As a technology for food processing it means bombarding a range of foods with gamma rays from a radioactive source. The energy passes out of the product leaving no residue, like light passing through a glass window. Unlike light through a window, radiation passing through a clear sheet of glass will leave it browned.

Foods to be irradiated are placed on a conveyor belt that travels into a chamber where Cobalt 60 or Cesium 137, a waste product of the nuclear weaponry industry, emits the radioactive rays. The actual process is contained in a chamber with concrete walls 2 metres thick and within the chamber is a tank of water where the source of radiation is kept. The source is raised out of the water to expose the product. No other material in industrial use requires such cautious handling as a radioactive isotope. Cobalt 60 pencils are constantly emitting gamma radiation. At Lucas Heights a 1 metre thick lead glass window is needed to protect the technician from a couple of Cobalt rods the size of a pencil. The Cesium is stored in cold water when not being used. Any accidental release of Cesium 137 into the cooling pond or the environment would therefore pose serious contamination problems. If Cesium 137 were introduced into the ground water, the damage would be irreversible.

When the fumigant Ethylene Dibromide gas (EDB), a known carcinogen, was banned in the USA by the Environmental Protection Agency (EPA) in 1984, it rekindled interest in radiation as an alternative to chemicals used after harvesting. Irradiation totally or partly sterilises the product, inhibits ripening and sprouting in fruits and vegetables, kills most insect pests and many of the microorganisms which cause food spoilage.

The main thrust for the introduction of this process within Australia comes from the agricultural organisations hoping to capture the export market: notably Japan who was to follow in the ban of EDB. The major drawback here lies in the fact that this technique can, at best, replace only one post-harvest spray. Reinfestation does occur. In Russia wheat is often reinfested, eg when removed from the silo for distribution, and the irradiation process must be repeated. Also, there is no guarantee that export markets will open up to Australian irradiated produce as they will then be competing on the international market with produce from Third World countries eg Mexico. The main point here is that we can be sure that irradiated produce from overseas, which is presently banned from Australia, will no longer be able to be kept out. Do Australian farmers want these cheaper products competing on the domestic market with locally grown products, to the detriment of our primary industry? There is also a strong possibility of contaminated food being irradiated and dumped on the Australian market.

The International Atomic Energy Agency (IAEA) is the push behind the World Health Organisation (WHO) in claiming benefits to the Third World. For a country with severe economic problems and the installation cost alone of an irradiation plant of approximately $3 to $4 million one must pay serious consideration to the difficulties of communication and transport over long distances. It is ludicrous to suggest, for instance, that a country which currently cannot afford refrigeration would find this form of technology economically viable when the process itself would increase the cost of food per unit. As a ‘high tech’, capital-intensive technology, it is particularly unsuited for use in the Third World.

There are doubts as to the long-term effects of irradiated foods on human health. Janine Haines when Senator for the Democrats said: "Australia’s 16 million people should not be used as guinea pigs!" Dr. John Gofman, Professor Emeritus of Medical Physics at the University of California, Berkeley and author of ‘Radiation and Human Health’ stated on ABC TV’s ‘Four Corner’s’ program of 4th August 1986 that the only meaningful test would be to compare what happens in cancer rates for 100,000 people eating irradiated food for 10-20 years and 100,000 matched people not eating it. He said: "The idea of telling people that this is safe is a scientific hoax of the first magnitude." Professor Gofman has spent over 20 years studying the effects of radiation on human health and was once one of the US Government’s most senior advisers on the issue.

Under the US Government’s Delayney Clause of 1958, approval of irradiated food was prohibited until its safety could be ensured. Under the Reagan administration the Food and Drugs Administration (FDA) said that IF could not be proven safe, as the technology to monitor safety did not exist. Therefore regulations authorising the radiation of fresh fruit and vegetables up to one Kilogray, (the unit by which radiation is measured), took effect in the USA in April 1986. This is the equivalent of more than 3 million chest x-rays according to ‘The Washington Post’ article 16th April 1984. Why did the FDA approve IF when, during a comment period, the agency received over 4,000 comments 10 to 1 against IF from scientists, doctors and consumers? Did they simply bow to political pressure from the irradiation industry?

