BOTTLED WATER SURVEY

A report on a sampling survey examining the composition and labelling of the varied range of bottled water available locally. The following varieties of bottled water : Natural Mineral Water Spring Water Table Water are compared with tap water locally supplied. March 2005

SUMMARY

The following samples were taken :- 31 Natural Mineral Waters 20 Spring Waters

8 Bottled Drinking Waters 9 Local Tap Water

The samples were all analysed for :-

Chemical Analysis - - pH value - Nitrate ( NO3 mg/Litre) - Chloride ( Cl mg/Litre ) - Calcium ( Ca mg/Litre ) - Magnesium ( Mg mg/Litre ) - Fluoride ( Fl mg/Litre ) - Sodium ( Na mg/Litre ) - Potassium ( K mg/Litre )

Microbiological Examination

- Colony count per ml at 22C after 72 hours - Colony count per ml at 37C after 24 hours - Total coliforms numbers per 250 ml - Escherichia Coli ( E. coli ) number per 25 ml

Issues were identified with :- - pH - Nitrates - Chloride - Sodium / Salt - Total Viable Count

A short word on Tap Water -v- Bottled Water Problems identified with manufacturers guidelines And Recommendations given for new guidelines

RECOMMENDATIONS In the main the recommendations apply to the updating / re-writing of the Guidelines in line with current good manufacturing practice and the issues observed as a result of this survey. Clearly manufacturers need clear and modern guidelines to set industry standards, so consumers can obtain appropriate information. It is therefore vital that new guidelines are produced. It is also recommended that they include the following :- - Set Standard levels of testing for specified parameters in line with good

manufacturing practice. Daily and Weekly analysis rather then monthly. - Set a specified review period for the typical analysis perhaps annually, with

a requirement to change the stated typical analysis in line with any drift away from the previous levels.

- That the updated typical analysis parameters should be readily available to the

general public as well as enforcement agencies.

- A requirement to change the typical analysis on the label in line with periodically reviewed and re-set level. These parameters to include the normally observed microbiological levels.

- Specify which parameters must be stated in the typical analysis on the label.

These to include -

pH Salt rather than Sodium Calcium Nitrates Chloride Fluoride

- Specify which additional parameters can voluntarily be stated.

- Specify how these levels are stated on the label. E.g.

o Consumers are interested in the amount of Salt present in each pack

rather than the mg/Litre of Sodium. o The detection level of the test should be given rather than zero levels. o The pH level of any water after the addition of carbon dioxide should

be given rather than the level of the source water.

CONTENTS

- BACKGROUND i. LEGISLATION

ii. AIMS

- METHOD i. STATISTICS

- RESULTS

i. CHEMICAL ANALYSIS 1. pH VALUES 2. NITRATE 3. CHLORIDE 4. CALCIUM & MAGNESIUM 5. SODIUM 6. FLUORIDE 7. POTASSIUM

ii. MICROBIOLOGICAL EXAMINATION 1. TOTAL VIABLE COUNT 2. COLIFORM COUNTS

- CONCLUSIONS - GUIDELINES - APPENDIX A RAW RESULTS - APPENDIX B NUTRITIONAL INFORMATION

- APPENDIX C - GUIDELINES FOR THE RECOGNITION AND EXPLOITATION OF NATURAL MINERAL WATERS

BACKGROUND

LEGISLATION - The Private Water Supplies Regulations 1991 - The Water Supply ( Water Quality ) Regulations 2000 - The Natural Mineral Water, Spring Water and Bottled Drinking Water Regulations 1999 as amended

With proposed amendments to the latter The Natural Mineral Water, Spring Water and Bottled Drinking Water (Amendment) (England)(No.2) Regulations 2004.

