The Canadian cabinet is expected to issue a policy statement on food irradiation some time in September 1987, in response to a House of Commons Committee Report issued in May 1987.

The Report includes thirty-three recommendations aimed at preventing any sudden or ill-considered increase in food irradiation technology until:

• certain questions about the health and nutritional value of irradiated food are answered,

• clear unambiguous labelling of irradiated food is required, and

• GOOD consultation processes involving scientists (for safety/nutrition questions) and consumers (for labelling and granting of case-by-case permission) have been put in place.

The nuclear industry is annoyed about this report and is urging cabinet to ignore it. They want to forge right ahead. If you feel that the kind of caution urged by the Committee is wiser, your views should be communicated to Ottawa before September 15.

BACKGROUND

Nuclear Industry Plans

In recent years, the nuclear establishment has been promoting the commercial use of food irradiation using gamma rays from cobalt-60 (produced as a by-product in nuclear power plants) or cesium-137 (produced as a by-product of nuclear weapons manufacture).

Selling points:

• kills all insects and many micro-organisms,

• extends shelf life by a few days,

• meets quarantine for exotic fruits from tropical countries, and

• reduces salmonella in poultry.

Motives:

• to find new markets for the nuclear industry,

• to give the industry a more positive public relations image, and

• to make inroads into Third World countries which do not yet have nuclear facilities.

Promoters:

• AECL (Atomic Energy of Canada Ltd.) manufactures gamma-irradiators using cobalt-60, of which Canada is the world's largest producer;

• cobalt-60 is produced by neutron bombardment of cobalt-59 in the control rods of Ontario Hydro's CANDU reactors.

Objectives:

• to have food irradiation reclassified as a "process" rather than an "additive" -- which, by law, requires less stringent testing;

• to ensure innocuous labelling using the "radura symbol", preferably with no words of explanation;

• to gain consumer acceptance for irradiated food in Canada so that exports of irradiation equipment to Third World countries are easier.

  (It is expected that Third World countries would irradiate food only for export because of the great expense.)

Government Involvement

By the time the House of Commons Standing Committee on Consumer and Corporate Affairs decided to look into the question of food irradiation, industry plans were already far advanced, and government had already been co-opted:

• Health and Welfare Canada was ready to re-classify irradiation as a process;

• the Department of Consumer and Corporate Affairs was ready to authorize innocuous labelling;

• Agriculture Canada was building a pilot plant at Ste-Hyacinthe (Quebec) to help private industry get into food irradiation;

• the Armand-Frappier Institute (with government subsidies) was building a larger experimental food irradiation plant at Laval (Quebec);

• the Department of External Affairs (through CIDA) was funding construction of a food irradiation plant in Thailand; and

• AECL was printing lots of glossy brochures and drumming up customers in various parts of the world.

Standing Committee Report

In May 1987, the Standing Committee published its report after extensive hearings in Ottawa. The Committee noted that:

• irradiation of food is not devoid of potential health risks;

• there are legitimate questions about both the safety and the nutritional value of irradiated food;

• there are occupational and environmental concerns about the plants themselves (each with more than a million curies of radioactivity, needing additional thousands of curies each year); and

• though irradiation of some foods (potatoes, onions, wheat, flour, spices) has been allowed in Canada since 1960, it has not been done commercially -- except briefly in the 1960s -- because it is too expensive.

Irradiation Technology

Irradiation aims to kill everything that is alive in the food. To accomplish this, a dose of ionizing radiation equivalent to thousands of medical x-rays must be delivered to the food in a short time. Such a dose would promptly kill any human being.

To deliver such a dose, large quantities of a highly radioactive material such as cobalt-60 or cesium-137 -- both of which give off intense gamma rays, even more powerful than x-rays -- are stored under water, in the form of rods, inside a heavily shielded irradiation chamber. The food is brought in on a conveyer belt, the door is locked to prevent any accidental escape of gamma rays, the radioactive rods are then lifted out of the water, and the dose is automatically delivered to the food.

Photons of ionizing radiation (unlike those of non-ionizing radiation) can break chemical bonds directly by stripping off orbital electrons. This creates hundreds of chemical fragments, "radiological products", some of which are also found in cooked or frozen foods, but some of which are unique to the irradiation process. The chemical formulas and long-term effects of many of these unique radiological products (URP's) is unknown.

In 1983, the US Army was allowed to irradiate bacon based on studies purporting to show it was safe. In 1988, the Army tried to extend the permission to ham. It was then discovered that the earlier studies had been falsified. Health problems in animals were unreported. Animals supposedly fed irradiated food were not. Animals supposedly autopsied were still alive. Permission for use of irradiated bacon was rescinded.

On April 8, 1988, the US Federal Register reported that of 441 toxicity studies purporting to show the safety of irradiated food, only five were valid studies by today's standards. Several respectable scientific publications have reported an increase in chromosome abnormalities (polyploidy) in rats, rice, monkeys and human children. Other studies have reported increases in dominant lethal mutations and in kidney lesions, decreases in litter size and in birth weight, as well as gonadal changes and effects on various metabolic and reproductive parameters. Many studies show no adverse effects, but a large number of these studies are also seriously flawed.

