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  Health
  Food Irradiation Is Very Controversial!

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Topic:   Food Irradiation Is Very Controversial!

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Ellyn
Senior Member


1203 posts, Jul 2000

posted 10-28-2001 04:15 PM     Click Here to See the Profile for Ellyn     Edit/Delete Message   Reply w/Quote
The following letter was emailed today to at least 34 News Media locations--mainly TV news channels--in response to what I have observed to be a totally one-sided reporting of the food irradiation issue.

TO: THE NEWS MEDIA

FROM: Ellyn Sutton
(Note: I am writing this in caps because I am screaming at you.)

WHY IS THE NEWS MEDIA REPORTING THAT FRUITS AND VEGETABLES ARE IRRADIATED TO DESTROY BACTERIA AND GERMS IN A WAY THAT COMMUNICATES THAT THERE IS NO MAJOR CONTROVERSY SURROUNDING THE PRACTICE AND PROCESS OF IRRADIATING FOOD?

DO YOU HAVE NO CONCERN FOR THE HEALTH AND WELL-BEING OF THE PEOPLE WHO WILL BE EATING THIS IRRADIATED FOOD, LET ALONE THE HEALTH AND VITALITY OF YOURSELF AND YOUR LOVED ONES? ARE YOU JUST REPORTING WHAT THE FOOD IRRADIATION INDUSTRY WANTS YOU TO REPORT? THIS CERTAINLY APPEARS TO BE THE CASE!

THE FOOD IRRADIATION INDUSTRY HAS BEEN POSITIONING ITSELF TO MAKE BILLIONS OF DOLLARS AT THE EXPENSE OF THE HEALTH AND VITALITY OF THE PEOPLE OF AMERICA AND ANY OTHER PEOPLE WHO WILL BE EATING IRRADIATED FOOD, AND IT APPEARS AS THOUGH THEY HAVE THE NEWS MEDIA IN THEIR POCKETS.

CONCERNING IRRADIATING THE MAIL: DO YOU THINK THERE WILL BE ANY EFFORT TO NOT IRRADIATE PRODUCTS SUCH AS FOODS CONTAINING ENYZMES WHICH IRRADIATION IS KNOWN TO DESTROY ABSOLUTELY? PEOPLE WILL BE PURCHASING A TOTALLY USELESS PRODUCT AND NOT EVEN BE AWARE OF IT.

NOT ONLY WILL THESE IRRADIATED FOODS BE USELESS, BUT THERE IS NOW MORE AND MORE EVIDENCE COMING OUT THAT THESE IRRADIATED FOODS ARE ACTUALLY HARMFUL WHEN INGESTED--THAT THE IRRADIATION PROCESS ITSELF CHANGES ONE'S DNA. THIS IS INFORMATION THAT THE FDA NOW HAS IN ITS POSSESSION.

TAKE A LOOK AT THIS ARTICLE LISTING ITS TEN TOP REASONS FOR OPPOSING FOOD IRRADIATION.
__________________________

Ten Top Reasons For Opposing
Food Irradiation http://www.citizen.org/cmep/rad-food/factsheet10reasons.htm
4-15-1

1. In legalizing food irradiation, the U.S. Food and Drug Administration (FDA) did not determine a level of radiation to which food can be exposed and still be safe for human consumption, which federal law requires. I, II

2. In legalizing food irradiation, the FDA relied on laboratory research that did not meet modern scientific protocols, which federal law requires. I, IV

3. Research dating to the 1950s has revealed a wide range of problems in animals that ate irradiated food, including premature death, a rare form of cancer, reproductive dysfunction, chromosomal abnormalities, liver damage, low weight gain and vitamin deficiencies. V, VI, VII, VIII

4. Irradiation masks and encourages filthy conditions in slaughterhouses and food processing plants.IX, X Irradiation can kill most bacteria in food, but it does nothing to remove the feces, urine, pus and vomit that often contaminates beef, pork, chicken and other meat. Irradiation will not kill the pathogen that causes mad cow disease.

