A special report by Public Citizen and GRACE

October 2002Prepared by Mark Worth

This document can be viewed or downloaded atwww.citizen.org/cmep or www.gracelinks.org/nuke/food

BAD TASTETHE DISTURBING TRUTH ABOUTTHE WORLD HEALTH ORGANIZATION’SENDORSEMENT OF FOOD IRRADIATION

Public Citizen215 Pennsylvania Ave., S.E.Washington, D.C. 20003tel: (202) 546-4996fax: (202) 547-7392cmep@citizen.orgwww.citizen.org/cmep

© 2002 Public Citizen. All rights reserved.

Public Citizen, founded by Ralph Nader,is a non-profit research, lobbying andlitigation organization based in Washington,D.C. Public Citizen advocates for consumerprotection and for government and corporateaccountability, and is supported by more than150,000 members throughout the United States.

GRACE215 Lexington Avenue, Suite 10016New York, NY 10016tel: (212) 726-9161fax: (212) 726-9160info@gracelinks.orgwww.gracelinks.org

© 2002 GRACE. All rights reserved.

GRACE works to form new linkswith the research, policy and grassrootscommunities to preserve the futureof the planet and protect the qualityof the environment.

ContentsExecutive Summary 5Introduction 9Controlling the Science 11

A Solid FoundationThe Foundation Begins to CrumbleThe Brussels Agenda Continues to FadeDrifting Further AfieldThe Final Step

Controlling the Information 21‘Shaping Public Opinion’‘Facilitate the International Movement of Irradiated Food’‘Develop a More Friendly Feeling to Irradiation’‘All Available Methods Should Be Exploited’Dismissing Consumer ConcernsGoing Global

Controlling the Future 30A Disturbing TrendHidden Harm?

Recommendations 36Notes 37Table 1 – A Dubious Record: How the Original Food Irradiation

Research Agenda Has Largely Been Ignored 17

Table 2 – Scientific Shell Game: How Research Questioningthe Safety of Irradiated Foods Fell by the Wayside 31

BAD TASTETHE DISTURBING TRUTH ABOUTTHE WORLD HEALTH ORGANIZATION’SENDORSEMENT OF FOOD IRRADIATION

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WHO, IAEA and FAO officialsfalsely stated in 1980: “All thetoxicological studieshave produced no evidence ofadverse effects as a result of irradiation.”

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Executive Summary

WITH IRRADIATION’S PROMISEof killing E. coli, Salmonella, Listeria andother food-borne pathogens; neutralizingfruit flies, mango seed weevils and otherexotic pests; and delaying the spoilage ofmeat, fruit and vegetables, this proclama-tion holds the potential to dramaticallyalter the way food is produced, distributedand sold around the globe. As far as theworld’s food supply is concerned, theproclamation is one of the most significantin recent memory.

In the process of assessing the safetyand wholesomeness of irradiated foods, did

the World Health Organization fulfill itsmission to preserve the health of theEarth’s population?

How could irradiated foods be de-clared safe and wholesome if animals fedirradiated foods in experiments dating back50 years have suffered dozens of healthproblems, including premature death,mutations and other genetic abnormalities,fetal death and other reproductive prob-lems, immune system disorders, fatalinternal bleeding, organ damage, tumors,stunted growth and nutritionaldeficiencies?3a

THE WORLD HEALTH ORGANIZATION is the mostimportant and influential agency of its kind on the planet. Created in1948 by the United Nations, the WHO pursues a mission nothingshort of preserving the health of the Earth’s population – “a state ofcomplete physical, mental and social well-being and not merely theabsence of disease or infirmity.”1

Headquartered in Geneva, the WHO has grown from 61 membernations at its founding to 193 today, from Algeria to Zimbabwe. Itsmore than 100 initiatives encompass virtually every health problemimaginable, from anthrax and adolescent reproductive health, tovitamin A deficiency and violence against women.2

When the WHO speaks, the world listens.

In 1999, the WHO announced that any food could be “treated”with ionizing radiation and still be safe for human consumption. Eventhough this radiation – in the form of gamma rays emanating fromradioactive cobalt-60 or cesium-137, or near-speed-of-light electronsfired by linear accelerators – could be as high as the equivalent ofseveral billion chest x-rays, a WHO report proclaimed that irradiatingfood “does not result in any toxicological hazard.”3

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Has the WHO’s assessment been madeindependent of efforts to further thelegalization, commercialization and con-sumer acceptance of irradiated foods?

Has the WHO’s analysis been uncor-rupted by efforts to resuscitate the nuclearindustry – an analysis that could have beentainted by an agreement giving the IAEAthe ultimate control over nuclear research?

THESE QUESTIONS YIELD dis-turbing answers – answers that challengethe reliability of the WHO’s stamp ofapproval. An in-depth review of theWHO’s 40-plus-year involvement inassessing whether irradiated foods are safefor human consumption reveals the follow-ing:

! The WHO has played a role inabandoning the original research agendathat it co-drafted in 1961, which urged thata wide range of experiments be conductedinto the safety and wholesomeness ofirradiated foods. These experiments, thedrafters wrote, should analyze whetherirradiated foods are toxic or radioactive;whether they could cause cancer or nutri-tional deficiencies; or whether the scientificexpertise even existed to answer thesefundamental questions. Most of the itemson this research agenda were not followedup in key WHO reports.

! The WHO has ceded an inordinateamount of authority to the InternationalAtomic Energy Agency, going so far as tohand the IAEA the ultimate power toresearch the safety of irradiated foods. TheIAEA – whose mission is preserving thenuclear industry, not the health of people –has exercised this power to a significantextent. The IAEA has published 19 of the29 major international reports on foodirradiation since 1962, and all but four ofthe reports issued during the formativeperiod from 1973 to 1993. These later

reports led to the proclamation that anyfood could safely be irradiated at any dose.

