INTRODUCTION

In the International Institute of Concern for Public Health (IICPH), we believe that a healthy environment is a human right. Food is one of the most basic elements necessary for human health. Our Past President and Founder, Dr. Rosalie Bertell, Ph.D. GNSH, a recognized expert on the effects of low-level radiation, has stated, «Basic to the question of food irradiation is an understanding of wellness. Food is not just another form of pills or an inert pile of chemicals. One doesn't choose to have sickly chicken or to eat moldy eggplant for the evening dinner. A healthy plant or animal is able to balance harmful and healthful bacteria so that it maintains its normal size, shape, texture and colour. Even a child can distinguish between a rotten apple and a red juicy wholesome apple freshly picked.» - Food Irradiation - Dr. Rosalie Bertell www.iicph.org

The Canadian public has a right to expect that our federal and provincial governments will take whatever measures are necessary to ensure the safety of our food. New food processing methods that would retain the integrity of our food may be necessary but, in our opinion, food irradiation is not one of them. There is too much to question about the sources of some research and the adequacy of others.

In cases where there is faulty or inadequate research, unsuspected consequences can occur when a new drug, chemical or process is introduced. A case in point is the drug Thalidomide. The possible cytotoxic effects could have been uncovered through research methods (See Toxic Effects of Irradiated Foods» - G. Lofran NATURE 211-302 1966.)

Dr. Bertell stresses that it is impossible to kill all the bacteria in food by irradiation without causing damage to the cellular structure to such an extent that texture and flavour are reduced to a virtually unpalatable state and results in the loss of vitamins and enzymes. However, the hardier bacteria such as the one that causes botulism will not be totally killed, nor will irradiation prevent food-borne bacteria from contaminating the food after radiation. However, the good bacteria will be killed giving greater scope to the pathogens. The toxins that were already formed in the foodstuffs will still be there as well as any contamination such as by feces or insects. Not only that, the usual smells that identify meat and fish as contaminated will likely not be present.

No matter which method of food irradiation is used, it fails to remove toxic chemicals from the food, creates radiolyticc products (UPRs) of unknown toxicity.. It also damages the cellular structure and ruptures long proteins like vitamins and enzymes.

In our view, through research that has already been done, there are enough indicators to tell us that food irradiation has the potential to adversely affect the health and well being of humans especially fetuses and children.

We further believe that food irradiation does not replace proper food production, processing, handling or preparation.

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WHO TO BELIEVE

I. The Food and Drug Administration of the United States (FDA)

According to the Organic Consumers Association (OCA), the FDA based its approval of irradiation for fruits and vegetables on a theoretical calculation of the amount of UPR's in the diet from one 7,5 0z. serving per day of irradiated food. The OCA believes that, considering the different kinds of foods approved for irradiation (in the U.S.), this quantity is too small and the calculation irrelevant. It is also their opinion that the science of today is not adequate to prove the long-term safety of food irradiation, www.purefood.org/irradlink.html

II. The International Atomic Energy Agency (IAEA)

The mandate of this organization is to promote nuclear technology.

Dr. Bertell states in her Food Irradiation article that, in the early 1970's, this organization began to hold seminars on food irradiation and established a joint committee of experts from the IAEA the World Health Organization (WHO), and the Food and Agricultural Organization (FAO). This group, the Joint Expert Committee on Food Irradiation (JECFI) decided in 1976 that the new chemicals called unique radiolytic products (URP's), which are produced in irradiated food, do not need to pass tests of toxicity, as do other food additives. It declared food irradiation to be a process not an additive, although free radicals (highly reactive molecules) and new chemicals are produced in the irradiated food. Dr, Bertell states, «The question of classification of food irradiation as a process or additive is not trivial. Food additives must be tested for toxicity. Food processes do not require such testing.» If this is true also in Canada, then there is a need for new legislation to cover additives attributable to processing.

