Introduction

Food irradiation was a hot topic in 2002. That was the year in which Health Canada made proposed regulatory changes to its list of accepted foods for irradiation ( www.hc-sc.gc.ca/food-aliment/fpi-ipa/e_rlo01.html). Health Canada's earlier list included potatoes, onions, spices, dehydrated seasonings, flour, wheat, and whole wheat flour. Its new 2002 proposed list included four other food commodities: fresh and frozen ground beef; fresh and frozen poultry; pre-packaged fresh, frozen, prepared and dried shrimp and prawns; as well as mangoes ( www.hc-sc.gc.ca/food-aliment/fpi-ipa/e_rlo01.html). This move compelled Canadian NGOs, the media and public to bring to light the controversy surrounding food irradiation. There was a concerted effort to thwart both Health Canada's and the food industry's declaration that the consumption of irradiated foo d was safe. What followed was a semi-silence from the media for almost two years. While there have been no developments made by Health Canada since 2002, a significant development has been made south-of-the-border that should inspire Canadians to reclaim their voices in issues regarding their health and take action against food irradiation. The purpose of this paper is to revisit the food irradiation controversy and emphasize the need in Canada to make public demands on Health Canada for adequate and reliable research on the impact of short- and long-term consumption of irradiated food.

History

In her paper titled Food Irradiation, Dr. Rosalie Bertell, Ph.D., GNSH, past President and Founder of the International Institute of Concern for Public Health (IICPH), recounts the global history of irradiation (Aug 1988; updated Jan 2003, www.iicph.org/docs/food_irradiation.htm). Briefly, West Germany first permitted irradiation of spices in 1957 (permission rescinded in 1958); Canada permitted potato irradiation in 1960 (permission rescinded); and the U.S. permitted irradiation of potatoes, wheat and bacon for export in 1963 (bacon permit rescinded in 1968) ( www.iicph.org/docs/food_irradiation.htm). According to Dr. Bertell, a Joint Expert Committee on Food Irradiation (JECFI) was created in the early 1970's, which included experts from the International Atomic Energy Agency (IAEA), the World Health Organization (WHO), and the Food and Agricultural Org anization (FAO). The group's mandate was to promote nuclear energy and in the 1970's it began to hold food irradiation seminars. By 1976, the JECFI concluded that the new chemical by-products added to the post-irradiated food item, called Unique Radiolytic Products (URPs), did not need to pass toxicity tests (despite the existence of standards for the testing of food additives as toxic). Due to the enormous weight given to these organizations, and especially the WHO, governments were then able to move forward with food irradiation plans - with the JECFI `stamp of approval' in hand.

Food Irradiation Process

As per the recommendations of the Joint Expert Committee on Food Irradiation, food irradiation is permitted to an average dose of 10 kilograys ( www.iicph.org/docs/food_irradiation.htm). Ten kilograys is equivalent to about 100 million times the bone marrow dose received during a hospital chest x-ray ( www.cbc.ca/consumers/market/files/food/irradiation/canada.html; and Bertell, 2004). The process of food irradiation exposes foods to ionizing radiation that kills insects, moulds and bacterium ( www.planetark.org/avantgo/dailynewsstory.cfm?newsid=19685). The three types of ionizing radiation currently permitted by the U.S. FDA include: gamma rays, high-energy electrons and X-rays. According to the FDA, food irradiation kills 99% of the pathogens.

In Canada, the Canada Food Inspection Agency is the branch responsible for food labelling. Their food irradiation regulations apply to both domestic products as well as imported ones ( www.inspection.gc.ca/english/fssa/labeti/guide/ch2ae.shtml). Wholly irradiated foods must be clearly labelled as `irradiated', `treated with irradiation' or `treated by irradiation', and have the international Radura symbol. Furthermore, foods with ingredients constituting more than 10% of the final product must be identified as `irradiated'. The same applies to bulk food items. There is, however, no requirement for food products made of several irradiated ingredients, each falling under the 10% mark individually, to be labelled `irradiated' despite the fact that their combined percentage of irradiated ingredients may equal more than 10% of the final food item.

Food Irradiation Controversy

The food irradiation controversy penetrates deeply considering that the global advocates of food irradiation and the food industry include the WHO, FAO and the IAEA ( www.iicph.org/docs/food_irradiation.htm). What has not been publicized, however, is that these «supposedly independent international organizations all accept the advice of a small NGO, the International Commission on Radiological Protection (ICRP), which dictates what is and is not permissible, despite it not being a health-based organization» (Bertell 2004). These organizations support the food industry's promotion of the food irradiation process as a viable protective barrier against deadly bacteria such as E. coli and listeria causing food-borne illness. Marketed by the industry as a food decontamination tool, food irradiation is perceived of as an answer to modern society's attempt at coping with large-scale microbiological contamination and food-borne illne sses. It is being sold to the public as a means of protecting «children, the elderly and those with weakened immune systems» ( www.planetark.org/avantgo/dailynewsstory.cfm?newsid=19685). And it is the fear of food and water contamination outbreaks, almost commonplace globally, which helps the pro-irradiation camp set the foundation for social acceptance of food irradiation.