Tap Water is treated in order to remove bacterial and algal colonies living in the water. Public Analyst doesnt find bugs in tap water unless there is a local problem with storage on site. Natural Mineral Water (NMW) is a statutory name for a specific type of water. A NMW must be officially recognised through a local authority after a qualifying period of two years, during which time it is repeatedly analysed. It must also be registered with the Food Standards Agency. It must come from a specified ground water source which is protected from all kinds of pollution. The water may not be treated in any way to alter its original chemical and microbiological composition. In addition NMWs must provide certain information on their labels such as a statement of the analytical composition, which is required to indicate the characteristic constituents of the water. There is, therefore no control over which mineral levels are labelled so long as they are characteristic of the water. As of November 2004 there were 98 recognised Natural Mineral Waters from the UK. Spring Water is a statutory name for water which comes from a single non-polluted ground water source. Unlike NMW there is no formal recognition process required although it must still be registered with the local authority. Many NMWs begin their lives as Spring Waters trading as such during the two year testing period. Unlike NMWs, Spring Waters may undergo permitted treatments but like NMWs must meet microbiological criteria. Drinking Water ( or Table Water which is the trade name applied to other bottled drinking waters ) is any bottled water other than NMW or Spring Water. After NMW and Spring Water the regulations only talk about Drinking Water. It applies to water which may come from more than one source and may include the public water supply. Treatment is permitted which results in the water achieving the compositional/microbiological requirements of the regulations. Some companies may also add mineral salts to their waters to replace those minerals lost during treatments or to enhance those which already exist. Guidelines for the recognition and exploitation of natural mineral waters. See Appendix C for the 3rd Draft written by the Ministry of Agriculture Fisheries and Food, May 1989.

- Tap water is safe, costs a fraction of a pence per litre and is environmentally friendly in terms of transporting it direct to your home. - The Drinking Water Inspectorate has found that if tap water has been chilled, most of us cant taste the difference between tap and bottled water. - When Health Which? taste-tested bottled water the panel of testers liked the tap water as much as the bottled waters Bottled water on test, August 2000. - So why should bottled water be so popular at 1,000s times the price of tap water. Not to mention the environmental cost of transporting all those bottles ? e.g. Blue water by the Ultimate Water Company reputably sold at 11.00 a litre ! AIMS - To compare compositional analysis with declared values on label. - To compare nutrition properties of mineral waters/spring waters with other bottled waters and tap water. - To use results to inform consumers of health issues re sodium levels and presence of other minerals.

METHOD The aim was to sample a variety of different waters available within this area. The following types were sampled

- 31 samples of Natural Mineral Water } 59 bottled - 21 samples of Spring Water } water samples - 7 samples of Drinking Water } in total - 9 samples of Tap Water

Flavoured waters will not be looked at in this survey ( as these are covered by the Food Labelling Regulations and need to be considered as soft drinks ). Informal samples were taken. With bottled water unopened bottles were purchased noting the price per litre at time of sampling. For tap water samples the tap was allowed to run for 2 minutes prior to filling sterile sampling bottles provided by the Public Analyst. The analyst has reported on each water sample for :-

- Standard Micro Test

- Colony count at 22C after 72hrs - Colony count at 37C after 24hrs - Total Coliforms number per 250ml - E. coli numbers per 250ml

- Chemical Analysis :- - Nitrate - Chloride - Calcium - Magnesium - Fluoride - Sodium - Potassium - pH value

Regulations set maximum levels for these parameters in all water except for Natural Mineral Waters. In the case of Natural Mineral Waters no limits are set but the water has to comply with the stated Typical Analysis. STATISTICS The chemical and pH values were compared with the Typical Analysis, where stated, for each of the samples. These Typical Analyses were mainly taken from the labels, but a few were available from websites. The differences of the actual values found from those values declared, were noted and used to determine what would be considered a reasonable difference from declared values. Most values for the chemical composition were within 30% of the declared values. There seemed to be greater variation for Chloride and Fluoride discussed later. Values with greater than 30% difference from stated values were therefore considered unacceptable

