February 1, 2010
Ms. Patricia N. Daniels
Director, Supplemental Foods Program Division
Food and Nutrition Service
United States Department of Agriculture
3101 Park Center Drive, Room 528
Alexandria, Virginia 22302
Re: Comments on Special Supplemental Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages: Interim Rule
Dear Ms. Daniels:
On behalf of the National Potato Council (NPC), I/we are writing to contest the Supplemental Nutrition Program for Women, Infants and Children (WIC) interim ruling which currently excludes white potatoes from the list of allowable vegetables. The National Potato Council is the trade association that represents the producers of Irish potatoes in all the major growing regions in the United States. The council was created in 1947 by potato growers to provide information to policy makers on issues that impact the use and availability of potatoes to domestic and international consumers of U.S. potatoes. It is our contention that the exclusion of white potatoes was not based on sound nutrition science and is certainly not in the best interest of WIC participants. As the information in this document will demonstrate, there is absolutely no nutritional reason for excluding white potatoes and, in fact, their exclusion is in direct contradiction with the nutritional guidance documented in the 2005 Dietary Guidelines for Americans jointly prepared by the U.S. Department of Health & Human Services (HHS) and the U.S. Department of Agriculture (USDA) and MyPyramid prepared by USDA. Moreover, there are a number of important reasons that potatoes should be included in the WIC food list such as:
1. Potatoes contain key nutrients currently consumed in inadequate amounts by Americans (e.g., potassium, fiber, and vitamin C).
2. Potatoes are more nutrient dense than the other vegetables frequently consumed by WIC participants.
3. Potatoes are more nutrient dense than the other starchy vegetables remaining on the WIC list of “allowable” vegetables.
4. Potatoes are economical and their inclusion would maximize WIC program dollars.
5. Potatoes are recognized, prepared and well-liked by virtually every socioeconomic, cultural and ethnic group.
Potatoes Contain Key Nutrients “Of Concern”
As indicated in the interim final ruling of the Special Supplemental Nutrition Program for Women, Infants and Children, a primary reason for the revision of WIC food packages was to make them more consistent with the new Institute of Medicine’s (IOM) recommended dietary intakes for individuals. Of particular concern were the recent increases in the recommended dietary allowances (RDAs) for vitamin C and potassium. Specifically:
· In 2001 the IOM increased the RDA for vitamin C from 60 mg to 90 mg for men and to 75 mg for women (1). Meeting this revised guideline will likely prove difficult for most Americans, particularly women and children. Indeed, USDA data comparing vitamin C intake to the old RDA, shows that nearly 40% of (37.5%) Americans are not reaching this goal (2), which means even more are missing the mark since the RDA for Vitamin C was raised. A medium potato (5.3 oz) eaten with the skin provides 45% of the DV for vitamin C, the same amount as a serving of spinach but more Vitamin C than one medium carrot, (10% DV), tomato (40% DV) or sweet potato (30% DV).
· In 2004 the RDA for potassium was increased from 3500 mg to 4700 mg (3). Research indicates that most American adult women are getting little more than half the recommended amount of potassium (4). A medium white potato provides 620 mg of potassium, which ranks it highest in potassium content among the 20 most frequently consumed raw vegetables and the 20 most frequently consumed raw fruits (5).
The 2005 Dietary Guidelines for Americans identified several “nutrients of concern”; that is nutrients most likely to be consumed by both adults and children in amounts low enough to be of concern (6). These nutrients included among others vitamin C and potassium. Thus, from a nutrient content perspective it makes little sense to exclude potatoes from the WIC package. In fact, few other fruits or vegetables contain the levels of vitamin C and potassium that potatoes do.
