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WHAT REGULATIONS GOVERN BOTTLED WATER?
The Food Standards Australia New Zealand (FSANZ) sets the minimum standards for all types of bottled water. These regulations are set out in the Food Standards Code. The primary Standard is 2.6.2 "Non-alcoholic Beverages & Brewed Soft Drinks". Bottlers must also comply with all the other requirements of the Code including "Labelling and Other Information Requirements" (Standard 1.2), Contaminants and Residues (Standard 1.4), Microbiological and Processing Requirements (Standard 1.6) and the Food Safety regulations (Standard 3.1).
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WHAT IS THE ABWI MODEL CODE?
The bottled water produced by ABWI members must meet standards that are, in some cases, stricter than the FSANZ standards. ABWI has developed a quality assurance program called the Model Code, which is a strict set of standards for the safe processing of bottled water. All members of ABWI must meet the standards contained in the Model Code.
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THE CURRENT ABWI MODEL CODE - A BRIEF HISTORY
The ABWI Model Code is the Australasian successor to the International Bottled Water Association's Model Code. The Model Code Sub-Committee started with the IBWA Code and made amendments based on suggestions from the membership and assessment of local needs and FSANZ regulations. Where no suggestions for changes were made, and where the Committee did not identify the need for changes, the provisions of the IBWA Model Code were adopted. From the beginning, the Committee saw the ABWI Model Code as a living document and instituted a mechanism for receiving suggestions and for review by the ABWI Technical Committee.
THE ABWI CODE CERTIFICATION - WHAT DOES IT MEAN?
One of the primary objectives of the Model Code is to create a framework for the safe bottling of water, and guarantees the consumer a quality product. Another objective is to provide bottlers with a "how-to" framework, to assist them in raising the quality of their production methods. It is therefore important that bottlers realize that the Code is not simply a "food safety program".
Passing a HACCP certification or any other certification process, does not mean that you will comply with the ABWI Model Code.
The ABWI program requires a commitment that goes above and beyond the minimum requirements of a food safety program. Hence it's uniqueness and it's value in differentiating the ABWI Certified Bottler from the run-of-the-mill operator that may produce a potable water product.
WHOSE RESPONSIBILITY IS IT ANYWAY?
It is the primary responsibility of every Candidate Bottler, on joining ABWI to familiarize itself with the Model Code. Further, it is the responsibility of every Candidate Bottler to achieve compliance within the first 12 months of membership. If a bottler does not wish to comply with the Model Code, then that bottler ceases to be a member of ABWI.
THIRD PARTY AUDITORS
The ABWI Board, on the recommendation of the ABWI Technical Committee, approves appropriately qualified third-party auditors to conduct audits based on the ABWI Model Code. Each third-party auditor meets the Technical Committee's requirements for an audit check-list and scoring method.
AN INTERNATIONAL PROGRAM
ABWI is a member of the International Council of Bottled Water Associations (ICBWA). A fundamental requirement of membership is that each member Association must have in place an approved, third-party audit program and certified Model Code and that membership be based on compliance with that Code. Membership of ICBWA is in its own way a "certification" of the respective Codes and Programs.
ABWI is proud of its compliance and participation in this international program to raise the quality of bottled water.
PLANT INSPECTION PROGRAM
SELF-REGULATION FOR BOTTLERS
As a condition of membership, all ABWI Bottler Members participate in a self-regulatory scheme of plant inspections. The Plant inspection program assists members to reach the highest levels of quality and to provide a benchmark. As part of the program all bottler members are subject to an annual plant audit administered by an independent internationally recognized third-party organization. This inspection assures that all ABWI bottler members meet both FSANZ and ABWI requirements for the production and sale of bottled water.
AUDITS
The The Australasian Bottled Water Institute has certified Correct Food Systems, Lloyd's Register Quality Assurance, NCSI and QUASI as independent internationally recognized third-party auditors for approved Bottled Water plants.
The purpose of the Audits is to ensure that ABWI bottler members' quality standards are in compliance with the requirements of the Model Code. For example, ABWI bottler members must analyze their source and their final bottled water product. ABWI bottler members submit the full records of their bottled water test results to theCorrect Food Systems, Lloyd's Register Quality Assurance, NCSI and QUASI auditor.
WHAT HAPPENS IF A BOTTLER FAILS THE INSPECTION?
Although rare, if a bottler does fail the inspection, the bottler must take corrective action to rectify the problem. ABWI fully documents and verifies the corrective measures that were taken. Any deficiencies discovered during their annual inspection must be corrected within 30 days. In addition, a second inspection may be performed at the bottler's expense.
If a bottler fails the inspection, does it mean that they failed to meet FSANZ Regulations?
Just because a bottler failed ABWI's unannounced inspections does not necessarily mean that they failed to meet FSANZ Regulations. In some instances, ABWI's Model Code standards are more stringent than the FSANZ regulations currently in place for bottled water.
CERTIFICATION
Bottlers on successfully completing their audits and after signing a contract with the Institute are entitled to the use of the ABWI "Certified Bottler" Logo on their labels, coolers, stationary etc.
For further details contact abwi@bottledwater.org.au
SOURCE APPROVAL
An issue of importance to us all, is that of source approval. The ABWI has written to the Chief Food Officers in all States & Territories.
What we are seeking is a uniform source approval process that in addition to any local geological assessment requirement, also requires:
- an analysis of the water indicating that it is fit for human consumption,
- an inspection of the source and any extraction mechanism, to ensure that the source is protected and that sanitary extraction methods are in place,
- an approved HACCP based safety plan, and
- An annual inspection program of the site and the safety plan.
Our aim is for this to be required by regulation, to reduce any competitive disadvantages that may otherwise flow on from simply adopting these procedures as part of our own rules.
FOOD SAFETY
The Australasian Bottled Water Institute's Food Safety Templates are under review, due to changes of Victorian State regulations and draft national regulations.
If you are an ABWI member and you need ssistance, ABWI can put you in touch with an ABWI member consultant. Contact abwi@bottledwater.org.au.
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