An article in ‘The Globe and Mail’ Report on Business 1983 noted that acceptance of gamma processing would mean a great deal to the troubled nuclear industry, which is ‘aggressively marketing the process as a means of selling the by-products of nuclear research’. The nuclear industry welcomes IF as a way of improving its image by claiming a ‘peaceful’ use of atomic power. It is also a profitable way of disposing of waste products from nuclear reactors. A statement to this effect regarding Cesium 137 was made in the 1984 report of the US Department of Commerce, Bureau of Industrial Economics. The Department of Energy has stated: "There exists the opportunity to convert perceived national liabilities into resources…" by making Cesium 137 a marketable product. THIS is the main political motive behind IF.

If the USA has approved radiation of up to one Kilogray, why has Australia accepted a level 10 times higher and the equivalent of 30 million chest x-rays? According to ‘Four Corners’, Australia lacked a national draft standard on IF so the Queensland Health Department drew up the draft and a key National Health and Medical Research Council (NHMRC) committee, headed by a Queensland bureaucrat, pushed for the standard to be finalised. The NHMRC Model Food Standards Regulation endorsed June 1986, accepts an overall AVERAGE dose of 10 Kilogray. The maximum dosage then would be 15 Kilogray, the equivalent of 45 million chest x-rays, in comparison to 3 million for the USA.

On ‘Four Corners", Gordon de Cean of the Australian NHMRC was asked if the NHMRC was aware that the United States FDA was only allowing the irradiation of fresh food up to 1 Kilogray. He replied: "No, we are not aware of their limitation to 1 Kilogray." In correspondence to the Commonwealth Department of Health requesting information on the NHMRC Standard, the Coalition for Safe Food (Nth. Coast) drew a reply from Gordon de Cean, Acting Assistant Secretary, Food and Environmental Protection Branch, dated 25th July 1986. In his reply he stated that the NHMRC Standard: "…follows closely the guidelines of the United Nation’s Food and Agriculture Organisation (FAO)/World Health Organisation (WHO) Joint Expert Committee of Food Irradiation." What he obviously omitted to mention is that the International Atomic Energy Agency (IAEA), previously mentioned, was also a member of the Joint Expert Committee of Food Irradiation (JECFI).

It seems that in 1973, after years of rejection, proponents of IF adopted a strategy at a meeting of the IAEA. From an article entitled ‘Glowing in the Fridge’ by Judy Light, Environmental Action, 1984: "To convince US officials…the IAEA suggested that the WHO, a sister agency, should be asked to make a statement claiming irradiated foods ‘are at least as safe for human consumption as foods processed by conventional methods’. Thereafter a joint FAO/IAEA/WHO statement recommended blanket approval of all irradiation up to a certain dose. IAEA strategy was so successful in convincing countries to adopt IF that it is expected to be the cornerstone of food legislation worldwide.

Correspondence to the Coalition for Safe Food (Nth. Coast) from the Assistant Secretary, Environmental Protection Branch, Commonwealth Health Department, Dr. GJ Murphy, October 1986, includes the IAEA in the Joint Expert Committee (JECFI). He states that: "JECFI has been meeting since 1964 to assess international toxicological data relating to IF." So who has conducted these tests that the JECFI assess? According to an article entitled ‘Food Irradiation: An FDA report’ by Alan T. Spiher Jr., FDA Papers, October 1968, animals in laboratory tests showed an increase in infant mortality rates, reduced body weight, shortened life spans, increased rates of tumours and cataracts on a diet of irradiated food. In other tests sponsored by the USDA between 1976 and 1980, rats and other test animals experienced an increase in testicular tumours and kidney disease, and a shortened life span while being fed irradiated chicken. "It was a consistent finding," said FDA researcher Dr. Donald Thayer. A recent pair of Russian studies has also found evidence of testicular damage and kidney disease.

