Canadian consumers drank 60 litres of bottled water per person in 2005, more than double than in 1999.[1] But do you know what you are drinking? What is actually in bottled water? And can you tell from the label?
Labelling
Many people buy bottled water, believing that it is safer than tap water. In fact, the major difference between bottled water and municipal tap water is that we know less about what is in bottled water. In the US, an Environmental Working Group (EWG) investigation of almost 200 popular bottled water brands found less than 2 percent disclose the water’s source, how the water has been purified and what chemical pollutants each bottle of water may contain. Just 2 of the 188 individual brands EWG analyzed disclosed those three basic facts about their water. See Most Bottled Water Brands Don’t Disclose Information About Source, Purity and Contaminants, http://www.ewg.org/health/report/bottledwater-scorecard/news-release and http://www.loe.org/shows/shows.htm?programID=09-P13-00028 .
The same is likely true in Canada, except in Quebec.
Municipal water is subject to frequent and detailed testing, and the source of the water is public. In most provinces, test results for municipal water are easily accessible to the public. Edmonton, for example, publishes daily, monthly and annual water quality reports, including details on dozens of parameters from bacteria to lead: http://www.epcor.ca/en-ca/Customers/water-customers/water-quality-reports/Pages/default.aspx . Most provincial water quality standards, such as Ontario’s Drinking Water Quality Standards regulation[2] under the Safe Drinking Water Act, 2002 (SDWA), set maximum limits for microbiological, chemical and radiological parameters for all drinking water in the province. But these rules don’t apply to bottled water.
Bottled water is regulated, much less tightly, under the federal Consumer Packaging and Labelling Act and Regulations. The source of the water need not be disclosed, unless it is labelled as “spring” or “mineral” water. (Many bottled waters are actually tap water. For example, Dasani (owned by Coca-Cola) is filtered municipal tap water, bottled in Brampton, Ont., and Calgary. Pepsi’s Aquafina, is essentially the same. Both companies pay less for municipal water, by the way, than consumers do.)
The bottle label need only include:
- · Common name (e.g., “water”)
- · List of ingredients, if more than one
- · Net quantity
- · Name, address of responsible company
- · Fluoride content
- · For all bottled waters, except spring or mineral water: description of any treatment the water has received (e.g., chlorination, filtration)
- · For spring or mineral water: dissolved mineral salt content, statement as to whether ozone or fluoride has been added, and geographic location of underground water source.
Thus, bottled water in most of Canada may contain undisclosed levels of many health-related parameters that municipal tap water providers must measure and control, such as metals (eg mercury, lead), nitrites/ nitrates or sodium.
What else could be in bottled water?
Bottled water that looks clean could actually contain lots of things. Drinking water in general is vulnerable to contamination by chemicals (e.g., lead, arsenic benzene), microbes (e.g., bacteria, parasites) or physical hazards (e.g., particulate matter).[3]
In its 2008 Guidelines for Drinking-Water Quality, [4] the World Health Organization noted that bottled water may contain glass and metal bits. Bromate, a possible carcinogen, may form when ozone is used as an oxidant prior to bottling.[5] Minute quantities of chemicals like bisphenol-A (BPA) may leach from some types of plastic bottles. [6] Since bottled water may be stored for long periods, microbes that are not usually a public health concern can grow to significant concentrations, posing uncertain risks to vulnerable populations like immuno-compromised individuals, pregnant women and infants. (Expiry dates are not required on labels in Canada, although most products have a 2-year shelf life.[7] That makes it hard to know how old a bottle is.)
What isn’t in bottled water?
Then there is the fluoride question, which many bottled waters lack. The fluoride debate is a heated one, with the Canadian Dental Association opting for fluoride based on anecdotal reports correlating increase in cavities and use of bottled water and oral hygienists verifying that fluoride reduces the incidents of decay. The International Council of Bottled Water Associations denies that fluoride reduces decay, and argues that fluoride can discolor the teeth.
