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Proposed Draft Code of Hygienic Practice for Packaged (Bottled) Drinking Waters (Other than Natural Mineral Water)[10] (Agenda item 9)

32. The Delegation of the United States presented the proposed draft which had been revised in the light of the comments received. The Committee expressed its appreciation to the United States and the countries involved in the redrafting for their constructive work, and after reviewing the text section by section, agreed on the following amendments.

33. The Committee agreed to the proposal of the Delegation of India to amend the title to refer to Packaged (Bottled) Waters to better reflect various packaging materials being used.

34. In the Introduction, a reference to "physical and chemical safety" was added to microbiological safety, in order to cover all classes of hazards.

35. In Section 2.1 Scope, the Committee agreed that reference to labelling should be placed in square brackets for the time being, subject to deletion of the term at a later stage.

36. In Section 2.3 Definitions, the Committee agreed that some clarification would be needed regarding "Ingredient" to avoid any possible confusion. The Delegation of Uruguay suggested the deletion of the word "Ingredient" or that the reference be made to the definition of packaged (bottled) potable water.

37. In Section 3.3.1, the wording was amended to make it clear that the text covered surface water as well as underground water, especially by referring to "extraction and collection". In Section 3.3.1.3, the Committee agreed to replace the reference to "coliforms" with "indicator organisms".

38. In Section 3.3.2, the Delegation of France, supported by some delegations, proposed to indicate that bottling at the source should be encouraged in order to minimize risks of contamination. The Delegation of the United States, supported by other delegations pointed out that when it was not possible to bottle water at the source, other preventive measures could be applied, that physical distance between the point of origin and the bottling point did not constitute a risk in itself, and that the code should not be too prescriptive in this respect. The Committee however agreed to refer to a directly connected piping system of water supply as one of the means of avoiding contamination from bulk transport. The Committee agreed that the important consideration was adherence to hygienic practices through all stages.

39. The Committee agreed to the proposal from the Delegation of Brazil to include a new section on Protection of Surface Water Supply (3.2.2) and Criteria for Surface Water Supplies (3.2.2.1), with specific wording to be included at a later stage.

40. The title of Section 5.1.1 was amended to refer to "Preventive measures", to reflect that other measures than treatments were included. The Committee further agreed to delete the reference to glacier water in the third paragraph and to specify that surface water should be treated where necessary.

41. The Committee noted a proposal to delete the entire Section 5.4 Packaging as reference to the General Principles of Food Hygiene might be sufficient, and agreed to consider this possibility at a later date.

42. The Committee noted that the sections corresponding to matters covered by the General Principles of Food Hygiene were omitted, whereas an explicit reference was included in other codes and it was noted that consistency should be sought in the format of the codes. The Delegation of Canada preferred the approach being used in the Draft Code considered under Agenda Item 4 (see Appendix III).

43. In Section 9, the Committee recalled its decision at the 29th Session that labelling provisions should not be included unless they related to food hygiene matters, and the opportunity of including the requirements intended for infants (9.3.1) and immunocompromised persons (9.3.2) was discussed extensively. Some delegations and the Observer from Consumers International pointed out that the section addressed essential health concerns and should be included in the code, especially as no standard existed as yet for bottled waters.

44. Other delegations supported the deletion of Section 9 as labelling provisions should not be addressed in a code of hygienic practice; it was also noted that recommendations on the ingestion of water by infants (9.3.1) were more closely related to nutrition aspects than to food safety. Moreover, such labelling might imply that treated waters were safer than other similar products and therefore mislead the consumers. Information for specific population groups should preferably be provided through consumer information and education programmes.

45. The Delegations of the United States and the United Kingdom stressed that, although the current text (9.3.2) referred to immunocompromised persons, the contamination of underground water with parasitic protozoa was a serious concern affecting all consumers, and this issue would need to be addressed in further discussions.

46. The Committee agreed that Section 9 should be deleted at a later stage and that related issues might be addressed in some way by the time the corresponding commodity standard was developed in the future. However, as the need for further consideration of these important issues was recognized, both sub-sections were left in square brackets, in order to invite governments to provide additional comments on how to address these issues for consideration by the next session.

47. It was suggested by the Delegation of India, supported by other delegations, that end-product specifications should be reflected in the Product Standard as has been done in the case of the Standard for Natural Mineral Waters. The Committee noted that the development of Appendix 1 (Application of the

HACCP System) would proceed with the questions and guidelines and not give HACCP examples. Appendix 2 (Microbiological, Chemical and Physical Criteria) would be considered at the next session on the basis of the comments received.

STATUS OF THE PROPOSED DRAFT CODE OF HYGIENIC PRACTICE FOR PACKAGED (BOTTLED) DRINKING WATERS (OTHER THAN NATURAL MINERAL WATER)

48. The Committee, recognizing that substantial progress had been made on the text, agreed to advance the Proposed Draft Code to Step 5 of the Procedure (see Appendix V).


[10] CX/FH 97/8, CX/FH 97/8-Add. 1 (comments of Canada, UK, USA, Consumers International, UNESEM/GISEM, CRD 6 (Costa Rica))

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