HomeMy WebLinkAbout11/7/2017 Item 8, International Bottled Water Association
November 3, 2017
San Luis Obispo City Council
990 Palm Street
San Luis Obispo, CA 93401
1
The California Bottled Water Association (CBWA) and the International Bottled Water
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Association (IBWA) appreciate this opportunity to provide comments in opposition to Ordinance
1641, which would ban the sale of beverages packaged in single-use plastic containers of less than
21 ounces, including bottled water, on city property in San Luis Obispo.
IBWA and CBWA oppose bans on the sale of specific products, particularly those that include
bottled water. We believe that any proposal that would prevent access to bottled water is not in the
public interest. We urge the City Council to oppose any proposal to ban the distribution or sale of
bottled water because:
efforts to ban or restrict access to bottled water hinder individuals searching for a healthier
beverage alternative;
bottled water has the lowest environmental footprint of any packaged beverage;
it unfairly targets one food product (beverages), even though thousands of others use PET
plastic in their containers; and,
bottled water is strictly regulated by the U.S. Food and Drug Administration (FDA) as a
food product, making it a safe choice for consumers.
IBWA and CBWA fully support the efforts by the City Council within Ordinance 1641 to increase
access to water via refilling stations and public drinking fountains. We agree, at all times, people
should be encouraged to drink more water whether it is tap, bottled or filtered.
1
The California Bottled Water Association is the trade association of the bottled water industry in California. CBWA
supports its member bottlers, distributors, and vendors by keeping them informed and representing them in matters of
government and regulatory legislation, providing them with educational and training opportunities related to the bottled
water business, creating an environment of open communications for sharing resources and information and,
representing their unified voice in the future development of the bottled water industry.
2
The International Bottled Water Association is the trade association representing all segments of the bottled water
industry, including spring, artesian, mineral, sparkling, well, groundwater and purified bottled waters.
is to serve the members and the public, by championing bottled water as an important choice for healthy hydration and
lifestyle, and promoting an environmentally responsible and sustainable industry. IBWA represents bottled water
bottlers, distributors and suppliers throughout the United States, including several small, medium and large size
companies doing business in California.
CBWA & IBWA Comments to San Luis Obispo City Council
Page 2 of 5
Bottled water is the healthiest packaged beverage option
#1 packaged drink, according to the latest
data from BMC. Bottled water sales increased by 10 percent in 2016, and now total $16 billion
(wholesale). In 2016, total U.S. bottled water consumption grew by 8.6 percent to 12.8 billion
gallons, up from 11.8 billion gallons in 2015. In addition, per-capita consumption is up 7.7 percent
in 2016, with every person in America drinking an average of 39.3 gallons of bottled water last
year, while average intake of carbonated soft drinks slipped to about 38.5 gallons, BMC statistics
show.
The release of the 2015 Dietary Guidelines for Americans (DGA) by the U.S. Department of Health
and Human Services (HHS) and U.S. Department of Agriculture (USDA) provide strong support for
the important role played by water in America
availability of water as a healthy beverage choice. In particular, the new DGAs note that calorie-free
beverages especially water should be the primary beverages consumed. In addition, the 2015
DGAs en
with no added sugars, such as water, in place of sugar-
The DGAs recommend that Americans significantly reduce their intake of added sugars to no more
than 10 percent of daily calories about one 16-ounce soft drink. So, when it comes to beverages,
the smart and healthy move is to choose water first for thirst. Limiting sugary beverages and
drinking more water including bottled water is one of the easiest ways to follow the new
Center for Nutrition Policy MyPlate MyWins guide specifically highlights the need
to choose water instead of sugary drinks.
The United States, and especially a state like California and a city like San Luis Obispo that
encourages and offers so much in terms of unique activities, is an on-the-go society that depends on
convenience when making food and beverage choices. Ideally, water should be accessible to people
everywhere. Much of what people drink comes in a package and as a result, today, almost half of
the water people drink comes in a bottle. Encouraging the consumption of water, and increasing its
availability in all formats including bottled water, is a smart and direct way to help Americans make
healthier beverage choices.
Bottled water companies are strong environmental stewards
Data compiled by the Beverage Marketing Corporation (BMC) show that between 2000 and 2014,
the average weight of a 16.9-ounce (half-liter) single-serve PET plastic bottled water container has
declined 51 percent to 9.25 grams. This has resulted in a savings of 6.2 billion pounds of PET resin
since 2000. The National Association for PET Container Resources (NAPCOR) notes that
producing new products from recycled PET (rPET) uses 84 percent less energy than what is
required to make products from raw virgin materials. It also reduces greenhouse gas emissions.
All bottled water containers are 100 percent recyclable; and of all the plastics produced in the U.S.,
PET plastic bottled water packaging makes up only 0.92 percent less than one percent. Moreover,
CBWA & IBWA Comments to San Luis Obispo City Council
Page 3 of 5
according data derived from BMC, NAPCOR, and the Container Resource Institute, bottled water
containers make up only 3.3 percent of all drink packaging in landfills. And according to NAPCOR,
PET plastic bottled water containers are the most frequently recycled PET beverage container in
curbside recycling programs.