III. The World Health Organization (WHO)

«When the WHO speaks, the World listens»

There are serious questions about the credibility of the World Health Organization's endorsement of the safety of food irradiation.

See BAD TASTE The Disturbing Truth About The World Health Organization's Endorsement of Food Irradiation, a joint project of the Public Citizen and the Global Resource Action Centre for the Environment It is found at www.citizen.org/cmep

.In this 44-page document, a very distressing picture is painted of the relationship and consequent decisions of the WHO, the IAEA and the FAO. In 1999, the WHO declared that any food could be treated with ionizing radiation and be safe for human consumption. This announcement is quoted as saying, that irradiating food does not result in toxicological hazards. The litany of inadequate or never undertaken scientific tests is chilling reading. For quick reference there are two tables. On page 17 the table is entitled «A Dubious Record: How the Original Food Irradiation Research Agenda Has Largely been Ignored.» Page 31 is called this «Scientific Shell Game: How Research Questioning the Safety of Irradiated Foods Fell by the Wayside.» We certainly believe this document presents the case for an investigation of the activities of the three bodies in question, the WHO, IAEA and FAO by the United Nations. Who do you trust if you can't trust the WHO?

OTHER STUDIES

The Public Citizen in an article entitled «The Health Problems of Irradiated Foods» states: «In the course of legalizing the irradiation of beef, chicken, pork, fruit, vegetables, eggs, juices, spices, and sprouting seeds - a process that has spanned nearly 20 years - the U.S. Food and Drug Administration has dismissed and ignored a substantial and growing body of evidence suggesting that irradiated foods may not be safe for human consumption.»

There follows samples of research many funded by government agencies and performed at universities. All of these appear to have been published. The first one is striking because it was carried out on children.

« Fifteen children suffering from severe protein-calorie malnutrition...receiving freshly irradiated wheat developed polyploid cells and certain abnormal cells in increasing numbers as the duration of the feeding increased... Though the biological significance of polyploidy is not clear, its association with malignancy makes it imperative that the wholesomeness of irradiated wheat for human consumption be carefully assessed.

-Bhaskaram. C. and G.Sadasivan «Effects of feeding irradiated wheat to malnourished children.» American Journal of Clinical Nutrition28:130-135 1975. This article can be found at www.citizen.org/cmep

Dr. Bertell has commented on a similar case in «Food Irradiation»

page 5. Under the heading «The Controversial Report from India, this study undertaken by the National Institute of Nutrition (NIN) fed irradiated wheat to children. When these children developed polyploidy, the researchers changed to research on animals, which also developed abnormal blood cells. A «committee» of two scientists who had been appointed to resolve a dispute when the Bhabba Atomic Research Centre refused to accept the NIN findings rejected this study. They decided that the animal studies were «outside their frame of reference.»

Dr. Bertell says of this turn of events, «obviously data on negative health effects of irradiated wheat on malnourished children deserves more serious attention by supposed scientific bodies, especially when food irradiation is being proposed for use in developing countries».

VICTORY IN EUROPE

On December 30,2002, the European Parliament rejected expanding the list of irradiated foods. The winning amendment was passed in a 214-182 vote and states that the current list of spices, dried herbs and seasonings should continue to be the only approved food allowed to be irradiated until adequate evidence proving its safety is conducted. It was accomplished even in the face of strong opposition from the irradiation industry. There had been an amendment proposed that called on the European Commission to yield to the WHO in commissioning and disseminating information and research on the safety of irradiated foods.

This surely is an indication that the European Parliament does not place any faith in the endorsement of food irradiation by the WHO. This vote should be a wake-up call to our own parliamentarians. In 1957, the WHO signed an Agreement with the IAEA to allow the IAEA to take the lead on questions related to the health effects of ionizing radiation. We therefore think it is reasonable to assume that WHO's « approval» was derived by a small committee deputized by the WHO and not allowed to question health matters

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OUR CHILDREN, OUR GUINEA PIGS

The Scientists Speak:

Almost every human community whether in the economically developed or developing world is attempting to cope with toxic waste dumps, polluting industries, global nuclear fallout, high tension wires, electromagnetic fields from broadcasting studios or radar installations, changed climate, automobile and truck exhausts, pesticides, herbicides and defoliants.