On the other side of the food irradiation controversy are NGOs concerned with the short- and long-term effects of food irradiation on human health. Across-the-border allies in the battle against food irradiation are organizations like the Toronto-based International Institute of Concern for Public Health (IICPH) ( www.iicph.org), the Washington-based consumer group Public Citizen ( www.citizen.org/cmep), and the Cancer Prevention Coalition ( www.preventcancer.com), to mention but a few. These organizations contend that food irradiation should not be deemed safe by any government or industry without immediate in-depth research into its potential health effects on humans. In fact, according to the IICPH, «through research that has already been done, there are enough indicators to tell us that food irradiation has the potential of adversely affect[ ing] the health and well being of humans, especially fetuses and children» ( www.iicph.org/docs/FoodIrradiationToHealthCanada.htm). In Food Irradiation, Dr. Rosalie Bertell, points out the shortcomings of food irradiation: the impossibility of killing all of the pathogens; post-irradiation bacteria contamination; and the presence of carcinogenic toxins in irradiated foods ( www.iicph.org/docs/food_irradiation.htm).

In a similar vein, Public Citizen believes that there has not been adequate and reliable research done on the effects of irradiation on food and nutrient quality. This organization has been the main body of opposition to the U.S. Agriculture Department's attempt to use irradiated beef in the National School Lunch Program. Wenonah Hauter, Director of Public Citizen's Critical Mass Energy and Environment Program, stated that permitting the feeding of schoolchildren with irradiated food would mean that the USDA «is willing to put our children's health at risk to help cover up the meat industry's sanitary failures» ( www.planetark.org/avantgo/dailynewsstory.cfm?newsid=19685). In their article, The Great Vitamin Robbery, the Public Citizen documents accumulated research dating back to 1956 implicating the significant nutrient losses from the irradiation process - equalling between 2-95% destruction of the vitamin content ( www.citizen.org/documents/ACF23B.pdf).

Health Canada & Food Irradiation: Nutritional Losses

The Health Canada slide show Food Irradiation: Proposed Regulatory Changes explains that food irradiation is beneficial in that it reduces the levels of pathogens associated with food-borne disease such as E. coli and Salmonella; reduces microbiologically-caused spoilage and insect infestation; and delays the ripening of fruit and vegetables (Slide 4) ( www.hc-sc.gc.ca/food-aliment/fpi-ipa/e_rlo01.html).

Health Canada categorizes nutrient losses from food irradiation based on the nutrient's sensitivity to the process. According to their research, Thiamine (vitamin B1) and Vitamin E were most sensitive; Vitamins A, K, D, Riboflavin (B2) and B6 were intermediate sensitive; and Vitamin B12, Niacin (B3), Biotin (a B vitamin), Pantothenic Acid (B5) and Folate were least sensitive (Slide 10). The overall conclusions indicate that consuming the newly proposed list of post-irradiated commodities would not result in risks to the consumer (Slide 16), as «there are no health concerns» (Slide 17), and that irradiation does not «result in significant reduction of nutrients» (Slide 11).

The NGOs fighting food irradiation argue against Health Canada's claims. The fundamental issues are: the impact of Health Canada's `insignificant' nutritional losses on the health of children, and the poorly understood hazards of the new chemical by-products that result from the process. The latter is of particular concern for the IICPH.

Research gathered by the Public Citizen illustrates the significant losses of nutrients from irradiation. For example, irradiated hazelnuts lost 17% of its Vitamin E during irradiation, another 35% during storage and a further 49% loss during cooking ( www.citizen.org/documents/ACF23B.pdf). Both the Public Citizen article and Health Canada rate Vitamin E as sensitive to irradiation, but Health Canada did not observe any losses and therefore they do not consider Vitamin E loss as `significant' (Slide 10, 11).

In addition, the IICPH is also very concerned with the resulting loss of nutrients in irradiated food. Dr. Bertell states that the «production of hyper oxides apparently reduces the concentrations of fatty acids and fat-soluble vitamins...[which] may in turn influence absorption and utilisation of the food ( www.iicph.org/docs/food_irradiation.htm). The issue of reduced nutrient content from irradiated food is highly significant. Irradiation advocates perceive of the process as a means of protecting «children, the elderly and those with weakened immune systems» ( www.planetark.org/avantgo/dailynewsstory.cfm?newsid=19685). The implication is that irradiated food is clean from bacteria and thus considered safe for those segments of the population. Yet, by the same token, it would also be clean from nutrients - for populations that require proper nutrition the most.