Potatoes Are More Nutritionally Dense Than Other Vegetables Consumed By WIC Participants
It is our understanding that a primary rationale for excluding white potatoes from the WIC food packages was the concern that consumers already consume significant amounts of potatoes and, thus, by excluding potatoes it might encourage the consumption of a wider variety of vegetables. This faulty logic not only goes against the basic tenants of behavioral psychology but is not supported by scientific research. In fact, a study published in the Journal of the American Dietetic Association challenges this faulty notion and provides support for the importance of including potatoes in the WIC food vouchers (7). In this study, Dr Dena Herman and her colleague Gail Harrison from UCLA’s Department of Community and Health Sciences sought to evaluate the extent to which potential WIC participants who were given access to a fruit and vegetable subsidy (such as that proposed in the final interim rule of the revised WIC food package) would actually use it and to determine which of the fruits and or vegetables should be restricted or left to the individual participant’s choice (based on contribution to nutrient intakes). The specific nutrients of concern were vitamins A and C, potassium and fiber. It should be noted that in this study potatoes were not excluded from the list of allowable vegetables. A total of 452 women enrolling for postpartum services at three selected WIC program sites in Los Angeles, CA participated in the study. Subjects were of mixed ethnicities with the largest percentage being Hispanic (~80%). Sites were assigned to the intervention with vouchers redeemable at a local supermarket and a nearby, year-round farmers market. Vouchers were issued bimonthly at the level of $10/wk.
The results indicated that the vouchers were almost fully used by the participants and that a wide variety of fresh fruits and vegetables were purchased. Redemption rates for the vouchers were 91% for the farmers market and 86% for the supermarket. Tomatoes, carrots, iceberg lettuce, and broccoli were the top four most frequently consumed vegetables, potatoes ranked 5th. Of these, only broccoli and tomatoes contain more vitamin C than potatoes and none contain more potassium. Indeed, while carrots provide significant amounts of beta carotene, iceberg lettuce, which was the second most frequently consumed vegetable (consumed twice as often as potatoes) is virtually devoid of nutrients (Table 1). The authors concluded, that “with the exception of lettuce, the most frequently consumed vegetables- including potatoes- were significant sources of potassium, vitamin C, vitamin A, and/or dietary fiber—food components determined to be of high priority in revising the WIC food package as indicated by the IOM report (WIC Food Packages: Time for a Change) (7, 8) Such studies demonstrate that there is no rational basis for treating potatoes differently from the other nutrient-rich vegetables that are included in the WIC food packages.
Table 1
Vegetable Comparison of Select Nutrients (per serving)*
| Potato (1 small) | Broccoli (1 cup) | Carrot (2 medium) | Tomato (1 large) | Iceberg (2 cups) |
Protein (g) | 3.43 | 2.57 | 1.13 | 1.6 | 1.3 |
Fiber (g) | 4.1 | 2.4 | 3.4 | 2.2 | 1.7 |
Vitamin C (mg) | 33.5 | 81.2 | 7.2 | 23.1 | 4.0 |
Vitamin B6 (mg) | 0.35 | 0.16 | 0.17 | 0.15 | 0.06 |
Folate (mg) | 31 | 57 | 23 | 27 | 42 |
Calcium (mg) | 15 | 43 | 40 | 18 | 26 |
Magnesium (mg) | 36 | 19 | 15 | 20 | 10 |
Iron (mg) | .88 | 0.66 | 0.37 | 0.59 | 0.59 |
Potassium (mg) | 692 | 288 | 390 | 431 | 203 |
Sodium (mg) | 10 | 30 | 84 | 9 | 14 |
*USDA National Nutrient Database for Standard Reference- Release 21
Potatoes Are More Nutrient Dense Than Other Starchy Vegetables That Remain “Allowable” Items In The WIC Food List
According to the 2005 IOM report (WIC Food Packages: A Time for Change), the guiding document for the development of the WIC interim ruling and new WIC food packages, evidence suggests that the average American diet is lacking in whole grains, vegetable subgroups (excluding white potatoes), fruits, milk and milk products and meat (8). This data led to the IOM report recommendation that the interim ruling focus on “increasing intakes of non-starchy vegetables”. How this recommendation was translated into the singular exclusion of white potatoes from the WIC food package is without scientific validity (nor support from the guiding IOM committee and their recommendations). Perhaps those responsible for translating the IOM report recommendations believed that restricting access to starchy vegetables would increase the intakes of non-starchy vegetables? Yet, if this were the case then all starchy vegetables should have been excluded, from the WIC food lists not just potatoes. Neither the IOM report nor nutrition science in general justifies the agency’s decision to treat potatoes differently from other starchy vegetables.