US Government agencies have spent over $80 million in research and IF is not yet proven safe. In 1968 the FDA rejected the US army’s research on irradiated pork on grounds of possible adverse health effects to food consumers. The US army or the Atomic Energy Commission, whose plainly stated support of IF may have caused inconclusive or adverse findings to be discounted, commissioned many of the early studies. Some of the early research is still ‘classified in the interest of National Security’. In the 1970’s, the US army contracted out their research to the Industrial Bio Test Laboratories (IBT). Years of government testing and over $4 million spent to prove safety and the tests were disqualified because of fraudulent testing procedures by IBT. By 1982 the FDA had rejected some 17 studies done on IF by IBT between 1959 and 1977. Eleven of these were important tests meant to determine the long-term toxicity of IF. The army had found IBT in default of its contract on 2 IF studies due to missing records, departures from testing protocols and poor quality work. In 1983, in a major scientific scandal, 3 IBT company executives were convicted of performing fraudulent safety research for industry and government of other drugs and chemicals. Among the charges were failure to conduct routine analysis, faulty record keeping, suppression of unfavourable findings and falsifying test data.

In the Health Department’s correspondence of October 1986, mentioned above, it is stated: "In respect of radiolytic products the FDA has reported that if exotic molecules of the extreme toxicity were present at any level of toxicological significance in irradiated foods ingested by test animals, some consistent toxicological trends and patterns would be manifest in the studies reviewed. Because it has seen no consistent trends or patterns, the agency concludes that foods irradiated as prescribed by this regulation are safe."

What are these radiolytic products? From ‘Four Corners’: " The instant food is irradiated, millions of chemical bonds are shattered. When they recombine, new chemical compounds are formed. These compounds are called radiolytic products…" Scientists in Washington have shown that the more you irradiate food, the more radiolytic products are formed. Dr. Bernstein, a New Jersey GP and a passionate opponent of IF said: " The major disease cause of death in children up to the age of 14 is cancer and leukaemia. That’s the heritage we’re leaving our children." He said that IF will create new molecules in the food that no-one knows anything about and also: "…causes an over-production of aflatoxins, a naturally occurring fungus that is extremely carcinogenic." Aflatoxins are 1,000 times more cancer causing than the pesticide EDB that irradiation would replace. It is found in mould-containing foods such as grains, onions and potatoes and is already a major contributor to liver cancer, specifically in humid areas and tropical countries. The Division of Microbiology at the US FDA found that for irradiated rice the aflatoxin production was 50 times higher in the high dose radiation group compared to the non-irradiated control. They also identified mutant strains and spores.

Apparently the FDA reviewed 441 studies before setting its standards but only 5, which appear to support safety, were ultimately accepted. Dr. Bernstein said that the FDA did not even rely on these to approve IF: " They said ‘we cannot use toxicological studies’, so they just disregarded all toxicological studies that have been done in the entire world, saying that ‘we cannot prove the safety of food through toxicology because of technical difficulties.’ And therefore they based it on theory; theoretical calculations based on radiation chemistry. That’s right in the Federal Registrar." We now begin to identify the inconsistencies in what we are being told and we still haven’t answered the question: who has actually conducted these tests that the JECFI assess? Dr. Sanford Miller of the FDA stated on ‘Four Corners’: "We had developed some theoretical analysis of the irradiated food, of the safety of irradiated food, and we looked at those studies not only to support the conclusions we had come to but also to see if there was anything in them that would give us any cause for concern and indicated that our theory was wrong." Sarah Walls, ‘Four Corners’, referring to radiolytical products: " The trouble is that normal toxicological tests may not necessarily show whether all these products are safe. It’s hard enough to isolate them, let alone concentrate them in sufficient quantities to feed to animals for test purposes. That’s why the FDA had to rely on theory."

