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Bottled Water and the Overflowing Nanny State

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For the past couple decades, bottled water had been growing in popularity as an environmentally preferred choice and as a healthy beverage alternative. Especially when you can have unlimited bottled water with under sink Reverse Osmosis system. Yet in recent years, environmental activists have begun attacking its value and quality. The activists’ claims do not hold water, yet, based on those claims, they are promoting bans, taxes, and regulations on bottled water—taking the Nanny State to a whole new level. The following analysis counters this “new wisdom,” questioning the justifications for this new assault on consumer freedom.

Some key facts include:

Bottled water regulation is at least as stringent as tap water regulation. Under federal law the Food and Drug Administration (FDA) must pass bottled water regulations that are “no less stringent” than Environmental Protection Agency (EPA) regulations. The law does not allow the FDA to set standards that produce a lower quality product. As a result, FDA regulations mirror EPA regulations very closely and are more stringent in some respects because FDA applies additional food, packaging, and labeling regulations.

Bottled water is substantially different from tap. About 75 percent of bottled water is from sources other than municipal systems such as springs or underground sources. Much of the bottled municipal water undergoes additional purification treatments to produce a higher quality product that must meet FDA bottled water quality standards, packaging, and labeling mandates. In terms of safety, tap water has more documented health-related case reports compared to bottled water. The Centers for Disease Control and Prevention recommends bottled water for individuals with compromised immune systems to reduce the risks associated with tap water.

Bottled water containers are a tiny fraction of the solid waste stream. Many people have turned to bottled water to replace other portable drinks containing sugar and calories, producing little increase in total waste. In any case, single-serving plastic water bottles amount to just 0.3 percent of the nation’s solid waste. Bottles used in water coolers are recycled at high rates and have even less impact on landfill waste. Taxing and banning either type of container will not matter much in terms of overall waste.

Plastic bottles are safe for consumers. The chemicals which environmental activists suggest are a problem are not even used in the PET plastic used for single-serving water bottles. Bisphenol A, a chemical found in large five-gallon water cooler jugs and other food containers exists at such low trace levels that there have been no reported health problems and the FDA, along with several scientific organizations around the world, have not found any problem with this substance.

The public has freely turned to bottled water as an alternative to drinks with calories, for convenience, freshness, and whatever other reasons they themselves find worthy. Misinformation spread by activists should not determine who can access this product. People who do not like the product can make their own choices. They should not have any right to make them for the rest of us.

Bottled water is substantially different from tap water. Yet people are calling for bottled water regulation because they say it is either the same as tap or of a lower quality. The EPA points out, both tap and bottled water vary from one source to the next. Bottled water that is labeled “purified” originates from the tap, but the final product is different because the tap water undergoes additional treatments to eliminate flavors from chlorination among other things. In other words, purified bottled water that comes from public drinking water systems is a higher quality, since it receives additional treatment after meeting tap water standards. In contrast, unpurified tap water is less predictable in terms of flavor and quality because it can take on flavors from disinfectants as well as from contaminants from pipes.

Activists like to suggest that a large portion of bottled water is simply “bottled tap water,” and hence, we should not buy any bottled water. But according to the International Bottled Water Association 75 percent of bottled water is from sources other than municipal systems. Nonetheless, the NRDC uses this data to suggest that as much as 25 percent of bottled water is simply tap water that may or may not receive additional treatments. That may be true, but so what? A good portion of that 25 percent does receive additional treatments and hence is higher quality. All consumers need to do is look at the labels and select a water that meets their needs. Many people simply want the convenience of the packaging. Others can simply look at the label to select one that meets their needs. In addition to complying with FDA labeling mandates, most bottles include phone numbers where consumers can access additional information and have their questions answered.

Like most consumer products, bottled water qualities can vary considerably from one brand to the next, but labeling can help consumers decide which kind they want. Unlike tap water, bottled water manufacturers have a package on which they can provide information on the water source, and most provide such information. The FDA sets labeling standards that help consumers understand the terms on bottled water labels, as detailed in Table I of this document.