RESULTS See Appendix A for the raw results. CHEMICAL ANALYSIS pH Values The pH value is a measure of a solutions acidity or alkalinity, with a value of 7 being neutral neither acidic or alkaline. Pure water is neutral and therefore has a pH value of 7 ( but carbon dioxide soon dissolves in the pure water making it more acidic ). Acidic solutions have a pH of less than 7, while alkaline solutions have a pH of greater than 7. The proposed amendments to The Natural Mineral Water, Spring Water and Bottled Drinking Water Regulations 1999, seek to increase the range of allowed pH values to :- Minimum 4.5 pH Maximum 9.5 pH The pH values of the samples were found to range from 4.2 to 8.7 from acidic to alkaline. 3 samples had a pH value less than the proposed minimum of 4.5, while being labelled as having values of 6.3 to 6.5. Manufacturers seem to be required to label the pH value of the source water not the pH value of the water as sold. All the sparkling versions of bottled water were found to be on the acidic side of neutral. This is due to the introduction of Carbon Dioxide into the water, to give it the fizz, which produces Carbonic Acid in solution rendering the whole acidic. The potential problem here is that acidic drinks can damage teeth. This is a recognised problem for children who consume fizzy soft drinks, and are therefore encouraged to drink water instead. But what if they drink sparkling bottled waters which are themselves acidic ? The artificial carbonation of bottled waters can decrease the ph to levels of 4.5 or lower. While helping to keep the water bacteriologically pure, it does make the water aggressive and can lead to problems such as leaching of minerals from teeth if drunk regularly. Drinking water with low pH levels could therefore cause concern for Dentists. 39 of the survey samples were bottled waters with a stated pH value printed on the label :-

Bottled Water with pH Labelled

0123456789

10

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39

Samples

pH V

alue

Actual pH Labelled pH

pH values of 7 and above are Neutral to Alkaline, and are not an issue. Values between 6 and 7 are probably not an issue, being only slightly Acidic. This graph shows 14 samples with actual pH values below 6. All but 2 of these have stated values higher than the actual found, these being values above 6. Food Name pH Labelled % Diff Budgens Montgomery Spring - Sparkling NMW 5.2 8.24 -36.9 Highland Spring - Sparkling NMW 5.1 7.8 -34.6 Morrisons - Sparkling Spring Water 5.3 8.1 -34.6 TESCO Ashbeck Mountain Spring - Sparkling NMW 4.3 6.5 -33.8 CO-OP Fairbourne Springs Sparkling NMW 5.2 7.85 -33.8 Safeway Savers Sparkling Table Water 4.2 6.3 -33.3 Shepley Spring Water Sparkling 5.3 7.8 -32.1 Aqua-Pura - Sparkling NMW 4.4 6.4 -31.3 Asda - Fountain Head Sparkling Spring Water 5.3 7.5 -29.3 Hadham - English Spring Water Sparkling 5.5 7.4 -25.7 TY NANT - Sparkling NMW 5.1 6.8 -25 Harrogate Spa - Sparkling Spring Water 5.3 7 -24.3 Sainsbury's Caledonian - Sparkling NMW 5 4.6 8.7 Sainsbury's Pennine - Sparkling Spring Water 5.2 4.3 20.9

Of the 39 samples with a stated pH :-

-7 samples were labelled with an alkaline pH, but were found to be acidic;

- 5 samples with either a neutral pH or a slightly acidic pH were found to be much more acidic. - Where both a still and sparkling versions of a bottled water were sampled, they both had the same stated pH.

NITRATE NO3 Nitrates are naturally present in all sources of water. Higher levels in water can indicate contamination, whether from Human or animal waste or fertiliser runoff from farmers fields. For this reason levels are strictly controlled in tap water. All the samples analysed were well below the maximum levels set for tap water. Natural Mineral Waters are not allowed to be treated, so nitrates already present in these waters can not be removed. Great care is therefore taken to ensure the Natural Mineral Waters comes from a source well away from such potential sources of contamination. Many aquifers are showing increasing nitrate levels and there is a tendency not to state nitrate levels in the typical analysis. Excessive nitrate can give rise to two problems: infantile methaemoglobinaaemia and the formation of nitrosamines. The nitrate itself is not a direct toxicant, but it is the conversion of nitrate to nitrite which causes the problems. This can occur readily in the digestive tract under certain conditions, so low nitrate levels are desirable. Up to a maximum of 50mg/Litre of Nitrate is allowed in Tap Water, Spring Water and Drinking Water.

