Florida Citrus Processors Association 1611 Harden Blvd../Lakeland, FL 33803 Tel.(863)293-4171/ Fax. (863) 683-2849

April 27, 2011

Mr. Terry Bane, Branch Chief
USDA, AMS,FV,PPB

STOP 0247 1400 Independence Ave SW Washington, DC 20250-0247

Subject: United States Standards for Grades of Grapefruit Juice

Dear Mr. Bane:

The Florida Citrus Processors Associa tion (“FCPA”), a leading representative of United States processors of grapefruit juic e, hereby requests a revision to the United States Standards for Grades of Grapefru it Juice (48 FR 40875) and asks that the maximum “free and suspended pulp” (referred to in the industry as “sinking pulp”) grade parameters be eliminated from the USDA grade standards for a ll forms of grapefruit juice. Currently, the standards provide that Grapef ruit Juice from Concentrate, Grapefruit Juice and Frozen Concentrated Grapefruit Juice have maximum free and suspended pulp as follows: Grade A- 10% by volume; Grade B 15% by volume. Concentrated Grapefruit Juice for manufacturing requirements are Gr ade A- 10% by volume and Grade B-12% by

volume.

I. The Reason for the Proposed Revision. The existing United States Standards for Grad es of Grapefruit Juice, that relate to maximum values for free and suspended pulp, do not take into account modern extraction and finishing technologies, no r are they supported by evid ence of correlation between these criteria and acceptable flavor.

II. Technical Information Supports the Revision.

The free and suspended pulp parameters have b een a part of the USDA Grade Standards for Grapefruit Juice since the standards were first issued in 1941. In the evolution of the citrus industry, excessive sinking pulp was, ear ly on, perceived as an indication of high pressures used in extraction and finishing of citrus juice and bitterness in juice where these high extraction pressures were applied. The current standards ha ve been in effect since 1983. In the promulgation of the 1983 US DA Grade Standards, it was noted that sinking pulp levels could be correlated to bitte r flavor (the bitter flavors in grapefruitjuice are due to the naturally occurring fl avanone glycoside, naringin and the liminoid, limonin). Although bitterness is an inherent co ntributor to what we know as “grapefruit flavor,” an excessive amount of bitterness can be objectionable to some consumers.

Processing technologies used in the early 1940’ s, while such technologies were in their infancy, were considerably different than the technologies in place today.

We have learned that sinking pulp levels can be greatly in fluenced by modern processing techniques, which techniques eliminate the corr elation between sinki ng pulps, and “hard” extraction and finishing result s in excessive bitterness.

Brown International Corporation and John Bean Technology Corp. (formerly FMC) are the two predominant suppliers of commercial citrus juice extraction and processing equipment in the United States. Equipment changes by these suppliers since the standard was first published supply some basis for the requested revision.

Early FMC juice extractors used press type applications and did not use a pre-finishing strainer concept inside the extr actor as is the case today. Th is change to FMC equipment, has since 1947, proved to be a significant advancement for citrus juice quality. Other quality improvements were also realized by incorporating new finishing technology which separates juice and juice solids.

Brown brand juice extractors are designed to ex tract juice, cell sacs, seeds, and some of the membranes from the peel by a combined pressing and wiping action. This gentle method leaves a sound extracted peel half, which is not crushed or mangled. Reamed juice from a Brown extractor has greater whol e cell sac retention and very little bitter tasting oils and peel extracts. Reamed jui ce is free of all albedo (where the largest concentrations of naringin re side in the fruit) and flave do. A significant advantage of the reaming method is that numerous undesirable components inherent in the peel are not liberated into the juice. Brown equipment curre ntly also uses other finishing technology that was not available when the standards were originally adopted.

There are several more recent processing tech nologies that have been introduced that probably have even more influence in making maximum levels for sinking pulp questionable as a factor in determin ing grapefruit juice quality. The post extractor/finisher technologies of centrif ugation and homogenization can reduce sinking pulp levels dramatically. These technologies can be used for pulp removal (primarily to reduce viscosity) to prevent gela tion of grapefruit juice concen trate in storage, to allow evaporators to produce more highly concentr ated juice, to impr ove flow rates when pumping concentrates, and to improve product flow in juice dispensers in convenience
stores, restaurants, etc. Ce ntrifuges are also used for removing defects in juice.

Centrifuge efficiency in citrus plants is simply calculation of the difference in percent pulp between the feed and product streams divide d by the percent pulp in the feed stream. At normal feed rates, the process tries to achieve 20-50% pulp re duction. If the process requires greater than 50% reduction, slower feed rates and loss of capacity will result. It

2should be noted that since centr ifuge applications re sult in juice yield lo ss, careful control and optimization is important.

