Do Not Copy Paperwork: (back)
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! (back)
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 (back)
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 (back)
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 (back)
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 (back)
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.
Bromide Detection Level: (back)
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: (back)
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. (back)
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. (back)
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 (back)
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 (back)
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 (back)
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 (back)
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.
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.
New Source = New Testing: (back)
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: (back)
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: (back)
Quarterly Testing for Bromate, Bromide and ChlorideFor 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). (back)
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 (back)
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.