! With the WHO assuming a backseatrole, the IAEA is leading a campaign tofurther the legalization, commercializationand consumer acceptance of irradiatedfoods worldwide. Toward accomplishingthis goal, the IAEA has published all eightof the major international reports related tothese issues. One IAEA publication states:“We must confer with experts in the vari-ous fields of advertising and psychology toput the public at ease… Any word orstatement containing the word ‘radiation’or ‘radiate’…will cause the product to beavoided…and should not be required onthe label.”4

! The WHO has played a role indismissing and misrepresenting evidencesuggesting that irradiated foods may not besafe for human consumption. The WHO,along with the IAEA and the UnitedNations’ Food and Agriculture Organiza-tion (FAO), took research that revealedhealth problems in animals that ate irradi-ated foods, and stated that the researchactually revealed no health problems thatcould be attributed to irradiation. More-over, some research that the WHO, IAEAand FAO initially claimed yielded adverseeffects were later omitted from key reports.

! The WHO has played a role indismissing recent evidence that uniquechemical byproducts formed in irradiatedfoods – cyclobutanones – promoted thecancer-forming process in rats, caused thedevelopment of tumors and lesions in rats,and caused genetic damage in rats and inhuman cells. Cyclobutanones have neverbeen found to occur naturally in any food.Furthermore, a prominent U.S. Armyresearcher falsely stated in a 1989 IAEApublication that no such unique chemicalshave ever been detected in irradiated foods.

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Despite efforts to downplay the potentialhazards of cyclobutanones, the EuropeanUnion and the Codex Alimentarius Com-mission (which sets food-safety standardsfor more than 160 nations) have delayedproposals to expand food irradiation. Atthis writing, the EU is conducting a formalinquiry into the potential hazards ofcyclobutanones.

A full airing of these shortcomings andswift actions to remedy them are needed tohelp ensure that the increasing proliferationof irradiated foods throughout the worldwill not endanger the health of people whoeat these products. By assuming, in the faceof mounting evidence to the contrary, thatirradiated foods are safe for human con-sumption, the World Health Organizationhas taken a leap of faith that couldthreaten the health of millions of peopleliving in more than 50 countries wherethese products can legally be sold.

DUE TO THE IRREGULARITIES inthe process by which the World HealthOrganization, the International AtomicEnergy Agency, and the United Nations’Food and Agriculture Organization haveendorsed food irradiation, Public Citizenmakes the following recommendations:

! The WHO, IAEA and FAO shouldpromptly place a moratorium on any furtherrecommendations to expand food irradia-tion in any fashion.

! The WHO, IAEA and FAO shouldpromptly withdraw the conclusions andsuspend the recommendations issued in the1999 report, High-Dose Irradiation: Whole-someness of Food Irradiated with Doses Above10 kGy, which endorsed irradiation for allfoods at any dose – no matter how high.The agencies should inform all membernations of this action and recommend thatthey not proceed with food irradiation ofany kind.

! The WHO should promptly conduct,commission or otherwise foster published,peer-reviewed research into the core safetyand wholesomeness issues raised at theFAO/IAEA/WHO meeting on the whole-someness of irradiated food held in Brus-sels, 23-30 October 1961. Research shouldalso be conducted into key safety andwholesomeness issues raised since theBrussels meeting, including the toxicity ofcyclobutanones, and the radiation-inducedformation and increased concentration ofchemicals known or suspected to causecancer, birth defects and other healthproblems. These chemicals include ben-zene, toluene and methyl ethyl ketone.

! A 1959 agreement giving the IAEA“the primary responsibility” to research anddevelop nuclear technologies, and torequire the WHO to consult with the IAEAon overlapping projects, should be dis-solved.

! The United Nations should promptlyappoint an independent panel of expertsfrom the fields of toxicology, food science,radiation chemistry, nutrition and otherrelevant fields to conduct a comprehensivereview into the activities of the WHO,IAEA and FAO related to food irradiation.This panel should review all WHO, IAEAand FAO publications, and identify andcorrect all inaccurate, misleading andincomplete statements regarding foodirradiation.

This panel should also investigate therole played by the IAEA in the process ofendorsing food irradiation, and whether theagency’s role has corrupted the integrity ofthe analysis of the safety and wholesome-ness of irradiated foods. Meetings of thispanel should be open to the public, and allmaterials and findings should be distributedto member nations and be made availableto the public.

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“We have to know and understand the ordinary people. We must confer withexperts in the various fieldsof advertising and psychology to put the public at ease, and develop a more friendly feeling to irradiation.”– A South African food industry executive, speaking in 1982 at an international conference on marketing and consumer acceptance of irradiated foods

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WITH IRRADIATION’S PROMISE ofkilling E. coli, Salmonella, Listeria and otherfood-borne pathogens; neutralizing fruitflies, mango seed weevils and other exoticpests; and delaying the spoilage of meat,fruit and vegetables, this proclamationholds the potential to dramatically alter theway food is produced, distributed and soldaround the globe. As far as the world’s foodsupply is concerned, the proclamation isone of the most significant in recentmemory.

In the process of assessing the safetyand wholesomeness of irradiated foods, did

the World Health Organization fulfill itsmission to preserve the health of theEarth’s population?

How could irradiated foods be de-clared safe and wholesome if animals fedirradiated foods in experiments dating back50 years have suffered dozens of healthproblems, including premature death,mutations and other genetic abnormalities,fetal death and other reproductive prob-lems, immune system disorders, fatalinternal bleeding, organ damage, tumors,stunted growth and nutritionaldeficiencies?7a

IntroductionTHE WORLD HEALTH ORGANIZATION is the most

important and influential agency of its kind on the planet. Created in1948 by the United Nations, the WHO pursues a mission nothingshort of preserving the health of the Earth’s population – “a state ofcomplete physical, mental and social well-being and not merely theabsence of disease or infirmity.”5

Headquartered in Geneva, the WHO has grown from 61 membernations at its founding to 193 today, from Algeria to Zimbabwe. Itsmore than 100 initiatives encompass virtually every health problemimaginable, from anthrax and adolescent reproductive health, tovitamin A deficiency and violence against women.6

When the WHO speaks, the world listens.

