Randall S. Joslin, MPA - Comment

Subject: Comment on Proposed Rule: Docket No. FDA-2008-N-0446 As a student of Public Administration, and a former department manager within a bottled water manufacturing plant, I find myself enlightened by research performed on the subject of this proposed rule. In my past experience as a manager within a bottled water manufacturing plant, I was already very familiar with the multitude of quality control testing processes required in all aspects of the production of bottled water, and even more familiar with the existence and application of Good Manufacturing Practices (GMP) related to the production of an FDA- regulated food product. What I was not so familiar with was the actual regulations and legislation behind the practices of my former career. Research on this proposed rule has explained the existence of the regulatory rules, 21 CFR parts 129 and 165, regulations which the FDA uses, in conjunction with the Federal Food, Drug, and Cosmetic Act (FFDCA) in the compliance standardization applicable to the production of bottled water. Further, I was not aware that these aforementioned regulations have a direct ‘tie- in’ to the Safe Drinking Water Act (SDWA) enforced by the EPA. Both as an American citizen and a student of Public Administration, it is impressive to see the interaction of these various regulations in the federal government’s protection of the public health. Based on my extensive experience as a manufacturer of bottled water, and my newly acquired regulatory knowledge relating to the establishment of the standards to be followed to safely produce bottled water, I can attest most positively to the need for the existence and enforcement of such regulations. To know that the public policy involved in this arena of public safety is continuously evolving, for the better, I can only offer my most sincere support. Consequently, I whole-heartedly support the passage of this proposed rule as it is most definitely in the best interest of public safety. This rule should prove to be fully implementable by manufacturers with little or no extra cost or effort, and I remain confident that it will prove it’s worth in the public interest. Randall S. Joslin, MPA Doctoral Student (Public Administration) University of La Verne