In 1975 two noteworthy papers were published in the American Journal of Clinical Nutrition: ‘Effects of Feeding Irradiated Wheat to Malnourished Children’ by C. Bhaskaran and G. Sadasiran. The National Institute of Nutrition in India conducted a clinical trial in undernourished children who were fed wheat freshly irradiated at a dose of 75,000-rad (1 Kilogray). 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 cells. Some animals fed irradiated wheat have also been known to develop cells that contained more than the usual number of chromosomes. Dr. Michael Simic, Acting Group Leader for Radiation Chemistry at the US National Bureau of Standards says: "The chemistry of irradiated foods is not understood and the radiolytic products have not been measured to the extent they should be."

From the article ‘Preserving Food the Radiation Way’ by Linda Pim, Probe Post, December 1983: "Gamma treatment of food can also produce unique radiolytic products (URPS), which are found only in irradiated foods. Some 42 URPS have been isolated. In a 1980 report the FDA stated that foods treated in the 1-10 Kilogray range may contain enough URPS to warrant toxicological evaluation…there is some evidence to suggest that irradiation of food may cause chronic reproductive and mutagenic effects". Referring to the JECFI, she says: "In their 1976 report, the committee admitted that, while there is little evidence of actual health effects from gamma-treated food, there is still the possibility of more subtle, long-term effects (eg carcinogenic and mutagenesis).

Mr. Neil Turner, a former Queensland Minister for Primary Industries, said in his press release on IF: "It is simply not true to say irradiated food is radioactive". Explaining the difference between the Australian acceptance of an average dose of 10 Kilogray and the American acceptance of 1 Kilogray he says: "The 1 Kilogray standard there applies to pork and fruit and vegetables because of particular domestic market requirements". Ms. Sharon Bomer, Director of US Government Relations for the United Fresh Fruit and Vegetable Association says that: "Despite approval of irradiation for fresh produce, it is unlikely to be introduced in the near future". American growers, she says, have benefited from the public’s swing towards fresh, healthy foods, and ‘they don’t want to hurt the fresh image.’ Could this be the reason or could it be the increasingly vocal critics of the introduction of IF in the USA? Take, for example, when Radiation Technology Inc. had plans to build a giant food irradiation plant just 4 miles from a New Jersey community. The citizens there held numerous town meetings, jammed the phone lines to the Governor’s office, to the Mayor’s office and put pressure on in every way to let the industry’s proponents know they did not want it. One of the many US groups, the National Coalition to Stop Food Irradiation says: "Unleashing food irradiation is Administrative permission to increase production of Cobalt 60 and to reprocess nuclear power wastes, giving the Department of Energy the green light to proliferate its isotopes and radioactive wastes throughout our land and wherever on the planet the naïve, the ignorant and the corrupt will accept it".

In Australia the CSIRO Food Research Quarterly 3rd September 1985 reported test results on meats. Severe problems appear to limit the use of irradiation for the treatment of meats. It causes changes in flavour, aroma and colour and these may alter the product significantly to cause problems with consumer acceptance…on opening the packs, atypical odours (described as ‘wet-dog’ or ‘fishy’ were noted). The fat was also noticeably bleached and peroxide accumulated more rapidly in the irradiated than in untreated fat. Clostridium may grow within meat tissue. To eradicate this very dangerous organism, a sterilising dose is required, but the organoleptic changes (changes to colour and odour) caused by a dose of this magnitude are a problem. They report that ‘commercial sterilisation’ of beef first requires cooking, then vacuum-packing, freezing to about –40 degrees Celsius and then irradiating at 50 Kilogray (the equivalent of 150 million chest x-rays). Also, as noted by the London Food Commission booklet: "Food Irradiation in Britain", the use of additives such as Sodium Tripolyphosphate are necessary to prevent discolouration, bleeding and the breakdown of fats in meat. Sodium Tripolyphosphate is a chemical used for cleaning grime off walls.

According to G. Fisher’s article, CSIRO report, page 58, the IAEA sponsored workshop in May 1985 recommended the initiation and stimulation of interest in IF among food manufacturers and the community generally. It further recommended that the steering group should ‘operate through the central organisation representing food manufacturers and/or food producers’. This recommendation appears to have achieved results in one sophisticated piece of propaganda. Released by the central organisation representing food producers, the Queensland Agricultural Journal, Jan-Feb 1986 in an article titled ‘Food Irradiation’ by GE Mitchell, Food Research Branch.

