Glowing pet food? Irradiation applied to pet food

Warning: Today’s comment may have 2 different side affects: Either it turns the reader into an ”Einsteiny” rocket scientist or it turns the reader away from this blog for ever. Therefore, please read this only if you are specifically interested in the topic and don’t mind heavy and long reading. I promise, in future I will try to refrain from writing similar comments. This one is an exception as the subject matter in itself is quite complicated to begin with.

Just recently towards the end of last year Canadian Champion Pet Foods made headlines abroad as pet owners were warned about its high end Orijen brand. Consequently here in this country too warnings were issued, we ourselves included a warning on our recall alert

Recall Update and I briefly addressed the case to some degree in my comment “Pet Food Recalls: Does the pet food industry require federal watch dogs?”. Back then, the company was found to be the only link between a strange illness that paralyzed cats with the unfortunate outcome that the animals had to be euthanized. To bring everybody up to speed, here is what (in Australia only) had transpired in a summary background provided by Orijen: “On November 20, 2008, Champion Pet Foods announced a voluntary recall of its Orijen Cat food brand sold in Australia. The recall is restricted to Australia ….. was issued in response to reports from the Australian veterinary community of cats showing symptoms of a neurological syndrome after consuming Orijen cat food. To prevent the risk of cats eating Orijen dog foods and becoming ill Champion ceased the sale of Orijen dog foods in Australia. The recall was unique to Australia and did not affect any of the other 50 countries to which Orijen is exported. Champion Pet Foods believes the Australian cases resulted from the high-level irradiation (exceeding 50kGY) applied to Orijen upon entering Australia. This high-level irradiation procedure for is unique to Australia and Orijen foods are not irradiated in any other market or country. Champion Pet Foods no longer exports or sells its Orijen pet foods in Australia.”
Susan Thixton of the Truth About Pet Foods.com, back then when it all came to light, spoke with Orijen. On her website she shared the conversation she had with an Orijen representative:
“The only reports of sick cats (or any pets) have been in Australia. All pet foods shipped into Australia must be irradiated, treated with radiation, before they are sold. Orijen has no control over this, this is a mandated issue from the government of Australia. Orijen has sent two samples of the irradiated food, along with non irradiated food from the same batch to two separate University testing laboratories. It is not sure if an answer for the illnesses will be found in these tests, however it should provide a wealth of information regarding effects of irradiation of foods.” Note: Those results were subsequently posted on Orijen’s website at www.championpetfoods.com. Susan then continued: “Orijen told me they feel the irradiation is the concern. Although this is frightening for already frightened pet owners, at this point I am in agreement that the irradiation is the concern. Food is irradiated, treated with radiation, to kill bacteria and molds. In the process, much more is destroyed. Not only is the nutrition destroyed, but far more research than the FDA lets on to, tells us much more damage can occur. Irradiation breaks chemical bonds, and it is suspect that broken chemical bonds within foods containing numerous ingredients (a pet food) can alter the entire ‘food’ in many ways. “

