Status of UK's Natural Mineral Waters in EU/EEA after 1 January 2021

Essentially, if exporting to EU/EEA states and Northern Ireland, an application for recognition of mineral water has to be made after 1 January 2021.

UK mineral waters would be regarded as 3rd country waters and have to be accepted by a member state. If one member state (EU and EEA) recognises the UK mineral water, all states will recognise the mineral water automatically. 

The UK mineral water must comply with the requirements of the 2009 Directive for mineral water (2009/54/EC).

Note that Northern Ireland is included solely because of the Northern Ireland Protocol. 

Applications have to be made in the language of the member state approached. Currently, Republic of Ireland and Malta cannot accept applications because of lack of administrative capability. Some countries will charge an administrative fee plus expenses (for example to visit the source).

 The requirements for TVC count at source are interpreted differently in the UK compared with the 2009 Directive. The Directive indicates maximum values of 20/ml and 5/ml at 22 deg C and 37deg C respectively, whereas the UK interpretation treats these figures as a guide only. If values are higher than these, some clarification will be required when making applications. 

Some countries (for example France) have suggested applying now to save time. Other counties will allow existing stocks in a country to be used up before applying the recognition requirements.

New Drinking Water Directive

The Directive was first published in 1998 and since then there have been three amended versions from 2003, 2009 and 2015. Over 20 years have passed since the first Directive and many things have changed since then regarding drinking water contamination. Four areas were considered as needing revision:

• The list of parameters

• The use of the risk-based approach

• Increased transparency giving consumers access to up-to-date information

• Greater insight into materials in contact with drinking water and analysis of migration

Rather than issue another amended version of the Directive, it was decided to recast a new version.

Redundant Parameters

Some parameters are no longer considered to be a problem in today’s water supplies, such as benzene, mercury and cyanide and these have been omitted from the listings.

New Parameters

Some parameters have been added, such as polyfluoroalkyl substances, which are considered as increasing pollutants (these are used widely in fire-fighting foams). Uranium has been added (occurring naturally or as a contaminant). Clearer indications of analytical methods and thresholds for migration of pipework materials into water (vinyl chloride, epichlorohydrin and acrylamides) have been established. The full list of new additions is about to be published.

Risk Analysis

Rather than analyse annually a large list of parameters, the list may be made smaller by considering the individual risks at the location of water extraction. This was first described in the 2015 amendment and briefly is as follows:

• Analytical results should be review over the previous 3 years

• If the parameter measured is consistently less than 30% of the threshold during this time, it may be  omitted

• If the parameter measured is consistently less than 60% of the threshold, the frequency of analysis may be reduced

Tables in the New Directive

There are three Tables in the new Directive, A, B and C. The latter is new and intended to provide more information for the consumer:

• Table A, microbiological parameters

• Table B, physico/chemical parameters

• Table C, indicator parameters

The indicator parameters are not considered harmful, such as colour, taste, conductivity and turbidity but are considered useful information for the consumer. Interestingly, HPCs and coliforms have been included in this table and removed from Table A.

Exemptions to the Directive

Bottled mineral waters are exempt from this Directive and considered under Directive 2009/54/EC. Spring water, on the other hand, is covered partly by the 2009 Directive and partly by the new Drinking Water Directive. The requirement from the 2009 Directive is that microbiological analyses for spring water must be the same as those for mineral water and with the same thresholds. Other aspects are covered by the new Drinking Water Directive.

At the point of bottling, mineral water, spring water and drinking water are considered as foodstuffs under Regulation 178/2002 and follow the requirements of food law.

Bottling plants that have their own private water supply (borehole, spring) and use it for bottling water for sale are exempt from the provisions of the Directive, provided they follow a HACCP plan under the relevant legislation on food.

Water Quality for POU

Water Quality – filtration, treatment and testing

Introduction

POU water dispensers use the water at point of entry into the building.  Depending on the quality of the water, a choice has to be made on further treatment required at the point of use.  The quality of mains water in the UK is good and the treatment processes effective, however, there are 25 water companies in England and Wales alone, each with its own treatment regimes.  It is essential that the POU distributor is aware of the water quality when installing new dispensers.  In fact, this should be part of the risk assessment when deciding on appropriate filters and dispenser types.

Information from Water Companies

The water companies are required to provide you with information for purposes of your risk assessment, as indicated by the Environmental Information Regulations 2004.  Information can include a description of their treatment process, data on historical cryptosporidium breakthroughs and whether special treatment has been used, such as additional filtration and use of UV.  Data on additives used to reduce lead migrating from old pipework and whether chloramines are used in the disinfection process should be available on request.  All this information should enable you to make a make a more informed decision about filter choice.

Typical Water Treatment

There is no typical water treatment because each company’s treatment process will have been worked out based on risk assessments of the source waters.  Generally, coagulation and filtration are the first stages using mixed media filters followed by a primary chlorination.  This chlorination stage will provide initial germ-kill and remove organic material by forming organo-chlorine compounds which are then removed by granular activated carbon beds.  Immediately afterwards the main dose of chlorine is added and allowed several hours contact time.

