August 11, 2006 : ISDMA's statement on the allegations directed to the cola industry
Our products are absolutely safe. We meet or exceed all applicable government standards -- including those relating to agricultural pesticide residues -- in every country in which we operate, including India. Our products in India are developed and produced to the same stringent quality and safety standards we employ across the globe. Our products were completely safe three years ago when the India pesticide discussion first surfaced, and since then, we have increased testing on key ingredients and enhanced manufacturing processes to further minimize any potential trace pesticides in products. Furthermore we have been working to develop a scientifically validated test method capable of accurately and reliably measuring pesticides in soft drinks to extremely low subpart per billion (ppb) levels.
Through tight quality control measures, we are confident that our beverage ingredients achieve trace pesticide levels that are the lowest technically achievable anywhere in the world. Not only does Pepsi comply with the India Packaged Drinking Water Standard for total pesticide levels (under 0.5 ppb) in the treated water used to make our soft drinks, but we also are confident that our products in the marketplace meet that limit. The accompanying table provides a summary of pesticide test information:
Approximate % of Beverage
Trace Pesticide Test Results at Beverage Strength
|Water||89%||< 0.1 ppb|
|Sugar||10%||< 0.1 ppb|
|Flavor, Caffeine, Color, etc.||1%||< 0.1 ppb|
The use of good manufacturing and hygiene practices, along with the use of approved, safe ingredients and rigorously treated water assure the safety of our products. Our normal quality testing program includes hundreds of tests carried out by our suppliers, our manufacturing plants, our internal central laboratories, and external accredited and internationally recognized laboratories. Our quality approach allows us to successfully make and provide consumers with billions of high quality and safe bottles and cans of soft drinks each year throughout the world.
Every water source used for Pepsi beverages must first be analytically qualified, which includes using accredited laboratories to test for at least 100 parameters. Many classes of compounds are evaluated, including pesticides, metals, radiologics, disinfectants, and organic and inorganic substances. In addition, the microbial quality is evaluated, to help confirm that our products will be microbially and chemically safe. We also believe that protection of water at the source is important, so we provide a formal training program to all of our key beverage plant personnel. The training covers a wide range of areas including water source selection, well construction, and source protection. At every plant, we require the incoming water to be purified even further, using a variety of treatments depending on the raw water characterization, to meet the exceptionally high standards of quality to be used in our products. At a minimum, every plant in India employs a dual back-to-back carbon filter to provide trace pesticide removal just in case any enters the incoming water supply.
PepsiCo commends the Government of India for its leadership in 2004 in establishing standards for pesticides in Packaged Drinking Water that were among the strictest anywhere in the world. According to Indian regulations, the treated water used for the manufacture of soft drinks must also meet these stringent limits-and the water we use consistently meets those standards. We conduct routine global pesticide sampling sweeps of water using an independent, respected, external laboratory in the United Kingdom-the Central Science Laboratory (CSL). Due to our rigorous water source qualification process, on-going monitoring, and purification of incoming water at all of our beverage plants worldwide, the CSL data show all treated water samples from our beverage plants in India contain no detectable pesticides. In addition, all plants regularly submit plant water samples to a Bureau of Indian Standards approved lab, and they too have shown no pesticide detections in our treated water to date.
In addition to the water used in our products, sugar is also a very important ingredient. Testing of sugar samples by the beverage industry and sugar industry has shown no issues with pesticides. In addition, in 2005 the Ministry of Health and Family Welfare undertook a comprehensive study of the quality of the sugar supply in India along with the Ministry of Agriculture. The preliminary results of this study, to be published as an effort of the local World Health Organization, show no pesticides detected in any of the over 200 samples which were obtained. This supports data from a study that was conducted in 2004 by the Sugar Processing Research Institute, with testing performed by CSL.
Sugar must meet high standards of quality, which are uniform for all of our beverage plants across the globe. All of our sugar manufacturers must undergo the same supplier qualification process. This centrally-developed and locally-executed process includes submission of samples to approved third-party laboratories, in order to verify the sugar meets our strict specifications. Also included in this supplier qualification process are audits of the refinery operations. To add to our already high quality standards, all of our plants in India further purify sugar with hot activated carbon and fine filtration, which has been demonstrated to be extremely effective at removing trace levels of pesticide residues if they happen to be present in sugar supplies.
Our flavor concentrates, which make up less than 1% of our finished beverages, also are diligently controlled. The suppliers of our key concentrate ingredients must pass a rigorous supplier qualification scheme, which includes detailed, on-site audits of every facility producing the ingredients. This qualification is centrally directed from our Technical Headquarters, and the same audit and verification standards are applied globally. Each supplier must submit written verification that each lot of ingredient shipped to our facilities meets our strict specifications. Flavor ingredients are tested twice, at the supplier and at time of receipt. Flavors which yield unacceptable test results are immediately screened out of use.
In addition to water, sugar, and flavor testing, other ingredients, which make up only a fractional part of the finished beverage, have been analyzed by outside laboratories. These include ingredients that are not agriculturally derived. None of the other additives had pesticide levels above the level of detection. One more key point on Pepsi flavors and concentrate ingredients: All materials sourced to manufacture concentrates are used all across the globe to produce our soft drinks.
So, our products are safe-absolutely. The scientific data described above demonstrate that pesticides are not a safety concern with our beverages. Nonetheless, in an ongoing effort to ensure safety and encourage consumer confidence, we want to work with the Indian government to establish an acceptable beverage testing methodology to support the establishment of appropriate pesticide limits in soft drinks. The analysis of residues at very low levels of detection even in water is difficult and requires expensive and highly sophisticated equipment not readily available in many countries. The complexity of testing beverages is partly due to the variety of ingredients which are not present in water. The ingredients can interfere with the detection of pesticides and lead to faulty results. Methods must be specific for beverage systems to eliminate this interference so accurate assessment of the pesticide residue content can be determined.
To that end, Pepsi has been working hard the past two years and is close to finalizing a beverage test method that will allow the industry to accurately measure pesticides to sub-ppb levels. Pepsi has engaged the premier methods validation leader, the Association of Official Analytical Chemists (AOAC) International, to support the standard scientific protocol of conducting peer reviews and multiple laboratory validations in order to confirm the effectiveness of the test method. This test method involves very sophisticated equipment (gas chromatographs, liquid chromatographs, and mass spectrometers) and procedures (residue extraction from the test sample, separation from other materials, concentration for analysis, and selective/specific detection) to ultimately provide confidence in the accuracy and dependability of the results when testing a complex matrix like soft drinks.
We have always supported efforts which strive to improve the safety of India's drinking water, environment, and food supply. PepsiCo will continue to support and collaborate with the most appropriate Government ministries in order to assure the safety of the people of India.
PepsiCo remains committed to ensuring consumer safety, complying with all applicable regulations, protecting our product trademark, and delivering a safe, refreshing beverage to the consumer.