Irradiation destroys many vitamins, Industry says it is no worse than cooking, but they propose to irradiate many uncooked foods (like fruits) which are the main source of many vitamins.

Food irradiation is expensive.

• In 1978, the US Army decided that food irradiation was of interest to them, but not affordable. If the U.S. Army can't afford it, who can?

• The reason why potatoes and onions aren't irradiated in Canada, although they are allowed to be, is that it costs too much. A small enterprise that irradiated potatoes many years ago in the Eastern townships of Quebec went broke.

• More recently, a US company ("QIX") planning to build a food irradiation plant in British Columbia (using accelerated electrons instead of gamma rays) has gone broke, and the Canadian government is trying to recover $438 million in loans owed to Ottawa.

• Private investment will not touch food irradiation without government subsidies and/or guarantees.

• Irradiation is not cost-effective in controlling salmonella compared with other methods.

FOOD IRRADIATION IN CANADA - RECOMMENDATIONS -

Irradiation: Process or Additive?

The Food Irradiation Committee of the CCNR (Canadian Coalition for Nuclear Responsibility) has discussed the advisability of re-classifying the irradiation of food as a process rather than as an additive, and has come to the following conclusions:

1. Is Anything Added to the Food?

There is still much that is unknown about the hundreds of Unique Radiological Prcoducts (URP's) which are created in the food as a result of irradiation. These new chemical substances are added to the food in the sense that they were not previously there prior to irradiation. Indeed, there is no other method of food processing which introduces so many different new chemical substances into the food, albeit in very small amounts. (Unlike any other agent used in food processing, ionizing radiation indiscriminately and randomly breaks hundreds of thousands of chemical bonds, resulting in unstable molecular fragnents which can then recombine in unpredictable ways, resulting in a bewildering array of new chemical substances called URP's.) Despite decades of research, a great many of these URP's remain unidentified, so that even their chemical formulae are a mystery. This being the case, the sub-committee recommends that food irradiation continue to be classified as a food additive at least until these unknown URP's have been identified and tested.

2. Will Re-Classification have Any Advantages?

Those promoting food irradiation technology must see some practical advantages in changing the classification of this technology from an "additive" to a "process". The only advantages the subcommittee can identify would, in fact, be disadvantageous from the point of view of the consumer. These are listed below in point form:

• Advantage: Less animal testing may be required.
• Disadvantage: Less assurance of safety for the consumer.

• Advantage: Less stringent labelling for irradiated ingredients.
• Disadvantage: Less information available to the consumer.

• Advantage: Less difficulty in convincing people it's harmless.
• Disadvantage: Less awareness of the URP problem by consumers.

  3. Does the Status Quo have any Advantages?

  As stated above, the subcommittee believes that food irradiation should continue to be classified as an additive. One of the most important reasons for this is that whatever protection is available to consumers in the case of food additives should also apply in the case of food irradiation.

  Food is such a basic part of life, affecting all of us so intimately, that there is no excuse for shifting the burden 04 proof away from the commercial interests who are promoting this new technology. Nor should the standards of proof be relaxed in any way. (From a scientific point of vim, the testing requirements for irradiated food should be at least as stringent as those for chemical additives, since the situatior is complicated by the presence of literally hundreds of new chemicals, many of which are unknown.)

  This technology is not being demanded or practiced by consumers, but is being promoted by certain commercial interests. Consumers are entitled to full protection against any possible adverse side effects. They are entitled to full and complete information as to which foods and ingredients have been irradiate. They are also entitled to know that URP's have been incorporated into foods which have been irradiated. It is up to the industry promoting this technology to convince the authorities and the public that URP's are not harmful; it is not right that people should be prevented in any way from knowing that URP's have in fact been added to irradiated food. Yet changing the classification of food irradiation from an additive to a process may have that effect.

  4. Other Considerations

  Proponents admit that food irradiation won't replace all or even most chemical additives. Along with URP's, the effects of irradiation on such chemical additives must also be tested.

  Irradiation reduces vitamin content in fresh fruits and other fresh foods. Proponents argue that cooking also reduces vitamin content. However, most vitamins are obtained from uncooked foods. If these fresh fruits have been irradiated, the consumer suffers an overall loss of vitamin intake. Doses sufficient to reduce spoilage are not sufficient to eliminate botulism. Thus food which is poisonous may appear wholesome as a result of irradiation.

  Although processes such as freezing and cooking also introduce new chemicals into foodstuffs, they do not break chemical bonds in an indiscriminate and random manner. Consumers have accumulated decades of experience with these processes, and practice them at home. Unproven technologies like irradiation are treated differently precisely because they are unproven.

