International Journal of Health Services
Volume 31, Number 1, Pages 187-192, 2001
Samuel S. Epstein and Wenonah Hauter
food poisoning can be readily prevented by long overdue basic
measures rather than by ultrahazardous irradiation technologies.
The food and nuclear industries, with strong government support,
have capitalized on recent outbreaks of pathogenic E.coli 0157
meat poisoning to mobilize public acceptance of large scale food
irradiation. Already, the Food and Drug Administration (FDA) is
allowing the use of high-level radiation to "treat" beef, pork,
poultry, eggs, vegetables, fruit, flour and spices, while the United
States Department of Agriculture (USDA) proposes the imminent irradiation
of imported fruit and vegetables.
Caving in to powerful corporate
industry interests, both House and Senate Appropriations Committees
have recently proposed to
sanitize the FDA's already weakened labeling requirements for irradiated
food by eliminating the word "irradiated" in favor of "electronic
pasteurization" (1); this term was proposed by the San Diego based
Titan corporation, an erstwhile major defense contractor using
highly costly linear accelerator "E-beam" technology, originally
designed for President Reagan's "Star Wars" program, which shoots
food with a stream of electrons travelling at the speed of light.
However, the proposed electronic pasteurization label is a euphemistic
absurdity, especially since the FDA's approved meat radiation dosage
of 450,000 rads is approximately 150 million times greater than
that of a chest X-ray, besides circumventing consumers' fundamental
right to know.
Furthermore, the new labeling
initiative is reckless. Irradiated meat is a very different product
from cooked meat. Whether irradiated
by linear accelerators or pelletized radioactive isotopes, the
resulting ionizing radiation produces highly reactive free radicals
and peroxides from unsaturated fats. U.S. Army analyses in 1977
revealed major differences between volatile chemicals formed during
irradiation or cooking meat (2). Levels of the carcinogen benzene
in irradiated beef were found to be some tenfold higher than cooked
beef. Additionally, high concentrations of six poorly characterized "unique
radiolytic chemical products" admittedly "implicated as carcinogens
or carcinogenic under certain conditions," were also identified
Based on these striking changes
in the chemistry of irradiated meat, FDA's 1980 Irradiated Food
Committee explicitly warned that
safety testing should be based on concentrated extracts of irradiated
foods, rather than on whole foods, to maximize the concentration
of radiolytic products (3). This would enable development of sufficient
sensitivity essential for routine safety testing. In 1984, Epstein
and Gofman more specifically urged that "stable radiolytic products
could be extracted from irradiated foods by various solvents which
could then be concentrated and subsequently tested. Until such
fundamental studies are undertaken, there is little scientific
basis for accepting industry's assurances of safety" (4). In an
accompanying editorial comment, FDA was quoted as admitting that "it
is nearly impossible to detect (and test radiolytic products) with
current techniques" on the basis of which the agency's claims of
safety and regulatory abdication still persist (5).
While refusing to require standard toxicological and carcinogenicity
testing of concentrated extracts of radiolytic products from irradiated
meat and other foods, FDA instead has relied on some five studies
selected from 441 published prior to the early 1980's, on which
its claims of safety still remain based. However, the chair of
FDA's Irradiated Food Task Committee which reviewed these studies
insisted that none were adequate by 1982 standards (6), and even
less so by the 1990's (7). Furthermore, detailed analysis of these
studies revealed that all were grossly flawed and non-exculpatory
These results are hardly surprising since a wide range of independent
studies prior to 1986 clearly identified mutagenic and carcinogenic
radiolytic products in irradiated food, and confirmed evidence
of genetic toxicity in tests on irradiated food (9). Studies in
the 1970's, by India's National Institute of Nutrition, reported
that feeding freshly radiated wheat to monkeys, rats, mice and
to a small group of malnourished children induced gross chromosomal
abnormalities in blood or bone marrow cells, and mutational damage
in the rodents (10).
Food irradiation results in
major micronutrient losses, particularly vitamins A, C, E, and
the B complex (11). As admitted by the U.S.
Department of Agriculture's (USDA) Agriculture Research Service,
these losses are synergistically increased by cooking, resulting
in "empty calorie" food (12); this is a concern of major importance
for malnourished populations. Radiation has also been used to clean
up food unfit for human consumption, such as spoiled fish, by killing
odorous contaminating bacteria.
While the USDA is strongly promoting meat and poultry irradiation,
it has been moving to deregulate and privatize the industry by
promoting a self-policing Hazard Analysis and Critical Control
Point (HACCP) control program (13); in late 2000, the agency will
start a rulemaking process to privatize meat inspection. Moreover,
the Department of Energy (DOE) continues its decades long aggressive
promotion of food irradiation as a way of reducing disposal costs
of spent military and civilian nuclear fuel by providing a commercial
market for cesium nuclear wastes.
