A commentary on the Technology of Processing and Preserving Foods by Exposure to Ionizing Radiation
by Lorna Salzman & Judith Johnsrud, Ph.D.
The staff of Food and Water, Inc., having reviewed a memo entitled "The Processing/Preservation of Food with Ionizing Radiation" which was conveyed to Assemblyman John Kelly under a cover letter from Public Strategies, Inc., and dated February 5, 1987, and having examined pertinent governmental regulations and scientific literature on the subject of food irradiation, concludes the following:
Food radiation provides no discernible benefits that are not now available to consumers via cheaper, safer methods.
There is an agreement that irradiation destroys crucial vitamins.
Approximately 10% of the radiolytic products produced in foodstuffs by irradiation do not exist in non-irradiated foods; the long-term impact on health of these "Unique Radiolytic Products" is unknown because no proper studies have yet been done.
Irradiation stimulates production of dangerous, sometimes lethal, pathogens and their toxins, such as botulin and aflatoxin.
Because irradiation destroys familiar odors, textures, and appearances associated with decay, consumers could suffer illness or fatality from eating spoiled foods.
Irradiation is a post-harvest treatment; therefore, the use of pre-harvest pesticides, herbicides and fungicides is not eliminated.
No analytical method is now available for detecting whether a food has been irradiated, or how many times it has been re-irradiated.
Irradiation will increase, not decrease, food costs and may cause economic damage to U.S farmers.
The handling, transportation, and storage of millions of curies of radioactive source materials required for irradiation threaten communities, workers and the environment.
No demonstrated safe disposal facilities are in operation for the isolation of radioactive wastes from food irradiation facilities.
Viable alternatives exist and are in use for all the proposed purposes of irradiation.
No need for food irradiation has been demonstrated, yet the U.S. Department of Energy and FDA are actively promoting its commercialization.
Serious safety violations have occurred at all licensed New Jersey irradiators, resulting in license suspension and criminal charges.
Ionizing radiation in any amount poses somatic and genetic risks.
Background to Food Irradiation
When the United States entered the Atomic Age at the close of World War II, there was great hope for the beneficial uses of nuclear energy. The Atomic Energy Act of 1954 stated a national policy with respect to atomic energy that remains in federal law today:
Atomic energy is capable of application for peaceful as well as military purposes. It is therefore declared to be the policy of the United States that -
a. the development, use, and control of atomic energy shall be directed so as to make the maximum contribution to the general welfare, subject at all times to the paramount objective of making the maximum contribution to the common defense and security; and
b. the development, use, and control of atomic energy shall be directed so as to promote world peace, improve the general welfare, increase the standard of living, and strengthen free competition in private enterprise. (42 U.S.C. 2011)
Among the early projects for "beating swords into plowshares" were proposals for nuclear-powered airplane engines, nuclear-powered automobiles, and a variety of engineering uses of atomic explosives to create deep water harbors, dig a new Panama Canal, and recover oil and natural gas locked in shale rock - and the hope of irradiating food to extend its storage life, to control insect infestations, and to alter ripening times.
What was not fully understood during the 1950"s and 1960"s, however, was the nature of damage to human health and genetics that could result from radiation exposures. The long-term effects of the atomic bomb - first leukemias, then cancers and other life-shortening effects - did not begin to appear until the expiration of the "latency period" that follows the damage at the time of exposure. Some diseases did not make their clinically observable appearances for ten or twenty years following the exposure.
Epidemiological studies of the Japanese survivors of the atomic bombs, of the Marshall Islanders and U.S. service personnel and civilians who were irradiated during atmospheric nuclear tests, and of groups exposed to substantial radiation doses in the course of medical treatments required many years of careful analysis before the nature and extent of the effects of ionizing radiation began to be assessed. Subsequent research is identifying the occurrence of radiation damage at levels far lower than were originally predicted from the various activities that produce or utilize radioactive materials. Medical and epidemiological experts today therefore recommend extreme caution about allowing any additional increases in the exposure of workers and the public to ionizing radiation.
Food irradiation experiments were conducted during the 1950"s, however, among military personnel. The U.S. Army conducted non-scientific feeding experiments utilizing irradiated foods in the diets of soldiers. The cited advantages included sterilization, preservation, and disinfestation. Irradiation of bacon was, in fact, permitted by the Food and Drug Administration (FDA) in 1963 (See Federal Register, 28 FR 1465), but, in 1968, the FDA rescinded its approval, stating that the sponsor had "not met its burden for demonstrating safety" (33 FR 12055: 33 FR 15416). During the 1960"s, FDA also granted petitions for irradiation in order to inspect certain foods, to control insect infestation of wheat and wheat flour, and to inhibit sprouting in white potatoes. (See 21 CFR 179.21, 179.22, and 179.24.)
The current FDA support for food irradiation began in 1979, and regulations were then proposed on the initiative of the FDA Commissioner in 1981 (46 FR 18922). FDA adopted the existing irradiation regulations for fresh fruits and vegetables, pork and spices on April 18, 1986 (51 FR 13376). Currently, petitions to extend irradiation to meat in addition to pork are under FDA review. After April 18, 1988, no written labels stating that a food has been irradiated will be required by FDA regulations.
Why Food Irradiation Is a Hazardous Technology
The forms of ionizing radiation used to irradiate are not so benign and life-giving as the sun. The history of our development of atomic fission and fusion for weapons and for commercial purposes has shown us that exposures to x-rays and to radioactive gases and particulate sources cause serious, often long-delayed injury to human beings in the form of cancer, leukemia, other diseases associated with immune deficiency, and adverse genetic effects.
Our species, like all life on earth, has evolved in what is often described as a "sea of naturally occurring background radiation." In its naturally occurring quantities from cosmic and terrestrial sources, ionizing radiation cannot be "good" or "bad". It"s simply there. When unstable elements, such as uranium, thorium, and radium, decay, they give off energy. Radiation, in the form of gamma rays or alpha and beta particles, can penetrate living tissues, causing disruptions and injury at the cellular level, or death to the cell. A damaged cell may subsequently reproduce defectively or out of control, giving rise to a malignant tumor. If radioactive materials are ingested or inhaled and remain within the body, these internal emitters will decay within an individual"s body, potentially causing damage to organs, bone, bone marrow, or the genetic material. Responsible geneticists, biologists and medical doctors therefore recognize that any exposure to ionizing radiation, including naturally occurring ones, carry a risk of damage. Some exposures can be avoided; some cannot. There is general agreement that most radiation-induced mutations are harmful, not beneficial. Some cellular repair may occur when a cell is damaged by irradiation, but little is yet known about the imperfections of the repaired cell.
