QUESTIONS AND ANSWERS ON BOTTLED WATER

The issue of bottled water has recently evoked a great deal of interest and concern both from media and consumers. In this regard, the Health Protection Branch would like to offer the following responses to a number of questions posed concerning the quality of bottled water sold in Canada.

Q1: What is Bottled Water?

A1: Bottled water is regulated as a food under the Canadian Food and Drug Regulations. Bottled water is water sold to consumers in sealed containers. It can be represented as "spring" or "mineral" or is simply water from various sources that could have been treated to render it fit for human consumption and put in sealed containers for sale. Both categories of water are differentiated as follows:

Mineral or spring water is water obtained from an underground source but cannot come from a public water supply. Mineral water is spring water with a larger amount of dissolved mineral salts, usually above 500 milligrams per litre of total dissolved solids. The mineral content of spring water usually varies between 20 and 500 milligrams per litre.

Bottled water, other than water represented as mineral and spring, is water from any source that can be treated by carbonation, ozonation and/or irradiation to eliminate most bacteria. Some bottled water are simply water from a community water supply that is bottled for sale. The treatments applied to water must be identified on the label. Therefore, water can be "carbonated" or "sparkling", "deionized", "demineralized", "distilled", "fluoridated". See Table 1.

Q2: Why has there been such an increase in the consumption of bottled water?

A2: This is a matter of taste and preference for bottled water.

Q3: Are there bacteria in bottled water?

A3: In some cases, yes. "Natural" waters are sold, especially in Europe, with the understanding that the naturally safe bacteria are still present. Generally, bottled water are not sterile products unless so identified and meet the required criteria (i.e. sterile water used to dilute medicinal ingredients or prepare infant formula if recommended to do so.) Like most foods, bottled water can contain naturally occurring bacteria and bacteria introduced during processing, which under improper and/or prolonged storage conditions can increase in numbers to levels that MAY be harmful to health, especially for susceptible populations (see Question 13). Refrigeration of the smaller bottled water and use of refrigerated water coolers for 18 L sizes are effective means to minimize microbial growth.

Other bottled water can contain very little or no bacteria (Table 2) because they have been undergone a disinfection step, such as ultra-violet (UV) irradiation, carbonation, or ozonation.

Q4: Can drinking water be a source of illness?

A4: Yes. Water from wells and other sources, can contain pathogens such as bacteria, parasites and viruses. Similarly, bottled water can contain these contaminants. Illness caused by bottled water is very rare, although published reports have shown that improperly manufactured bottled water was the causative agent in cholera and typhoid outbreaks, as well as in "Traveller’s Disease". To the best of our knowledge, NO WATERBORNE DISEASE OUTBREAKS HAVE BEEN ASSOICIATED WITH THE CONSUMPTION OF BOTTLED WATER IN CANADA.

Q5: What are the government regulations on bottled water?

A5: As mentioned earlier, in Canada, pre-packed water (bottled water) is a food and thus is regulated under Division 12 of the Food and Drug Regulations. Water represented as mineral or spring water is a potable water obtained from an underground source, but cannot come from public water supply. To be potable, mineral or spring water should not contain any coliform bacteria. Other bottled waters may undergo a variety of treatments and should meet the regulatory requirements of Division 12 for coliform and aerobic bacteria (Table 3). The aerobic colony count (ACC) standard, in addition to the coliform standard, was established for treated bottled water in 1980, and these are also outlined under Division 12 of the Food and Drug Regulations. The treatments applied to bottled water must be declared on the label.

It should also be remembered that pre-packaged ice must also comply with the provisions of Division 12. Because they are foods, pre-packaged water (bottled water) and ice must also comply with all of the provisions of the Canadian Food and Drugs Act. For example, they must comply with the general prohibition of Section 4 of the Act which states:

No person shall sell an article or food that:

is unfit for human consumption;

consists in whole or in part of any filthy, putrid, disgusting, rotten, decomposed or diseased animal or vegetable substance;

is adulterated; or

was manufactured, prepared, preserved, packaged or stored under unsanitary conditions.