- Bottled waters sampled ranged from less than 5 mg/Litre to 33 mg/Litre. - Tap water sampled ranged from 16mg/Litre to 27mg/Litre.

All of these were within the limits specified. Actual levels below 5 mg/Litre were not reported as this is the limit of detection employed in the laboratory. For results stated as

Of these 29 samples only 19 bottled waters with levels above 5 mg/Litre voluntarily labelled the typical levels of nitrates present :-

% Difference from stated NO3 levels

-40

-20

0

20

40

60

% D

iffer

ence

Series1 43 33 33 26 17 15 11 10 10 10 10 8 5 5 5 -8 -9 -331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

The only brand to significantly understate the levels of nitrate present was Hadham Naturally Pure English Spring Water with 23 mg/Litre labelled as typically present but actually having 33 mg/L for Sparkling ( 43% difference ) and 29 mg/Litre for Still ( 33% difference ). One sample ( Ashe Park Natural Mineral Water not shown here ) stated the Nitrogen content of Nitrate as 6.9 mg/Litre, rather than state the actual Nitrate level. From this it was calculated that the Nitrate level would be 30.5 mg/Litre, the Public Analyst actually found 31 mg/Litre. Paragraph 15 of the Guidelines ( see Appendix C ) seems to suggest that Nitrate levels should be expressed as NO3 mg/Litre. 5 samples stated a Zero level for Nitrates. 26 further samples stated Nitrate levels of less than 5 mg/Litre ( 4 of these less than 1 mg/Litre ). The Public Analysts results can neither confirm nor refute this statement.

Food Name Stated NO3 Budgens Montgomery Spring - Sparkling NMW 0

This is naturally present at low levels in all water supplies. The highest level found in the bottled waters sampled was 186 mg/Litre, Chloride is not dangerous at these concentrations. Chloride seems to have a taste threshold of about 200 mg/Litre, but even this level wasnt reached. The amounts of Chloride present varied between :- Tap Water - 18mg to 72mg per Litre Bottled Water - 4mg to 186mg per Litre Stated Values - 4.5mg to 155mg per Litre Even the highest level of Chloride found was less than half the maximum of 400mg/Litre allowed by regulation for Tap, Spring and Drinking water. 55 samples out of the 59 bottled water analysed stated a typical figure for the presence of Chloride in the water. The Public Analyst found much greater variation in the results from the analyses as a whole for Chloride. The Public Analyst as a result considered 50% variation to be the limits of acceptability. 18 of the samples were found to have above a 30% difference from the stated value, while 7 of these had a difference above 50%. 6 samples understated the presence of Chloride by greater than 50% ( the worst being a 500% difference ).

Cl Difference from Label

-200.0-100.0

0.0100.0200.0300.0400.0500.0600.0

1 5 9 13 17 21 25 29 33 37 41 45 49 53

Samples

% D

iffer

ence

Bottled waters have both much lower and much higher levels than tap water depending on the geology of the water source. CALCIUM - Ca & MAGNESIUM - Mg

These are naturally present in water at varying amounts, and together contribute to the hardness of the water. The local tap water is hard, so it is not surprising that the majority of bottled waters have less calcium than local tap water. Tap, Spring and Drinking water is allowed the following levels :- Calcium up to a maximum of 250mg/Litre. Magnesium up to a maximum of 50mg/Litre.