Although scientists have studied the effects of radiation on living things intensively, they are only now, after nearly a century, beginning to be able to discern the ways in which ionizing radiation actually affects human beings at low doses or at low dose rates (i.e., protracted exposures over a long time). We have much to learn about the pathways of long-lived radioactive materials which are released into our environment; about biological concentration in the various organisms that make up our human food chain; and about the sensitivity of the very young and the very old to exposures at or near background radiation levels. We have much to learn about cancer causation, and even more to learn about its cure.
Recent research shows, for example, that exposure of an embryo during its first months of development to terrestrial gamma radiation at naturally occurring background levels appears to be the primary cause of childhood cancer and leukemia deaths. This association has been masked in the past because pre-cancerous and pre-leukemic children tended to succumb to the infectious diseases of childhood, diseases which we now control with antibiotics and vaccines. Since the late 1950"s, such children have been enabled to live long enough that the malignancies, with latency periods of five to ten or more years, have an opportunity to develop and to be the cause of death. (G.W. Kneale and A.M. Stewart, "Childhood Cancers in the U.K. and their Relation to Background Radiation," Proceedings of the International Conference on Biological Effects of Ionizing Radiation, London, December, 1986.)
These findings - in addition to our inability to prevent nuclear accidents (Chernobyl, Three Mile Island) or to dispose safely of radioactive wastes - are now causing many experts to rethink our radiation exposure standards for the public. Recent reconsideration of data on the survivors of the Hiroshima and Nagasaki atomic bombs suggests that radiation protection standards, which are based on that body of data, may be non-conservative. Some former irradiation proponents now urge that we exercise extreme caution about extending our commitments to additional nuclear technology that would expand the widespread uses of large amounts of highly radioactive isotopes.
It is thus not a question of "subduing the forces of nature," or of recognizing nuclear energy as "only another natural force that technology can tame," as the Public Strategies paper states. We are learning to be less reckless about introducing pollutants wholesale into our environment. Because we have evolved at certain, very specific levels of naturally occurring background environmental radioactivity, it is only prudent to exercise great care about increasing those levels. The total amounts of radioactivity in the environment depend upon the number of sources of exposure to these known carcinogenic and mutagenic contaminants.
We are, after all, essentially composed of the foods we eat and the water we drink. As a society, therefore, and under law, we have a grave responsibility (not always carefully exercised) to protect the quality of the environment for ourselves and for future generations. (National Environmental Policy Act of 1969, "NEPA," at 42 U.S.C. 4321 et seq.). In the absence of prudence by the Federal government, which remains legally mandated to promote nuclear energy, the States bear responsibility for protection of the welfare of their citizens.
Uses of Ionizing Radiation
The ionizing radiation sources now used for food irradiation and sterilization (cobalt-60) and proposed for the future (cesium-137) are man-made radioisotopes that come from the nuclear fission process. Although ordinary background radiation from cosmic rays and terrestrial sources is unavoidable (and is both harmful and beneficial, as we have seen), the radioisotopes from nuclear reactor operation or from high-level radioactive wastes are intensely radioactive and require constant shielding and permanent isolation from people and the environment for the full duration of their hazardous decay time.
The decay time, referred to as "hazardous life," is the number of half-lives required to render a radioactive quantity innocuous, and ranges from a few seconds to many millions of years. Some of the most biologically dangerous fission products from nuclear reactors do not exist in nature. The production and utilization of these artificial isotopes represent potential hazards to the biosphere many orders of magnitude greater even than background radiation. It is the generation, storage, transport, handling, and ultimate safe disposal of these man-made radioactive materials, and of the materials they contaminate during industrial processes such as food irradiation, that are of grave concern to physicians and public health officials. The fact that these activities are proposed for "peaceful uses of atomic energy" in no way lessens or mitigates their inherent biological dangers.
Infra-red food heating and photography, radar, television, electric light, and microwave cooking, cited in the Public Strategies paper as forms of electro-magnetic energy that we already utilize in our daily lives, are markedly different from the ionizing radiation proposed by the food irradiation industry, nor are these technologies entirely risk-free. Medical x-rays and radioisotopes are important diagnostic and therapeutic tools for the detection and treatment of certain diseases.Conscientious doctors agree that their benefits for an individual patient must be weighed against the serious risks they pose. Sound public health practice today urges avoidance of exposures to ionizing radiation unless there is a commensurate benefit to the individual who is exposed.
Although cobalt-60 is presently used for commercial irradiation purposes, the U.S. Department of Energy (DOE) is vigorously promoting, through direct subsidies and artificially low prices, the sale of cesium-137. DOE describes its promotional role thus:
Specific food irradiation activities being supported by the DOE include research, feasibility studies and development of full-scale irradiation facilities....(which) are being designed and constructed to accomplish the technology transfer goals of the BUP (Byproducts Utilization Program). These facilities will serve as a validation of cesium irradiation technology.... ("Technology Update and Future Initiatives," U.S. Department of Energy, Byproducts Utilization Program, 1985.)
Cesium-137 is a fission product, with a 30-year half-life; it is considered one of the most biologically hazardous of all radioisotopes. It is a major component of radioactive wastes. The largest source of cesium is at the Hanford, Washington nuclear weapons facility, where it was separated out during waste reprocessing, as a by-product of plutonium extraction for weapons. A single irradiating facility may use 3-10 million curies of cesium-137 as its source material. Says DOE:
Since 1974, the ADC/ERDA/DOE has encapsulated 77 million curies of cesium-137. This supply is a small fraction of the total amount of cesium potentially available from all sources over the next twenty years. Most of the isotope is contained in spent fuel rods from commercial power reactors that are currently being stored onsite at these facilities....
...any major utilization of irradiation in the food industry is precluded in the near term. In order to assure that the promise of food irradiation technology is realized, the DOE is investigating options for increasing the supplies of radiation sources. (U.S. DOE, Byproducts Utilization Program, supra.)
In addition, there are large inventories of unreprocessed military and civilian reactor wastes containing between one and two billion curies of cesium. A full-fledged food irradiation industry would undoubtedly create strong pressure on DOE to reprocess these wastes in order to extract the cesium. The Secretary of Energy has testified before Congress that the Energy Department has no objection to a resumption of commercial spent fuel reprocessing by private industry (DOE testimony, U.S. Senate Energy and Natural Resources Committee hearings, January 29, 1987).
Although irradiated materials do not ordinarily become radioactive, machine-generated electron or x-ray irradiators could give higher energy doses that are capable of inducing radioactivity in certain foods, especially those containing trace metals. Thus, in a multiple-use irradiation facility, equipment used to sterilize medical equipment and to irradiate food, could, if improperly calibrated or operated, theoretically induce radioactivity accidentally in some foods.