Q6: Could bottled water be manufactured from tap water?

A6: Yes, municipal water is considered and "approved source" (Table 1). It is conceivable that bottled water, such as demineralized water, is simply tap water which has undergone a process to lower the mineral content. Similarly, this water so-represented could also be mixed with water from some other source. The term "demineralized" simply means that the water has undergone a demineralization process; i.e. the mineral content of the water has been reduced, and does not reflect the original mineral content of the source. See Table 2.

Q7: Who checks bottled water? How often?

A7: Bottled water is classified as a food and therefore it is subject to the same surveillance that would apply to any food commodity marketed in Canada. The Canadian Food Inspection Agency (CFIA) conducts and on-going program, including inspection of domestic bottled water manufacturers as well as sampling and analysis of both domestic and foreign products, to ensure that bottled water sold in Canada meets the requirements of Division 12 and thus is safe for human consumption. If the results of surveillance activities show that Canadian standards are not met, appropriate actions are taken to correct the situation, including subsequent follow-up with the manufacturer or the importer. The monitoring programs have, for the most part, focussed on the bacteriological quality of products available in the marketplace. The results form these monitoring activities indicate that the majority of products tested were in compliance with Canadian regulations. Some provincial and municipal agencies also conduct some surveillance of bottled waters. In addition, manufacturers that are members of bottled water associations must follow specific requirements to ensure quality of their products.

Q8: What kind of license is needed to start bottling?

A8: Under the Canadian Food and Drugs Act and Regulations, no license is required to sell bottled water. However, as soon as the product is offered for sale, it would be subject to inspection by CFIA field personnel. Questions concerning licensing requirements under provincial or municipal regulations should be directed to the respective agencies.

Q9: Can buyers be confident they are getting safe and suitable water when they buy a bottle at a grocery store?

A9: Based on the available information, bottled water sold in Canada has generally been found to be of good microbiological and chemical quality and is not considered to pose any health hazard. Consumers should be aware that the consumption of pre-packaged water and that these products are as safe as water from the tap from a microbiological quality and chemical safety standpoint.

Q10: Do soft drink bottlers use municipal water supplies?

A10: Some do and some do not. However, irrespective of the source of the water, soft drink bottling companies generally subject incoming water to additional treatments. Questions of this nature should be directed to individual bottling companies.

Q11: Could distilled water have bacteria in it?

A11: Yes. While the distillation process is likely to result in a relatively bacteria-free water, distillation alone cannot guarantee that bacteria will be absent in the final product. For example, unless the container is sterilized prior to the filling process, microorganisms can be introduced during the filling if appropriate care is not taken. In addition, once the filled container is opened, the water is exposed to microorganisms.

Q12: Are there any new standards for bottled water being put forth?

A12: New and more stringent regulations and additional guidelines to prevent bacterial and chemical contamination are being formulated. Consideration is given to establish regulatory requirements for Pseudomonas aeruginosa, and Aeromonas hydrophilia. It is proposed to regulate aerobic colony counts for all bottled water in addition to the current coliform regulations. Also, additional sampling plans and microbial limits for bottled water at the source and at critical control points are being formulated. These will include guidelines for specific bacteria, such as E.coli, faecal streptococci, clostridia and parasites. See Table 3.

More stringent regulations to limit levels of specific chemical contaminants for all pre-packaged waters, including spring and mineral waters, are being examined. Changes to certain labelling requirements are also being considered to better inform consumers. Finally, suggestions for storage at the manufacturing and retail levels are being considered.

Q13: What types of bottled water do you recommend?

A13: Young infants, pregnant women, the frail elderly and those whose immune system has been weakened by disease, surgery or therapy are particularly susceptible to bacterial diseases. If such individuals use bottled water, scientists recommend that the water be ozonated, carbonated or disinfected by some manner. All these treatments minimize bacterial content and subsequent growth upon storage. Consumers should read labels carefully or write to the bottled water manufacturer for detailed information on the process used by the company.

