International Journal of Health Services
Volume 31, Number 1, Pages 187-192, 2001

PREVENTING PATHOGENIC FOOD POISONING: SANITATION NOT IRRADIATION
Samuel S. Epstein and Wenonah Hauter

Bacterial food poisoning can be readily prevented by long overdue basic sanitary
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 (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 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 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 Citizen.

REFERENCES

1. Congress Pressures FDA For Softer Labeling Of Irradiated Foods. FDA Week, p. 9-10, May 12, 2000.
2. 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.
3. 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.
4. Epstein, S. S., and Gofman, J. W. Irradiation of food. Science 223:1354, 1984.
5. Sun, M. Science 223:1354, 1984.
6. van Gemert, M. Memorandum Re: Final Report of the Task Group for the Review of Toxicology Data on Irradiated Food. April 9, 1982.
7. van Gemert, M. Letter to New Jersey Assemblyman John Keller, October 19, 1993.
8. 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.
9. Piccioni, R. Food irradiation: contaminating our food. Ecologist 18(2):48-55, 1988.
10. 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.
11. Murray, D. R. Biology of Food Irradiation. RSP Research Studies Press Ltd., Taunton, Somerset, England, 1990.
12. Food Chemical News, Irradiation compounds vitamin loss from cooking, ARS Reports. November 10, 1986, p. 42.
13. 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.
14. 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.
15. Alvarez, R. Food irradiation: 50 years of hollow promises. Bull. Atom. Sci. 2000, in press.
16. 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.
17. Diaz-Gonzalez, F. et al. Science 281:1666-1668, 1998.
18. Analysis of Ontario E.coli Walkerton pollution disaster. The Gallon Environmental Letter, Montreal, Quebec, May 2000.

ENDORSEMENTS

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
Tewolde Berhan and Sue Edwards, Institute for Sustainable Development, Addis Ababa, Ethiopia
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
Ronnie Cummins, National Director Organic Consumers Association, Little Marais, MN
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, USDA
Margarita Florez, Instituto Latinoamericano de Servicios Legales (ILSA), Columbia
Dr. John Gofman, Emeritus Professor Molecular and Radiation Biology, University of California, Berkeley, CA
Edward Goldsmith, M.A., Publisher and Editor The Ecologist, London, U.K.
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, 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, Malaysia
Martin Khor, Director Third World Network, Penang, Malaysia
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, 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, 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
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, Chicago, IL

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

Wenonah Hauter
Public Citizen
Critical Mass, Energy and Environment Program
215 Pennsylvania Avenue, S.E., Washington, D.C., 20003