Natural irradiation?

Towards the end of last year there were reports about some problems Champion Pet Foods with its Orijen brand was having in Australia. I reported in great detail on this in various comments on this blog (Pet Food Recalls: Does the pet food industry require federal watch dogs? and Glowing pet food? Irradiation applied to pet food); we also mentioned the issue with a warning in our RECALL ALERT (though there was NO recall here in the States).

Since then not a day goes by without an inquiry from concerned pet owners about the issue of food irradiation.

In case you don’t recall, back then, the Orijen 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. “

As a subsequent measure the Australian government went to work about the problem. Most recently on 06/01/09, Veterinary Practice News reported under “Australia Bans Pet Food Irradiation”:
“Australia has banned the government-mandated practice of irradiating imported pet food, the Sydney Morning Herald reported. The ban comes after a number of cats died or became ill after eating irradiated cat food manufactured by the Canadian company, Champion Petfoods Ltd.
The Australian Minister for Agriculture, Fisheries and Forestry, Tony Burke, has ordered the sterilization process to cease immediately after receiving international reports that some cats can suffer neurological damage from eating irradiated dry food, according to the Herald. Details on the reports were not immediately available. …"

Sorry, that the introduction to today’s comment became a little lengthy, however it was necessary to understand my thought process. I recently found an article in Pet Food Industry.com, a print and on-line publication for pet food professionals. Written by David A.Dzanis, DVM, PhD, DACVN, the title is “Is irradiation of petfoods natural? AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.” Her is what he had to say:

‘”In 2001, the US Food and Drug Administration (FDA) approved a petition broadening the use of irradiation of animal feeds to include petfoods, treats and chews. That same year, the Association of American Feed Control Officials (AAFCO) accepted the feed term "natural" and established guidelines concerning its use on petfood labels. Because these two independent matters were in development during the same period, the AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.”

Then, many of you will like his explanation of irradiation much better than my original, boring and lengthy rocket scientist approach (Glowing pet food? Irradiation applied to pet food). Mr. Dzanis explains: “What is irradiation?
Under FDA regulations, ionizing radiation can be from either of two origins:
X-rays generated from machine sources; or
Gamma rays emitted during radioactive decay of radionuclides.
The former are the result of energy shifts in orbiting electrons of molecules, while the latter come from energy shifts within the nuclei of atoms. Other than their origins, though, the two types of radiation are virtually indistinguishable from each other, as the range of wavelengths used to define one versus the other largely overlap.
In neither case does the food incorporate or come in direct contact with radioactive material, nor is there a chemically synthetic step to the process.
The approved purpose of irradiation of pet foods is for microbial disinfection, control or elimination. While not intended as a replacement for other appropriate sanitation measures, it gives the manufacturer another weapon in the arsenal against potential microbial contamination. Irradiation may be more suitable for some types of pet products compared to others, but considering the heightened concern regarding pet food safety today, all manufacturers should consider it a potential means to address safety issues.”

And here comes what really matters to me today: “Natural or not?
There are many different ways to interpret "natural," which led to wide misuse of the term on pet food labels in the past. To help provide consistency in meaning and a basis to uniformly interpret use of the term, AAFCO defined it to differentiate products and ingredients in terms of their sources and processing methods. For example, natural products or ingredients must be of animal, plant or mined sources but can be ground, cooked, dried, rendered, purified, extracted, hydrolyzed or even fermented.

The key factor in determining the applicability of the term is that anything that is manufactured by means of chemical synthesis or contains a chemically synthetic substance is not natural (at least not without further qualification, such as with a pet food containing synthetic vitamins but otherwise meeting the definition).

Of course, not all people would necessarily agree with this definition. For example, many consumers would not consider chicken meal, wheat middlings, sugar or salt to be natural, but those ingredients are natural under AAFCO. On the other hand, because the bulk of commercial ascorbic acid (vitamin C) used in pet foods is chemically synthesized, this source would not be natural, despite the fact that vitamin C occurs in nature as well.

Aside from these perceived discrepancies, the AAFCO definition as it exists today is the only basis by which the matter of irradiation can be rationally discussed.

Why is FDA concerned?
In its letter to AAFCO, FDA rightly notes that irradiation is not the same as heat processing, rendering or other processes allowed under the natural definition. It ponders whether purification could apply to irradiation, but frankly, I do not believe that was the intent when the definition was drafted.

Rather, the process most likely was not mentioned because irradiation was not approved for use in pet foods while the definition was being developed. Unfortunately, the list of processes is not preceded by "such as" or similar phraseology that would allow for tacit extension of the list when appropriate. Thus, FDA concludes that irradiation effectively nullifies characterization of a product with the term "natural" as currently defined.

While irradiation may not be expressly named among the allowed processes for natural products or ingredients, the intent of irradiation is the same as some of the processes that are allowed, which ultimately is to help ensure microbial safety of the finished product. Essentially, heat is another form of radiation (infrared).

Also, ionizing radiation cannot be characterized as, nor does it result in, chemical synthesis, the key part of the natural definition. In my opinion, then, irradiation should be included among the processes allowed.

Let consumers decide?
Under current FDA regulations, the labels of irradiated pet foods must bear a Radura symbol, accompanied by the words "treated by irradiation" or "treated with radiation." FDA notes in its letter that few consumers may think of irradiation as natural. That may be true, but the same could be said of other processes or ingredients currently allowed under the natural definition.

Regardless, as long as the label discloses that the product has been irradiated as required under the regulations, it should be up to consumers to decide whether use of the term natural to describe that same product is inconsistent. They can then make their purchasing decisions accordingly.
I would encourage amendment of the AAFCO definition for natural to include irradiation for sake of clarity. In the interim, I hope state feed control officials look at the spirit of the definition and opt not to enforce label changes that could, in fact, compromise the safety of pet foods.”

Here is my take: I am not quite as liberal as Mr. Dzanis. To me the irradiation process is not a natural one, period. To me natural means “as occurring in nature, without being touched and changed by humans”. Irradiation does not fall in that category. Therefore I am against its use, whether the consumer approves it or not. I also have the strong opinion that the consumer in most cases probably is not even able to make an educated decisions since not too much is known about not just the process but also its possible consequences. I think that the label itself is kind of misleading, the irradiation symbol has too much of a kind of “healthy, natural” appearance. I refer you to an interesting article by Susan Thixton on her Truth About Pet Food blog “Do you know what this symbol means?”. Some of her reader’s comments were: “I thought the flower meant it was a good thing; The symbol looks like it is promoting something "Organic". Now that I know it means food is treated with Radiation, I will watch for and avoid it at all cost in both my food and my dog's food and treats; I appreciate the information about the symbol. At first glance it looks like a label on a food that would be considered a natural food that would be free of artificial colors and preservatives. The best defense is an educated consumer.”

Sure, irradiation, there is no doubt, is a working instrument and does what it is supposed to do, which is protecting against bacterial contamination. But do we know what else does it do? Chemotherapy helps against cancer too, but it also makes your hair fall out, …. The cat food in Australia was safe from spoilage, but it also caused some animals to die… I think my dogs and cats are safer off eating some minor bacteria, at least that would be natural. That is of course unless you feed your pets during the middle of the dark night, there irradiated food may come in handy since it may glow.