We are totally opposed to the introduction of the food irradiation industry into Australia. While we address the issues as put forward, by doing so we do not endorse the Application or the issues raised.
4.1 Safety of Irradiated Foods
We note that scientific opinion ‘currently’ suggests that under certain circumstances irradiated food is safe and nutritious. In our opinion an ambiguity exists in this statement. Could we conclude that this position may alter in the future as a result of implementing the DIAMOND model? We question whether Proposal P153 would apply to irradiated food and could therefore be utilised to further substantiate health and safety claims by monitoring the effects of irradiated food on human health? The Australian population should not be subject to health risk.
We note with great concern, at 4.5, the direct safety claim made in relation to irradiation.
As this issues paper relates solely to the irradiation of food, we challenge the assertion of the statement: ‘An irradiation process is characterised by a minimum effective dose and a maximum dose that does not result in significant or negative changes to a product.’
As stated by John W Gofman, MD Ph D: ‘What we do know with certainty is that irradiation causes a host of unnatural and sometimes unidentifiable chemicals to be formed within the irradiated foods, and that the number, kind and permanence of these foreign chemical compounds depends on the food itself and the dose of radiation.’ Dr Gofman is Professor Emeritus of Medical Physics at the University of California, Berkeley, author of ‘Radiation and Human Health’ and has spent over 20 years studying the effects of radiation on human health and was once one of the US Government’s most senior advisors on the issue.
Samuel S Epstein MD states: ‘The large scale irradiation of food, as proposed by the industry and administration, represents the largest prospective toxicological experiment in human populations in the history of public health.’ Professor Epstein is Professor of Occupational and Environmental Medicine, at the University of Illinois, Chicago.
George L Tritsch, Ph D, Roswell Park Cancer Institute, Buffalo, NY states: ‘I am opposed to food irradiation because it is clear that this process increases the levels of mutagens and carcinogens in the food. The inevitable consequence of this is that in two to five decades in the future, the incidence of cancer will increase from what we see now, in direct proportion to the amounts of irradiated food consumed…’
Food and water org
The Australian public has not been sufficiently informed about the health risks involved with this technology. We urge ANZFA to place the health and safety concerns of consumers ahead of trade and economic demands.
4.2 Nutritional Adequacy of Irradiated Foods
Irradiation destroys vitamins in food. According to a Parliamentary Library Legislative Research Service paper prepared by Dr R Panter, Science, Technology and Environment Group, 22 August 1986, entitled ‘Food Irradiation in Australia – A Short Discussion Paper’, there is significant destruction of several vitamins, especially the vitamins B1, C, B12, A, E and K resulting from irradiation of food. Furthermore, it added that ‘if an irradiated food is cooked at home, further vitamin losses will occur.’
In her article ‘Food irradiation and vitamin A deficiency – Public Health Implications’, Food Policy, vol 18, Feb 1993, pp 64-72 Leah Bloomfield gives an example of large-scale vitamin destruction associated with irradiated food: ‘irradiation of chick feed at 20 kGy resulted in losses of vitamins A and beta-carotene of 12.5% and 25% respectively; treatment of cat feed reduced vitamin A by 93% and beta-carotene by 6.3%. As the irradiation in this case was demonstrated on animal laboratory feed, vitamins then have to be added to ‘bring it up to the required laboratory specifications.’
We note the statement that ‘…fats undergo little change during irradiation even at doses over 10 kGy’. The CSIRO Food Research Quarterly 3 Sept 1985 reported, however, that as a result of irradiation: ‘The fat was also noticeably bleached and peroxide accumulated more rapidly in the irradiated than in the untreated fat.’
Adverse results in scientific research into irradiated foods have been suppressed and discounted in favour of more lenient and positive results. We note with utmost concern that the results of trials conducted by the National Institute of Nutrition, India have been retrospectively discounted. The results were published in the American Journal of Clinical Nutrition, 1975 in a paper entitled: ‘Effects of Feeding Irradiated Wheat to Malnourished Children’ by C. Bhaskaran and G. Sadasiran. A clinical trial was conducted in undernourished children who were fed wheat freshly irradiated at a dose of 1 kilogray. It was proven that ‘they developed polyploid cells and certain abnormal cells in an increasing number as the duration of feeding increased, and showed a gradual reversal to the basal level of nil after withdrawal of irradiated wheat. In a marked contrast, none of the children fed unirradiated wheat showed polyploid, and abnormal cells were of a significantly decreased number.’ These studies have linked irradiated food with leukaemia and abnormal development of white blood cells.
