Irradiated Food: Safe or Scandalous?

The other night I was at a dinner party. Several of the invited were public-interest policy wonks, and the table-conversation at my end was mostly politics. At the conclusion of the meal, the hostess asked one of the guests to say a few words about why he was there. As he spoke, I realized why our host had waited until after dinner to have him speak.

Dr. Samuel Epstein, a professor at the public health school of the Illinois Medical Center, was promoting a study he had cowritten on how the Food and Drug Administration has legalized food irradiation without adequately testing the process. He was happy to describe the report he had worked on with Mark Worth and Wenonah Hauter of Public CItizen's Critical Mass Energy and Environment Program. It was not talk that would have enhanced one's appetite.

He quickly gained our attention with a factoid: beef, which is irradiated (that is, shot with radiation to kill off bacteria and increase the product's shelf-life), undergoes the equivalent of 150 million chest x-rays. The food and irradiation industries maintain this poses no threat to whoever ends up eating the treated meat. A reasonable reaction from a lay person is a skeptical "yeah, right." Epstein was armed with more than skepticism.

First some background: the FDA has been approving food irradiation for the past seventeen years. It started with spices in 1983, moved to pork in 1985. Then came fruits and vegetables in 1986, poultry in 1990, beef and lamb in 1997, and eggs in July. In May, irradiated meat went on sale in the United States. Epstein and the report contends that these approvals were based on a small number of sub-standard tests.

As you might expect, the debate over irradiation can become enmired in scientific jargon. What's a consumer to do? Has the FDA and the food industry actually endorsed a procedure that boosts profits at the expense of the public?

Epstein and his colleagues maintain they have, and one of the more alarming portions of their argument concerns what's known as unique radiolytic products. These URPs are chemical compounds that are created within food when it is exposed to the radiation. A 1977 study conducted for the Army discovered that of 65 chemical compounds found in irradiated beef, 35 did not naturally occur in this food, five did not naturally appear in any food, and 15 increased in concentration due to irradiation. The latter category included benzene, which has been branded a carcinogen by the Environmental Protection Agency. This 1977 study also noted that with irradiated food, "the possible presence of undetected substances can never be excluded."

So the chemical composition of the food was changed. Shouldn't the next step have been for the FDA to conduct rigorous tests on the URPs? Nah. According to the report Epstein co-wrote, the FDA's Irradiated Food Committee "stated, without presenting specific evidence, that any URPs formed in irradiated food likely would not cause health problems in humans because the chemicals likely would be similar to chemicals in non-irradiated food." That seems a conclusion based more on hope than science.

The scientists who conducted the 1977 study called for further study of URPs in irradiated foods. Because "insufficient data are available to allow judgment of the effects on health," they said that "metabolic and toxicological studies of these compounds are desirable." But the Public Citizen report notes that no extensive testing of this sort occurred and that the FDA's Irradiated Food Committee did not consider the formation of URPs in irradiated poultry, pork, vegetables and eggs before giving the go-ahead for nuking these products.

Before the FDA legalizes a food additive, it must establish, according to federal regulations, "a reasonable certainty in the minds of competent scientists that the substance is not harmful under the intended condition of use." The FDA has to use a tight standard: it must determine the highest level at which laboratory animals are not harmed by the substance and then divide it by 100.

But the FDA has not followed this procedure in the case of URPs. As the report states, "The FDA legalized the irradiation of beef in 1997 without formally reviewing any studies in which [significant] concentrations of radiolytic products were fed to lab animals....In short, the FDA does not know whether the new chemicals formed in irradiated beef can be harmful to humans."

Epstein and his colleagues also say that when the FDA legalized the irradiation of poultry (1990) and eggs (1999), it did not release any information regarding the identity and quantity of URPs in these products. Moreover, their report claims that in 1981 an FDA panel reviewed 409 toxicology standards on irradiated food and labeled all but five "deficient." Even though none of the five met FDA standards, they formed the foundation of FDA's pro-irradiation rulings.

Epstein asserts irradiation is dangerous; it results in nutritional loss within the treated foods. (Imagine malnourished beef eaters.) He points to studies that found gross chromosonal abnormalities in animals fed irradiated food. And then there's the risk posed by possible accidents in irradiation facilities. His Public Citizen report calls for revoking all food irradiation permits and an all-out independent testing program for irradiated foods.

It's not easy for the non-scientific among us to navigate through a technical controversy. In these disputes, industry often pooh-poohs the critics and cites its own no-reason-to-worry research. But the Public Citizen report includes a 1998 FDA memo that supports those doubtful of the FDA on this front. The memo lists three animal studies that were used to justify the agency's decision to permit the irradiation of eggs. But the document notes that the first of these was accepted by the FDA "'with reservation' because it was only a summary report," the second was reviewed and "rejected" because it was "hard to follow," and the third was identified by the FDA as a "weak study because only a few toxicological parameters were measured." But each of these studies maintained that irradiated eggs pose no threat, and the FDA concluded that despite their individual flaws the studies, "taken together," backed the irradiation of eggs. This reliance upon less-than-stellar research hardly inspires confidence.

The nuke-the-food cheerleaders argue that irradiation thwarts such health threats as E. coli. (The process also allows the industry to sell the stuff for longer and ship it further.) But improving sanitation in the food industry would address most of the health problems.

Still, the industry is looking to irradiate a wider slice of the food chain. The National Food Processors Association, which lobbies for the $460 billion food processing industry, has asked the FDA to okay irradiating "ready-to-eat" foods, which make up about one-third of the typical American's diet. And, according to the Public Citizen report, if the government approves all the pending requests for food irradiation, 90 percent of the average Joe's diet will be foods eligible for irradiation.

The FDA, under pressure from industry and its allies in Congress, is also considering changing the rules that require irradiated foods to be labeled as such. Possible replacement terms include "cold pasteurized" and "electronically pasteurized." (The second of these terms was proposed by the San Diego-based Titan corporation, a military contractor that developed a costly linear accelerator for Ronald Reagan's semi-defunct Star Wars program. It now wants to shoot at food rather than incoming missiles.)

Whatever happened to the free market? Why not put a big label on these foods that proclaims "Zapped with Radiation Equivalent to 150 Million Chest X-Rays!" and then let market forces run their course?

Epstein's post-dinner talk sounded rather convincing. (Was it his British accent?) And a recent paper he wrote with Wenonah Hauter proposing a sanitation-not-irradiation policy was endorsed by two dozen scientists and public health experts. As I listened, I sure wondered about the delicious beef we had been served earlier, and, I assume, the other guests did, too. But no one dared ask. It wouldn't have been polite. Besides, what was in, was in. Which is the point. Consumers should be able to have confidence in the food supply and the government officials who are entrusted with the task of safe-guarding it. Epstein and his Public Citizen have raised unsettling questions -- questions that Congress, the Administration and the FDA ought to digest.

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