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SAMPLE COLLECTION
Do Not Copy Paperwork:
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The forms we send out to customers to complete and send in with samples
includes information that the laboratory uses to log your samples into our
computer system. There are report codes and order numbers which have a
specified number of samples assigned per the order you placed. It causes
processing delays when paperwork is copied and more samples are submitted
than initially ordered. Therefore, if you need additional forms, please call
your laboratory representative.
Flush, Flush...and Flush Again!
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Your Spring Source water analysis comes up clean. Your Spring Finished
Product water analysis has minimal detections of THF and/or MEK. Your
Distilled Finished Product water analysis has even higher detections of THF
and/or MEK. Sounds like you recently installed new PVC pipe going to the
filler. Since the distilled water is more aggressive, it picked up even more
of the chemicals found in the compound used to fuse the sections of PVC pipe
together. These lines must be flushed extremely well to avoid contamination
of your finished product water. You may even want to do a preliminary VOC
analysis of your purest product water run through the new lines before
production resumes and/or before you submit samples for your annual analysis
which you will be submitting to regulators.
** As always, don't forget to have MSDS sheets on file for any compounds,
chemicals, cleaners, etc. used anywhere in your facility.
Hold Your Water
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When you send your finished product water samples to the laboratory for
analysis, you should keep some water on hand from that same batch of
production until you receive completed test results. Circumstances may
arise, such as shipping delays, power outages, or equipment failure, which
make it necessary to "resample". When you have to submit additional samples,
they should come from the same production code as the original samples.
Latex Gloves
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Wearing latex gloves for collecting your bacteria samples may offer extra
protection from bacterial contamination of your water samples during
collection. However, they should be removed before filling the rest of the
bottles for your annual testing. Adipates and phalates are plasticizers
found in latex. These contaminants could show up in water if it comes in
contact with the gloves. (Another possible source of contamination would be
cap liners.) Reduce contamination risks by: washing hands, rinse them
thoroughly to remove soap residue, and fill bottles carefully.
Tape on Your Bottles
If you're trying to be diligent in packaging your finished product bottles
for shipment to a laboratory by taping the cap to avoid leakage, you may
end up with toluene detections in your test results. Chemicals in the
tape's adhesive may leech through the plastic cap and contaminate the
water sample.
Give Up the Bottle
Although your three and five-gallon bottles are valuable, trying to save
money by sending your worst bottles to the lab could cost you more in the
long run. Dirty bottles put through a rigorous cleaning may result in
detections of chemicals on your test results. If you are not sending new
bottles, be sure (as always) you only use food grade approved cleaners on
your bottles according to proper instructions. Remember - care enough to
send the very best.
QUALITY CONTROL
Bromide Detection Level:
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If you believe your water does not have bromide based on the results
included on your full annual test report, you may be mistaken. Look at the
detection level. If the detection level (det. level) is not 0.005 mg/l or
lower, this test is not providing you with enough information. Bromide is
a parameter that has historically been included in our annual test
packages (and probably those of other labs) but it was by method 300.0 at
a detection level of 1 mg/l which is not low enough to determine if a
problematic level exists.
FYI: New Applications for New York Require Bromate and Bromide Results.
Potential Solutions for Minimizing Bromate in Finished Product Water:
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Treat water using RO or Distillation:
Utilizing water treatment such as RO or distillation removes the bromide
precursor. The disadvantage is that these treatments also remove other
inorganics as well. Utilizing RO or distillation would prohibit the
product from being labeled as "spring", "artesian" or "mineral".
Eliminate Ozone as a Treatment Process:
Removal of ozone from the treatment process should only be done with
extreme caution. If ozone is not used bromate will not be formed. Ozone
should never be reduced unless a bottler has carefully evaluated all
potential sources of microbial contamination including the source,
facilities, environment, and packaging materials.
Reduce and Control Ozone:
Reducing and controlling ozone may allow some bottlers to achieve
compliance with the bromate regulated allowable levels. Bottlers
experiencing bromate conversion could consider the following: reduce ozone
concentrations; only ozonate immediately prior to filling; replace other
ozonation points with UV and microfiltration; install in-line equipment to
monitor ozone levels; and install ozone generation control systems.
pH adjustment by CO2:
Lowering the pH by injecting CO2 into the product water immediately prior
to ozonation may minimize bromate formation while maintaining the
effectiveness of ozone as a disinfectant. Challenges with this solution
include control of CO2 and potential off taste issues.
Ozone followed by UV destruct:
Stop the oxidation of bromide to bromate after disinfection using
ultraviolet light (UV). This can minimize conversion of bromide to bromate
in the bottle. The disadvantage of this option is that ozone residual in
the bottle would also be reduced.
Add minerals, not bromide.
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If you add minerals to your water, be sure to get documentation from your
supplier that the ingredients meet USP standards. Ingredients such as sodium
chloride, calcium chloride, potassium chloride, etc. may contain bromide if
they are not USP grade.
Prevent
your customers from contaminating your water.
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Improper storage of finished product water and/or using inappropriate
cleaners on water coolers can lead to contamination of the water. Some
customers have been known to store the 5-gallon bottles of water for their
coolers in the garage where they also have gasoline or other substances
which produce fumes. It is also baffling how someone chooses a cleaner for
their cooler. It may be wise to advise your customers (in writing) about
proper care and storage to minimize complaints of strange taste or odors in
the water.
