28 March 2016
Food Standards Australia New Zealand Food Standards Australia New Zealand
Submission on Rec 34: Review required labelling of irradiated foods
FSANZ will acknowledge that FSANZ and the Food Forum have already approved 24 fruits and vegetables for radiation energy exposure of at least 1.5 million chest x-rays: apple, apricot, bread fruit, capsicum, carambola, cherry, custard apple, honeydew, litchi, longan, mango, mangosteen, nectarine, papaya (paw paw), peach, persimmon, plum, rambutan, rockmelon, scallopini, strawberry, table grape, tomato, zucchini (courgette). It is understood that blueberries and raspberries are also being considered for irradiation.
These foods cover a substantial range of the fresh foods consumed in the daily diet. What child does not take an apple to school in his/her lunch box or eat sandwiches spread with jam made from plums, apricots, berries or other fruits? How often do tomatoes or capsicums go into a salad, or any of the above fruits go into a fruit salad or other fruit dish?
Removing mandatory labelling of irradiated foods denies consumers the right of choice as to whether they ingest those foods or fresh non-irradiated foods, and whether or not to feed them to the most vulnerable in society, infants and children.
Currently, irradiated fruits, vegetables, herbs and spices are labelled so consumers know they are processed and not fresh, and can therefore make an informed choice.
Most countries require irradiated foods to be labelled and prescribe wording for labels. These countries are not currently reviewing their requirements. New Zealand and Australian consumers should also retain the right to be informed.
Irradiation technology is used to cuts costs and disguise poor management practices, including controlling fruit fly worms and extending shelf life; neutralising but not removing some food contaminants. Irradiation affects the value of some vitamins and nutrients, and at some radiation doses may actually create toxins and carcinogens. Consumers have a basic right to know what is done to the food they put in their mouths.
Reasons why we should not irradiate foods
Irradiation kills most bacteria, including beneficial bacteria that naturally control the growth of harmful bacteria. It also potentially adversely affects the nutritional value of a significant proportion of a fresh fruit, vegetable or grain, and these can go on to be used in dried, canned and/or frozen processed foods. Some studies suggest irradiated foods may lose 5-80 percent of many vitamins, particularly vitamin A, thiamin, B2, B3, B6, B12, folic acid, C, E, and K. Amino acid and essential polyunsaturated fatty acid content may also be affected.  The amount of loss depends on the dose of irradiation and the length of storage time.
Foods not irradiated - i.e. fresh foods - contain high levels of phytonutrients and digestive enzymes necessary for good health. They are powerhouses to help fight disease. Among others claimed2:
· Black raspberries have been shown to reverse oral cancer
· Pomegranates to halt prostate cancer
· Green tea to halt breast cancer;
· Berries generally can prevent heart disease.2
A study looked at the viability of broccoli seeds and functional properties - such as ascorbic acid, carotenoid, chlorophyll, and total phenol contents - of broccoli sprouts grown from seed irradiated using electron beam and gamma ray at doses up to 8 kGy. The yield ratio and sprout length decreased with increased irradiation dose. The resulting underdeveloped sprouts had decreased ascorbic acid, carotenoid, and chlorophyll contents. In another study, looking at irradiation to disinfest wheat, the researchers found, “...irradiation significantly reduced seed germination and seedling vigour.” Irradiation caused adverse effects in both studies.
Fresh fruits and vegetables such as those already approved for irradiation treatment are vital sources of Vitamin C, important for healthy gums, teeth, bones, and muscles, for healing wounds and fighting infection and many experts say it contributes to a reduced risk of heart disease, cancer, and cataracts. Vitamin C levels have been shown to be reduced in foods exposed to commercial levels of irradiation. At low doses (0.3 to 0.75 kGy) irradiation has been found to destroy up to 11 percent of Vitamin C in fruit before storage, and up to 79 percent of Vitamin C after three weeks of storage.
While the extent to which vitamin loss occurs will vary based on a number of factors, including the type of food, irradiation levels, and availability of oxygen, vitamin loss almost always increases with increasing doses of radiation and the destruction of vitamins continues beyond the time of irradiation. Irradiated food that is stored, experiences greater vitamin loss than food not irradiated. At the limit of its shelf life of 270 days, irradiated mango pulp contained 57 percent less Vitamin C than non-irradiated mango pulp at the limit of its shelf life of 60 days.
