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Subject: Excerpts from : FOOD IRRADIATION - Who Wants It?
TL: FOOD IRRADIATION, WHO WANTS IT
Source: Thorsons Publishers, Inc.
Rochester, Vermont
Wellingborough, Northamptonshire
Date: 1987
NOTE: to find each section in order, search for []
 
[] A Brief History of Food Irradiation
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. (1,2)
The first commercial use of food irradiation actually occurred
in West Germany in 1957, for the sterilization of spices used in
the manufacture of sausage. This was brought to an abrupt end
when the German government banned the process in 1958. The
Soviet Union was the first government to permit irradiation, for
inhibiting the sprouting of potatoes in 1958, and for
disinfestation of grain in 1959. Canada permitted its use for
potatoes in 1960. 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FDA, however, rescinded the bacon approval in 1968, citing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. (3) A
list of regulatory permits in the United States is given in
Table 1. (Omitted here.)
About 30 countries have permitted irradiation of 28 different
foods for public consumption (Table 2). (Omitted here.)
Commercial activities were planned in a further 11 countries as
of January 1985. (4)
There are some notable exceptions. Britain, West Germany, and
most of the Scandinavian countries currently do not permit
irradiation of food for public consumption. (5) So far, in
Britain, permission has been given only for animal feed, and for
irradiation of food for hospital patients needing sterile diets.
This may soon change as a result of the report of the British
government's Advisory Committee on Irradiated and Novel Foods,
(6) and with the growing pressures for harmonization of national
legislation within the countries of the European Economic
Community. (7)
Although several countries have given permits for food
irradiation, there has been little use of the technology.
Eighteen countries actually engage in irradiation, but the scale
of its use is still very small. As well as worries about
consumer reactions, the mixture of protective and permissive
national regulations clearly acts as a barrier to inter-
national trade in irradiated food products, which food
manufacturers would like to see removed.
The International Atomic Energy Agency (IAEA), the World
Health Organization (WHO), and the Food and Agriculture
Organization (FAO) of the United Nations have collaborated on a
joint initiative to research and promote food irradiation since
the early 1960s. These organizations have funded an
international Food Irradiation Research Project at Karlsruhe in
West Germany since 1970, and a joint IAEA/WHO/FAO committee
produced key reports in 1976 (8) and 1980 (9) on the
wholesomeness of irradiated foods. At the same time, the Codex
Alimentarius Committee of the United Nations (UN) has
formulated International Guidelines on irradiated foods based on
the recommendations of this joint committee. (10) It has
recommended that there are no special safety reasons why food
should not be irradiated up to a dose of 1 million rad (10 kGy).
So far, the United States Food and Drug Administration has
recommended that general irradiation be permitted only up to the
lower dose of 100,000 rad (1 kgy) - one tenth of the Codex
level. The exception to this is spices, which are to be
permitted doses up to 3 million rad (30 kGy). (11,12) The USDA,
which has control of the regulation of standards for processing
of meats, particularly poultry and pork, has been slightly more
restrictive, particularly over the use of vacuum packaging of
meats, for reasons we will discuss later.
On the other hand, irradiation companies have been promoting the
technology aggressively in the United States, and the Department
of Energy (DOE) is preparing to finance demonstration
irradiation plants and provide access to cheap sources of
radioactive material as part of its nuclear waste management
program.
Meanwhile, a coalition of interests has begun to emerge as
opponents of food irradiation, not just in the United States but
in Australia, New Zealand, Malaysia, Japan, and throughout
Europe and Scandinavia. It has clearly become an issue of
national and international concern, one where the facts on which
to base responsible decisions are needed to counteract
misinformation and unreasoned opinion, on both sides. If and
when irradiation takes its place beside other appropriate food
processing technologies, we need to be assured that we are
having only its real benefits and none of the unnecessary risks
that come from over-hasty decision making at the behest of
hidden interests.
 
 
REFERENCES
1. Edward S. Josephson and Martin S. Peterson, eds.
Radiation (2 vols.). Florida: CRC Press, Vol.1 1982, Vols. 2 &
3 1983
2. P. S. Elias and A. J. Cohen. Recent Advances in Food
Irradiation. Amsterdam and New York: Elsevier Biomedical
Press, 1983.
3. US Government Accounting Office. The Department of the
Army's Food Irradiation Program - Is It Worth Continuing?
PSAD-78-146 (September 29, 1978), pp. 6, 14; Spiher. "Food
Irradiation: An FDA Report." FDA Papers (October 1968), p.
15.
4. US Agency for International Development. Draft
Feasibility Study. Washington, DC, May 1985.
5. See Answer to Written Question No. 1398/81 by Mr. Narjes
on 25 November 1982 to Mr. Schmid, and also Answer to
Mrs. Hanna Walz, Question 1618/83, given 7 February 1984
in the European Parliament, Brussels.
6. The Safely and Wholesomeness of Irradiated Foods. Report
of the Advisory Committee on Irradiated and Novel Foods.
London: HMSO, 1986.
7. Lord Cockfield's Memorandum: Completion of the Internal
Market, COM [85] 310; and Community Legislation on
Foodstuffs, COM [851 603. European Commission, Brussels,
1985.
8. World Health Organization. Wholesomeness of Irradiated
Food. Report of joint FAO/IAEA/WHO Expert Committee. WHO
Technical Report Series No. 604, Geneva, 1977.
9. World Health Organization. Wholesomeness of Irradiated
Food Report of joint FAO/IAEA/WHO Expert Committee. WHO
Technical Report Series No. 659, Geneva, 1981.
10. Codex Alimentarius Commission. FAO/WHO, Reports of the
Executive Committee of the Codex Alimentarius Commission.
United Nations, Rome, 1978, 1981.
11. Department of Health and Human Services. Food and Drug
Administration 21 CFR Part 179, Irradiation in the
Production, Processing and Handling of Food; Final Rule.
51 Federal Register 13376 at 13385, Washington D.C.,
April 18, 1986.
12. Tony Webb and Tim Lang. Food Irradiation. The Facts.
London: Thorsons, 1987.
 
 
[] WHAT IS FOOD IRRADIATION?
VERY SIMPLY, FOOD irradiation is a treatment involving very
large doses of ionizing radiation to produce some desired
changes in food, particularly those allowing longer storage, or
shelf life. This section covers the nature of radiation and what
it does, the types of irradiation plants, radioactive sources
used, the doses involved, and the question on everyone's mind:
can food become radioactive?
Ionizing Radiation
Radiation is a household word that covers a wide spectrum of
energy. At the low end of the spectrum are the emissions from
power lines and visual display units. Higher up are radiowaves
and microwaves. Also included are infrared, visible, and
ultraviolet light, and at the upper end are found x-rays, and
gamma rays from radioactive material.
When radiation strikes other material it transfers its energy.
This energy transfer can cause heating, as with microwave
cooking or lying in the sunshine. At a certain level the
radiation has sufficient energy to knock electrons out of the
atoms of the material bombarded. This can break the molecular
structure of the material, leaving positively and negatively
charged particles called ions or free radicals. At or above this
level the radiation is called ionizing radiation. (1) The ions
are chemically very active and easily recombine or initiate
chemical reactions with surrounding material.
Thus, ionizing radiation alters the chemical structure of
material, which in turn can have biological effects on the
behavior of living organisms and the materials they feed on. (2)
Some of the biological effects in the irradiation of food can be
considered desirable. Irradiation of living organisms,
especially people, is almost always damaging. (3 4,5)
Food Irradiation Plants
In general, an irradiation plant consists of the following
facilities:
1. A loading facility, where the food to be irradiated is
packaged and pretreated by heating and/or refrigeration as
needed and loaded onto conveyors that carry it to
2. The irradiation cell, where food is exposed to the
radiation source. This can be either a cobalt or cesium gamma
ray source, or an x-ray or electron beam machine source. The
distance the food passes from the source and the length of time
it is exposed determine the dose that the food receives. The
size of the batch controls the extent to which the food is
uniformly exposed or has large differences between maximum and
minimum doses to different parts of the food batch. Thick
concrete shielding protects workers from direct exposure to the
source. It then passes into
3. A storage facility, where i is removed from the conveyor and
stored at the required (usually low) temperatures before being
sent to long-term storage or retailing outlets.
In addition, the plant needs the following facilities:
1. A fuel handling unit, where irradiated radioactive sources in
the form of sealed rods or strips of cobalt 60 or cesium 137 are
received and loaded by remote handling into the irradiator. They
are usually stored under water, or in some instances in dry gas
storage, and raised from them into the irradiation cell to
expose the food.
2. A control unit, which governs the movement of the food (and
the radioactive, sources) through the irradiator.

3. There are also facilities for monitoring doses to the food
and keeping records.
The design of the irradiation cell, the siting of the
radioactive sources, and the path of the food through the cell
depends on the type of food being irradiated. The aim is to
achieve as small a difference as possible between the outside
and the centre of the bulk food package. In practice, however,
these differences can be quite large unless the thickness of the
bulk package is small.
Some foods such as fish may pass along a tube or between two
parallel sources. The Atomic Energy Commission had a
demonstration low-level irradiator for use on board ships, but
the prototype took up too much space and was moved to a dock
instead. If this idea is revived, the plan is to lightly
irradiate fish at sea and then further irradiate them when they
come ashore.
Other facilities may use a simple conveyor belt to carry food
past either a gamma ray or a machine source of radiation. The
French have designs for a small-scale field irradiator for
potatoes. There are plans for a mobile irradiator to be mounted
on a 40-foot truck. 96)
There are currently around 50 planned or operating irradiation
facilities worldwide that are licensed to irradiate food, (6,7)
17 of which are currently operating in the United States (Table
3). (8,9) The major company involved is Isomedix, with seven
plants and plans for three more. The Department of Energy
proposes to build six demonstration irradiators in Hawaii,
Washington, Alaska, Iowa, Oklahoma, and Florida.
In Europe, the main facilities are the Gammaster plant at Ede,
The Netherlands, and the IRE plant at Fleurus, Belgium. Tables
4 and 5 indicate the other countries which have irradiation
plants capable of irradiating food. (6) The Soviet Union is
currently the largest user of irradiation, almost exclusively
for grain.
Although irradiation of food is still illegal in Britain, ten
plants in Britain currently irradiate medical supplies or animal
feed. Of these, only four, all owned by Isotron plc, will be
able to handle commercial food irradiation. One other may be
able to do so, and privatization of some hospital facilities may
open possibilities for others on a small scale. (10,11)
A list of known gamma irradiation facilities in the United
States is given in Appendix 1. (9) Several of those currently
irradiating medical supplies may also be capable of irradiating
food.
Radioactive Food?
The first concern of most people is whether or not food
becomes radioactive. Ionizing radiation with high energy can
cause radio- activity to be created in the material that is
bombarded. (1,3,5) The energy level is usually expressed in
electron volts (eV). Above approximately 10 to 15 million
electron volts (MeV), it is possible for significant amounts of
radioactivity to be created. It is, therefore, important that
only lower-energy ionizing radiations are used in irradiation of
food.
Even so, it is still possible for some compounds in the food to
be made radioactive. Below the 10-MeV level, however, the amount
of this induced radioactivity is small, and it decays very
rapidly. If foods are stored before use, the level of radiation
is likely to be insignificant and well within the range of the
natural radioactivity already found in food. (12)
The other way food may become contaminated with radioactivity is
if the radioactive source is damaged. Obviously, great care
should be taken to prevent this kind of accident. Thus, provided
irradiation is properly controlled, food should not become
measurably radioactive.
Radioactive Sources for Food Irradiation
It has been suggested that the nuclear wastes from power
stations be used as a radioactive source for food irradiation.
(13) This is not immediately feasible because these wastes
contain a wide range of radioactive materials, some emitting
radiation with energy above the critical level. (12)
Two radioactive materials have been identified that are suitable
and have energies considered low enough to be safe for use in
food irradiation: cobalt 60 and cesium 137.
Cobalt 60 gives off two gamma rays of 1.17 and 1.33 MA, and
cesium 137 gives off 0.66 MeV gamma radiation. A mixture of
cesium 137 and cesium 134 can also be used. Radiation from these
radioactive isotopes is well below the 10-MeV threshold, and
after storage there should be no measurable levels of induced
radioactivity.
Disposal of radioactive cesium currently presents a considerable
problem because of the quantities produced in nuclear wastes
from reactors and the length of time they take to decay. The
nuclear energy and weapons industries are therefore eager to
find commercial uses for cesium. On the other hand, the
viability of using this source depends on the continuing
existence of the nuclear power program. (13)
Cesium in particular presents some storage problems because it
is used in a water-soluble form and hence can cause greater
environmental contamination in the event of any break in the
tube in which it is sealed. Because its energy level is only
about half that of cobalt, considerably more cesium is needed to
give the same exposure to the food, and the ratio of maximum
dose (on the outside) to minimum dose (in the middle of the
food) is much greater.
The other possible sources of irradiation include beams of
electrons and x-rays created when a metal target is bombarded
with electrons. These machine sources give off a wide spectrum
of energies, and greater care must be taken to ensure that the
maximum energy is below the 10-MeV threshold. Electrons do not
penetrate materials as far as gamma or x-rays do, and so are
only useful for irradiating the surface of foods. (12)
Radiation Doses
Dose is commonly used to mean either of two distinct things: the
amount of radiation received or, in the case of exposure to
people, the amount of biological damage done. In measuring the
dose to food we are concerned about the amount of energy that
has been deposited as a result of irradiation. The old unit for
dose was the rad; this is now being replaced by the gray (Gy).
Very large doses up to 1 million rads are being considered for
food irradiation. Therefore, the doses are more often given in
megarads (Mrad) or kiloGrays (kGy), a million rad (1 Mrad) = 10
kGy (10,000 Gray).
To give some idea of the scale of these doses, the making of a
chest x-ray film will deliver about 10 millirad (0.01 rad), and
an average dose from natural background radiation will give
about 100 millirad (0.1 rad) per year. The food irradiation dose
is therefore 10 million to 100 million times these common doses.
The changes produced in the food increase as the dose goes up.
This applies to both the desired and the undesirable changes.
(12,14)
Uses of Food Irradiation
As was just explained, radiation produces chemical changes in
the food, and these in turn have biological effects. In some
cases the exact mechanisms are still not fully understood. The
following effects can be produced:
Radurization: low doses, usually below 100,000 rad (1 kGy)
Sprouting of vegetables such as potatoes and onions can be
inhibited so that they keep longer (5,000 to 15,000 rad: 0.05 to
0.15 kGy).
Ripening of some fruits can be delayed so that they keep
longer and can be transported longer distances (20,000 to 50,000
rad: 0.2 to 0.5 kGy).
Insects in grains such as wheat and rice, or in spices and some
fruits, can be rendered sterile. This may replace current
methods involving gas storage or fumigation treatments for
insect disinfestation that are hazardous to workers, and could
reduce losses of foods.

