From: Alan Titchenal [titch@hawaii.edu] Sent: Friday, June 03, 2005 6:07 PM To: Dockets, FDA Cc: Joannie Dobbs Subject: Comment - Docket No. 2001N-0548 - opposition to changes Reference: Docket No. [2001N-0548] PROPOSED RULE CFR Citation: 21 CFR 101 Published: April 04, 2005 [FR Doc. 05-06475] Federal Register Vol. 70, No. 63 To whom this may concern: The following is submitted in response to the above Federal Register notice requesting interested parties to comment on FDA's proposal to amend its voluntary nutrition labeling regulations by updating the names and nutrition labeling values for the 20 most frequently consumed raw fruits, vegetables, and fish in the United States. As a nutritionist who has been teaching nutrition and using food composition data for over 20 years, I oppose the changes in nutrient amounts as they are presently proposed. I think that voluntary nutrition labeling regulations for the 20 most frequently consumed raw fruits, vegetables, and fish is an important consumer education tool, but most, if not all, of the proposed changes in nutrient amounts make little or no sense in the real world of daily food consumption by US citizens as explained below. Most of the changes are too small to matter since they fit within the natural variability found in whole foods. The amounts of nutrients in these natural foods can vary greatly due to differences in the varieties of a given item (ie. apple varieties), agricultural practices, seasonal differences, handling and storage of produce, etc. NLEA fruit and vegetable reference sizes should be updated first. Although I think that it is a good idea to revise nutrient values for all of these foods at one time, I don't think the changes in nutrient amounts should be made until the NLEA serving amounts are revised to reflect what is currently available in the U.S. market. The NLEA sizes for produce items do not reflect the sizes available in markets in Hawaii according to data we have collected. Since the produce we measured in our stores was obtained from mainland USA sources, it is likely similar to what is nationally available. Most of the items we measured were significantly larger than the NLEA reference amounts. For example, the NLEA apple is 154 g (edible portion) and the edible portion of a medium sized apple in our stores was almost 100 grams greater. Overall, I think that the NLEA produce reference amounts need review and revision before the nutrient values are changed. Also, USDA and FDA should emphasize that the sizes given for produce items are expressed for the edible portion. This is not always obvious. The 154 gram (5.5 oz) edible portion in the NLEA apple comes from an apple that weighs about 175 grams (6+ oz). Thank you for the opportunity to provide these comments in opposition to the proposed changes. Please feel free to contact me at titch@hawaii.edu or 808-956-7411 Respectfully, C. Alan Titchenal, PhD, CNS Human Nutrition, Food and Animal Sciences Department University of Hawaii at Manoa 1955 East West Road #216 Honolulu, HI 95822 The comments above are based on my experience and judgement and do not reflect any position or opinion of the University of Hawaii in general.