Vitamin E is the most sensitive fat-soluble vitamin with losses of 50 percent when irradiated with oxygen present and Vitamin B1 (Thiamine) has been shown to be the most vulnerable to radiation.
Officially we may maintain that the average NZ diet is adequate, yet with all the changes in the production of fruit and vegetables this can be a serious misconception. There are references made to other sources of reduction in food values and when these are added to those of irradiation, the cumulative effect will be far greater. Where are the safety data on these cumulative effects? People who eat less than two servings of fruits and/or vegetables per day may not receive sufficient Vitamin C. For example, the elderly, children, alcoholics, men living alone who develop ‘widower’ or ‘bachelor’ scurvy, people with medical conditions that may prevent the intake and/or absorption of nutrients, dialysis patients, and people with inflammatory bowel disease (Crohns Disease), malabsorption disorders or severe dyspepsia.  In communities where nutrient intake is marginal, up to 15 percent of the population may be scorbutic (<0.2mg/100ml serum) without a further reduction in dietary input by eating irradiated foods. A scorbutic condition can lead to an increased risk of bacterial endotoxin toxicity: for example, with many of the impoverished and nutrient-deficient South Auckland populations.
The latent scorbutic state can then be converted into frank scurvy by infections, and even vaccines, and under such conditions hemorrhagic phenomena are frequent. All of the patho-physiological features of haemorrhagic and thrombotic conditions found in bacterial meningitis, for example, are seen in ascorbic acid deficiency states.
While irradiation (or pasteurization) may kill 99.9 percent of the pathogens present, and may decrease outbreaks of food-borne illnesses, as consumption of a greater range of irradiated food products increases, there may be unintended consequence of increasing the number of people who get sick from other infections and chronic diseases due to the fact that the ‘natural’ advantages in fresh food plants have been at least diminished in the irradiation process. The long-term health consequences of eating irradiated food are still unknown and untested, an inexcusible situation.
Multiple studies support the premise that an increased rate of pathogen growth may occur when irradiated food is cross-contaminated with a pathogen, as the competing spoilage organisms are no longer present.
For example, spores from the toxigenic organism Aspergillus ochraceus NRRL-3174 were exposed to specific levels of gamma irradiation and then allowed to germinate, and increases in ochratoxin A production by irradiated, compared to non-irradiated, spores were observed after inoculation of spores onto a cracked red wheat.
As FSANZ will know, irradiation creates a complex series of reactions that alter the molecular structure of food and creates known carcinogens. Irradiation damages food by breaking up molecules and creating free radicals.
Free radicals kill some bacteria, but can also damage vitamins and enzymes, and combine with existing chemicals, such as pesticides, in a food to form new chemicals known as unique radiolytic products (URPs).
In a 2002 study, Wistar rats received daily a solution of highly pure 2-tetradecylcyclobutanone (2-tDCB) or 2-(tetradec-5-enyl)-cyclobutanone (2-tDeCB) at a concentration of 0.005 in 1 percent ethanol as drinking fluid – substances known only in irradiated foods. Control animals received 1 percent ethanol. All animals received a single intraperitoneal injection of the chemical carcinogen azoxymethane (AOM) at weeks 3 and 4. The researchers found that, “At six months, the total number of tumours in the colon was threefold higher in the 2-ACB-treated animals than in the AOM controls” and “Multiple tumours were observed in four and three of six animals treated with 2-tDCB or 2-tDeCB, respectively. Medium (6 < S < 25 mm3) and larger (>25 mm3) tumours were detected only in 2-ACB-treated animals.”
The European Food Safety Authority acknowledges that, “As ionising radiation passes through food, it creates a trail of chemical transformations by primary and secondary radiolysis effects. The main reported radiolytic products are certain hydrocarbons and 2-alkylcyclobutanones produced from the major fatty acids in food, and some cholesterol oxides and furans.” Available “data indicate that at least some 2-alkylcyclobutanones may induce DNA damage in vitro. Yet no in vivo genotoxicity studies are available...” and “Concerning other radiolytic products no new relevant toxicological studies have been reported.” This is unacceptable in terms of safety issues for human consumers. EFSA goes on to say that, “evidence was indicated in publications on leukoencephalomyelopathy in cats which have been fed mainly or exclusively with highly irradiated feed” and “the relevance of the cats’ studies for human health should be clarified.”