5. Irradiation destroys vitamins, essential fatty acids and other nutrients in food-- sometimes significantly. The process destroys 80 percent of vitamin A in eggs and 48 percent of beta carotene in orange juice, but the FDA nonetheless legalized irradiation of these products. XI, XII

6. Irradiation can change the flavor, odor and texture of food-- sometimes disgustingly so. Pork can turn red; beef can smell like a wet dog; fruit and vegetables can become mushy; and eggs can lose their color, become runny and ruin recipes. XIII, XIV, XV

7. Irradiation disrupts the chemical composition of everything in its path-- not just harmful bacteria, which the food industry often asserts. Scores of new chemicals called "radiolytic products" are formed by irradiation-- chemicals that do not naturally occur in food and that the FDA has never studied for safety. XVI, XVII

8. The World Health Organization did not follow its own recommendation to study the toxicity of "radiolytic products" formed in high-dose irradiated food before proposing in November 2000 that the international irradiation dose limit-- equal to 330 million chest x-rays-- be removed. XVIII, XIX

9. Soon, some irradiation plants may use cesium-137, a highly radioactive waste material left over from the production of nuclear weapons. This material is dangerous and unstable. In 1988, a cesium-137 leak near Atlanta led to a $30 million, taxpayer-funded cleanup. XX

10. Because it increases the shelf life of food and is used in large, centralized facilities, irradiation encourages globalization and consolidation of the food production, distribution and retailing industries. These trends have already forced multitudes of family farmers and ranchers out of business, reduced the diversity of products in the marketplace, disrupted local economies in developing nations, and put American farmers and ranchers at a great economic disadvantage. XXI

Notes

I. U.S. Code of Federal Regulations, Title 21, ß 170.22.

II. Federal Register, various filings, 1983-2000.

III. U.S. Code of Federal Regulations, Title 21, ß 170.20.

IV. Federal Register, various filings, 1983-2000.

V. A Broken Record: How the FDA Legalized-- and Continues to Legalize-- Food Irradiation Without Testing it for Safety. Washington, D.C.: Public Citizen, Cancer Prevention Coalition, Global Resource Action Center for the Environment, Oct. 2000.

VI. Kesavan, P.C., Swaminathan, M.S. "Cytotoxic and mutagenic effects of irradiated substrates and food material." Radiation Botany, 11:253-181, 1971.

VII. Schubert, J. "Mutagenicity and cytotoxicity of irradiated foods and food components." Bulletin of the World Health Organization, 41:873-904, 1969.

VIII. Spiher, A.T. "Food Irradiation: An FDA Report." FDA Papers, Oct. 1968.

IX. Nestor, F. and Hauter, W. The Jungle 2000: Is Americaís Meat Fit to Eat? Washington, D.C.: Government Accountability Project, Public Citizen, Sept. 2000.

X. Piccioni, R. "Food irradiation: Contaminating our food." The Ecologist, 18:2:48-55.

XI. FDA Memorandum, from Kim Morehouse, Ph.D. to William Trotter, Ph.D. April 11, 2000.

XII. FDA Memorandum, from Antonio Mattia, Ph.D. to William Trotter, Ph.D. Nov. 2, 1999.

XIII. Webb, T. et al. Food Irradiation: Who Wants It? Rochester, Vermont: Thorsons Publishers, 1987.

XIV. Huang, S. et al. "Effect of electron beam irradiation on physical, physicochemical and functional properties of liquid egg during frozen storage." Poultry Science, 76:1607-15, 1997.

XV. Wong, Y.C. et al. "Comparison between irradiated and thermally pasteurized liquid egg white on functional, physical and microbiological properties." Poultry Science, 75:803-808, 1996.

XVI. Murray, D. Biology of Food Irradiation. Somerset, England: Research Studies Press Ltd., 1990.

XVII. Op. cit. Note 5.

XVIII.International Consulative Group on Food Irradiation: Review of Data on High Dose (10-70 kGy) Irradiation of Food. Report of a Consulation, Karlsruhe, 29 August - 2 September 1994. Geneva: World Health Organization, 1994.