We emphasize, however, that the statements in the Public Strategies document (p.4) that the "radiation within the chamber itself dissipated immediately upon completion of the process" and that "anyone may safely enter the chamber" are inaccurate and seriously misleading. The radiation source, cobalt or cesium, emits gamma rays that penetrate whatever is in the chamber as long as the source is uncovered. In a properly constructed and operated irradiation chamber, the source material is carefully shielded when not in use and the chamber does not leak. But malfunction and human error can lead to worker exposure. This occurred at the Radiation Technology, Inc. facility in Rockaway Township, New Jersey; a faulty interlock was allowed to remain unrepaired and led to a severe worker overdose reportedly monitored at 222 rads, a sublethal dose. (See 51 Federal Register 23612, June 30, 1986.)
Doubly misleading is the statement in the public strategies document (p.8) that the shielding pool water "does not even get hot." It cannot be too strongly emphasized that thermal heat is not the issue; the issue is radioactivity. The shielding pool water does become radioactive, and in event of accidental leakage, as took place in the Isomedix and International Nutronics cases (see p.15 of this document), the entire area could become radioactive and require decontamination or removal of contaminated materials, as in fact was required at Isomedix.
The unidentified author(s) of the Public Strategies document either misunderstand the problem of radiation safety, or are deceptive, in their claims (p. 8) that "radiation is so low in these plants that a shielding pool of water suffices to absorb all the energy from the cobalt when not in use" and that "the radiation utilized in this process dissipates when the cobalt returns to its protective pool of water." (emphasis added) Spent fuel rods from commercial nuclear reactors are also stored under water, because they must be kept cool to prevent the intensely radioactive spent fuel from melting, undergoing a chain reaction, and releasing its radioactivity.
Gamma radiation is extremely penetrating energy; it can pass through steel and concrete walls. It is precisely the potential for the loss of shielding, be it water or concrete, that makes irradiation facilities inherently dangerous. The radioactivity of the cobalt or cesium source material does not disappear or dissipate when the source is not in use; rather, the radioactivity is prevented from passing beyond the chamber by the water of the shielding pool and by the concrete walls of the chamber. Integrity of that shielding pool and the constant presence of adequate cooling water are essential to prevent radioactive releases.
Contrary to the claim that the chamber "can easily withstand ....even the crash of a jumbo jet," it should be noted that the containment building of the Three Mile Island nuclear reactor was not designed to withstand the crash of a jumbo jet. The federal Nuclear Regulatory Commission exercises far less stringent construction requirements for irradiation facilities than for nuclear power reactors.
The impending use of ionizing radiation for food irradiation does not eliminate, but rather compounds, already existing problems of worker safety, nutrition, pesticide poisoning, and environmental protection. The transport, handling, and disposal of many millions of curies of intensely radioactive isotopes anywhere, and particularly in densely populated areas like New Jersey, pose additional threats to communities which are already plagued with toxic waste dumps, nuclear reactors, other hazardous industries, and polluted groundwater.
What Public Strategies memo (p.1) describes as a "deeply human impulse" to "subdue the forces of Nature" has all too frequently produced instead inhuman consequences. This has been true particularly in cases where legislators and regulators did not demand prior proof of safety or information on alternatives to a hazardous technology. Public Strategies cavalierly dismisses legitimate public concerns with apparent contempt, and seems to elevate its version of science on a highly controversial subject to a position beyond public scrutiny or criticism. Responsible consumer, public health, and environmental officials and organizations, far from condemning science or technology, focus instead on large, societal implications and long-term consequences of specific technological innovations; they raise important questions about the quality, adequacies, and underlying assumptions of scientific studies. They attempt to avoid unpleasant after-the-fact surprises.
Some corporations and their scientists, conversely, have tried to portray such citizens and officials as uninformed, while they themselves conceal or understate the negative aspects or omissions in their supporting research. For example, in the case of nuclear energy, both nuclear scientists and the government in the past have gone to great lengths to discount or conceal the dangers of low-level radiation. Some have gone so far as to experiment with ionizing radiation on human beings: on soldiers, prisoners, hospital patients, even children. (See "American Nuclear Guinea Pigs: Three Decades of Radiation Experiments on U.S. Citizens," A Subcommittee Staff Report for the Subcommittee on Energy Conservation and Power, Committee on Energy and Commerce, U.S. House of Representatives, October, 1986.)
It is only now, following the 10 to 30-year latency periods, that the consequences of low-level radiation exposures are turning up in the form of cancers, leukemias, and genetic defects. Governmental standards and risk estimates and regulatory procedures are proving to be entirely inadequate to protect either workers or the public from radiation exposures. Will food radiation be allowed to repeat this historic pattern of unfounded optimism on the part of proponents of nuclear technologies?
Accidents and Violations
Serious violations at irradiation facilities, resulting in severe worker radiation overexposure and environmental contamination, have already occurred here in New Jersey at all three major irradiators: Radiation Technology, Isomedix, and International Nutronix. Between March and June, 1986, Radiation Technology"s license was twice suspended by the Nuclear Regulatory Commission (NRC). The agency said:
The recent investigation findings, indicating that the violations originally described in the March 3, 1986 suspension order were willful and that numerous management and operations personnel willfully provided false information to the NRC, demonstrate a pattern of wrongdoing so pervasive that the NRC no longer has reasonable assurance....that the Licensee will comply with NRC requirements and that the public health and safety, including the safety of the Licensee"s employees, will be protected if this Licensee is permitted to continue to conduct licensed activities. If at the time the license was issued the NRC had known that such a pattern would develop, the license would not have been issued. (51 Federal Register 23613, June 30, 1986.)
The NRC also cited Radiation Technology for "defeating required safety interlocks" and for continuing irradiator operations "following the malfunction of the personnel access door interlock system." (See 51 FR 23612-3.) Irradiator operation continued with the inoperable interlock for approximately one week until identified by the NRC.
Also notable is that Radiation Technology refused to cooperate with regulatory and inspection officials, according to the Food and Drug Administration"s Public Health Service. The FDA report stated, "The firm management refused inspection of product storage area," and noted further that the inspector was physically restrained from inspecting a storage and processing area behind a floor-to-ceiling curtain. Radiation Technology, according to FDA, also refused to provide a list of drug products and customers to the inspector or to allow him to review the processing and customer records. FDA found serious discrepancies in record keeping and was permitted to see the facility only after getting a court order. (See FDA, Public Health Service, Internal Reports, released under Freedom of Information Act request.)
The State of New Jersey found that "Radiation Technology is exclusively responsible for the groundwater contamination at and about their property." (New Jersey Department of Environmental Protection, Division of Water Resources, Site Evaluation Report, Radiation Technology, Inc., August 13, 1984.)