Do we enforce the laws we have?
The laws on municipal drinking water safety have been heavily enforced since Walkerton. In contrast, the laws on bottled water labelling have barely been enforced. According to the CFIA, it didn’t launch a single prosecution relating to bottled water in the past four years. The only reported conviction we found was a 2003 case, in which a bottled water distributor pleaded guilty to selling water falsely labelled as “spring water”; he was fined the modest sum of $5,000.[8]
The CFIA is slightly more active in issuing health hazard alerts. In 2007, for example, there were two, both for Armenian mineral waters that contained hazardous levels of arsenic.[9][10] Hazardous levels of arsenic were not found anywhere in Canadian municipal tap water.
Are we doing anything about all this?
Health Canada says it is doing something about bottled water, but progress is slow. In 2002, the Canadian Food Inspection Agency and Health Canada circulated a discussion paper with promises to update the laws on bottled water[11], especially labelling and limits for arsenic and lead. It admits that Canadian laws require updating to incorporate new scientific knowledge, to harmonize with standards used in Quebec, the US and the Guidelines for Canadian Drinking Water Quality (CDWQ),[12] and to better protect consumers. But nothing has been done.
One solution would be to adopt international standards on bottled water. One of the purposes of the international Codex Alimentarius[13] was to develop food standards that protect consumer health. Two of these standards, the GeneralStandard for Bottled/Packaged Drinking Waters (other than natural mineral waters; 2001) and the Standard for Natural Mineral Waters (1981) are available to regulate bottled water,[14] but neither is being used in Canada.[15]
Quebec stepped into the gap with its Regulation Respecting Bottled Water,[16] a comprehensive rule for the distribution of bottled water in the province. It requires a hydrogeological and vulnerability study of source waters for spring and mineral waters; detailed chemical, microbiological and radiochemical information, and standard labels. This is a great precedent that other provinces should follow.
Elsewhere in Canada, the Canadian Bottled Water Association has a model Code, April 2009, that it asks its members to follow.[18] The Code states that “natural water”, i.e., that obtained from an underground or approved natural source, must comply with maximum allowable concentrations of parameters defined in the CDWQ Guidelines.[19] The Code also sets out rules for product quality as well as good manufacturing practices, storage, handling and testing, as well as operational requirements that include bottlers submitting a hydrogeologic report that shows the integrity of the source water supply. It includes monitoring source water and the final product for contamination. Unfortunately, no one enforces this Code.
Bottom line
When we drink municipal water, we can tell where the water came from, how it has been purified and what chemical pollutants it contains. And all three of these key quality measures is closely regulated by the provinces. When it comes to bottled water, we are relying primarily on the good will of the industry itself. Is that good enough for you?[20]
By: Dianne Saxe and Jackie Campbell
[1] CBC news – Bottled Water – August 20, 2008 at http://www.cbc.ca/news/background/consumers/bottled-water.html
[2] O.Reg. 169/03
[3] WHO Bottled Drinking Water – October 2000 (fact sheet). At http://www.who.int/mediacentre/factsheets/fs256/en/
[4] At http://www.who.int/water_sanitation_health/dwq/fulltext.pdf
[5] WHO guidelines at 315
[6] Health Canada FAQ at http://www.hc-sc.gc.ca/fn-an/securit/facts-faits/faqs_bottle_water-eau_embouteillee-eng.php
[7] CFIA Food Safety Facts on Bottled Water. At http://www.inspection.gc.ca/english/fssa/concen/specif/bottwate.shtml
[8] From http://archives.foodsafety.ksu.edu/fsnet/2004/1-2004/fsnet_jan_7.htm#story3
[9] CFIA – Health hazard alert – Arsenic In Ark Land Brand Naturally Carbonated Mineral Water. March 14, 2007. At http://www.inspection.gc.ca/english/corpaffr/recarapp/2007/20070314ce.shtml
[10] CFIA – Health hazard alert. Excessive Levels Of Arsenic In Jermuk Classic Brand Natural Sparkling Mineral Water. March 9 2007. At http://www.inspection.gc.ca/english/corpaffr/recarapp/2007/20070309be.shtml
[11] Making it Clear – Renewing the Federal Regulations on Bottled Water: A Discussion Paper. August 2002. At http://www.hc-sc.gc.ca/fn-an/consultation/init/bottle_water-eau_embouteillee_tc-tm-eng.php
[12] A summary table of the guideline is at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/sum_guide-res_recom/index-eng.php and technical documents are available at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/index-eng.php#tech_doc
[13] which was established in 1963 by the WHO and the UN’s Food & Agriculture Organization