- Dr. Bertell

Man-made chemicals first came into being with the Industrial Revolution, increased after World War I but have proliferated at an alarming rate since World War II. In Fallon Nevada, a small desert town became alarmed when they had 16 cases of childhood leukemia in only five years. One of Nevada's top health officials, Dr. Mary Guinan, got in touch with the Centre of Disease Control and Prevention (CDCP) to investigate the potential links between these leukemia cases and the environment. Dr. Richard Jackson, director of the National Centre for Environmental Health at the CDCP was sent to investigate.

Research on cancer clusters originally focused on gathering environmental samples because the investigators didn't have tools sensitive enough to measure which toxins had actually been absorbed into people. However, Dr. Jackson explained how their laboratories are using sophisticated blood and urine analyses to test for minute traces of toxins in the bodies of the sick children and their families in Fallon. This type of effort is part of a larger movement in the U.S.

Dr. Philip Landrigan of Mount Sinai School of Medicine in New York City is working with scientists around the country to understand how children are affected by exposure to chemicals. He states:

Of the three thousand high production volume chemicals in use in this country today, only 43% have been minimally tested. Only about ten per cent have been thoroughly tested to examine their potential effects on children's health and development.

Many authorities including Landrigan will tell you that children are potentially more vulnerable to chemicals and forms of radiation than adults. They are more heavily exposed. They eat more food, drink more water, breathe more air pound for pound. Their body systems are more vulnerable depending on the stage of their development. Children are more in touch with the earth and therefore also get more chemicals into their body through the hand-to-mouth route.

Dr. Landrigan spoke at the Children's Environmental Health II Conference in September 2001 held in Washington DC. The theme was «A Global Forum for Action.» He spoke about what is known about the environmental effects on the health of children.

He said that there was a study done in 1998 by the U.S. National Academy, which discovered that probably at least one third of neurobehavioural problems are caused by environmental factors:

«Over the last one hundred years, medical researchers have identified a whole series of chemicals and physical elements causing illness in adults and children. These include radiation, asbestos, benzene, certain artificial dyes, a whole series of industrial chemicals, ethylene oxide, 1,3 butadiene, formaldehyde.

Sometimes we hear the phrase, everything causes cancer so there is nothing we can do about it. We can do something about it! That is just absolutely false. It will be years before we do, but we know many of the specific causes of cancer.

People that are interested in reducing children's exposure to chemicals need to understand full well that there are powerful forces who are very much interested in continuing the production and use of those chemicals.»

Dr. Landrigan said further that he gets very angry when he sees people refusing to take prudent steps to protect the health of children, when scientists know or strongly suspect certain chemicals «The industries that make pesticides or other toxic chemicals, they have teams of people whose job it is to visit the administrator of the EPA,» (U.S. Environmental Protection Agency) and the various regulatory agencies all the time and I expect this is true as well in Canada. They have teams of people whose job it is to go to the agencies and political officers to persuade them that the chemicals aren't so bad - that in the whole scheme of things we have to quote, «Be rational, we need to balance the needs of the chemical production against considerations of human health. Human health is good but has to be weighed against economic issues.»

«We cannot fix lead-poisoned brains...the only thing we can do is to prevent harm in the first place by developing policies to reduce the risk of these things happening» Dr. Devra Lee Davis, Ph.D. epidemiologist at Carnegie Mellon University

«I wish for a world in which the babies of all mammals particularly the babies of our human mammals can be born without a toxic load already in their brains, their flesh, in their body, and that the first food that they drink, mammalian milk, is free of toxic chemicals.» Dr. Sandra Steingraber, Ph.D. biologist and author Cornell University, New York Dr. Steingraber calls the load of toxic chemicals in mothers' milk, «Toxic Trespass.»