Orijen, on 03/10/09 issued another press release to Australian consumers, which addresses various details and summarizes as follows:
“Background: On November 20, 2008, Champion Pet Foods announced a voluntary recall of its Orijen Cat food brand sold in Australia.
The recall is restricted to Australia only and is a result of the high level of gamma irradiation (61kGy) that was applied to Orijen cat foods upon entry into Australia.
As the Australian regulations provide no alternative option but to irradiate our products, we stopped all Orijen sales in Australia, and cancelled our Australian distribution in November of 2008.
No other countries or markets are affected by the Australian recall.
Judging the irradiation process to be unsafe for our foods, Champion Petfoods pledges not to distribute or sell our products anywhere that requires irradiation.
All of us here at Champion deeply regret the effect irradiated Orijen foods have had on those families whose cats were affected, and we are committed to providing support in the following areas: Compassion fund; Contribution to Australian cat community; Ongoing research into irradiation of dry cat foods”
“ongoing research into irradiation of dry cat foods
Although Champion Pet Foods has permanently withdrawn from the Australian market, we remain committed to on-going research which we hope will bring added clarity to the effect of high irradiation on dry cat foods.
Through extensive test results, experts confirm Orijen Cat foods meet and exceed all nutritional standards that are set by AAFCO, NRC, and other various research on cat foods.
Our research team – including international nutritional experts and veterinary toxicologists – has reviewed all data and test results concerning Orijen cat food in Australia, including research on existing scientific journal articles and available research data.
With the exception of the pathway of increased oxidation and reduced vitamin availability resulting from the high (61kGy) irradiation dosage applied in Australia, all known causes for the Leukoencephalomyelopathy in cats have been eliminated. As Champion Pet Foods Ltd. does not endorse testing on animals, we will not physically test this hypothesis in a laboratory, and believe there is sufficient evidence from previous published scientific studies to conclude that irradiation is the cause of disease in Australia.
What champion knew about irradiation in Australia:
The error made by Champion was in not realizing our foods would be irradiated upon entry into Australia. The health certificates issued for pet food export to Australia make no reference for irradiation upon arrival and while some reference is made to potential irradiation in background documents, this was not noticed as a concern within our company.
A “permit to import’, which does make a clear reference to the irradiation requirements, is sent only to the importer, and not to the manufacturer. It is not stated on this document that irradiation poses a potential risk to the pet food, and we cannot find any reference to the potential danger of irradiation on any subsequent document in our files of export and import requirements for Australia.
Once we discovered our foods were irradiated, we began to investigate why and whether the process was safe. We engaged the Canadian Consulate in Sydney to discuss with AQIS the reasons why our foods were irradiated and to ask whether there were possibilities to avoid the irradiation process. AQIS advised our consulate that:
“As the products your client exports to Australia have not been subjected to any heat treatment other than those applied during the extrusion and drying process we were unable to consider the processing as being equivalent to a moist heat treatment achieving a minimum core temperature of 100°C for at least 30 minutes. As a result, the only remaining option available was to gamma irradiate the products at 50 kGrays upon arrival in Australia.
When early reports began to emerge from Australia concerning cats fed Orijen, we immediately re-tested retained samples and found them to be completely normal. As more reports emerged, we began to suspect environmental factors specific to Australia, including potential contaminated water supplies, poisonous insects, other foods fed in conjunction with Orijen, and irradiation.
We contacted the company contracted to perform gamma irradiation in Australia and received assurances that the irradiation process was safe for our foods.
At this time very little research on the effect of irradiation on dry cat foods was available. We were assured by irradiation experts in Australia that the process was safe.
While Champion Pet Foods no longer exports to Australia, we believe that the tradition of irradiating dry cat foods entering Australia continues which, we assume, reflects the belief at AQIS that the process is safe.
None of the above detracts from the very strong feeling all of us have at Champion - that we should have known more about exporting to Australia prior to making the first shipment. Rather, this information is provided to explain the sequence of events.
Of the more than 50 countries to which we export Orijen products, none require irradiation as part of the import process”.

