SAFETY ADVISORY

CUBITAINER SAFETY

Date/Time: June 20, 2010

Purpose: Cubitainer Safety

Narrative: During recent fire incidents in the Southwest Area, safety concerns continue to arise regarding the
safety and quality of drinking water stored in cubitainers. The concerns stem from the safety of the water that sits
for long periods of time and/or becomes exposed to heat with other concerns related to the sanitation of the water
and cubitainers, especially when used by multiple personnel or filled from multiple water sources. These
concerns are associated with recent health concerns of plastic water bottles containing bisphenol-A (BPA). There
was an initial concern that the cubitainers had an established ‘shelf life’, which has turned out not to be
determined.

Recent studies provided by Missoula Technology and Development Center (MTDC) states that containers
constructed from a high density polyethylene (HDPE) provided no evidence of adverse health effects. These
include containers such as quart canteens currently used by fire personnel and Nalgene bottles. MTDC also
stated that the manufacturer of cubitainers was contacted and stated that the plastic used has no contaminants, is
FDA food and beverage grade, and does not have any "shelf-life" for water storage. They also stated that the
cubitainers are sterile and ready for use as the manufacturing process and subsequent handling follow FDA
guidelines for food container handling. No further sterilization is necessary. The manufacturer also provided a
letter with the following statement about BPA in the plastic:

No Bisphenol-A (BPA) is intentionally introduced or used as an additive or raw material in the manufacture of
the product listed below. Although our suppliers do not analyze for substances not purposely added, it would not
be expected to be found in the final product. Any presence of Bisphenol-A is purely incidental and unintentional.
We would not expect the total incidental concentration of this substance to exceed 0.1% (1000 ppm).

Some personal water containers such as Camelbak-type systems are known to contain possible bisphenol-A.
However, research on human health effects from bisphenol-A in polycarbonate plastics is limited. Other
containers used by fire personnel such as single use water bottles are produced from polyethylene terephthalate
(PET) which has been determined acceptable for use by the Food and Drug Administration (FDA).
Currently all companies that produce products containing bisphenol-A have removed these products from
production as of April 2008.

To date, there have been no ‘safety alerts’ or ‘advisories’ posted in the Federal Wildland Fire agencies specific to
cubitainer safety. Cubitainers have been used for decades by wildland firefighters with no known health hazards
and continue to be safe and efficient when used properly and in accordance to recommended guidelines.

The following are recommendations to consider when using any water container for personal use and as
determined through 21CFR129.80(b) and the current National Mobile Food Services contract:
 • 21CFR129.80 (b) Containers. (1) Multiservice primary containers shall be adequately cleaned,
sanitized, and inspected just prior to being filled, capped, and sealed. Containers found to be unsanitary
or defective by the inspection shall be reprocessed or discarded. All multiservice primary containers shall
be washed, rinsed, and sanitized by mechanical washers or by any other method giving adequate sanitary
results. Mechanical washers shall be inspected as often as is necessary to assure adequate performance.
Records of physical maintenance, inspections and conditions found, and performance of the mechanical
washer shall be maintained by the plant.
• When using cubitainers, ensure that the container is clean and the inside of the lid has not been
contaminated (such as dirty fingers putting the lid back on).
• Store all water storage containers in a cool, dry place out of heat and direct sunlight, when possible.
• Do not store cubitainers near any sources emitting fumes such as gasoline, kerosene, or other as the fumes
can penetrate some plastics.
• When filling cubies or water containers with municipal or other (such as a well), ensure it is a safe water
source (through testing when applicable) in compliance with contract specifications.
• Cubitainers should be cleaned out and fresh water provided as often as deemed necessary based on the
conditions. (time, temperature)
• Cubitainers are intended for use by multiple personnel to refill personal water containers. Therefore, one
should never drink directly from the cubitainer.

The current National Mobile Food Services contract (AG-024B-S-07-9001, Section J, pages 92 – 94) can also
be used as a reference (http://www.fs.fed.us/fire/contracting/food/food_contract.pdf ) as it applies to drinking
(potable) water to include the following:

• All equipment surfaces for potable water contact, including source fill point equipment, containers,
caps, tanks, hoses, valves, and fittings shall be inspected, washed, rinsed, sanitized, and replaced as
often as necessary to effect and maintain sanitation of surfaces.
• Disinfection needs to occur before being put in service, or when it has been unused and stored in a
sealed condition after a period of 4 weeks or more, or after any food product has been hauled.
• The host incident unit will designate the water source.
• Use only potable water from a permitted private of public drinking water supply. Filling must be
accomplished using acceptable source water under pressure. Drafting of surface water is not allowed
under any circumstances.

In Closing:

Cubitainers have been used on fires safely and successfully for decades and will continue to be used! This
coincides and supports the renewed emphasis being placed to reduce the volume of bottled water that is being
purchased and consumed on large fire incidents in the hope of moving towards the government’s “green” (EMS)
initiative.

For more information:

• Contact Bequi Livingston, Region 3 Fire Operations Health and Safety Specialist, 505-842-3412 or
blivingston@fs.fed.us

To Your Continued Health and Safety!