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Date: Wed, 24 Mar 1999 23:49:30 -0500
From: Mike Ewall <>
Subject: Food Irradiation Alert

Food Irradiation Alert

Please circulate
Action steps below

March 15, 1999

You like good food? Me too. And I prefer to have mine without irradiation, but soon I may not have the option.

In case you didn't hear, all labeling requirements for irradiated food are on the verge of being withdrawn in the U.S. It's the FDA's call.

This means anything you eat can be irradiated and the seller will not be required to inform you. I am not making this up. I guess the feds, GE, Westinghouse, etc.'s need to unload the nuclear waste they generate supersedes your right to know how the food you eat is treated.

The FDA is trying to keep this issue out of the spotlight -- it won't post comments on the Internet according to Anuradha Mittal Policy Director for Food First.

The plan has long been (I read first read about it 15 years ago) to have hundreds of small irradiation plants, one in every population center, so not only is there likely to be irradiated food in your future, one of these plants might soon be in you neighborhood, hooked up to your city's sewer system.

No need to worry though. The low wage workers who handle the radioactive material will operate under "strict federal guidelines." And think of all the jobs it will create. What a boon!

Don't expect to see this story on NBC or CBS, or ABC or CNN for that matter. You might, however, soon start reading stories that sing the praises of "cold pasteurization" and "electronic pasteurization" -- the new name for irradiation.

If you're puzzled how such perversities come into being, see Toxic Sludge is Good for You for the stranger-than-fiction answer.

Bottom line: Millions of dollars are spent each year devising new ways to persuade us that various poisons, which add to the profits of a handful of big companies, are "OK." Public relations is one of the fastest growing "professions" in America today. No wonder. There's a lot of work to be done.


Here's the info. You can write in and help stop it. It will take one minute. Tell your friends to write in, too:

Action Alert: Last Chance To Stop Food Irradiation
Comments To FDA Needed Before July 19, 1999
Please Publicize This Issue

The FDA is planning to remove all current labeling requirements for irradiated food. The FDA has approved irradiation for essentially all foods, including fruits and vegetables. Without labeling, there will be no way for you to know if your food has been irradiated. If labels are eliminated now, only a public health catastrophe can reinstate them. Irradiated foods could be on your table within a year-some facilities already exist, and hundreds more could be built.

The labeling requirement has been the sole impediment to widespread use of irradiation. Irradiation proponents fear that even the current requirement -- a tiny statement no bigger than the ingredients, and no statement at all for irradiated components of mixed food -- will scare consumers. The FDA proposal to remove labeling practically begs for 'consumer focus' studies that will tell it how to 're- educate' the 77% of the public that does not want irradiation.

Irradiation has powerful friends in the food processing and nuclear industries, the medical establishment, and the Federal government. For several years they have been engaging in a covert public relations campaign to convince us that irradiation is the answer to food safety problems, like contaminated Guatemalan raspberries and lunch meats. But if you look at the news, these problems are overwhelmingly concentrated in the meat and poultry processing business. Jack-in-the-Box and Hudson Foods lost a lot of money. Irradiation is really just a quick (and temporary) fix for poor slaughterhouse sanitation, and a way of disposing of nuclear wastes by selling them to private industry and leaving the taxpayers to fund the inevitable clean-up costs.

It is completely unethical to impose irradiation on people who do not want it in order to protect the factory-farmers from the consequences of their business practices.

And the FDA is trying to keep this issue out of the spotlight -- it won't post comments on the Internet.

What You Can Do:

Send a comment to the FDA demanding prominent labeling, the use of the terms "irradiation" or "irradiated" and the use of the radura symbol. Tell the FDA you feel 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 causes changes in sensory and spoilage qualities that are not obvious or expected by the consumer. A general statement opposing irradiation will NOT help, because the FDA requests 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.
(Please read the document following the next set of double lines before writing). The complete proposal is at:

Send comments before July 19, 1999 to:

    Dockets Management Branch (HFA-305)
    Food and Drug Administration
    5630 Fishers Lane, Room 1061
    Rockville, MD 20852.

Refer to Docket #98N-1038, "Irradiation in the production, processing and handling of food." E-mail is discouraged, because garbled messages will be discarded, and e-mail is MUCH less effective than a letter. Send e-mail to: and/or
and put the docket number in the "Subject" line.

Send a copy of your letter to your congressperson and your senators, and tell them that as your representatives, they are responsible for representing you, and you don't want to eat irradiated foods in any form. At the very least, these foods should be prominently labeled, and all irradiated components of a food should be identified.

Contact the media in your area (alternative weeklies, food sections, public radio, talk radio) and tell them to report on this story. Tell them you don't want to eat irradiated foods, and why irradiation is a risky technology.

Act Now! This Is Our Last Chance!!

If the FDA eliminates labeling, U.S. exporters of irradiated foods will be able to successfully claim that other countries' labeling laws are "restraint of trade" under international trade rules. Our actions now are critical!

Instructions and Background for Sending a Comment to the FDA Please Read!!

What Kind of Letter to Write and Why

If you are writing as an individual, send one copy to the fda; otherwise, send two copies.

If you have any expertise or personal status that bears on the issue (e.g., you are a physician, scientist, chef, farmer, food manufacturer, parent), state it in your comment.