Pet food treated with radiation is something we don’t hear about every day. However, primarily because I have been asked quite often about this popular food and pet owners of course are concerned about this issue and second, because I thought, in this world of constant recalls and problems with our pet’s foods it is certainly worth our time to take a closer look at its meanings.
Well, that initially sounded easy, but turned out a little more difficult than I had initially thought. There is really not a lot to be found about the subject matter. Of course, as always I invite and welcome everybody’s input if better and most desirable, easier understandable information is available to share that with everybody here on the blog.
For starters I have chosen to quote the free and famous on-line encyclopedia since I figured there I would find an easy to understand explanation of what irradiation is all about. As you keep reading you will probably agree with me since it gets pretty complicated. So here is what Wikipedia says: “Irradiation is the process by which an item is exposed to radiation. The exposure can be intentional, sometimes to serve a specific purpose, or it can be accidental. In common usage the term refers specifically to ionizing radiation, and to a level of radiation that will serve that specific purpose, rather than radiation exposure to normal levels of background radiation or abnormal levels of radiation due to accidental exposure.” Well, so much for easy understandable, right? Within this explanation I also found a link to the Food Standards Agency, which is the British FDA so to speak. Using a FAQ approach, the agency explains on it’s site:
“Irradiation can be used to kill bacteria that cause food poisoning, such as salmonella, campylobacter and E. coli. It can also delay fruit ripening and help stop vegetables such as potatoes and onions from sprouting. …..
What is food irradiation?
Food irradiation is a processing technique that exposes food to electron beams, X-rays or gamma rays, and produces a similar effect to pasteurization, cooking or other forms of heat treatment, but with less effect on look and texture.
Irradiation can be used to kill bacteria that cause food poisoning, such as salmonella, campylobacter and E. coli. It can also delay fruit ripening and help stop vegetables such as potatoes and onions from sprouting. It is used in many parts of the world because it is an effective way of killing bacteria and with some food, such as spices that are dried in the sun, irradiation kills bacteria without changing their flavors or aromas.
How does food irradiation work?
Food absorbs energy when it is exposed to ionizing radiation. The amount of energy absorbed is called 'absorbed dose', which is measured in units of Gray (Gy). The energy absorbed by the food causes the formation of short lived molecules known as free radicals, which kill micro-organisms and also interact with other food molecules.
Free radicals are formed by almost all food processing techniques, including cooking, chopping and grinding. Radiation also kills bacteria directly by affecting their DNA.
There is only one source of ionizing radiation permitted for food irradiation in the UK: gamma rays from cobalt-60.
How safe is food irradiation?
Decades of research worldwide have shown that irradiation of food is a safe and effective way to kill bacteria in foods and extend its shelf life.
Food irradiation has been examined thoroughly by joint committees of the World Health Organization (WHO), the United Nations Food and Agriculture Organization (FAO), by the European Community Scientific Committee for Food, the United States Food and Drug Administration and by a House of Lords committee.

Does irradiated food taste different to other foods?
There is no significant difference to the smell, taste or appearance of food that has been irradiated. This is due to the fact that very small levels of energy are absorbed by the food during irradiation.

Does food irradiation change the food in any way?
All food preservation techniques cause chemical changes in food – that is how they work. The changes caused by food irradiation are similar in nature and extent to those caused by other preservation techniques, such as cooking, canning and pasteurization. There is no evidence that any of the chemical changes caused by food irradiation pose a risk to the health of consumers.

How do I know if a food has been irradiated?
It is required that all foods, or ingredients of foods listed on the label, which have been irradiated, are labeled as 'irradiated' or 'treated with ionizing radiation'. When irradiated food is not pre-packed and is sold for immediate consumption (for example, in restaurants) it must be marked or labeled on a menu, notice or ticket that the consumer can see when choosing the food.

How does the Food Standards Agency know if a food has been irradiated?
A number of tests have been perfected and validated for the detection of different irradiated foods, including herbs and spices, poultry and meat containing bone and products containing fats. These tests have been verified in trials involving laboratories throughout Europe. Regular surveys are undertaken by the Food Standards Agency. Further research is currently taking place to extend the range of irradiated foods which can be detected.

Can non-irradiated food become irradiated by contact with irradiated food?
No, irradiated food has been exposed to radiation but is not contaminated with radioactivity. Many foods, however, contain ingredients from different sources, such as curry powder. The law states that if a permitted irradiated food is mixed with a non-irradiated food, the resulting product has to be labelled as either ‘irradiated’ or ‘treated with ionizing radiation’.

What do other countries do?
… In the US a variety of foods have been approved for irradiation, for several different purposes. The current list includes wheat, potatoes, fruit and vegetables, herbs and spices, pork, poultry and beef.
Other countries irradiate food, including Canada, France, the Netherlands, Indonesia, Israel, Thailand.

Where are foods irradiated?
Foods are irradiated in authorized irradiation facilities which must be licensed, regulated and subjected to strict safety inspections by the Food Standards Agency. Irradiation facilities are of mainly two types: gamma sources and electron beams.

What are the effects of irradiation on food packaging materials?
One of the practical aspects of food irradiation is that is can be used on food already in its final package. The effect of irradiation on plastics and other packaging was investigated in the 1960s and early 1970s, in order to identify safe packaging materials for use in the space program. Only a few materials have been approved for use in packaging food that is to be irradiated and many more need to be tested if food irradiation is to become widely used.