Radicidation: medium doses, between 0.1 and 1.0 Mrad (1-10 kGy)
Killing insects and other food parasites can involve higher
doses than those that merely keep them from breeding in the food
(30,000 to 600,000 rad: 0.3 to 6.0 kGy) and will not, of course,
remove the dead parasites from the food.
The number of microorganisms that lead to food spoiling, such as
yeasts, molds, and bacteria can be reduced, and the life of
foods can thereby be extended or the risk of food poisoning
reduced. This may be important in the case of salmonella in
chicken or fish.
Rappertizatzion: high doses, above 1 Mrad (10 kGy)
At extremely large doses, higher in fact than the 1 million rad
(10 kGy) doses being proposed at present, food can be completely
sterilized by the killing of all bacteria and
viruses. This process might be used for meat products,
allowing them to be kept indefinitely. (12)
These doses are only approximate. The actual dose depends on the
thickness and density of the food package being irradiated as
well as the desired effect. For bulk spices, doses of up to 3
million rads (30 kGy) can be used to kill insects and
contaminating bacteria. (15) These effects can be said to extend
the shelf life of foods - the time it takes before stored food
becomes unsaleable. In these cases, irradiation is used as a
preservative.
Improvement of Food by Irradiation
In addition to the food preservation benefits claimed for
irradiation, a number of other "improvements" in quality have
been claimed. (16) One is the improvement of baking and cooking
quality of wheat, including the ability to add up to 15% soy
flour to wheat flour without loss of baking quality. Irradiation
also "improves" the elasticity and volume of dough in bread
making. A number of' additives are currently used to increase
the bulk and the water and air content of the standard white
loaf. Yeast can be stimulated by irradiation, leading to faster
bread-making. (14) While this has obvious benefits to the large
baking companies, it is a matter of opinion whether it leads to
an improvement in bread quality. (17,18)
Irradiated barley can increase its yield during malting by 7% -a
fact of interest to the brewing industry. Irradiation can be
used to "age" spirits, (19) and irradiated grapes yield more
juice when processed, possibly benefiting the fruit juice, wine-
making, and distillery industries. Irradiated sugar solutions
can be used as antioxidants, possibly replacing other chemicals
used for this purpose in processed and prepared foods.
The time needed to reconstitute and cook dehydrated vegetables
including peas and green beans, is reduced if they are
irradiated. Since cooking times for dehydrated foods are already
very short, it is debatable whether this provides any real
benefit.
It is claimed that irradiation enhances the flavor of carrots.
and the suggestion has been made that it could be used for
tenderizing meat. (12)
It has been suggested that contaminated or spoiled food can be
sterilized by irradiation and so made safe for human
consumption. However, the joint expert committee of the
WHO/FAO/IAEA has explicitly said that irradiation should not be
used to make an unsuitable product saleable for human
consumption and that food should always be wholesome before
irradiation. There are, however, some who argue that this should
be considered. (20) As we will show in Chapter 5, some cases of
irradiation being used to conceal contamination have been
documented. (21)
Most of the basic mechanisms of these "favorable" changes in
food quality are not fully understood. (2,12,14) On balance,
most of the uses just described are not necessities. They are
either luxuries or techniques that may benefit the manufacturer
but provide no clear benefit to the consumer.
Other non-food, but food-related, uses include modification of
starches for the paper and textile industries, and radurization
of gelatin for use in the photofilm industry.
Thus we find irradiation to be a potentially dangerous
technology with its own needs for regulation and control, but
one that is already in use on a small scale in several
countries. It would appear to have some beneficial applications
- certainly to food processors and possibly food retail sales
outlets. If irradiation is properly controlled, food should not
be made any more radioactive than it already is. If these were
the only issues, there would seem to be little reason to be
concerned beyond ensuring that the process is properly regulated
and controlled. Unfortunately, as we shall see, there are other
issues that give us grave cause for concern.
 
 
REFERENCES (omitted here - unscannable)
 