- 56 bottled water labels stated a typical level for Calcium; - Calcium levels stated on labels varied from 4mg to 190mg per Litre; - Calcium levels in the water source found varied from 4.4mg to 202mg/L; - 1 sample had added calcium as an ingredient (see below) to 359mg/Litre; - 8 samples had a difference of greater than 30% (3 greater than 50%); - 55 bottled water labels stated a typical level for Magnesium; - Magnesium levels stated on labels varied from 2mg to 85mg per Litre; - Magnesium levels found varied from

Of the bottled water only 2 samples did not state a typical level in the water for Sodium these were Table Waters, which gave no typical analyses at all, as allowed by the regulations. Only one sample significantly understated the level of Sodium present Co-op Fairbourne Springs Still Natural Mineral Water stated 31.2mg/Litre, BUT 78mg/Litre were found by the Public Analyst. While the Co-op Fairbourne Springs Sparkling Natural Mineral Water was found only to have 26mg/Litre of Sodium. FLUORIDE - Fl The Fluoride levels in the tap water sampled ranged from 0.08mg/Litre to 0.23mg/Litre ( at the highest level less than one sixth of the maximum allowed ). The Fluoride levels in the bottled waters sampled ranged from 0.08mg/Litre to 0.55mg/Litre ( more than double the highest from the tap water, but still only about one third of the maximum allowed for tap, spring and drinking water ). 24 of the bottled waters sampled stated a level for the presence of Fluoride in the water. These showed a much greater variation from the stated levels than most of the minerals tested ( up to 321% difference ) but the actual levels are so low these percentage differences are probably meaningless.

Fluoride in Natural Mineral Waters

0

0.2

0.4

0.6

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31

Samples

Fl m

g/Li

tre

Fluoride in other Water

00.10.20.30.4

1 4 7 10 13 16 19 22 25 28 31 34 37

Samples

Fl m

g/Li

tre

POTASSIUM K Potassium occurs in all water sources in trace amounts. The maximum level allowed for Potassium in Tap, Spring and Drinking water is 12mg/Litre. 62 out of 68 samples, had levels of Potassium that were less than half the maximum allowed for tap water. The highest Potassium level found was at 10.9 mg/Litre in Badoit Sparkling Natural Mineral Water. At these levels water is unlikely to make a significant contribution to the daily recommended Potassium intake and is unlikely to have an adverse effect on health. The biggest differences between the stated level and the levels found in the water, were due to over statements so safe levels were not exceeded.

MICROBIOLOGICAL EXAMINATION Total Viable Count The Total Viable Count (TVC), or Aerobic Colony Counts, is a test used to measure the general quality of water. The data is commonly used to plot changes in water quality over time. The legislation requires there be No significant increase over that normally observed. A summary of the Total Viable Counts per ml of water are as follows :- Natural Mineral Waters

- only 1 sample had a zero count at 22C and 5 samples had counts in excess of 1,000; - only 2 samples had zero counts at 37C, with 1 sample having a count in excess of 1,000;

Spring Water

- 2 samples had zero counts at 22C, with 3 samples having counts in excess of 1,000; - 3 samples had zero counts at 37C, the highest being 410;

Drinking Water

- the counts at 22C ranged from a count of 1, to 1 sample with over 1,000; - 1 sample had a zero count at 37C, the highest count being 17;

Tap Water - 3 samples had zero counts at 22C, the highest count being 20;

- the counts at 37C ranged from 4 to 30.

Coliforms Counts No coliform counts were recorded. Such an absence of coliforms bacteria indicates that there is no faecal pollution in the waters sampled.