XIX. High-Dose Irradiation: Wholesomeness of Food Irradiated with Doses Above 10 kGy. Report of a Joint FAO/IAEA/WHO Study Group. Technical Report Series 890. Geneva: World Health Organization, 1999.

XX. Last radioactive capsules taken from DeKalb plant." Macon Telegraph, Nov. 20, 1990.

XXI. A Citizen's Guide to Fighting Food Irradiation. Washington, D.C.: Public Citizen's Critical Mass Energy and Environment Program, 2000.




[Edited 2 times, lastly by Ellyn on 10-28-2001]

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Duncan Kunz
Senior Member


582 posts, Oct 2000

posted 10-28-2001 10:47 PM     Click Here to See the Profile for Duncan Kunz     Edit/Delete Message   Reply w/Quote
I'm not a biochemist, and I don't have either the education or time to do a serious study of all the
evidence pro and con regarding irradiated food.

However, food-irradiation has been going on in Arizona for quite some time now. People
regularly irradiate all kinds of food, and the result is a drastic change in food taste, texture, and
often results in a diminishing of vitamins in the food.

The type of electromagnetic radiation involved is heat. We call the process "cooking".

Because cooking food is irradiating it, too. And it does -- you know this as well as I -- result in a
reduced vitamin count, and certainly changes the texture and flavor of the food. Also, cooking
can impart carcinogenic levels of carbon to the food, if it's burned.

Now I'm not making the point that the kind of irradiation that you're talking and cooking the food
is the same -- of course it's not. But I do believe that irradiation has some benefits, just like
cooking food does.

The most important one that comes to mind is that, in places where refrigeration is not available,
irradiated food -- like freeze-dried and vacuum-packed food -- will last longer and can be
transported anyplace without having to worry about the food spoiling and Third-World people
going without food.

I don't know whether the stories about the dangers from irradiated food are all true; like I said,
I'm not an expert. But my guess is that the people who really need irradiated food --
people in drought and famine-stricken areas, for example -- probably think the possible dangers
from getting sick from some irradiation byproducts are not as bad as the very real danger of their
kids starving.

Ant I think that’s the bottom line when it comes to new or controversial technologies. Not “Is this stuff that we’re using a perfect answer?” Because it isn’t – never.

The real question should be: “Is this new technology worth the possible problems? Do the advantages outweigh the disadvantages? Is this approach cost-effective?”

I can’t think of any of the newer technologies – food irradiation, nuclear power, genetic
engineering, vaccinations, missile defense, mega-vitamins, cloning - that are a no-brainer when it
comes to implementing them. They all have advantages over the older ways of doing things.
They all have disadvantages, too. I think it’s up to all of us to educate ourselves so we can figure
out whether the new technology is worth using.

But remember – all this new technology is like a genie – it'll never go to go back in the bottle.

------------------
Duncan Kunz / duncankunz@home.com
Mesa AZ / 480-891-2525

[Edited 2 times, lastly by Duncan Kunz on 11-02-2001]

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Molliani
Senior Member

Illinois
420 posts, Mar 2001

posted 10-29-2001 12:46 AM     Click Here to See the Profile for Molliani     Edit/Delete Message   Reply w/Quote
Duncan

[They all have disadvantages, too. I think it’s up to all of us to educate ourselves so we can figure
out whether the new technology is worth using.]

It seems to me there is a word missing
here. The word is choice.
Laws and mandates make no room
for choice.

Who really benefits from irriadiated
food?
Who really benefits from the genetic
manipulation of our seeds?

Guess again ..........it's not the poor and
starving downtrodden masses of some
beleaguered nation.

hmmm.......who do you suppose
really benefits?

hmmm.......why don't they want us to
have a choice?

hmmm........I know what my choice is
and I know who benefits.

It doesn't take a scientific mind or an
engineer to figure that one out.


