Updated October 31, 2002 BACKGROUND and STATUS OF LABELING OF IRRADIATED FOODS Which foods can be irradiated? What labels are currently required? NEW: Codex (world trade) requirements Political background and history of labeling What labeling does OCA recommend? What can you do to preserve labeling? and Contact us A brochure written by the FDA implies that ALL irradiated food is currently labeled and therefore the consumer is always informed. NOT TRUE! See our rebuttal. Which foods can be irradiated in the U.S. The United States Food and Drug Administration (FDA) has two functions, evaluation of scientific evidence and regulation of certain foods. 1) It has the primary responsibility of deciding if a new process like food irradiation can be used on foods. The FDA also sets the minimum labeling standard for all irradiated foods. 2) The FDA regulates all foods except meat, poultry and seafood. The FDA has approved the following foods for irradiation: 1986: spices, herbs, herb teas, pork, wheat, wheat flour, fruits and vegetables 1992: poultry 1997: beef 2000: eggs in the shell, seeds for sprouting (like alfalfa) The USDA has approved the following foods for irradiation: 1999: Refrigerated or frozen raw beef, pork, lamb, and poultry. 2002: Imported fruits and vegetables 2002: Meat purchased by the National School Lunch Program In August 1999, a food-industry coalition asked the FDA to allow irradiation of seeds, sprouts, fresh juices, frozen foods, prepared fresh fruits and vegetables, and luncheon meats. The FDA has not yet decided. Organic foods cannot be irradiated. What kind of labeling is currently required top All irradiated foods must be labeled using the radura and some wording, but only to the FIRST PURCHASER, who is often NOT the consumer. Consumers should be able to see the wording and radura on: Plant foods sold in their whole form in a package (e.g., a bag of wheat flour or oranges). Fresh whole fruits and vegetables. (on the fruit, the box or a display) Whole meat and poultry in a package (like chicken breasts). Unpackaged meat and poultry (like from a butcher) (display label). Irradiated meat and poultry that are part of another packaged food (like irradiated chicken in a frozen chicken potpie). Consumers will NOT see the wording or radura* for: Irradiated ingredients in foods prepared or served by restaurants, salad bars, hotels, airlines, hospitals, schools, nursing homes, etc. Irradiated foods prepared by delis or supermarket take-out counters. Spices and herb teas Sprouts grown from irradiated seeds Ingredients in supplements Plant-food ingredients that are processed again (like apples in applesauce or papaya in a salad-bar salad). *Labels are required from the irradiation facility to the first purchaser, such as the supplement manufacturer, the hospital kitchen, the restaurant that makes the salad. When labeling is required at the consumer level: There must be wording, either "treated with radiation" or "treated by irradiation". For packaged foods, the wording does not need to be bigger than the smallest type on the ingredient label, or in any special colors or typeface. For bulk fruits or vegetables, the words must appear on a card or display (or on each piece of food), but no size is specified and there is no enforcement. In Summer 2002, Congress created a loophole long sought by the meat and poultry industries. Companies that wish to use a term not approved by the FDA like "electronically pasteurized" on their labels can go over the FDA's head and petition the Secretary of Health and Human Services. The Secretary can then allow them to use the term. The USDA consumer labeling requirements for for meat and poultry are the same as the FDA requirements, with the following differnces: Multi-ingredient products that include an irradiated meat product must reflect its inclusion in the ingredient statement on the finished product’s label. This is the major difference from the FDA's requirements for processed nonmeat products, which do not have to be labeled to the consumer at all. Packaged meat products irradiated in their entirety must either include the word "irradiated" as part of the product name (this option is not allowed for plant foods) or must bear a statement such as "Treated with radiation" or "Treated by irradiation." Unpackaged meat products irradiated in their entirety are required to have the radura symbol and a statement "prominently and conspicuously" displayed to purchasers either through labeling on a bulk container or "some other appropriate device." The USDA does not define what this "other appropriate device" could be. The USDA allows claims regarding the "beneficial effects" and the purpose of irradiation (like "treated to kill Salmonella"). The FDA does not allow these claims for the foods it regulates. Codex Requirements top The Codex Alimentarius is the international standard for world trade in food. What it says is important, because a country that requires different labels from the Codex requirements cannot keep out food from other countries that is labeled according to Codex requirements. At this time, the FDA-required irradiation policy does NOT match Codex requirements, which are stronger. If the US stops requiring labels, under world trade rules other countries will not be able to exclude unlabeled US imports--because the other country's labeling policy is an "import barrier." Therefore, there will be a conflict between the US FDA policy of unlabeled exports, and the Codex requirements. It just so happens that the Chairman of Codex is Tom Billy, the man at the USDA