Health Canada recommends that only disinfected bottled water should be used by susceptible populations such as the immunocompromised, the elderly and the very young, as well as pregnant women. The use of a one micron "Absolute" filter for the removal of protozoan cysts and other purification steps are consistent with Health Canada’s recommendation for disinfection of bottled water for susceptible consumers.

Q14: Should bottled water be used to clean contact lenses?

A14: No. Only products designated for use with contact lenses should be used. These products are sterilized and are safe for this use. If in doubt about the suitability of a product, check with your pharmacist.

Q15: What is safe storage and use of bottled water?

A15: To maintain the purity of bottled water, the Health Protection Branch recommends that consumers refrigerate the smaller bottled water at least upon opening, but preferably upon purchase. The 18 L bottled water carboys should be dispensed through a refrigerated water cooler that is kept clean to avoid contamination (see Q18). Consumers can determine the freshness of the product by referring to the bottling date and best-before-date on the bottle.

Q16: Could I use bottled water as "emergency water"?

A16: There is no reason why bottled water could not be used for "emergency water"; meaning that large quantities and large volumes of bottled water are stored in one’s basement or cold storage area in preparation for times when there are problems with municipal supplies, or natural disaster, such as earthquakes and tornadoes, or for war and nuclear fall-out. The water should be disinfected (ozonated etc.) in well-sealed containers, keep in cool, dark storage areas and changed every year. Bottle water manufacturers indicate that their product has a two (2) year shelf-life, however Health Canada suggests a one year shelf-life to ensure "freshness".

Q17: What should I do or look for when purchasing bottled water:

A17: It is recommended that you follow the following:

If concerned about chemical and bacterial content, contact the manufacturer. They should be able to provide you with analytical print-outs. Most can be contacted via the phone numbers on the labels, by mail or even via Internet accounts.

Buy only those bottles where the seal is unbroken. Examine the outside and interior of the bottle before purchase. Do not purchase any bottles where there is visible extraneous material. Report any tampering or extraneous material to the store manager and health officials.

Do not be fooled by impressive labels. Examine the bottle and label for the date of manufacturing or manufacturing code, best-before-date, chemical analysis (declaration of minerals), treatment (ex. Ozonized, ozonated etc.), company contact number, location and type of source water.

Keep the bottle clean, and preferably refrigerated (the water and inside cap and liner can support bacteria). Clean the outside of the bottle cap and neck before and after each use.

Do not refill old bottles. It is preferable to buy newly manufactured bottled water.

Do not share bottles, that is do not have more than one person drink directly from a bottle.

While travelling: avoid bottled water unless it is carbonated or disinfected. Buy only sealed products. Wipe off the bottle or can top before drinking or pouring from them.

When refrigeration is impractical, store the bottled water in a cool, clean environment away from sources of heat and sunlight. Although manufacturers give bottled water a best-before-date or shelf-life of two years, Health Canada suggests replacement after one year.

Clean water coolers regularly.

Buy products that have no spill caps, i.e. water is not spilt and air does not enter the bottled water when replacing the bottle in the cooler. Use water coolers that filter the air that enters the bottle as the water level lowers.

Use water dispensers with coolers that keep the water refrigerated. Some units have heaters as well.

If you are buying water marketed for a baby or an infant, check the label to determine if the water is sterile. It is best to consult your physician or use according to infant formula preparation instructions. If you are a member of any susceptible population, buy disinfected bottled water. If particularly concerned, boil before use.

Q18: How do I maintain the cleanliness of a water cooler?

A18: Cleaning your water cooler:1

Unplug cord from electrical outlet of cooler.

Remove empty bottle.

Drain water from stainless steel reservoir(s) through faucet(s).

Prepare a disinfecting solution by adding one tablespoon (15 mL) household bleach to one Imperial gallon (4.5 L) of water solution. This solution should not contain less than 45oC (113oF) and pout into reservoir.