In 1999, the WHO announced that any food could be “treated”with ionizing radiation and still be safe for human consumption. Eventhough this radiation – in the form of gamma rays emanating fromradioactive cobalt-60 or cesium-137, or near-speed-of-light electronsfired by linear accelerators – could be as high as the equivalent ofseveral billion chest x-rays, a WHO report proclaimed that irradiatingfood “does not result in any toxicological hazard.”7

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Has the WHO’s assessment been madeindependent of efforts to further thelegalization, commercialization and con-sumer acceptance of irradiated foods?

Has the WHO’s analysis been uncor-rupted by efforts to resuscitate the nuclearindustry – an analysis that could have beentainted by an agreement giving the IAEAthe ultimate control over nuclear research?

These questions yield disturbinganswers – answers that challenge thereliability of the WHO’s stamp of ap-proval. An in-depth review of the WHO’s40-plus-year involvement in assessingwhether irradiated foods are safe for humanconsumption revealsthe following:

! The WHO hasplayed a role in aban-doning the originalresearch agenda that itco-drafted in 1961,which urged that awide range of experi-ments be conductedinto the safety andwholesomeness ofirradiated foods. Theseexperiments, thedrafters wrote, should analyze whetherirradiated foods are toxic or radioactive;whether they could cause cancer or nutri-tional deficiencies; or whether the scientificexpertise even existed to answer thesefundamental questions. Most of the itemson this research agenda were not followedup in key WHO reports.

! The WHO has ceded an inordinateamount of authority to the InternationalAtomic Energy Agency, going so far as tohand the IAEA the ultimate power toresearch the safety of irradiated foods. TheIAEA – whose mission is preserving thenuclear industry, not the health of people –

has exercised this power to a significantextent. The IAEA has published 19 of the29 major international reports on foodirradiation since 1962, and all but four ofthe reports issued during the formativeperiod from 1973 to 1993. These laterreports led to the proclamation that anyfood could safely be irradiated at any dose.

! With the WHO assuming a backseatrole, the IAEA is leading a campaign tofurther the legalization, commercializationand consumer acceptance of irradiatedfoods worldwide. Toward accomplishingthis goal, the IAEA has published all eightof the major international reports related to

these issues. OneIAEA publicationstates: “We mustconfer with experts inthe various fields ofadvertising andpsychology to put thepublic at ease… Anyword or statementcontaining the word‘radiation’ or‘radiate’…will causethe product to beavoided…and shouldnot be required on the

label.”8

! The WHO has played a role indismissing and misrepresenting evidencesuggesting that irradiated foods may not besafe for human consumption. The WHO,along with the IAEA and the UnitedNations’ Food and Agriculture Organiza-tion (FAO), took research that revealedhealth problems in animals that ate irradi-ated foods, and stated that the researchactually revealed no health problems thatcould be attributed to irradiation. More-over, some research that the WHO, IAEAand FAO initially claimed yielded adverse

The WHO hasplayed a role indismissing andmisrepresenting

evidence suggestingthat irradiated foodsmay not be safe for

human consumption.

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effects were later omitted from key reports.! The WHO has played a role in

dismissing recent evidence that chemicalbyproducts formed in irradiated foods –cyclobutanones – promoted the cancer-forming process in rats, caused the devel-opment of tumors and lesions in rats, andcaused genetic damage in rats and inhuman cells. Cyclobutanones have neverbeen found to occur naturally in any food.Furthermore, a prominent U.S. Armyresearcher falsely stated in a 1989 IAEApublication that no such unique chemicalshave ever been detected in irradiated foods.Despite efforts to downplay the potentialhazards of cyclobutanones, the EuropeanUnion and the Codex Alimentarius Com-mission (which sets food-safety standardsfor more than 160nations) have delayedproposals to expandfood irradiation. Atthis writing, the EU isconducting a formalinquiry into the poten-tial hazards of cy-clobutanones.

A FULL AIRING OF THESE short-comings and swift actions to remedy themare needed to help ensure that the increas-ing proliferation of irradiated foodsthroughout the world will not endanger thehealth of people who eat these products.

By assuming, in the face of mountingevidence to the contrary, that irradiatedfoods are safe for human consumption, theWorld Health Organization has taken aleap of faith that could threaten the healthof millions of people living in more than50 countries where these products canlegally be sold.

CONTROLLINGTHE SCIENCE

A Solid FoundationON MAY 28, 1959, the Twelfth WorldHealth Assembly agreed that the WorldHealth Organization would cede to theInternational Atomic Energy Agency “theprimary responsibility for encouraging,assisting and coordinating research on, anddevelopment and practical application of,atomic energy for peaceful purposesthroughout the world.”The agreement continues: “Whenevereither organization proposes to initiate aprogram or activity in which the other

organization has ormay have a substantialinterest, the first partyshall consult the otherwith a view to adjust-ing the matter.”Further, the agree-ment states that theWHO and IAEA

“shall keep each other fully informedconcerning all projected activities and allprograms of work which may be of interestto both parties.”9

Few present that day in Geneva couldhave imagined the repercussions this five-page document would have over the futureof food irradiation, a technology then in itsinfancy. As shall be seen, the IAEA’s primedirective – to “accelerate and enlarge thecontribution of atomic energy to peace,health and prosperity throughout theworld” – would come at odds with theWHO’s mission.