 
[] IS FOOD IRRADIATION SAFE?
THE JOINT EXPERT Committee of the International Atomic Energy
Agency, the World Health Organization, and the Food and
Agriculture Organization of the United Nations says that food
irradiation is safe. (1) In Britain the Advisory Committee on
Irradiated and Novel Foods says it is safe. (2) The European
Economic Community's Scientific Committee for Food and experts
from the food and irradiation industries say it is safe. (4.5.6)
Who are we to say it is not?
The answer to that question is to pose another. Are we being
asked to take the word of experts, or is there conclusive
evidence, backed up by scientific research that can be referred
to and checked by independent researchers?
Some of those who have been lobbying for irradiation have
suggested that 40 years of research show there are no safety
problems whatsoever. (7) This is untrue. Ignoring or discounting
evidence and studies that suggest damage from irradiated foods
does not make this evidence go away. The first research done by
the United States Army was used to obtain clearance for
can-packed bacon in 1963, but clearance was subsequently
withdrawn in 1968 when the Food and Drug Administration (FDA)
found the research to be flawed. The FDA found that significant
adverse effects were produced in animals fed irradiated food and
that major deficiencies existed in the conduct of some
experiments. The adverse effects included decreases in survival
of weaned young for animals fed irradiated bacon and greater
losses of young for those eating bacon exposed to higher doses
of radiation. (8)
This same 40 years of research presumably also includes the
subsequent research done in the United States when the work was
turned over to Industrial Biotest Limited (IBT). Three officials
of IBT were convicted in the federal courts in 1983 for doing
fraudulent research for government and industry. (8) The
government uncovered such problems as failure to conduct routine
analyses, premature death of thousands of rodents from
unsanitary laboratory conditions, faulty record-keeping, and
suppression of unfavorable findings. Prior to the convictions,
which were unrelated to food irradiation studies, the Army had
declared the beef and pork feeding studies being conducted by
IBT in default for similar contract violations. The Army
discovered
"missing records, unallowable departures from testing protocol,
poor quality work, and incomplete disclosure of information on
the progress of the studies." (8)
The government lost about $4 million and 6 years' worth of
animal feeding study data on food irradiation. (8) Some of this
early discredited work is still used as part of the "scientific"
basis for official assurances on food safety.
In this chapter we review some of the key issues: the possible
hazards from chemical changes in the food, the adequacy of
safety testing and the reviews undertaken by various
governments, animal and human feeding trials, and
microbiological hazards.
Toxic Chemicals
Properly controlled, irradiation should not make food
radioactive; the amount of induced radioactivity is extremely
small and will die away very rapidly. It is certainly
undetectable against the background levels of radiation in our
food from natural sources and the fallout from nuclear weapons
tests and accidents that have occurred since 1945. The first
concern, therefore, is not radioactivity but the possibility of
creating toxic chemicals in the food.
As noted earlier, bombarding any material with radiation can
alter its chemical structure. The first stage of this process is
the creation of "free radicals," highly reactive parts of the
original chemical structures that have been split and that carry
either positive or negative charges. A free radical rapidly
combines with another radical of opposite charge. In some cases
this can lead to recombination of the original molecule. In most
cases it does not, and a completely new chemical can be created.
The chemicals created in the irradiated food are called
"radiolytic products" or "radiolytes." Many of these are
similar to those that occur in other forms of food processing,
such as cooking. Some, however, are unique to irradiation.
(9,10,11)
Because of the complexity of the reactions, it is difficult to
identify all these radiolytic products and to test them in the
usually accepted way by which, for example, chemical additives
are tested. Initially, irradiated foods were fed to animals.
Although the results have been reassuring overall, testing of a
potential hazard usually involves feeding large quantities of
the chemical. Testing by merely feeding the food is inadequate.
Only small quantities of the unique radiolytes exist in the
food. Testing can therefore miss underlying problems or long-
term hazards.
More recently, a number of radiolytic products have been
isolated and more normal high-dose testing has been done on
them. (9) Again, the results have been claimed as reassuring.
Even though some adverse effects have been found in experimental
conditions, it is claimed that they are not likely to occur with
irradiated foods under practical conditions, i.e., provided they
conform to the international Codex Alimentarius standards and
the guidelines developed by the joint Expert Committee of the
FAO/IAEA/WHO. (9) It must be noted that the FAO/IAEA/WHO
committee initially required testing on all irradiated food
products. In 1976 this requirement was removed; results from one
food could be applied to another, provided that the doses were
below a limit of 1 million rad (10 kGy). (12) The Food and Drug
Administration, however, insists that food irradiated in the
medium-dose range could contain enough unique radiolytes to
warrant toxicological study - hence the requirement that all
foods irradiated above 100,000 rad (1 kGy) in the United States
are required to be tested.
Clearly the dose is a critical factor. The higher the dose, the
more radiolytic chemicals are created and the greater the
potential risk. Initially, the FAO/IAEA/WHO specified both the
maximum and minimum doses to be used in giving clearance to
particular foods. (12) The minimum dose guaranteed that the food
would have the changes expected of it, and the maximum
guaranteed that undesired effects would be limited. In 1980,
this requirement was changed and only an average dose was
specified. In doing so, the committee accepted that doses up to
50% greater than this average could result. (1) In some
quarters, this has been interpreted as giving clearance for
maximum doses to be 1.5 million rad (15 kGy). (10) In the United
States, the maximum dose is 100,000 rad. The use of cesium, with
its low penetrating power, can result in wide differences
between maximum and minimum doses unless the packages being
irradiated are thin.
Thus, although testing has been undertaken over a number of
years, and the dose ranges within which irradiated food can be
regarded as safe have been defined, there has been a steady
relaxing of the requirements for testing and for control of
doses. In our opinion, these changes appear to have more to do
with commercial considerations than public health.
The public needs far more information than simple statements
that irradiated food is "safe." The public needs to know about
the scientific uncertainty that underlies these statements from
the expert bodies and to be given details of some of the adverse
effects that have been found.
For chemicals that can cause cancer or genetic defects, it is
safest to assume that there is no safe level of exposure to such
chemicals; any dose can cause the initial damage that develops
into a cancer. Damage to the genetic blueprint may cause
miscarriage or defects in future generations. The fact that a
chemical change is small does not eliminate the risk. When even
a very small risk is spread over a large enough population, or
a long enough time period, some damage is inevitable. (13)
Evidence or Opinion?
There are problems involved in testing irradiated foods. Normal
tests for chemical safety require isolation of the chemical and
feeding it in large quantities to animals on the grounds that if
no problems are found with high doses, then small doses should
be safe. Isolating and testing all these chemical products would
be a massive task. It may be that the normal animal testing
program is inappropriate for irradiation. The fact remains that
the 1976 decision of the FAO/IAEA/WHO expert committee to relax
the requirements for testing of irradiated foods means that the
chemical products of irradiation have not been tested with the
same stringency required, say, of chemical additives. We have
every reason to be concerned about many permitted food additives
in use today. (14) Any less stringent testing program does not
inspire confidence.
On the question of the assurances of food safety being based on
fact or opinion, the fact is that neither the FAO/IAEA/WHO joint
committee nor the British government Advisory Committee provide
detailed references to the scientific literature to support
their conclusions. Neither does the summary report of the
opinion given by the Scientific Committee for Food to the
European Commission in 1986. (3) This committee claims that it
reviewed over 500 original studies from the Federal Research
Center for Nutrition in Karlsruhe, West Germany, where most of
the recent work done for the IAEA on food irradiation has been
undertaken. It is to be hoped that the full report, now promised
for 1987, will remedy this deficiency in a basic principle of
scientific reporting: that sources for the evidence are cited so
that they can be checked by independent critics.
Presumably, one who is an expert in the field, and knows of all
the research being done, may be able to infer which evidence is
being used to support which claim. One who is not has no chance
of untangling the mystique, but will have to trust (or doubt)
the experts. We happen to believe that democratic
decision-making deserves better than this. Given the current
public mood on many similar issues, the reaction to the
suggestion that we should "trust the experts" is more likely to
be doubt than trust, (15) and this will damage the chances that
irradiation will be introduced even in those areas where, on
balance, the benefits may outweigh the risks.
There is, in fact, a body of scientific literature indicating
adverse effects from feeding irradiated foods. It may be that we
can safely ignore this evidence on the basis of flaws in the
data or on the basis of systematic investigation of all the
possible effects and potential causes. If so, we respectfully
ask to see this evidence. So far it has not been forthcoming. We
simply cannot understand how the various committees could have
undertaken to review the available scientific evidence without
some systematic plan, which involves looking at each area of
concern, identifying the studies indicating that there is or may
be a problem, similarly identifying those that did not find the
problem, and weighing all the various strengths and weaknesses
of both sets of studies against objective criteria. This would
have been required of an undergraduate university degree
student, let alone some of the world's leading experts advising
governments and the United Nations on an issue of such
importance.
The best that can be said of many of these reviews is that they
offer the opinion that there are no "special" safety problems
associated with consumption of irradiated food if it is properly
controlled, but that they fall to back up these opinions with
facts. They are also, as we will see, noticeably silent on the
systems for control of the technology and how to prevent its
abuse. We can hardly be blamed for not finding these opinions
reassuring.
The situation in the United States is marginally better than in
the rest of the world. Irradiation is governed by the 1958 Food,
Drug and Cosmetics Act, (16) which classifies irradiation as an
"additive" and requires users of irradiation to petition the FDA
for clearances on specific foods and show, by supporting
evidence, that the food will be safe. So far the FDA has given
clearances for food only up to 100,000 rad (1 kgy) - one tenth
of the internationally recommended limit. The exception is that
in the United States, spices can receive up to 3 million rad -
three times the international level.
In practice, however, it is possible that foods will get higher
doses than those permitted. In a petition to the FDA to allow
higher irradiation doses for spices, R. L. Hall, Vice President
of McCormick & Company, Inc., stated, "In existing large-scale
irradiators, it is quite likely that an overdose of up to 25O%
can be expected." (17) It is unclear at this time whether the
FDA's limits are maximum doses or whether, like the recommended
Codex standard, they are to be interpreted as average doses.
How Adequate Are the FDA's Review Processes?
A recent review of the process adopted in granting approval for
irradiation of pork shows that the FDA did make some attempt to
evaluate the strengths and weaknesses of the studies both for
and against the existence of harmful effects. Some objective
criteria were drawn up by which studies were to be judged
acceptable. Using these criteria, the FDA discarded all the
evidence suggesting that there were adverse effects. FDA staff
also found that they had to discard most of the studies
indicating that irradiation was safe by the same criteria. The
result was that they were left with only five studies on which
to base the approval for irradiation of pork.
Dr. George Pauli of the FDA's Food Safety Division admitted that
neither the FDA nor any other review body has so far attempted
to show that the safety concerns raised by many of the studies
can be discounted by reference to other studies that did not
find these problems under similar conditions. (18) Such a review
might, on balance, show that the risks could be considered
slight and perhaps acceptable. It would also show the extent of
scientific uncertainty that exists. More important, it would
indicate the areas where further research is needed and provide
both legislators and consumers with the basis for deciding
whether they wish to accept the outstanding risks in return for
the benefits of irradiation.
In fact, the FDA's 1986 clearances are not even based on the few
studies it approves of. Rather, they are based on a theoretical
estimate of the number and amount of unique radiolytic chemicals
likely to be created. In 1980, the FDA concluded that the levels
of new chemicals are so low that doses up to 100,000 rads (1
kGy) are acceptable. (19) This appears to some critics to be a
reinterpretation of the law that requires proof of the safety of
irradiation by animal testing studies. It may even be illegal.
Evidence of Cause for Concern
The problems of investigating the safety of irradiated foods are
compounded by the lack of credibility of some of the research
done by the United States Army and IBT. Lethal effects from
feeding irradiated food to mice have been observed. Other
studies have not confirmed these effects. (9) Some animals fed
irradiated food have been found to have reduced growth rates,
lower birth weights for offspring, changes in white blood cells,
and kidney damage. The chemical agents responsible have not been
identified, but some of the changes may be due to effects on the
body's immune system. There is also a suggestion that vitamin
reduction in irradiated foods is a cause of some of these health
effects. (10) Studies have found increased incidence of tumors,
which suggests that cancers may be caused by long-term
consumption of irradiated foods. (3,21) Other studies have not
detected significant increases in tumors. A similar conflict of
evidence exists over whether irradiated food can cause genetic
mutations. The balance is in favor of the view that they do not,
but some uncertainty remains. (10)
With cancer and genetic damage, we are concerned that even very
small quantities of a harmful chemical may cause the damage. Dr.
George Tritsch, a researcher at the Reswell Park Memorial
Institute Cancer Research Center in Buffalo, New York, has
expressed concern about exposure of people to possible
carcinogens like those which may be created in small amounts in
irradiated foods. He notes that "...a single carcinogenic insult
is all that is needed to produce a malignant neoplasm a decade
or more later." (22) As early as 1979, a review of food
irradiation literature by J. Barna for the Hungarian Academy of
Sciences identified hundreds of adverse effects in animals
relating to the feeding of irradiated food. (23) Study results
were classified as either neutral, adverse, or beneficial. Each
study could have several outcomes, since studies could address
more than one issue. Barna found 1,414 adverse effects, 185
beneficial effects, and 7,191 neutral effects. For bacon, he
found 86 neutral study results, 31 adverse study results, and no
beneficial results. For soybeans, he found 60 adverse study
results, no beneficial results, and 26 neutral study results.
For sucrose, he found 39 adverse study results, 38 neutral, and
one beneficial. For corn oil, he found 13 adverse, five neutral,
and no beneficial results.
The results of extensive animal feeding studies conducted by
Raltech Scientific Service for the federal government were
reported in 1984. Some results suggested safety, but according
to the Department of Agriculture reviewer, Donald W. Thayer,
chief of the Food Safety Laboratory at the Agricultural Research
Service,
"Two of the studies ... had some possible adverse findings which
will require careful consideration before the process can be
declared safe." (21)
The nutritional and toxicological studies evaluated five diets:
(a) commercial laboratory diet (no chicken control), (b) frozen
chicken (control), (c) thermally processed chicken, (d) cobalt
60 processed chicken, and (e) electron irradiated chicken.
Although Dr. Thayer did not highlight the problem, one study to
explore the effects on offspring had to be terminated
prematurely because of excessive mortality among offspring in
all diet groups. The study, intended to last two years, was
cancelled after only nine months. Instead of repeating the study
to determine the true long-term reproductive effects, the
researchers declared the process safe on their limited
nine-month data. (24)
In studies of mice fed test diets from birth to death, survival
of both sexes was significantly reduced for those fed
gamma-irradiated food, and the group eating gamma-irradiated
chicken had the highest incidence of several tumors among those
analyzed. To counter claims of possible harm, the National
Toxicology Program assembled a new panel to review the slides on
lesions in the test animals, and this panel declared that the
lesions were not cancerous. Nonetheless, this panel failed to
explain the increased number of deaths among the animals eating
gamma-irradiated chicken. It did demonstrate disagreement among
experts.
In another portion of the Raltech study, fruit flies
(Drosophila), which are commonly used to test for mutations,
were fed test diets. For this portion of the study, a sixth
group was fed a known hazardous chemical (TRIS) as a positive
control. The TRIS was expected to show dominant lethal
mutations. Table 6 shows the results of the study.
Dr. Thayer reported
"... an unexplained significant reduction in the production of
offspring in cultures of D melanogaster reared on
gamma-irradiated chicken. This response was dose related and was
not overcome by the addition of vitamin supplements."
Table 6: Number of Drosophila Offspring
Average Number of
Compound Offspring
Negative control
(no chicken meat) 720.6
Frozen control chicken 332.7
Thermally processed chicken 404.4
TRIS (@ 100 ppm) positive
control (no chicken meat) 269.9
Electron-irradiated chicken 160.0
Gamma-irradiated chicken 57.1
(Source: Raltech Scientific Services Inc The Final Report
Evaluation of the Mutagenicity of Irradiated Sterilized Chicken
by the Sex-Linked Recessive Test in Drosophila Melanogaster.
Contract DAMD 17 76-C-6047, June 15, 1979.)
In fact, the table reprinted here (which was not part of the
Thayer report) demonstrates that the fruit flies fed
gamma-irradiated chicken had seven times fewer offspring than
those fed thermally processed (cooked) chicken. A dose-response
pattern occurred, with higher concentrations of
gamma-irradiation of chicken producing fewer offspring.
Food irradiation proponents declared the results irrelevant,
since fruit flies don't normally eat chicken. Table 6 clearly
shows that fruit flies consuming no chicken had far more
offspring, but, particularly in view of the study results, it is
certainly appropriate to compare the groups eating the chicken
diets. The positive control, the chicken diet with a known
hazardous chemical, led to better reproduction than either the
electron- or gamma-irradiated diets. While the fruit flies
eating electron-irradiated chicken had about three times more
offspring than those fed gamma-treated chicken, they still had
less than half the offspring of the flies fed unirradiated,
frozen chicken.
Despite these findings, in an article published in Cereal Foods
World in 1984 Dr. Thayer concluded:
"On balance, the studies on radappertized chicken conducted by
the US army and various contractors strongly supports the
process' safety, but these are some potentially serious adverse
results, which must be considered when the FDA examines these
studies." (25)
Many of these studies involved much higher doses than those
proposed for commercial irradiation. The quantities of a
particular radiolytic chemical may increase with the dose.
However, the type of radiolytic chemical change is likely to be
the same whatever the dose. We are concerned that even small
quantities of some chemicals could be hazardous. (23)
Indeed, the European Committee for Food states, of the study
feeding chicken to mice,
"the use of a higher dose would amplify any effects of
irradiation and [this study] might be a sensitive indication of
a carcinogenic effect which could also be present at lower
doses." (3)
Human Studies
There have also been some studies on feeding irradiated foods to
people.
Conscientious objectors were fed irradiated foods in a
university study in 1953. The men were given physical
examinations before and after a two-week diet of irradiated
foods, and no immediate damage was observed. Unfortunately, no
long-term follow-up was built into this research. (26)

The United States Army has performed trials in which people
consumed several irradiated foods. There is little information
in the scientific literature on these studies. Chinese
researchers reported that in 1982 they were "unable to get the
information in detail." (27)
The Chinese have done most of the work on feeding irradiated
foods to human volunteers. Reports on these have been
reassuring. Studies on feeding potatoes, (28) rice, (29)
mushrooms, (30) meat products, (31) and peanuts (32) all found
no adverse effects.
These studies were followed by eight human volunteer studies in
1982. The foods investigated included rice, mushrooms, sausage,
peanuts, meat products, and potatoes. There were also two
studies in which 60 to 66% of the whole diet was irradiated.
These extended over 7 to 15 weeks and took into consideration a
variety of health factors. In no case was any difference found
between the volunteers in the experimental group and those in
the control group, who were on a normal unirradiated diet.
A subsequent human volunteer study (27) in 1984 tested the
effects of irradiating the whole diet, consisting of 35
different foods. This involved 70 volunteers and lasted for 90
days. The only possible adverse effect noted was a small
increase in polyploidy, a defect in the chromosomes of blood
cells. This was not thought to be significant, as a similar
increase in polyploidy was also found in the control group.

Polyploidy was also observed in a study on feeding freshly
irradiated wheat to malnourished children, conducted by the
National Institute of Nutrition (NIN) at the Council of Medical
Research, Hyderabad, in India. Children fed freshly irradiated
wheat developed polyploidy, whereas children in a control group,
fed a similar but unirradiated diet, did not show this problem.
Once the children were taken off the irradiated wheat diet,
their blood patterns gradually returned to normal. The research
indicated that if the wheat were stored for a period of time
(several months), the blood abnormalities probably would not
occur. (33)
The treatment of this issue by both the FDA and the British
ACINF highlights the concern we expressed earlier over the way
that scientific evidence is handled and possible concerns
dismissed.
It was suggested in November 1984, at the American Nuclear
Society/European Nuclear Society joint meeting held in
Washington, D.C., that the study was fraudulent. (34) A panel
member even claimed that the study was repudiated by the
Director of the Institute conducting the study. (35) We wrote to
the Institute, and the Director responded that they stand behind
their study. In fact, similar problems with freshly irradiated
wheat have been demonstrated in the blood of both monkeys and
rodents. (36)
 