Low pH
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Purified and Distilled product water will typically have a pH lower than the
range specified by the EPA of 6.5 to 8.5 for drinking water. Although those
of us in the water industry are aware of this, your customers may question
it. If a customer request a copy of your test results and questions a low pH
level, we can provide you with a notice on our laboratory letterhead which
states that the pH of Purified or Distilled water falls in a lower range due
to the nature of the water. Simply give us a call if you need this type of
documentation to provide to your customers.
UV Light Housing
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In your routine cleaning program, don't forget your UV light housing. A
biofilm can develop in the housing causing a potential source of bacterial
contamination as well as interfering with the effectiveness of the UV
lights. Contact your supplier to find out how frequently the housing should
be cleaned.
Leaking Bottles
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At the last NEBWA convention, I heard of a bottler who was experiencing
leaks in 5-gallon bottles. As it turned out, the bottles were being damaged
when they were removed from the delivery truck. When the driver pulled a
bottle from the top of the rack, he was pulling down before pulling the
bottle completely out of the rack. This was creating a small kink or crease
in the side of the bottle. The problem was not immediately detected since
the bottle did not leak right away. This weakened spot began to leak after
the bottle was brought back to the plant and refilled.
Water Cooler Cleaning
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If you bring your customers' water coolers into your facility for routine
cleaning, be careful about the environment and the cleaning products you
use. Phenols and other VOC's detected in your test results may come from
cleaning products used near your bottling lines or in a room which shares
ventilation with your bottling room.
MSDS
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Keeping Material Safety Data Sheets (MSDS) on file for all cleaning products
and chemicals used in your facility is crucial. They will come in handy when
trying to track down the culprit if any chemicals are detected in your water
analysis.
REGULATORY
New Source = New Testing:
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When changing sources for any of your products, don't forget to perform
annual tests prior to selling product. A full annual test should be
performed on the new source (if it is not municipal) and each finished
product from that source. Bottlers can save money by switching sources
around the time their annual tests are due. Many states require approval
prior to switching, so don't forget to contact state regulators where your
product is sold well in advance of any changes to allow time for the
approval process.
IBWA Members Reminder:
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You must notify IBWA that you are complying with quarterly bromate & bromide
testing requirements. Don't send results - just a letter stating monitoring
requirements are being met.
Also, get your new CPO manual if you have not done so. There may be updated
information you are missing which could be covered on an exam.
IBWA MODEL CODE UPDATE:
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Quarterly Testing for Bromate, Bromide and Chloride
For 2001, the IBWA is requiring quarterly bromate and bromide testing on
finished product water and quarterly bromide and chloride testing on source
water. This recommendation is prompted by the limit for bromate in drinking
water of 10 ppb (0.010 ppm) established by the EPA. The FDA and the Canadian
government are now expected to add Bromate to the regulations for bottled
water analysis.
Although bromate testing is not yet required by the FDA, it is advisable for
bottlers to determine if they are at risk so they can address potential
problems before regulations go into effect. Test results which reflect that
no problem exists, will also be useful documentation to have on hand to
address customer inquiries.
Call your laboratory representative right away to schedule your testing so
four consecutive quarters of testing can be completed within the required
time frame.
Licensing a New
Spring Source in New York State
(with a borehole).
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If you are collecting your spring water through a borehole and plan to get
licensed in the state of New York, you must prove the water from the
borehole is the same matrix as the water from the natural spring orifice.
Samples from both the natural orifice and the borehole must be collected on
the same day and analyzed by a certified laboratory for the state specified
list of parameters. Consult your laboratory representative for more
information on how to proceed with this analysis.
Consumer Confidence & Your
Label
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In light of a recent article which sighted bottled water companies as
unresponsive to consumer inquiries, the IBWA urges bottlers to include their
telephone number on the label and respond promptly to inquiries. Lack of
response may lead customers to believe you have something to hide.
Attention Texas Bottlers:
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Due to a misunderstanding at the Texas bottled water regulators office, you
may have received a list of laboratories whose results will be accepted by
the state that did not include National Testing Laboratories. We spoke to
the state and they assured us that this was an oversight and NTL's results
are accepted by the state of Texas. As an extra measure, we will be mailing
a letter to our Texas bottlers with our certification numbers for you to
keep on file with your reports. Our certification numbers also appear on
each report.
As with any issue, if an inspector questions anything on your test results,
call us immediately while the inspector is still there so we can address the
question for you. You can reach Kristin at 800-458-3330 ext. 215 or Barb at
ext. 217. If you get our voice mail, dial "0" for the operator, let her know
you have a regulator there, and ask her to find one of us immediately.
In our experience, when a regulator or inspector questions a report or is
looking for some result you seem to be missing, it is often easy to clarify
where the data can be found on the reports. For example, some parameters may
be known by more than one name and the inspectors list may use different
nomenclature. Therefore, we like to be able to address these situations for
you as soon as they come up to avoid confusion. NTL is committed to
supporting our customers to the best of our ability.
New York's Bottled Water
Regulators
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They Moved! In the process of updating our regulatory files, we discovered
the office for the New York bottled water regulator has moved. We thought we
would share this information with those of you who may have missed it.
Public Water Supply Protection
Planigan S-uare, 547 River St.
Troy, NY 12180-2216
Phone: 518-402-7676
Fax: 518-402-7689
Recertification & regulations
Paul John or Cecilio Gracias
New applications & general questions:
Richard Bonczek
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