So why were potatoes singularly excluded? The committee would be hard pressed to justify this action with the claim that the other starchy vegetables are more nutritious than potatoes. In fact, of the starchy vegetables, potatoes are the most nutrient dense and provide significantly more of the “nutrients of concern” identified by the 2005 Dietary Guidelines Advisory Committee (and confirmed recently by the 2010 Dietary Guidelines Advisory Committee) (Table 2). Perhaps the argument was that potatoes are not consumed in “healthful ways.” Yet, data indicates that very few fresh potatoes purchased by WIC participants (or consumers in general) are ever consumed as “French fries”. Instead of French fries, we know through the NPD Group’s National Eating Trends®, 2008, (9) that the most popular ways to consume fresh potatoes at home is mashed followed by baked. The NPD Group data indicates that annual in-home potato eatings per capita for mashed is 18 and for baked is 12.
Table 2
Starchy Vegetable Comparison of Select Nutrients (per serving)*
| Potato (1 small) | Carrots (2 medium) | Corn (1 large ear) | Peas (1/2 cup) | Green beans (1/2 cup) |
Calories (kcal) | 131 | 50 | 123 | 35 | 22 |
Protein (g) | 3.43 | 1.13 | 4.6 | 2.6 | 1.2 |
Fiber (g) | 3.7 | 3.4 | 3.9 | 2.2 | 2.0 |
Vit C (mg) | 33.5 | 7.2 | 9.7 | 38 | 6 |
Vit B6 (mg) | .50 | .168 | 0.08 | .2 | .04 |
Ca (mg) | 20 | 40 | 3.0 | 34 | 28 |
Fe (mg) | 1.33 | .37 | 0.74 | 1.6 | .41 |
K+ (mg) | 716 | 390 | 386 | 192 | 91 |
Na (mg) | 10 | 84 | 21 | 3 | 1 |
*USDA National Nutrient Database for Standard Reference- Release 21
Potatoes Are Economical and Maximize WIC Food Dollars
The provision of a weekly voucher (dollar amount) to purchase fresh fruits and vegetables was perhaps the single most significant revision to the WIC food package in terms of encouraging increased consumption of fruits and vegetables (the exclusion of potatoes not withstanding). Nonetheless, it is important to emphasize that the voucher dollars are fixed and limited; thus, it is important to choose fruits and vegetables that provide the greatest “nutritional value” (i.e., nutrients per dollar). Dr. Adam Drewnowski, Director of the Center for Public Health Nutrition at the University of Washington, has developed a data analysis tool to measure exactly that. The Affordable Nutrition Index (ANI) is a measure of nutrients per serving divided by the price per serving - or in effect a measure of nutrients per dollar. The ANI is derived from the USDA nutrient composition database Food and Nutrition Database for Dietary Studies (FNDDS 1.) and mean national food prices for 2001 released in may 2008 by the USDA Center for Nutrition Policy and Promotion (note: a higher score is indicative of greater nutrients per dollar). Table 3 highlights the ANI for potatoes prepared in a variety of ways compared to other commonly consumed vegetables. As you can see, potatoes score very high, in most cases higher than other commonly consumed vegetables (5). Most notably, in most cases potatoes score significantly higher than the other four most frequently consumed vegetables by WIC participants identified in the Herman and Harrison study previously described (7) (i.e., tomatoes, carrots, broccoli and lettuce).