International Nutronix was cited by the NRC and later charged in court for nine violations, including failure to report a December, 1982 leak; conspiracy to cover up the leak; falsifying reports; improper decontamination procedures, and dumping of contaminated water into a shower stall from which it then ran into the sewer system. International Nutronix filed for bankruptcy three days after the company was indicted by a Federal Grand jury in Newark; one defendant, Eugene O"Sullivan, former vice-president of the company, was once a member of the Atomic Energy Commission (Newark Star-Ledger, October 21, 1986).
The Isomedix plant in Parsippany was contaminated during the period 1976-1980; the contamination problem was reported by employees. A cobalt rod ruptured, and the clean-up water was poured down the toilet. Both the toilet and the drain pipes were later found to be radioactive as was the concrete around a shielding pond, which later had to be physically removed because of its radioactivity. "Probe asked of Irradiation Plant," New Jersey Daily Record, May 3, 1981.)
Regulatory abuses have also been reported in foreign shipping of irradiated food. Bacterially contaminated prawns, which had been refused entry into the United Kingdom, were sent to the Netherlands for irradiation to conceal decay odor and appearance, were re-imported to the U.K., and were sold there illegally. Some U.K. shippers also knowingly imported contaminated foods which they knew would be refused entry. After one shipment was rejected, the shipper collected the insurance for his "unfit" cargo, bought back the food at a low price and irradiated it to "clean it up" in order to illegally re-import the same shipment. (Super Marketing, United Kingdom, July 11, 1986.)
Certain limited uses of artificial food additives,such as nitrates, have been approved with appropriate warning labels following research to establish some basis for estimating their hazards. The FDA has taken an entirely different approach, however, in permitting the consumption of foods containing "Unique Radiolytic Products" ("URP"), not found in non-irradiated foods, in the absence of definitive research on their extent, effects on human health, or synergistic effects in combination with other factors. There is substantial concern among many in the scientific community about what some have termed an irrational and irresponsible decision by the FDA to proceed with a food irradiation Final Rule without first acquiring studies of URP"s and their effects on human diet and health. FDA itself seems to share these concerns. In 1980, the FDA"s Bureau of Foods Irradiated Foods Committee stated:
Ionizing radiation results in the formation of free radicals, which are characteristically unstable and very reactive chemical intermediates....The radiolysis data available....are insufficient to completely catalog the identity and quantity of each radiolytic product formed in any particular irradiated food.... (S)ome 10% of this particular subset of radiolytic products are in fact Unique Radiolytic Products. (Recommendations for Evaluating the Safety of Irradiated Foods, Irradiated Food Committee, Bureau of Foods, FDA. Final Report, July, 1980. BFIFC)
Independent scientists agree that radiation-induced chemical changes may result in the formation of new chemical compounds during irradiation. The extent to which these products might be toxic is not, however, well known, according to Drs. Noel F. Sommer and F. Gordon Mitchell of the University of California at Davis. Dr. Geraldine Dettman, Biosafety and Radiation Safety Officer, Brown University, said, in comments on a proposed FDA food irradiation regulation in 1984:
Although the cells will be killed by radiation at 100,000 rads, and sprouting thus inhibited, all enzymes will not be inactivated. Therefore, chemical reactions in the fruits and vegetables will still occur. There will be a changing chemical composition in the food with time after irradiation. Therefore, the composition of the radiolytic products (unique or not) or products produced by reactions with radiolytic products will change with time after irradiation. (Geraldine Dettman, Ph.D., Safety Office, Brown University, Providence, R.I., Comments on FDA Docket 81N-0004, April 10, 1984.)
Several authorities raise questions about the biochemical impacts of free radicals. Of their effects on fruit and vegetables, Sommer and Mitchell write:
Gamma rays which are produced by cobalt-60 and cesium-137 cause ionizations when they collide with matter.... During ionization, highly reactive free radicals are produced which react in various ways to also produce damaging events in cells. With a water content of 85-90% in most fresh commodities, the most common free radicals are those of water. Space within tissues comprise up to about 20% of the volume of many horticultural commodities...so free radicals from oxygen are also likely to be important. (Noel F. Sommer and F. Gordon Mitchell, Department of Pomology, University of California at Davis, California Fruit Grower, vol. 61, May 1984.)
The impact of free radicals in the human body is also a significant question. Dr. George L. Tritsch, of the Roswell Park Memorial Institute, states:
The greatest danger of food irradiation...is the induction of free radicals. In fats, this results in peroxidation and cross link formation which could result in substances, which, when incorporated into cell membranes, would result in unusually rigid membranes which would furthermore be resistant to enzymatic degradation. Damage to DNA by free radicals is one proposed mechanism of carcinogenesis....I would think that the risks of including molecules altered by free radical reactions in the diet outweigh by far the benefits of irradiation. George L. Tritsch, Ph.D., Roswell Park Memorial Institute, Department of Health, State of New York. Comments on FDA Docket 81N-0004, March 29, 1984.)
There are additional sources of potential toxicity, according to the scientific literature. These chemical changes are in addition to those caused by canning, freezing, cooking or "digestion itself," to use Public Strategies' phrase.
Polycyclic aromatic hydrocarbons such as BP (Benzo[a]pyrene) are present in significant amounts in many foodstuffs...and the wide-spread occurrence of these compounds in the environment makes them highly suspect as human carcinogens.... [P]re-carcinogens of this type may be oxidized to mutagenic and toxic species in foodstuffs which contain polyunsaturated fats and are subjected to conditions which induce peroxidation, such as the production of free radicals by irradiation.... (J.D. Gower, E.D. Wills, "The oxidation of benzo[a]pyrene mediated by lipid peroxidation in irradiated synthetic diets," International Journal of Radiation Biology, 49:471-484, March 1, 1986; emphasis added.)
Some reports indicate more frequent genetic changes in fruit flies (Drosophila melanogaster) fed an irradiated diet; because if this, the British Ministry of Health said: "The possibility must be considered that, under the influence of radiation, substances are formed in food which are capable of increasing the natural mutation rate at any form of life." (Report of the Working Party on Irradiation of Food, Ministry of Health, Committee on Medical and Nutritional Aspects of Food policy, 1964).
