Sworn affidavit of University of Texas toxicologist William Au
 raising concerns about the risks posed by chemicals formed in
irradiated food

The Cancer Prevention Coalition and Illinois Food Safety Coalition
 Announce a Public Information Campaign to Warn of the Serious
 Dangers of Food Irradiation

Cyclobutanones – which do not occur naturally in any food – were shown to promote cancer development and cause genetic damage in rats. The chemicals have also been shown to cause genetic and cellular damage to human and rat cells.

[snip]

Under the Microscope

Research into the potential toxicity of cyclobutanones came to light in 1998. Henry Delincée of Germany’s Federal Research Center for Nutrition found that a specific cyclobutanone called 2-DCB caused genetic and cellular damage to human and rat colon cells. [5]

In three subsequent experiments, Delincée  and his colleagues found that 2-DCB caused genetic damage in rats [6]; that related chemicals called 2-TCB and 2-TDCB caused genetic and cellular damage in human cell cultures [7]; and – most disturbing of all – that cyclobutanones promoted cancer development in rats. [8]

[snip]

Europe Takes It Seriously

Meanwhile, the FDA’s counterparts in Europe are treating the matter far more cautiously.

In spring 2002, the 15-member European Union succeeded in delaying an international proposal by the Codex Alimentarius Commission (which sets food safety standards for more than 160 nations) to allow any food to be irradiated at any dose – no matter how high.

And, the EU has delayed its own proposal to allow irradiation for shrimp, frog legs, cereal grains, egg whites and other foods. until ongoing experiments into the toxicity of cyclobutanones are completed.

This approach to policy-making, known as the precautionary principle, is more prevalent in Europe than in the U.S., where government officials are much more inclined make political decisions before all the facts are in.

Righting the Wrongs

In the interest of protecting the public health, we have called on the FDA to:

_ Analyze the cyclobutanone levels of all foods that the FDA has legalized or has under consideration for irradiation;
_ Refrain from legalizing irradiation for any additional foods until comprehensive, published, peer-reviewed research is conducted into the potential health hazards of cyclobutanones; and
_ Convene public hearings to thoroughly explore and educate consumers about the potential health hazards of cyclobutanones.
 
Notes

1.   Stevenson, M.H. “Identification of irradiated foods.” Food Tech, 48:141-144, 1994.
2.   LeTellier, P.R. and Nawar, W.W. “2-alkylcyclobutanones from the radiolysis of triglycerides.” Lipids, 7: 75-76, 1972.
3.   FDA Food Additive Petition 9M4697, Docket No. 99F-5522.
4.   Personal communication with Laura Tarantino, Deputy Director, FDA Office of Premarket Approval, June 27, 2001.
5.   Delincée, H. and Pool-Zobel, B. “Genotoxic properties of 2-dodecylcyclobutanone, a compound formed on irradiation of food containing fat.” Rad Phys and Chem, 52:39-42, 1998.
6.   Delincée, H. et al. “Genotoxicity of 2-dodecylcyclobutanone.” Food Irradiation: 5th German Conference, Karlsruhe, Nov. 1998.
7.   Delincée, H. et al. “Genotoxicity of 2-alkylcyclobutanones.” (Abstract) 12th International Meeting on Radiation Processing, March 25-30, 2001, Avignon, France.
8.   Marchioni, Eric et al. “Information about the potential toxicity of 2-alkylcyclobutanones.” International Consulative Group on Food Irradiation, Dec. 2001.
9.   Annual Report on Activities: 17th Meeting of the International Consultative Group on Food Irradiation. Geneva, Nov. 2000.
10.   65 Federal Register 45280, July 21, 2000.
11.   Crone, A.V.J. et al. “Synthesis, characterization and use of 2-tetradecylcyclobutanone together with other cyclobutanones as markers for irradiated liquid whole egg.” Jour Sci Food Agric, 62:361-367, 1993.

http://www.citizen.org/cmep/foodsafety/food_irrad/articles.cfm?ID=12342

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Nuclear lunch: The dangers and unknowns of food irradiation

On December 12, the US Food and Drug Administration (FDA) approved the use of food-irradiation for beef. Irradiation has been available for years for poultry, pork, spices and vegetables in several other countries. The food industry claims it is absolutely safe and a good way to kill harmful bacteria. But consumer organizations protest food-irradiation as unsafe.

