Bottled water sales are expected to surpass carbonated soft drinks by the end of the decade, if not sooner, according to an article published last year in The New York Times. Although it implied a rosy future for North American water bottlers, there will be challenges.
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Explore This IssueAugust/September 2014
From a consumer perspective, bottled water is a convenient, clean, and safer option for today’s busy families. However, there have been numerous articles in national publications that have questioned the assumption that bottled water is better, cleaner, and purer. Bottlers need to deliver on that quality promise.
Whether it is spring water, mineral water, or filtered water, many water bottlers use ozone for water disinfection. Ozone has been used as a disinfectant and an oxidizer for drinking water for more than 90 years.
“Ozone is the perfect solution for preserving bottled water,” comments Lee Comb, a principal with G4 Water, LLC, a San Francisco-water quality projects consultancy. “Ozone can also be used for rinsing containers and caps, as well, instead of chlorinated city water.”
Ozone is made from oxygen in the air on-site. After oxidizing microorganisms, ozone immediately reverts back to pure oxygen. If handled and used properly and under controlled conditions, ozone leaves no by-product and will not change the taste or smell of the water product.
It is also approved by the FDA and USDA as a food contact substance and is an allowed ingredient under USDA National Organic Program regulations (USDA’s Organic rule in 2000).
Ozone use has provided many benefits to the bottled water industry, including improved taste and the elimination of odors as it oxidizes microorganisms and organics.
Updating the Process
In the past it was sufficient to know the ozone system was on and producing ozone. That is not true with the today’s regulations. The enactment of the Food Safety Modernization Act has serious implications for water bottlers. Keeping records of the dissolved ozone level is mandatory. Local and/or remote data logging and using sensors for the calibration of dissolved ozone is preferred.
A programmable logic controller (PLC) utilizes a PID to maintain precise ozone concentrations. A PLC is a digital computer used for process control and governs the PID, a feedback control mechanism that calculates the difference between a measured process variable and a desired set point.
Jon Brandt, president of Ozone International, states that “It will become increasingly difficult to comply with these regulations using outdated ozone equipment.” The old saying “if it ain’t broke, don’t fix it” no longer applies.
The good news, according to Comb, is that the technology has advanced significantly in recent years, with more reliable and efficient equipment.
Even at the turn of the century, ozone generators were often unreliable and had difficulty controlling ozone levels. Coupled with poor customer service, ozone companies came and went.
“Service is a key component,” adds Brandt. “There’s no point in paying for a piece of equipment that is not functioning properly.”
The United States Occupational Safety and Health Administration (OSHA) has approved ozone as safe for workers (29 CFR 1910.1000). Ozone has a distinctive, clean odor that is immediately recognizable at unsafe levels.
The FDA approved ozone for bottled water in 1982. In 1997, an FDA expert panel declared ozone to be safe for use in food processing. In 2001, the FDA approved ozone as a food additive and recognized ozone as a Good Manufacturing Practice.
Ozone is regulated by the U.S. Environmental Protection Agency (EPA) as a “biocidal device,” because it leaves no residue on products or in the environment. It is also exempt from further EPA restrictions—eliminating the need for handling, storage, record keeping, and disposal of chemicals that are covered by increasingly stringent government regulations.
Older ozone systems may have difficulty maintaining desired set points. This problem has been attributed to manually controlled ozone generators and lack of proper monitoring technology. Without an in-line monitor driving the generator through a PID control, ozone levels are erratic. And without ambient monitoring, a bottling plant is at risk if there is an ozone leak, which could lead to EPA and OSHA air quality concerns.
Under the law, the FDA has the ability to charge food processors for the re-inspection of facilities that are found to be deficient during the routine first inspection.
Taking a staged or phased approach is key. Start by implementing a Hazard Analysis and Critical Control Points (HACCP) plan and recommend that the HACCP team leader take a certified HACCP training course as well as a course on the principles of internal auditing. NSF International offers several courses and a readiness tool to help prepare for the Food Safety Modernization Act (FMSA) regulations and implement an effective control program. FSMA has several requirements for facilities that are registered with the FDA.
Water bottlers are taking an unnecessary risk relying on antiquated equipment to produce ozone for water disinfection.
Bottlers must identify potential gaps in their food management safety systems and provide practical steps to develop and implement an effective control program. Upgrading the ozone disinfection program is a critical part of that process.
In the final analysis, there are many reasons why water bottlers should upgrade old equipment. But the most important one is meeting customers’ expectations for product quality and safety.
Malo is global business manager for NSF International’s Beverage Quality Program. She serves as Chairman of Education and Audit Committee of Watercoolers Europe, represents NSF for the European Federation of Bottled Water, and is a member of Audit Committee of European Ice Packaging Association. Reach her at firstname.lastname@example.org.