The IAEA’s power to have the “pri-mary responsibility” over nuclear research,however, was not apparent at the first

The WHO has taken aleap of faith that couldthreaten the health of

millions of people.

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international meeting the WHO helpedorganize to discuss global food irradiationpolicy – just two years after the WHO/IAEA agreement was signed. For eight daysin Brussels in 1961, 114 delegates from 28countries raised virtually every questionthat would enter the mind of any compe-tent health professional charged withexamining the safety and wholesomenessof irradiated foods.

Though co-sponsored by the IAEAand the United Nations’ Food and Agricul-ture Organization (FAO), the meeting’sfocus was clearly on the health consider-ations of irradiated foods – not on the roleof nuclear interests, nor the role of agricul-tural interests.

The meeting’s 205-page report explores in-depth a wide range offundamental problemsthat the delegatesbelieved must beresolved before recom-mending that irradiatedfoods are safe forhuman consumption(emphasis added):

! The WholesomenessProblem: “By the very nature of radiation,certain changes in the molecular structureof the organic compounds present in foodcan be expected. Evidence of toxicity orsevere nutritional damage would no doubtseriously curtail research into food irradia-tion.”

! The Vitamin Problem: “The fact that[vitamins] are quite [susceptible to radiationdamage], and perhaps more so than othercompounds, is ultimately reflected incertain biological responses observed intest animals. Vitamin loss may be overcomeby supplementation.”

! The Protein Problem: “In addition toeffects of irradiation on the internal chem-istry of the amino acids which make upprotein, irradiation also causes chemicalchanges in protein. More basic chemistry isrequired.”

! The Fat Problem: “Many geneticistsare of the opinion that the mutagenic effectof high-energy irradiation is mainly due to[free radical] action. The mechanism of theultimate damage caused by irradiated fats isunknown. A large amount of fundamentalwork has still to be done before thesequestions can be answered satisfactorily.”

! The Carbohydrate Problem: “Carbohy-drates when irradiated undergo chemical

degradation. Withregard to the possibletoxicity of irradiatedcarbohydrates, it isnecessary to ascertainwhether there are anypossible [indirect]effects involved. Theproblem should in noway be consideredsolved. Obviously itwill be necessary tofind out whether there

may not be some deleterious effects involv-ing a mutation or carcinogenic hazard.”

! The Safety Testing Problem: “Moresophisticated techniques for food toxicol-ogy investigations are needed and severalnewer approaches to the problem areneeded.”

! The Cancer Problem: “Experiments arenot sufficiently advanced to comment oncarcinogenicity.”

! The Induced Radioactivity Problem: “Itwould be advisable to measure the radioac-tivity of irradiated products to ensure thatno radioactive contamination has occurredduring treatment. It is indeed very difficult

Irradiatedcarbohydrates couldhave “deleteriouseffects involving

a mutation orcarcinogenic hazard.” – WHO/IAEA/FAO officials, 1961

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to get the public to accept the fact that aproduct that is highly radioactive afterirradiation becomes harmless a few hourslater.”

! The Indirect Radiation Problem: “The[indirect] effects include mutagenic effectsin plant tissues and a significant drop in thenumber of leukocytes in rats. These effectsshould not be overlooked, and only furtherresearch can clarify their relevance to thewholesomeness problem. [They] may beone link in the chain of events leading tocancer.”10

PARTICIPANTS IN Brussels concludedthat a wide range ofresearch avenuesshould be followedbefore putting theirstamp of approval onirradiated foods,including:

! Further exami-nation of howradiation affectsnutrients and otherfood components;

! The chemical, physical and biologi-cal changes caused by irradiation;

! The wholesomeness of irradiatedfoods; and

! The nutritional adequacy and pos-sible toxicity of irradiated foods by con-ducting long-term animal-feeding studies.11

Overall, the meeting laid a solidfoundation upon which food scientiststhroughout the world could build a credibleresearch program into the wisdom ofallowing people to eat food “treated” withhigh doses of ionizing radiation.

But, as will be seen, WHO, IAEA andFAO irradiation planners soon became lessinterested in health and safety, and moreinterested in politics and commerce.

The FoundationBegins to CrumbleTHREE YEARS LATER, in April 1964,irradiation planners from the WHO, IAEAand FAO re-convened for another eight-daysession, this time in Rome. Though manyof the people who attended the Brusselssession found themselves in the same roomagain, the agenda quickly turned away fromsafety and wholesomeness problems, andtowards the problem of legalizing irradia-tion in countries throughout the world –including many developing countries.

Initiating a trend that continues to thisday, the report thatcame out of themeeting makes littlereference to thesafety and whole-someness problemsinitially raised inBrussels. Instead,the delegates by-passed these discus-sions and shifted thedialogue toward

strategies designed to encourage govern-mental and, ultimately, consumer accep-tance of irradiated foods worldwide.

Accordingly, the meeting report beginsnot by calling for more research into thelikelihood that irradiated foods could causecancer, genetic damage, nutritional defi-ciencies and other health problems dis-cussed in Brussels, but rather by calling for“a common approach to legislation [to]facilitate international acceptance of theprocess.”12

INITIATING ANOTHER TREND thatcontinues to this day, the report states thiscommon approach should be designed to“facilitate international trade in irradiatedfood.”13

In 1964, the dialogueshifted toward strategiesdesigned to encourage

governmental andconsumer acceptanceof irradiated foods.

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Of the nine recommendations madeby what would become known as the JointFAO/IAEA/WHO Expert Committee,none specifically addressed any of thehealth and safety concerns so explicitlyspelled out in Brussels three years earlier.Instead, the recommendations focused onefforts to foster the “acceptance,” “coop-eration” and “exchange of information”among government officials wishing toestablish a foothold for irradiated foods intheir countries.14

In particular, the importance of influ-encing irradiation policy in the UnitedStates was underscored by the fact that twoof the FAO’s four advisors were intimatelyinvolved with foodirradiation research inthe U.S.