(486.4825) Food & Water - Beginning in 1986, the FDA has given the green light to expose nearly the entire US food supply to nuclear irradiation. Since then, staunch citizens' opposition has kept the technology out of use. Its use in the beef industry would open the door to food irradiation as the "solution" to contamination crises in all food groups, from poultry to fruits and vegetables.

With beef irradiation approved, citizens' opposition, not government regulation, remains the critical component in keeping irradiated food off US store shelves. And from the hazards inherent in the technology to the FDA's own admission that the safety studies are flawed, the risks involved with food irradiation still far outweigh the presumed "benefits".

Food is irradiated using radioactive gamma sources, usually cobalt 60 or cesium 137, or high-energy electron beams. The gamma rays break up the molecular structure of the food, forming positively- and negatively-charged particles called free radicals. The free radicals react with the food to create new chemical substances called "radiolytic products". Those unique to the irradiation process are known as "unique radiolytic products" (URPs).
Some radiolytic products, such as formaldehyde, benzene, formic acid and quinones are harmful to human health. Benzene, for example, is a known carcinogen. In one experiment, seven times more benzene was found in cooked, irradiated beef than in cooked, non- irradiated beef. Some URPs are completely new chemicals that have not even been identified, let alone tested for toxicity.

In addition, irradiation destroys essential vitamins and minerals, including vitamin A, thiamine, B2, B3, B6, B12, folic acid, C, E, and K; animo acid and essential polyunsaturated fatty acid content may also be affected. A 20-to-80 percent loss of any of these is not uncommon.

Safety studies flawed

The FDA reviewed 441 toxicity studies to determine the safety of irradiated foods. Dr. Marcia van Gemert, the team leader in charge of new food additives at the FDA and the chairperson of the committee in charge of investigating the studies, testified that all 441 studies were flawed. The government considers irradiation a food additive in testing food additives for toxicity, laboratory animals are fed high levels (in comparison to a human diet) of potential toxins. The results must then be applied to humans with theoretical models. It is questionable whether the studies the FDA used to approve food irradiation followed this process. In fact, the FDA claimed only five of the 441 were "properly conducted, fully adequate by 1980 toxicological standards, and able to stand alone in support of safety". With the shaky assurance of just five studies, the FDA approved irradiation for the public food supply.

To make matters worse, the Department of Preventive Medicine and Community Health of the New Jersey Medical School found that two of the (five) studies were methodologically flawed. In a third study, animals eating a diet of irradiated food experienced weight loss and miscarriage, almost certainly due to irradiation-induced vitamin E dietary deficiency. The remaining two studies investigated the effects of diets of food irradiated at doses below the FDA-approved general level of 100,000 rads. Thus, they cannot be used to justify food irradiation at the levels approved by the FDA.

Other studies indicate serious health problems associated with eating irradiated food. A compilation of 12 studies carried out by Raltech Scientific Services, Inc. under contract with the US government examined the effect of feeding irradiated chicken to several animal species. The studies indicated the possibility of chromosome damage, immunotoxicity, greater incidence of kidney disease, cardiac thrombus, and fibroplasia. In reveiwing Raltech's findings in 1984, USDA (Department f Agricultur) researcher Donald Thayer asserted: "A collective assessment of study results argues against a definitive conclusion that the gamma-irradiated test material was free of toxic properties."

Studies of rats fed irradiated food also indicate possible kidney and testicular damage and a statistically significant increase in testicular tumors. One landmark study in India found four out of five children fed irradiated wheat developing polyploidy, a chromosomal abnormality that is a good indication of future cancer development.