Dr. Drewnowski is also the creator of the Nutrient Rich Food (NRF) index, a formal system to rate individual foods by their nutrient composition (10, 11). The NRF index is based on 9 nutrients to encourage (protein, fiber, vitamins A, C, and E, calcium, iron, potassium and magnesium) and 3 nutrients to limit: saturated fat, added sugar and sodium. As Table 3 indicates, fresh white potatoes, prepared in different ways, have NRF scores that are similar to or exceed that of many other allowed vegetables. The NRF score for roasted white potato is not substantially different from cooked spinach and is much higher than tomatoes, mushroom, beans or corn. Thus, from both a nutrient density standpoint (i.e., NRF score) and, most importantly, an affordability standpoint (ANI score), potatoes excel.
Table 3
Affordable Nutrition Index Scores for Potatoes Compared to Other Vegetables
Food descriptor from FNDDS1.0 | FDA serving size RACC | Cost in dollars/1000 kcal | Cost in dollars per serving | Nutrient Rich Foods NRF index score | Affordable Nutrition Index (ANI) |
WHITE POT,BAKED,PEEL EATEN,FAT NOT ADDED IN COOKING | 110.00 | 1.0919 | .1105 | 52.57 | 475.72 |
WHITE POTATO, BOILED, W/O PEEL, FAT NOT ADDED | 110.00 | 1.3071 | .1222 | 32.55 | 266.30 |
WHITE POTATO, ROASTED, FAT NOT ADDED | 110.00 | 1.1889 | .1792 | 101.46 | 566.28 |
WHITE POTATO, SCALLOPED (INCLUDE CREAMED) | 140.00 | .9886 | .1329 | 58.51 | 440.34 |
WHITE POTATO, FRENCH FRIES, FROM FRESH, DEEP-FRIED | 70.00 | .6549 | .1224 | 74.35 | 607.39 |
WHITE POTATO, FROM FRESH, MASHED,MADE W/ MILK | 140.00 | 1.3105 | .1486 | 38.92 | 261.91 |
COLLARDS,COOKED,FROM FRESH,FAT NOT ADDED | 85.00 | 24.3566 | .5383 | 79.09 | 146.94 |
SPINACH, RAW | 85.00 | 22.7146 | .4441 | 135.59 | 305.33 |
SPINACH,COOKED,FROM FRESH,FAT NOT ADDED | 85.00 | 23.1127 | .4519 | 113.03 | 250.15 |
BROCCOLI, RAW | 85.00 | 12.3547 | .3571 | 137.04 | 383.81 |
CARROTS, RAW | 85.00 | 5.5564 | .1936 | 68.69 | 354.74 |
SWEETPOTATO, BAKED, PEEL EATEN, NO FAT ADDED | 110.00 | 3.6505 | .4538 | 142.07 | 313.10 |
SWEETPOTATO, BAKED, PEEL NOT EATEN, FAT NOT ADDED | 110.00 | 2.3678 | .2318 | 141.51 | 610.48 |
SWEETPOTATO, BAKED, PEEL NOT EATEN, FAT ADDED | 110.00 | 1.8498 | .2299 | 135.23 | 588.13 |
SWEETPOTATO, BOILED, W/O PEEL, FAT NOT ADDED | 110.00 | 2.2656 | .1894 | 106.13 | 560.33 |
SWEETPOTATO, CANDIED | 140.00 | 1.1038 | .2303 | 42.30 | 183.69 |
TOMATOES, RAW | 85.00 | 19.6846 | .3012 | 38.09 | 126.47 |
TOMATOES, FROM CANNED, STEWED | 130.00 | 5.1487 | .1740 | 40.68 | 233.74 |
BEANS, STRING, GREEN, RAW | 85.00 | 9.1273 | .2405 | 59.56 | 247.63 |
CAULIFLOWER, RAW | 85.00 | 27.3188 | .5805 | 91.30 | 157.27 |
CUCUMBER, RAW (INCLUDE CUCUMBER, NFS) | 85.00 | 19.8301 | .2023 | 16.24 | 80.27 |
LETTUCE, BOSTON, RAW | 85.00 | 30.3209 | .3350 | 38.42 | 114.68 |
LETTUCE, ARUGULA, RAW | 85.00 | 19.2807 | .4097 | 77.68 | 189.61 |
MUSHROOMS, RAW | 85.00 | 30.2998 | .5666 | 24.70 | 43.60 |
ASPARAGUS, COOKED, FROM FRESH, FAT NOT ADDED | 85.00 | 38.1320 | .7131 | 32.75 | 45.92 |
BEETS, COOKED, FROM FRESH, FAT NOT ADDED | 85.00 | 17.8539 | .6677 | 21.82 | 32.67 |
CORN, YELLOW, COOKED, FROM FRESH, NS FAT ADDED | 85.00 | 5.6867 | .5994 | 30.09 | 50.20 |
PEAS & CORN, COOKED, NO FAT ADDED | 85.00 | 10.1640 | .8294 | 48.99 | 59.06 |
Potatoes Are Recognized, Prepared and Well-liked By Virtually Every Socioeconomic, Cultural and Ethnic Group