Vested interests are also at work in the UK where there is considerable pressure for the removal of the current ban on IF by Isotron, who have a virtual monopoly on the UK facilities for irradiation of medical equipment. It is therefore not surprising that Frank Ley, the Director of Isotron was a consulting adviser to the UK Government’s Advisory Committee on Irradiated and Novel Foods. Sir Arnold Burgen, the chairman of the committee is a part-time director of Amersham International, Britain’s leading isotope manufacturer.

According to the LFC booklet ‘Food Irradiation – Who Wants It?’, a number of British MP’s have tabled a motion in the House of Commons pointing out their concern over possible conflict of interest. They noted that predictions of the main recommendations of the Advisory Committee had been widely leaked, not least by Frank Ley. 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 company had raised capital through flotation on the stock exchange while the committee was sitting, to build a new irradiation plant. The motion called for an investigation of the share dealings in the company.

Meanwhile, according to ‘The Australian’ 14th April 1986, a spokesman for the Federal Department of Health has said that IF would eventually ‘come into Australia in a really big way’. According to the ‘Courier Mail’ 26th July 1986: ‘…a public education campaign…which includes preparing 1 million public information pamphlets and 30,000 booklets’ was being planned. Mr. John Scott, then ALP backbencher, member for Hindmarsh SA and IF opponent said that the so-called ‘information’ pamphlet being planned for public distribution was ‘nothing more than propaganda promoting IF and did not address 3 important points: labelling, safety of the process and cost to the consumer’. The Australian Federation of Consumers Organisation walked out of the planning campaign as they believed the public and consumers had not been consulted.

Locally, an article in ‘The Northern Star’, 10th July 1986 entitled ‘Food Irradiation Safe, Expert Says’ by Mr. J. Walker of the Australian Atomic Energy Commission (AAEC) states that ‘…irradiated fruit and vegetables soon would be a common sight in Australia’. Mr. Walker was the senior Media Relations Officer with the AAEC. He said that Queensland would probably lead the way and also said that: "The NHMRC was preparing an information program to counter public concern over nuclear related programs. It was because of this concern that some companies did not label their products as being irradiated". In the USA the term ‘food fascism’ has been applied to the food irradiation issue and associated propaganda.

So we can see how the nuclear industry and the food producers hope to benefit. Now to the food manufacturers or middle market management sector. The irradiation of some perishable food items will promote longer storage and shelf life. This means that manufacturers can concentrate their production and storage in fewer centres, cut handling costs thus cutting jobs! From ‘Oceania’, Trade Union and Community Media Service 14th May 1986: ‘…as distributors will be able to hold large stocks of food for longer periods there is likely to be a lowering of costs of some parts of the chain, from food production to point of sale, particularly in transport and employment costs. These savings will not automatically be passed on to the consumer and are more likely to be used to enable some groups, particularly large retailers, to increase their profits and their control over the food market by increasing ability to stockpile goods’.

In an article in ‘The Sun’, 9th May 1986, the problems resulting from the US and CSIRO experiments with IF are detailed. It then says that the Group Controller of Fresh Produce at GJ Coles, Mr. Lawrence Watson ‘acknowledged the problem in January, in a speech to the Bureau of Agricultural Economics’. He told the conference that the average consumer would not be ‘switched on’ by the idea of irradiated strawberries and that food should be labelled in a way ‘less scary’ to the public’. Anti-food irradiation groups are already picketing Coles stores in Sydney.