An Australian company had to recall cat food products involving irradiation and 40 cats were euthanized after severe paralysis following ingestion of one product marketed by the company. Scientists concluded the cat deaths were caused by Vitamin A depletion, saying irradiation treatment is known to deplete vitamin A. Of the cats studied, histopathological damage to the white matter of the spinal cord and brain was observed.
As long ago as 1977, the US Army discovered that of 65 chemical compounds found in irradiated beef, 35 did not naturally occur in that particular food, five did not naturally occur in any food, and 15 increased in concentration due to the irradiation processing, including benzene, a known carcinogen. The researchers also noted that with irradiated food “the possible presence of undetected substances can never be excluded.” Other URPs are known toxins, such as quinones, formaldehyde and lipid peroxides, and many are unique to irradiated foods. Studies have still not adeqeuately covered the long-term effect of these new chemicals in the human diet and we cannot simply assume they are safe.1
However small each factor is, the cumulative effects of continuous ingestion of irradiated foods have not been studied or proven safe.
Of particular concern is the fact that there are no studies on the effects of feeding babies or children diets containing irradiated foods, except for a very small study in India which found four of five children fed irradiated wheat developed polyploidy, a chromosomal abnormality that is a good indication of future cancer development.
Studies on animals fed irradiated foods continue to show an increase in tumours, reproductive failures and kidney damage among other effects. The causes may include irradiation-induced vitamin deficiencies, inactivity of enzymes in the food, DNA damage, and/or toxic radiolytic products in the food.3
When the US FDA approved irradiation for poultry, the approval was based on 5 of 441 animal-feeding studies. Toxicologist, Dr Marcia van Gemert, who chaired the committee that approved irradiation, later said: “These studies reviewed in the 1982 literature from the FDA were not adequate by 1982 standards, and are even less accurate by 1993 standards to evaluate the safety of any product, especially a food product such as irradiated food.” Does this still stand in 2016?
The standards of studies quoted as approving irradiation still need critical analysis by independent scientists. The five studies mentioned above showed adverse health effects on the animals in the tests and/or were conducted using irradiation at lower energies than those the FDA eventually approved. The Department of Preventative Medicine and Community Health of the New Jersey Medical School found two of the five studies were methodologically flawed. In a third study, animals eating a diet of irradiated food experienced weight loss and miscarriage, almost certainly due to irradiation-induced Vitamin E dietary deficiency.
The remaining two studies investigated the effects of diets of foods irradiated at doses below the FDA-approved general level of 100,000 rads. That fact alone eliminates them in justifying food irradiation at the FDA approved levels.
Twelve studies carried out by Raltech Scientific Services Inc. under contract to the US government, examined the effect of feeding irradiated chicken to several different animal species. The studies revealed the possibility of chromosome damage, immunotoxicity, greater incidence of kidney disease, cardiac thrombus, and fibroplasia. Studies of rats fed irradiated food also indicate possible kidney and testicular damage and a statistically significant increase in testicular tumours.5
Irradiation also stimulates aflatoxin production, which occurs naturally in humid areas and tropical countries in fungus spores and on grains and vegetables. The World Health Organization considers aflatoxin to be a significant public health risk and a major contributor to liver cancer in the South.
Irradiation will also potentially have a mutagenic effect on bacteria and viruses that survive exposure becoming radiation-resistant.5 Radiation-resistent strains of salmonella have already been developed under laboratory conditions. Scientists at Louisiana State University in Baton Rouge found bacteria in spoiled meat and animal faeces that can survive a radiation dose five times that the FDA is suggesting for beef. Scientists exposed bacteria (D. radiourans) to between 10 and 15 kGy of radiation for several hours - enough radiation to kill a human subject many thousand times over. The bacteria, which scientists speculate evolved to survive extreme conditions of dehydration, survived the radiation exposure.5
The FDA is reported to have based its approval of irradiation for fruits and vegetables on a theoretical calculation of the amount of URPs in the diet from one 7.5 oz. serving per day of an irradiated food.
