From: Steven R Fore [sfore@watermelon.org] Sent: Thursday, June 02, 2005 2:11 PM To: Dockets, FDA Cc: 'Mark Arney'; Gordon Hunt; lcoleman@watermelon.org; Bill Winsemann Subject: Docket No. 2001N-0548 fruit and vegetable labeling Dear FDA, The National Watermelon Promotion Board would like to note that we support the 2005 Reopening Comment Period Proposed Values for watermelon (80 calories, 0 mg sodium, 270 mg potassium, 21 g carbohydrates, 1 g fiber, 20 g sugar, and 30% daily value of vitamin A). We asked our nutritional advisor Penny Perkins-Veazie USDA ARS in Lane Oklahoma to review the proposed values, and she assured us that the proposed values fall within the averages for watermelon. Following you will find her letter. Thank you. Sincerely, Steven Steven R Fore Director of Research National Watermelon Promotion Board sfore@watermelon.org www.watermelon.org 407-657-0261, phone 407-657-2213, fax It is wrong always, everywhere and for everyone to believe anything upon insufficient evidence. W. K. Clifford (circa 1876) E-mail: pperkins-usda@lane-ag.org Phone: (580) 889-7395 Fax: (580) 889-5783 May 23, 2005 National Watermelon Promotion Board 3660 Maguire Blvd. Ste. 212 Orlando, FL 32803 RE: Proposed FDA Food Labeling Guidelines, Federal Register April 4, 2005 (V.70, No. 63) To Whom It May Concern: I have looked through the documentation provided by the website and that sent to me from the NWPB (through Mary Brandt). I cannot find data that justifies the 2002 proposed FDA labeling for sodium, potassium, sugars, or total carbohydrates for the NLEA serving size of 280 g. Documentation from Sue Gebhardt (in the blue rectangle for watermelon) indicates that total sugars should be 20 g, not 25 g per NLEA serving. This value (20 g) is also proposed in the documentation guide of Legault and Brandt, (2004). Total sugars are used to calculate total carbohydrates, so a downward adjustment to 21 or 22 g total carbohydrates (depending on whether 1 or 2 g dietary fiber is added to the sugars) is also needed. No information on sodium or potassium is provided in the blue rectangle, but this nutrient data was sent in 2003, and can be found under the reference of Brandt, 2005 (memo to the file). In this reference, potassium data values for watermelon range from 83.7 to 112 mg/100g. If an average of these values is used to calculate the potassium per NLEA serving size of watermelon, it would be 279.2 mg/280 g; an average without high and low values yields 281.8 mg/280 g. For sodium, only 2 values are provided, which are not closely matched (2.5017 and 0.694 mg/100g). An average of these two yields 4.5 mg/NLEA serving, which, under the rounding rules of LeGault and Brandt (p. 3) would be expressed as 0 mg. However, if only the high value of 2.5017 is used to calculate sodium in an NLEA serving of watermelon, then 7 mg results, which would be rounded up to 10 mg. Since only two sodium values are given for documentation, and these vary widely, I think an average sodium value of 1.6 mg, corresponding to 4.5 mg sodium/280 g, should be used for watermelon. In summary, therefore, I find the nutrient values for watermelon listed under the reopening comments period (0 mg sodium, 270 mg potassium, 21 g total carbohydrate, and 20 g sugar) to most accurately reflect the documentation provided by FDA and USDA. References: 1. Brandt, M.M., memo to the file: Nutrient data from U.S. Department of Agriculture received after close of comment period, Center for Food Safety and Applied Nutrition, FDA, February, 2005. pdf 2. LeGault, L.A. and M.M. Brandt, "Documentation for the Nutrition Labeling Values for the 20 Most Frequently Consumer Raw Fruits, Vegetables, and Fish," Center for Food Safety and Applied Nutrition, FDA, November, 2004. pdf 3. Gebhardt, Susan http://www.fda.gov/ohrms/dockets/dailys/02/Aug02/080602/01n-0548-c000006-vol 1.pdf (click on the blue rectangle for watermelon) Sincerely, PENELOPE PERKINS-VEAZIE Plant Physiologist