Apart from the aflatoxin and unique radiolytic products in irradiated foods there are a number of other vital points to be considered. One, which should concern all consumers, is the nutritional value of IF. According to a Parliamentary Library Legislative Research Service paper prepared by Dr. R. Panter, Science, Technology and Environment Group, 22nd August 1986, entitled ‘Food Irradiation in Australia – A Short Discussion Paper’, there is a 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’. The LFC booklet ‘Food Irradiation – Who Wants It?’ says that ‘…irradiated foods are frequently to be sold as fresh or at least looking fresh. At a time when the public is being encouraged to eat more fresh, whole and nutritious foods, this depletion of nutrients seems extraordinary’. They say there have been no studies that have assessed the impact of IF on the diets of critical groups in the population: ‘People on low incomes may already have diets close to, if not below, the recommended levels for some nutrients’. They go on to say that IF on a large scale is experimental and that this is admitted by both the DHSS Panel on Novel Foods and the Advisory Committee, which recommended long term monitoring of irradiated food-stuffs for nutritional damage.

In 1976, a ‘Review of International Wholesomeness Testing of Food and Feed From 1925 to the Present’, prepared for the International Food Irradiation Project stated that: ‘…it was not possible to draw conclusions about the wholesomeness of IF because the experiments were ambiguous and unreproducible’.

Food Irradiation, it seems, came into Australia through the back door of Queensland. A number of Australians in key positions were wooed by the nuclear industry here and in the USA. Dr. Martin Welt, the entrepreneur for Radiation Technology Inc. apparently got the ear of Sir Joh. In an article in ‘The National Times’ it was stated that Welt said he saw no need for the plant to be delayed until the United States reaches a decision on IF. He said that there was no point in Australia ‘kow towing’ to the whims of the US health authorities. Baden Cameron of the Queensland Department of Primary Industry and also the Brisbane Market’s Trust was, according to ‘Four Corners’, 4th August 1986, one of 6 senior Government advisers who saw and favoured the same type of plant design used by Radiation Technology Inc., while in the USA. According to ‘Four Corners’, Radiation Technology Inc. has a history of Nuclear Regulatory Commission (NRC) violations which include failure to maintain irradiator pool depth at required level, excessive radiation levels in unrestricted areas, failure to provide required training to employees, failure to adequately evaluate DOSE to workers and failure to evaluate material sent for disposal as normal trash.

Dr. Bernstein said that Radiation Technology Inc. was just one of 3 irradiation facilities in his community and that all 3 have had major accidents related to contaminated air, water and environment. Radiated water was poured down the drains, contaminating ground water areas and the sewerage system of whole communities without them knowing. Radiation Technology Inc. is responsible for a hazardous, toxic waste-dumping site it maintains in Rockaway NJ. It has been designated by the EPA to undergo remedial action under the Superfund Program. It has been estimated that it will cost up to $40 billion just to convert liquid wastes from the Hanford Nuclear Reservation in Washington (the world’s oldest nuclear weapon’s factory) into glass form so that it will be stable enough to be permanently disposed of. This does not include the costs of permanent disposal.

Within the industry as a whole, numerous incidents over the past few years have been reported where sources were simply ‘lost’ or were found by children in public, unrestricted areas. In Mexico, for example, a small boy found an unmarked Cobalt 60 source in a dump and took it home where it sat on a shelf irradiating his family and eventually led to the deaths of the whole family. How could an item of this nature find its way to a public dump? Radioactive materials have been disposed of along with non- radioactive garbage in a number of cases.

Is this the type of ‘definite advantage of drawing on international experience going back almost 50 years’ which Neil Turner, then Queensland Minister for Primary Industries, mentions in his press release on IF? Brisbane passed an amendment to the council’s town plans to allow for the disposal of radioactive waste within the Brisbane city boundaries. Australia’s first IF plant was planned for Brisbane and the Rocklea market site, which is flood prone, was the likely choice. Bearing in mind that the accident potential in the nuclear industry is so great, was this a wise choice to begin with? A US Department of Agriculture official, Robert Jarrett, warned food irradiators at a convention in 1986 to: "Make sure you have a good rapport with local disaster agencies". This is interpreted as ‘always expect the unexpected’…Chernobyl for instance.