[snip]

Not a Silver Bullet

Irradiation poses serious risks, and it still does not ensure safe meat. Although it kills most bacteria, it does not destroy the toxins created in the early stages of contamination. And it also kills beneficial bacteria which produce odors, indicating spoilage and naturally control the growth of harmful bacteria.

Irradiation also stimulates aflatoxin production. Aflatoxin occurs naturally in humid areas and tropical countries in fungus spores and on grains and vegetables. The World Health Organization (WHO) considers aflatoxin to be a significant public health risk and a major contributor to liver cancer in the US South.

In addition, irradiation will likely have a mutagenic effect on bacteria and viruses that survive exposure. Mutated survivors could be resistant to antibiotics and could evolve into more virulent strains. Mutated bacteria could also become radiation-resistant, rendering the radiation process ineffective for food exposed to radiation-resistant strains.

Radiation-resistant strains of salmonella have already been developed under laboratory conditions, and scientists at Louisiana State University in Baton Rouge have found that one bacteria occurring in spoiled meat and animal feces can survive a radiation dose five times what the FDA will eventually approve for beef. Scientists exposed the bacteria, called D.radiodurans, to between 10 and 15 kilograys (kGy) of radiation for several hours--enough radiation to kill a person several thousand times over. The bacteria, which scientists speculate evolved to survive extreme conditions of dehydration, survived the radiation exposure.


[snip]

Excepted from the Food & Water report Meat Monopolies: Dirty Meat and the False Promises of Irradiation by Susan Meeker- Lowry and Jennifer Ferrara, published in Food & Water Journal, Fall/Winter 1997-1998. For a copy of the complete report contact Food & Water Inc. at: R.R.1, Box 680, Walden, Vermont 05873. Tel: +1-802-563-3300; Fax: +1-802-563-3310

http://www.antenna.nl/wise/index.html?http://www.antenna.nl/wise/486/4825.html

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Mark Worth and Peter Jenkins / Public Citizen and The Center for Food Safety
Executive Summary

In 1971, two University of Massachusetts food researchers discovered that when certain fats commonly found in food are irradiated, the resulting byproducts include a class of chemicals that had never before been found in food. These chemicals _ called cyclobutanones _ are not just unique to food, they have never been found to naturally occur in any other substance.

Thirty years later, the discovery of these chemicals lies at the center of an international debate that could have profound implications for the future of irradiated food. In recent experiments conducted by German government scientists, one of these chemicals, 2-dodecylcyclobutanone _ or 2-DCB _ was shown to cause genetic damage when given to rats, and genetic and cellular damage to human and rat cells. Two other chemicals in the cyclobutanone family _ 2-TCB and 2-TDCB _ were also shown to cause genetic and cellular damage to human cells.

[snip]

In the interest of protecting the health of Americans, and in order for the agency to fulfill its federal mandate to protect Americans from dangerous food additives, Public Citizen and the Center for Food Safety are calling on the FDA to:

•  Conduct a comprehensive analysis of the fat levels of all foods that the FDA has legalized or has under consideration for irradiation, and the cyclobutanone levels of these foods after they are irradiated;
•  Refrain from legalizing the irradiation of any additional foods until comprehensive, published, peer-reviewed research is conducted into the likelihood that cyclobutanones could cause health problems.
•  Convene public hearings to thoroughly explore the potential health effects of cyclobutanones

‘Since we would like to know whether, in the case of cyclobutanones, DNA [damage] has any significance, ...the results urge caution, and should provide impetus for further studies.’ – Henry Delincée, Federal Research Center for Nutrition Karlsruhe, Germany 

To see the complete study, please go to: http://www.mindfully.org/Food/Irradiation-FDA-IgnoringDec01.htm

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Why Oppose Food Irradiation?

•   Irradiation is not necessary to prevent food borne illness and irradiation merely masks filthy conditions in slaughterhouses which cause meat to be contaminated with bacteria that cause illness.