Even with continuing growth and increased consumption, bottled water still has the smallest water
and energy use footprint of any packaged beverage. The results of a 2014 IBWA benchmarking
study show that the amount of water and energy used to produce bottled water products in North
America is less than all other types of packaged beverages. On average, only 1.32 liters of water
(including the liter of water consumed) and 0.24 mega joules of energy are used to produce one liter
of finished bottled water.
Research shows that when bottled water is removed as a choice, people will turn less-healthy
beverages, not necessarily tap water.
Banning the sale of bottled water in plastic containers would have an adverse impact on public
health and the environment. The University of Vermont (UVM) experienced unintended and
negative consequences as a result of its bottled water sales ban. Students increased their per capita
consumption of soda and the amount of waste actually increased after the sales ban was in place. In
a published research study, the
decision to remove bottled water drove our students, faculty, staff, and visitors to purchase more
unhealthy sugary drinks (33% increase). At the same time, the number of plastic beverage
The study, The Unintended Consequences of Changes in Beverage Options and the Removal of
Bottled Water on a University Campus in the July 2015 edition of the American Journal
of Public Health (AJPH), shows when bottled water is not available in a vending machine, people
choose other packaged beverages, which may contain sugar, caffeine, and other additives. That is
not in the public interest and would cause negative health and environmental consequences.
Bottled water is safe
Safety and consistency are key reasons consumers choose water, particularly bottled water products.
Bottled water is comprehensively regulated by the FDA as a packaged food product and it provides
a consistently safe and reliable source of drinking water. By federal law, the FDA regulations
governing the safety and quality of bottled water must be at least as protective of the public health
as the Environmental Protection Agency (EPA) standards for tap water.
All bottled water products - whether from groundwater or public water sources - are produced
utilizing a multi-barrier approach. From source to finished product, a multi-barrier approach helps
prevent possible harmful contamination to the finished product as well as storage, production, and
transportation equipment. Many of the steps in a multi-barrier system are effective in safeguarding
bottled water from microbiological and other contamination. Measures in a multi-barrier approach
may include one or more of the following: source protection, source monitoring, reverse osmosis,
distillation, micro-filtration, carbon filtration, ozonation, and ultraviolet (UV) light. The bottled
water industry supports a strong and reliable public drinking water system and infrastructure.
CBWA & IBWA Comments to San Luis Obispo City Council
Page 4 of 5
Further, bottled water is one of the few food products that must comply with two sets of FDA
requirements in addition to the general food Good Manufacturing Practices (GMPs) -- one
prescribes bottled water Good Manufacturing Practices, and the other imposes specific bottled water
standards of identity and quality. FDA's GMPs for bottled water apply to every aspect of
production, from source protection, all the way through processing, to finished water sampling for
purity prior to final bottling.
FDA has established standards for more than 90 substances pursuant to the Standard of Quality
(SOQ) for bottled water.
maximum contaminant levels (MCL) for public water systems. The few differences are usually the
result of the substance not being found in bottled water or the substance is regulated under FDA
food additives program.
Widespread public concern about lead contamination in public water systems (PWS) has been
making headlines throughout the US recently. Bottled water lead standards are very different and
more stringent than those applied to a PWS by the EPA. While the FDA imposes a standard of
quality of 5 parts per billion (ppb) for l
detected, bottled water is treated much differently. Any single bottle water product that exceeds the
established SOQ could result in an automatic recall, significant fines, and criminal penalties. The
no way stops the lead-contaminated tap water from being consumed.
The bottled water industry helps ensure that our product is there when California needs it
The bottled water industry has always been at the forefront of relief efforts during natural disasters
and other catastrophic events. This has been clearly evident over the last few months with
overwhelming need for water following natural disasters impacting the Gulf Coast, Florida, the
Caribbean, and the Pacific Northwest. Clean, safe water is a critical need for citizens and first
responders immediately following a natural disaster or other catastrophic event. Unfortunately, the
availability of water from public water systems is often compromised in the aftermath of such an
event (e.g., hurricanes, floods, wildfires, boil alerts). During these times, bottled water is the best
option to deliver clean safe drinking water quickly into affected areas.
It would be a huge disservice to the consumers of bottled water and the citizens of California and
San Luis Obispo to restrict access to a product that is so important during times of need. The bottled
water industry prides itself on the ability to get water to those in need but this proposal would make
it more difficult to get an essential product to those who need it most. IBWA and CBWA members
are in fact often the first responders during disasters, personally driving their own trucks filled with
water and other relief supplies into affected areas where assistance has not yet arrived. They do so
willingly, and they often do so for free.
The bottled water industry would not be able to provide safe, clean drinking water to California
citizens when their public water systems are compromised without a viable commercial market.
This provides the industry with the capital and resources to respond quickly when needed. The
bottled industry cannot, and should not, exist only for disaster responses something some critics of
CBWA & IBWA Comments to San Luis Obispo City Council
Page 5 of 5
the bottled water industry desire. We urge the Council to remember that the bottled water industry is
called upon every year to provide drinking water during critical times throughout California.
Conclusion
IBWA and CBWA hope that this information has provided you with better insight into the bottled
water industry and the importance of access to bottled water for the people of California. For these
reasons, we would ask that the Council oppose any attempt to restrict access to bottled water and
oppose Ordinance 1641. We appreciate this opportunity to offer these comments and are available
at any time to discuss information on the industry and the important products we provide.
James P. Toner, Jr. Sepp Becker
Director of Government Relations President
International Bottled Water Association California Bottled Water Association