One of the advi-sors was EdwardJosephson, who di-rected the U.S. Army’sill-fated food irradia-tion research program.Despite Josephson’srenown, the Armyprogram was so poorlymanaged that in 1968 –even as overseas food supply problemsmounted at the height of the Vietnam War– the U.S. Food and Drug Administrationrevoked the Army’s permit to feed irradi-ated bacon to military personnel.*

Meanwhile, only a few of the manyconcerns raised in Brussels were dealt within Rome. Ironically, because the concerns

that were raised received only tokenattention, even more worries were ex-pressed in these areas.

In the one-page section on nutritionallosses, for example, the report states:

In some countries, relatively fewtypes of food may constitute a criti-cal part of the diet. Consideration ofthe change in nutritional value maybe needed in connection with any pro-posal to irradiate food which may beof particular importance in the dietof infants, children, and old or sickpersons. Before permitting the use ofradiation processing of a specific food

item, the appropri-ate government au-thorities should beaware of these pos-sible effects, and itis desirable thatthey should con-duct controlledsurveys in order toensure that thereare no effects inthe population ingeneral and in vul-

nerable groups.17

THE TWO OTHER PROBLEMS origi-nally raised in Brussels that were discussedin Rome – those dealing with inducedradioactivity in food and the indirecteffects of radiation – also received littleattention in the Rome report and, for thatmatter, they were relegated to the appen-dix. And, like the problem of nutritionalloss, the statements did not comprehen-sively address these concerns.

On the question of food becomingradioactive, the report states “there is apossibility that radioactivity will be induced

* The FDA took this action shortly after previously withheldArmy research revealing premature death, cancer, stuntedgrowth and other health problems in lab animals came tolight, triggering congressional hearings into the affair.15 De-spite this failure, Josephson, now deceased, remained veryactive in the field for the next 35 years. In 2000 he won theFDA’s approval to irradiate eggs, despite presenting no spe-cific toxicological evidence indicating that irradiated eggsare safe to eat.16

On the questionof food becoming

radioactive, irradiationplanners only suggestthat further research“may be made” into

this potential problem.

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in some atoms of the food.” The report,however, only suggests that further re-search “may be made” into this potentialproblem.18

On the question of the indirect effectsof radiation – “radiomimetic” effects – thereport acknowledges experiments thatfound mutations in fruit flies (a commonlyused bellwether of mutagenicity); a de-crease in white blood cell counts in rats;genetic damage in plants; and mutations inbacteria. Mutations of certain strains of E.coli and Salmonella, for example, caused thebacteria to become 14 and 10 times moreresistant to radiation,respectively.19

Initiating anothertrend that continues tothis day, the reportcalls for more researchinto these radiomi-metic effects. But, inone of several leaps offaith, the reportproceeds to equate thelack of information toa lack of concern.

Though acknowl-edging that “more dataconcerning a possiblemutagenic effect are desirable,” irradiationplanners from the WHO, IAEA and FAO“concluded that the evidence available atpresent is insufficient to establish whethersubstances present in irradiated food maybe mutagenic in man and, at present, nosignificant hazard can be foreseen.”20

And, in another of the report’s morenoteworthy contradictions, delegates statein one section that animal toxicity andcarcinogenicity studies can be extrapolatedto humans “with a reasonable degree ofcertainty.” Later in the report, however,

delegates state that genetic damage ob-served in fruit flies “cannot be assumed tooccur in man.”21

THE ISSUE OF EXTRAPOLATION isalso addressed in a brief section on apply-ing wholesomeness data on certain types offood to other types of food. Without citingany scientific research, the report states:“When an irradiated food has been estab-lished as safe for human consumption, itmay be proposed that a closely related foodbe treated under similar conditions andwith the same radiation dose.”22

This statement –among the mostsignificant ever madein the half-century offood irradiationresearch – continuesto have repercussionstoday. In 2000, forexample, the U.S.Food and DrugAdministrationlegalized the irradia-tion of eggs based onno toxicity datawhatsoever derivedfrom irradiated eggs.23

Taken together,the shift in dialogue from safety to accep-tance, the leaps of faith, the discrepanciesand the unsubstantiated claims that grewout of the Rome meeting represent adividing line in the 40-year history ofinternational deliberations on irradiatedfood policy.

Early experiments onthe indirect –

or “radiomimetic” –effects of irradiationfound mutations in

fruit flies, a decreasein white blood cell

counts in rats, geneticdamage in plants, andmutations in bacteria.

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The Brussels AgendaContinues to FadeFIVE YEARS LATER, in April 1969,irradiation planners from the WHO, IAEAand FAO reconvened for five days inGeneva – this time, officially speaking atleast – to address wholesomeness prob-lems.24

Like in Rome, however, the Genevareport contains leaps of faith, discrepanciesand unsubstantiated claims. Though theBrussels meeting was held just eight yearsearlier, most of the fundamental problemsraised at that first meeting had fallen by thewayside.

Of the nine health and wholesomenessissues raised in Brus-sels in 1961, only threewere discussed in the1969 meeting report.Only one issue, deal-ing with toxicitytesting, was discussedat any length. Mean-while, problemsconcerning whole-someness, nutrientdepletion, carcinoge-nicity, and the direct and indirect effects ofradiation were not discussed.

As shall be seen, the 1969 meeting wasthe first of three critical meetings held inGeneva at which WHO, IAEA and FAOofficials asserted the safety and whole-someness of irradiated foods, while failingto discuss a majority of the core issuesraised in 1961 in Brussels. (For a summary,see Table 1, next page. Further discussionfollows.)