Irradiation facilities using pelletized isotopes pose risks of
nuclear accidents to communities nationwide from the hundreds of
facilities envisaged for the potentially enormous radiation market;
in contrast to nuclear power stations, these facilities are small,
minimally regulated, unlikely to be secure, and require regular
replenishment of cobalt (Co-60) or cesium (Cs-137) isotopes, entailing
nationwide transportation hazards. Furthermore, linear accelerators,
besides plants using radioactive isotopes, pose grave hazards to
workers and are subject to virtually no regulation (9, 14).
The track record of the irradiation industry is, at best, unimpressive.
Robert Alvarez, former DOE Senior Policy Advisor, recently warned
that the Nuclear Regulatory Commission files are bulging with unreported
documents on radioactive spills, worker over-exposure, and off-site
radiation leakage (15). Strangely, the Environmental Protection
Agency has still failed to require an Environmental Impact Statement
prior to the siting of food irradiation facilities.
The focus of the radiation and agribusiness industries is directed
to the highly lucrative cleanup of contaminated food rather than
to preventing contamination at its source (16). However, E. coli
0157 food poisoning can be largely prevented by long overdue improved
sanitation. Feedlot pen sanitation, including reducing overcrowding,
drinking water disinfection and fly control, would drastically
reduce cattle infection rates. Moreover, E. coli 0157 infection
rates could be virtually eliminated by feeding hay, rather than
the standard unhealthy starchy grain diet, for seven days prior
to slaughter (17). Sanitation would also prevent water contamination
from feed lot run off, incriminated in the recent outbreak of E.
coli 0157 poisoning in Walkerton, Ontario (18); run off will remain
a continuing threat even if all meat was irradiated.
Pre-slaughter, post-knocking and post-evisceration sanitation
at meat packing plants is highly effective for reducing carcass
contamination rates (16). Testing pooled carcasses for E. coli
0157 and Salmonella contamination is economical, practical, and
rapid. The expense of producing sanitary meat would be trivial
compared to the high costs of irradiation, including possible nuclear
accidents, which would be passed on to consumers. Additional high
costs are likely to result from an anticipated international ban
on the imports of irradiated U.S. food, and also from losses of
We charge that support of
the "electronically pasteurized" label
by the food and radiation industries, governmental agencies, and
Congress, is a camouflaged denial of citizen's fundamental right
to know. Rather than sanitizing the label in response to special
interests, Congress should focus on sanitation and not irradiation
of the nation's food supply.
Note - This article is largely based on a June 6, 2000
P.R. Newswire press release by the Cancer Prevention Coalition
and Public Citizen.
- Congress Pressures FDA For Softer Labeling Of Irradiated
Foods. FDA Week, p. 9-10, May 12, 2000.
- Federation of American Societies for Experimental Biology, Evaluation
of The Health Aspects of Certain Compounds Found in Irradiated
Beef. Report to the U.S. Army Medical Research and Development
Command, Bethesda, MD, August 1977.
- U.S. Food and Drug Administration. Recommendations for Evaluating
the Safety of Irradiated Food. Final Report of FDA's Irradiated
Food Committee. Washington, D.C., July 1980.
- Epstein, S. S., and Gofman, J. W. Irradiation of food. Science 223:1354,
- Sun, M. Science 223:1354, 1984.
- van Gemert, M. Memorandum Re: Final Report of the Task Group
for the Review of Toxicology Data on Irradiated Food. April
- van Gemert, M. Letter to New Jersey Assemblyman John Keller,
October 19, 1993.
- Public Citizen's Critical Mass Energy and Environment Program
and the Cancer Prevention Coalition. A Broken Record: How the
FDA Legalized and Continues to Legalize Food Irradiation Without
Testing it for Safety. Special Report, October 2000.
- Piccioni, R. Food irradiation: contaminating our food. Ecologist 18(2):48-55,
- Vijayalaxmi, and Srikantia, S. G. A review of the studies on
the wholesomeness of irradiated wheat conducted at the National
Institute of Nutrition, India. Radiat. Phys. Chem. 34(6):941-952,
- Murray, D. R. Biology of Food Irradiation. RSP Research
Studies Press Ltd., Taunton, Somerset, England, 1990.
- Food Chemical News, Irradiation compounds vitamin loss from
cooking, ARS Reports. November 10, 1986, p. 42.
- USDA Food Safety Inspection Service, Irradiation of Red
Meat: A Complication of Technical Data for its Authorization
and Control. International Consultative Group on Food Irradiation,
- Trager, E. A. Review of events at large pool-type irradiators. Office
of Analysis and Evaluation of Operational Data, U.S. Nuclear
Regulatory Commission, Washington, D.C., March, 1989.
- Alvarez, R. Food irradiation: 50 years of hollow promises.
Bull. Atom. Sci. 2000, in press.
- Elder, R. O. et al. Correlation of enterohemorrhagic E.coli
0157 prevalence in feces, hides and carcasses of beef cattle
during processing. Proc. Nat. Acad. Sci. 97(7):2999-3003,
- Diaz-Gonzalez, F. et al. Science 281:1666-1668, 1998.