in charge of deregulating the meat industry and introducing irradiation. So put your money on the Codex LOWERING its labeling requirements to match whatever final labeling policy the FDA comes up with in 2001-2. See why the FDA labeling policy is so important? In the following three ways, Codex requirements differs from current USDA and FDA regulations: For Codex: A text statement is required and the use of the radura is optional. When an irradiated product is used as an ingredient in another food, this shall be so declared in the list of ingredients. When a single ingredient product is prepared from a raw material which has been irradiated, the label of the product shall contain a statement indicating the treatment. OCA's recommendation for labeling: Permanent labeling (no expiration) Prominent labeling that is readable to all consumers Retain mandatory use of the radura No misleading terminology Labels that reflect the vitamin loss in "fresh" foods caused by irradiation Political background and history of labeling top The following excerpt is from the book "Food Irradiation: Who Needs It?" The idea of irradiating food is not new. We have had nearly 70 years of experimentation with it. The treatment was tested on strawberries in Sweden in 1916. The first patents on the idea were taken out in the United States in 1921, and in France in 1930. Little progress was made, however, until 1953, when President Eisenhower announced the "Atoms for Peace Program". Public attention was to be shifted away from nuclear weapons by the promotion of nuclear power and other uses of nuclear technology, so that the academic and industrial infrastructure could be developed behind which the weapons program would continue. There followed a decade of intensive research into food irradiation, funded and supervised by the United States Department of Defense. …The United States Food, Drug, and Cosmetics Act of 1958 defined the irradiation process as an additive. Users have to petition the Food and Drug Administration for permission to market irradiated products. This has resulted in stringent requirements for testing of irradiated foods in the United States. Not until 1963 was clearance given for sterilization of can-packed bacon and the inhibition of potato sprouting and wheat disinfestation already in use elsewhere. The FDA, however, rescinded the bacon approval in 1968, citing possible health problems with the test animals and deficiencies in the way some experiments were designed and conducted." In the 1980's, the U.S. Department of Defense saw irradiation as a way to privatize nuclear materials. At the same time, deregulation of the meat and poultry industry resulted in outbreaks of food poisoning and product recalls. The 'status quo' method of food production was simply becoming too expensive. Irradiation provided a means to 'clean up' the product of high-speed slaughter and decreased meat and poultry inspection. In November 1997, Congress passed the FDA Modernization Act. Hidden in this large bill were two provisions concerning irradiated foods. The first provision told the FDA (which Congress oversees) that the labels required for packaged irradiated foods did not need to be any larger than the typeface on the ingredient label. The second told the FDA to revise the current labeling requirement, because labels were scaring consumers from buying irradiated foods. The Congressmen responsible for pushing the labeling change are these friends of the factory farming industry: Senator Mitch McConnell (R-KY), Representative Greg Ganske (R-IA), Senator James Jeffords (R-VT) and Senator Tom Harkin (D-IA), a vocal advocate of irradiation. In February 1999, the FDA submitted its Advanced Notice of Proposed Rulemaking for the first round of public comments. It asked for surveys to find out if labels scare people and for suggestions on how to write a label so it doesn't cause consumers "inappropriate anxiety." The original deadline of May 1999 was extended to July 1999 after a public outcry. The FDA received a total of approximately 10,000 comments addressing the labeling issue and 19,000 petition signatures opposing food irradiation. Over 99% were in favor of continued labeling and consumer right-to-know. Many people expressed outrage at the condescending language used by Congress to describe their opposition to this technology. On February 22, 2000, the USDA allowed meat producers to begin selling/ shipping irradiated products. A number of beef and chicken packers have begun planning to sell irradiated products, primarily to food service, and the roll-out began in late spring and summer 2000. What you can do to preserve labelingtop Sign up to be contacted when the FDA issues its comprehensive policy on labeling of irradiated foods. We will be organizing public comments to the FDA. Participate in Action Alerts on irradiation. Check our site regularly. When a news story about irradiation, meat recalls or food contamination appears, write a letter to the editor stating that you want permanent, prominent labeling with current terminology only for all irradiated foods. Write a letter to your members of Congress stating that you want them to sponsor or support a bill to require a higher standard of labeling than the current FDA standard. That is, permanent, prominent labeling using current terminology for all irradiated foods, with no possibility of expiration. Pass out literature at farmers markets, health fairs, etc. about irradiation. The food industry is very sensitive to consumer pressure. Download flyers from this site or Public Citizen.