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Regulations for D/DBPs:
Disinfectants and Disinfection
By-Products
On March 28, 2001, the U.S. Food and Drug Administration (FDA) published a
Direct Final Rule for Disinfectants and Disinfection Byproducts (D/DBPs) in
the Federal Register.
On July 5, 2001, the FDA confirmed the effective date of January 1, 2002 for
the D/DBPs final rule. Therefore, bottled water "on the shelf" as of January
1, 2002 must be in compliance for D/DBPs regulations.
Basically, the FDA has stated that although bottled water on the shelf as of
January 1, 2002 would be out of compliance if it does not comply with the
bromate MCL, the FDA does not currently intend to take any action such as an
off-the-shelf study.
However, if any other organization should decide to perform such a study,
non-compliance could result in the need for a recall.
The rule establishes allowable levels for the following: |
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* Awaiting FDA and
state guidance regarding methodology, certification and frequency of
testing requirements.
The rule also revised allowable levels for the DBPs Total
Trihalomethanes (TTHMs) to an MCL of 0.080 mg/l.
Source Water Requirements
Only sources which are treated with chlorine-based disinfectants or
ozone will require testing for DBPs and residual disinfectants.
Bottlers using public water supply (PWS) sources and those receiving
source water via disinfected tanker transport would be required to do
this testing.
Frequency of Testing
For 2001, the IBWA is requiring quarterly bromate and bromide testing
on all types of finished product water and quarterly bromide and
chloride testing on all types of source water (including municipal
sources).
As of January 1, 2002, the FDA will be requiring testing "at least"
annually on all types of finished product water and chlorinated or
ozonated sources for the D/DBPs. We are awaiting clarification on
frequency of testing from the FDA.
Some states are expected to require quarterly bromate/bromide
monitoring but we are still waiting for more information.
Sources of Contaminants
Bromate can be formed when bromide, a naturally occurring inorganic
ion, is exposed to ozone.
THMs & HAAs are formed as a result of chlorine disinfections. They are
formed when chlorine reacts with organic matter in the water. TTHMs is
the sum (in mg/l) of the concentration of the trihalomethane
compounds:
Trichloromethane
(chloroform) Dibromochloromethane
Tribromomethane (bromoform) Bromodichloromethane
Chlorite is a
disinfection by-product which is formed as chlorine dioxide
decomposes.
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