In its final ruling, the FDA stated:
"A committee of Indian scientists critically examined the
techniques, the appropriateness of experimental design, the data
collected, and the interpretations of NIN scientists who claimed
that ingestion of irradiated wheat caused polyploidy in rats,
mice, and malnourished children." (37)
The FDA goes on to say that the committee report was "presented
to the joint Expert Committee in 1976," (of the IAEA/FAO/WHO).
although agency personnel later had to retract this claim. (38)
The so-called committee of Indian scientists turned out to be
two researchers who submitted a confidential report to the
Ministry of Health and Family Planning in India. The report was
requested by the ministry because research undertaken by the
Bhabba Atomic Research Centre (BARC) obtained different results
from those found by NIN. BARC was seeking approval to irradiate
food. NIN responded to the two-person "committee" with a report
to the Indian government verifying the validity of their work
and refuting in detail the claims and conclusions of the
critical report. They also included independent evaluations of
their data by two of the country's foremost cytogeneticists.
(39)
The ACINF report, referring to what can only be the Indian
study, concluded that
"It was found that the abnormal cells disappeared within a few
weeks after withdrawal of irradiated wheat from the diet, and we
do not think that this transient phenomenon would have any
harmful long term consequences." (2)
While this may be true for the Indian children involved in the
study, it hardly reassures us that long-term consumption of
irradiated food will be safe. Neither did it reassure the
British Medical Association, whose Board of Science produced a
report in March 1987 emphasizing that further research is needed
in this area. (40)
A Cancer Connection?
Polyploidy may be a significant health issue. Normally, we all
have 46 chromosomes, which contain the blueprint for the cells'
functions. Damage to the chromosomes can cause the cell to
malfunction. With polyploidy there are extra complete sets of
chromosomes, i.e., human polyploid cells may have two sets (92
chromosomes) or three sets (138 chromosomes), and so on.
Polyploidy is rare in human cells. It can result from a simple
failure to separate at cell division and is frequently seen in
tumor cells, although this is only one example of the bizarre
cell forms present in established tumors. Polyploid lymphocytes
have been found in increasing numbers with age, (41) but, as
yet, there is no evidence of a direct correlation with cancer
incidence. (42) However, to quote the Indian study, (33)
"The long term health hazard significance of polyploidy seen in
the children studied here who had received freshly irradiated
wheat, is not clear. On this will depend the answer to the
question whether irradiated wheat is safe for human
consumption."
In the light of these observations, it is clear that a
cautious approach must be adopted to the whole question of the
mutagenic potential of irradiated wheat.
Scientists do not fully understand what mechanisms come into
play in the formation of cancer, but it is widely believed that
there is damage at the cell level, in particular to the
chromosomes, that initiates the process, and that exposure to a
secondary agent may be needed to promote the cancer. (43)
What is particularly worrying is that the initial effect of
irradiation is to create free radicals, i.e., highly reactive
chemical components created by splitting the more stable complex
chemical structures in food. Free radicals are believed to be
common cancer "promoters." (41,44) That is, they promote the
second-stage developments that turn the initially damaged cells
into malignant (i.e., cancerous) ones. Most of the free radicals
created by irradiation rapidly recombine into stable chemical
forms. However, some remain. One of the tests being developed to
detect irradiated foods relies on detection of very small
quantities of free radicals remaining in some foods for some
time after irradiation.
Whatever the mechanisms involved in the chain of events from
cell damage to cancer and/or genetic damage, few in the medical
profession would regard an increase in polyploid cells as a
trivial matter. The discovery of such changes in the blood of
animals and humans fed irradiated diets is clearly cause for
concern, though not in itself proof that eating irradiated foods
causes such effects. It does require careful evaluation of all
the scientific evidence.
There are other studies whose conclusions offer some
reassurance, in that they did not find an increase in
polyploidy. A closer look at the primary research reports,
however, raises more doubts than are laid to rest. One of the
reports refers to an eight-week feeding trial done in
Cambridgeshire, England. (45) A group of rats fed an irradiated
wheat-based diet was compared with a control group fed an un-
irradiated diet. Unfortunately, this study did not address the
issue of damage from freshly irradiated food. The wheat used had
been irradiated two weeks before the start of the study and was
thus ten weeks old at the end. In addition, the experimenters
(to their credit) reported that on the eighth week they could
not find the feed for the experimental animals and concluded
that they must have fed it to the control group. After various
changes were made in the study protocol to compensate for this,
they could not find significant differences between the two
groups. The results from the two experimenters who counted the
numbers of polyploid cells showed no consistency, even though
they were both investigating cells from the same animals. This
indicates some of the problems of counting polyploid cells. By
the same token, it weakens the strength of the initial Indian
findings.
Other Long-term Effects
Perhaps more worrying than any specific disease attributable to
irradiated foods is the report of a 15-week study on rats fed a
diet containing 70% freshly irradiated wheat (irradiated at
75,000 rad, or 0.75 kGy). These animals were found to have a
lowered immune response, which suggests that irradiated food may
inhibit resistance to fight off infections and lower the body's
resistance to a wide range of diseases. (3)
The key issue appears to be whether there is a problem with
freshly irradiated foods. It is entirely reasonable to expect
that there will be a higher incidence of reactive chemicals in
the food immediately after irradiation. With time, many of them
will recombine to more stable forms, and some volatile chemicals
may escape from the food. After a while the irradiated food
becomes, chemically speaking, harder to distinguish from the
unirradiated product. Any possible undesirable biological
effects on human health will likely be considerably reduced.
If there is a problem with freshly irradiated produce, this will
not, of itself, invalidate the use of irradiation. What will be
needed, however, is a system that guarantees that the produce is
stored for a suitable period before being consumed. A simple "do
not sell before" or "do not consume before" date marking label
put on the food at the time of irradiation may be all that is
required.
In summary, we clearly need further research and a more open
discussion of the available evidence on possible adverse effects
of food irradiation. Failure in some instances to conduct
appropriate experiments, attempts to deliberately misrepresent
the work of third world scientists who have had reason to be
concerned, and the offering of vague opinions from some national
and international committees concerned with food irradiation do
not help. The conclusions offered by such committees seem more
designed to provide reassurance than scientific facts. They only
add to the level of suspicion over the way that scientific
testing of the safety of irradiated foods has been conducted.
Microbiological Hazards
The effects of irradiation are not limited to chemical changes
in the food. Irradiation is also used to kill the yeasts, molds,
and bacteria that cause food to spoil. It will also render
sterile any insects that infest it.
There is a possibility that irradiation causes mutations in
viruses, insects, and bacteria in food, leading to more
resistant strains. (13) There are numerous examples of insects
developing resistance to pesticides. Could they become resistant
or genetically altered by radiation?
Fortunately, most genetic changes are nonviable; i.e., insects
or their offspring are most likely to be killed or rendered
sterile. Some strains of resistant salmonellae have been
developed by repeated irradiation under laboratory conditions.
Radiation-resistant bacteria have been found in environments
with high natural or artificial radiation levels, (10) and
development of such resistance may be a problem around large
irradiation plants. (9) Indeed, the ACINF stated
"Sub-lethal doses of ionizing radiation can produce chemical
changes in genetic material of micro-organisms (mutations)
leading to altered characteristics which will be propagated in
subsequent generations. Such mutant micro-organisms could be
more pathogenic than native forms. Also they might exhibit
altered growth characteristics which would make them difficult
to detect or identify, and thus interfere with the standard
microbiological evaluation of irradiation. Mutants might also be
more radiation resistant, and if they were to spread into the
environment, they might contaminate food prior to irradiation
and so render the process ineffective." (2)
Of greater concern, however, is the fact that, though
irradiation can kill bacteria in food, it will not remove the
toxins (chemical poisons) that have been created by the bacteria
at the earlier stages of contamination. This is important, as we
will see when we consider some of the abuses of irradiation in
Chapter 5. It is the toxins created by bacterial contamination
that are the real public health hazard.
Not all the microorganisms in food are harmful. Some perform
useful functions, particularly in warning us that food is going
bad by giving off a putrid smell. Yeasts and molds also compete
with harmful bacteria and so provide natural controls on their
growth. If this natural balance is destroyed, it is possible
that the few remaining harmful bacteria can multiply rapidly
without inhibition, and within a short time the problem can be
greater than before irradiation.
Increased production of aflatoxins following irradiation was
first found in 1973 (46,49) and confirmed in 1976 and 1978
(Table 7). Aflatoxins are powerful agents for causing liver
cancer. Their production was found to be stimulated by
irradiation at doses approved by the FAO/IAEA/WHO expert
committee.
 
Food Increase
wheat increases with dose
corn 31%
sorgum 81%
millet 66%
potatoes 74%
onions 84%
(Source Reference 49)
Aflatoxins occur in damp environments on fungus spores on grains
or vegetables. Control of humidity in storage becomes even more
important in the case of irradiated than of nonirradiated foods.
One food in which this issue can be of concern is peanuts,
Currently, some importers go to great lengths to ensure that
imported nuts are not contaminated with aflatoxin-creating
bacteria. They fear that if irradiation is legalized, suppliers
may irradiate nuts to keep the bacterial count below the control
levels. In doing so, the competing bacteria will also be
destroyed, and within a short time after the importers have
purchased what they believe to be "clean" peanuts, aflatoxin
production could rapidly increase. It is the processors, not the
foreign suppliers, who will be blamed by the consumer for any
subsequent health hazard.
Other, more complicated and expensive tests can be used to
detect aflatoxins. For some other toxins there are not, as yet,
corresponding tests that can detect the chemical poisons in the
absence of the bacteria that create them.
Another example of the possible effect of irradiation arises in
the irradiation of chicken to reduce the risk of Salmonella food
poisoning from chicken and fish. Irradiation of chicken could
kill most of the Salmonella bacteria on chicken flesh, and also
kill most of the yeasts and molds that are the natural
competitors of clostridium botulinum - the bacterium that causes
the much more serious food poisoning, botulism. It will also
kill most of the organisms that cause the putrid odor when meat
has gone bad. Yet, at the doses proposed, c. botulinum will not
be killed. Under the right conditions (e.g., warmth and absence
of air) the organisms could multiply and become a health hazard
without the consumer's having detected any warning odor.
(2,9,14,37) With fish this is less likely. Lower doses will be
used, and there should be enough spoilage organisms left to
multiply along with the c. botulinum so that the food smells
unacceptable when the botulism becomes a hazard. (9)
Clearly, such possibilities reinforce the need for strict
control of both the irradiation process and the conditions under
which irradiated food is packaged, stored, and handled. They may
also severely limit the uses of irradiation. The USDA has set up
a strict testing protocol for studies that will be needed before
it will allow vacuum packaging of irradiated meat products (48)
It is clear from our conversations with USDA staff that botulism
formation is the main concern. If irradiated foods cannot be
packaged so as to prevent airborne recontamination by bacteria,
then there is no way that the technology can fulfil many of the
promises claimed for it. The food cannot be guaranteed to remain
free from food poisoning organisms. Use of chemical
preservatives, refrigeration, and even more rigorous hygiene
practices in food handling will be needed, as well as
irradiation.
Summary of Our Concern
We are not saying that irradiated food is definitely unsafe or
harmful. However, the testing program to date does indicate that
some possibly harmful effects could occur and that they need
proper investigation. The way these concerns have so far been
dismissed is profoundly disturbing. They are frequently called
"insignificant" or "not likely to occur in practice." The
studies that find problems are discounted.
The expert bodies appear to change the rules by which we judge -
the validity of a test. To present an independent challenge to
this process is like playing football while the referee is
moving the goal posts. First the chemical products created by
irradiation are to be tested like chemical additives, then they
are not. It is to be sufficient to show that there are no
harmful effects when the food itself is fed to animals. Then
when this study shows unwanted results, the criteria for
accepting the results from an animal feeding study are tightened
up. Finally, when so few studies are left - either showing or
failing to show harmful effects - that it looks as though we
should go back and redo the whole testing program and get it
right this time, the FDA removes the goal posts completely.
Approval can now be based on estimates of the quantities of
chemical products formed by irradiation, and the opinion they
are so small as to present no hazard.
The public has a right to unbiased, objective information on the
possible harmful effects of irradiation, and not bland
reassurances that hide uncomfortable evidence under value
judgments. It is the job of the democratic processes to decide
whether the effects are significant and the risks acceptable,
and to lay down the conditions under which any risks can be
minimized. When science, scientific experts, and regulatory
agencies enter this area to preempt discussion of these issues,
we have reason to be concerned.
 
 
REFERENCES (omitted - unscannable)
 
 
[] Excerpt from Chapter 4 - "Wholesomeness of Irradiated
Food?"
Yet, despite these valid reasons for having irradiated food
clearly labelled as such, there has been a remarkable
reluctance on the part of the authorities, the pro-irradiation
lobby, and the food industry to allow labelling to be done
simply and honestly. The 1984 FDA-proposed rule for
irradiating fruits and vegetables tried to drop the existing
labelling requirement. FDA officials stated that Margaret
Heckler's office removed their initial recommendation for
consumer labelling. (12) The no-label proposal elicited several
thousand letters demanding that irradiated foods be labelled,
although most writers preferred that the process not be
approved.
In the United States, companion bills have been introduced in
the House and Senate that would prevent individual states from
enacting their own legislation to require labelling. In one of
her last acts before resigning as Secretary of Health and Human
Services, Margaret Heckler announced that the label would
contain the term "picowaved," probably as an attempt to draw on
the widespread acceptance of microwave technology, even though
microwaves cannot alter the food chemistry as ionizing radiation
can. Fortunately, this idea didn't pass the "laugh test" within
the corridors of power. The FDA's final rule (April 18, 1986)
requires labelling of whole foods with the statement "treated
with radiation" or "treated by irradiation," and the use of a
symbol that looks like a stamp of approval. Unfortunately for
consumers in the United States, the requirement to label foods
with words that tell us what has been done to it will be dropped
in April 1988, and food manufacturers may then be free to use
only the symbol.
The United States symbol is similar to the "Radura" label that
was first developed for use in South Africa and the
Netherlands. American consumer activists charge that the
symbol is misleading. They think that the stylized flower inside
a circle is more suggestive of a health food than an irradiated
one. The Environmental Protection Agency pointed out the close
similarity of the symbol to its own logo (Figure 3).
The system in Europe is in fact voluntary. It is very hard to
find any food with this label on it in Europe. The Dutch
irradiators tell us that all their food goes for export. The
South Africans, no doubt fearful of fuelling the boycott of
South African produce, assure us that none of theirs is
exported, though there is evidence of a test marketing trial of
South African produce in the Netherlands in 1984.
In Britain, the ACINF reluctantly recommended that irradiated
food be labelled - just as well, because a national opinion poll
conducted for the London Food Commission showed that 95% of the
public thought that all irradiated foods, including ingredients
of processed foods, should be clearly labelled as irradiated.
The use of the words "the emblem of quality" would almost
certainly contravene the United Kingdom's Trade Descriptions
Act, which prohibits any false claims in advertising. What is
clearly needed is international agreement for clear and
unambiguous labelling of all irradiated foods as "irradiated."
Even this will not be enough. Within Europe, the European
Commission is the body that actually drafts the laws that will
be applied by all European governments; the elected European
Parliament has only an advisory role at present. The
Commission is currently considering a draft directive that would
not require labelling of any food making up less than 50% by
weight of the finished product. Furthermore, this directive
would require all governments to pass laws no more restrictive
of irradiation than those of the directive. The states' rights
issue in the United States is paralleled by loss of sovereign
rights for European nations through the determination of the
irradiation lobby to conceal, as far as possible, the fact that
food has been irradiated.
There are considerable pressures in Europe for nutritional
labelling, at least at the minimum level that exists in the
United States, where the vitamin and other nutritional values of
foods are printed on the package. More and better labelling is
in fact needed. The information is currently given in as
unintelligible a form as manufacturers are permitted to provide.
How do food manufacturers intend to modify the nutritional label
to take account of vitamin losses?
As we have seen, irradiated food is intended to be stored
longer. Wherever they have been asked, consumers indicate that
they want the date of irradiation to be stamped on the food so
that they'll know how old it is. (8) The food has been able to
gain acceptance for the vague "sell by" date marking system. Is
a return to a more honest date marking system a price that the
industry is prepared to pay for the benefits it expects to get
from irradiation?
 