CONCLUSIONS pH VALUES pH values given on labels were the typical values for the water from the source, NOT the pH value of the bottled water after the Carbon Dioxide has been added. This is misleading, especially for those trying to avoid acidic drinks in order to have healthier teeth. NITRATE The levels of nitrates found in bottled water do not indicate potential health problems. But there seems to be a trend for the Nitrate levels to increase over time, possibly with changing farming / land use patterns. This could be a significant increase on that labelled where the original exploitation of the water was some considerable time ago. As already stated above, Nitrates are naturally present in all sources of water and its unlikely that no nitrate is present in the samples labelled as having 0 Nitrates. It could be construed that this 0 value is technically incorrect and misleading, the bottle should be marked with the limit of detection of the test house. 4 further samples stated Nitrate levels of less than 1 mg/Litre statements of

It is unlikely that high levels of these mineral would cause any health problems. In fact drinking hard water has been linked to reduced risk of heart attacks. Only 3 samples showed levels above what is allowed for tap, spring or drinking water. These samples are :- 1 - Danone Activ which was found to have a total Calcium level of 359 mg/Litre, which was in fact described as Still Water plus Calcium. This product is therefore being sold as a refreshing and simple way to top up you and your familys calcium levels. The label also states :-

1 litre of Danone Activ provides as much Calcium as

A 250ml glass of milk* =37% calcium RDA*

Nutritional Information: 100 ml provides Energy 0kj/0kcal, Protein0g, Carbohydrate 0g, Fat 0g, calcium 30mg. 1 litre provides calcium 300mg = 37% RDA* Ingredients: Spring Water 99.1% (Typical Analysis per litre : calcium 31mg, sodium 8mg, magnesium 6mg, potassium 7mg, nitrates 3mg, chlorides 16mg, sulphates

SODIUM / SALT This is a key element in bottled water and is essential for health. In healthy adults excess sodium is excreted, but in sensitive adults such as those with hypertension and heart weakness, infants with immature kidneys and the elderly, high sodium levels may cause problems and so a low sodium diet is often advised. Deaths of babies have occurred from drinking formula feeds made up with high sodium mineral waters, so if bottled water needs to be used, choose one with the lowest sodium levels. This is also the reason behind the requirement for an untreated tap, when salt using water softeners are installed in houses. Sodium is associated with high blood pressure, hence the recent emphasis on reduced salt diets. An adults daily maximum dose of salt is 6g, a minimum amount is considered to be 1.6g per day. For routine use by the family it may be advisable to look for a water with less than 150 mg/Litre, and preferably less than 50 mg/Litre. Only 12 samples were found to have levels above 50 mg/Litre, the highest being at 152 mg/Litre. Again the maximum level of 150 mg/Litre of Sodium do not apply to Natural Mineral Waters they can legally have levels higher than this so long as the composition of the water is stable. See information on the Food Standards Agency website :- http://www.salt.gov.uk This includes a Salt Calculator Using the Salt Calculator on a level of Sodium at 150 mg/Litre we get

375mg/litre of Salt are present in each Litre of water If a person drinks 2 Litres of such water a day, as advised, then 0.75g of salt will be consumed this is equivalent to 12.5% of the daily allowance. This is a significant proportion of a person daily salt intake especially when most people would not think of salt being present in the water they drink. FLUORIDE Traces of Fluoride occur naturally in many water sources. Fluoride is added to tap water in some areas at the request of the local Health Authority to protect the teeth of young children. http://www.dentalhealth.org.uk/faqs/leafletdetails.php?LeafletID=17 It seems to be generally accepted that the addition of fluoride to water supplies to bring the level above 0.6 mg/Litre led to a reduction in tooth decay in growing children, with the optimal beneficial effect occurring around 1.0 mg/Litre. Other studies have indicated that fluoride is also beneficial to older people in reducing the hardness of the arteries and in the treatment of osteoporosis.