Health Canada & Food Irradiation: Chemical By-Products

The process of food irradiation produces by-products called Unique Radiolytic Products (URPs). These are of unknown toxicity as there has not been substantial research conducted on them to date. In 1976, the JECFI decided that the URPs do not need to be subject to toxicity tests since irradiation was a process and not a food additive ( www.iicph.org/docs/FoodIrradiationToHealthCanada.htm). Health Canada's chemical assessment of the food irradiation process concludes that the «chemical compounds formed by irradiation are found in extremely small quantities (ppb)», and therefore the «overall weight of evidence indicated that these new compounds do no pose a risk to human health» (Slide 8). However, according to Dr. Samuel Epstein, Founder and Chairman of the Cancer Prevention Coalition, the method of irradiation (either by linear accelerators or pelletized radioactive isotopes) will result in the producti on of «highly reactive free radicals and peroxides from unsaturated fats» ( www.preventcancer.com/consumers/food/irradiation_ijhs.htm). Likewise, Dr. Bertell believes that: «our past experience with minute particles in food [such as] PCBs in ppb, as hazardous, should make [Health Canada] more cautious of food additives» (Bertell, 2004). Even more alarming, Dr. Bertell argues that irradiation can increase the production by certain fungi of some highly toxic aflotoxins, which are «extremely potent carcinogens» ( www.iicph.org/docs/food_irradiation.htm). In addition, the effect of aflotoxins continues even post-irradiation, thereby making it a truly harmful compound to be present in our food. Health Canada's admission of the existence of these compounds, coupled with Dr. Epstein's and Dr. Bertell's statements, should merit the curiosity of the Canadian public to call for Health Canada to pursue further studies in order to explain what «extremely small quantities» means and how it affects human health specifically.

Other chemical compounds, no less harmful than aflotoxins, have been discovered in irradiated food. In 1998, German government researchers made an alarming discovery: unique chemicals called Cyclobutanones were formed when food was irradiated. These compounds were shown to actually promote the development of cancer and cause genetic damage in rats ( www.citizen.org/documents/cyclobutanone.pdf). By the same token, Dr. William Au, a toxicologist at the University of Texas Medical Branch, stated: «the scientific community and regulatory agencies have very little knowledge regarding how children respond to insult from toxic chemicals. These concerns also apply to toxicological risk with respect to eating irradiated food» ( www.citizen.org/documents/schoollunchbackgrounder.pdf).

The Rejection Of Irradiation: Us And Europe

Fortunately for Canadians, the recent developments in the United States against the acceptance of food irradiation by its citizens, give us a prime example of how public outcry can potentially alter this radioactive mess from spinning out of control. In 2004, American parents, students, teachers and concerned citizens fought against the USDA's decision to permit serving irradiated food to schoolchildren ( www.citizen.org/documents/schoollunchbackgrounder.pdf). The incident started in 2001 when the Agricultural Marketing Service (AMS) issued revisions for commodity contracts for the National School Lunch Program. Under these revisions, irradiated foods would be permissible for purchase and use in the program. Quick public outcry, however, forced the AMS to rescind the revisions. This, however, was just the beginning. In 2002, the US Congress passed the Farm Bill, which included language directing the Secretary of Agricult ure not to prohibit the use of irradiated meat in the National School Lunch Program. Public outcry once again was successful after a year-long battle, but not before the United States Department of Agriculture (USDA) blatantly ignored the cries of 5,000 teachers, parents, students and concerned citizens opposing irradiated school lunch food. By 2004, continued public pressure in Los Angeles, San Francisco, D.C. and around the U.S., forced the USDA to relegate the decision to purchase irradiated food to the food service directors and the school officials in each district.

There are other prime examples of the rejection of irradiated food by the public outside of North America. In 2002, the European Parliament rejected an expansion of its list of irradiated food, and more significantly, won a clear victory (214-182 votes) allowing «the current list of spices, dried herbs and seasonings...to be the only approved food allowed to be irradiated until adequate evidence proving its safety is conducted» ( www.iicph.org/docs/FoodIrradiationToHealthCanada.htm). Based on the European decision and the U.S. incident, it is plausible to understand that our health and particularly that of our children are potentially at risk if we decide to consume irradiated food.

