Challenges and the practical issues with enforcing the Regulations

1. Challenges and the practical issues with enforcing the Regulations Kathy Griffiths, Chartered Environmental Health Practitioner

2. Law specifically relevant to bottled water... • The Natural Mineral Water, Spring Water and Bottled Drinking Water Regulations 2007 • They are relevant to all water other than tap water

3. Natural mineral water: • Is microbiologically wholesome • Emerges from a spring or tapped via a borehole from aquifer • Nature is preserved intact • Is characterised by its mineral content • Must be bottled at source

4. Water Sources • They are a water company’s lifeblood • Water sources must be protected against deliberate and unintended contamination • They must be protected from surface water

5. Parasites • Examples include Giardia and Cryptosporidium • Come from cattle, sheep & wildlife • These have been a serious problem in some tap waters but are not found in UK bottled waters • The BWCA requires a 1 micron filter on bottling lines • Care is needed when changing filters

6. Source Protection

7. Inside the well protection building… • Everything washable • Protected from pests • Security from other intruders • Frequent monitoring of the water • Water protected from the air

9. Reg 16 - Checking and Enforcement • Relevant authority must: • Look periodically on recognised NMW to check composition, temp and that “essential characteristics” remain stable

10. Sampling Water from source -how often? • FSA recommend at least once a year • Also recommend that bottler tests water daily for micros, chemical and physical parameters • Bottlers don’t always send LA’s the results • Take great care with samples and sampling technique

11. For the period of 12 hours following bottling • The total colony count of water at source shall not exceed-(i) 100 per ml at 20 to 22°C in 72 hours; and(ii) 20 per ml at 37°C in 24 hours; and(b) water shall be maintained at a temperature of 4°C +/- 1°C. • How does that relate to bottled water in shops?

13. Water from Coolers

15. Potential Problems with Bottled Water Coolers… • They need sanitising regularly – the BWCA states every 13 weeks • Once a bottle is positioned on the cooler the water should be drunk ideally within 3 weeks • Algae can grow if the cooler or water is in sunlight • Consumers often misuse coolers – thinking drip trays are connected to a drain etc. • Consumers may try to re-fill the bottles themselves

19. Ozone • It’s a gaseous disinfectant • It kills bacteria and can oxidise pesticide residues • It breaks down quickly to oxygen • It can be a good back up for bottle washing and can be used to sanitise coolers and pipework …but… • You still have to pre-clean the cooler before ozonating it • It can be harmful if health and safety precautions are not followed • Over ozonation of water can cause high bromate levels • It’s not allowed for spring or natural mineral water

20. Containers and Closures… • Closures must be designed to avoid the possibility of adulteration or contamination • Containers and closures must be made from food safe materials • Bottlers must have info on file and keep traceability details • Media scrutiny about • Antimony with PET bottles, • bisphenol A (BPA) from PC bottles

21. There are of course always the worriers and water seems to fascinate them

22. Another interesting development by restaurants… • Take ordinary tap water, pass it though a series of filters • Add some (optional) carbon dioxide • Bottle it • Charge as much as if you were selling “normal” bottled water • It has now become bottled drinking water

24. There must be a catch… • A maintenance contract with the installer is needed to keep the filters working and replaced regularly. • The bottles need cleaning properly. They must be washed vertically in dish washers - if they are just laid on the tray they will not be cleaned. • The taps used for filling the bottles and the rest of the equipment need looking after and kept clean. Just because the treatment unit looks clean and shiny doesn’t mean you can forget about it.

26. Personal hygiene • The person filling the bottle must be as well-trained and hygienic as they are when they are producing food. • Proper, enthusiastic hand washing remains the number one priority. • Restaurants with one of these need to make sure they understand what it does and when it needs servicing. • Be safe, not sorry, water is a great carrier of germs from unwashed hands to unsuspecting tummies.

27. For the future… • David Clapham is trying to set up a group of interested EHP’s who have water bottling plants in their area and would like to discuss common issues with others • If you haven’t made contact with him yet… David.clapham@bradford.gov.uk

28. And finally… As Benjamin Franklin said: In wine there is wisdom, In beer there is freedom, In water there is bacteria.