Dr. Irena Buka, a pediatric environmental Health specialist from Edmonton Alberta stated «there is no doubt that over the past fifty years since we have had immunization, medicines and better socioeconomic conditions that there has been significant improvement in these broad general population health figures. Over a shorter time period, there has been a major increase in asthma in children, significant increase in neurodevelopmental disorders, increasing congenital abnormalities and an increase in certain childhood cancers. There is a growing body of circumstantial evidence that environmental factors, pollutants, chemical toxicants are linked to these illnesses. There is no doubt that children living in poverty are significantly more affected by environmental health concerns. These children are more likely to be exposed to cigarette smoke, dump and waste sites as playgrounds, and often live downwind and downwater in the poorer parts of town.»

Dr. Bertell believes that « Environmental Health is becoming a new discipline in its own right, different from Occupational Health. I believe that Environmental Health efforts will more and more come to rely on biomarkers of exposure rather than gross biological end points; such a severe tissue damage or cancer deaths. The child with its sensitivity and rapid growth rate will become the most important indicator of community health, and will become the focus of major preventive health action. «

TURNING OUR CHILDREN INTO GUINEA PIGS

We, and more particularly Our Children, are being turned into guinea pigs by inadequate or faulty research, whether intentional or unintentional.

The research done on the effects of many man-made chemicals on health and the environment have proven in the past to be inadequate - leading to the introduction of a long list of toxic hazards to our health. When chlorine was first introduced to purify drinking water, it was considered a great boon. However, chlorine combines with decaying organic matter to produce organochlorine compounds most of which are highly toxic. In Dr. Bertell's book, Planet Earth: The Latest Weapon of War*, she describes how these organochlorines combine with organic matter in the water to create pseudo-estrogens, which mimic the normal female hormone, estrogen. This is harmful to all mammals including humans. «This results in birth defects in offspring, reproductive abnormalities, poor survival, and feminization of males. Pseudo-estrogen is implicated in human breast and prostate cancer, the dramatic increase in endometriosis, and neurological and developmental problems in children.» *pp. 162 - 164 Planet Earth: The Latest Weapon of War ISBNISBN 1-55164-182-8 Black Rose Books

Chlorine and its compounds are also used in a number of industrial pursuits and products. Dr. Bertell states that, «It is an essential ingredient in about half of the 48 commonly used chemicals that are the most damaging to our planet.»

Whether intentional or unintentional, the consequences of inadequate or faulty research to those whose life or health has been compromised are the same.

Although we think that the people who originally approved chlorine use for water purification probably had no idea of the consequences or how widespread would be the damage caused, the lessons should be learned and appropriate research done before bringing in any new chemical into the environment. This is particularly true for substances that would remain in the environment for long periods of time such as the radiolytic products (URPs) of food irradiation.

Pesticides are another example of an area where serious harm to health has been caused by their use. DDT has been banned for many years in Canada but still sold and used in other countries mainly in the developing world. It has accumulated in surprising places such as our own Arctic where Inuit women are faced with the prospect of providing their infants with their daily dose of DDT through breast milk or alternatively, using expensive infant formula.

When it comes to ionizing smoke detectors, it is a little hard to fathom why those who developed and manufactured these items would not have realized the danger from the Americium 241 or Radium 226 particularly for home use. Is it really possible that no one thought about what might happen if the radioactive material in this device was damaged by fire or destroyed in a land-fill site? Considering that Americium 241 has a half- life of 458 years and Radium a half-life of 1600 years, did no one wonder what would happen when they were discarded?