From the 1988 Report of the House of Reps:
Page 107 (5.119): ‘The researchers concluded that it is necessary to recommend that irradiated wheat be stored for 12 weeks before it can be considered safe for human consumption.’ This is to ensure that induced radioactivity is no longer present at levels harmful to human health.
Page 108 (5.120): ‘One study which the Committee’s advisers considered well designed also found increased levels of polyploidy cells in the bone marrow of animals fed freshly irradiated wheat but only at dose levels above 20 kilogray.’
Page 109 (5.125): ‘A past director of the National Institute of Nutrition and Member of the 1976 Joint Expert Committee (which gave qualified support to food irradiation) has however stated that he had the feeling that all findings which are in favour of wholesomeness of irradiated food are readily accepted without question, while those findings which question this stand are either rejected or viewed with suspicion, either covertly or overtly, as in the case of the Indian studies. He defended the NIN studies and the conclusion that irradiated wheat should be stored for 12 weeks.’
While we note that canning and freezing foods may cause nutritional loss, these processes are easily recognisable and therefore consumers have choice. The assumptions in relation to the DIAMOND dietary modelling system may be inconsistent with the nutritional and dietary intake of sectors of the population with particular health and safety needs. We therefore support any alternative to irradiation of food for disinfestation purposes, including oxygen deprivation techniques as mentioned in 4.2. We believe that further investigation into alternative approaches could result in technologies that are less environmentally degrading and unsafe to human health.
4.3 Labelling
SYMBOLS: For labelling purposes we do not recommend the use of benign symbology. We regard this as intent to deceive potential consumers due to the inadequacy of symbols to convey complete and accurate information. To avoid misrepresentation, the labelling should be worded in clear and unambiguous terms as being irradiated product.
SIZE: The size of the labelling is of the utmost significance and should conform to current eyesight-testing standards, for example: The Road and Traffic Authority (RTA) driver’s licence specifications.
We oppose any transfer of regulatory control in relation to labelling (and all other aspects of the food irradiation industry) to industry codes of practice. We see this as a possible conflict of interest as the industry would therefore become self-regulatory.
4.4 Efficacy of Treatment
The applicant claims that irradiation is more effective to sanitise spices than ethylene oxide (ETO). There are, however, alternatives that deserve consideration. Foremost would be the implementation of adequate hygiene procedures without which no sanitising treatment would be effective.
As Tony Webb of the Food Irradiation Network points out in his 1993 paper ‘Could Irradiation Deliver Clean-Green Food?’ at page 4: spices could come: ‘…complete with dirt, dead insects, rat … and pigeon droppings then collected, ground up and sold as ‘spices’.’
Dr. Dick Copeman, Coordinator of the Consumer Food Network proposes the drying of spices on concrete slabs using a cover of fine mesh. This method would prevent previously mentioned contaminants from entering the product while at the same time would not jeopardise the integrity of the environment. Being labour-intensive it would also create jobs. Other alternatives to irradiation are: steam treatment, oxygen deprivation and temperature control.
It is our opinion that the comparative risks to public health and safety from the proliferation of nuclear isotopes far outweigh risks associated with spices treated by methods other than irradiation. We note the absence of herbs in the comparison drawn between ethylene oxide and irradiation treatment.
4.5 Dose of Irradiation
The kilogray is the incorrect unit in relation to assessing public health and safety exposure. A becquerel is the unit for determining biological damage to food because it measures the ionising radiation’s effect on bacteria that may be present on food products. On the other hand a kilogray unit measures radiation energy contained within the food. It does not measure biological damage done to bacteria on the food or to human health and safety.
There is a perceived future opportunity to increase the maximum dose as though it was no longer an appropriate value to apply. Steritech’s application is for food irradiation and not some other product, such as medical devices. We advise the retention of the minimum dose as a precautionary measure for future standards.
In 1984, McCormick’s spices in the USA had their maximum permissible dose levels increased from 10 kilogray to 30 kilogray. In their petition to the FDA they stated that for the bulk irradiation of spices: ‘It is not possible to achieve uniform dose distribution throughout the product…some portions may receive an overdose of up to 180% of the average, while portions receiving the lowest amounts of irradiation could receive as little as 60% of the average dose. It is our belief that if the minimum was not published in the Standard, Steritech would apply to increase the maximum dose, which would then eliminate the average.