 
CAN FOOD IRRADIATION BE CONTROLLED?
LET US ASSUME for the moment that irradiated food is safe, that
consumers welcome the benefits it offers, and that they are
willing to pay a premium price for food that keeps longer and is
guaranteed free of food-poisoning organisms. What is there to
stop the unscrupulous trader from labelling food
"irradiated" that has never gone near an irradiation plant? The
answer is, incredibly, nothing! There is currently no test that
can be used to show that a food has been irradiated. There is no
test to show what dose it has received or how many times it has
been irradiated.
Perhaps more worrying, however, is that there are also no tests
to show what may have gone on inside the food before it was
irradiated.
As we have seen, there are doubts over the safety and
wholesomeness of irradiated foods; but even if there were not,
we need to be assured that it can be controlled - that we have
the system of regulations, agencies, trained staff, and
technology to ensure that it is used properly. None of this
exists.
In 1986 it was revealed that a company in one of Britain's major
food groups, Imperial Foods, had used irradiation to conceal
bacterial contamination of seafoods that were then sold for
public consumption in Britain. (1,2)
It was revealed that the British Imperial Foods Group
subsidiary, Young's Seafoods (now owned by the United
States/United Kingdom financial giant, the Hanson Trust), had
used irradiation to conceal contamination of seafoods that were
then sold for public consumption in England, where irradiation
and sale of irradiated food is illegal. (2) The company found
contamination on a shipment of prawns that it had imported into
Britain. It shipped these prawns to the Netherlands for
irradiation and then, illegally, reimported these same prawns
back into Britain to be sold under the "Admiral" label (See
Appendix 2). (2)
This is not an isolated case. A television program, "4 What It's
Worth," produced for the British Channel 4 network, also
reported that the Flying Goose Company, now part of the
British Allied Lyons Group (which owns food companies in the
United States such as Baskin-Robbins), had sent prawns to the
IRE irradiation plant in Belgium to be irradiated. (3) These
prawns were sent to Sweden, where, as in Britain, the
importation of irradiated food is prohibited. (3) The company
was reported as saying that the shipment had been a mistake and
the practice would not continue. However, the consignment was
rejected by the customer in Sweden following a tip-off. The
Swedish authorities allowed it to be reexported. Its final
destination was unknown. (4)
Irradiation has been used on spices that have been sent to West
Germany and irradiation was used on a shipment of contaminated
mussels that was sent to Denmark. Like the Imperial Group's
prawns, these foods were irradiated at the Gammaster plant in
The Netherlands. (5)
The International Maritime Bureau is investigating cases of
possible insurance fraud involving shipments of various foods to
the United States. It is believed that shipments of seafood and
frogs' legs may have been overinsured before being
rejected by the authorities in the United States. Once the
insurance claims are made, the consignments are then bought back
as "reject lots" and shipped to Europe for irradiation before
being put back on the market. One consignment of frogs' legs is
suspected of having crossed the Atlantic 11 times.
When asked to take legal action to stop these abuses, the
British government minister replied that it was a matter for the
port authorities and that, in any case, one documented example
did not indicate widespread abuse. (6)
Our information is that the practice of concealing bacterial
contamination by use of irradiation is more widespread than the
governments are prepared to admit, partly because they are
unable to control it. Seafood products such as those just
described travel the world as relatively valuable consignments.
Within the trade, their whereabouts is fairly well known. These
cases also involve illegal trade and so have been easier to
track down. These documented cases represent the tip of the
iceberg. Many other irradiated products are similarly traded. If
the current bans in these European countries were removed in the
absence of stringent controls, such abuses would be even more
frequent.
The reason for concern goes beyond legality and beyond even the
deceit involved in concealing bacterial contamination.
Irradiation can reduce the bacterial load on foods - known in
the trade as the "bug count" - but it leaves unaffected the
toxins generated by the earlier bacterial contamination, which
can present a very real public health hazard.
The FAO/IAEA/WHO joint Expert Committee emphasized that
irradiation should be used only to extend the shelf life of
otherwise wholesome food and should never be used to make unfit
food saleable. (7) Yet this is precisely what is already
happening in countries where irradiation is permitted, and is
even occurring, despite the law, in countries where it is not.
When consumers, public health agencies, or responsible food
companies inspect food for its wholesomeness and saleability, we
use our eyes to see if it looks fresh and our nose to see if it
smells bad; if in doubt, we can send it to the laboratory for a
"bug count." Unfortunately, irradiation is intended to make food
look fresh longer, kill the bacteria that cause it to smell bad,
and kill most of the bacteria that are usually detected in the
bug count.
Use of irradiation makes all the usual testing systems for food
wholesomeness ineffective. A whole new battery of tests will be
needed just to determine whether foods have been
irradiated. There will also be a need for appropriate training
of the staff in monitoring for food safety. There has been
massive funding for research designed to show that irradiated
food is "safe." Until very recently, there has been no funding
of research into methods of detecting irradiation treatment. (8)
Without such methods, it will be impossible to provide
assurances - in the real world of the international food trade -
about the safety of possibly irradiated foods.
A survey conducted in Britain revealed that there had been no
preparation of the responsible agencies-port health and
trading standards officers-for monitoring, detection, and
control of irradiated foods. (9) Not only are there no
available tests to detect irradiation, there are no readily
available tests for measuring many of the chemical toxins
directly if concealment of earlier contamination by irradiation
is suspected. Even those toxin tests that do exist are
complicated and expensive, and would not be used routinely.
The United States National Bureau of Standards and a British
university have recently begun to collaborate on research that
may lead to a battery of tests being available, perhaps within
the next three years. At the time of writing, one of them
involves detection of small changes in the level of some protein
chemicals, such as ortho-tyrosine in meats. Another is designed
to identify residual free radicals in hard foods, e.g., in bone
or chitin, using electronic spin resonance techniques. This may
also be useful for other dry whole foods. Other approaches based
on changes in food chemistry, chemiluminescence, measurement of
electrical conductivity in foods such as potatoes, or
measurement of differentials between bacterial and toxin counts
and detection of changes in the DNA - that part of the food's
chemistry that carries the genetic code - are also under
consideration. As yet, none of these approaches is developed to
the point where public health agencies or concerned companies
can use them to detect irradiation. It will take considerably
longer to develop tests that measure the dose of radiation
received or how many times a food has been re-irradiated before
being sold to the consumer.
What we find amazing is that there is, as yet, no serious
government funding for this research. The United States/United
Kingdom research program described here is partly funded by
charitable donations from the British company Ken Bell
International. Ken Bell has been an outspoken critic of
irradiation and the major source of information on current
abuses in the irradiated food trade. (3)
Perhaps most incredible of all is the fact that various
governments, that of the United States included, have given
permits for irradiation without there being a regulatory,
testing, and enforcement system in place and without
appropriation of significant funds for the research to develop
tests that could help stamp out the abuses that are going on.
The United Kingdom Ministry of Agriculture, Fisheries, and Food
has allowed only L150,000 a year for research in this area. (8)
Whatever the views on the safety of long-term consumption of
irradiated foods, many responsible companies in the food
industry have given assurances that they will respect the
consumers' demand for labelling of all irradiated foods.
Unfortunately, without tests to detect irradiation, they cannot
guarantee that some unscrupulous supplier has not used
irradiation at some stage. There seems to be common ground
between the food industry and consumers for a moratorium on
irradiation until such tests are available and until monitoring,
control, and enforcement systems are developed. The few years of
breathing space would allow time to clear up the confusion over
safety testing and other concerns about irradiated foods. This
position has been adopted by the British Food and Drink
Federation (10) and endorsed by the European Parliament. (11)
For the moment, however, we are dependent on the integrity of
the irradiation companies, processors, shippers, and retailers
to measure, record, and provide documentation on irradiated
foods all the way down the line from the irradiation plants to
the consumer, if we are to know anything about their history.
Such documentary approaches are inadequate. The USDA, for all
its inspections and controls, uncovered only one illegal
shipment of irradiated pork on its way to Sweden when the ship
was in the mid-Atlantic. (12) The idea that irradiation
companies will take the trouble to inquire about a food's
history and final destination before irradiating it flies in the
face of the evidence. (3,4) Sources in the food trade report
that European brokers openly offer to have consignments
irradiated and some traders regularly deal in "reject"
consignments.
So far, however, governments have refused to take action against
the companies involved in abusing irradiation or to stop the
abuses. How many more cases must we and other independent
researchers uncover (and provide the hard-to-obtain documentary
evidence for) before our governments will take action?
Working with Radiation
The abuse of food safety, unfortunately, is only one of the
areas where we have reason to doubt that the irradiation
industry will act with integrity. Exposure of food to radiation
may, in the end, have some beneficial effects. Exposure of
workers has none.
Large doses of radiation can kill by destroying cells in the
body so that various organs cease to function, or by damaging
the body's immune system, leaving it susceptible to disease.
Some acute effects such as skin burn, nausea, and diarrhea are
also experienced; they may not cause death, but years later,
exposed people may suffer from cancer, or their children from
genetic damage, as a result of the exposure. Even at doses too
low to bring about immediate effects, there remains an increased
risk of cancer, genetic damage, or susceptibility to disease.
(13,14,15,16)
There is no threshold or safe level. When radiation strikes a
living cell, one of three things can occur:
Damage done, if any, is adequately repaired.
The cell is killed. In this case, provided too many cells are
not killed at once, the body will eliminate the dead cells and
little harm will be done.
The cell will be damaged but survive to reproduce in this
damaged form. Years later, successive reproductions from the
damaged cell may show up as what we call a tumor or cancer, or
be passed on as a genetic defect to future generations. (15,17)
Also, a growing body of evidence suggests that radiation causes
a more general reduction in health by weakening the body's
resistance to disease. (15,17)
The crucial point is that there is no dose below which these
effects do not occur. It is like walking across a main road
blindfolded. Do this at rush hour and you'll probably be killed.
Do it at midnight when there is less traffic and you may be more
lucky; but if you are hit by one of the few vehicles around you
will be just as dead. A little bit of radiation does not give
you a little bit of cancer. Any dose, however small, can be the
one that does the damage (15) that, years later, may show up as
cancer or other health problems in this or future generations.
The extremely large doses involved in the irradiation of food
could result in exposure to workers in the industry. They face
considerable risks in the event of malfunctioning equipment,
leaking radioactive sources, or accidental exposure to the
source. In addition, the irradiation chamber will be a very
corrosive atmosphere requiring "regular and preventative
maintenance. (13) Irradiation sources will also need to be
produced, transported, stored, and installed, and the spent
sources replaced. At every stage workers can be, and usually
are, exposed to "low levels" of radiation. (19)
As a general principle, any exposure to radiation should be
avoided unless it can be justified in terms of some overall
benefit. Even then, the exposure should be kept as low as
possible. (12,20) In addition, there are regulations setting
limits on the maximum dose that workers and/or the public can be
exposed to. Unfortunately, most of these regulations were set
before establishment of the principle that there is no safe
level. As a result, most radiation use technologies
developed under standards that can now be seen as inadequate. It
is, however, very costly both in economic terms, and, more
importantly, in terms of the safety image of these industries,
to admit the error. Considerable effort, which could be better
spent on radiation protection for workers and the public, has
gone into attempting to maintain the myth that exposures
within the limits are "acceptable."
A person is permitted to receive a maximum of 5 rem per year
external whole body exposure to radiation at work, or a
maximum of 0.5 rem as a member of the public, with certain
exceptions. A rem (roentgen equivalent man) is a measure of the
biological damage done by radiation. For gamma radiation,
electron beams, and x-rays, it is effectively the same as the
rad used to measure doses to food.
As with rad and Gy, the Sievert has now replaced the rem in most
countries except the United States. Since the Sievert is a large
dose compared with the likely worker dose, the millisievert
(Msv) is commonly used (0.001 Sievert); 1 rem equals 10 mSv.
The 5 rem (50mSv) limit was set in 1957. Since then, it has
become clear that exposure to this level of radiation
represents a completely unacceptable level of risk, using the
officially accepted levels of risk from radiation. A worker
receiving this dose each year would run a risk eight times
higher than is acceptable for a "safe" industry, and more than
double the risk faced by workers in high-risk jobs such as
mining. (21,22,23) A "safe industry" accepts that one worker in
10,000 will die each year; or, over a lifetime, one in 200
workers will die from an accident at work. Clearly, a risk eight
or more times greater than this is completely unacceptable.
For a worker to face radiation risks equal to risks in a "safe
industry," the exposure limit will need to be reduced to about
0.5 rem (5 mSv) a year. Even then, radiation workers will face
all the normal risks of other accidents and so will still be
doubling their risk of dying from the job. (24)
On top of this, these risks apply only to fatal cancers and
serious genetic damage over two generations. The nonfatal but
debilitating effects of other cancers, the less serious or long-
term genetic effects, and the general lowering of the quality of
health from radiation should not be forgotten.
The need for a drastic reduction of the dose limits, by at least
a factor of 10, is reinforced by the more recent scientific
evidence on the risks of radiation exposure. The national
standards and the risk estimates are usually based on the
recommendations of the International Commission on Radiological
Protection (ICRP), a self-appointed body of experts closely
identified with the nuclear industry. (14,25) Two recent
international reviews of the scientific literature have put the
risks between two and 10 times higher than does the ICRP.
(26,27)
Further evidence suggests that the risks may be higher still.
(28,29,30,31,32) Studies of Japanese survivors of the atomic
bombings in 1945 show a higher-than-expected incidence of
cancer, and the dose of radiation they received is less than was
previously believed.
The most recent evidence from studies of nuclear workers in the
United States and the United Kingdom indicates that the risk is
probably four to six times, but could be as much as 15 times,
greater than estimates by the ICRP. (32)
New Regulations?
In these circumstances it might have been expected that the
changes to regulations being considered by the United States
Nuclear Regulatory Commission (NRC) (33) and by almost all other
countries would have revised and improved standards for
radiation protection. Unfortunately, the reverse is the case. In
some significant ways, these new regulations relax the already
inadequate standards currently in force. (22,34)
Under the new ICRP-based system for calculating worker doses
from exposure to different parts of the body, the permitted dose
to a number of organs is to be allowed to rise by two to eight
times the current limits (See Table 10 - not included here.)
Most of the limits on amounts of particular radioactive
materials that a worker can absorb are also relaxed, in some
cases quite dramatically. (22)
These relaxations are taking place despite the private view of
many within even the nuclear establishment that exposures need
to be below 1 rem (10 msv) to be considered acceptable. (35)
Are Design Standards for
Food Irradiation Plants Adequate?
Clearly, in these circumstances, food irradiation technology
will be introduced into a regulatory framework that does not
provide adequate protection for radiation workers. Once
established, the technology will be yet one more reason why
improvements cannot be made in the future. It will undoubtedly
then be argued that changes will cost money and jobs.
Several eminent scientists in the field of radiation
protection have argued for a new limit for radiation
technology of 0.5 rem (5 msv), which should be the maximum a
worker is likely to receive from all normal operations
involving exposure to radiation. (36,37) Unions in the United
Kingdom and Canada have called for a phased reduction of all
radiation exposures to below this limit. (38,39) The need for
lower limits was recently endorsed by the International
Chemical and Energy Federation, representing most of the
western world's unions in this field. (40)
For most purposes, a 0.5 rem (5 mSv) limit is already
feasible. (19,21,41) In the case of a new technology such as
food irradiation, the plant can be designed to ensure that the
limit is not exceeded.
These measures will not, as already indicated, remove all risks,
but they would begin to bring these risks into line with those
faced in other industries. Just like consumers, workers need to
be allowed to make informed choices about the risks and to have
adequate protection laid down by a framework of regulations.
Lest these concerns be thought of as peripheral, it should be
noted that in 1986, the NRC revoked the license on the Rockaway
food irradiation plant of Radiation Technology, Inc., for
violations of worker health and safety regulations that could
have caused serious overexposure of some of the work force. (42)
The NRC concluded that the violations
"... were wilful and that numerous management and operations
personnel wilfully provided false information to the NRC thus
demonstrating a pattern of wrongdoing so pervasive that the NRC
no longer has reasonable assurances ... that the licensee will
comply with NRC requirements and that public health and safety
will be protected. 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." (43)
Radiation Technology, Inc., has been cited 32 times for various
violations, including throwing radioactive garbage out with the
regular trash. (44) The most serious violation involved
bypassing an interlock safety device that prevents people from
entering the irradiation cell during operation. (45) In 1977,
one worker received a near lethal dose of radiation. (44) The
NRC investigation found that Dr. Martin Welt, the company's
founder and president, ordered that the interlock system be
bypassed and that he and other senior managers directed
employees to give false information on the matter to the NRC
investigators. (43)
Under pressure from the NRC, Martin Welt resigned as president
but retained his stockholding in the firm and will continue to
do planning and consulting work for it. (46) The Department of
Energy has appointed Dr. Welt to a job, at $100 per hour plus
expenses, as advisor to the advisory committee to plan the six
DOE-funded demonstration irradiation plants. (46)
The Radiation Technology worker over exposure is not an isolated
case. An Isomedix worker received a dose of about 400 rads when
he entered the radiation chamber in Parsippany, New Jersey, on
June 13, 1974. The worker received a dose considered lethal for
70% of people so exposed, but prompt hospital treatment helped
save his life, and he was discharged from the hospital on July
27, 1974. (47)
Environmental Safety and Controls
Many workers live close to their jobs. They and the rest of the
community face particular hazards from the operation of the
plant and the transport in and out of the highly radioactive
sources used.