Food irradiation may also cause the appearance of, or increase in, radiation-resistant pathogens. Of particular concern are aflatoxin, produced by Aspergillus flavus, and botulin toxin, produced by Clostridium botulinum. Research at the U.S. Naval Research Laboratory in Washington D.C., showed that medium and high doses of gamma radiation actually stimulated heavier production of the potent carcinogen, aflatoxin, with the increase of aflatoxin in the higher irradiation group over fifty times greater than the non-irradiated control. The experimenters, all of the FDA, said:
These experiments indicate that gamma radiation of aflatoxin- producing molds probably cause an increase in aflatoxin production.... These results should be considered when irradiation of food products is being contemplated. (A.F. Schindler, A.N. Abadie, and R.E. Simpson, "Enhanced Aflatoxin Production by Aspergillus flavus and Aspergillus parasiticus after Gamma Irradiation of the Spore Inoculum," Journal of Food Protection, vol. 43, no.1, January, 1980, pp.7-9.)
At the U.S. Army Natick Research and Development Center, experiments showed that Clostridium botulinum spores survived irradiation and were able produce botulin toxin if sufficiently low temperatures were not maintained. (D.B. Rowley, R. Firstenberg-Eden, G.E. Shattuck, "Radiation-Injured Clostridium Botulinum Type E Spores: Outgrowth and Repair," Journal of Food Science, vol. 48, 1983, pp. 1829-31.)
Ironically, food irradiation, by destroying the visual and olfactory signs of spoilage, could permit consumption of contaminated foods and actually increase the incidence of food-borne diseases. The Federal government has already expressed its concern:
While radiation sterilization does destroy microbial life, it does not necessarily destroy the toxins and residue that may be built up or be deposited by large concentrations of such micro-organisms. Therefore, processing would have to remain much the same as it is now. ("The commercial prospects for Irradiated Foods," U.S. Department of Commerce, Business Defense Services Administration, March, 1968.)
Pork products are especially vulnerable:
...cans of ham which were irradiated at substerilization radiation doses for Clostridium botulinum were subject to increased spoilage rates compared to non-irradiated hams. Similar results have been reported for other cured meat products including bacon. (D.W. Thayer, U.S.D.A., Agricultural Research Service, Eastern Regional Research Center, Memo of March 11, 1986, re: Proposed Research to be Conducted by the ARS.)
The projected consumption of irradiated pork and pork products is highly problematic. The U.S. Army fed irradiated bacon to troops in the 1960"s after receiving FDA approval, but when FDA reviewed studies showing tumors, diseases, and changes in production of offspring among test animals consuming irradiated diets, the FDA rescinded its approval.
One study conducted in India by the National Institute of Nutrition, Indian Council of Medical Research, examined, under controlled conditions, a small group of malnourished children who were fed freshly irradiated wheat, and leukocyte cultures were then performed. In four of the five children fed the freshly irradiated grain, polyploid and other abnormal cells developed within a few weeks of initiating the irradiated food, with a gradual return to no polyploidal cells following the cessation of the irradiated wheat diet. In contrast, none of the children receiving unirradiated foods showed this effect, while those fed stored irradiated wheat showed polyploid and abnormal cells in "significantly decreased numbers." This study has been contested by proponents of food irradiation but has received the backing of the Institute in which it was conducted. (C.Bhaskaram and G. Sadasivan, "Effects of feeding irradiated wheat to malnourished children," The American Journal of Clinical Nutrition, 28: February, 1975.) Ten years later, the director of the Institute wrote:
A series of studies were therefore planned and carried out to test the safety 21 of irradiated wheat under dietary and nutritional conditions prevailing in our country. Feeding of irradiated wheat to children with kwashiorkor was a part of these comprehensive studies. In light of published data we did not anticipate any adverse effects of feeding irradiated wheat to these children. However, as soon as some abnormality was observed in these malnourished children, we terminated the study for ethical reasons and the children were put on the normal therapeutic regime. We could not repeat such studies just for the sake of scientific curiosity since we know that some abnormality (polyploidy) would result. However, a series of animal studies did indicate that when freshly irradiated wheat was fed, polyploidy was observed. (B.S. Narasinga, Ph.D., Director, National Institute of Nutrition, letter, April 2, 1985)
These Indian findings were essentially ignored by the FAO/IAEA/WHO committee in its report, Wholesomeness of Irradiated Food, while other Indian studies and some from China that reportedly showed no such adverse effect were cited as refuting the Bhaskaram and Sadasivan wheat study. One of the Chinese studies lasted only fifteen weeks, far too short a time period to determine the safety of long-term ingestion of irradiated foods. Dr. John Gofman, who worked on the development of the atomic bomb and is a distinguished heart specialist and professor emeritus, University of California at Berkeley, says unequivocally that proper studies, to be of any value, should be conducted for several decades and must use very large numbers of people.
Foodstuffs can also become contaminated after, and in spite of, irradiation. "If the moisture content of stored rice is too high, fungi such as Aspergillus flavus, which are sometimes toxigenic, may grow," reports the FAO committee. Regarding the irradiating and shipping of fish, studies conclude that:
...maintenance of the temperature of melting ice throughout the period of storage of the product has been specified as an additional safeguard against botulism; salting, drying, or other effective measures would have to be substituted if this temperature could not be maintained reliably.... In the case of irradiation, as in any other method of food processing, the gains in microbiological quality must be safeguarded by proper care of the product after processing. (Wholesomeness of Irradiated Food, Report of a Joint FAO/IAEA/WHO Expert Committee, World Health Organization Technical Series 659, 1981.)
These findings demonstrate that food irradiation does not eliminate the need for other forms of preservation,, as well as cooking, any of which unavoidably destroy nutrients to some extent, as does food irradiation itself. Moreover, those animal studies that have been done have shown clear adverse effects. Ralston Purina studies undertaken for the USDA showed "Statistically significant increase in testicular tumors in mice fed irradiated food (Group G)." "...the preponderance of evidence suggests some degree of toxicity was present." "Many lesions (including cancer) ...were often found most frequently in the G group." (Ralston Purina, "Animal Feeding Study for Irradiation Sterilized Chicken," USDA Contract 53-3K06-1-29, June, 1983, quoted in Health Research Group comments on FDA Docket 81N-0004, April 12, 1984.)
The Health Research Group concluded:
There was, according to the final report of this study, a statistically significant dose-related increased rate of death among the offspring of flies fed gamma irradiated chicken.This effect is consistent with chromosomal damage. Health Research Group, supra; emphasis added.)