Directly related to the case on hand, Orijen reported published details about its research as follows:
“Two independent scientific publications support Champion Petfoods position regarding the potentially harmful effects of gamma irradiation on dry cat foods in particular.
1. Research findings of a 2007 study published by the AMERICAN COLLEGE OF VETERINARY PATHOLOGISTS WWW.VETPATHOLOGY.ORG/MISC/TERMS.SHTML determined that the feeding of a gamma-irradiated diet of 35-45 kGy was associated with the development of the same conditions as are reported in cats in Australia.
2. JOURNAL OF THE AMERICAN ASSOCIATION FOR LABORATORY ANIMAL SCIENCES, vol 47, no. 6, 61-66. November 2008 entitled “EFFECTS OF GAMMA IRRADIATION AND PASTEURIZATION ON THE NUTRITIVE COMPOSITION OF COMMERCIALLY AVAILABLE ANIMAL DIETS” finds that “results raise questions regarding the suitability of gamma-irradiated diets for the long-term exclusive feeding of cats in particular, given that such feeding regimes have been associated with the development of leukoencephalomyelopathy in this species”.
Last month’s study was released in the JOURNAL OF THE AMERICAN ASSOCIATION FOR LABORATORY ANIMAL SCIENCES, entitled “EFFECTS OF GAMMA IRRADIATION AND PASTEURIZATION ON THE NUTRITIVE COMPOSITION OF COMMERCIALLY AVAILABLE ANIMAL DIETS”.
Key study findings are summarized below “Irradiation reduces the vitamin content of food, the effect of which may be indirect in that inadequate amounts of
antioxidant vitamins (such as c, e, and b-carotene) may be available to counteract the effects of free radicals generated by normal cell metabolism... Furthermore, the irradiation of diets containing fats with high levels of polyunsaturated fatty acids increases the onset of oxidative rancidity due to peroxidation of the contained unsaturated bonds.”
“the irradiation of a variety of commercial dry cat diets at 25 kGy resulted in considerable reductions in vitamin A levels, with up to 93% reduction observed in a diet with a relatively high fat content.”
“concentration of peroxide in the dry cat diet was increased to 11- and 21- fold after the typical [28.9-34.4 kGy] and high-end [38.4-48.7 kGy] irradiation treatments respectively.
“the results of this study confirm that gamma irradiation, at the doses used, (which were less than those used on ORIJEN foods) has profound effects on the vitamin A (retinol) and peroxide content of the dry cat food analyzed.”
“the fatty acid composition of the fat in the diet and especially the degree of unsaturation of these acids is particularly important.”
“…polyunsaturated fatty acids containing 3 or more double bonds are destroyed readily by irradiation.” From hammer ct, wills ed. 1979. The effect of ionizing radiation on the fatty acid composition of natural fats and on lipid peroxide formation. INT J RADIAT BIOL RELAT STUD PHYS CHEM MED 35: 323-332.
“the formation of peroxide in irradiated fat is dependent on factors such as the chemical composition of the fat, type of radiation used, total dose-rate of the radiation, dispersion of fat in the diet, nature of the medium used for dispersion, and the presence of water.”
“RESULTS RAISE QUESTIONS REGARDING THE SUITABILITY OF GAMMA-IRRADIATED DIETS FOR THE LONG-TERM EXCLUSIVE FEEDING OF CATS IN PARTICULAR, GIVEN THAT SUCH FEEDING REGIMES HAVE BEEN ASSOCIATED WITH THE DEVELOPMENT OF LEUKOENCEPHALOMYELOPATHY IN THIS SPECIES.”
“IN CONCLUSION, THIS STUDY HAS SHOWN THAT GAMMA IRRADIATION, AT THE DOSES USED, HAS PROFOUND AND SELECTIVE EFFECTS ON THE VITAMIN A AND PEROXIDE CONTENTS OF DRY ANIMAL DIETS, PARTICULARLY ON DRY DIETS FORMULATED FOR CATS.””

