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Action alert: Tell USDA not to allow irradiation for imported fruits & vegetables

July 21, 2000

DEADLINE EXTENDED! Comments on this proposal are due before August 9th. Go to short comment letter.

Summary: On May 26, the USDA's Animal and Plant Health Inspection Service (APHIS) announced a proposal to allow irradiation on nonorganic, imported fruits and vegetables that are carriers of 11 species of fruit flies and the mango seed weevil. Irradiation could be used instead of or in addition to currently approved disinfestation treatments. Irradiation could be used in the U.S. or abroad. Examples of foods that might be irradiated: Australian grapes, Mexican oranges and grapefruits, Spanish tomatoes. Fragile, life-giving fresh foods could be blasted with up to 1 kGray of energy, about 1.5 million chest x-rays from electron guns or nuclear gamma rays. See the complete APHIS proposal. Download our detailed letter to APHIS in RTF.

Why they want to irradiate (1): Multinational corporations want to move food production out of the U.S because labor is cheaper and environmental laws are more lax in the developing countries where this food is grown. Fully 1/3 of our fruits and veggies are imported, and if irradiation is widely used, the amount will increase, damaging our own farm economy. Unlike existing disinfestation treatments, irradiation increases the shelf/storage/shipping 'life' of fruits and vegetables by up to several weeks. Irradiation will make long-distance transport of imported foods much less risky for the growers and shippers.

Why they want to irradiate (2): Fruit and vegetable producers see irradiation as the solution to government-mandated elimination of methyl bromide, a widely used chemical that damages the ozone. But other alternatives are already successfully in use, as the USDA admits. Depending on the food to be treated, they may include: 1. Prevention by keeping facilities clean and culling out infested fruits and vegetables; 2) Heat treatments; 3) Cold treatments; 4) High-pressure water; 5) Controlling the atmospheres of shipping containers; 6) Treatment with other chemicals. But if irradiation is permitted, it will be very widely used instead of these other treatments.

This could be the beginning of the end of fresh fruits and vegetables in the U.S.A.

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What you can do:

Send original and 3 copies of your letter to arrive before August 9, 2000. If you are a grower or retailer, please discuss the value of existing treatments. Here's the e-mail address.

Cut and paste this sample letter, or see http://www.citizen.org/cmep/alerts/USDAAlert.htm

Date:

Docket No. 98-030-1
Regulatory Analysis & Development, PPD
APHIS, Suite 3C03
4700 River Road, Unit 118
Riverdale, MD 20737-1238

RE: Docket No. 98-030-1

Dear USDA-APHIS:

As a consumer, I am writing to comment on the proposal to allow the use of irradiation to kill fruit flies and the mango weevil present on some imported fruits and vegetables.

I do not want to consume fruits and vegetables blasted with the energy equivalent of up to 1.5 million x-rays. Irradiation creates free radicals, depletes vitamins and damages the living enzymes in raw foods that are essential to good nutrition. If the APHIS proposal is accepted, the imported one-third of American fruits and vegetables could potentially be irradiated, in addition to domestically produced foods.

The APHIS proposal states that “with regard to phytosanitary irradiation treatments to control plant pests, the World Health Organization, the International Plant Protection Convention, and the North American Plant Protection Organization have endorsed the technology as effective and safe.” However, the proposal does not discuss the regulatory basis for assuming that there are no human health effects when a large proportion of foods in the diet may be irradiated. The proposal, therefore, relies on the FDA approval of
the safety of irradiated fruits and vegetables.

The FDA approved irradiation for fruits and vegetables based on a theoretical calculation of the number of Unique Radiolytic Products (URPs) that would be caused by irradiation. An independent analysis of the FDA's calculation found that if only 1 in 1000 URPs is assimilated from the intestine to the liver, and if only 1 in 10,000 of these is cardinogenic or mutagenic, then for every 7.5 oz. meal (2 small pieces of fruit), over 2,500 potentially carcinogenic or mutagenic cells will threaten each liver cell. Eventually the liver's ability to ward off these threats will weaken, and the result will be liver damage or cancer. The FDA's approval is scientifically inadequate to allow irradiation of any fruits and vegetables.

The APHIS proposal provides no good rationale for employing irradiation instead of currently approved treatments. According to the proposal, the only imported commodity that will be seriously affected by the phase-out of methyl bromide is grapes, which however happen to be sensitive to irradiation. Nevertheless, if irradiation is approved it will be much more widely used instead of other, less 'traumatic' treatments. I do not see the value to the consumer of providing more imported fresh fruits and vegetables if the cost is damaged vitamins and enzymes. Irradiation produces an inferior product that defrauds customers who buy fresh foods in order to enjoy the health benefits of fresh, raw foods.

Sincerely,

Your name and address