1. Belgrade, 25 th June 2012 Raymond Ellard Director – Consumer Protection Food Safety Authority of Ireland

2. - EU and individual country per capita consumption in 2009 (litres) Annual Europe 2009

3. Annual Consumption- Ireland 183 million litres of bottled water 26 bottled water companies

4. Most Expensive? Acqua di Cristallo Tributo a Modigliani – $60,000 for a 1.25 ml bottle

7. Fame & Fortune

8. SAFETY & FRAUD

9. Bottled Water Regulation Department? Labels Recognition Trade Description Micro Criteria Treatment Hygiene/Safety Testing

10. Codex Alimentarius

12. Key EU Food Hygiene Laws 178/2002 852/2004 Hygiene 2002/99 Animal Health 2073/2005 Micro criteria 882/2004 Official Feed and Food Controls 853/2004 Food of Animal Origin 854/2004 Official Control Animal Origin

13. The Rules Key Components Activated Alumina 115/2010 Revised Drinking Water Directive Ozone 2003/40/EC 2009/54/EC Bottled Water 852/2004/EC

14. Official Controls 1.Conduct a risk profile of each establishment 2.Assign a risk category from 1-6 based on the risk profile 3.Assign a standard frequency of inspection based on the risk category 4.Consider if a deviation from the standard frequency of inspection is warranted

15. Inspection Frequency

16. OUTCOME & ACTION Grade 1: Satisfactory Grade 2: Minor non-compliance Grade 3: Unsatisfactory Grade 4: Unsatisfactory Significant Grade 5: Unsatisfactory Serious

17. Inspection Elements An Inspection can be considered as having various elements, which include the examination of: –A- Hygiene Prerequisite Programme (structural) –B -Hygiene Prerequisite Programme (operational) –C - Procedures based on HACCP principles –D - Management systems –E - Relevant food legislation in addition to food hygiene legislation Rules on Bottled Water must be checked

18. NSAI HSE/FSAI Controls in Ireland: Responsible Authority Recognition Competent Authority Inspections Working together

19. NSAI HSE/FSAI

20. Natural Mineral Water Spring Water Any Other Water

21. USA Bottled Water Identity Labelling 21 C.F.R §165.110 (a)

22. Natural Mineral Water

23. Man made or God Made?

24. Natural Mineral Water Microbiologically wholesome Underground source Protected from pollution Distinguished by –Nature – mineral content, trace elements –Original State Stable Bottled at source Limited treatment Recognised

25. Natural Mineral Water Authorisation –Within EU –Outside EU List Published in Europa Website

26. RECOGNITION NSAI –Certificate of Recognition –Conditions of Exploitation –Chemical Fingerprint Tolerances Specific Boreholes –5 Years

27. Consumers in Ireland

28. Approval & recognition Assessment –Geological –Hydrogeological –Physical, Chemical and physicochemical properties –Microbiological –Pharmacological –Physiological –Clinical Stability –Rate of flow –Temperature –Terrain properties Protection from Pollution Equipment Treatments Periodic Checks Irish Standard IS432: 2010

29. Page 29 Permitted Treatments 1)the separation of its unstable elements, such as iron and sulphur compounds, by filtration or decanting, possibly preceded by oxygenation, 2)the separation of iron, manganese and sulphur compounds and arsenic from certain natural mineral waters by treatment with ozone-enriched air - NOTIFIED 3)the separation of undesirable constituents other than those specified NOTIFIED 4)the total or partial elimination of free carbon dioxide by exclusively physical methods 5)Activated alumina to remove fluoride NOTIFIED Microbiological treatments are prohibited

30. Spring Water intended for consumption in its natural state, underground source, protected from pollution bottled at source. limited treatments

31. Legislation

33. Micro Criteria TCC –Evidence of pollution Free from –Parasites and pathogens –E Coli 0/250ml –Sulphite reducing in 50ml –Pseudomonas in 250ml Organoleptic defects AFTER BOTTLING TCC –100/ml @22 0 in 72hrs –20/ml@ 37 0 in 24hrs Measure with 12hrs AT SOURCE TCC –20/ml @22 0 in 72hrs –5/ml@ 37 0 in 24hrs