[14] Access via Codex Alimentarus Official Standards – FAO/WHO Food Standards http://www.codexalimentarius.net/web/standard_list.jsp
[15] Health Canada. Codex Alimentarius in Canada. http://www.hc-sc.gc.ca/fn-an/intactivit/codex/index-eng.php
[16] c. P-29, r.1.1
[18] http://www.cbwa.ca/en/modelcode_files/CBWA%20Model%20Code%20-%20April%202009.pdf
[19] A summary table of the guideline is at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/sum_guide-res_recom/index-eng.php and technical documents are available at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/index-eng.php#tech_doc
[20] Gleick PH. The myth and reality of bottled water, in The World’s Water, the Biennial Report on Freshwater Resources: 2004-2005, Island Press. At http://www.pacinst.org/topics/water_and_sustainability/bottled_water/myth_and_reality.pdf
{ 3 comments… read them below or add one }
Nestle, a major vendor of bottled water, doesn't agree with my comments. See below, (two posts):
There are considerable differences between government regulations regarding bottled water quality, recycling rates for bottled water and marketing requirements for bottled water in the United States and Canada. I have attached some information, all footnoted, that may be of assistance to you, in future.
I have also provided some factual information in response to some of the specific commentary in your article. It is as follows:
"Many people buy bottled water, believing that it is safer than tap water. In fact, the major difference between bottled water and municipal tap water is that we know less about what is in bottled water."
This is incorrect. According to Health Canada, which regulates bottled water as a food under the Food and Drugs Act, all bottled water must carry the following basic labelling information: common name, net quantity, name and address of the responsible company, list of ingredients if it consists of more than one ingredient, nutritional information, and – fluoride ion content. The following additional information must be on the label spring and mineral water: dissolved mineral salt content, statement indicating whether ozone or fluoride has been added, and statement relating the geographic location of the underground source of the water. The label of bottled water, other than spring or mineral water, must also include a description of any treatment the water has undergone.
"Most provincial water quality standards, such as Ontario's Drinking Water Quality Standards regulation under the Safe Drinking Water Act, 2002, set maximum standards for microbiological, chemical and radiological parameters for all drinking water in the province. But these rules don't apply to bottled water."
This is incorrect. Bottled water is held to the same scrutiny as tap water. By law, Health Canada regulations for bottled water must be as strong and protective of public health as Ontario Ministry of Environment regulations for tap water. Bottled water is regulated as a packaged food product by Health Canada through the Food and Drug Act. With respect to regulation, the Regional Municipality of Waterloo, for example, reported on September 9, 2008, that it did 10,000 tests on its water supply in 2007. Nestlé Waters Canada performs more than 1,700 tests on its water supply daily at its Aberfoyle plant or more in one week than Waterloo Region does in one year. A copy of our testing activities is available upon request. Testing is also conducted via surprise inspections by the Canadian Food Inspection Agency, Health Canada, the Canadian Bottled Water Association and NSF. Nestlé Waters Canada takes a multi-barrier approach to water safety. The Company subjects its finished products and source water to microbiological analysis every day that exceeds the microbiological requirements outlined in the Safe Water Drinking Act, which governs both municipal tap water and bottled water. The Company is required to test for 160 compounds in both source and finished product for coliform, E-coli (daily), coliform, E-coli (weekly), chemicals (quarterly) and metals, chemicals and minerals (annually). Water samples are also sent to a third party independent lab for analysis every week. Basic chemical and physical analysis of bottled water is completed daily. Annually, we conduct a full spectrum analysis on each water source for primary inorganics, secondary inorganics, radiologicals, volatile organic compounds, organics, disinfection byproducts, pesticides, herbicides, physical contaminants as well as several other potential chemical contaminants. In addition to the tests identified above, there are many on-line quality checks performed by our operators on an hourly basis to ensure the chemical, microbiological and physical safety of the finished goods produced at our plants. Our testing levels meet or exceed all requirements of Health Canada and other governing bodies. The annual monitoring reports are conditions of our permits and are submitted to the province and other public agencies. As such, they become public documents upon receipt.
