The Environmental Working Group (EWG) is an independent organization that speaks out on issues of public health and safety. They publish a list of fruit and vegetables they consider unhealthy referred to as "The Dirty Dozen." They also publish a list they consider healthy and refer to as the "Clean Fifteen" -- this list includes watermelon. While the list is specifically related to the presence of pesticides, watermelon?s smooth and thick rind is an environment that is not conducive to the retention of pesticides or pathogens. The Commodity-specific Approach: The Food Safety Working Group (FSWG), created by President Obama in 2009, announced that FDA would issue "commodity-specific draft guidance on preventive controls that industry can implement to reduce the risk of microbial contamination in the production and distribution of tomatoes, melons, and leafy greens".
The Melon guidance is not, in our opinion, commodity-specific. The guidance has an emphasis on a category of crops, not a commodity, which hampers our crop/commodity unfairly. In the FDA letter dated January 22, 2010, FDA stated,"We agree that some of these designations cover a range of commodities (e.g., melons and leafy greens) and others are narrower (e.g., green onions). We also agree that produce varieties (and practices) within a category may have significantly different risk profiles.
The following submitted comments by the produce industry?s largest organizations help to validate the differences: The industry recognizes that netted skin melons, like cantaloupe, have a different contamination risk profile from waxy skin melons, like watermelon, and this is reflected in the relative frequency that each has been associated with illness outbreaks. (United Fresh comments, October 2009).
Western Growers remain unconvinced that these products present the same risk profile and question the need to include them all in this Guidance. While production practices are generally similar, the outbreak history discussed in the background section of this document clearly indicates that netted skin melons, like cantaloupe, have a different contamination risk profile from waxy skin melons, like watermelon.
It is Western Growers recommendation that FDA reduce the scope of the Guidance to netted melons consistent with the "risk based" approach to food safety guidance and regulation promoted by FDA. (Western Growers comments, January 2010)