Fluoride levels in excess of 1.5 mg/Litre lead to an increase in the occurrence and severity of dental fluorosis ( teeth becoming mottled and brittle ) without decreasing the incidence of decay, missing teeth or filled teeth. Long-term exposure to Fluoride may result in permanent grey to black discolouration. Children who drink water containing fluoride in excess of 5 mg/Litre also develop severe pitting of the enamel. This explains the maximum levels of 1.5mg/Litre allowed in Tap, Spring and Drinking water. Some water sources have to reduce the level of Fluoride to make it safe No Fluoride being added to the tap water sampled locally. POTASSIUM Potassium occurs in all water sources in trace amounts. Recommended daily levels are specified for this mineral, to ensure continued health, at 3,500mg/day. Although it is an essential element, the body finds it difficult to deal with excess potassium, resulting in kidney stress and possible kidney failure. Although potassium is not considered to be toxic, long-term exposure to high potassium concentrations should be avoided. Hence the maximum level allowed for Potassium in Tap, Spring and Drinking water is 12mg/Litre. TOTAL VIABLE COUNT The Total Viable Count (TVC), or Aerobic Colony Counts, is a test used to measure the general quality of water. The data is commonly used to plot changes in water quality over time. Aerobic bacteria, yeasts and mould are all detected as colonies growing on a standard growth medium which is inoculated from the water sample. A physical count of the number of separate colonies found growing on the growth medium produces the TVC figure. The inoculated growth media are incubated at 22C and 37C, this gives two separate TVC figures for a water sample. The lower incubation temperature will encourage the growth of bacteria that may be derived from environmental sources. The higher incubation temperature will encourage the growth of bacteria that may be derived from human or animal sources. The legislation for Natural Mineral Waters requires there be No significant increase over that normally observed. These levels, to have any legal validity, need to be checked at source or almost immediately after bottling. The samples in this survey were taken from shop shelves obviously some considerable time after bottling and therefore have no legal basis. In any case the levels normally observed at source are not known by the Public Analyst and can not be compared to the levels found in the bottles. The reason for testing at or near the source is that if any viable colonies are present they can grow and multiply after bottling. As already stated Natural Mineral Waters can not be treated to remove their presence, the emphasis must therefore be on obtaining water which is isolated from any sources of pollution. High TVCs found in bottled could be due to multiplication of living organisms after bottling from low numbers present in the source water. It is however

impossible for the Public Analyst to state what these levels would have been at the time of bottling. COLIFORM COUNTS Any pathogenic micro-organisms in water supplies will probably be present in low numbers and the methods for their detection are usually difficult and time-consuming. Reliance is therefore placed on simpler and quicker tests for the detection of indicator organisms, usually Coliforms bacteria. Coliforms bacteria are always present in the faeces of man and warm-blooded animals in large numbers. An absence of Coliforms bacteria indicates that there is no faecal pollution ( or that it has been eliminated and therefore the risk of the water containing pathogenic bacteria may be considered remote. Surface waters may contain large numbers of Coliforms bacteria whereas ground waters drawn from well-constructed and maintained wells and boreholes are less prone to contamination and may contain no Coliforms. No Coliforms were found in any of the samples. This indicates there is no problem, and the producers controls seem to be adequate. TAP WATER - V - BOTTLED WATER It is very difficult to come to any firm conclusions here regarding the merits and disadvantages of the different waters sampled in this survey. For one thing there is such a wide variation in Natural Mineral Waters, let alone the other forms of bottled water. What is clear, however, is that tap water as a result of the required treatments, consistently sit within the safety limits of whichever parameter is being looked at. The very nature of Natural Mineral Waters

- they have high mineral contents; - the mineral content varies from source to source; - they cant be treated in any way other than by the addition of

carbon dioxide;

means that some vulnerable consumers need to take care which brands they consume. This is not the case with tap water, which also has the advantage of :-

- being ecologically friendly ( it is not transported by road etc over large distances, or even around the world );

- being a fraction of the cost of bottled water;

Are consumers actually paying considerable sums for WATER when they buy bottled products ? OR Are they buying into the image of PURITY ? If they are actually buying the latter these results show they should be paying a fraction of these prices for tap water !