FDA chose to ignore these studies and justified its decision to approve food irradiation not because it possessed sufficient data to make a finding of safety, but rather because it chose to extrapolate from radiation chemistry and to make, instead, a wholly subjective judgment that irradiated diet components would comprise a small part of the "normal" diet. Put bluntly, FDA waived its customary approval process and substituted mere subjective assumptions for verifiable scientific data:
Ordinarily, animal feeding tests are essential for assessing toxicity of a substance. Not all situations require the same amount or type of testing, however, to determine whether use of an additive is safe. The degree of effort expended in reducing uncertainty about the safety of an additive must relate in some way to the likelihood that use of the additive poses a potential health risk to the public. Testing that is unlikely to provide information that would reduce uncertainty regarding safety should not be required. To do otherwise would waste scarce scientific resources that could be used for more productive purposes. (51 FR 13377; 21 CFR Part 179, April 18, 1986)
Almost entirely missing from the Public Strategies memo is any reference to nutrition - an understandable void if one is promoting food irradiation. Clear scientific documentation exists that demonstrates that food irradiation destroys vitamins:
Undesirable changes in component molecules do occur...as a consequence of ionizing events. Especially noted has been the radiation induced destruction of certain vitamins in fruit and vegetables to thereby reduce the nutritive value. The extent of vitamin destruction is dose related. Vitamin loss will vary from commodity to commodity and will be influenced by storage and handling procedures. Sommer and Mitchell, California Fruit Grower, supra)
The USDA is well aware of this problem, particularly regarding vitamin destruction in pork:
The degradation of thiamine was significantly increased by cooking after irradiation of the bacon. The two processes, irradiation and cooking, produced degradation, but when the product was cooked after it had been irradiated, the overall effect was greater than the sum of the processes applied individually. (USDA, Agricultural Research Service, Research Update Needs, FSIS No. I-87-7, September, 1986.)
A study conducted at the USDA"s Eastern Regional Research Center showed that pork irradiated at 100 Krads (the amount arbitrarily allowed by FDA), suffered a 20% loss of thiamine. Thiamine levels in pork irradiated at 500 Krads were reduced by 54%. Pork consumption is estimated to account for 14% of U.S. thiamine intake. (Health letter, Public Citizen-Health Research Group, March /April, 1986.)
The impairment of nutritional quality of irradiation is of concern to both U.S. government and international agencies. Experts within FDA have stated:
From a number of studies on the radiation stability of vitamins, proteins, fat and other nutrients, it is known that several nutrients are sensitive to degradation by ionizing radiation.... Particular attention should be focused on vitamin A and carotene, vitamin E, vitamin C, vitamin B-12, thiamine, and vitamin B-6. Although other vitamins and essential nutrients must not be ignored, the aforementioned vitamins are noted because of published studies that demonstrate losses in irradiated products. (Recommendations for Evaluating the Safety of Irradiated Foods, Irradiated Foods Committee, Bureau of Foods, FDA, Final Report, July, 1980)
In light of the various negative findings and the unaddressed questions about the safety of food irradiation cited above, Public Strategies" emotionally charged phraseology ("scare tactics," "sow confusion," "ill-advised legislative proposals"), as well as the implied accusation that people who are concerned with health and nutrition are merely "food faddists," seem misdirected if not hypocritical. Perhaps their unidentified author(s) should be asked if these charges are to be applied to members of these distinguished national and international bodies reflecting scientific opinion.
In our search of the scientific literature, we have failed to find the "nightmarish images" of which Public Strategies speaks (although some might consider the unpleasant facts about food irradiation somewhat nightmarish). If the public and legislators are doubtful about the safety of food irradiation, it is in part precisely because overall the scientific findings are inconclusive about the nutritional impacts of food irradiation, and the experts have expressed strong reservations about its safety. Many scientists are also disturbed about the adverse effects that are already known from animal feeding studies, about vitamin destruction, and about the sheer lack of adequate research on the long-term effects of eating irradiated foods, upon the embryo, the ill, the aged, and everyone in between.
Environmental Problems and Radioactive Waste
Despite Public Strategies" accusation (p.17) that "antagonists...confuse the radiation used" in their technology with nuclear power and radioactive wastes, it is important to recognize the relationship between food irradiation and the so-called nuclear fuel cycle, as well as recognizing that exposure to ionizing radiation from any source may be damaging. One portion of a system of production cannot be separated from the total contribution to all parts of that system to the contamination of the environment.
Thus, New Jersey residents have learned, long after the U.S. Radium Company had departed, that radioactive residues from industrial operation decades ago continue to contaminate Montclair and the Oranges, and that there is still no solution to the safe disposal of those radon-emanating wastes. Much of the Northern Hemisphere experienced the passage of the radioactive plumes from the Chernobyl disaster, and cesium-137 fallout from that explosion in 1986 will contaminate European food supplies for upward of 300 years, causing delayed sickness and death to numbers of people estimated variously from 5000 to 1,000,000 over the next 70 years. Radioactive releases from the Three Mile Island Unit 2 reactor damaged severely in 1979 continue, as does the slow, difficult removal of the crumbled and solidified fuel; more than 2000 legal claims of health injury are pending in courts, in addition to those already settle out of court. Hundreds of thousands suffered enduring damage in the Bhopal chemical disaster; toxic materials accidentally released into the Rhine River will continue to wreak their damage for many years to come, at great economic loss to downstream nations.
No technology is risk-free, and the technologies that employ radioactive materials seem especially vulnerable to onsite technical and human failures. The Public Strategies" argument (p.9) that "radiation cannot escape from the chamber" is specious and has been shown by events to be false. Safety systems can be bypassed; workers or managers are sometimes careless or tired; equipment fails; trucks have accidents; waste facilities leak; sabotage is a shadowy threat. In short, the potential for error and accident is always present and by its nature cannot be predicted or protected against.
Public Strategies" claim that the Environmental Protection Agency requires no environmental impact statement misses the point: it is the Nuclear Regulatory Commission, well known for the laxity of its regulatory procedures, that licenses such facilities, not EPA. The statement that "insurance companies routinely provide ordinary liability and property coverage" must also be weighed against the fact that all homeowners" property insurance policies specifically exclude compensation for all radiation-caused accidents. An individual homeowner still cannot purchase any private property insurance to cover against losses incurred in consequence of radiation damages.
Food irradiation"s success commercially, as we have shown, is clearly dependent upon the existence of an ample source of the biologically hazardous cesium-137. This material is regained from high-level radioactive wastes, and is no less hazardous to human beings in its recycled form at the food irradiating plant. Spent source materials will nonetheless continue to be dangerously radioactive long after their economic value to the irradiators has passed. So far as is presently known, much of the cobalt and cesium waste from this industry will become eligible for, and will require, disposal at the regional disposal site of the state in which the food irradiation facilities are located. Food irradiation equipment and structures contaminated by exposure to or contact with these radioactive source materials, too, will require expensive isolation from the environment for their full hazardous lifetime.
