Water Quality Standards for Source and Bottled Water

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Water quality standards and licensing requirements to sell or distribute bottled water or carbonated non-alcoholic beverages in Massachusetts.

Water Quality Standards

All untreated (raw) source water used for bottled water and carbonated non-alcoholic beverages licensed to be sold in Massachusetts must meet the federal drinking water standards established by the EPA as well as any additional requirements set for drinking water by the MassDEP. Finished bottled water must also meet the federal standards established by FDA. [105 CMR 500.092(A)-(B)]

In 2020, MassDEP amended its Massachusetts Drinking Water Regulations (310 CMR 22.00) to implement a Maximum Contaminant Level (MCL) for Per-and polyfluoroalkyl substances (PFAS). In accordance with section 105 CMR 500.092 MDPH regulations now require laboratory results for source and finished water to be no more than 20 parts per trillion (ppt) for six PFAS chemicals combined (sum): PFOA (Perfluorooctanoic acid), PFOS (Perfluorooctanesulfonic acid), PFNA (Perfluorononanoic acid), PFHxS (Perfluorohexanesulfonic acid), PFHpA (Perfluoroheptanoic acid), and PFDA (Perfluorodecanoic acid).

Table 1 lists the current water quality standards (WQS) used by MDPH to review permit applications submitted by bottling plants. Table 1 also lists the minimum testing frequency required for raw water from private sources and treated water from public water supplies. [105 CMR 500.093(A)(1)]

If source water comes from a public water system, and the source water is used without treatment or with only minimal treatment, then compliance with water quality standards may be satisfied by either:

Submitting a copy of the public water system testing results, or

Submitting copies of certificates showing full compliance with the relevant provisions of 40 CFR Parts 141. [105 CMR 500.093(A)(1)(c)]

If source water from a public water system is treated, then compliance with water quality standards must be met:

For bottled water only – 105 CMR 500.093(A)(1)(d)

For non-alcoholic carbonated beverages – 105 CMR 500.093(A)(1)(a) and (b).

For bottled water, manufacturers are required to submit test results for finished products annually. For carbonated non-alcoholic beverages, manufacturers are also required to test finished products as frequently as necessary to ensure that no product is adulterated and submit results to MDPH upon request. [105 CMR 500.093(D)]

Laboratory Testing Requirements

Laboratories certified by MassDEP must be used when testing in-state water sources, raw water from in-state private sources, treated water from in-state public water supplies, and finished products bottled in Massachusetts. In-state bottling firms must use testing methods specified under MassDEP regulations. Water originating from sources in other states must be tested by laboratories that are certified by the appropriate agency within the state where the laboratory is located. Water from sources outside the U.S. must be tested by laboratories certified by the EPA. [105 CMR 500.091(A) and (C)]

Section 105 CMR 500.093 of MDPH regulations requires applications for all new and renewal permits to include copies of original laboratory reports for, as applicable, source water, treated source water, bottled water, and carbonated non-alcoholic beverages. The following information is required for MDPH review of laboratory reports:

Client's name and address.

Sample identification (indicating "Source" water, "Finished" water (for bottled water), or “Treated” water (for bottled water and non-alcoholic carbonated beverages)); the name of the "Source" or “Treated”, or brand of "Finished" water, and either the date water was bottled, or best buy/expiration date.

Sample collection date.

Sampler's name.

Laboratory name, address and certification number. 

Laboratory Director's signature and date.

Lab Sample ID #

Laboratory Reference #

For each contaminant:

Result in specified units;

Maximum contaminant level (MCL) in specified units;

The method detection limit in specified units;

Analytical method;

Date analyzed;

Space for notation if an analysis was subcontracted to another lab. Include the name, address and certification number of the sub-contracted lab;

A copy of the subcontracted laboratory analysis on the letterhead or report form of the subcontracted laboratory.

In addition to submitting original laboratory reports, applicants must provide the information outlined in Table 2 for each sample in the application.

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