LAST CHANCE TO STOP FOOD IRRADIATION
Deadline extended!! - Comments to FDA Needed Before July 19

The FDA is asking the public for comments on a proposal to remove all
labeling requirements for irradiated food. Essentially all foods,
including fruits and vegetables, may now be legally irradiated.
Irradiation advocates know that even the currently required label-a tiny
statement no bigger than the ingredients, and no statement at all for
irradiated components of mixed foods-drives away customers. (According
to a 1997 CBS news poll, 77% of the public would not buy irradiated
food.) Therefore, with no public hearings and with almost no media
coverage, a few agribusiness-friendly legislators amended the omnibus
1997 FDA Modernization Act to require the FDA to consider eliminated
labels for irradiated food.
Since the comment period began in February, the FDA has received well
over 8000 comments and petition signatures, most in favor of continuing
labeling. Probably because of this unexpected response, the FDA extended
the deadline another two months, to July 19, 1999. After, they may
announce a regulation, or they may decide to do nothing and keep the
labels.
Why is labeling important? Without labeling, there will be no way for
you to know if your food has been irradiated. You would be forced to
participate in a giant, uncontrolled experiment on human health, like
that being carried out using genetically engineered food. Only organic
foods would be spared. People who claim irradiated-food-related health
problems will not be able to prove them. Hundreds of irradiation
facilities will be built, and the owners will demand their investment be
returned. A flood of irradiated foods will enter the market as food
processors irradiate merely to protect themselves from liability.
American meat exporters will sue foreign governments whose labels act as
a restraint of trade. Only a public health catastrophe will move
Congress to reinstate labels.
If you believe you should be able to choose whether or not to eat
irradiated foods, you should write to the FDA and send a copyof your
letter to your member of Congress.
The FDA and USDA support irradiation in order to provide 'cleaner'
food. Irradiation does kill insects and bacteria, but it has many
environmental side effects and health question marks. However, it has
powerful friends in the food processing and nuclear industries, the
medical establishment, and the Federal government. a) the food
processors want to avoid liability for food poisoning; b) the Department
of Energy, since the early 1980s, has wanted to dispose of nuclear
wastes by selling them to private industry, c) the AMA doesn't look at
the environmental effects, and d) the FDA and USDA are heavily
influenced by the meat industry, which will be the main beneficiary of
irradiation. Although there have been many food poisoning outbreaks
associated with fruits and vegetables, the meat and poultry processing
business have been hit the hardest in the pocketbook. (Furthermore, many
of the responsible fruits and vegetables could not have been irradiated
anyway). Irradiation is a quick (and temporary) fix for poor
slaughterhouse sanitation: it allows meat packers to ship 'sterile'
food, and avoid liability for any subsequent illness. Unlabeled meat
irradiated at the slaughterhouse or packing can be recontaminated at a
restaurant, supermarket or home. Improving slaughterhouse cleanliness
and animal health would cost money--but so does irradiation, depending
on the volume of food irradiated, as much as .07 per pound, which will
be passed on to the consumer.
The authors of this directive to the FDA are very concerned about
shielding the factory farming industry from liability for food
poisoning, but they couldn't care less about our right to know what we
are eating. Constituents of Senators Harkin (IA), Jeffords (VT) and
McConnell (KY), and Rep. Ganske (IA) should hold them accountable.

SEND A COMMENT TO THE FDA:
Individuals should send one copy, organizations send two. The FDA has
requested comments on only two issues: "1) Whether the wording of the
current radiation disclosure statement should be revised, and 2) whether
such labeling requirements should expire at a specified date in the
future." Therefore, your comments should address some or all of the
following points:
- State any expertise or personal interest you have that would give
your comments more authority
- Demand prominent labeling that is easily visible and is
understandable by the uninformed consumer.
- Demand the use of the terms "irradiation" or "irradiated" and the
radura symbol. Tell the FDA that proposed alternative terms such as
"cold pasteurization" and "electronic pasteurization" are misleading and
should not be used.
- Say that the absence of a statement would be misleading because
irradiation destroys vitamins and you want labels on your fresh fruits
and vegetables so that you can adjust your diet to compensate for the
vitamin losses. Tell them that the comparison of vitamin losses to
cooking or other processing is not valid because you eat your fresh
produce uncooked.
- Say that irradiation causes changes in sensory qualities that are not
obvious or expected, and a label will explain the reason for qualities
that might otherwise cause you to reject the food.
- A general statement opposing irradiation will NOT help, because the
FDA has already decided irradiation is safe, and saying that a label
will cause you to reject the food strengthens the FDA's rationale for
eliminating labeling.
The complete proposal is at
<http://www.fda.gov/ohrms/dockets/98fr/021799a.txt>.

