International Journal of Health Services
Number 1, Pages 187-192, 2001
PREVENTING PATHOGENIC FOOD POISONING: SANITATION NOT
Samuel S. Epstein and Wenonah Hauter
Bacterial food poisoning can be readily prevented by long
overdue basic sanitary
measures rather than by ultrahazardous
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 (2).
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 (8).
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
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 tourist revenues.
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
- 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
- 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 9, 1982.
- van Gemert, M. Letter to New Jersey Assemblyman John Keller, October
- 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, 1988.
- 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, 1989.
- 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, August, 1996.
- 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, 2000.
- 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, Washington, DC
Berhan and Sue Edwards, Institute for Sustainable Development, Addis
Dr. Rosalie Bertell, International Institute of Concern
for Public Health, Toronto, Canada
Barbara Brenner, J.D. Executive
Director Breast Cancer Action, San Francisco, CA
Dr. Barry Castleman,
Environmental Consultant, Baltimore, MD
Vera Chaney, Green Network,
Leyden, Colchester, Essex, U.K.
Citizens Concerns, USA
Cummins, National Director Organic Consumers Association, Little Marais,
Dr. Donald Dahlsten, Professor and Associate Dean, University of
California, Berkeley, CA
Dr. Robert Elder, Senior Microbiologist Neogen
Co., Lansing, MI, formerly Senior Scientist Agricultural Research Service,
Margarita Florez, Instituto Latinoamericano de Servicios Legales
Dr. John Gofman, Emeritus Professor Molecular and
Radiation Biology, University of California, Berkeley, CA
Goldsmith, M.A., Publisher and Editor The Ecologist, London, U.K.
Jay M. Gould, Director Radiation and Public Health Project, USA
Hayes, President Rainforest Action Network, USA
Luc Hens, M.D.,
Professor Department of Human Ecology, Brussels Free University,
Dr. Mae-Wan Ho, Director Institute of Science in Society, The
Open University, Milton Keynes, U.K.
Jeffrey A. Hollender, President
Seventh Generation, Burlington, VT
Dr. Vyvyan Howard, Professor
Pathology, University of Liverpool, U.K.
S. M. Mohamed Idris,
President, Consumers' Association of Penang, Sahabat Alam Malaysia
(Friends of the Earth Malaysia) and Institute Masyarakat Berhad, Penang,
Martin Khor, Director Third World Network, Penang,
Dr. David Kriebel, Professor Epidemiology, University of
Massachusetts, Lowell, MA
Lynn Landes, Founder and Director Zero Waste
America, Yardley, PA
Dr. Marvin Legator, Professor Preventive Medicine,
University of Texas, Galveston, TX
Rabbi Michael Lerner, Ph.D., Editor
TIKKUN Magazine, San Francisco, CA
Dr. William Lijinsky, former
Director Chemical Carcinogenesis, Frederick Cancer Research Center,
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
Margen, Emeritus Professor Public Health Nutrition, University of
California, Berkeley, CA and Chairman of the Berkeley Wellness
George Monbiot, Health and Science Columnist, The Guardian,
Raymond Monbiot, Fellow of the Marketing Society, London,
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,
Debbie Ortman, National Field Organizer, Organic Consumers
Association, Duluth, MN
Dr. Peter Phillips, Professor Sociology, Sonoma
State University, Rohnert Park, CA
Dr. Robert Rinehart, Emeritus
Professor Biology, San Diego State University, CA
Dr. Janette Sherman,
Research Associate Radiation and Public Health Project, and Adjunct
Professor Department of Sociology, Western Michigan University, MI
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
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.
Quentin Young, past President American Public Health Association, Chicago,
Direct reprint requests and further endorsements to:
Dr. Samuel S. Epstein
Emeritus Professor Environmental
and Chairman the Cancer Prevention Coalition
Illinois School of Public Health
2121 W. Taylor St., Chicago, IL 60612
Critical Mass, Energy and
215 Pennsylvania Avenue, S.E., Washington, D.C.,