And finally I found this very detailed article explaining the history of food irradiation and some serious side effects: “Food Irradiation” by Rosalie Bertell, Ph.D., GNSH. Her article, after a number of updates, was revisited by Talya Rotem, B.A., M.A., C.N.P.. Here are the what I believe important passages of both articles: (Note, this is not the full version, for the original articles please refer to the links embedded above)
“Basic to the question of food irradiation is an understanding of wellness or health. 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 looking 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 color. Even a child can distinguish between a rotten apple and red juicy wholesome apple freshly picked.
Conventional human wisdom has identified freshly caught fish and game, freshly picked fruits and vegetables, and healthy domestic animal meat as the best nourishment for humans. Once the fruit is picked or the animal killed, it can no longer perform its balancing task and the forces of death and decay begin to take over. The decay process can be slowed through various means such as dehydration, cooking or heat processing, freezing or the newly proposed irradiation process. None of these has the ability to differentiate between desirable and undesirable bacteria. None has the ability to remove pesticide or herbicide residue, toxic nonliving material, or even all bacteria, yeasts or molds. Completely dead food loses its taste, color texture and attractiveness. It also loses vitamins and other nourishment.
With this in mind, the comparative benefits and disadvantages of food irradiation can be briefly sketched, including an assessment of the need for new food processing methods, the scientific studies on the wholesomeness of irradiated foods, and the political and economic climate under which the technology is being promoted.

History
Although patents for food irradiation were taken out as early as 1921 in the U.S.A and 1930 in France, the technology was not implemented. In 1957 irradiation of spices was permitted in West Germany under the assumption that spices make up only a small percentage of any food. This permission was withdrawn in 1958 and all food irradiation was banned. Canada permitted irradiation of potatoes in 1960 to prevent sprouting, i.e. that is to make the potato sterile, and in 1963 the U.S.A. granted permits for irradiation of wheat, potatoes and bacon for export. The U.S. food and Drug Administration withdrew the permit for bacon in 1968.
The impetus for food irradiation has not come from farmers, the developing world, retail grocers or consumers. In the early 1970's the international Atomic Energy Agency (IAEA), whose mandate is to promote nuclear technology, began to hold seminars on food irradiation and established a joint committee of experts from IAEA, the World Health Organization (WHO) and the Food and Agricultural Organization (FAO). This group, the Joint Expert Committee on Food Irradiation (J.E.C.F.I) decided in 1976 that the new chemicals called radiolytic products, which are produced in irradiated food, do not need to pass tests of toxicity as do other food additives. It declared irradiation to be a process not an additive, although free radicals (highly reactive molecules) and new chemicals are produced in the food. Some of these radiolytic products are the same as those produced in cooking or thermal processes, for example hydrogen peroxide and formaldehyde, but they occur in larger proportions in irradiated food. Other by-products are unique to the irradiation process.
The question of classification of food irradiation as a process or and additive is not trivial. Food additives must be tested for toxicity. Food processes do not require such testing. In this case, there is a need for new legislation to cover "additives attributable to processing", requiring toxicological testing of the new chemicals produced by irradiation.
…
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 illnesses. 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).

Potential problems with irradiation
Botulism
In thermal food processing there is a rather homogeneous reduction of all bacteria, both the relatively harmless and those that are pathogenic or toxin producing. In irradiation, bacteria are killed in a proportion relative to their sensitivity and resistance to radiation. Some of the bacteria, which produce the natural indicators of unwholesomeness in food, i.e. staleness, disagreeable smell or unpleasant taste, would be killed off while some of the most pathogenic bacteria would be left alive. For example, Clostridium Botulinum resists irradiation below the 10-kilogray upper-limit for food processing. The toxin produced by Clostridium Botulinum can cause botulism. It flourishes in anaerobic (oxygen free) conditions. This deadly pathogen would not be destroyed by irradiation and in fact could even thrive. Irradiated food requires some protection against re-contamination but the anaerobic growth-enhancing environment for Clostridium Botulinum rules out the use of vacuum-sealed cans for this purpose. The "old fashioned" canning of food done in the proper manner effectively eliminates botulism food poisoning.