Irradiation sources would also need to be produced, transported, stored and installed and the spent sources replaced. This whole process cannot be divorced from the wider processes of the nuclear power program without which it could not exist. At every stage workers can be, and usually are, exposed to ‘low levels’ of radiation. Dr. Bernstein on ‘Four Corners’ said that Radiation Technology Inc. had irradiated a worker with the equivalent of 20,000 chest x-rays in approximately 20 seconds. Sarah Walls reports that since recording the interview with Radiation Technology Inc., (the company which wanted to sell a plant to Queensland!), it has had the licence for its Rockaway, New Jersey plant suspended indefinitely by the Nuclear Regulatory Commission (NRC). ‘The NRC order said there was a pattern of wrong-doings so pervasive that it no longer had a reasonable assurance the safety of Radiation Technology Inc. employees would be protected’. She also stated that: "It will mean a vast increase in the amount of radioactive material imported into and carried around Australia. Just to transport 4 of these Cobalt rods - about 2,000 curies - requires several layers of steel, an aluminium carrier and a massive 3 tonne container".

There would be a large amount of dangerous radioactive materials moving on the highways and being located near population centres and major food growing areas if food irradiation was introduced. A combined booklet by the US Health and Energy institute and Environmental Policy Institute documents many incidents which have occurred in the USA where radioactive sources have ‘fallen off’ delivery trucks and have been found by members of the public, sometimes children. Also documented are processing plant leaks. The best publicised case was in Arizona in 1979 where the outraged Governor, Bruce Babbitt, had to send in the National Guard to dispose of abandoned radioactive tritium at the American Atomic Plant in Tucson. Due to the plant’s location, near the central kitchen for the Tucson public school system, the frequently leaked tritium (a radioactive form of hydrogen) ended up in the food served to 40,000 school children.

To date over 200 states and local governments in the USA have adopted bans or restrictions on nuclear cargo transport because of the growing concern over the Government’s inability to protect communities from radioactive cargo.

As to the question of economics, IF could well affect the domestic market in a number of ways. In Mr. Turner’s IF press release, he also stated that: "Perhaps the greatest potential to expand markets using irradiation is with seafood. Ionising energy can be used to extend shelf-life to enable fresh seafood to be transported much longer distances than currently possible". The point to be considered here would be the cost to the domestic consumer on certain items, for example exotic fruits, seafood etc if exports did eventually prove to be high. From the ‘Countrywide’ program, 11th July 1986, Lucy Broad stated: "There could well be disadvantages for producers as well. Get rid of the fruit fly and there’s nothing to stop vast quantities of northern produce heading south".

Apart from the cost of a plant, the costs of the irradiation process per unit have not been mentioned. The ACA Inquiry Food Irradiation Seminar, 17th November 1986, heard that an operating food irradiation plant would require 5,000 hours operation per year in order to be viable. The volume of food throughput required to meet this level of operation would be enormous. It is likely that IF would be more expensive as the costs of packaging and labelling would have to be passed on to the average consumer. In order to maintain irradiated foods at prices competitive to fresh produce, there could be a decrease in the price per unit paid to the producer since the price per unit to the public may remain at the lowest possible level. Further, since IF preserves the shelf life of food there would be fewer cases of spoilage. This would reduce the gross turnover of the number of units to a much lower level thus decreasing the quantity needed to be supplied. This situation would produce an over-supply of fruit, driving the price per unit even lower. The full economic implications of IF for producer and consumer need very careful analysis.

Labelling is a pivotal issue in the success of IF as a commercial process. A survey or retailers in the US Produce Marketing Association found that half of them would not sell irradiated food if it had to be labelled as such because they felt it would be the ‘kiss of death’. As labelling would prove to be a most contentious issue to the consumer, a labelling by-pass regulation, to change IF from an additive to a process was introduced in the USA. This would affect labelling of ingredients in fast foods, restaurant menus or processed foods where irradiated ingredients have been used. From "Food Technology in Australia", October 1983: "Under the original concept that radiation was to be considered as a food additive, its use would have had to be spelled out in the ingredient listing of each processed food. Preservation processes currently in use, however, do not now have to be specifically listed on the labels (whether canned, frozen, or dried); the same philosophy might apply to radiation processing".