Or Some companies suggest using one part vinegar to three parts water solution to clean the reservoir of scale before cleaning with bleach. Check your manual.

Note: Other disinfecting solutions may be suitable. Please check with your water cooler supplier.

Wash reservoir thoroughly with bleach solution and let stand for not less than two minutes (to be effective) and not more than five minutes (to prevent corrosion).

Drain bleach solution from reservoir through faucet(s).

Rinse reservoir thoroughly with clean tap water, draining water through faucets, to remove traces of the bleach solution.

Note: Clean your bottled water cooler with every bottle change.

Drip Tray (located under faucets):

Lift off drip tray.

Remove the screen and wash both tray and screen in mild detergent

Rise well in clean water and replace on cooler.

Replacing Bottle:

Wash hands with soap and warm water before handling. If you choose to use clean protective gloves (ex. Latex), discard or disinfect after each use and prior to reuse. Note: Protective gloves should never replace proper hand washing and hygiene.

Wipe the top and neck of the new bottle with a paper towel dipped in household bleach solution [ 1 tablespoon (15 mL) of bleach, 1 gallon (4.5 L) of water). Rubbing alcohol may also be used, but must be completely evaporated before placing the bottle in the cooler.

Remove cap from new bottle.

Place new bottle on cooler.

Q19: Where do I obtain more information?

A19: General inquiries concerning the microbiological quality of bottled water should be referred to:

Mr. Donald Warburton
Evaluation Division
Bureau of Microbial Hazards, 4th Floor West
Sir Frederick Banting Research Centre
P.L. 2204A1
Ottawa, ON K1A 0L2

T: (613) 957-1746 F: (613) 952-6400

E-mail: don_warburton@hc-sc.gc.ca

Other inquiries can be directed to those listed below:

• Any inquiries relating to bottled water should also be directed to provincial as well as municipal authorities (e.g. Toronto) for information on monitoring programs initiated by their respective health agencies.

• Manufacturers:

There are a large number of bottled water producers both here and abroad. Companies should be able to provide on request a chemical and bacterial analysis of their product. Consumers should also check labels to see if the manufacturer is a member of provincial or international bottled water association, and thus must comply with additional industry standards.

• Matters concerning bottled water industry:

Ms. Elisabeth Griswold
Executive Director
Canadian Bottled Water Association
70 East Beaver Creek Road, Suite 203-1
Richmond Hill, ON L4B 3B2
T: (905) 886-6928 F: (905) 886-9531

• Matters concerning municipal suppliers:

  Mr. T. Duncan Ellison
  Executive Director
  Canadian Water and Wastewater Association
  402-45 Rideau Street
  Ottawa, ON K1N 5W8
  T: (613) 241-5692 F: (613) 241-5193

• Matters concerning water treatment equipment:

  Mr. Ralph Suppa, CAE
  General Manager
  Canadian Water Quality Association
  295 The West Mall, Suite 330
  Toronto, ON M9C 4Z4
  T: (416) 695-0447 F: (416) 695-0450
  e-mail: suppa@cwqa.com

• Matters concerning packaged ice:
  
  Mr. Eric Wiffen
  Executive Secretary
  Canadian Association of Ice Industries
  P.O. Box 551, Station R
  Toronto, ON M4G 4E1
  T: (416) 921-4702

• Matters concerning bottled water in Quebec:
  
  Monsieur Michel Lavallee
  Gouvernement du Québec
  Ministère de l’Environnement et de la Faune
  5199, rue Sherbrooke Est, bureau 4701
  Montreal, QC H1T 3X3
  T: (514) 873-8878, poste 307 F: (514) 873-7382

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Matters concerning water treatment equipment:  

Mr. Kevin Wong- Executive Director

Canadian Water  Quality Association
295 The West Mall, Suite 330
Toronto, ON M9C 4Z4
T: (416) 695-3068 F: (416) 695-2945
e-mail: k.wong@cwqa.com