  B. Labelling of Irradiated Foods

  The subcommittee also considered the question of labelling of irradiated foods, and came to the following conclusions:

  1. Unambiguous Labelling

  Foods which have been irradiated should be labelled in an unambiguous way. The words "IRRADIATED" in English, and "IRRADIE" in French, should appear in a clearly legible format (in large letters with suitable contrast). Corresponding words in other languages may also be required to appear on the package where appropriate (e.g.. if the package contains any other information in those other languages).

  2. Appropriate Logo

  The use of a large, brightly colored, distinctive logo is recommended in addition to (but not as a replacement for) the explicit wording recommended above. However, the radura symbol is not recommended because it does not communicate any image that would suggest, in and of itself, that the food has been irradiated. By contrast, the commonly accepted symbols for such things as poisonous substances, explosive substances, corrosive substances, etc, attempt to communicate in visual form the concepts which the symbols are being used to represent. The subcommittee strongly recommends that government authorities require a better logo. An alternate design concept is attached for purposes of discussion.

  3. Irradiated Ingredients

  Any ingredients (including spices) which have been irradiated, should be so itemized in the list of ingredients. (Instead of "spices", one would read "irradiated spices".) Moreover, a smaller black-and-white version of the irradiation logo should appear beside the list of ingredients to indicate that some of the ingredients have been irradiated.

  4. Imported Foods

  Any foodstuffs imported into Canada should be subject to the same labelling requirements as food produced and/or packaged in Canada, as itemized above. Such foodstuffs should not be allowed into Canada however if the dose levels permitted in Canada have been exceeded,

  5. Dose Levels

  Full public hearings should be held in Canada to determine the maximum dose levels that will be permitted for foodstuffs. The recommendations of the International Atomic Energy Agency should not be accepted uncritically, given the fact that the IAEA is a promoter of nuclear technology.

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  Food Irradiation
  May 23 1987

  The nuclear industry is madly spending our money trying to convince us that we should expose our food to atomic radiation as a way of "extending the shelf life". On Tuesday, May 11, the Canadian Department of Agriculture opened a Food Irradiation Centre at Ste. Hyacinthe, built with taxpayer's money, to assist any private enterprise that might want to irradiate our food before selling it to us in the markets. On Friday, May 29, the Armand Frappier Institute will be opening an even larger Food Irradiation Centre at Laval, which also depends partly on public subsidies. If we do not want to have our food irradiated, now is the time to speak up. Here's what we can do:

  (1) Support the 33 recommendations in the House of Commons Committee Report on Food Irradiation that was issued on Thursday, May 14. The report acknowledges that there are legitimate questions about the "safety and nutritional value" of irradiated food. If implemented, the recommendations would prevent any hasty approval of food irradiation, and would protect the public interest by requiring explicit labelling, thorough testing, and full consultation.

  (2) Support our campaign to stop the spending of public money on such a questionable investment. Food irradiation is so expensive that the U.S. Army has decided it can't afford it. Although the irradiation of potatoes and onions (to prevent sprouting) has been allowed in Canada for many years, it is not being done because it costs too much. Why should the public purse subsidize an industry which is too financially risky for private investors?

  (3) Educate yourself and others on the subject. Irradiation is not an alternative to chemicals, but is intended to be used in addition to chemicals. Irradiation does not replace the need for refrigeration, curing, sanitary packaging or any other currently used method for preserving foods. On the other hand, irradiation does require the transport of large quantities of intensely radioactive materials to and from the food irradiation plant, raising serious questions of chronic low-level exposure to the public and to workers, transport accidents, radiation spills, and ultimate disposal of radioactive wastes. This affects all of us.

  SUPPORT PARLIAMENTARY COMMITTEE
  RECOMMENDATIONS ON FOOD IRRADIATION

  The Canadian Coalition for Nuclear Responsibility and l'Association des Opposants à l'Irradiation des Aliments today called on the federal government to stop spending taxpayers' money on the promotion of food irradiation technology and to accept the thirty-three recommendations of the House of Commons Standing Committee on Consumer and Corporate Affairs on the question of food irradiation in Canada.

  "Now is the time for the consumers of Quebec to speak out on this issue," said Gordon Edwards, President of the CCNR. "The Committee's recommendations are designed to protect the public interest, but they will not be adopted as government policy without massive public support. We are urging all those who care about this matter to make their views known to their elected representatives before it is too late."

  Following four months of public hearings, the Standing Committee on Consumer and Corporate Affairs issued its report on Food Irradiation on Thursday, May 14. The report makes it clear that there are legitimate questions about the safety and the nutritional value of food which has been exposed to atomic radiation. Believing that "the safety of the consumer must not be compromised", the Committee recommends that no further approval be given to market irradiated food in Canada until a thorough, independent assessment has been done to ensure that there are no significant adverse health effects.

  The Committee recommends that the irradiation of food continue to be regulated as a food additive. (Proponents of food irradiation have been lobbying hard to have the government of Canada reclassify food irradiation as a "process" rather than as an "additive"; this would result in less stringent testing requirements.) The Committee also recommends that the labelling of irradiated food be explicit and highly visible. (Proponents want to substitute an innocuous logo called the "radura" symbol in place of explicit labelling of irradiated foods.)
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