International Bottled Water Association

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International Bottled Water Association Company/Contact Information Facility# - Name 30551 - Vetter's Inc Address Store# Facility Contact DBA Culligan701 W. 76th Street,Davenport,Iowa,United States,52806 Mr. Jeff Claussen Phone 800-383-6088 Fax 563-391-8750 Email jeffc@vettersculliganwater.com Audit Contact Client# - Name Client Contact Jeff Claussen 85000 - International Bottled Water Association Mr. Bob Hirst Audit Information Audit# - Visit# 577697-385865 Audit Type IBWA Template Version 1.2 Audit Category RECURRING Audit Year 2011 Period Auditor Audit Start Time Audit End Time Stuart Zeilstra 11-AUG-2011 08:00:00 AM 11-AUG-2011 12:00:00 PM Facility Performance Number of GMP + HACCP Major Non conformances 0 Number of GMP + HACCP Minor Non conformances 0 Number of Membership Major Non conformances 0 Auditor's Note General H1 HACCP Plan written and implemented. (HMj) H2 HACCP Plan independently validated or self-validated by the company. (HMn) H3 Multi-disciplinary HACCP team with product and process experience identified in HACCP Plan - meets regularly. (HMj/HMn) H4 All product water types identified and addressed by HACCP Plan. (HMj) H5 Process flow diagram covering all steps in the operation and representative of operation included in HACCP Plan. (HMj/HMn) H6 Biological, chemical, and physical hazards identified in HACCP Plan.(HMj) H7 Preventive measures identified for each hazard in HACCP Plan. (HMj) H8 Critical control points identified in HACCP Plan. (HMj) H9 Monitoring schedule established for each CCP in HACCP Plan and is verifiable with records. (HMj) H10 Person(s) responsible for monitoring identified In HACCP Plan and verified. (HMj) H11 Records signed by responsible person(s); verified. (HMn) H12 Records reviewed and signed by review official and verified. (HMn) H13 Corrective action established in HACCP Plan for each CCP. (HMj) H14 Product disposition tracked and verifiable with records. (HMn) Page 1 of 5 08/12/2011 00:07:22 Audit# - Visit # : 577697-385865

General H15 Process for review of HACCP system and records established. (HMj) H16 Documentation and recordkeeping system in place. (HMj / HMn) H17 Employee training documentation. (HMn) H18 Quality assurance SOP. (HMn) GMP G1 Product water from approved source; complies with applicable laws and regulations; documented; complies with GMPs and SOQs; source integrity verified; source free of surface water influence. (HMj) Iowa American Water Company is the source. G2 Source waters analyzed annually for chemical/physical parameters; every four years for radiological parameters. Non-PWS source waters analyzed weekly for microbiological contaminants. (HMj) G3 Product water contact surfaces comply with FDA, Codex, or other applicable standards; are of nonabsorbent, nontoxic materials; can be adequately cleaned and sanitized. (HMj) G4 Treatment process achieves intended purpose; inspection records maintained and reviewed. (HMn) G5 Product water samples taken after processing prior to bottling to verify effectiveness of treatment process; approved analysis methods. (HMn) G6 Unsanitary or defective containers reprocessed or discarded; multi-service containers cleaned, sanitized prior to filling and capping; records maintained. (HMn) G7 Mechanical washers inspected and records maintained for maintenance and performance. (HMn) G8 Sanitizing operations comply with applicable regulations and manufacturers directions; records maintained. (HMn) G9 Containers and closures nontoxic; comply with applicable regulations. (HMj) G10 Filling, capping, and sealing monitored; filled containers inspected; records maintained. (HMn) G11 Containers and closures tested for microbiological contaminants at least quarterly; records maintained. (HMj) Customer should make sure to note on the test reports that four caps have been tested. The results they have do not state that four caps were tested, but they did submit four to the lab. G12 Samples taken at least once per week for each product type; analyzed at an approved laboratory for microbiological contaminants; records maintained. (HMj) G13 Bottled water products tested daily for total coliform by an in-house laboratory or an approved laboratory. (HMj) G14 Samples analyzed at least once per year for each product type for chemical and physical parameters by an approved laboratory. (HMj) G15 All records of certifications and approvals of source and operations water on file. (HMn) G16 All records retained for a minimum of five years. (HMn) Plant Construction G17 Properly stored equipment, refuse, waste; litter. G18 Road, yard, and parking lot dust controlled. G19 Grounds adequately drained. G20 Sufficient space for equipment, storage of materials; aisles and working spaces clear; sufficient width. Page 2 of 5 08/12/2011 00:07:22 Audit# - Visit # : 577697-385865

