Response to the Report of the House of Representatives Standing Committee on Environment, Recreation and the Arts, November 1988.

This response was prepared at the request of the Lismore Labor Party by Ms Dana Young.

The Report has been read and we draw attention to the following recommendations.

Recommendations:

The Committee recommends that:

the Australian Government request the World Health Organisation to:

review existing data relating to the safety of irradiated food;

produce a fully referenced report on the safety of irradiated food, and

identify those areas where further research is required. (paragraph 5. 143)

Reply:

We note that on page 65 this report states that the National Coalition to Stop Food Irradiation and a Government Caucus Committee, for example, have called on the Australian Government to Request the World Health Organisation (WHO) to reopen the investigation into the public safety aspects and to produce a report. We see this, however, as a further delay in the decision-making process. The safety of irradiated food for human consumption cannot be proven based on all the scientific evidence to date. Dr. John Gofman, Professor Emeritus of Medical Physics at the University of California, Berkeley, and author of Radiation and Human Health, stated on the ABC Four Corner’s program, 4/8/86, that the only meaningful test would be to compare what happens in cancer rates for 100,000 people eating irradiated food for 10 to 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 subject.

The Committee recommends that:

if the irradiation of food were to be approved the Minister for Community Services and Health request Commonwealth and State Public Health Authorities to monitor the quantities and types of foods that are irradiated. (paragraph 6.38)

Reply:

The National Health and Medical Research Council (NHMRC), whose Model Food Standard, endorsed June 1986, covers the introduction of food irradiation into Australia, was unable to enforce a ban on the waxing of apples, therefore the ban had to be lifted. We point out that if such a simple task cannot be regulated, the complexity of introducing food irradiation technology and regulating it to meet required standards would present an enormous and subsequently impossible task, open to manipulation by the greedy and the unscrupulous.

The Committee recommends that:

if the irradiation of food were to be approved the Minister for Community Services and Health ensure that all future dietary intake surveys are designed in a manner which would enable identification of those at risk groups who may consume irradiated food as a significant proportion of their diet and whose diet may be nutritionally inadequate. (paragraph 6.39)

Reply:

The substantial nutritional losses incurred by food irradiation have been well documented in a Parliamentary Library Legislative Research Service paper prepared by Dr. R Panter, Science, Technology and Environment Group (22/8/86) entitled "Food Irradiation in Australia – A Short Discussion Paper." Further, we should not allow the cost of a survey specifically designed to monitor the effects of food irradiation on the ‘at risk’ categories of the Australian population to be passed on to the taxpayer without public consultation.

The Committee recommends that:

the Minister for Industry, Technology and Commerce request the Australian Nuclear Science and Technology Organisation (ANSTO) to develop suitably equipped radiation safety specialists and engineers to provide assistance in the event of any unusual occurrences at Australian and regional irradiation facilities. (paragraph 7.51)

Reply:

Irradiated food is unsafe and so is the industry that produces it.

The Committee recommends that:

14 (1) the Minister for Industry, Technology and Commerce direct the Australian Nuclear Science and Technology Organisation (ANSTO) 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 (11) detailed certificates of competence of plant operators be submitted and assessed. (paragraph 7.91)

Reply:

It is stated on page 68 of the Report (paragraph 4.98) that: ‘ANSTO advised that with the explicit approval of the Australian Government it has at different times become involved in a number of international programs for the development of peaceful applications of nuclear energy.’ We question the supervisory role of ANSTO in relation to these approvals as this could be perceived as a self-monitoring process. An Environmental Impact Assessment is the most basic requirement for any development.

The Committee recommends that:

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. (paragraph 7.96)

Reply:

This is an acknowledgment that the technology, as a whole, is not fail-safe.

Feasibility of Food Irradiation.

