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Watermelons are not melons.

That is the message that the watermelon industry is trying to convey to the U.S. Food & Drug Administration, and it is utilizing the comment period on the FDA's proposed rule for Preventive Controls for Fresh Produce, Docket ID FDA-2010-N-0085, to do so.

A large graphic on the National Watermelon Association web site's home page emphasizes this undertaking, and also provides links to submit comments via a form letter to the FDA as well as to members of Congress.

Bob Morrissey, executive director of the association, told The Produce News April 5 that he "had worked with the FDA for the previous 18 to 20 months in an attempt to convince them that watermelon doesn't belong in the melon category for a number of basic reasons," but was unsuccessful in getting the agency to change its stance.

"Our industry is just like most other members of the industry, and we're going out and spending all kinds of money on basic food-safety and traceability programs because we know by the end of next year, it is going to become mandatory by law," he said. "We absolutely don't have a problem with that, and in many cases, we are leading the produce industry because many of our large handlers are actually reducing traceability down to the item level, which most produce items cannot do."

Mr. Morrissey said that the industry is doing this now "because they expect these [programs] to become mandatory in the future, especially since watermelon is included by the FDA in the high-risk melon category, and because they're being told by their customers -- both foodservice operators or retailers -- 'you will do this.'"

The high-risk designation puts growers and handlers "in a very precarious and negative financial position," he said. "There are some customers out there that require them to do additional audits, use certain chemicals or certain wash-and-brush systems or traceability systems. The expectations are all different, and the requirements are all different. What that adds up to is hundreds of thousands of dollars that are being spent on food safety and traceability in addition to the basics that [growers and handlers] are doing anyway, and [the money is] all being spent unnecessarily because [watermelon has] already been proven to be one of the safest fruits and vegetables available to consumers worldwide," he said.

"The biggest problem with this high-risk inclusion is the fact that we have it verified by the FDA, in writing, that watermelon has no [food-safety related] outbreaks since" FDA has been keeping records beginning in 1995, he said about a letter that the organization received Jan. 22. But he said that the FDA is not in any position to redefine the category, because it considers watermelon to be a melon.

The letter stated that "melons have been linked to 13 of the 82 foodborne illness outbreaks associated with the consumption of fresh produce between 1996 and 2008 in which FDA was involved (i.e., outbreaks not associated with contamination at point of service). Cantaloupe was involved in 10 of the 13 outbreaks associated with melon consumption. Of the remaining three outbreaks, two were linked to honeydew melons and a third to pre-cut melon, type not specified. FDA's outbreak data for fresh produce during this time period does not reflect any illness outbreaks linked to pathogen contamination of watermelon during production, harvest or packinghouse handling."

"I'd love to see our industry get involved and participate during this FDA comment period," Brent Harrison, president of the association and president of Al Harrison Co. Inc., told The Produce News April 4. "To me, voice in numbers will have a big effect in our goals in getting watermelons removed from the high-risk category. I'd like to see international participation, especially Mexico, because a big chunk of the watermelons consumed in the U.S. comes from Mexico, and they are affected in the same manner from this classification. I'd also like to see support from other organizations and associations in our industry, as a lot of their members are watermelon growers."

Said Mr. Morrissey, "The FDA is looking at this from a category-specific approach rather than a commodity-specific approach, like the food-safety working group and the White House said that [they] will do. If they are going to follow a true commodity-specific approach, then [FDA needs] to follow the model that the U.S. Department of Agriculture has."

Mr. Morrissey noted that the USDA has grades and standards for watermelons, cantaloupes and honeydews. "The USDA looks at [melons] commodity by commodity, where the FDA is looking at it as an overall category, and we feel like we are wrongly included," he said. "Just because 'melon' is in our name doesn't mean that this is right."

Said Mr. Harrison, "Our industry has done research on rind pathogens, and we have come to the conclusion that watermelon is a safe product when compared to other melons currently in the same category. We're all about food safety. The NWA has created commodity-specific GAP guidelines, and we're one of the few that have this. I think we're ahead of the curve and are being proactive. Every year we continue on our research efforts, in conjunction with our sister organization, the National Watermelon Promotion Board, to make our product safe."

Mr. Morrissey said that the designation is putting the industry in a position where the industry is "guilty by association, and regardless if we can prove that we have had no incidents, because the FDA includes us in that category, we are treated like any high-risk category out there," and this is happening even though watermelon "is not a true melon like the rest of them are considered to be."

The organization's letter to the FDA pointed out that the agency separates green onions from regular onions, and Mr. Morrissey wondered out loud that "if it has already been done for [onions], why can't watermelons be separated from the melon category, or why can't cantaloupes, which have 10 of the 13 outbreaks, be separated? Green onions are high risk, and rightly so, and regular onions are not, and we want to be treated the same way."

Mr. Morrissey said that the NWA is also seeing "kind of an alarming trend" starting to evolve, though on a small scale, of "some farmers leaving watermelons and putting in other crops because they are not getting the returns they need to stay in business. We've lost a few farmers just in the past year and possibly a few more this year. We're a small industry as it is, and though the commodity continues to grow in sales and consumption year after year, largely thanks to the [NWPB's] efforts, we need farmers to be planting watermelons in the U.S. If [growers] continue to move away from planting watermelons to go to something else because of this incorrect high- risk inclusion, it will impact supply, and that is not good for anybody."