SOLUTIONS AND REMEDIES

ALTERNATIVE FARMING METHODS

Before the introduction of grain fed beef cattle, the acid in the stomach of humans destroyed E coli. The newer strains of E coli are acid resistant. The September 11 issue of «Science» states, «Grain-based cattle diets promote the growth of E coli that can survive the acidity of the human and cause intestinal illness. By feeding hay to cattle for about five days before slaughter the number of acid-resistant E coli can be dramatically reduced.» James B. Russell a USDA microbiologist and faculty member of Cornell University Microbiology Section, said, «When we switched cattle from a grain-based diet to hay for only five days, acid-resistant E coli could no longer be detected..» www.news.cornell.edu/releases/Sept98/acidrelief.hrs.htm

SANITATION Vs. IRRADIATION

Some of the farming practices that have occurred through big business are a serious cause for concern, In an article published in the International Journal of Health Sciences Volume 31, Number 1, pages 187 - 192, 2001, Dr. Samuel S. Epstein and Wenonah Hauter state, «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. (Preventing Pathogenic Food Poisoning:Sanitation Not Irradiation3), Dr. Samuel S. Epstein and Winonah Hauter)

Alternative treatments to preserve food can and in some instances are in the process of development. These treatments can be ones that kill all the bacteria but do not add toxic chemicals or reduce the food value http://www.organicconsumers.org/irrad/alternatives.cfm

CONCLUSION

We believe that Health Canada should recognize that there is enough evidence to believe that food irradiation is a health hazard. Science has not proved that a diet of irradiated foods is safe for humans. On the contrary, there is evidence that points to many health problems from food irradiation. If you are not convinced by the evidence presented by the independent studies, then you ought to come to the conclusion that food irradiation has not been researched thoroughly enough to be able to prove that it is safe for human consumption. Rather than asking Parliament to approve new foods for irradiation, efforts should be undertaken to introduce regulations to ban food irradiation and the importation of irradiated foods. The present body of research at the very least indicates that there are serious consequences to human health particularly to the most vulnerable, our children and future generations. It is easier to approve something than it is to stop its usage once there are a large number of vested interests involved. Even if enlightened countries ban these products, they will often continue to be sold in other countries. This is particularly harmful to the poor in developing nations where they are already living in a polluted environment. In many of these countries, the diet of many is limited to a small number of foods, which makes the use of irradiation in these countries problematic. Once food irradiation has become commonplace and widespread, it might be well nigh impossible to eliminate it from the marketplace It therefore behooves us in the wealthy industrial western nations to take every precaution to make sure that the process is safe.

I realize this step would place the government in an embarrassing position - because of the agreement through the Canadian International Development Agency (CIDA) to build a food irradiator in Thailand. As part of the deal, apparently, Canada has agreed to import irradiated mangoes, papayas and shrimp from Thailand. I imagine this may have prompted their interest in obtaining changes to the regulations. Better to suffer some awkwardness than to harm the health of Canadians and the Thai people. Here is a case where finding alternative preserving methods would pay off for everyone.

When Food irradiation is denied, resourceful people will discover methods of food preservation that are not harmful to health, farming methods will be modified with a concomitant improvement to our soil, air and water.

There are valid reasons why Health Canada should not be asking Parliament to change the regulations to allow the irradiation of any more foodstuffs. We are puzzled that Health Canada has already allowed the use of food irradiation on spices let alone be even contemplating adding ground meat, poultry, shrimp, prawns and mangoes to the list when there is good hard evidence of the potential dangers from many credible sources. The dangers of food irradiation are well-documented through the work of a long list of scientists independent of government or the nuclear industry. Dr, Samuel Epstein of the University of Illinois is presently fighting against the feeding of irradiated ground beef to school children in the U.S.A.

Since the Canadian public by and large does not want food irradiation and its safety has not been proven, indeed, there are valid reasons to believe that there are health hazards, why then add to the toxic burden carried, not only by our children but by many living things?

Submitted by Marion Odell,
Vice-President,
For the IICPH Board of Directors