Subversive attempts have been made to have the term ‘picowaved’ or ‘picofresh’ on packaged irradiated foods and to avoid any use of the word ‘irradiated’. The London Food Commission said that the difficulties of labelling loose fruit and vegetables are obvious, but unless faced by the Government, make a mockery of consumer choice. The Australian NHMRC Model Food Standard, endorsed June 1986, makes no reference to the labelling of non-packaged food. The LFC further said that nutritional and date-marking labelling are necessary, and that the consumer has a fundamental right to know about the processes used to preserve the food being bought. They said that all irradiated foodstuffs need to be labelled as ‘irradiated’ in clear and unambiguous terms at point of sale and this should apply to packaged, bulk, food normally sold loose or unpackaged and also food offered for sale in catering outlets. Their opinion is that until such time as a test for detecting previously irradiated food is developed there is a strong argument for delaying the introduction of the process.

In 1984, McCormack’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’.

Packaging also presents a problem as plastic used can undergo structural changes when irradiated and become permeable to air, thus endangering the durability of the enclosed foods or even delivering toxic substances to the food.

Enforcement of regulations:

Will we have regulations which will cover the labelling of bulk bins of irradiated produce once taken out of original crates and who could possibly enforce these necessary regulations at every distribution point?

The NHMRC was forced to lift a ban on the waxing of apples because it was unable to enforce the regulation. As it is the NHMRC who set the standards for the introduction of food irradiation into Australia we ask: If the NHMRC was unable to enforce the ban on the waxing of apples, how could they possibly enforce the complex set of regulations required for food irradiation?

Once fresh fruit or vegetables are irradiated they are no longer the same product, in a molecular sense, thus posing complex, long-term health risks.

The author of the paper on the trials with irradiated food on Indian children concluded that: ‘Wheat must be stored for a period ‘beyond’ 12 weeks after irradiation’ before it is ready for human consumption. No mention is made of an enforced storage period for freshly irradiated produce in the NHMRC Model Food Standard. Adequate post-irradiation storage period is necessary to ensure that induced radioactivity is no longer present at levels harmful to human health.

In the NHMRC Model Food Standard there is, however, a sub-regulation allowing re-irradiation of particular food items ‘for another technological purpose’. Could this be for reinfestation? As previously mentioned by the LFC, there is no test available that can monitor previously irradiated food so we can see how many times it has been re-irradiated before it is finally sold.

A newly emerging enforcement problem is late irradiation. Take the scandal of a few years back where an Imperial Foods Group subsidiary imported a shipment of contaminated prawns into Britain. They had them shipped to the Netherlands where they were irradiated, illegally imported back into Britain and sold under another label to the restaurant trade.

Unscrupulous monopolies have no regard for nutritional losses incurred during re-irradiation or where contaminated foods which don’t meet safe microbiological testing levels are ‘cleaned up’.

While irradiation can leave food looking fresh longer, this can be deceptive as it can reduce the bacterial load on foods but will not eliminate the chemical toxins that may have been created by earlier contamination, presenting a very real public health hazard. This applies to chicken according to the article "Out of the Frying Pan" by Carl Gardner in ‘New Society’, 17th January 1986. He states that irradiation ‘at recommended doses 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 JECFI was emphatic on this issue, that irradiation should not be used to make unfit food saleable, but we can see from the previous 4 points the sheer complexity that enforcement of food irradiation regulations would present.

The impact of the IF industry as a whole on suburban Australia would be vast. Once implemented as a technology, we would have difficulty retracing our steps. The LFC report entitled: ‘Food Irradiation – Who Wants It?’ by Tony Webb and Angela Henderson states and rightly so that ‘the widespread consumption of IF in Britain or any other country would be an unprecedented human experiment’. Mr. Turner also states in his press release on IF that: "It should be remembered that 3 irradiation plants have been operating in Australia for many years". It seems that Mr. Turner was unaware that wine corks, talcum powder and disposable medical supplies are not currently on the list of foods for human consumption.