In the case of the 1969 meeting,irradiation planners gave their “temporaryacceptance” of irradiation for wheat andpotatoes, pending further research.25 At-

tendees did so despite a lack of discussionin the meeting report to six of the nineissues raised in Brussels – and withoutstating whether these six issues had beenresolved.

Further, attendees gave their approvaldespite acknowledging recent evidence thatcell-damaging and mutation-causing “sub-stances may be formed in radiation-pro-cessed food,” and despite “a paucity ofdata” on cancer- and mutation-causingchemicals that may be present in irradiatedfoods.26

MOREOVER, APPROVAL FORwheat was granted despite a study con-ducted a year earlier in which mice that ate

irradiated wheat flourdied younger, experi-enced a higher deathrate for offspring, andhad more tumors thanmice fed non-irradi-ated flour.27

In another experi-ment, intestinallesions developed inrats fed irradiatedwheat flour. Attendees

cited no rationale in dismissing the lesionsas “probably unrelated to the consumptionof irradiated flour.”28

In yet another experiment, hens fed adiet that included irradiated wheat pro-duced and hatched fewer eggs, and lostmore embryos than hens fed non-irradiatedfood. Though calling these findings “dis-turbing,” and acknowledging “indirectevidence that vitamin D may be de-stroyed,” WHO, IAEA and FAO attendeesendorsed irradiation for wheat.29

Additionally, attendees of the Genevameeting downplayed a contemporaneousreport that explored many potential dangers

By 1969, most of thefundamental problems

raised at the firstmajor conference

in Brussels had fallenby the wayside.

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Table 1

A Dubious RecordHow the Original Food IrradiationResearch Agenda Has Largely Been Ignored

At the first major international conference on food irradiation, held inBrussels in 1961, WHO, IAEA and FAO officials documented nine keyconcerns they felt needed to be addressed before irradiated foods couldbe considered safe for human consumption. Only a few of theseconcerns, however, were addressed at the next three major conferences,held in Geneva in 1969, 1976 and 1980. Irradiation for all foods wasendorsed in 1980, despite the fact that the original research agendawas largely ignored.

Discussion at later conferencesConcerns Raised in 1961 1969 1 1976 2 1980 3Wholesomeness of Irradiated Foods Limited Limited LimitedIrradiation’s Effect on Vitamins None Limited LimitedIrradiation’s Effect on Protein None None NoneIrradiation’s Effect on Fat None None NoneIrradiation’s Effect on Carbohydrates None None NoneTesting for Toxicity Yes Limited NoneLikelihood of Causing Cancer Limited None NoneInduced Radioactivity in Food None None LimitedIndirect Health Effects of Radiation None None None

Key:None: Issue not discussed at conferenceLimited: Issue briefly discussed at conferenceYes: Issue discussed at some length at conference

1 Wholesomeness of Irradiated Food with Special Reference to Wheat Potatoes and Onions. Report of a Joint FAO/IAEA/WHO Expert Committee, Geneva, 8-12 April 1969. World Health Organization Technical ReportSeries No. 451. Geneva: World Health Organization, 1970.

2 Wholesomeness of Irradiated Food. Report of a Joint FAO/IAEA/WHO Expert Committee, Geneva, 31August - 7 September 1976. World Health Organization Technical Report Series No. 604. Geneva: WorldHealth Organization, 1977.

3 Wholesomeness of Irradiated Food. Report of a Joint FAO/IAEA/WHO Expert Committee, Geneva, 27October - 3 November 1980. World Health Organization Technical Report Series No. 659. Geneva:World Health Organization, 1981.

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of irradiated foods. Published in the WorldHealth Organization’s official journal twoyears before the 1969 meeting, the 32-pagereport describes in great detail the mu-tagenic and cytotoxic effects of irradiatedfoods.

The report was written by a Universityof Pittsburgh radiation chemistry professorworking under a grant from the U.S. AtomicEnergy Commission.30 To date, the reportstands as perhaps the most comprehensiveanalysis of the health problems associatedwith irradiated foods ever published in theEnglish language.

In its report from the 1969 Genevameeting, the WHOreduced the professor’sfindings to four sen-tences – disregardinghis recommendationsfor further research,and ignoring his fearsof another thalido-mide-type disaster.31

(During the late 1950sand early 1960s,thousands of womenin Europe and Canadawho took the sleepingpill thalidomide lost their babies or gavebirth to children with missing limbs, disfig-urement, blindness and other major healthproblems.)

Drifting Further AfieldWITH THE PRECEDENT-SETTINGapprovals from the 1969 Geneva meetingin hand, irradiation planners redirectedtheir attention away from making sure thatirradiated food is safe to eat, to makingsure that governments would legalize it,that corporations would sell it, and thatpeople would eat it.

As a result of seven major conferencesheld in Europe between 1972 and 1980,WHO, IAEA and FAO officials concludedthat people could safely eat food “treated”with a radiation dose of 1 million rads (or10 kiloGray)32 – the equivalent of 330million chest x-rays, a dose far beyond whatthe U.S. Food and Drug Administration hadever considered at that time.

Of those seven major conferences,however, only two dealt primarily with thesafety and wholesomeness of irradiatedfoods. Moreover, the reports from thosetwo conferences totaled 78 pages, only 16of which dealt specifically with analyzingtoxicity issues.33,34 The other five confer-

ences dealt primarilywith issues related toefficacy, legalization,commercialization andacceptance.

The first of thetwo FAO/IAEA/WHO conferencesthat dealt primarilywith safety andwholesomeness issueswas held in Geneva in1976.35 The meeting

report fails to discuss six of the nine coreissues raised in Brussels in 1961. (See Table1, page 19.) And though numerous knownand potential safety and wholesomenessproblems were cited in the report, irradia-tion planners endorsed irradiation for eightcommon foods, including rice, wheat,potatoes, onions and chicken.