In other words, juice that leaves the finish er at 16% sinking pulp could be easily reduced via centrifugation to achieve 8% sinking pulp in the final pulp tes ting during grading. The 16% sinking pulp juice, in this instance, could be high in naringin content, but not necessarily so, depending on fruit maturit y. Centrifugation can thus render any

correlation between harsh extraction and sinking pulp levels invalid.

When centrifugation is used, pulp levels can be reduced leaving the naringin/ limonin levels unchanged in the juice.

Another way to reduce viscosity is to hom ogenize or break up particulate matter in the juice. This process results in “finer” par ticles of pulp, which when “spun down” in the laboratory centrifuge during the pulp test, will result in more compaction of the pulp and yield a lower percent by volume of sinking pulp as a result and without affecting naringin/limonin content.

Also, some processors now use debittering technology to reduce naringin/limonin levels for consumer acceptance. This technology l eaves pulp levels unchanged while decreasing bitterness. This technology u tilizes absorption resins to selectively remove limonin and naringin.

Limonin levels as high as 40 ppm can be debi ttered to as low as the generally accepted taste threshold of 7 ppm, depending pr imarily on the amount of resin used.

In addition to processing enhancements, methods of storage of grapefruit solids have also changed through the years pr oviding opportunities to produ ce products with more consistent quality.

Data collected by John Bean Technologies Co rp. of Lakeland, FL (“JBT”) demonstrates

over several seasons that there is no statistic al correlation between the grapefruit flavor components associated with bitter and off flav or i.e. naringin and limonin-- and free and suspended pulp levels. See charts in Exhibit 1.

III. The public benefits to be gained by the proposed revision. Recent Consumer panel tests run by the Univ ersity of Florida show no significant difference in consumer preference or acceptabi lity between lower sinking pulp values and values that exceed grade parameters. See Exhibit 2. Deleting the maximum sinking pulp values from the grade standard s will allow processors to proc ess the entire grapefruit crop (more mature grapefruit tend to be sweeter bu t when juiced, they can also cause product to exceed the maximum free and suspended pulp values) without resorting to expensive technologies that drive up the cost of juice for consumers with no concomitant benefit. If the parameter is removed from the standard, other grade requirements will remain in place that assure quality color, flavor and de fects with related co nsumer preferences.

3Members of the trade that value sinking pu lp parameters will be free to continue specifying sinking pulp parameters in juice purchase contracts.

The only other quality consideration worth noting may be the change in “mouth feel” (viscosity) due to the potentia l of higher pulp levels if th e parameter is removed. Mouth feel is consumer preference influenced. Some consumers could even consider a “lower” sinking pulp juice to be “thi n” or “watery. Although grapefru it isn’t known for being a “thick” product, there are many loyal consumer s of fruit juice nectars, which typically have much higher viscosity than grapefruit juice.

Another strong indication that increased sinking pulp volum e in grapefruit would be accepted by consumers is the fact that USDA eliminated sinking pulp as a grade parameter from orange juice standards without any apparent backlash from consumers.

IV. The revised standards would be practical and objectively enforceable. Deleting the sinking pulp requirement will not impact the ability of the USDA to grade product on the basis the rema ining grade criteria.

VI. There is broad industry support for the proposed revision. FCPA contacted known processors of grapefruit juice in Nort h America. Virtually all of the major grapefruit juice processors in the United States (Florida, Arizona, Texas and California) support the proposed revision and no processor contacted indicated opposition to removal of the free and suspended pulp parame ter. The parameter at issue is not a part of the Codex Standard for fruit juices and nect ars (including grapefruit juice), thus repeal

would not contradict this international standard.

VII. Conclusion. For the reasons above, we request that th e existing 1983 United States Standards for Grapefruit Juice eliminate maximum va lues for free and suspended pulp.

FCPA looks forward to coope rating with the USDA and indus try going forward on this matter. If you have any questions, pleas e do not hesitate to contact us.

Sincerely,

Kristen C. Gunter Executive Director, FCPA

cc. Peter Hahn, President, FCPA

FCPA Board

4John Bean Technologies Corp. Data Over Six Seasons.

The following data represents six Florida Grapefruit juice seasons. JBT routinely collects fruit throughout each season to process on their pilot lab extraction and finishing equipment. Among the data coll ected, included are results fo r sinking pulp, naringin, and limonin. The graphs illustrate sinking pulp vs . naringin and sinking pulp vs. limonin for

each of the six seasons.

The testing protocol was as follows: The fr uit tested was obtained from a homogenous bin of fruit, all from the same grove lot a nd picked at the same time. The fruit was randomized at the JBT pilot plant, meaning each fruit was hand pl aced into each sample and the samples are prepared simultaneously. This eliminated any possible differences from fruit at the top or bottom of the bins et c. Each sample was identical in its sorting and selection process to the other. The finish er was set for a consta nt 160 quick fiber for

these tests and is monitored on each test. A correction was made if any slight difference in the finisher results was detected (in other words, finishing protoc ol is kept constant between all samples). The samples were pasteurized after finishing.