Unfortunately, Health Canada's decision regarding the proposed acceptance of irradiated food would not affect only the health of Canadians. In Food Irradiation, Dr. Bertell comments on the results of a study conducted in 1975 in India on the effects of food irradiation on children (Bhaskaram, C. and G. Sadasivan «Effects of feeding irradiated wheat to malnourished children» American Journal of Clinical Nutrition 28:130-135 1975, www.citizen.org/cmep). She states that the development of abnormal cells in malnourished children after consuming irradiated wheat «deserves more serious attention by supposed scientific bodies, especially when food irradiation is being proposed for use in developing countries» ( www.iicph.org/docs/FoodIrradiationToHealthCanada.htm). This is highly significant also for children whose immune systems are already compr omised, as in the case of cancer. «Blood changes seen in children consuming freshly irradiated foods are frequently seen in children with cancer. These results are most likely due to harmful radiolytic products in the food...» (Bertell, 2004).

Conclusion

Currently, there is very little evidence as to the amount of irradiated foods on the shelves in Canadian stores. While spices in specialty stores have been irradiated for some time ( www.iicph.org/docs/FoodIrradiationToHealthCanada.htm), it is unknown exactly what new products bearing the International Radura irradiation symbol are available in stores. Nevertheless, this should not reassure the Canadian consumer that there is no reason to be alarmed about food irradiation. This silence on behalf of Health Canada is the perfect time for Canadians to re-voice their opinion regarding the consumption of irradiated food, and decide whether they «stop it now or eat it later» ( www.commonground.ca/iss/0302139/25_food.shtml).

Although this paper highlights health concerns surrounding food irradiation, there are numerous other issues at hand that could harm entire populations through second-hand exposure to the process. As more demand is created for the production of irradiated meats and poultry, it becomes more economical for processing facilities to have on-site irradiation capabilities. As such, facilities using palletized isotopes increase the exposure of workers, their children and future offspring to the risk of nuclear accidents, fallout, and transportation hazards, all of which are currently virtually unregulated ( www.preventcancer.com/consumers/food/irradiation_ijhs.htm).

To conclude, ironically there already exists a de facto agreement about the hazards of food irradiation among the scientific community. No research has been conducted anywhere around the globe on the long-term effects of food irradiation. In fact, current conclusions regarding the use of food irradiation must be centred on animal-based research and only a few cases of short-term human research. This exposes the underlying belief among scientific researchers that there is enough proof of the negative health hazards of food irradiation to consider any deliberate long-term exposure to irradiated food as unethical. Unfortunately, the irradiation industry and Health Canada willingly ignore this glaring warning.

References

1. Bertell, Dr. Rosalie. Food Irradiation. International Institute of Concern for Public Health. August 1988; Revised January 2003. www.iicph.org/docs/food_irradiation.htm
2. Bertell, Dr. Rosalie. Written comments made when editing this paper. September 2004.
3. Bhaskaram, C. and G. Sadasivan. «Effects of feeding irradiated wheat to malnourished children». American Journal of Clinical Nutrition. 28:130-135 1975. www.citizen.org/cmep.
4. Epstein, Dr. S. and Hauter, Winnonah. Preventing Pathogenic Food Poisoning: Sanitation not Irradiation. International Journal of Health Services. 31 (1):187-192, 2001. www.preventcancer.com/consumers/food/irradiation_ijhs.htm
5. Food Irradiation Bomb. Common Ground. February 2003. www.commonground.ca/iss/0302139/25_food.shtml
6. Irradiated Food in School Lunches: Background. Public Citizen. www.citizen.org/documents/schoollunchbackgrounder.pdf
7. Irradiation in Canada. CBC Marketplace. Broadcast April 10^th, 2002. www.cbc.ca/consumers/market/files/food/irradiation/canada.html
8. Leyte, Darren. Food Irradiation: Proposed Regulatory Changes. Health Canada. 2002. www.hc-sc.gc.ca/food-aliment/fpi-ipa/e_rlo01.html
9. Odell, Marion. Our Children, Our Guinea Pigs: Submission to Health Canada Proposed Changes to Food Irradiation Regulations. International Institute of Concern for Public Health. February 2003. www.iicph.org/docs/FoodIrradiationToHealthCanada.htm
10. 2003 Guide to Food Labelling and Advertising. Canada Food Inspection Agency. Chapter 2. www.inspection.gc.ca/english/fssa/labeti/guide/ch2ae.shtml
11. The Great Vitamin Robbery: What Irradiation Does to the Nutrients in Your Food. Public Citizen. www.citizen.org/documents/ACF23B.pdf
12. Why is the FDA Ignoring Toxic Chemicals in Irradiated Food? Public Citizen. www.citizen.org/documents/cyclobutanone.pdf
13. US Food Industry Begins to Embrace Irradiation. Planet Ark: World Environment News. March 8, 2004. www.planetark.org/avantgo/dailynewsstory.cfm?newsid=19685