I don’t know about Nestle’s water… I just saw a test done on a bottle of Nestle water and the amount of “stuff” that was separated from the bottle water and turned black – was disgusting… Sorry – but I don’t think I will drink bottled water again…
Nestle second post:
"What else could be in bottled water? Bottled water that looks clean could actually contain lots of things. Minute quantities of chemicals like bisphenol-A may leach from some types of plastic bottles."
This is incorrect. Bisphenol A is not used in the production of PET-based plastic beverage containers used by the bottled water industry — a fact Health Canada confirmed in its recent study on the matter.
"The laws on municipal drinking water safety have been heavily enforced since Walkerton. In contrast, the weak laws on bottled water labelling have barely been enforced. According to the CFIA, it didn’t launch a single prosecution relating to bottled water in the past four years. The only reported conviction we found was a 2003 case, in which a bottled water distributor pleaded guilty to selling water falsely labelled as “spring water”; he was fined the modest sum of $5,000."
This is incorrect. CFIA inspected 85 percent of the industry, by marketshare, last year. The fact that there are few if any convictions since 2003 is not a reflection of weak regulations or a lack of enforcement. It is a reflection of the fact that government is working hand-in-hand with the Canadian bottled water industry to deliver a safe product to consumers.
"Health Canada says it is doing something about bottled water, but progress is slow. In 2002, the Canadian Food Inspection Agency and Health Canada circulated a discussion paper with promises to update the laws on bottled water, especially labelling and limits for arsenic and lead. Elsewhere in Canada, the Canadian Bottled Water Association has a model Code, April 2009, that it asks its members to followUnfortunately, no one enforces this Code."
This is incorrect. Government regulations for bottled water have been revised since 2002. Lead is not permitted to be present in bottled water. I would recommend that you contact Health Canada to receive its regulatory updates and to confirm its views on the presence of lead. CBWA members, who make up 85 percent of the Canadian bottled water industry by marketshare, are subject to surprise annual inspections by NSF International, the foremost independent testing facility in the world.
"When we drink municipal water, we can tell where the water came from, how it has been purified and what chemical pollutants it contains. And all three of these key quality measures are closely regulated by the provinces. When it comes to bottled water, we are relying primarily on the good will of the industry itself."
This is incorrect. Bottled water is held to the same scrutiny as tap water. According to Health Canada: “Consumers should be aware that bottled water is as safe to consume as tap water from a microbiological quality and chemical safety standpoint.” Bottled water is regulated as a packaged food product by Health Canada and the Canadian Food Inspection Agency through the Food and Drugs Act.
Dianne, should you have any further questions, comments or concerns, please contact me at your earliest convenience.
Thanks!
JC
<<CC-4d) The Safety of Bottled Water (EG FR) Health Canada.pdf>> <<In the Know_FINAL.pdf>> <<The Facts About Bottled Water – July 2009.pdf>>
John B. Challinor II APR
Director of Corporate Affairs
Nestlé Waters Canada
101 Brock Road South
Guelph, Ontario N1H 6H9
Telephone: 1 888 565-1445, Ext. 6441 (B)
Telephone: (519) 767-6441 (Direct)
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