Considering the varieties of foods that could potentially be approved for irradiation, and the wide variations in varieties and quanties consumed in human diets, this quantity was obviously inadequate and provided a misleading result.
The European Food Safety Authority Panel on Biological Hazards (BIOHAZ) considered the efficacy of food irradiation and concluded “food irradiation should be based on risk assessment and on the desired risk reduction rather than on predefined food classes/commodities and doses as proposed in the past. . . . Irradiation should be considered as one of several approaches to reducing pathogens in food and thus helping to ensure protection of consumers’ health.” The EFSA also recommended food irradiation should only be used in conjunction with an integrated food safety management programme. Is such an approach maintained to a sufficiently high standard, if at all?
Of concern is the fact that, as with genetically engineered foods, there is no regulatory body monitoring the effects of ingesting irradiated foods in any quantity for any period of time, thus epidemiologists cannot determine what are those effects. It may take decades to demonstrate a statistically significant increase in cancer and/or other diseases or adverse effects due to mutagens and other factors introduced by food irradiation. The current absence of independently approved acceptable testing methods for irradiated foods also leaves consumers with inadequate protection. The foods listed in this Application, if irradiated, could further disadvantage the following significant percentages of New Zealand children and adults involved in establishing government health statistics:
· 66.3% of adults ate at least three servings of vegetables per day: 33.7% did not.
· 69% of women ate at least three servings of vegetables per day: 31% did not.
· 64% of men ate at least three servings of vegetables per day: 36% did not.
· 47% of Pacific adults ate at least three servings of vegetables per day: 53% did not.
· 58% of adults living in the most deprived areas were less likely to eat at least three servings of vegetables per day.
· Two out of five children ate the recommended two serves of fruit per day: 60% did not.
· Three out of five children ate three or more vegetables per day: 40% did not.
· 58.2% of adults ate two or more servings of fruit per day: 41.8% did not.
· 51% of adults living in the most deprived areas were less likely to eat at least two servings of fruit per day
· 64% of adults living in the least deprived areas were less likely to eat at least two servings of fruit per day: 36% did not.
PSGR maintains that FSANZ must be open to alternative, safer methods of decontamination, other than irradiation to meet their duty of care to the consumers, especially those less wealthy and less well.
Polls in the US – where irradiated foods are most freely available - have clearly shown people do not want irradiated foods and look to buy non-irradiated food in stores. Some stores reportedly will not stock irriadated foods in order to support consumer choice.
New Zealand growers that export the fruits and vegetables listed may be exposed to greater competition or market exclusion for foods that may be irradiated. It may also reflect on New Zealand’s ‘clean green’ image for tourism.
Retaining labelling for irradiated foods
In the light of the forementioned studies, PSGR urges FSANZ to retain full, accurate irradiated food labelling that is plainly visible in a legible font size on any product that has been irradiated; and for supermarkets and food markets to be mandated to display large informative signs for the benefit of the buying public.
PSGR further urges FSANZ to not support irradiation of fresh produce further and to establish and maintain a labelling system that also includes the source of the irradiation: Gamma rays as emitted by the radionuclides cobalt-60 (Co-60) or caesium-137 (Cs-137); Electrons (electron beams, E-beams) or X-rays.
We urge FSANZ to do this as an acknowledgement that the listed irradiated foods cover too many of the basic, daily fresh foods essential for sound human health.
Is there a system in place to continuously monitor for effects from ingesting irradiated foods over an extended time period? Removing labelling on foods for human consumers leaves no recourse on adverse effects manifested.
The food regulation review process of FSANZ has a legislated mandate to protect public health and safety. PSGR urges Food Standards Austria New Zealand (FSANZ) to retain mandatory labelling of irradiated foods to meet this duty of care. Most other countries require irradiated food labels, prescribe label wordings and are not reviewing their requirements. Australasian consumers should retain that right, too.
The Trustees and Members of Physicians and Scientists for Global Responsibility Charitable Trust
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