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Ellyn
Senior Member


1203 posts, Jul 2000

posted 10-29-2001 03:28 AM     Click Here to See the Profile for Ellyn     Edit/Delete Message   Reply w/Quote
For those who are interested, here is another article from PUBLIC CITIZEN which contains quite a bit of information. It is entitled: The Problem With Irradiated Food: What The Research Says.

http://www.citizen.org/cmep/foodsafety/food_irradiation/articles.cfm?ID=1382

Another enlightening article: Microwave Cooking is Killng You! By Stephanie Relfe B.Sc.(Syd.) can be found at: http://www.relfe.com/microwave.html

Or you can use a search engine to investigate further. Good health to all!

Concerning ENZYMES: We are born with a limited number of food digestive enzymes. When we eat normally cooked food, these food digestive enzymes are used to help us digest our food. When these food digestive enzymes run out, numerous problems with digestion of food can often do occur. People get a lot of aches and pains and just think: It most be old age creeping up. The culprit is very often poor digestion which can be the cause of a very wide range of ailments.

Those of us who have few of our own digestive enzymes left can assist ourselves greatly by eating the food digestive enzymes in uncooked fruit or vegetables, or we can take papaya mint or another type of digestive enzyme aid. This is not a problem as long as these products have not been irradiated. Irradiation destroys all food digestive enzymes.

Now, with this mass irradiation program about to take place, there is going to be a question in our minds whether the product we purchased at our local store or through the mail is of any value. When we take a food digestive enzyme or eat a piece of uncooked fruit to help us digest our meal, will it be dead or alive?

The media has been very biased on this subject from the beginning and it was their most recent one-sided statements concerning irradiated food that prompted me to write my irate letter.

Another important point concerning enzymes:
Proteins and enzymes are interrelated and need to be in our diet in sufficient quantities. Enzymes activate proteins, which in turn activate hormones. Hormones in turn regulate enzyme levels. A full cycle!

When our foods are irradiated, the enzymes in them are destroyed. It is one thing to eat irradiated foods, knowing that there are no viable enzymes left in the food; it is another to eat food, thinking that it has enzymes in it, when in fact it has none, because somewhere along the line the food has been irradiated without our knowledge.



[Edited 2 times, lastly by Ellyn on 11-24-2001]

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Duncan Kunz
Senior Member


582 posts, Oct 2000

posted 10-29-2001 10:06 AM     Click Here to See the Profile for Duncan Kunz     Edit/Delete Message   Reply w/Quote
Dear Molliani:

As I mentioned earlier, I do not have either the education or training -- or the time to do a careful search of the literature -- to come down one way or another on whether or not food irradiation is a good thing. I do know there are many people who come out very strongly either in favor of or against irradiated food; I can only assume that those people know a lot more than I do - or they have some other agenda with which I am not familiar.

However, you do make some comments that I would like to respond to.

"It seems to me there is a word missing here. The word is choice. Laws and mandates make no room for choice."

I'd say it's just the opposite. It seems to me that the recent laws that allow for food to be irradiated means that now you can choose whether or not to have such things done. Before, there was no choice whatsoever. Before the laws which permitted food to be irradiated, nobody had a choice. Now we do.

And bear in mind that, just because the stuff is permitted, the Big Bad Companies are not going to stuff irradiated foods down our throat. As a matter of fact, an article in CNN Health at
http://www9.cnn.com/HEALTH/9711/25/irradiation/

says that "It works, but few are buying". And bear in mind that the people in Europe seems to be less in favor of irradiated food than most, and the sale of irradiated food is only a fraction of the food that's not irradiated.

"Who really benefits from irriadiated [sic] food? Who really benefits from the genetic manipulation of our seeds?"

Those are two different questions about two different technologies. Of course the companies who do the irradiation and/or the genetic engineering profit; anyone who says Monsanto or ADM are working solely for the good of the planet is a liar and a fool! But in a way, your question is like "But who really benefits from pickup trucks? It's Ford and Chevy that are making the profit here!"

Just because a big company makes a profit from irradiating food or manipulating seeds' genes or building 4X4s does not mean those things are necessarily bad. If enough people think that irradiated rutabagas or Starlink copyright corn-kernels or F-150s with the 6.2 liter PowerStroke Diesel are good things to have, they'll buy them. Otherwise, they won't. It gets back to giving us a right to make a choice.