The four most common extractor setups are us ed on each sample (representing what JBT describes as “minimum”, “standard”, and “m aximum” setups relative to “hardness” of squeeze).

Data collected from all extractor setups are included on the following graphs since each processor could be using any or all of the se tups listed above at any given time during the

season.

Testing Methodologies: Free and suspended (sinking) pulp – per USDA Citrus Handbook 6.16.1 – 6.16.3 Naringin - Rouseff, R.L. 1988. Liquid chromatogra phic determination of naringin as a detector of grapefruit juice in orange juice J. Assoc. Off. Anal. Chem. 71:798

− 802.

Limonin - Shaw, P.E. and Wilson, C.W. 1984. A rapid method for determination of limonin in citrus juices by high performan ce liquid chromatography. J. Food Sci. 49:1216

− 1218.0 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 04 / 05

0 5 10 15 20 25 30

0 2 4 6 8 10 12 14Limonin(ppm)

% Sinking Pulp

Significance F"is NOT >0.05, thus there IS a statistically significant association between X and Y(95%)0 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 05/06

0 5 10 15 20 25 30

0 2 4 6 8 10 12 14Limonin(ppm)

% Sinking Pulp 

## 05/060 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 06/07

0 5 10 15 20 25 30

0 2 4 6 8 10 12 1Limonin(ppm)

% Sinking Pulp 4 

# 06/070 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 07/08

0 5 10 15 20 25 30

0 2 4 6 8 10 12 1Limonin(ppm)

% Sinking Pulp 4 

# 07/080 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 08/09

0 5 10 15 20 25 30

0 2 4 6 8 10 12 1Limonin(ppm)

% Sinking Pulp 4 

# 08/090 100 200 300 400 500 600 700

0 2 4 6 8 10 12 14Naringin(ppm)

% Sinking Pulp 

# 09/10

0 5 10 15 20 25 30

0 2 4 6 8 10 12 1Limonin(ppm)

% Sinking Pulp 4 

# 09/10The following two graphs contain data from the 09/10 season. The results come from a major Florida citrus processor. These sample s were taken as pasteurized single strength grapefruit juice and represent a myriad of different extractor and finisher setups.

0 100 200 300 400 500 600 700

0 5 10 15 20Naringin(ppm)

% Sinking Pulp 

# 09/10

4 5 6 7 8 9 10 11 12 13

0 5 10 15 20Limonin(ppm)

% Sinking Pulp 

# LIMONIN

09 / 10As you can see from the graphs above, from six years worth of data, there is no significant association (95%) between naringin vs. sinki ng pulp and limonin vs. sinking pulp except for the Limonin 04/05 graph. That relationship shows that as sinking pulps increased, limonin decreased.

The results from the JBT pilot lab come from juice that was extracted and finished only. If centrifuges, homogenizers, and debittering un its had been used, it would make a direct comparison of sinking pulp to naringin/limoni n levels in processed juice even more unpredictable.

This data appears to suppor t the premise that influences of the post 1941 processing technologies make sinking pulp quantity an unreliable indicator of juice quality.The Foundation for The Gator Nation

An Equal Opportunity Institution Institute of Food and Agricultural Sciences PO Box 110370

Food Science and Human Nutrition Department Gainesville, FL 32611

‐ 0370

352

‐ 392

‐ 1991

352

‐ 392

‐ 9467 Fax

CSims@ufl.edu

Consumer Acceptability of Grapefruit Juice With 2 “Free and Suspended Pulp” Levels Dr. Charles Sims, Eric Dreyer, Tom Young

Participants Dr. Charles Sims is a professor in the Food Science and Human Nutrition Department at the University of Florida, Gainesville, Florida. Dr . Sims performed the sensory testing in the sensory laboratory at the University of Florida. Eric Dreyer has a MS in food scie nce and is an assistant to Dr. Sims. Eric was present during the processing of the grapefruit juice and brought the juice back to Gainesville. Tom Young is with Florida’s Natura l Growers, a Division of Citrus World Inc. and coordinated the juice processing with John Bean Technologies Corporation (“JBT”) in Lakeland, Florida.

Purpose of Evaluation: USDA Grade Standards for Grapefruit Juice define “free and Suspended Pulp” as “particles of membrane, core, peel and similar particles that se ttle upon centrifuging a sample unit from which the floating fruit cells and floating pulp have b een removed.” The USDA Grade standards for grapefruit juice prescribe maximum levels for free and suspended pulp ranging from 10% to 15%. The purpose of the test was to te st consumer acceptability of juice with a free and suspended pulp value that exce eded the grade parameter.

