disinfect and/or remove microorganisms from contaminated water, including bacteria and viruses, to a safe level. Class B systems (16,000 uwsec/cm2) are designed for supplemental bactericidal treatment of public drinking water or other drinking water, which has been deemed acceptable by a local health agency.” (NSF, 2004)
• NSF/ANSI Standard 62: Drinking Water Distillation Systems
  “Standard 62 covers distillation systems designed to reduce specific contaminants, including total arsenic, chromium, mercury, nitrate/nitrite, and microorganisms from public and private water supplies.” (NSF, 2004)
  
  For more info on above standards, click here.
  
• NSF/ANSI Standard 60: Drinking Water Treatment Chemicals – Health Effects
  “The nationally recognized health effects standard for chemicals which are used to treat drinking water.” (NSF, 2004a)
• NSF/ANSI Standard 61: Drinking Water System Components – Health Effects
  “The nationally recognized health effects standard for all devices, components and materials which contact drinking water” (NSF, 2004a). Section 9 of this standard “regulates the levels of contaminants that can leach from drinking water devices into potable water” (Sorensen, 2004). While the U.S. federal government only requires compliance for lead levels, the 2003 International Plumbing Code (IPC) requires that products comply with all sections of this standard.
  For more info on the above standards, click here.
  
  Underwriters Laboratories (UL)
  The Underwriters Laboratories certifies filters with their Water Quality Mark, which is based on, but is not verified precisely to, NSF standards.
  
  Water Quality Association (WQA)
  The WQA certifies filters with their Gold Seal, which is based on, but is not verified precisely to, NSF standards.
  
  State Department of Health Certificate of Claims
  Some states (such as California, Wisconsin, and Massachusetts) require certification of performance claims and promotional literature for water treatment devices. Companies earn this certification by providing extensive laboratory test data for each contaminant removal claim. The Certificate also means the company’s literature, website, and packaging have been reviewed to contain no false or exaggerated claims (WFC, n.d.).
  
  ENERGY STAR for Bottled Water Coolers
  Energy Star has not created a testing protocol for bottle-less coolers, but many bottled coolers are Energy Star compliant. These coolers use less standby energy (the required energy to maintain cold and/or hot water at appropriate dispensing temperatures) (EPA, n.d.). To earn the Energy Star label, the cold-only and cook-and-cold (i.e., room temperature and chilled) units must use less than or equal to 0.16 kWh per day. Hot-and-cold units must use less than or equal to 1.20 kWh per day. Note that while Europe has regulations requiring that water coolers be sanitized on a quarterly basis, no such standards exist in the United States.
  
  ADA and IPC/UPC Standards for Fountains
  Fountains are affected by two additional standards: model plumbing codes and the Americans with Disabilities Act (ADA). Model plumbing codes, such as the International and Uniform Plumbing Codes (IPC and UPC), specify the number of drinking fountains required in public buildings and spaces. The ADA addresses design features of fountains, requiring them to be accessible to wheelchair-bound or disabled persons. Fountains must have a certain amount of knee and toe clearance and limits are set on how high the fountain stream can be set.

Other Organizations

Association for the Advancement of Sustainability in Higher Education (AASHE), Sustainability Tracking, Assessment and Rating System (STARS)
The STARS program is a voluntary self-assessment undertaken by many colleges and universities to track relative progress toward sustainability.  Universities receive “credits” based on their performance in three categories: Education and Research, Operations, and Planning, Administration and Engagement.

While there are no specific categories pertaining to bottled water in STARS, such an initiative could help earn existing Operations credits.  For example, Operations Credit 17: Waste Reduction recognizes the reduction “of the use of materials in the first place...and the total amount of materials discarded… (AASHE, 2009).”  The reduced waste resulting from a bottled water ban can be included in this category.  Colleges and universities can receive a maximum of five points from this credit by reducing waste by 50 percent or more relative to their 2005 baseline.  For reductions under 50 percent, a formula, which measures waste reduction by campus users, is used to award points (to calculate the amount of waste reduced by eliminating bottled water in terms of plastic, energy, water and oil saved, use RPN’s Bottled Water Calculator).

In addition to receiving credits from other related categories, colleges and universities can earn an “Innovation Credit” for “new, extraordinary, unique, ground-breaking, or uncommon outcomes, policies, and practices (AASHE, 2009)” that greatly exceed the criteria of a STARS credit or is not covered elsewhere in STARS.  The elimination of bottled water could possibly earn a credit in this category as well.

For more information on the STARS program and how your college or university can become involved, visit http://www.aashe.org/.

 

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This work by the Responsible Purchasing Network is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 United States License.