For starters, there was no discussionabout the two most unsettling prospects ofexposing food to high doses of ionizingradiation: the likelihood that food willbecome radioactive, and the potentialindirect (“radiomimetic”) effects of irradia-tion.

The WHO ignored areport – published in

its own journal –describing in great

detail the mutagenicand cytotoxic effects of

irradiated foods.

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Like other FAO/IAEA/WHO docu-ments, this report contains leaps of faith,discrepancies and unsubstantiated claims.

Attendees stated, for instance, that it“appears” the chemicals formed by irradia-tion (“radiolytic products”) “do not poseany toxicological hazards in the concentra-tions at which they have been detected.”Yet, they wrote that “it is not yet possibleto give an assurance that all radiolyticproducts having possible toxicity have beenidentified.” They also said that “thereremains the possibility that more subtlelong-term effects (e.g. carcinogenesis,mutagenesis) may occur.”36

In addition,attendees said –without citing anyevidence – that irradia-tion would not cause“any significantdeficiency in nutri-tional quality.” Yet,they acknowledged “itwill be necessary toensure that there is nocumulation [sic]” ofnutrient loss.37

PERHAPS MOST DISTURBINGLY,WHO, IAEA and FAO representativesgave their approval of irradiation for eightcommon types of food – wheat, potatoes,onions, chicken, rice, strawberries, cod andpapayas – in the face of a still growingbody of evidence suggesting that irradiatedfoods may not be safe to eat. Specifically,attendees cited studies showing that:

! A genetic aberration called polyp-loidy, which increases the number ofchromosomes in a cell, developed inseveral animal species fed irradiated wheat.

! Genetic damage developed in micefed irradiated potatoes;

! Ovary sizes changed in rodents fedirradiated potatoes; and

! Poison-producing fungi could formon irradiated potatoes that are improperlystored.38

OVERALL, THE REPORT’S four-pagediscussion about the problems of toxicityand nutrient loss fails to mention a singleexperiment in the course of dismissing anyneed for worry. In both cases, irradiationplanners blamed a lack of information, butstated nonetheless that they did not antici-pate any serious problems.39

The report did recommend furtherresearch into thechemicals formed byirradiation, toxicityand nutrient loss. But,as shall be seen, futureconferences andreports consistentlydismissed or, in somecases, misrepresentedexperimental findingsthat question thesafety and whole-someness of irradiatedfoods.

It is worth noting that this break-through decision by the FAO/IAEA/WHOcommittee to endorse irradiation for eightfood types was based largely on researchconducted by the International Project inthe Field of Food Irradiation in Karlsruhe,Germany.40 The program was established bythe IAEA, and funded by the IAEA andU.S. Department of Energy, a federalgovernment agency that oversees keyaspects of the U.S. nuclear bomb program.41

It is also worth noting that althoughmost of the eight foods types could notlegally be irradiated in the United States atthe time, the meeting was chaired by FDA

In 1976, the WHO,IAEA and FAO

endorsed irradiationfor eight types of fooddespite acknowledging

the possibility ofcancer and mutations.

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WHO, IAEA and FAOofficials falselystated in 1980:

“All the toxicologicalstudies have producedno evidence of adverse

effects as a resultof irradiation.”

Toxicology Director Hubert Blumenthal,for many years a key figure in setting U.S.food irradiation policy, and a member ofthe FAO/IAEA/WHO committeethroughout the 1970s.42

These two relationships are indicativeof the central role that U.S. governmentofficials and scientists have played in thecourse of endorsing higher irradiationlevels for more types of food.

The Final StepFOUR YEARS LATER, in 1980, WHO,IAEA and FAO representatives were backin Geneva for whatwould become per-haps the single mostimportant meeting inthe 40-year history ofinternational delibera-tions over foodirradiation policy.

Attendees of theweek-long gatheringreached an extraordi-nary decision thatcontinues to shape –and likely will con-tinue to shape for many years to come –not just the regulation and sale of irradi-ated foods in dozens of industrialized anddeveloping countries, but, as economicstructures become increasingly global,throughout the entire world.

Irradiation planners concluded that anyfood could be irradiated at doses up to 10kiloGray43 – the equivalent of 330 millionchest x-rays – without posing a healthhazards to people who eat it. As had beenthe case in prior meetings – and would bethe case in future meetings – this decisionwas reached through leaps of faith, discrep-ancies and unsubstantiated claims.

And, as was the case with the 1969and 1976 meetings, six of the nine coreissues raised in Brussels in 1961 were notdiscussed in the meeting report. (See Table1, page 19.) Most conspicuously, there is nodiscussion about methods to test the safetyand wholesomeness of irradiated foods –perhaps the most fundamental problem thatWHO, IAEA and FAO officials themselvessaid in 1961 needed resolution beforefurther endorsements could be handeddown.

OF THE THREE ISSUES THATwere discussed at the 1980 meeting, thequestion of wholesomeness was handled in

particularly question-able fashion.