Special Treatments

Special treatments are put in place according to source water characteristics, for example, if animal waste contamination occurs frequently, special filtration and UV treatment would be employed to reduce risks of cryptosporidium breakthroughs.  If the distribution network is very long, chloramine treatment may be used to enable a more lasting disinfection during transit.  This is done by injecting ammonia in to the chlorinated water which forms the chloramine in situ.  Polyphosphate is added to the water supplies if the pH is low, to avoid lead being dissolved from the surfaces of old pipework.

Water Testing

Water companies provide a source of information to help you in making informed decisions about filters and dispenser specifications.  However, if you need an immediate answer, test strips are available which will indicate free chlorine, total chlorine (the difference will indicate whether chloramine is present), water hardness and pH.  However, you need to contact the water company to assess the risk of cryptosporidium contamination and for lead content.    

Monitoring Water Quality in Bottling Plants

        

Monitor your water quality with a range of diagnostic kits, such as Colilert®.  This measures presence or absence of coliforms and E.coli in source water.  Dipslides give a rapid indication of TVCs (Total Viable counts).   Ensure that your pipework is cleaned and disinfected with the correct cleaners and disinfectants. Hydrogen peroxide is an effective disinfectant which is taint-free and degrades to water and oxygen.  Foam cleaners, for larger surface areas, are available with alkaline, acidic and disinfectant properties.  Water sources are important, whether they originate from springs, boreholes or municipal supplies.  The water needs to be monitored to guarantee wholesomeness.  Our range of kits, test strips, cleaners and disinfectants will take care of the incoming water.  Water hygiene issues? Please call us for advice.

                            

                                                        Colilert® testing

 

                                                                        

                                                  

           Dipslides for Water and Surfaces

Taint in Bottled Water - Airborne Contaminants

Introduction

Bottled water is produced and distributed as a packaged food product and listed under food standards legislation in the UK.  The larger bottles seen on water dispensers in offices and other locations are a popular means of providing hydration to work forces in many industries and students in schools and universities.

Production, Storage and Distribution

The large 19L bottles are filled in a bottling plant and transported to distribution depots where they are stored for a while before delivery to customers.  When the bottles are empty, they are collected from the customer, returned to the distribution depot and subsequently forwarded to the bottling plant for washing and refilling.

Choice of Polycarbonate

Polycarbonate is the major plastic material used for the large 19L bottles.  This has many advantages over other plastic materials, for example, it is a clear, strong plastic which is durable and able to withstand the washing process at high temperatures without shrinkage or damage.  The disadvantage of polycarbonate is the porosity of the material when used in bottles.  Although the porosity does not affect any of the other bottle properties, there is a vulnerability to transmission of certain materials through the bottle walls which can then affect the taste of the water.  The porosity of polycarbonate has been studied and several scientific papers are available^{1, 2}.  The taste buds are very sensitive to minute traces of odoriferous materials in water.

Airborne Contaminants Affecting Taste

Materials with a strong odour, such as solvents, strongly flavoured foodstuffs such as garlic and coffee and certain chemicals will all affect the taste of water if kept in close proximity.  Of particular concern are highly volatile materials, such as volatile organic compounds, since the concentration of these can be very high near their source.  Small molecules are able to penetrate through polycarbonate more easily than larger molecules, for example, xylene is both volatile and a small molecule.  This is a component of paints and other coatings.

Proximity of Contaminants

It is a requirement of all distribution depots that no materials affecting the taste of water are allowed within the depot.  For example, diesel fork lift trucks are forbidden.  It is necessary at certain times of the day to open the roller doors to allow access for loading and unloading.  At this time, the bottled water is vulnerable to contaminants coming from the immediate outside environment.  This is particularly a problem with volatile contaminants such as solvents and other chemicals.  The choice of location of the depot is made with due consideration of near neighbours and any existing processes which could result in airborne contamination.  This sometimes limits the choice of location.

At the point where the roller doors are open, prevailing winds, down draughts, humidity or rain can markedly affect the ingress of contaminants that could affect water taste.

References 

1. D. S. Lee, K. L. Yam and L. Piergiovanni “Food Packaging Science and Technology”, CRC Press, Taylor and Francis Group (2008).
2. Valentina Siracusa “Food Packaging Permeability Behaviour: A Report” International Journal of Polymer Science, 2012 (2012) Article ID 302029, 11 pages.

Tap Hygiene in Hospitals

Many hospital departments have very high public usage of dispensers.  For example, in a major London hospital, the cooler located in A&E was in use 24hrs and, on average, 1000 cups were consumed over a time period when the average for other coolers in the hospital was 300 cups over the same time period.  The bacterial contamination at the tap outlets increased proportionally as the usage increased (survey previously commissioned by British Water Cooler Association).