In terms of safety, both tap and bottled water are generally good, yet available data indicates that bottled water has a better safety record. If you compare health-related problems that have been connected to both bottled and tap water, tap water has more documented health-related incidents. For example, one EPA study documents a total of 207 waterborne-disease outbreaks producing 433,947 documented illnesses and 73 deaths between 1991 and 2002. Most of these cases were the result of a major outbreak of the pathogen cryptosporidium in Milwaukee’s tap water during 1993, which produced 403,000 illnesses and 50 deaths. In addition, many tap water problems go unreported and undetected. Of note, while many people focus on risks associated with trace-level chemicals in the water supply, the overwhelming majority of deaths resulted from microbiological pathogens in tap water. In addition to the deaths resulting from cryptosporidium, EPA researchers report:

“Another protozoan agent, Naegleria fowleri was responsible for two deaths in a single WBDO in 2002. During 1991–2002, deaths were also attributed to bacterial pathogens: seven due to Salmonella typhimurium, six due to Vibrio cholerae, non 01, four due to Legionella; two deaths occurred during a WBDO caused by both E. coli O157:H7 and Campylobacter jejuni. The remaining deaths during this period occurred during WBDOs caused by excess fluoride concentration (one death) and norovirus (one death).”

The EPA also reports that many of the deaths were among people with compromised immune systems. For example, of 54 deaths associated with cryptosporidium during 1991-2002, 85 percent were among individuals suffering with AIDS.

According to the EPA, the risks of tap water are underestimated. In fact, agency officials believe that many Americans suffer from acute gastrointestinal illness (diarrhea) every year from drinking tap water. In one study, the EPA estimates that 16.4 million Americans suffer from acute gastrointestinal illnesses annually. This number is simply an estimate, but it is indicative of the potential illnesses associated with tap water, with the vast majority being minor and short-term, fortunately.

In recent years, tap water illnesses have been increasingly related to the means of distribution via piping. Keeping the water clean from the treatment plant to the tap offers challenges that do not exist for sanitary packaged bottled water. Potential contamination in municipal pipes is a key reason why bottled water is recommended for ill individuals. Dr. Stephen C. Edberg, director of the Clinical Microbiology Laboratory of the Yale-New Haven Hospital and professor of Laboratory Medicine, Internal Medicine and Chemical Engineering at Yale University, notes the differences:

“The greatest disparity between tap water and bottled water is the distribution system. Tap is delivered through pipes where the most variability in the safety of tap water occurs. On average, a city loses between 18 percent and 44 percent of its water from leaking pipes. These pipes are often in the same trenches as our sewer pipes. It has been shown that even under normal operating conditions, pressure changes in the distribution system can cause environmental intrusion from the outside of the pipe to the inside, allowing sewage contamination to enter drinking water systems. This open distribution system is more vulnerable to contamination.”

Bottled water, on the other hand, uses a more controlled process that can avoid external contamination from the source through the bottling process. Moreover, the bottle hygienically seals in the quality.

Government agencies have not found nearly as many health-related problems associated with bottled water. Both the sources of water used for bottled water (much of which comes from ground rather than surface waters, which tends to be cleaner) and their delivery systems play a critical role in keeping risks low. Edberg reports: “the CDC has associated bottled water with less than 10 incidents resulting in possible cases of illness in the past 35 years.”

“There has not been a documented major outbreak of illness from bottled water in the U.S.,” says Amy Simonne, Assistant Professor for Food Safety and Quality at the University of Florida. The fact that there hasn’t been a major outbreak does not mean there are no isolated cases of individual problems. The CDC reports a handful of cases over the past several decades in their reports on waterborne illnesses in Morbidity and Mortality Weekly Report. Yet the few illnesses associated with bottled water are dwarfed by the more numerous tap water related illnesses.