Salmonella Poisoning
Irradiation can kill some bacteria, those most sensitive to it, but it never removes toxins already deposited in the food. For this reason, the cleanliness and health of food chosen for preservation can never be neglected. Moreover, food irradiation should not be allowed to replace sanitary handling of food.
The nuclear industry is promoting food irradiation primarily as a preventative action against Salmonella in poultry. From 1983 to1985, there were 28 deaths in Canada attributed to Salmonella poisoning. Present statistics are unknown at this time. The report of the standing committee on food irradiation from 1983 to 1985 notes that:
"Relatively rough extrapolations have indicated that Salmonella may have contributed to approximately 750 deaths in Canada in 1985, but actual statistics attributed only 28 deaths to Salmonella from 1983 to 1985. Which figures may be more accurate is unknown at this time, but Salmonella contamination is a major source of food poisoning and a significant public health concern in Canada and elsewhere."
Salmonella contamination is due to improper handling techniques by processors, handlers, consumers and restaurants. Mechanical cleaning of chickens (which bursts the gut) is the single greatest cause of the problem. According to an article by economist R. Krystynak, irradiation of poultry ranks sixth out of eleven methods of food processing investigated to control Salmonella poisoning on a cost/benefit analysis basis. ("Current Concerns, Food Irradiation An Economic Perspective", Food Market Commentary, Ottawa, Agriculture Canada September 1986)

Aflotoxins
The Joint Expert Committee on Food Irradiation (J.E.C.F.I) declared (with a disclaimer) that there would be no toxicological problems with irradiated food not exceeding an average dose of 10 kilograys. It gave no specified minimum to ensure the killing of radiation sensitive bacteria; nor did it specify a maximum, which would avoid the production of radiolytic by-products or stimulation of the production of known harmful pathogens. It is well known that irradiation can increase the production of some extremely toxic aflotoxins by certain fungi, especially nuts and grains. These aflotoxins are known to be extremely potent carcinogens and their ability to continue production following irradiation has not been addressed by the Joint Committee. Proposing and average exposure only leaves this technology open to widespread misuse.
Pesticides and other Chemical Hazards in Food
Irradiation fails to eliminate pesticide residues and other chemical hazards in food. It has been proposed as an alternative to pesticides and preservatives. However pre-harvest pesticides will still be used, and their chemical interaction with irradiation is unknown. Irradiated food will still require cooking, freezing, preservatives and other means to avoid re-contamination.

Loss of Nutrients
Some key vitamins, especially E, C and Thiamine are lost through irradiation. The production of hyper oxides apparently reduces the concentrations of fatty acids and fat-soluble vitamins. This may in turn influence absorption and utilization of the food.

Assessment of US food irradiation research
There have been about 2000 research papers on food irradiation published internationally. The U.S. Food and Drug Administration selected about 400 for serious review. They chose 6 "considered by agency reviewers to be properly conducted, fully adequate by 1980 toxicological standards, and able to stand alone in support of safety" (U.S. Federal Register). Two studies were in English, three in French and one in German. Upon investigation, in one of the English language papers, published in 1964, the authors state, (about their own research): "consequently in many cases statistical comparisons were not possible. However, examination of data intuitively suggests that the differences have no real significance." There were differences between the control rats and rats fed irradiated wheat, with a statistically significant increase in stillbirth rate among those fed irradiated wheat. Other findings failed to reach significance because of the small number of animals. This hardly constitutes strong proof of the safety of food irradiation.
The second English language paper reported unexplained deaths and abnormalities in animals given irradiated food, not reaching statistical significance because of the small number of animals in the study. One of the studies indicated negative effects on older animals, but the finding was not pursued. The food used in the English language studies had been irradiated at 20 kilorad (equivalent to 0.2 kilogray), fifty times below the proposed level of irradiation of human food, i.e. below the 10-kilogray average.
In two of the three French studies, the dose to food was less than 50 kilorad (0.5 kilogray). No adverse effects were reported. In the German study, animals fed irradiated food weighed significantly less than controls and had reproductive abnormalities. Both of these effects were mitigated with administration of vitamins.
Certainly no scientist would accept these studies with low dose irradiation of food well below the proposed level, small number of animals, short follow-up time and negative results, as firmly establishing the safety of irradiated food.

Ionizing radiation breaks chemical bonds
Both the U.S. F.D.A. and the Science Council of Canada attempt to minimize the effects of food irradiation by quoting a report from Ames, Iowa, July 1986, (Report No. 9, Council for Agricultural Science and Technology) saying that each kilogray of ionizing radiation breaks only 6 chemical bonds out of 10 million in food. This makes the magnitude, the nature and the biological impact of the breaks seem small. However, in 100 milliliters (or 0.1 liter) of water there are 5-gram moles, that is 1025 molecules. At the low-dose of one kilogray, 6 times 1018 chemical bonds are broken creating the hydroxyl radical, one of the most reactive entities known in biochemistry. Water makes up some 80% of most foods. Food irradiation will be permitted to an average dose of 10 kilograys. There is no maximum permissible dose mentioned in the regulations.