Please note that the FDA is only asking for comments on the issues of:

  1. whether labeling of irradiated foods should remain; and,
  2. if so, what kind of label.
The FDA has already decided that irradiation is 'safe'; the irradiation advocates in the medical establishment, big agriculture, the nuclear industry and Congress know that labels frighten consumers. The irradiators know that most consumers do not want irradiated foods (77% according to a CBS poll in 1997).

But in November 1997, President Clinton signed into law a Congressional bill reducing the size of the irradiation label. As an agency overseen by Congress, the FDA is only able to ask what kind of labeling it should require. This is NOT the time to tell the FDA you are against irradiation. In fact, if you state that you don't want to eat irradiated food and that labels will help you avoid it, you will give the FDA more reason to eliminate labeling (because the FDA has already decided irradiation is safe, and it doesn't want to scare people). We must play the FDA's game -- use its own arguments in favor of labeling.

The sample letters stress that the FDA's original reason for labeling is still valid -- that irradiation is a process that can change the texture, taste, storage characteristics and nutrients of a food and should therefore be disclosed to avoid misleading the consumer. The FDA proposal is posted at:

Feel free to alter the sample letters as desired.

Importance of Acting Now

This really is our last chance to stop food irradiation. If labeling is eliminated, hundreds more irradiation facilities will be built. Once built, they have to be used. Not just meat and poultry, but fruits and vegetables will be irradiated. And one of the two materials commonly used for irradiating foods is radioactive for 600 years. Do you trust any business to be responsible for that long?

Our actions today have global consequences: the Codex Alimentarius, the international rule for trade in food, requires labeling of irradiated foods. If the United States eliminates its requirement, U.S. food exporters, under the General Agreement on Tariffs and Trade (GATT), can say that the Codex's requirements are a restraint of trade. And the exporters will prevail. Other countries that want labeling of imported irradiated foods will not be permitted to require it.

So it is essential that we write opinion pieces and letters to the editor, inform journalists, contact our Congressional representatives and senators, get on talk radio, and tell our families and friends. Most people don't want irradiation, and they don't like the government taking away their freedom of choice. We only have to let enough people know.



Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, Maryland 20852

Re: Docket # 98N-1038, "Irradiation in the Production, Processing, and Handling of Food"

To whom it may concern:

The FDA should retain the current labeling law, the current terminology of "treated with radiation" or "treated by irradiation," and the use of the radura symbol on all irradiated whole foods.

Regarding the issue of labeling, in its initial petition, the FDA concluded that irradiation was a "material fact" about the processing of a food, and thus should be disclosed. The material fact remains; therefore, labeling should remain. Consumer acceptability, storage qualities and nutrients are affected. Some irradiated foods have different texture and spoilage characteristics than untreated foods. Most fruits and vegetables have nutrient losses that are not obvious or expected by the consumer.

In addition, processing by irradiation causes chemical changes that are not evident and are potentially hazardous. Meat may have a higher level of carcinogenic benzene. All irradiated foods contain unique radiolytic products that have never been tested.

Whether or not the FDA has approved irradiation as safe, it remains a new technology with no long-term human feeding studies. Consumers certainly have a right to know if this process has been used on their food.

As to the kind of label used, I believe that label should be large enough to be readily visible to the consumer, on the front of the package. The label contains important information regarding the processing of the contents. For displayed whole foods such as produce, a prominent informational display similar to that used for meats should be used (but containing the term "irradiation" and the radura).

Because of the newness of the technology and the need to assess the public health effects of widespread use of irradiated foods, I believe that the FDA's labeling requirement should not be permitted to expire.

    Yours truly,



Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, Maryland 20852

Re: Docket No. 98N-1038, Irradiation in the Production, Processing, and Handling of Food

To whom it may concern:

I support the recommendation by the Center for Science in the Public Interest regarding labeling of irradiated foods:

"any foods, or any foods containing ingredients that have been treated by irradiation, should be labeled with a written statement on the principal display panel indicating such treatment. The statement should be easy to read and placed in close proximity to the name of the food and accompanied by the international symbol. If the food is unpackaged, this information should be clearly displayed on a poster in plain view and adjacent to where the product is displayed for sale."

Like other labels, irradiation labels are required by FDA to be truthful and not misleading. I believe that the terms "treated with radiation" or "treated by irradiation" should be retained. Any phrase involving the word "pasteurization" is misleading because pasteurization is an entirely different process of rapid heating and cooling.

I recognize the radura as information regarding a material fact of food processing. The requirement for irradiation disclosure (both label and radura) should not expire at any time in the future. The material fact of processing remains. Even if some consumers become familiar with the radura, new consumers (e.g., young people, immigrants) will not be. The symbol should be clearly understandable at the point of purchase for every one. If there is no label, consumers will be misled into believing the food has not been irradiated.

I urge you to place the comments received on the Internet so that the public can be informed about who is participating in this comment process.


This action alert has been generated by:
The Campaign for Food Safety (formerly known as the Pure Food Campaign)
860 Highway 61
Little Marais, Minnesota 55614
For more information on irradiation:
(213) 387-5122 or
Web page with links and background:
Anuradha Mittal
Policy Director
Institute for Food and Development Policy - Food First
398 60th Street
Oakland, CA 94618
(510) 654-4400 / Fax: (510) 654-4551

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