Efficacy, Need, Alternatives
Irradiation does not always extend shelf life, if that is indeed put forth as a "benefit". In some instances, shelf life may be shortened by irradiation, which can accelerate ripening in some foods and induce undesirable alterations in color and consistency. Leading experts in horticulture have this to say:
...irradiation to extend shelf life by suppressing rot generally was not feasible because of softening and consequent increases in handling and transit injury, low benefits in relation to anticipated costs for irradiation, added commodity handling. Often, improved alternatives were available.... Large differences are found in reports of estimated shelf life extension due to irradiation.... Ripening may be delayed in some fruit species or hastened in others.... Unpleasant flavors and aromas may be noted soon after radiation and may be intensified with time after irradiation.... Loss of firmness in irradiated commodities may render some commodities susceptible to handling and transit injuries. (Sommer and Mitchell, "Gamma Irradiation - A Quarantine Treatment for Fresh Fruits and Vegetables?" HortScience, June 1986.)
There are also economic implications for producers and consumers, since irradiation does not eliminate the need for conventional processing, storage, and hygiene measures to prevent post-irradiation contamination and spoilage.
The need for extensive refrigeration facilities and the costs of extra handling and local transport that might be required in connection with irradiation heretofore have not been adequately considered.... It is likely that altered organoleptic qualities, excessive softening leading to transit and handling injury, and skin pitting and other damage will preclude use irradiation for some commodities. The availability of less costly alternative quarantine treatments will further eliminate possible candidates for irradiation. (Sommer, et al., supra.)
Since irradiation is a process that will require extra transport, handling, and storage, there will inevitably be additional costs incurred, but one must ask: incurred by whom? Unless irradiators go into the food business themselves, owning the food they irradiate, the probable sector to be burdened with the extra costs will be the middlemen, the packers and shippers, who in turn will charge food producers, and undoubtedly also consumers, for the extra costs of irradiation.
Packers and shippers operate on a cost-plus basis which means they would charge the grower for the additional cost of having the product irradiated. This cost can me mitigated, if not eliminated, in the case where a premium for the irradiated product can be obtained. As long as the consumer is willing to pay a higher price, the grower most likely would not have to bear the entire cost in the long run. ("Feasibility of Irradiating Washington Fruits and Vegetables for Asian Export Markets," a report prepared by International Marketing Program for Agricultural Commodities and Trade (IMPACT), sponsored by the Washington State Department of Agriculture, September, 1986.)
It is difficult, if not impossible, at this time to demonstrate a clear need for food irradiation or to point to any potential benefits that cannot be obtained from cheaper, safer alternative processes.
There is simply a lack of a need for a new preservation method in the U.S., thus the desire for irradiation could drop over the next ten years. Presently, other technologies, such as freezing, can do most of the same job more cheaply and effectively.... Although the pork industry is favorably inclined to irradiation as a means to help eliminate trichinosis, Dave Meisinger of the National Pork Producers Council says a method called ELISA (Enzyme-Linked Immunosorbent Assay) holds more promise because of economics. Testing each carcass by ELISA would cost a maximum of about 15 cents per hog, compared with 27 to 95 cents for irradiation. (Trends, International Association of Refrigerated Warehouses, January, 1986.)
Proven alternatives for all the stated purposes of food irradiation exist and are now in use: fruit fly sterilization, cold storage, single and double hot water dip, detection of larval infestation with acoustic devices and mechanical removal of larvae, microwaves, and infrared heat treatment, among others. (Health Research Group, op. cit., 1984.) Even enthusiastic supporters of irradiation in the agricultural industry admit that irradiation of produce and grains will not replace all fumigants and pesticides. It should be stressed that irradiation is a post-harvest means of disinfecting foods. The usual pre-harvest herbicides, fungicides and insecticides will still be applied to many commercial crops, some having persistent residues. Very little information exists on the chemical properties of and impacts of these synthetic chemicals which have also been irradiated.
Parenthetically, we would note that the same "expert bodies" who have approved food irradiation had also in the past given approval to other food treatments that were later shown to be harmful and eventually were banned: DDT and ethylene dibromide are instructive examples. Ethylene dibromide is, in fact, the fumigant that food irradiation is touted to replace. Some years ago, its safety was vigorously defended by USDA and New York City officials when lower Manhattan residents opposed its use to fumigate a grain storage building infested by an Asian beetle. Ethylene dibromide is now banned.
Most recently, the European Parliament revoked its general authorization of food irradiation on precautionary grounds and called for study on alternative methods of preserving food. This resolution, adopted March 10, 1987, noted the absence of comprehensive studies on long-term effects, loss of nutritional value, and doubts about the chemical changes induced by irradiation.
The world hunger argument is intended to rouse up sympathy and compassion, but Public Strategies" claims that food irradiation can help to eliminate world hunger do not hold up under scrutiny. A world conference on irradiated food, for instance reported:
Pulses [legumes] are a major source of dietary protein in certain parts of the world. Any deleterious effects of irradiation on the nutritional quality of these crops would therefore be of importance. Conflicting results appear in studies of the protein efficiency ratio (PER) and the effects on B-complex vitamins have not been well established for different pulses. These possible effects should receive consideration wherever irradiated pulses are used as staples of the diet. (Wholesomeness of Irradiated Food, Report of a Joint FAO/IAEA/WHO Expert Committee, World Health Organization Technical Report Series 659, 1981.)
World hunger has social and political roots which give rise to conditions, in addition to poverty, that obstruct the sale and distribution of food supplies. Spoilage of grains held in storage and insect or rodent depredations in Third World countries would be lessened if such foods were promptly and efficiently distributed. The failure to do so is often directly attributed to local economic or political conditions that would not be improved markedly by irradiated foods. Most people who live at subsistence levels lack enough disposable income, anyway, to purchase pre-processed and pre-packaged meats or produce, especially expensive foreign imports.
The proposed "benefits" of food irradiation would in fact accrue to those who would employ this process in order to broaden their foreign markets. But in Third World countries, with low annual per capita income, the importing of foreign pre-processed foods would increase the local cost of food for poverty-stricken populations, and at the same time could discourage the development of local subsistence foodstuffs that can be produce and marketed without processing, packaging, preservation, or extensive transport.
Furthermore, the purportedly beneficial extension of shelf life of produce by irradiation could actually operate to impair nutrition among the already malnourished of Third World nations: not only would irradiation destroy crucial vitamins in produce and grains, but also the extended storage of some irradiated foods would contribute to additional nutritive deterioration and possibly to consumption of spoiled foods.
Raising the specter of food scarcity is truly a scare tactic, or a smoke screen to justify the promotion of high-tech food treatment practices that are inappropriate to the real needs of developing countries. The Institute for Food and Development Policy categorically rejects the notion of food scarcity, stating that, although there is more than enough food produced now to feed the population of the world as projected for the year 2000, extreme inequality in the ownership and availability of land and of access to even low-technology equipment, seed, fertilizer, water, and techniques have together exacerbated the food problem. The vagaries of weather combine with increasing social conflict between poor farmers and the wealthy: age-old problems that the promise of food irradiation can do little to nothing to alleviate.