Labeling requirements for irradiated food offer no assurance to the consumer that food has not been irradiated because there is no test to detect irradiation.
The flower like radura symbol is misleading and should be accompanied with the word "Irradiated". The wording should appear on all foods that have irradiated ingredients. The proposed labeling exemption for irradiated ingredients that comprise less than 10% is not acceptable. A food could contain six ingredients, each one less than 10% of the whole, which together comprise 45% of the product. All irradiated ingredients at any percentage in the food product should be listed.

Conclusions
The IICPH sees little Canadian benefit in food irradiation other than economic gain for Canada's nuclear industry. In the U.S., it can be shown to benefit the nuclear weapons industry since it will require commercial reprocessing of nuclear fuel rods to separate out the cesium 137 requirements. For the farmer, the consumer and the developing world, it means higher priced food, less nourishment in the food and probable harmful side effects in terms of pregnancy outcomes, cancers and chronic diseases. The IICPH recommends complete cost/benefit analysis of food irradiation and much more well- designed scientific testing of its impact on health. Both should be independent of the industries that tend to profit from the technology, for without this assurance, food irradiation becomes a massive experimental program on humans.
The Canadian and American public are justifiably concerned over the unknown effects of the irradiation of food. Consumer resistance will and should continue until these effects are known and quantified. Toxicological testing should be mandatory.
Skepticism by Canadian consumers in regard to food Irradiation can only be increased by the failure of the Government of Canada to follow the recommendations of the Standing Committee on Food Irradiation.
Export of food irradiation equipment to developing countries at this time is premature and exploitative.
Not covered in this brief report are questions of worker exposure, accident potential and waste disposal from this experimental technology.”

Ms. Bertell briefly addressed labeling issues and the flower like radura symbol shown at the beginning of this comment. According to Wkipedia, “The Radura is the international symbol indicating a food product has been irradiated. The Radura is usually green and resembles a plant in circle. The top half of the circle is dashed. Graphical details and colours vary between countries.” Susan Thixton on her site a little while ago asked her readers “Do you know what this symbol means?” The results were not all that surprising, Radura is a little misleading indeed. In their responses her readers described their initial thinking of this logo as standing for “friendly, safe, non-threatening, organic type, flower like, definitely something good, healthy, earth friendly”. This shows that basically very few people have an idea about not just what the symbol stands for, but also that it describes something way more complicated and possibly not being so friendly and non-threatening if not properly applied. And to answer the question posed in today's head line: No, the food isn't glowing. I did however, due to improper application cause serious harm. This in itself justifies this long and complicated comment.

Acknowledgements

Source links embedded in the comment. The following is the acknowledgement posted by IICPH along with the articles quoted.
The IICPH is grateful for research assistance on this issue from Food and Water Inc., Probe International, the Food Chain, the National Institute of Nutrition of India, testimony from the U.S. Congressional Hearing on Food Irradiation and the New Jersey State Assembly public hearing on food irradiation.
In particular, we are grateful for the research of Donald B. Lauria, M.D., Professor and Chairperson of the Department of Preventive Medicine and Community Health, New Jersey Medical School; George Tritsch, Ph.D., Cancer Research Scientist, Roswell Park Memorial Institute, Buffalo, New York; and Richard Piccioni, Ph.D, Senior Staff Biophysicist with Accord Research and Educational Associates, New York City.
International Institute of Concern for Public Health is a Canadian-based nonprofit organization dedicated to helping communities assess and improve their environmental health status. The IICPH alerts and informs the public of the health hazards of pesticides, nuclear industries and other commercial, military, and industrial products. As well -- independent of government and industry -- the Institute provides the evidence and documentation needed by survivors of environmental disasters. This unique and essential service both supports and furthers the key principle on which the IICPH operates: that a safe environment is a fundamental human right. IICPH works in cooperation with Native Peoples, professionals, grassroots organizations, and citizens groups in Canada, the United States, Russia, the Central Pacific, India, South America, Europe, South Africa, and many other countries.