Coverups have also been alleged at other irradiation companies.
A nine-count federal indictment issued on June 24, 1986, charged
International Nutronics and company officials Eugene T.
O'Sullivan and Bruce J. Thomas with the coverup of a radioactive
spill in December 1982. (48) International Nutronics formerly
operated a radiation sterilization plant in Dover, New Jersey.
On December 4, 1982, International Nutronics employees found
several inches of radioactive water covering the floor of the
plant because a hose had blown out and was leaking radioactive
water from a pool that stored cobalt 60. (49) Approximately 600
gallons of contaminated water leaked from a pool that held about
500,000 curies of cobalt 60 when the source was not in use. The
water in the cobalt 60 pool was contaminated as early as 1974 by
one or more broken cobalt 60 sources. (50)
Company officials ordered workers to clean up the spill without
protective equipment, and some of the water was carried in
buckets to a shower stall and dumped down a drain into the Dover
sewer system. Workers were not given proper protective clothing
during the internal cleanup, and they were asked to move
radiation badges from belt level up to their collars so that the
badges would not reveal the true level of their radiation doses.
(51) Contaminated water was poured down the shower stalls into
the sewer system in violation of requirements to ship
contaminated water to a radioactive waste site. Company
officials did not inform the NRC of the accident, as required by
regulations, and by the time the NRC learned of it about 10
months later through a whistle-blowing worker, radioactive
contamination was found outside the building. (52) The plant is
located in a densely populated area, within 100 feet of both
residences and a major highway. (53)
Records of the operation of a demonstration food irradiator in
Hawaii and radiation sterilizers owned by Isomedix and Radiation
Technology offer further evidence of leakage problems in cobalt
60 plants. The Hawaii development irradiator was established by
the Atomic Energy Commission and the Hawaii State Department of
Agriculture in 1967 to research papaya irradiation. The first
shipment of cobalt 60 arrived from Brookhaven National
Laboratories in 1967. It was discovered that the source was
leaking after it was installed in the storage pool inside the
building. They dropped a shipping cask through the roof plug
opening into the source pool to retrieve the damaged source. The
source pool water contaminated the outside of the shipping cask.
and the radioactive water dripped onto the roof, spreading the
contamination. Despite some efforts to clean up the site, during
which the machine room, tools, and workers' clothing became
contaminated, problems persisted.
The facility operated until 1973, when funds were no longer
available, and eventually the cobalt 60 source was removed and
transferred to the University of Hawaii. The Hawaiian
legislature allotted $385,000 to decontaminate the facility and
convert it for other uses in 1979. A contractor discovered
cobalt 60 contamination on the lawn at the site on March 23,
1980. Experts believe that at one meter from the contaminated
area of lawn, approximately six b eight feet, a person would
have been exposed to the equivalent of 7.5 chest radiographs per
hour. The public was apparently at risk for many years from the
original accidental releases in 1967. (54)
Isomedix, Inc. had another leaking cobalt 60 source in 1976,
(55) and Radiation Technology was fined by the NRC for a leaking
cobalt 60 source whose endcap loosened in 1975. It had been
sealed in a pipe and stored at the bottom of the pool. (56)
Despite industry claims, cobalt 60 sources can and do leak.
Isomedix, the largest radiation sterilizing company in the
United States, has been cited by the NRC for allegedly (a)
overexposing workers to radiation, (b) failing to post radiation
areas, (c) allowing food and cigarettes in the same areas as
radioactive materials, (d) operating the facility without
authorized personnel physically present, and (e) failing to
adequately monitor the water disposed into sanitary sewage
systems. (57,58) The last violation was discovered when former
workers advised the NRC that Isomedix had conducted unsafe
practices, such as disposing of contaminated water from the
cobalt 60 pool by dumping it into a toilet connected to the
public sewer system. The NRC verified that a pipe leading from
a toilet was measurably contaminated in 1979. (58)
Other radiation sterilization plants have suffered fires in the
irradiation rooms. In one case, at Becton Dickinson, a product
fell off the conveyor, and when the heat of the source caused it
to ignite, the automatic sprinkling system failed to extinguish
the fire.
In short, the history of the irradiation plants already in
operation leaves much to be desired. What assurance can we have
that operation of future plants will be better controlled?
 
The Food Industry?
The food industry is the largest in the United States in terms
of shipments and the third largest in terms of contribution to
gross national product (GNP). Some 66% of all the food produced
by 2.5 million farmers is processed by only 20,000 manufacturing
companies before being sold through half a million distributing
companies. Many of the manufacturers are small. Ninety-six
percent have fewer than 100 employees. However, the 700
companies who employ more than 100 people have about 80% of the
business. In terms of any particular food, the business can be
dominated by even fewer firms. In most cases, fewer than 20
firms will control about 90% of a specific food market. These
firms are both large and powerful. While profits in farming have
been steadily declining, those in manufacturing have risen.
There have also been mergers and takeovers, so that the whole
processing industry is dominated by fewer and fewer large
corporations, each producing a wide range of food products. The
20 largest corporations now control nearly 30% of the food
market as a whole.
In the food distribution sector we find a similar picture. There
are three main channels through which we buy our food: the large
retail chains, which increasingly market their own brand or
"generic" brand products; the small independent stores, many of
which have entered into cooperative buying arrangements to get
better deals from the food manufacturers; and the restaurant and
institutional food service trade, which has about 15% of the
total food sales in the United States. Approximately 50% of food
in the retail stores reaches us through only 40 companies. The
20 largest grocery chains have 37% of the total volume of food
sales. They buy direct from manufacturers. The 20 largest
wholesalers dominate the remainder of the trade, which goes
through the independent grocers. (3)
The concentration of supermarket power is even more dramatic in
particular cities. In any one city, the four largest retailers
will frequently control 60% or more of all food sales. A small
manufacturer finds it very hard to market a food product in
Washington, D.C., if Safeway or Giant refuses to put it on the
shelves, or similarly in Denver if it is rejected by King
Soopers (Kroger) and Safeway. The retailers can also dictate the
price, quality, packaging, labelling, and formula to be used in
the processed foods that the manufacturers supply. In some
cases, the retailers are also manufacturers. The largest eight
supermarket chains supply 90% of their sales from foods they
manufacture themselves. This market power may not always be used
against the large manufacturers, but it is often used against
smaller food processors, who have little choice but to accept
the terms the supermarkets dictate.
By contrast, the import/export trade accounts for only 1% of the
domestic market. (3) Even so, this is over 10% of the total
world trade in food, second only to that of the EEC, which has
17% of the total. As we noted earlier, international trade is
becoming increasingly important in providing exotic and
out-of-season foods from other countries.
Advertising plays an increasingly important role in the food
market. Again, this is dominated by the large corporations,
where the 100 largest do 92% of all advertising and 99% of all
network television food ads. (3)
Even this picture understates the full extent of concentration
of market power. The largest firms are linked to each other in
a network of overlapping stockholders, directors, financial
ties, and other business contacts. (3)
The United States is not alone. A similar concentration of power
exists in other developed countries. In Britain, for example,
all farmland is owned by about 2% of the population. In food
manufacturing, there are about 5,000 firms but the ten largest
companies account for one-third of all sales. Approximately two-
thirds of the trade in some food manufacturing sectors, such as
oils, fats, biscuits, and bread, is controlled by the top 10
companies. In food retailing, the top nine companies control
over half of the market. The number of retail outlets nearly
halved between 1974 and 1983. Even in catering - a sector famous
for its small businesses - the top 10 companies control nearly
60% of the contract catering market. (4)
Many consumers believe that retailers and manufacturers of food
all think alike. They don't. Ever since the 1970s, they have
been fighting an often bitter battle between themselves over
prices and profit margins. Retailers currently hold the sway.
With so few retailers dominating the consumer market in any
city, what manufacturer can afford to drop a contract with them?
In the context, irradiation can be seen to offer manufacturers
a chance to regain the advantage. If you make or deal in
perishable goods, a technology that leaves the goods looking
fresh and fine and that extends their shelf life could be a
bonus. Irradiation also offers food manufacturers a chance to
intervene in some parts of the food chain where they do not at
present; irradiation could give some companies a chance to gain
markets in fresh food. Shelf life of vegetables and fruit could
be extended to fit into new one-stop shopping patterns. Already,
smaller manufacturers, producers, farmers, and retailers are
being squeezed out. This process, while allowing some consumers
to benefit, reduces the range of choices to many others.
Tensions between sections of the food trade are nothing new.
What is new for the food business is the likelihood that by the
end of the 1990s, there will be no trade barriers between the
member countries of the EEC and high tariff walls and quotas.
There would also be uniform regulations about what is and is not
acceptable for all European food, including standard rules for
irradiation. This would be ideal for the big American and
European companies wanting to trade in food across the EEC, but
it has implications for the thousands of food workers who might
lose their jobs. (6)
Clearly, the food magnates have their eyes on important
matters. Big takeovers and battles for market share can lead to
astronomic returns. Amid the merger mania, it is easy to forget
food workers and consumers - especially those on low incomes.
(7)
Thus, one answer to the question "who wants it?" could be the
large manufacturers, especially those engaged in international
trade between Europe and the United States and with the third
world. To be able to store food longer, with an acceptable
appearance of freshness, might help the processing industry's
stockpile and increase its power in relation to the retailers.
However, this hardly seems a compelling reason to take on
irradiation technology with all its uncertainties.
Another, more compelling, reason concerns the ability of
unscrupulous importers, domestic packers, and processors to
conceal contamination of some foods caused by poor hygiene in
handling and processing. As we saw in Chapter 5, this is already
a major problem within the very small volume of trade in
irradiated food that is allowed at present.
Overall, however, there is not much evidence that the food
industry actually wants irradiation. Listening to the
pro-irradiation lobby, we may be forgiven for thinking that the
whole food industry is waiting for it with bated breath.
Certainly, some of the 33 companies that established the
Coalition for Food Irradiation in January 1985 may have seen it
as helping their interests. However, a number of these have
indicated that their participation does not imply endorsement of
the process, only a desire to keep abreast of developments in
the field. For example:

"Heinz does not irradiate any of its products - nor do we have
any intention to do so in the foreseeable future. Our support of
food irradiation to date has consisted of membership in a group
that is seeking to determine, through research, if food
irradiation has any long-term potential for processed food
products." (8)
On the other hand, there is evidence from a British survey that
the food manufacturing industry is by no means united, most
frequently undecided, and in many cases opposed to the use of
irradiation technology at this time, for many of the reasons set
out in this book. In Britain, two of the five largest retailers;
Marks & Spencer and Tesco, have indicated that they do not favor
irradiation at this time, in one case because it does not fit in
with the company policy of providing fresh food on a fast
turnover, an in the other because of dissatisfaction with the
assurances provided so far on safety. The concern from Tesco is
all the more telling because that company has been involved with
the British equivalent of the CFFI, a "Working Group on Food
Irradiation" run by the Food Industries Research Association
(FIRA) at Leatherhead in England. The British Frozen Food
Federation has also expressed concern that the current ban on
irradiation should not be removed. (10) The survey we undertook
in Britain followed a year-long campaign conducted through the
media that attempted to convince the public that both the food
industry and consumers wanted irradiation. There were statements
like these:
The food industry wants irradiation. (11)
The food industry is optimistic that the government will give
broad approval for low-level irradiation of fruit and
vegetables. (12)
Food irradiation will be ushered in by food retailers rather
than manufacturers. (13)
The Meat Trades industry is hoping for Government approval for
irradiation of food. (14)
The consumer wants fresh foods, they want long shelf life
foods,they want more natural foods ... this [irradiation] is a
way of providing that. (15)
There is no evidence to suggest that irradiation of food is
harmful to humans. (16)
I have a dream that for once the public will take the
scientists' word and welcome the process as a great step
forward. (17)
From those media quotes we get these impressions:
1. It is the food industry, and retailers in particular, who
were pushing for food irradiation.
2. Consumers wanted irradiated food because it would last longer
and be free from bacteria, thus making it more "safe,"
"natural," and "fresh."
3. The scientific community was fully convinced that there are
no safety problems associated with irradiated food.
On the other hand, the feedback we had been getting from both
consumers and some sections of the food industry did not support
this, as the graphs of responses to the survey clearly show. The
survey found only one leading company in favor of irradiation,
many with reservations, and some who had already decided against
it (Figure 4).
The survey also found that most of the organizations surveyed
recognized a need for increased regulation and control of the
technology if it is to be permitted (Table 13 - not included
here).
Concern was not confined to consumer organizations. Many in the
industry felt these additional controls would be needed if
irradiation were introduced. In addition, many industry
organizations and all consumer groups felt there was a need for
a public education program covering the risks and benefits of
irradiation before it was introduced. (9)
These findings of widespread concern are reinforced by a
survey of Trading Standards Officers throughout the United
Kingdom. (18)
It seems from the London Food Commission survey that the food
industry had not decided about irradiation. While some major
firms in the food industry saw some benefits in irradiation,
others, especially retailers and smaller producers, had
reservations.
Any advantages for smaller manufacturers and retailers from the
use of irradiation may well be offset by increasing their
dependence on the large manufacturers, who alone can afford to
invest in irradiation plants. It is also unlikely that smaller
retailers can cope with consumer reaction if the large
supermarket chains turn the process down.
For the farmers, as we have seen, there are no benefits. It is
not they who would control the technology if it gained
widespread use. They would be even more dependent on the food
processors. In the case of third world farmers, there is already
enough evidence to show that few have benefited from the
technological advances of the so-called green revolution. The
lesson is that high-level "Western" technology merely allows
multinational agribusinesses to increase its control over the
process of growing and marketing food on a global scale. Even if
irradiation could deliver on all its technological promises, the
belief that this would actually benefit those in need in poor
countries is a triumph of hope over experience - a delusion that
few who understand the nature of the food industry in the 20th
century would subscribe to. (19)
The Irradiation Industry?
Pressure to permit irradiation is coming from the irradiation
industry.
The food industry has an interest in the process but they are
very cautious. (Robert L. Lake, Chief of Regulation for the FDA
Bureau of Foods, 1983 ). (20)
The plain fact is that pressure for food irradiation has been
coming not from the food industry but from those who have
already invested in irradiation plants, whether for food or for
medical and other products. These companies see a bonanza if
irradiation permits are given and the food industry and
consumers can be persuaded to accept the process. Given the high
costs and inevitable lead times before competitors could enter
the field, these firms stand to make a killing if there is a
rapid takeup of food irradiation.
Many public statements on the benefits of irradiation have come
from people either directly involved with the irradiation
industry or with close connections to it. Many of these
statements also appear to be made as much with an eye on the
stock market value of the companies as to the effect on public
opinion. In several instances, they also appear to be part of
the campaign by these companies to influence government
decisions to permit irradiation.
In Britain, statements on the benefits of food irradiation were
linked throughout 1985 to hints that the government
advisory committee was about to give the process its approval.
A similar pattern emerges from analysis of the press reports
from the United States. There, as reported in the press, two
major irradiation firms linked the benefits of the process with
impending approval by the FDA.
In Britain, a small working group on food irradiation was set up
at Leatherhead with representatives of the following companies:
Isotron, the company with a virtual monopoly position in the
field of gamma irradiation facilities capable of handling food;
Radiation Dynamics, the leading user of electron beam and x-ray
sterilization techniques; Unilever plc, one of the major food
companies with strong Dutch connections; and the Leatherhead
Food Industries Research Association.
Two of the leading British spokespersons on the advantages of
food irradiation quoted in the media have been Alan Holmes of
Leatherhead and Frank Ley of Isotron.
Frank Ley has worked in the food research department at
Unilever and as principal scientific officer at the United
Kingdom Atomic Energy Authority, leading a team investigating
the irradiation of food. In 1970, he left to set up a private
irradiation company. (21) In September 1983, Ley, now the
marketing director of Isotron and a leading shareholder in it,
was appointed as industrial advisor to the Advisory Committee.
Several British Members of Parliament introduced a motion in the
House of Commons pointing out their concern over possible
conflict of interest (see Appendix 2). Specifically, they noted
that predictions of the main recommendation of the
Advisory Committee had been widely leaked, not least by Frank
Lev; that the company had raised capital through a flotation on
the stock exchange, while the committee was sitting, to build a
new irradiation plant (Isotron already had existing production
spare capacity of 46% at its four existing plants); (22) and
that there had been a rise in the capital value of Isotron when
stories in the financial press linked the future of the company
to the impending recommendations of the Advisory Committee. The
motion called for an investigation of share dealings in the
company (see Appendix 2). (23)
Clearly, it does not help public acceptance of the impartiality
of the Advisory Committee report to have suggestions of conflict
of interest. This would be of little consequence if the
scientific evidence put forward by the report were impeccable
and verifiable. As we have shown, this is far from the case.
There have also been difficulties with the development of the
food and radiation industry in the United States. Analysis of
press reports in the United States indicates that the most vocal
spokesperson for food irradiation has undoubtedly been Martin
Welt, former president of Radiation Technology, Inc. Radiation
Technology has four plants in New Jersey, Virginia, North
Carolina, and Arkansas. One of them was the subject of scandal
when its license was revoked in 1986. Various reports quoting
Welt throughout 1983 hinted that the FDA was about to give
clearances for foods that Radiation Technology had petitioned
for permission to irradiate. The other major company in the news
in 1983 was Isomedix. It now has a network of eleven irradiation
facilities in seven states, Puerto Rico, and Ontario, Canada. In
July the company raised about $16 million in capital through a
share flotation to finance the cost of expansion, including
construction of an additional three facilities. (24)
In April 1984, the Securities and Exchange Commission of the New
York Stock Exchange uncovered insider trading involving the
shares of both Radiation Technology and Isomedix, linked to
favorable reports on both companies in the Wall Street Journal.
(25) Martin Welt, though not implicated in illegal share
dealings, was required to resign as president of Radiation
Technology, Inc., in 1986 by the NRC in order to obtain a
license reinstatement for Rockawa plant. He remains a major
shareholder.
"Atoms for Peace" - The Role of the Nuclear Industry
Even this level of corporate vested interest does not explain
the international pressures. Food processors and irradiation
companies are clearly opportunist, but they are not the prime
motivators of the international program that is currently
selling the benefits of food irradiation and systematically
ensuring its acceptance on a global scale.
To understand these pressures, we need to go back to the origins
of the technology in the "atoms for peace" program of the 1950s.
This was taken up internationally through the IAEA and by a
joint committee with the WHO and FAO as early as 1961. (27) As
we have seen, the IAEA has spent a considerable portion of its
budget on promoting the international scientific consensus on
the benefits and safety of irradiation as a food processing
technology. The latest phase of this program involves systematic
promotion of approvals for the process by governments and key
organizations that can influence public opinion.
In the United States we have seen that it is the DOE - the
agency responsible for most of the nuclear energy and weapons
industry plants - that is providing at least $10 million to
finance demonstration food irradiation plants using cesium 137
rather than the potentially more economic, efficient, and
versatile x-ray technology.
Why? If the benefits are as great as claimed, why the need for
the hard sell? Who else stands to benefit?
The main gamma ray source used worldwide for food irradiation is
cobalt 60. It is manufactured by placing nonradioactive cobalt
59 in the core of a nuclear reactor for about 18 months. The
process is carried out by only a handful of nuclear power
companies. Atomic Energy of Canada, Ltd. (AECL), produces about
90% of the world's industrial cobalt. The supply has been
outstripped by demand in recent years, and AECL has had to draw
up an allocation schedule. The company is planning to increase
production threefold, with a new facility near Ottawa, but even
so, the supply is unlikely to be sufficient to meet a rapid rise
in demand such as that we would experience if food irradiation
were to gain widespread acceptance.
In these circumstances, the alternative isotope, cesium 137,
becomes an attractive proposition, even though the gamma rays it
emits are of a lower energy level and, as we have seen, it may
be more dangerous to handle. But, what is the source of cesium?
Again, it is a byproduct of nuclear reactor technology, this
time produced mainly as a fission product in spent fuel rods-in
other words, a highly radioactive waste product and one which,
because of its 30-year half-life, poses serious problems for
those trying to find a solution for the disposal of nuclear
wastes. It is the cesium wastes that the DOE is most eager to
find a use for. Could it be that the whole program to promote
food irradiation is little more than a thinly disguised attempt
to find a commercial use for radioactive wastes? This hardly
seems plausible; yet, the early texts on food irradiation make
exactly this kind of connection. (28) Since then, food
irradiation has taken on a life of its own, but the original
pressures remain, and perhaps help to explain some of the
irrational behavior of the agencies promoting it.
There is currently no reprocessing of commercial spent nuclear
fuel in the United States. What reprocessing occurs is done to
extract plutonium for the nuclear weapons program. France and
Britain, however, do undertake reprocessing, at the Sellafield
plant in Cumbria and The Cap La Hague plant on the Brittany
coast. In addition, for both the United States and Europe, there
is the possibility that radioactive cobalt, also produced as a
waste product by the activation of the cobalt in the steam
generators of pressurized water reactors, might be worth
refining commercially to meet a shortfall in demand for
radioactive sources if food irradiation facilities were to be
built in large numbers.
Even if there is no direct benefit to the nuclear industry from
disposal of problematic nuclear wastes, there are clearly
benefits to the image of the "atoms for peace" program from
having another "beneficial" use of radiation. Who can dispute
that the beleaguered nuclear industry urgently needs a boost to
its tattered image in this decade that has seen Three Mile
Island, Chernobyl, growing evidence of childhood leukemias
around the British reprocessing plants at Sellafield and
Dounreay, and not a single new order for a nuclear power plant
in the United States since 1978?
However, the underlying concern of many who have monitored the
activities of the nuclear industry over the years is that the
artificially created need for cesium may be used to justify
reprocessing of spent commercial fuel in the United States,
thereby making the civilian plutonium available for the
production of even more nuclear weapons.
Industry Pressure Points
As we saw in Chapter 6, the food industry is by no means united
in wanting food irradiation. There is an underlying struggle for
power between processors and retailers. While irradiation might
offer advantages to some processors, there are also benefits to
be gained from clear statements of policy opposing irradiation
at this time. We would argue that responsible food companies
should be in the forefront of the campaign for a moratorium on
irradiation until there are tests that can detect irradiation,
so that consumer choice can be guaranteed and the existing
abuses stamped out.
In Britain, the national Food and Drink Federation (FDF),
representing the major food companies, has stated that it is no
longer seeking a removal of the ban on irradiated food in
Britain until such time as tests are developed that can detect
irradiation. This follows earlier statements from the British
Frozen Food Federation, the Farmers Union, and two of the
leading supermarket chains. (14) Some companies in the United
States have already taken a position. Arrowhead Mills, which
produces organic foods in northern Texas, has promised that it
"will not use (or allow to be used) any form of irradiation on
the foods it sells." Citizen groups are eliciting the stance of
other food companies, and eventually hope to extract similar
promises from all of them.
Some leading food companies have joined with the irradiation
companies to form the Coalition for Food Irradiation. As of
February 13, 1986, members included Alpo Petfoods, Inc.,
American Meat Institute, Beatrice Companies, Inc., CH2M Hill,
Campbell Soup Co., W. R. Grace & Co., Del Monte Corp., E. I. du
Pont de Nemours & Co., Inc., Emergent Technologies, Inc.,
Rockwell International, Gaines Foods, Inc., General Foods,
George A. Hormel & Co., Gerber Products Co., Heinz USA, Hershey
Foods Corp., Isomedix, Inc., Kraft, Inc., Mars, Inc., McCormick
& Co., Inc., National Food Processors Association, National Pork
Producers Council, Northwest Horticultural Council, Oscar Mayer
Foods Corp., Papaya Administrative Comm., Produce Marketing
Association, Ralston Purina Co., Sandoz Nutrition, Stokely USA
Inc., Stouffer Foods Corp., Thomas J. Lipton Co., United Fresh
Fruit and Vegetable Association, and Welch Foods Inc. (15) #
While this body seeks to promote the benefits of irradiation, it
is clear from correspondence with these companies that not all
of the coalition members are intending to use the process. As a
Thomas J. Lipton spokesperson wrote in November 1986:
"We recognize that there is a great deal of confusion associated
with food irradiation. Therefore we are participating in the
Coalition for Food Irradiation, a group comprised of scientists,
food industry representatives and consumer advocates. We hope
that through this coalition, we will better understand the
advantages and disadvantages of food irradiation as well as any
concerns regarding its use. At present, Lipton does not
irradiate any food products. We are not involved in any food
irradiation research, nor is any planned." (16)
# Since this list was compiled, a number of these companies have
withdrawn their membership from the coalition for Food
Irradiation, indicating that companies can be influenced by
consumer opinion.
It is not clear which "consumer advocates" Lipton is referring
to. As far as we are aware, no responsible consumer advocate is
in favor of irradiation at this time.
It is important that people write to food companies, especially
those involved in the Coalition for Food Irradiation, to find
out exactly where they stand and to let them know of the
widespread nature of the public concern and of the full range of
issues that concern critics of the process. Many people in the
food industry have been convinced that safety is the only issue
and that this has been settled by the various expert bodies.
Citizens Against Irradiated Food (CAIR), based in Ohio, wrote to
food processors to elicit information about their current and
planned irradiation practices, and received answers from 44
companies (see Appendix 3). Only McCormick replied that it was
irradiating products, although not for direct retail sales
(which would require a label to consumers). Beatrice-Hunt/Wesson
admitted that it had used irradiated spices, but several
companies did not respond to the inquiry regarding the use of
irradiated ingredients. Campbell Soup Co., Heinz, McCormick, and
Gerber wrote that they are conducting research into food
irradiation. Several companies considered the technology
promising or safe (Beatrice-Hunt/Wesson, Campbell's Soup
Company, Carnation, R. T. French Co., Holsum Foods, Thomas J.
Lipton, Inc., and Ralston Purina). (17)
The majority of manufacturers do not yet use irradiated foods,
and most have taken no position regarding the process. Hormel
stated that consumer acceptance of irradiated foods is a
"crucial issue." "Unless consumers are willing to purchase
irradiated foods, grocers will not stock them and food
processors will not invest in the technology". (18) Labelling is
critical. If consumers do not know that their food or food
ingredients were irradiated, then the problem of consumer
rejection can be avoided. Manufacturers can then be more certain
that the major food stores will carry irradiated products.
United States grocers and supermarket chains are apparently
taking a more cautious approach to food irradiation. When
Isomedix test-marketed irradiated mangoes in the fall of 1986,
the major food chains refused to carry the product in Florida.
(19) Store picketing in Southern California in spring 1987 also
stopped test-marketing of irradiated papayas. (20) The lesson
from Britain is that one of the most sensitive pressure points
in any country is the large retail companies. None of them is
likely to declare in favor of irradiation and risk losing trade
to its competitors. At the same time, there may be a commercial
advantage to be derived from an early decision not to use
irradiation technology. The British and Canadian Marks & Spencer
Companies have stated that they intend to maintain their policy
of "providing quality fresh food on a fast turnover" and so had
no use for irradiation. There are a variety of ways that
consumers can exert pressure on supermarkets to join the call
for a halt to irradiation at this time, e.g., letters to the
company president, leafleting and petition-collecting outside
selected supermarkets, and encouraging customers to hand in
model letters and cards at the checkout counter and to add their
own comments in letters to the company. In the event that some
supermarket chains introduce irradiated foods, some people might
even consider organizing consumer boycotts.
Health food stores were among the first to oppose irradiation.
Santa Rosa Community Foods wrote the FDA regarding food
irradiation:
"In essence, we feel that until the long-term safety questions
are answered, it is dangerous to allow use of this process. What
we find more important, as consumers and as distributors of
foods, is the proposal not to label irradiated foods as such
.... As responsible business people we demand that you require
accurate labelling of all foods exposed to the irradiation
process, through all the generations that that food product is
used." (21)
At the same time, some health food stores are merely part of
large corporations, and these need to be pressed to take a clear
stand on the issue and to help local campaigns by distributing
material calling attention to the issues of concern. Petitions
opposing food irradiation and demanding consumer labelling have
been circulated by some health food stores and food co-ops.
These were used both to educate consumers about the potential
hazard and to advise the FDA that consumers believed that the
FDA was making a mistake. On the other hand, food irradiation
promoters like the American Spice Trade Association wrote the
FDA that they were "encouraged... by the absence of a labelling
requirement for retail products." (23) The Almond Board of
California warned the FDA, "In fact, a special retail label
could be damaging ..." (23)
Robert Turner, International Promotion Director of the
Washington State Apple Commission, wrote the FDA:
 