- Analysis of Ontario E.coli Walkerton pollution disaster. The
Gallon Environmental Letter, Montreal, Quebec, May 2000.
Robert Alvarez, Former Senior Policy Advisor to the Secretary
of Energy and Executive Director the STAR Foundation
Kenny Ausubel, Collective Heritage Institute/Bioneers, Santa Fe, NM
Dr. Neal Barnard, President Physicians Committee for Responsible Medicine,
Tewolde Berhan and Sue Edwards, Institute for Sustainable Development,
Addis Ababa, Ethiopia
Dr. Rosalie Bertell, International Institute of Concern for Public Health,
Barbara Brenner, J.D. Executive Director Breast Cancer Action, San Francisco,
Dr. Barry Castleman, Environmental Consultant, Baltimore, MD
Vera Chaney, Green Network, Leyden, Colchester, Essex, U.K.
Citizens Concerns, USA
Ronnie Cummins, National Director Organic Consumers Association, Little
Dr. Donald Dahlsten, Professor and Associate Dean, University of California,
Dr. Robert Elder, Senior Microbiologist Neogen Co., Lansing, MI, formerly
Senior Scientist Agricultural Research Service, USDA
Margarita Florez, Instituto Latinoamericano de Servicios Legales (ILSA),
Dr. John Gofman, Emeritus Professor Molecular and Radiation Biology,
University of California, Berkeley, CA
Edward Goldsmith, M.A., Publisher and Editor The Ecologist,
Dr. Jay M. Gould,
Director Radiation and Public Health Project, USA
Randall Hayes, President
Rainforest Action Network, USA
Luc Hens, M.D., Professor Department of
Human Ecology, Brussels Free University, Belgium
Dr. Mae-Wan Ho, Director
Institute of Science in Society, The Open University, Milton Keynes,
Jeffrey A. Hollender, President Seventh Generation, Burlington, VT
Vyvyan Howard, Professor Pathology, University of Liverpool, U.K.
Mohamed Idris, President, Consumers' Association of Penang, Sahabat Alam
Malaysia (Friends of the Earth Malaysia) and Institute Masyarakat
Berhad, Penang, Malaysia
Martin Khor, Director Third World Network, Penang,
Dr. David Kriebel, Professor Epidemiology, University of Massachusetts,
Lynn Landes, Founder and Director Zero Waste America, Yardley, PA
Dr. Marvin Legator, Professor Preventive Medicine, University of Texas,
Rabbi Michael Lerner, Ph.D., Editor TIKKUN Magazine, San Francisco, CA
Dr. William Lijinsky, former Director Chemical Carcinogenesis, Frederick
Cancer Research Center, MD
Dr. E. Lichter, Professor Community Medicine, University of Illinois
Medical School, Chicago IL
Dr. Donald Louria, Chairman Department Preventive Medicine, New Jersey
Medical School, Newark, NJ
Dr. Sheldon Margen, Emeritus Professor Public Health Nutrition, University
of California, Berkeley, CA and Chairman of the Berkeley Wellness Letter
George Monbiot, Health and Science Columnist, The Guardian, London, U.K.
Raymond Monbiot, Fellow of the Marketing Society, London, U.K.
Dr. Vicente Navarro, Professor Health and Public Policy, The Johns Hopkins
University, Baltimore, MD, and Professor Political and Social Sciences,
University Pompeu Fabra, Spain
Dr. Herbert L. Needleman, Professor Pediatrics and Psychiatry, University
of Pittsburgh, Pittsburgh, PA
Debbie Ortman, National Field Organizer, Organic Consumers Association,
Dr. Peter Phillips, Professor Sociology, Sonoma State University, Rohnert
Dr. Robert Rinehart, Emeritus Professor Biology, San Diego State University,
Dr. Janette Sherman, Research Associate Radiation and Public Health Project,
and Adjunct Professor Department of Sociology, Western Michigan University,
Dr. Vandana Shiva, Director Research Foundation for Science, Technology
and Natural Resource Policy, Dehradun, India
Dr. George Tritsch, Cancer Research Scientist, Roswell Park Memorial
Institute, New York State Department of Health, NY
Stephen L. Tvedten, CEO Get Set, Inc., President of the Institute of
Pest Management, Marne, MI
Dr. Vijayalaxmi, Associate Professor Department Radiation Oncology, University
of Texas Health Science Center, San Antonio, TX
Frank D. Wiewel, President People Against Cancer, Otho, IA
Dr. Gesa Staats de Yanes, Professor Fetal and Infant Pathology, University
of Liverpool, U.K.
Dr. Quentin Young, past President American Public Health Association,
Direct reprint requests and further endorsements to:
Dr. Samuel S. Epstein
Emeritus Professor Environmental Medicine,
and Chairman the Cancer Prevention Coalition
University of Illinois School of Public Health
2121 W. Taylor St., Chicago, IL 60612
Critical Mass, Energy and Environment Program
215 Pennsylvania Avenue, S.E., Washington, D.C., 20003