The McCormick’s example demonstrates the unsuitability of irradiating spices in bulk because of the extreme radiation dose delivered and absorbed at the periphery of the food product.
4.6 Detection Methods
As acknowledged at 4.6 there is no effective detection method readily available for irradiated food. The acknowledgment that this procedure is still at the testing stage indicates that consumers are potentially at risk. Because of the diversity of foodstuffs, we claim that detection and labelling of irradiated foods would be an impossible task to regulate.
We submit that if the applicant, Steritech, receives permission to irradiate the food items listed in Application A413, that these food items may be exported. Under the GATT Treaty, any country that exports irradiated food must agree to accept the import of irradiated food. We therefore recommend that Application A413 be declined on the grounds that irradiated food would enter Australia undetected, placing Australian consumers at risk.
Irradiation Facilities
In the 1988 Report of the House of Representatives Inquiry Into the Use of Ionising Radiation, certain recommendations were made as follows:
Page 154 (7.91): ‘the Minister for Industry, Technology and Commerce direct the Australian Nuclear Science and Technology Organisation to ensure that before approval is granted to import radioactive sources proposed irradiation facilities be subject to an Environmental Impact Assessment which satisfies the conditions of the Environment Protection (Impact of Proposals) Act 1974 and includes an assessment of the maximum credible accident, and detailed certificates of competence of plant operators be submitted and assessed.’
We note that Steritech’s Development Application for a nuclear irradiation facility at Narangba, Qld, did not require an Environment Impact Assessment (EIA). We submit that an EIA should be required for all applications of this nature to protect public health and safety and the environment.
Page 155 ( 7.96): ‘the Attorney-General require that standard insurance contracts be worded in such a manner as to make it clear that the policy covers damage from gamma sterilisation plants and the transport of radioactive isotopes to and from those plants.’
We are firmly of the opinion that insurance companies have not and will not alter standard insurance contracts to cover radiation hazards associated with irradiation facilities because of the inherent risk.
We find it highly questionable that the Committee’s recommendations have not been implemented. We see legislation in this regard as vital to ensuring public health and safety.
4.6 Regulatory Issues
We agree with the Issues Paper at 4.8 that there are difficulties in demonstrating that foods have been irradiated and therefore we claim that the regulation of irradiated food is an impossible task.
*We note at 3.2 the assertion that: ‘irradiation cannot enhance food that has deteriorated…’ We agree in essence but point out that there are well-known cases where contaminated foods have been ‘cleaned up’ using irradiation technology. This ‘dutching’ of contaminated foods does occur although illegal and poses a significant danger to consumer health.
We charge ANZFA with the duty to guarantee protection of consumer health and safety in relation to the potential introduction of the food irradiation industry into Australia. The regulations surrounding the food irradiation industry should not be replaced with industry codes of practice.
Transport of radioactive waste
Disposal of radioactive waste
Worker training and safety
Emergency procedures
Environmental risk
Public litigation
4.6 International Obligations
We note that Australia has signed WTO agreements and that these agreements stipulate the need for sound scientific principles. There are, however, unresolved health and safety issues in relation to the import and export of irradiated food.
The Northern Star newspaper, 4 Oct 1997 page 4 ran a headline: ‘Food-safety scares hit US beef industry.’ It went on to advise that exports of US beef were becoming more important as ‘changing American eating habits reduce meat consumption at home…’ Any outbreak of E.coli bacteria could potentially threaten this industry which accounts for ‘7.6% of the total US agricultural exports.’ For one company alone, their beef exports grossed 13% of $US12.5 billion sales the previous year.
The USFDA has recently approved irradiation of red meat eg ground beef and hamburger due to public concerns after an outbreak of E.coli ‘associated with consumption of frozen beef patties.’ HYPERLINK http://www.foodscience.afisc.csiro.au www.foodscience.afisc.csiro.au
The Australian Food Inspector, vol 16, no 2, June 1993 contains a headline on the front cover: ‘Irradiation – Whitewashing food problems?’ It states on Fact Sheet no 1 that: ‘Dutching is difficult to eradicate as there are no reliable methods for detecting whether a food has been irradiated and if so, how many times and with what doses. Far from being a treatment which can make food safer, irradiation has made obsolete many of the methods which public health agencies use to check that food is wholesome and fit to eat.’ The Australian Food Inspector is a journal for Commonwealth Meat, Fish & Fruit Inspectors, Australian Public Service.