Plant Construction G21 Proper construction: floors, walls, and ceilings; clean. G22 Fixtures, ducts, and pipes placed to preclude drippage or condensate from contaminating product. G23 Bottling room separate from other plant operations; tight walls and ceilings; self-closing doors; conveyor opening size; lights protected. (GMj / GMn) G24 Adequate lighting: work stations (50 FC min.), hand washing, locker rooms, toilet rooms; Other areas (20 FC min.). All lighting excedes the minimum requirements. G25 Light fixtures over processing areas (outside fill room) safety type or otherwise protected. G26 Adequate ventilation provided to minimize odors, noxious fumes, or vapors and condensate in processing, bottling, container washing and sanitizing rooms; ventilation equipment clean. G27 Effective screening or other protection provided against birds, animals, or other pests. G28 Product in process in sealed piping system under pressure; free of excessive leaks or other sources of contamination. G29 Bottle washing/sanitizing in an enclosed room; positioned to minimize post-sanitization contamination. G30 Processing, washing, other rooms not directly connected to room(s) used for domestic household purposes. Sanitary Facilities & Control G31 Operations water meets applicable regulatory standards and requirements. (GMj) G32 Source water approved by agency having jurisdiction or by certified or licensed professional geologist or hydrogeologist. G33 Air under pressure directed at product water or contact surfaces free of oil, dust, rust, N/A excessive moisture; does not affect bacteriological quality. G34 Locker and lunch rooms separate from plant operations and storage areas; doors are self-closing; rooms are clean and sanitary; refuse container(s) provided; packaging, wrapping materials and processing supplies absent. G35 Sewage disposal and plumbing adequately installed and maintained. G36 Floor drainage adequate where flooding type cleaning or where normal operations discharge on the floor. G37 Toilet facilities adequate; handwashing facilities provided; facilities sanitary; doors selfclosing; doors do not open directly into processing areas; handwashing signs provided. G38 Handwashing facilities adequate, convenient; provided at each location where employees are required to wash or sanitize and dry hands; hot and cold tempered water provided; sanitary towels or dryers provided. G39 Rubbish disposal provided; proper receptacles with covers. Sanitary Operations G40 G41 G42 Product water contact surfaces (utensils, pipes, equipment) clean and adequately sanitized daily; records maintained. (GMj / GMn) Product water contact surfaces maintained free of scale, oxidation, and other residue. Presence of any unsanitary conditions corrected immediately. Cleaned multi-service containers, utensils, disassembled piping, and equipment transported and stored in a sanitary manner. Page 3 of 5 08/12/2011 00:07:22 Audit# - Visit # : 577697-385865

Sanitary Operations G43 Containers, closures, or seals purchased and stored in original containers in clean, dry place; examined before use; handled, dispensed in a sanitary manner. Washed, rinsed, and sanitized as needed. G44 Sanitized open bottles protected from washer to filler. G45 Filling, capping, closing, sealing, and packaging done in a sanitary manner. G46 Cleaning operations conducted in a manner to preclude contamination of product contact surfaces. G47 Only toxic materials necessary for maintaining sanitary conditions, plant, or equipment or for use in laboratory/processing operations are used/stored in plant. Materials are identified and used as intended. G48 Pesticides used in accordance with label directions, restrictions. G49 Non-product contact surfaces of equipment free of accumulated dust, dirt, and other debris. Equipment & Procedures G50 Equipment suitable for intended use, designated, and of materials to be cleanable and properly maintained. G51 Storage tanks can be closed to exclude all foreign matter; filtered vents provided; filters readily cleanable or replacement elements. G52 Product water separate from operations water to preclude contamination of product; either separate piping systems or suitable backflow prevention. (GMj) G53 Dispensing equipment refurbishing used acceptable coatings; water dispensing reservoirs and valves adequately sanitized and protected before use. (GMj/GMn) Processes & Controls G54 Treatment equipment processes and substances used preclude contamination or adulteration of product. Bottled water product shall not be transported, stored or processed through non-food equipment. If equipment is used for other foods, a documented cleaning/sanitizing procedure shall be made available. (GMj) G55 Multi-service shipping cases maintained to assure they will not contaminate primary container or product. G56 Each product identified by production code. Code identifies particular batch or segment of continuous run and day produced. (GMj) G57 Records maintained of kind of product, volume produced, date produced, lot code used, and distribution to wholesale and retail outlets. Personnel G58 Personnel with disease in communicable form excluded from work in any capacity where there is reasonable possibility of product contamination or transmittal to other individuals. (GMj) G59 Personnel practices: Clean outer garments worn; high degree of personal cleanliness exhibited; hand washing practices adequate; uncleanable jewelry not worn on hands; effective hair restraints used; tobacco not used in any form; no eating at workstations. G60 Sanitization SOP. (HMj) Page 4 of 5 08/12/2011 00:07:22 Audit# - Visit # : 577697-385865

Personnel G61 Recall program. (HMj) G62 Raw material program: Are raw materials specifications documented. Are raw materials verified and checked for condition at time of receipt? (HMn) IBWA MEMBERSHIP REQUIREMENTS M1 Plant is operated under the supervision of a competent person qualified by experience, education, and training to operate and maintain the plant's facilities. Said person holds a certificate from IBWA or an applicable state agency. (MMj) Kevin Schlemme, expires 12/31/13 M2 IBWA member proprietary brands include on the label a telephone number of the bottler, distributor, or brand owner as a means of contact for consumers who wish to obtain additional product information. (MMj) M3 Written document containing analytical test results and any other pertinent water quality information for bottler's proprietary brands available for inspection during audit. Document is made available by company to consumers upon request. (MMj) M4 Annual audit completed each year. (MMj) M5 Written policies and procedures designed to protect the integrity and security of their operations and products (bottled water facility security plan). Facility registered with the US Food & Drug Administration.(MMj). * Represents Non Compliances. For questions regarding the audit, please contact your program manager, Myla Estacio, at 734-913-5738 or mestacio@nsf.org or through NSF Online. Page 5 of 5 08/12/2011 00:07:22 Audit# - Visit # : 577697-385865