.We are working on a self regulation protocol that would enable members who install point-of-use to fulfill the European Directive for Human Consumption.

Alex Mezquida

Board Member of Watercoolers Europe and Training & Audit Manager at Laboratorio Dr. Oliver Rodés

May 4, 2012

Alex Mezquida makes an extensive review of European legislation

Alex Mezquida is Board Member of Watercoolers Europe and Training and Audit Manager at Laboratorio Dr. Oliver Rodés. He has two degrees: in Pharmacy (MRPharmSGB) and in Science and Food Technology.

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  • WE

    What are in your view the biggest changes that have affected the bottled water industry over the past few years?

  • Alex Mezquida

    These include the introduction of private labels; the marketing of bottled mineral water and especially the promotion of bottled water as a natural product that brings original purity to the consumer.

    Another change and a step forward is the way different kinds of bottled waters can be brought to the end user either by means of large-scale distribution, through small vending machines or through the larger, five-litre capacity bottles. This helps bottled water reach a wider audience and makes the product more affordable at the domestic level.

    Also, environmental considerations have lead the industry to further reduce plastic in its production and to invest in biodegradable materials in order to reduce the carbon footprint.

  • WE

    A European policy goal is to harmonize legislation in all Member States. Are there any conflicts or contradictions requiring harmonization?

  • Alex Mezquida

    Actually, European policy works in the completely opposite way. It lays out a base of minimum rules that all countries must and from that foundation, each Member State can develop further its own regulatory framework, in light of local considerations. So all of the countries have to harmonize their different regulations but can add further requirements.

    The fact is that this can cause contradictions between different countries laws. One of the requirements that may vary from country to country is the actual classification process of natural mineral water: some EU Member States require clinical, pharmacological and physiological tests to approve it as such, while others do not.

  • WE

    As a Manager at Dr. Oliver Rodés laboratory, what was your contribution to WE’s Code of Good Hygiene Practice that was adopted by every WE member?

  • Alex Mezquida

    I have worked in close cooperation with other experts from different countries when drafting several recently published texts, such as the WE Technical Manual and the Guidelines for Good Hygienic Practice for Distributors and Operators of Plumbed-in (POU - Point of Use) Water Coolers. These were both published in late 2011.

    I also participated in the writing and implementation of several protocols that enable our members to prove the efficiency of sanitation in bottled watercoolers and point-of-use. I equally participated in the writing of watercooler bottling and distribution audit checklists, used in annual audits that WE members carry out as part of ongoing improvement processes.

    Generally speaking, our laboratory which this year turned 110 years has collaborated with the European Bottled Watecooler Association since the founding of the Spanish Watercooler Association (ADEAC) in 1998. It is an independent and private entity highly specialized in different kinds of water, whether bottled water, main's water, waste water, pharmaceutical water and so on. This makes our technicians ideal experts for associations like WE. They are neutral in assessing different quality standards as our laboratory is commercially independent.

  • WE

    Water testing methods are regulated in the different laws. Which supervisory authority oversees these regulations at national level?

  • Alex Mezquida

    In Europe each state has its own authority - except Germany which has more than one - that authorizes laboratories to both analyse and oversee the enforcement. As we are located in Spain, the ENAC (National Entity of Authorization) is the authority that annually audits our work according to the international standard UNE-EN ISO/IEC 17025 that specifies the general requirements for the competence to carry out tests and calibrations.

  • WE

    The bottling of natural mineral water is regulated in detail in Directive 2009/54/EC. Which national authority supervises the implementation of these regulations?

  • Alex Mezquida

    The European authority responsible for supervising the implementation of regulations related to food and beverages in each Member State works closely with the corresponding national authorities. In Spain the Ministry of Health that supervises these regulations, while at local and regional level the competence lies with the relevant Sanitary Authority. Correct labeling in turn is supervised by the authorities that have the responsibility for trade in each country.

    This complexity creates a large diversity of criteria that can be open to interpretation, and this makes the implementation of relevant regulations even more complicated. Already for this reason, our laboratory s extensive experience is truly valued by our customers.

  • WE

    What would happen if the supervisory authority ruled that mineral water from a WE member company does not comply with directives, or involves a public health risk? What would the process be to rectify the situation?

  • Alex Mezquida

    In the event of bottled water not adhering to what is laid out in EC legislation, or involving a public health risk, the distribution of the product could be temporarily stopped. The EU Commission and the Member States would be informed of the situation, as well as of the reasons for the decision. The Member State that approved the bottled water would also be asked for the information that relates to its approval.

    Overall, each region within Spain can be held liable for the problem. The seriousness of the recorded deviation will determine whether there should be preventative retention and/or whether destruction of the non-compliant product is required. The authorities can resort to a range of different measures, ranging from economic sanctions and corrective measures to even the closure of a bottler's activities until requirements set in regulations are fulfilled.

  • WE

    With reference to regulations concerning bottled water and water for human consumption, what governing principles do European and other international laws have in common?

  • Alex Mezquida

    Related legislation is primarily based on the World Health Organization (WHO) Drinking Water Guidelines and its scientific reports, as well as on applicable national requirements that could be more stringent.

  • WE

    Do you think we miss any related European or international rule or policy that you believe all countries should adhere to?

  • Alex Mezquida

    We need to seek legislation to include point-of-use connected to main’s supply. This equipment should fulfill the most recent WHO directives that refer to the quality of the PoU dispensed water, not only to the rules for filters, fittings, treatments or pipes. Currently these are certified separately, according to the specific standard of the country in which the manufacturer sells its products.

  • WE

    Do you think there are opportunities to improve European legislation that regulates our industry?

  • Alex Mezquida

    Overall, materials which come into contact with water are an unresolved issue that should be addressed by the European Union. There is a gap vis-a-vis quality criteria for point-of-use. There isn't enough coordination between the numerous standards for each kind of point-of-use and these standards are often hard to meet. Also, there is no common position among industry experts when it comes to addressing this issue together.These factors have created a strained situation that could have an adverse effect. This could also create a situation where future regulation regarding point-of-use, filters or fittings may be difficult to implement.

    ADEAC (Spanish Watercooler Association) has constructively participated in the process of developing national industry regulation. The most significant advance in this respect was the inclusion of bottled watercoolers in the regulation regarding spring water, natural mineral water and other bottled waters (RD 1798/2010; RD 1799/2010).

  • WE

    Finally, is there anything more you believe should be included in the Code of Good Hygiene Practice?

  • Alex Mezquida

    At this moment we are working on a self regulation protocol “Standard methodology for the examination of dispensed water of POU & PE water coolers installed inside buildings”. It would enable members who install point-of-use connected to main s supply to fulfil the European Directive for Human Consumption (Directive 98/83/EC) and the Commission Regulation on plastic materials and articles intended to come into contact with food (Regulation (EC) 10/2011).

    This protocol will take WE members ahead of the requirements in existing legislation and will fulfil the WHO guidelines as expressed in the 2011 document ‘Water safety in buildings’ that refers to the quality of water provided through a dispenser connected to main s supply, whether PE or POU.The document recognizes POU and PE as compounds or elements that can improve water provided through water main's supply, but it also identifies them as critical points to which control measures must be applied.

    Also, at the next WE General Meeting we will present a proposal for an audit checklist for WE members who install POU and PE.

Past interviews