Send comments before July 19, 1999 to: Dockets Management Branch
(HFA-305), Food and Drug Administration, 5630 Fishers Lane, Room 1061,
Rockville, MD 20852. In your comment, refer to Docket #98N-1038,
"Irradiation in the production, processing and handling of food."
Questions at the FDA: Dr. William Trotter, 202/418-3088. E-mail is
discouraged, because e-mail messages are taken less seriously than
letters, and garbled messages will be discarded. Send e-mail to
FDADockets@oc.fda.gov and put the docket number in the subject line.
Include your name and address in the e-mail.

FOLLOW THE FDA'S AGENDA IN THE COMMENTS, BUT TELL CONGRESS HOW YOU
REALLY FEEL
Send a copy of your letter to your congressperson and your senators,
and add a cover letter saying that as your representatives, they are
responsible for representing you, and you want all irradiated components
of a food to be identified. Tell them that it is completely unethical to
impose irradiated foods of all kinds on people who do not want to eat
them. Only Congress has the power to direct the FDA to improve labeling
requirements. We will be contacting Congress to ask them to revise their
directive to the FDA. Your letters are critical. To find your
representatives, look up your zip code at
<http://www.visi.com/juan/congress/ziptoit.html> or call your local
Registrar of Voters.
Contact your local media (alternative papers, food sections, public
and talk radio) to tell them to report on this story.

THIS IS OUR LAST CHANCE!!
If the FDA eliminates labeling, U.S. exporters will be able to
successfully claim that other countries' labeling laws are "restraint of
trade" under international trade rules. The European Parliament recently
discussed harmonizing its members' policies on irradiation, anticipating
U.S. exports. A commercial irradiation facility for red meat is now
being built in Iowa.

WHAT'S WRONG WITH FOOD IRRADIATION?
Food irradiation is a technology that has not been covered well by the
media, and therefore it cannot be explained in a few sentences. Briefly,
it has many health, environmental and social justice effects. All should
be considered in evaluating whether or not it should be used Three
examples:
- Health. The FDA based its approval of irradiation on only five of 441
studies; all five were criticized as inappropriate by Donald Louria,
M.D., Chairman of the Department of Preventive Medicine and Community
Health at the New Jersey Medical School. There are no human feeding
studies longer than 15 weeks, and no studies on children.
- Environment. Privatizing nuclear material at the scale proposed
(hundreds of facilities) is a recipe for accidental leaks of
radioactivity, worker exposure and abandoned Superfund sites. Georgia
taxpayers already paid $47 million to clean up a spill in an irradiation
facility. One of the two materials used to irradiate foods is
radioactive for hundreds of years.
- Social justice and biodiversity. Given the record of Monsanto and
other biotech companies, it is not farfetched to expect that if
irradiation is used widely, these companies will engineer seeds for
plants that don't change taste or texture when irradiated. These seeds
will be patented, and farmers who sell their crops to irradiating
packers will be forced to use them.

SOME RESOURCES:
- Food & Water at 800/328-7233. The only national organization with
irradiation as its main issue, Food & Water has almost singlehandedly
tried to inform the public for the past 10 years. Excellent quarterly
newsletter.
- The Campaign for Food Safety, http://www.purefood.org. Look in the
Action Alert and Food Irradiation sections
- Irradiation-Free Food Hawaii, http://www.kilima.com/bill62.html has
been fighting food irradiation in Hawaii for years. Lots of information
and scientific background. Call 808/966-6846, activenow@hotmail.com
- Center for Science in the Public Interest, http://www.cspinet.org or
202/332-9110 in Washington, DC, proposes alternative government policies
to improve food safety without irradiation. Good background on the
public policy context.
Books: Food irradiation: Who wants it? by Tony Webb and Tim Lang, The
food that would last forever by Gary Gibbs, and The biology of food
irradiation by David Murray.
- US Government web site favoring irradiation:
http://www.foodsafety.gov (do a keyword search on food irradiation)