•   Irradiation forms new chemicals in food that are known or suspected to cause cancer and birth defects; destroys vitamins and other essential nutrients; and corrupts the flavor, odor and texture of food.  A wide range of health problems have been observed in animals fed irradiated foods, including premature death, stillbirths, mutations, fatal internal bleeding, organ damage, immune system dysfunction, stunted growth and nutritional deficiencies.

•   Irradiated food does not have to be labeled when served in schools, restaurants, hospitals, or nursing homes.  Parents would not know if their children are eating irradiated meat as part of the National School Lunch Program (a change the USDA has recently implemented)

•   Irradiation exacerbates the problems faced by family farms because it opens the floodgates to imported food.

•   Irradiation contributes to the consolidation of the food industry because it extends shelf life allowing agribusiness to move their operations outside the U.S., where costs are cheaper, but labor and environmental standards are weaker.

•   The European Parliament has refused to expand the use of irradiation for additional types of food (currently restricted to spices, dried herbs, and seasonings) due to lingering health and safety concerns.

•   Irradiation facilities can create air pollution and other environmental and worker safety threats.

•   In legalizing and endorsing food irradiation, the U.S. Food and Drug Administration and the World Health Organization, respectively, ignored a vast amount of research suggesting that irradiated foods are not safe for human consumption.

http://www.citizen.org/cmep/foodsafety/food_irrad/articles.cfm?ID=11803

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The Food Commission - UK

Press release Friday 25th October 2002

Scientists in row over safety of irradiated foods

Scientists investigating the toxicity of chemicals in irradiated food have challenged Europe's most prestigious advisory committee - the Scientific Committee on Food (SCF) - after the committee decided to ignore the researchers' latest findings, the Food Magazine revealed today.
The EU-funded research team's original study contained important new evidence of the genotoxicity and cytotoxicity of cyclobutanones, found exclusively in irradiated fat-containing food. The researchers' report summary said: 'The experiments demonstrate that pure compounds, known to be exclusively formed upon irradiation of fat-containing food, exhibit some toxic effects including promotion of colon carcinogenesis in rats… Whether these findings are relevant to the human exposure situation needs to be analysed. In our opinion further investigations, including confirmation of our results by other laboratories, will help to elucidate a possible risk associated with the consumption of irradiated fat-containing foods.' 1

However, the SCF concluded on 3 July 2002 that the research was not adequate to make statements about the real risk to human health, and that they would base their recommendations on a 15-year old review which failed to find evidence of toxicity.2 The SCF's decision was important because the discussion of irradiation at the international food standards-setting body Codex was delayed in March pending the opinion of the SCF on the results of the new research. If the SCF gives 2-ACBs the all-clear then Codex will probably follow suit.

In a remarkable open letter distributed in response to the SCF decision, the research scientists repeated their main concerns and emphasised that the chemicals in irradiated food '…present cytotoxic and genotoxic effects in cultured human cells, promote colon carcinogenesis in rats and accumulate in adipose tissues of rats fed with these compounds.'

In a veiled hint against the SCF's dismissalof their work, the researchers emphasise that their 'new data, which will be published in peer-reviewed journals, raise some doubts or at least suggest that caution should be exercised before any risk to consumers by exposure to these compounds is denied'.

Merav Shub, UK Food Irradiation Campaign leader, said 'Consumers are very concerned that the precautionary principle is being abandoned by the SCF. The committee must re-think its position.'

Details from Merav Shub tel: 020 7837 9229.

1. www.iaea.org/programmes/rifa/icgfi/documents/summary-press.pdf
2. SCF report SCF/CS/NF/IRR/26 ADD 3 Final, 3 July 2002 [http://europa.eu.int/comm/food/fs/sc/scf/out135_en.pdf]

http://www.foodcomm.org.uk/irradiation_2002_press.htm

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US food irradiation expert Wenonah Hauter states "irradiation significantly alters the composition of food. The negative health effects that irradiated foods have had on lab animals are well documented, including premature deaths, mutations, foetal death, reproductive problems, immune system disorders, fatal internal bleeding, organ damage, stunted growth and nutritional deficiencies". http://foodirradiationinfo.org/news.html