The Institute also notes that post-harvest grain storage occurs because of poor storage facilities directly traceable to local poverty. Actions based on the hypothesized need to apply high technology to augment food production actually tend to widen the gap between rich and poor, since only well-off farmers can afford access to these new technologies. The result is that high technologies never reach the truly poor.
America"s primary role in the world food trade is not to feed the hungry but to sell to the rich.... Less than 30% of our agricultural exports go to what USDA terms the "less developed countries." Our Food Power strategy...rests not on shipping our food to a world of hungry people, but on molding the tastes and habits of a certain class of people to make them dependent on products and styles that they had never wanted before. (F.M. Lappe and J.Collins, Food First, 1978)
Over eleven year of research on food issues has led us to oppose food irradiation; any argument that increasing production is necessary is deceiving the public; poverty, not technology, is the problem. (Kevin Danaher, Ph.D., Issues Analyst, Institute for Food and Development Policy, personal communication, March 3, 1987.)
These arguments concerning the impacts abroad of food irradiation have another, equally serious, side for the U.S. Agricultural economy. American farmers may be endangered by the uses outside the United States of food irradiation technology in ways which may undercut already precarious food producers in this country. Field applications of poorly regulated mobile irradiators, or port of exit or entry centralized facilities could encourage the importation of produce from abroad that would price American farmers out of business. For retail grocers, too, the arguments in favor of extending shelf life may cut the other way in the low-margin food retailing business; the longer the shelf life the slower the turnover of inventory. Specialty grocers whose business depends on high-quality produce suggest concerns about consumer rejection. (Testimonies before New York City Council, Hearings on Food Irradiation, May, 1986.)
Unquestionably, world hunger is now and will be in the future among the planet"s most serious problems. Starvation is real. It is, however, a consequence of conditions and situations that will not be alleviated by the commercialization of food irradiation here or abroad. We can only conclude that introduction of food irradiation technology is likely to worsen conditions of hunger and to promote greater dislocations in domestic agriculture.
FDA Testing and Approval Procedures
Contrary to statements in the Public Strategies memo, the FDA, in issuing its Final Rule on food irradiation, did not utilize the testing and approval procedures that it normally requires for food additives and other processes. FDA explicitly waived the customarily required proof of safety; ignored altogether the adverse physiological effects found in animal tests; failed to consider the extensive existing literature on the subject; and approved food irradiation based upon abstract radiation chemistry formulas, subjective criteria, and unfounded assumptions. In effect, FDA refused to require either confirmation or refutation of existing data that demonstrated adverse effects. The five studies favorable to food irradiation on which FDA relied, out of several hundred initially reviewed, appear to be seriously flawed. Dr, Donald B. Louria, Chairman of Preventive Medicine and Community Health at the New Jersey University of Medicine and Dentistry, has commented:
I looked in detail at three of those [five] studies. The one from Germany seems adequate, but the other two raise considerable questions. In one, the irradiated food was obtained from some other group and we are never actually given any data to show that the food was irradiated properly or even irradiated at all. Additionally, the authors note an increase in abnormality in dogs at autopsy and then seem to feel that the abnormalities they found were meaningless and should be ignored. In the other study from England, in the group receiving the food irradiated most, there were increased deaths in the offspring and this is completely ignored even though the authors say there is no explanation for it. ....For the FDA to selectively choose the five [studies], is, I believe, improper for deciding safety. (Donald B. Louria, M.D., Chairman, Department of Preventive Medicine and Community Health, University of Medicine and Dentistry of New Jersey, letter to Assemblyman John Kelly, February 13, 1987.)
Dr. Louria raises, in addition, the issue of the FDA"s decision not to require labeling of processed or multi-ingredient foods, in which one or more ingredients may be irradiated. No label is required for such foods, nor are restaurant foods or other institutional prepared foods required to be labeled.
As for fresh fruits and vegetables, single component produce (e.g. an apple or artichoke) is required to bear a label or be displayed in labeled containers that are stamped with a symbol called a "radura." The FDA regulations do not make clear if each individual item must be labeled, or only the packing case or display container.
One purpose of the label is to notify the consumer that a food has been subjected to radiation. A second purpose is to decrease the likelihood that a food will be exposed to radiation repeatedly in the distribution system. The USDA Food Safety and Inspection Service states that "At the present time there is no analytical method available for detecting whether a food has been irradiated." (51 Federal Register 43874, December 5, 1986. Emphasis added.)
These labels must also display a written warning, such as "This product has been treated with radiation." However, the written notification is required only for 24 months from the date of FDA approval, viz., April 18, 1986. By the time that irradiated foods begin to appear in large quantities in supermarkets, after April 18, 1988, only the radura, resembling a stylized flower, will be a required symbol to indicate that a food has been irradiated.
The "desire of the irradiation proponents not to label" [irradiated] foods puzzles Dr. Louria; he concludes, "That, alone, is reason to reject irradiated foods in the State of New Jersey."
In this lengthy review of the Public Strategies February 5, 1987, letter and memo in support of food irradiation, Food and Water, Inc., has tried to highlight and document both the scientific research findings and the unresolved questions about food irradiation in order to assist decision-makers in understanding this important topic of public policy. The literature is extensive; the staff of Food and Water will be pleased to provide additional information and citations upon request.
We are aware that affected corporations and, sad to say, some scientists have portrayed food irradiation and related issues, such as radiation effects, radioactive waste, and other nuclear industry connections, in a favorable manner, with little regard for matters of public and worker health and safety. The memo which is the subject of this document contains no references or citations of source material, expert studies, or valid data to substantiate extravagant claims for this radiation technology. In view of those omissions, we suggest that is would be folly to give credence to the opinions and demands on behalf of food irradiation contained in the Public Strategies memo.
The issue of health and safety, now and in the future, is the paramount consideration, and the health and safety of the citizens of New Jersey deserve more than self-promoting opinions of those who would profit from the expansion of this dangerous technology. In our opinion, on the other hand, the jury is still out as far as the safety of food irradiation is concerned. The scientific juries, however, are increasingly returning a verdict on the effects of ionizing radiation on human health: the carcinogenic, mutagenic, and teratogenic consequences of exposure to ionizing radiation are more severe than we had believed in the past. Prudence and sound public health policy therefore dictate that food irradiation technology be foregone unless and until there is irrefutable evidence that it is safe, necessary, and beneficial.
This document is respectfully submitted by the staff of Food and Water, Inc., a not-for-profit public educational and service organization.