"hmmm.......why don't they want us to have a choice? hmmm........I know what my choice is and I know who benefits."

Molliani, the only ones who don't want us to have a choice are the people that want to ban irradiated foods. It's those people that say that no one should be allowed to eat irradiated foods, because no one should be allowed to irradiate it. You say "I know what my choice is..." Exactly! With irradiation of food being legal you do have a choice, just like I do. You can choose to eat irradiated food and I can choose not to -- or the other way around. Before irradiation became permitted, we didn't have that right!

"It doesn't take a scientific mind or an engineer to figure that one out."

You're right. It doesn't. All it takes is for all of us to read both sides of the argument. If you base all your arguments on propaganda from the food-irradiation industry or the folks that do genetic engineering, you'll miss out on half the arguments. But if you base all your arguments on what Public Citizen says, you'll still miss out on half the arguments! Here's an example of another article on irradiation, found at

http://www.acsh.org/publications/booklets/irradiated.html .

"An overwhelming body of scientific data from around the world indicates that irradiated food, as approved by the United States Food and Drug Administration (FDA), is safe, nutritious and wholesome."

"As of November 1995, and dating back to 1958, food irradiation has been approved by 40 countries. This food preservation process has been adopted successfully in 27 countries, including such technologically advanced countries as Canada, France, Japan, The Netherlands, Belgium and South Africa."

"Commercial adoption of food irradiation is expected to reduce the presence of foodborne disease-causing microbes and parasites and thus also reduce the incidence of diseases caused by these pathogens."

"The United States Department of Agriculture estimates that the American consumer will receive approximately $2 in benefits such as reduced spoilage and less illness for each $1 spent on food irradiation."

"Irradiation has been studied more extensively than any other food preservation process, including canning, freezing, dehydration and chemical additives. Health authorities worldwide have based their approvals of irradiation on the results of sound scientific research."

"When food has been irradiated under FDA-approved conditions, no unique chemical (radiolytic) products have been detected."

Which article -- this one or the one from Public Citizen -- is right? I don't know. Maybe they both have some validity. All we can do is to read as much as we can on both sides of the issue, try to reason with our heads rather than our emotions, and hope that we, as consumers are given a choice as to what we want for ourselves and our families.

And the last comment you made is something I agree with heartily:

It doesn't take a scientific mind or an engineer to figure that one out.

Regards,

Duncan Kunz
duncankunz@home.com
Mesa AZ 480-891-2525

[Edited 5 times, lastly by Duncan Kunz on 11-02-2001]

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Ellyn
Senior Member


1203 posts, Jul 2000

posted 12-20-2001 02:30 AM     Click Here to See the Profile for Ellyn     Edit/Delete Message   Reply w/Quote
http://www.rense.com/general18/fo.htm

Chemicals Formed During
Food Irradiaton Can Be Harmful
12-19-1

The U.S. Food and Drug Administration (FDA) has ignored growing evidence that a new class of chemicals formed when food is irradiated could be harmful, according to a report released today by Public Citizen and the Center for Food Safety.

The groups are urging the FDA to refrain from legalizing irradiation for any additional types of food until the new chemicals are tested for safety. The chemicals, called cyclobutanones, do not occur naturally anywhere on Earth. They recently were found to cause genetic damage in rats, and genetic and cellular damage in human and rat cells.

The groups' report, Hidden Harm, details how the FDA has ignored this unique class of chemicals, which are created in many irradiated foods that the agency has legalized for sale in this country -- including beef, pork, chicken, lamb, eggs, mangoes and papayas. It is expected that cyclobutanones also would be formed in many other foods the FDA is currently considering to legalize for irradiation.

The organizations today also released a sworn affidavit of toxicologist William Au, who was retained by the groups to independently review the risks posed by cyclobutanones and other chemicals formed by irradiation that could cause genetic damage.

Along with a letter outlining numerous health concerns caused by food irradiation, the groups filed Hidden Harm and Au's affidavit with the FDA to oppose pending petitions to legalize irradiation for processed foods, which comprise 37 percent of the typical American's diet; molluscan shellfish, such as clams and oysters; crustacean shellfish, such as lobsters and shrimp; and meat products.