Potatoes are widely accepted across cultures and among ethnicities and are particularly important to those served by WIC. In fact, The IOM committee report from which the interim WIC ruling was derived (8) acknowledges that potatoes are a “core food” for many WIC-eligible participants. The report further acknowledges that the intent was to design a WIC food package that would serve as an incentive for participation in the WIC program. By excluding potatoes from the package, the government is blatantly ignoring the food preferences of the majority of participants of whom WIC is designed to serve and dictating which vegetables participants can and cannot have, neither of which provide much of an incentive for participation in the program.
Based on the magnitude of the scientific data presented in this comment letter (and the dearth of plausible rationale for the exclusion of potatoes), it would be highly advisable for the USDA to re-evaluate the singular exclusion of potatoes from the WIC food list of “allowable vegetables”. Potatoes are a highly nutritious, economical and well-liked vegetable. Their consumption should be encouraged and they should be included on the WIC food list.
Thank you for your time and consideration.
Sincerely,
John Keeling
Executive Vice President and CEO
National Potato Council
References
1. National Academy of Sciences. Dietary Reference Intakes for vitamin C, vitamin E, Selenium, and Carotinoids. 2000. http://www.nap.edu
2. USDA’s 1994-1996 Continuing Survey of Food Intakes by Individuals. U.S. Department of Agriculture. 1999. www.barc.usda.gov/bhnrc/foodsurvey/home.htm
3. National Academy of Sciences. Dietary Reference Intakes for Fluid and Electrolytes. 2004. http://www.nap.edu
4. Adams PF, Hendershot GE. Current Estimates from the National Health Interview Survey 1996. National Center for Health Statistics. Vital and Health Statistics Series 10, no. 200 (Hyattsville, MD: 1999).
5. Pennington JAT. Documentation for the 1995 Nutrition Labeling Values for the 20 Most Frequently Consumed Raw Fruits, Vegetables, and Fish. Washington, D.C.: Food and Drug Administration; October 1995, revised June 1996.
6. 2005 Dietary Guidelines for Americans. U.S. Department of Health and Human Services, U.S. Department of Agriculture. www.healthierus.gov/dietaryguidelines
7. Herman DR, Harrison GG. Choices made by low-income women provided with an economic supplement for fresh fruit and vegetable purchase. J Am Diet Assoc. 2006; 106:740-744.
8. Food and Nutrition Board. Institute of Medicine. WIC Food Packages: Time for a Change. Washington DC, The National Academies Press. 2005 www.nap.edu
9. NPD Group, National Eating Trends Report, 2008, NET data is collected from a balanced panel of 2000 households, who report all foods and beverages consumed by all individuals during an average two-week period via a paper diary. In-Home includes all foods and beverages prepared and/or consumed in the home. Includes carried meals, i.e. ‘brown bag lunches’.
10. Drenowski A, Fulgoni V 3rd. Nutrient profiling of foods: creating a nutrient-rich food index. Nut Rev. 2008;66:23-39
- Fulgoni VL 3rd, et al. Development and validation of the nutrient-rich foods index: A tool to measure the nutritional quality of foods. J Nutr. 2009; 139:1549-1554.
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