34. Micro Criteria E.Coli Enterococci Coliforms Pseudomonas Total Colony Count (TCC) Recall Investigate Investigate &HPSC notice Establish norm

35. Disinfection Not Permitted –UK says UV OK???

36. Any Other Water Complies with the same rules are tap water –98/83/EC Table Water

37. Sampling and Analysis Offical Controls Natural Mineral Waters –Microbiogical Testing – every 3 Months –Chemical Testing – every 6 months Spring Waters –Micro testing (2009/54) every 3 months –Micro & Chemical (98/83) – depends on volume Other Waters (98/83) – depends on volume

38. Monitoring – 98/83/EC Member States shall take all measures necessary to ensure that regular monitoring of the quality of water intended for human consumption is carried out… appropriate monitoring programmes shall be established by the competent authorities for all water intended for human consumption sampling points shall be determined by the competent authorities

39. Montoring Frequency

40. Test Type of microorganism Method b Microbiological quality (cfu/g) a SatisfactoryUnsatisfactory c E. coli IndexISO 9308-1 0/250 ml> 0/250 ml Enterococci IndexISO 7899-2 0/250 ml> 0/250 ml Coliforms IndicatorISO 9308-1 0/250 ml> 0/250 ml P. aeruginosa PathogenPr EN ISO 12780 0/250 ml> 0/250 ml a Criteria applied to natural mineral water and spring water at source and during their marketing. Criteria applied to other water at the point at which the water is put into the bottles or containers. However, other waters can be sampled at retail level for the purposes of check monitoring and analysed for these parameters (S.I. No. 225 of 2007) b Analytical reference method specified in S.I. No. 225 of 2007 c Follow-up action was taken by environmental health officers if test result was unsatisfactory

42. Survey Results 748 SAMPLES –2.5% unsatisfactory –4 considered unsafe E. coli or enterococci RECALLED –11 containted Coliforms –4 positive for P. aeruginosa. –3 unsatisfactory samples (two positive for E. coli and one for P. aeruginosa), RASFF LABELLING – Name of Spring and place of Exploitation

43. Labels Place in the Trade Description Not more than One Trade Description per source! Trade Description - name of spring or place 1.5 times Prohibited –Characters the water does not possess

44. Label Analytical Composition Place where spring is exploited Permitted Treatment Trade Description –Place name if not misleading –Only 1 Trade Description

45. Sales Descriptions NATURAL MINERAL WATER Naturally carbonated mineral water Natural mineral water fortified with gas from the spring, or Carbonated natural mineral water –Fully decarbonated –Partially decarbonated

46. Label

47. LABEL

48. Fluoride >1,5 mg/l ‘contains more than 1,5 mg/l of fluoride: not suitable for regular consumption by infants and children under 7 years of age’. CODEX USA has a maximum level in drinking water is 4mg/l. Codex now same as EU, but now maximum system

49. Prohibitions on Labels Medicinal Claims Will Cure Heart disease, Cancer, weak bones, and it also Whitens your teeth. HONEST!!! Currently Not Allowed in Europe

50. CLAIMS- Annex III Low Mineral content Very Low Mineral Content Rich in Minerals Contains calcium.. Suitable for a low sodium Diet

51. Other Claims May be laxative May be diuretic No Criteria in Ireland No criteria in Ireland

52. INFANTS Member States may adopt special provisions regarding information — both on packaging or labels and in advertising — concerning the suitability of a natural mineral water for the feeding of infants. Such provisions may also concern the properties of the water which determine the use of the said information.

53. Babies and NMW Mineral waters may have a high solute content, may contain inadequate fluoride, and should not be used either to reconstitute formula or as an infant drink.

54. Nationally Authorised Claims?

55. Main Issue Recognition of NMW is complex Specialist Work Guidance required for Inspectors Market Surveillance - Labelling

56. You need a good guide

57. Irish Standard IS432 –Revision 2010 –Includes general hygiene requirements –Recognised Guide to Good Practice

58. Guides THE NATURAL MINERAL WATER, SPRING WATER AND BOTTLED DRINKING WATER (ENGLAND) REGULATIONS 2007 GUIDANCE TO THE LEGISLATION

59. EFBW & UNSEDA - Guides Guides on Bottled Water

60. Thank You