A fifth petition seeks to double the maximum dose of radiation to which poultry can legally be exposed.

"The risk that the FDA is taking with the health of the American people cannot be overstated," said Wenonah Hauter, director of Public Citizen's Critical Mass Energy and Environment Program. "If government officials knowingly allow people to eat food that contains these chemicals, they are courting a major public health disaster."

Though federal regulations require the FDA to determine whether food additives proposed for human consumption are likely to cause cancer, birth defects or other health problems, the agency has not done so for cyclobutanones, nor have agency officials explained why they have failed to do so. Under federal law, irradiation is considered a food additive.

Americans likely are unwittingly eating irradiated foods containing cyclobutanones. Though most irradiated food sold in stores must be labeled, there is no such requirement for restaurants, schools, hospitals, nursing homes and other institutional settings. And there is no labeling requirement for foods with irradiated ingredients, except those containing irradiated meat. Moreover, due to a lack of reporting requirements for food companies, it is unknown how much irradiated food is sold in the US, or where.

"Children are likely to be especially vulnerable to the risks of these untested chemicals in their food," said Peter T. Jenkins, policy analyst at the Center for Food Safety. "It is beyond me why the FDA would take a chance by exposing American children in this way. The science is against it."

Au, an environmental toxicology professor at the University of Texas Medical Branch in Galveston, is internationally recognized for his work on the toxicological mechanisms that induce human disease. For more than 20 years he has taught, published peer-reviewed research and served on expert committees. He has received numerous awards, and has published or co-published more than 100 articles.

"An emphasis should be placed on the products that are unique to the irradiation process and that are potentially mutagenic, e.g. 2-DCB [2-dodecylcyclobutanone]," Dr. Au wrote in the affidavit. "Without conclusive evidence regarding the safety of these products, the safety of irradiated food cannot be assured." Au urged the FDA to "seriously and explicitly" consider "repeated observations" of genetic damage and reproductive toxicity in feeding experiments.

Though cyclobutanones were first identified in irradiated food in 1971, it was not until 1998 that German government scientists discovered that one type of cyclobutanone, 2-DCB, caused genetic damage in rats, and genetic and cellular damage in human and rat cells.

Subsequently, the scientists found that two other types of cyclobutanones -- 2-TCB and 2-TDCB -- caused genetic and cellular damage in human cells. Rat feeding studies of these two chemicals are expected to be completed soon.

Despite these findings, the FDA not only has failed to publicly acknowledge the potential risks posed by cyclobutanones, but the agency proceeded to legalize irradiation for three classes of food even after the first two German studies were made public.

Last year, the FDA legalized the irradiation of eggs, juice and sprouting seeds despite the fact that several high-ranking agency officials four months earlier had attended an international conference in Beijing at which the 2-DCB toxicity findings were presented and discussed.

Ironically, cyclobutanones are so easily detectable and have been known to remain in food for such lengthy periods - more than a decade - that they are commonly used as "markers" to determine whether food has been exposed to ionizing radiation.

The groups are calling on the FDA to take several steps: refrain from legalizing irradiation for any additional foods until comprehensive, published, peer-reviewed research is conducted on cyclobutanones; conduct a comprehensive analysis of the cyclobutanone levels in foods covered by irradiation petitions already approved by or pending before the FDA; convene public hearings to thoroughly explore the potential health effects of cyclobutanones.

Expert Affidavit on Safety of Irradiated Food

By William W. Au, Ph.D.

William Au, being duly sworn, hereby deposes and says:

A. My address is: Division of Environmental Toxicology, Department of Preventive Medicine and Community Health, Ewing Hall, 700 Harborside Drive, University of Texas Medical Branch, Galveston, Texas 77555-1110, where I have been employed as a Professor since 1991. My Curriculum Vitae is attached hereto indicating my professional qualifications as a toxicologist. My primary research interest is in conducting molecular and cellular studies to elucidate toxicological mechanisms for the induction of human disease. Since obtaining my Ph.D. from the University of Cincinnati, I have more than 20 years of experience teaching, conducting and publishing peer-reviewed research, consulting and speaking internationally, editing professional publications, and serving on numerous expert committees. I am a member of the major scientific societies related to toxicology and have received approximately one dozen awards recognizing my professional contributions. I have delivered more than 35 invited lectures internationally and published or co-published more than 100 articles in the toxicology field.

