Natural Mineral Waters: How to prepare for the Recognition Process Dr. Andrew F. Flanagan Executive Analytical Chemist Western Regional Public Analyst’s Laboratory University Hospital – Galway.
Natural Mineral Water –Natural Mineral Water (2009/54/EC [recast of 80/777/EC & amendments] /40/EC + 115/2010) ‘Natural mineral water’ means microbiologically wholesome water, within the meaning of Article 5 (micro rules), originating in an underground water table or deposit and emerging from a spring tapped at one or more natural or bore exits. Natural mineral water can be clearly distinguished from ordinary drinking water: (a) by its nature, which is characterised by its mineral content, trace elements or other constituents & where appropriate, by certain effects; (b) by its original purity, both characteristics having been preserved intact because of the underground origin of such water, which has been protected from all risk of pollution.
The composition, temperature and other essential characteristics of natural mineral water must remain stable within the limits of natural fluctuation; in particular, they must not be affected by possible variations in the rate of flow. Leads to a requirement to conduct: – Geological and hydrological surveys (protection zones) – Physical, chemical and physico-chemical surveys (chemical fingerprint!) – need for permitted treatments? – Microbiological analyses at source (“microbiologically wholesome”) – Clinical and pharmacological analyses – water may have “properties favourable to health” but not required (BADISCHE ERFRISCHUNGS-GETRÄNKE v LAND BADEN-WÜRTTEMBERG) i.e. Characterise site & water (UK FSA requires 2 yrs of acceptable characterisation data before granting recognition)
Once characterised & ok => Source Management!!! Protect your water Secure Site –Accidental & malicious –Pests Optimum Design (what businesses etc are around?) –Buildings –Bore hole Appropriate Services –Water (potable v. non-potable = SEPARATE!!!) –Containers Equipment, Cleaning, Personnel & Transport –Storage of materials that could effect the water –Health & Hygiene –External Materials = water packages (0.5 l, 1l etc…)
Processes (5 year certification cycle) HACCP Record Keeping Analysis (accredited laboratory – ISO 17025) Type (physical, chemical, microbiological) & Frequency (continuous, daily … annual) -based on production volumes? Consistent monitoring for changes in the locality (liaise with local government/landowners etc) Agricultural Industrial/commercial Residential Other (dumps, incinerators)
Certification (5 year cycle) Certified by: “responsible authority in the country of extraction” Meet provisions of Annex I Definition of Natural Mineral Water & criteria for the application of the definition Regular checks on Annex II (2) requirements Water exploited (i.e. extracted & packaged) to i)prevent contamination ii)preserve (characterised) unique water properties If the above requirements are no longer met = suspend certification (annex II (3) required FBO to suspend all exploitation & bottling) Voluntarily = protect brand image/name/reputation (EU Art. 19 of Reg 178 requires FBO to act if know of failure of food safety requirements)
Documents: Directive 2009/54/EC Directive 2003/40/EC Regulation (EU) 115/2010 Directive 98/83/EC Guides: Ireland: I.S. 432:2010 Ireland: Parameters of water quality EPA
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