"It is not necessary to add the irradiation of the foodstuff to
the existing label, or to create a new label identifying food
irradiation. In the case of possibly irradiated fresh apples for
insect control, the irradiation process could be compared to the
washing and waxing processes of apples which are also not
identified on any label attached to the fresh apples." (24)
The FDA April 1986 rule completely eliminated "food ingredients"
from labelling requirements, thereby exempting the irradiation
of any food item, once combined with another, from being brought
to the attention of consumers. (6) Dropping the wording from
labels in April 1988, and using only the "Radura" flower symbol
on whole foods, would leave most consumers unaware that their
food had been irradiated. It is clear that some sections of the
food industry are eager to prevent consumer knowledge of
irradiation, so as to prevent refusal in the marketplace.
Boycotts of companies irradiating foods are under consideration
by some groups, with McCormick frequently being suggested as a
target, since they admit to irradiating food ingredients
(spices) that are not labelled to the public. If certain
imported items, like papayas, become the test food for
irradiation, consumers will be urged to boycott all papayas, in
case food suppliers refuse to supply the necessary labels.
Even if labelling is made mandatory, enforcement will be a
problem. The FDA has admitted, "We cannot tell you at this time
how often each local grocery store will be inspected to
determine compliance or noncompliance with the labelling
requirements" regarding irradiated foods. (25) Local health
officials say they do not have the personnel to check grocery
stores, which they usually only visit once a year. There are
only 21 FDA offices, scattered in major cities, so they are
unlikely to be able to police stores regarding labelling.
 
Farmers
Farm organizations are potential allies in the campaign to
prevent needless food irradiation. Application of food
irradiation at the farm does not seem feasible. Even the
promoters of food irradiation have admitted that irradiated food
will be more expensive. Farmers are often blamed for rising food
prices, when the benefactors of the price rises are processors
and distributors, not the farmers. In addition, the ability to
stockpile foods such as grain for longer time periods could
adversely affect farm sales of new crops.
Farm organizations have already been approached with claims that
food irradiation will help the farmer, and some groups have
believed these claims. The American Farm Bureau Federation
represents more than 3.3 million member families, who help
produce virtually every commodity in the United States. John C.
Datt, Secretary and Director of the Farm Bureau, wrote the FDA
in 1984, stating:
"Agribusiness must be allowed to use the most modern
technological advances if we are to continue to be able to
provide consumers with the most wholesome food products at the
most affordable prices. While we approve of FDA's authorization
of the use of the irradiation food process, we are not
necessarily advocating its use. Once the technology is
available, its use will be determined on a commodity by
commodity basis." (26)
The National Pork Producers Council has promoted pork
irradiation very actively. (27) Many of their state chapters
wrote to the FDA supporting irradiation, and the group lobbied
for construction of food irradiators for pork. Despite recent
regulations approving pork irradiation to control trichinae, no
one was using the process as of spring 1987. In fact, Dr. David
Meeker, staff scientist for the National Pork Producers Council,
told the NCSFI that "It is more useful to test for trichina than
to irradiate 100% of pork to get at the 0.6% [that might be
infected.]" (27,28)
Apparently, the National Pork Producers Council wanted to insure
that all trichina control options were kept open, rather than
switch the industry to that particular technology. Their initial
support for irradiation helped promote the DOE project destined
for Ames, Iowa, which is intended to irradiate pork. This
project will provide a taxpayer subsidy for processing, but no
major meat companies have invested in their own facilities yet.
In Britain, farmers' and growers' organizations are opposed to
the introduction of irradiation. Farm groups who support food
irradiation should be asked to reconsider, and those that have
not taken a position asked to review the hazards and oppose the
process.
 
Unions
Food handlers in a variety of industries may eventually be
expected to become involved in or work near food irradiators, so
food workers are a natural constituency for concerns about
worker safety. Workers are also consumers. Since all union
members need to eat and feed their families, all unions can be
asked to consider this issue.
The Food and Allied Service Trades Department (FAST) of the
AFL/CIO has taken the view outlined earlier in this book that
irradiation should be studied as a possible substitute for more
toxic chemicals in the disinfestation of fruit, but it is
doubtful about its use as a way of preserving food. As Debbie
Berkowitz, FAST Health and Safety Director, has said:
"It is unclear whether any benefits in this area outweigh the
risks to workers and consumers. We are, like our British Trade
Union colleagues, deeply concerned about the worker safety
aspects and feel the whole issue needs further study before any
widespread employment of irradiation technology. In
addition, our members being consumers and residents, we also
have deep concerns about consumer risks from consumption of
irradiated foods and transport of highly radioactive materials
around the country." (29)
American labor unions have been in the forefront of some
campaigns about the transportation of radioactive materials. In
Britain, the Food Irradiation Campaign has the endorsement of
several key national unions involved in the food trade,
including the Transport and General Workers (T & GWU), General
Municipal and Boilermakers (GMB), Bakery Food and Allied
Workers (BFAWU), The Union of Shop Distributive and Allied
Workers (USDAW), and the National Union of Public Employees
(NUPE). Internationally, the European Committee of Food
Catering and Allied Workers Union within the International Union
of Foodworkers (ECF-IUF) has insisted that
"Techno-physiological processes should only be used when, first
they present no health hazards and secondly when they are
technically indispensable." (30)
And on consumer protection in general, it states:
"The ECF has considerable reservations in this field as to
whether consumers really can be protected against insidious
deterioration in quality and fraudulent practices through
labelling obligations and the recognition of quality brands."
(10)
There is considerable scope for raising many of the concerns
about irradiation through the labor movement. A resolution was
passed at the California state Labor Federation of the AFL/CIO
in 1986, opposing food irradiation, supporting the Bosco bill,
and demanding honest consumer labelling if food irradiation is
to be allowed in the future. (31) Similar resolutions have
already been passed by many local unions around the country, but
more are needed. This local union pressure can be used to alert
the international unions to the concern of their members and can
be used as part of the campaigns for legislation at municipal,
county, state, and federal government levels. Unions need to be
alerted to the proposals in the IAEA/FAO international marketing
strategy that suggest co-opting some trade union leaders onto
the national steering committees promoting food irradiation
technology. (32) It is not in labor's interest to be associated
with such pressures, but rather to be seen calling for further
study, greater safeguards, and a halt to further developments
until the many issues of concern have been resolved.
Consumer Organizing
The National Coalition to Stop Food Irradiation, based in
California, whose address is given in Appendix 5, serves as an
umbrella organization for many of the opponents of the process
in the United States. Local chapters and affiliated
organizations in most areas of the country can be reached
through the NCSFI.
Campaign efforts are being undertaken at local and national
levels to educate Congress, federal agencies, food processors,
food distributors, the press, and the general public about the
potential hazards of the process and to assert the right of
consumers to know how their food has been treated by requiring
an honest label. A great deal of effort goes into tracking food
irradiation activities by both industry and government and
raising the concerns at public meetings, some of which are those
organized by the Coalition for Food Irradiation in its attempt
to promote the technology.
Since everybody eats, most organizations can add food
irradiation to the list of their members' concerns. As
individuals learn about the potential hazards of this process,
they can bring this issue to groups in which they are already
members.
A couple of examples may help illustrate what can be done.
Roberta Kopstein and Rebecca Kirschbaum, both of New Jersey, did
just that within the National Council of Jewish Women. They
decided to launch a campaign within their organization that
would begin with the grassroots support of their local Essex
County division and build a record that could be taken to the
national organization.
First, they set up an environmental task force of the
4,300-member Essex County division of the National Council of
Jewish Women. The task force undertook a one-year study of food
irradiation and sponsored a forum, inviting both proponents and
opponents of the process. Even elected officials attending this
first forum went home vowing to fight installation of any more
irradiators, especially in their own backyards. Their concerns
were also aired on local cable television shows.
In April 1986, the National Council of Jewish Women formed a
coalition, the Women's Environmental Consortium of New Jersey,
with the Junior Leagues of New Jersey and the American
Association of University Women (AAUW), to create a broader
forum on issues of particular interest to women. Based on the
one-year study conducted by the National Council on Jewish
Women, food irradiation became the first forum topic. More than
500 leaders from government, religion, education, industry,
civic organizations, and the press were invited to participate
in a forum on November 18, 1986, presenting arguments for and
against food irradiation, and 101 attended. The issue will soon
be presented to the national organization.
Consumers United for Food Safety (CUFFS) was formed by concerned
citizens in the state of Washington after the FDA-proposed rule
alerted them to the possibility that irradiation would be
applied to foods. CUFFS members researched the food irradiation
issue and prepared educational materials to inform the public.
Then they turned to key organizations in the area, approaching
them to pass resolutions opposing food irradiation without
further research and demanding honest consumer labelling on any
allowed irradiated foods. The Group Health Cooperative of Puget
Sound, with 330,000 members, adopted such resolutions on April
27, 1985, and the Puget Sound Cooperative Federation (whose
members include many food coops) adopted two resolutions on
August 19, 1985. (33)


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