In his article ‘Out of the Frying Pan’ New Society magazine, 17 Jan 1986, Carl Gardner states that irradiation: ‘…at recommended dosed will destroy salmonella bacteria plus many organisms that give bad chicken its putrid odour. But botulism, the bacteria that causes botulism food poisoning, will not be killed thus it could still multiply without the consumer noticing any warning smell.’
The issue of limited detection poses a threat of massive biological hazard. In our opinion, technology ‘fixes’ such as food irradiation should not be relied on to the point where they may disregard proper food safety and hygiene standards at industry level.
In regard to the figures provided, at 3.3, by the International Atomic Energy Agency (IAEA), we wish to point out that the IAEA has a vested interest in food irradiation technology as part of the ‘atoms for peace program’ and nuclear proliferation.
At 3.3 of the Issues Paper it is stated that: ‘There are a number of factors influencing the expanding use of irradiation of food, including: food security, especially in some developing countries and countries that experience large losses of food from spoilage organisms and pathogens…’
From the 1988 Report of the House of Reps:
The Committee noted that:
Page 36 (3.54): ‘The problem of world hunger, it was argued, is not caused by inadequate food production or technology. Each year billions of dollars worth of food is dumped by the European Economic Community (EEC) alone. The resolution…lies…in a more equitable distribution of the world’s resources and a shift from spending on armaments to spending for human needs.’
Page 36 (3.55): ‘Third World hunger arises partly because of inadequate or outmoded transport, lack of refrigerated storage and generally high temperatures and humidity.’
Page 37 (3.58): ‘The Committee is of the view that food irradiation would have only a marginal impact on Third World hunger and health.’
Our perception of the situation is that the issues have less to do with safety of food than the spread of nuclear technology and disposal of nuclear waste.
4.10 Potential Regulatory Impacts
*We request that ANZFA consider the social impact of the export of irradiated food interstate. In the Sunday Mail, 26 Oct 1986 in an article entitled: ‘Government Plan Own Food Irradiation Plant Says Mr Plant’ it is stated that Citizens Concerned About Food Irradiation claimed that the Queensland Department of Primary Industries intended to irradiate foods for local consumption. A spokesman for Primary Industries Minister, Mr Turner responded: ‘The Minister has maintained that the broad thrust of any future food irradiation plant in Queensland would be towards the export market, whether interstate or overseas.’ (Italics ours)
*The country of origin for the supply of the special packaging material required for irradiated food has not been adequately addressed. Our opinion is that Australia should not be reliant on outside sources of supply. We question the potential impact on and degradation of the environment as a result of unnecessary packaging and high level of waste guaranteed by this industry.
*We submit that it would be impossible to prove whether irradiation has been used as a substitute for good hygienic food handling and subsequently the risk could be enhanced. This could result in an increase of litigation under the Trades Practices Act 1974.
*The choices in irradiation facilities and sources of irradiation are a future concern. The 1988 Report states:
Page 147 (7.72): ‘…it is probable that with increased use of ionising radiation in food and other industrial processes demand for cobalt 60 will exceed supply.’
Page 149 (7.79): ‘The Committee agrees with the conclusions of ACA that the environmental hazards of caesium are greater than with other sources.’ The Committee recommended that: ‘the Minister for Industry, Technology and Commerce prohibit the import of Caesium 137 for use as an irradiation source in commercial irradiation facilities.’
It was noted that a mobile Cobalt 60 irradiator had been developed ‘…which has been designed to meet the requirements of processing seasonal crops and produce in different geographical locations. The capacity of the automatic portable irradiator is 200,000 curies.’
Page 151 (7.81): ‘One witness who is an irradiation safety officer stated that he was shocked at the prospect of travelling on a highway with cobalt 60 on a season to season basis. Another witness advised that mobile irradiators would be harder to regulate than fixed irradiation facilities. She also noted that sources which are taken out into the field are possibly more hazardous than fixed irradiation sources.’
Page 148 (7.74): The use of electron accelerators was discussed in the Report however it was noted that ‘these machines consume huge amounts of electricity.’
It is the view of the authors and the following people and organisations that Application A413 is lacking the technological methodology and instrumentation required to safe guard consumers and the primary industries that would be involved. It is also inadequate in the information content provided. The public’s concerns have not been addressed at any stage of the debate and this industry is looking to provide a technological fix to a problem that would be better addressed using preventative methods that deserve further research at both farming and points of quarantine services.
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