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Pundit’s Mailbag — Irradiation, Pasteurization And Labeling

Our piece, Unfair CNN Report Showed One Clear Winner: Irradiation, brought a note from a frequent correspondent on the organic side of the business:

From the 5/22 Perishable Pundit, “Unfair CNN Report Showed One Clear Winner: Irradiation,” I am not sure if your statement, “There was no sense of proportion or comparative risk. The injury of a child was used to emotionally manipulate the audience,” was part of the argument for irradiation, or part of the argument against irradiation.

I have been to a couple of Bill Marler’s presentations where the clear message is “either irradiate (food X) or you’ll be hearing from me if you get implicated.” Complete with pictures of horribly injured children.

Attached here you can find a submission to FDA on the current bill to allow irradiated food to be labeled as being “pasteurized”.

I suspect you’ll hang me out to dry, but what the heck.

— Bob Sanderson
Jonathan’s Sprouts

We would never hang Bob out to dry, as he is not all wet, but he does approach things from a perspective different than the Pundit’s — which is why we so appreciate his contributions to this page.

Our statement about emotional manipulation and the CNN piece were neither pro- nor con-irradiation but an assessment of the problem with that type of journalism. Public policy issues are, of course, about the big picture, and bringing up suffering children can easily lead to a distortion of priorities.

So, for example, we might spend billions to get the death rate down to zero on spinach, and the weight of that expense might mean that budgets for medical research get reduced. The consequence might be that very visible deaths or injuries — such as that little girl on the television show — are eliminated. But countless thousands might die every year because a medication that would have been discovered or invented is not found.

Yet CNN can’t do a program and show you a person dying and say that this person right here would have been saved if we only had not spent money on the spinach industry. So the consequence of this type of television can be to distort public priorities toward solving the most visible, rather than the most important, problems.

When we say that Bob approaches the issues from a different perspective, the issue of irradiation and its labeling is a case in point. The attachment Bob sends is part of comment he sent to the FDA regarding the nomenclature used on irradiated food.

Currently the FDA has the following policy on labeling of irradiated foods:

The Radura is the international symbol for irradiation.

As part of its approval, FDA requires that irradiated foods include labeling with either the statement “treated with radiation” or “treated by irradiation,” along with the international symbol for irradiation, the Radura (see photo above.) Irradiation labeling requirements apply only to foods sold in stores. For example, irradiated spices or fresh strawberries should be labeled. Irradiation labeling does not apply to restaurant food.

There is a proposal to change this standard:

FDA is proposing that only those irradiated foods in which the irradiation causes a material change in the food, or a material change in the consequences that may result from the use of the food, bear the radura logo and the term “irradiated,” or a derivative thereof, in conjunction with explicit language describing the change in the food or its conditions of use. For purposes of this rulemaking, we are using the term ‘material change’ to refer to a change in the organoleptic, nutritional, or functional properties of a food, caused by irradiation, that the consumer could not identify at the point of purchase in the absence of appropriate labeling.

FDA is also proposing to allow a firm to petition FDA for use of an alternate term to “irradiation” (other than “pasteurized”). In addition, FDA is proposing to permit a firm to use the term “pasteurized” in lieu of “irradiated,” provided it notifies the agency that the irradiation process being used meets the criteria specified for the use of the term “pasteurized” in the federal Food, Drug, and Cosmetic Act (the act) and the agency does not object to the notification. This proposed action is in response to the Farm Security and Rural Investment Act of 2002 (FSRIA) and, if finalized, will provide consumers with more useful information than the current regulation.

So that means there are really two separate proposals: first, that unless there is a material change in the item no labeling would be required at all.

Second, that if the item is labeled, it can be labeled “pasteurized” as opposed to irradiated. The FDA is also looking for other terms that could be used in lieu of irradiation and pasteurization.

The FDA has a point. We don’t typically require labels for things we think are irrelevant. So, inherently, a requirement to label is an indication that something is up.

However, at this early stage in the battle for irradiated food, getting rid of the label would give opponents just another thing to argue against. So we would be inclined to maintain the labeling of irradiated foods so that opponents of irradiation can’t accuse those who are selling products of being deceptive.

We do not support the use of the term pasteurization for irradiation. Words have meanings, and the common usage of pasteurization does not include irradiation. However, the word irradiation gives rise to all kinds of thoughts that have nothing to do with food irradiation (no, the food doesn’t glow), so we would be open to another term.

However, our sense is that the folks pushing this have it almost precisely wrong. What they should be doing is proudly promoting the radura and the term irradiation and making it their own. Irradiated hamburger meat sells well in many venues. More and more imported tropicals are going to be treated with irradiation as we discussed in our piece on Mangos from India right here.

Enough people are concerned with food safety that they will prefer an irradiated product if properly marketed.

One key point regarding irradiation is that we have to make sure we keep up other food safety standards if we do start to use irradiation. As the CDC points out in a Q&A:


Irradiation has the potential to be used like milk pasteurization in the future. We have confidence in the safety of pasteurized milk for several reasons. The milk is graded and tested to make sure that the milk is clean enough to pasteurize in the first place. Careful industry standards and regulations monitor the effectiveness of the pasteurization process. The pasteurization occurs just before the milk goes into the carton, so the chance of re-contamination after pasteurization is nearly zero. Similar strategies and designs can make food irradiation as effective as milk pasteurization.

Currently, pasteurization is applied to foods (like milk) that already meet a defined cleanliness standard, and is applied at a dose that gives a standard defined effect. As the irradiation of food becomes commercialized for various foods, similar standardization will be required.

In other words, with or without irradiation, we still require Good Agricultural Practices.

Our correspondent’s submission to the FDA is focused on what he sees as the likelihood that allowing irradiation will eventually lead to requiring it or making food sold without irradiation illegal. This is a subject we dealt with, along with our correspondent, in this earlier piece.

We think Bob is probably correct, but we see less horror in this than he does.

To us here at the Pundit, there is a natural progression to these things. We build houses in hurricane zones, then learn the windows blow in and people die and property is destroyed. Then we invent hurricane shutters and, initially, this is the oddity. As they prove themselves, the zoning code is changed to require hurricane shutters.

So, if we get approval to irradiate spinach, and one brand starts out doing it and we have no foodborne illness on the irradiated product but have outbreaks on non-irradiated product, that irradiated product will gain market share.

More brands will do it, some retailers will only carry irradiated product and, one day, if irradiated has no outbreaks and conventional does, it will be the standard of safety.

Perhaps a law will be passed requiring treatment by irradiation or, perhaps, you won’t be able to get liability insurance if you don’t do it.

Some will recoil from this. Irradiation is currently forbidden on organic product. Yet the question, of course, is how serious are we about eliminating all foodborne illness?

If even one death or one case of kidney failure is unacceptable, then we really need a kill step and, for most food, that is going to be irradiation.

Many thanks to Bob for bringing this issue to light.

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