Like all food products, bottled water is also subject to recalls under FDA guidelines, which have occurred periodically. Yet these recalls are not associated with many actual illnesses, nor are they related to any deaths. Peter H. Gleick, author of The World of Water, The Biennial Report on Freshwater Resources: 2004-2005, lists a number of such recalls. None of them produced significant, long-term public health impacts. Of the 12 cases he found, 10 occurred in the United States and, of those, 10 involved FDA recalls, and one involved a recall by the state of Pennsylvania for a local water provider. In the Pennsylvania case, the water contained coliforms, and one person reported some gastrointestinal distress. All of the FDA recalls fell within Class II and III for food recalls. Both classifications indicate that the FDA determined the risks of any long-term problems to be “remote” or “unlikely.” The exact definitions of these classes are as follows:

Class II recall: “A situation in which use of or exposure to a volatile product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.”

Class III recall: “A situation in which use of or exposure to a volatile product is not likely to cause adverse health consequences.”

More recently, there have been a few additional recalls, some which have captured headlines, although the risk remained low. In 2004, Coca-Cola recalled Dasani bottled water overseas because it contained elevated levels of the chemical bromate. Nestle and Wegmans supermarkets conducted similar recalls in 2006. While much hype in the press makes it appear as serious, the risk was actually very low and the impact negligible. Bromate is a byproduct of disinfection with ozone, which water companies ensure stays below levels of concern.

Even though the recalls involved exceedances of standards, the levels of bromate in the water still did not pose acute or long-term health risks. Theoretically, long term risks—such as cancer risks—would involve drinking a substantial amount of this water over several decades. Moreover, according to the EPA’s assessmentof bromate, there is no human data indicating a cancer risk. Instead, bromate causes cancer in rodents that are administered very large doses, which is of questionable relevance to humans who are exposed to trace levels for short intervals. Hence, there is little reason to worry about a periodic short-term exposure to bromate in bottled or tap water.

The NRDC disputes claims that bottled water poses lower risks, but they are hard pressed to come up with much evidence. NRDC claimed in 1999: “However, such outbreaks from contaminated bottled water have indeed occurred and are well documented by CDC and others in the scientific literature.” Yet the group could only identify three such “outbreaks” ever, and only one occurred within a U.S. jurisdiction. In that case, there was an issue with bottled water in the U.S. territory of the Marianas Islands in the Pacific, which NRDC points out is covered by U.S. bottled water law. According to NRDC at least 11 people became sick, with four hospitalizations. However, the fact that NRDC could only find this one incident—compared to the many cases of waterborne problems with tap water—is indicative of an impressive safety record for bottled water.

Ironically, this single U.S. bottled water “disease outbreak” is addressed in a CDC document that underscores the more significant risks posed by tap water-related disease outbreaks. Specifically, the CDC report addressed the largest waterborne disease outbreak in recent decades—the contamination of Milwaukee tap water. CDC notes: “For the 2-year period 1993-1994, 17 states and one territory reported a total of 30 outbreaks associated with drinking water. These outbreaks caused an estimated 405,366 persons to become ill, including 403,000 from an outbreak of cryptosporidiosis in Milwaukee, the largest WBDO ever documented in the United States, and 2,366 from the other 29 outbreaks.” In comparison, the incident in the Marianas Islands appears to be what it was in fact: a rare and unfortunate accidental contamination of bottled water whose impact was relatively small and controlled.

By highlighting the challenges faced in the provision of tap water, this analysis is not meant to suggest that anyone should panic about tap water. The reality is that everything in life involves risks. In fact, much of human history has been characterized by a struggle to avoid dangerous microbes, particularly those in our food and water. Developed nations have made tremendous progress in this area, managing to provide food and water for millions of people every day with relatively few incidents. It is only because we have achieved such high standards that outbreaks have become major news. In the developing world, those challenges remain considerable and poor quality sanitation produces tragic results.

In the United States, problems with our water supply are relatively rare, but risks remain that demand some attention. When compared to bottled water, risks appear to be somewhat higher for tap water in large measure because of its distribution system. This reality simply underscores the fact that the two products are not the same. Accordingly, bottled water has important applications for individuals with special needs, for emergency situations, and for individuals who simply desire the qualities associated with bottled water.