The Report states at page 23 that the US Atomic Energy Commission funded studies on shelf life extension of fruit and vegetables during the 1960’s and the 1970’s:

Page 24 (paragraph 3.19): ‘The researchers concluded that irradiation has technical promise but only for a few commodities and that economic feasibility reduces possible applications even further.’ In the US they found that if extending shelf life was the only consideration, then strawberries were the only commodity ‘with a remote possibility’. Other products either ‘did not tolerate the doses required to achieve the desired effect or …there were cheaper and more effective alternative treatments.’ (italics mine)

Page 24 (paragraph 3.20): ‘While this research was conducted more than a decade ago the Committee received little evidence during the inquiry which contradicted these results…the prime purpose, at least in Australia, would be for insect disinfestation.’

Page 32 (paragraph 3.39): ‘…the US Department of Agriculture’s Foreign Agricultural Service has revealed that…few, if any, countries have legislated to permit the importation of irradiated foods.’ It was that Department’s opinion that, currently, there was limited potential for international trade.’

There are few commercial food irradiation facilities in operation around the world and the Committee noted that:

Page 36 (paragraph 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 not in a technological fix but in a more equitable distribution of the world’s resources and a shift from spending on armaments to spending for human needs.’

Page 36 (paragraph 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 (paragraph 3.58): ‘The Committee is of the view that food irradiation would have only a marginal impact on Third World hunger and health.’

( We note then that Third World hunger, which has often been cited as a reason to introduce food irradiation, is therefore not a justifiable reason.

Page 44 (paragraph 4.18): ‘Three Committees of the European Parliament have examined the question of food irradiation.’ The Committee on the Environment, Public Health and Consumer Protection (EPHCP) was one of these.

Page 46 (paragraph 4.22): ‘The EPHCP Committee concluded that despite decades of research it was not possible to prove that food irradiation causes no harm to health.’ It also concluded that: ‘…the use of ionising radiation to conserve food is potentially more dangerous than conventional methods…’

Page 48 (paragraph 4.28): The UK Burgen Committee Inquiry into food irradiation stated that if food irradiation were permitted in the UK: ‘…procedures should be established to monitor the consumption pattern of irradiated foods…to review new toxicological data on irradiated foods…to consider any toxicological implications…which might be revealed by monitoring the extent and pattern of use.’

This implies an unprecedented and massive experiment along the lines of what Dr John Gofman suggested on ABC Four Corners, 4/8/86 (above). It is also the reason that Janine Haines, when a senator for the Democrats, stated that: "Australia’s 16 million people should not be used as guinea pigs!" The Australian population or sectors thereof should not be subject to risk.

Page 53 (paragraph 4.48): ‘The New Zealand Government has established an Irradiation Issues Working Party to provide policy advice on irradiation technology and the appropriateness of food irradiation in New Zealand.’

We note that the Working Party concluded that:

1. No significant need for food irradiation technology had been identified for New Zealand.

2. None of New Zealand’s major export markets have accepted or required irradiated products. (italics mine)

3. There is no significant need for the irradiation of local foods for local consumption.

However, we note that the Committee goes on to state that:

Page 71 (paragraph 5.1): ‘The majority of expert scientific evidence, both oral and written….indicated that the process is wholesome and safe.’

Page 71 (paragraph 5.4): ‘…no substance can be considered intrinsically 100% safe…safety is always relative. Absolute safety is an unattainable ideal.’

Page 78 (paragraph 5.21): ‘ FDA believed that the database was inadequate to support a broad decision that all foods may be safely irradiated at higher doses than 1 kGy.’ (italics mine)

We draw your attention to the National Health and Medical Research Council Model Food Standard which would permit an overall, average dose of 10 kGy (a maximum,therefore, of 15 kGy) in Australia.

In our opinion the introduction of food irradiation technology into this country is not feasible enough to justify the potential risks involved.

The New Zealand Inquiry observed that New Zealand’s clean, fresh and natural image could be sullied and trade advantages could suffer as a result of the use of irradiation on food.

The Australian Inquiry was advised that Australia is increasing its markets for product in post-Chernobyl Europe because of Australia’s ability to export ‘clean’ food.

In summary we note with great concern that of the 25 recommendations, 20 appear to be concerned with regulations which would be applied when food irradiation technology is introduced. This indicates to us that the underlying assumption of the Report is that food irradiation will be introduced into Australia despite public opposition.