Grapefruit Juice Processing Mature and wholesome grapefruit was obtained by JBT personnel and transported to the JBT, Lakeland, FL pilot plant on January 13, 2011 and pro cessed into grapefruit juice on January 14, 2011. Before processing, the fruit was si zed below 3 7/8” and was randomly divided by hand into 4 large tubs. The fruit was then extracted, finished, and pa steurized using the JBT pilot plant equipment.

The extractor was set to a 4 1⁄4” co mmercial grapefruit setting. The juice was finished in a small JBT pilot scale finisher (model 35). A special pan was installed on the finisher to collect 2 different concentrations of free and suspended pulp. Approxi mately 1/3 of the juice came from the discharge end where the most pressure is applied to the jui ce/pulp. Approximately 2/3 of the juice came from

the intake end where the least amount of pr essure is applied.

The process yielded two juices with different pulp levels: 1) the discharge end juice tested at 18% free and suspended pulp (“high pulp”); and 2) the in take end juice tested at 12% free and suspended pulp (“low pulp”). The two juice sa mples were pasteurized at 90C for 10 seconds, cooled to ca. room temperature, and filled into 1/2 gallon PET bottles. The two grapefruit juice samples (labeled as “low pulp” and “high pulp”) were transported (on ice) from JBT, Lakeland, FL to the Food Science and Human Nutrition Department at the Un iversity of Florida in Gainesvi lle, FL. There was a total of 2 gallons of each juice sample. The juice was kept refrigerated at 2C until evaluated on January 18,

2011.Sensory Testing For the sensory evaluation, panelists were recruited from the University of Florida campus. Potential panelists were screened to verify that they were grapefruit juice consumers. They were asked to identify which of the following juices they consumed : orange, apple, grape, and grapefruit. If they did not say grapefruit, they were not allowed to participate. A total of 86 panelists (41 male, 45 female, 82% between 18-29 years old) participated in the evaluation.

Panelists evaluated the juices in individual booths in the Sensory Lab in the Food Science and Human Nutrition Department. Approximately 40 mL of each juice were presented to the panelists in plastic cups coded with 3-digit random numbers. Juices were kept cold (on ice) and served cold. The juices were thoroughly shaken and mixe d before pouring into the serving cups, which were immediately served to the panelists. The two orders of presentation were presented approximately an equal number of times. Panelist were first asked to identify which of the 2 samples they preferred (paired preference test), then they were asked to rate the overall acceptability of the samples on the traditional 9-point hedonic scale (1=dislike extremely, 5=neither like nor dislike, 9=like extremely). They were encouraged to give comments on wh y they preferred one sa mple over the other.

The overall acceptability data were subjected to an an alysis of variance to de termine if there were any significant differences (alpha level of 0.05) between the two juices. For the paired preference test, a

standard table of critical number of correct responses for a two-si ded directional difference test was

consulted to find the minimum numb er of correct responses needed for a significant difference at alpha 0.05.

Results The data are presented in the at tached table. 50 pa nelists preferred the low pulp juice and 36 preferred the high pulp juice. The minimum number of correct responses needed for a significant difference at alpha 0.05 was 53, so there was not a si gnificant difference in preference. The low pulp juice had an overall acceptability rating of 5.87 and the high pulp juice 5.64. The analysis of variance

indicated that there was not a significant difference in acceptability at alpha 0.05.

Conclusion There was not a significant difference in consumer preference or acceptabili ty between grapefruit juices with 18% and 12% free and suspended pulp.

Investigator and Cooperator Contact Information:

Dr. Charles Sims: 359 Food Scien ce and Human Nutrition Building/ P.O. BOX 110370/Newell Drive, University of Florida, Gainesville, FL 32611-0370/Email:

casims@mail.ifas.ufl.edu

Tom Young: Florida's Natural Gr owers/A Division of Citrus World, Inc./20205 US Highway 27 North, Lake Wales, Florida 33853 / tom.young@citrusworld.com

Donn Sabato: John Bean Technologies Corp. 400 Fairway Ave. Lakeland FL 33803/Tel. 863-683-

5411/ Donn.sabato@jbtc.comGrapefruit Juice Sensory Results, January 18, 2011

Acceptability

Treatment # Preferring Rating Low Pulp 50 5.87 High Pulp 36 5.64

NS NS

86 panelists (41 male, 45 female , 82% between 18-29 years old, screened to say they dr ink grapefruit juice)

Minimum number of panelists pr eferring to be significant = 53, alpha level of 0.05, 2-sided test

Acceptability ratings range from 1-9, with 1=dislike extremely, 5=neither like nor dislike, 9=like extremely, no significant

differences according to analysis of variance, alpha=0.05