Tap sprays containing disinfectants provide a simple way of reducing contamination and these are available from several suppliers.  Certain types of disinfectant spray produce a long-lasting effect, up to 30 days.  However, their use requires close cooperation between Facility Managers and the cooler providers to ensure that the coolers with the highest usage are treated more frequently.  Simple swab testing of the taps will enable the effectiveness of this intervention to be monitored. 

Radioactivity in Bottled Water

Objectives

The objectives of this short paper are to provide an easy understanding of the sources of radioactivity in bottled water, the regulated limits of the components causing radioactivity, types of analyses required, risks to human health and remedial actions where necessary.

Putting Risks in Perspective

Drinking-water may contain radioactive substances (radionuclides) that could present a risk to human health.  These risks are normally small compared with risks from microorganisms and chemicals that may be present in drinking-water.  Except in extreme circumstances, the radiation dose resulting from ingestion of radionuclides in drinking-water is much lower than that received from other sources of environmental radiation.  The United Nations Scientific Committee on the Effects of Atomic Radiation has estimated that the global average dose per person from all sources of radiation in the environment is approximately 3.0 mSv/year (the unit mSv is adopted as the measure of the effect of radiation on humans and is called “the Indicative Dose”).  Of this, 80% (2.4 mSv) is due to naturally occurring sources of radiation.  The maximum indicative dose set for drinking-water is just 0.1 mSv.

Indicative Dose for Drinking-water

The annual dose of 0.1 mSv for drinking-water is calculated from the alpha and beta particle levels in a sample of water taken at the point of filling and analysed at an accredited laboratory.  Alpha particles are positively charged and emitted by an atomic nucleus undergoing radioactive decay.  Beta particles are high speed electrons or positrons also emitted from an atomic nucleus undergoing radioactive decay.  They give a total measure of radioactivity from a sample of water measured in units called Becquerels (Bq/l).  The latest Directive (Council Directive 2013/51/EURATOM) sets out a procedure for demonstrating that doses from water supplies do not exceed 0.1 mSv per year (assuming a consumption rate of 730 litres per person per year).  This calculation is based on maximum alpha and beta particle concentrations of 0.1 Bq/l and 1.0 Bq/l respectively.

However, the WHO is at odds with these maximum concentrations and indicates that the maximum limit should be 0.5 Bq/l and 1.0 Bq/l respectively.  However, the EURATOM Directive will be put into the UK Regulations in November 2015, so we must comply with the lower figure for alpha particles.

Annual Water Analysis

Those companies producing between 100 and 1000 cubic metres of water daily must have an annual water analysis which includes alpha and beta particle concentrations.  If the values are less than 0.1 Bq/l and 1.0 Bq/l respectively, the indicative dose will calculate out at less than 0.1 mSv and no further action is necessary.  However if these values are exceeded, further analyses are required to determine repeatability and, if repeatable, analysis for other radionuclides must be done to determine the cause.  Many radioactive isotopes are naturally occurring, such as uranium and radium, which can contribute to high alpha particle readings.  Once identified, these materials can be eliminated by appropriate water treatment processes.

Risk Analysis

The additional risk to health from exposure to an annual dose of 0.1 mSv associated with intake of radionuclides from drinking-water is considered to be low.  Individual doses from natural activity in the environment vary widely.  The average is about 2.4 mSv/year, but in some parts of the world, average doses can be up to 10 times higher without any observed increase in health risks, as noted in long-term population studies.  An indicative dose of 0.1 mSv/year therefore represents a small addition to natural levels.

The nominal risk coefficient for radiation-induced cancer is 5.5 x 10^-2/Sv.  Multiplying this with an indicative dose of 0.1 mSv/year from drinking-water gives an estimated annual cancer risk of approximately 5.5 x 10^-6.

It should be clearly explained that guidance levels should not be interpreted as mandatory limits and that exceeding a guidance level may be taken as a trigger for further investigation, but it is not necessarily an indication that drinking-water is unsafe.

Recommendations and Going Forward

In the event that that alpha/beta particle results are consistently high, identification of the radionuclides causing this is necessary to enable remedial action.  For common radio nuclides which occur naturally, water treatment processes are available to remove them.  For example, uranium and radium can be removed by precipitation softening, ion exchange or reverse osmosis.  It may be possible to treat only part of water source and then blend it with untreated water to bring down levels to an acceptable level.

Conclusion

The new Directive will come into force in English Law in November 2015.  This will require an indicative dose of 0.1 mSv from 1 year’s consumption of drinking-water.  Initial screening has to be undertaken for alpha and beta activity on a yearly basis.  If below the levels of 0.1 Bq/l and 1.0 Bq/l, respectively, no further action to be taken.  If either of the screening levels is exceeded, the concentration of individual radionuclides has to be determined.  The outcome of this further evaluation will determine what further measures will be needed to reduce the dose, such as further water treatment processes.