GUIDELINES FOR THE RECOGNITION AND EXPLOITATION OF NATURAL MINERAL

WATERS See APPENDIX C Manufacturers have stated these are the only guidelines they have to help them negotiate the complexities of the legislation. The Third Draft, copied here in Appendix C, date from May 1989. This was a time before the major boom in the bottled water industry and sometimes refers to practices no longer current. The following points are mentioned in the numbered paragraph from the Guidelines :- 2 Refer to 1985 Regulations, now revoked and replaced. 3 The composition of Natural Mineral Waters must be reasonably stable. It doesnt state what reasonable means. 4 The conditions surrounding a catchment area can change over time and so therefore can the composition of the water. With the previous point, this seems to indicate that the composition of the water can remain reasonably stable while changing over time. The composition may drift over time such that after a few years the composition may be quite different from the time it was originally exploited, whilst still remaining reasonably stable. Meanwhile the label will still carry the typical analysis from the time the water was originally exploited. This would seem to be a major factor in the large differences seen between the actual composition of the Natural Mineral Water and the composition stated on the label. 13 Refers to tests to determine the Dry residues at 180C and 260C. These are tests that are not generally carried out now. Various intervals of testing are stated for different parameters :- 21 Parasites and Pathogens at not less than 6 monthly intervals over 2 years; 22 Coliform testing to be carried out at least monthly intervals; 23 Total Viable Colony Count be measured monthly over a period of 2 years; The normal viable count can then be established by assessing the range of counts over this period.

25 Pollution testing to be carried out at 3 monthly intervals over 2 years. These intervals between tests seem rather long in light of current good manufacturing practice. It also only refers to test taking place within the initial two year period. Can they stop worrying about tests after this period ? 26 Refers to Stability the composition of natural mineral water should be inherently stable. It is recognised that some variation will inevitably occur in all waters, but unfortunately the Directive offers no useful guidance on what degree of variation is permissible. . To establish stability, it is necessary to collect information over a sufficiently long period to demonstrate the extent to which the composition varies. These guidelines recommend an analytical regime for a number of parameters over a period of two years. It is recommended that the variation of results should be within the following limits. Characteristic Frequency Acceptable Variation Mineral content, determined monthly +20% As dry residue and Electrical conductivity Individual anions, captions, three monthly +20% And non-ionised compounds In addition, the level of the total viable count should be no higher than that normally observed. Notice the acceptable variations are only stated as +, not +/-. What does inherently stable and no higher than that normally observed mean ? Is this no higher than normally observed during the first two year period, or what is currently observed ?

The Guidelines can therefore be considered a mixed blessing, or even a hindrance to good manufacturing practice. They certainly seem to be a hindrance to clear, accurate and informative labelling. They appear to be at the root of the problem of giving consumers misleading information.

APPENDIX A

THE RAW RESULTS Food Name /L

pH NO3 Cl Ca Mg Fl Na K ColonyCount 22'C 37'C Coliforms E. coli

CO-OP Fairbourne Springs - Still NMW

0.33 7.6 1000 0 0 0

Highland Spring - Still NMW

0.50 7.7

Food Name /L pH NO3 Cal Ca Mg Fl Na K

ColonyCount 22'C 37'C Coliforms E. coli

Vittel NMW 0.36 7.2

Food Name /L pH NO3 Cal Ca Mg Fl Na K

ColonyCount 22'C 37'C Coliforms E. coli

M & S Still NMW - Carding Mill

0.40 6.6 8 18 15 4.3

APPENDIX B NUTRITIONAL INFORMATION The daily Reference Nutrient Intake ( RNI ) is an amount of a nutrient that is enough or more than enough for about 97% of people in a group. This is different to RDAs Recommended Daily Amount 15% of RDA is considered a Good or Significant source of that nutrient. RNIs for adults between 19 and 50 years ( different to RDAs ) :- Male Female Calcium ( Ca ) 700mg 700mg Chloride ( Cl ) no level given, average intakes range from 85 145 mmol Magnesium (Mg ) 300mg 270mg Fluoride no level given. 0.5 2.6g / day over short period gives rise to

acute and potentially fatal fluorosis Sodium 1600 mg Potassium 3,500 mg

APPENDIX C