B. I submit this Affidavit on the food irradiation petitions pending before the United States Food and Drug Administration, most specifically FAP 9M4697 (Docket No. 99F-5522), addressing "ready-to-eat foods," however, the conclusions herein also apply generally to other past and pending irradiation petitions.

C. I submit this Affidavit on behalf of two Washington, DC, non-profit groups, the Center for Food Safety and Public Citizen, who have retained me as a consulting expert. Prior to this consultation I had no prior involvement with those or any other non-profit groups involved in food irradiation issues.

D. In formulating my opinion, I have reviewed relevant documents and studies that were provided by my clients and conducted independent research including several publications that I have selected from the literature.

My opinion, based on a reasonable degree of scientific certainty, is as follows: Ionizing radiation is a well-documented teratogen, mutagen and carcinogen whereas some other procedures for food decontamination / sterilization such as heat and steam are not. Ionizing radiation interacts with cellular macromolecules that are also present in food products to generate toxic products. Therefore, the use of radiation to decontaminate/sterilize foods that are destined for human consumption should be evaluated for health concerns very carefully. Whenever other processing methods or combination of methods that are equally effective in reducing the risk of food borne disease are available, the use of the radiation procedure should be avoided.

Therefore, it is surprising to learn from the Food and Agriculture Organization/International Atomic Energy Agency/World Health Organization report (1999) that those agencies gave a blanket statement of approval in the conclusion section "the study group concluded that no upper dose limit need be imposed." (p. 161). This decision can lead to misuse of the procedure in processing food for human consumption. Some reports in the peer-reviewed literature on mutagenic activities of irradiated foods were not considered in the 1999 FAO/IAEA/WHO report (Bhaskaram and Sadasivan, 1975; Vijayalaxmi, 1975, 1976, 1978; Vijayalaxmi and Sadasivan, 1975; Vijayalaxmi and Rao, 1976).

Although the observations from these studies are not confirmed by some publications in the literature, the positive findings have support from other publications (Bugyaki et al, 1968; Moutschen-Dahmen, et al., 1970; Anderson et al., 1980; Maier et al., 1993). Furthermore, repeated observations of activities that have significant public health implications such as polyploidy in somatic cells, genetic alterations in germ cells and reproductive toxicity should not be ignored, but should be considered seriously and explicitly by FDA with respect to the pending food irradiation petitions.

Radiolytic products are formed during the irradiation of food (Schubert, 1969). Their potential health hazards have not been adequately evaluated. An emphasis should be placed on the products that are unique to the irradiation process and that are potentially mutagenic, e.g. 2-dodecylcyclobutanone (Delincee and Pool-Zobel, 1998; Delincee et al., 1998). The quality and quantity of these radiolytic products may be different from one food type to another. Without conclusive evidence regarding the safety of these products, the safety of irradiated food cannot be assured. Conclusive evidence of safety of these products can be derived from in vivo studies published in peer-reviewed journals.

The formation of hazardous free radicals in irradiated food that can cause DNA damage is of serious concern. For food with high water content, the free radicals are rapidly degraded after irradiation. Therefore, human exposure to the free radicals through the food chain is minimal. For food with low water content, the Food and Drug Administration stated that "irradiated dry spices and seasonings are examples of foods in which free radicals are known to persist for long periods of time." (FDA, 1986, p. 13379).

However, the FDA concluded that this should not be of concern based on the manner in which these foods are used. On the other hand, the concerns for other dry foods that are consumed without further cooking and that are consumed in large quantities, such as dried fruits and nuts, are not considered. This possibility should be evaluated to determine the potential for exposing consumers to free radicals. This concern should be included in the FDA?s analysis of the "ready-to-eat food" irradiation petition, FAP 9M4697.

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