First, attendees stated:“All the toxicologicalstudies…have pro-duced no evidence ofadverse effects as aresult of irradiation.”44

This directly contra-dicts the report fromthe 1976 meeting,which referencesstudies in whichchromosomal aberra-

tions developed in several animal speciesfed irradiated wheat, and genetic damagedeveloped in mice fed irradiated potatoextracts.45

Furthermore, numerous studies con-ducted over a more than 20-year periodbefore the 1980 meeting revealed healthproblems in animals that ate irradiatedfoods. Some of these experiments wereperformed by the U.S. Army, which wassearching for ways to preserve food des-tined for Vietnam and elsewhere. Amongmany health problems, rats died youngerand suffered a reduction in live births; dogs

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and mice gained less weight; dogs and ratshad lower red blood cell counts; and ratsdeveloped more malignant tumors (includ-ing pituitary cancer) than animals fed non-irradiated food.46

Second,seeking to dispensewith a problem thatremains unresolvedto this day, attend-ees stated thatradiolytic productsformed in irradi-ated food “do notappear to pose anytoxicologicalhazards in theconcentrations atwhich they weredetected.” Thisconclusion was reached primarily on thebasis of “unpublished observations.” Themeeting report does not state where, whenor under what conditions these observa-tions were made.47

And, the meeting report does notdiscuss in detail and makes no reference toany published research concerning thepotential toxicity of radiolytic products,despite three recommendations to do somade at the 1976 meeting.48

Thirdly, and perhaps most significantly,representatives from the WHO, IAEA andFAO endorsed irradiation doses of up to 10kiloGray for any food, even though thesafety and wholesomeness of only eightindividual types of irradiated food werespecifically analyzed.

Further, the recommended maximumirradiation doses for 7 of these 8 individualfood types, ranging from 0.15 kiloGray to 5kiloGray, were far below the 10 kiloGraylevel that attendees endorsed for all foods.And, irradiation doses of at least

10 kiloGray were used in experiments foronly 5 of these 8 types of food.49

Despite these shortcomings, attendeesstated in closing: “The irradiation of any

food commodityup to an overallaverage dose of 10kGy presents notoxicologicalhazard; hence,toxicologicaltesting of foods sotreated is no longerrequired.”50

As shall beseen, WHO, IAEAand FAO officialsdid not waver fromthis declaration,

despite an ever-expanding body of evi-dence that continues to throw into questionthe safety and wholesomeness of irradiatedfoods.

CONTROLLINGTHE INFORMATION

‘Shaping Public Opinion’THE SUPERFICIAL TREATMENT oftoxicity issues in the 1976 and 1980 meet-ing reports brings into sharp focus the driftfrom the core safety and wholesomenessissues raised in Brussels 20 years earlier.

Instead of analyzing whether irradiatedfoods are safe, wholesome and nutritious,the WHO, IAEA and FAO by the end ofthe 1980s had shifted almost completely tostudying how they could persuade morecountries to legalize irradiated food, morecorporations to sell it, and more peoplearound the world to eat it.

In U.S. Army experiments,rats died younger andsuffered a reduction in

live births; dogs and micegained less weight; dogsand rats had lower redblood cell counts; andrats developed moremalignant tumors.

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As will be seen, the responsibility forthe abbreviation of the process of assess-ing the safety and wholesomeness ofirradiated foods lies with the InternationalAtomic Energy Agency. And the responsi-bility for allowing this to happen lies withthe World Health Organization.

Eight of the 12 major internationalconferences between 1972 and 1988 dealtprimarily not with safety or wholesome-ness, but legalization, commercialization,trade, information control and consumeracceptance. The official reports of all eightmeetings were pub-lished by the IAEA.

ABOVE ALL,GETTING govern-ment officials andcorporate executiveson the same pageregarding these keyissues – particularly indeveloping nationswhere internationaltrade potential wasseen as the greatest –was, and remainstoday, the primedirective.

Accordingly, thistransition cannot fully be understoodwithout reviewing concurrent efforts byWHO, IAEA and FAO – led by the IAEA– to go one step further: To persuadepeople throughout the world that theyshould eat these products.

The first major meeting on acceptanceissues was held in Bombay in November1972. Irradiation planners came from farand wide: Bangladesh, Egypt, Indonesia,Iran, Iraq, Mexico, Nigeria, the Philippines,Thailand and Venezuela, as well as the hostcountry of India. Standard-bearers Austria,

France, Germany, Japan and the UnitedStates were also represented.51

In summarizing the challenges facingthe global food irradiation movement,attendees placed information control at thetop of the list. This established a trend thatwould continue for the next three decades– a trend that directed the debate not onlybeyond safety and wholesomeness issues,but even beyond the questions of effective-ness and economic viability.

Accordingly, this trend served tomarginalize theWHO and its role asthe world’s leadingpromoter of health,while elevating therole of the IAEA, theworld’s leadingpromoter of nucleartechnology.

Of the 11problems and solu-tions listed by attend-ees of the Bombaymeeting, six dealtexclusively or signifi-cantly with informa-tion control. Speak-ing with an unusualdegree of frankness,

they said:! “Some of the most primitive suspi-

cions about irradiated foods still prevaileven in certain otherwise educated circleswho, e.g. believe that irradiated foodcontains radioactive material. In manycountries, public opinion still associatestreatment with ionizing radiation with theatom bomb.”

! “It is especially important to providecorrect information to all those responsiblefor shaping public opinion, like journalists,science writers,…research councils, univer-

Eight of the 12conferences held

between 1972 and 1988dealt primarily

not with safety orwholesomeness, but

with legalization,commercialization,trade, information

control andconsumer acceptance.

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sities, etc.”! “In view of the great deficiency in

correct information about food irradiation,major efforts should be made to providethe public with factual information. Im-proving the education of the general publicshould start at school.”52

‘Facilitate the InternationalMovement of Irradiated Food’FIVE YEARS LATER, in 1977, irradiationplanners met in the Netherlands to brain-storm ways to encourage more countries tolegalize irradiation for the widest variety offoods possible.53 At this meeting, the CodexAlimentariusCommissionwas discussed atlength for thefirst time.Codex, a jointprogram of theFAO and WHObased in Rome,was created in1963 to set foodsafety standardsfor most of theworld’s coun-tries.

Though not legally binding at the time,Codex standards became de facto regulationsfor many countries that lacked the re-sources and expertise to establish regula-tions of their own. As a natural extensionof this, Western nations were largelyresponsible for proposing and approvingCodex standards, which were then adoptedby developing nations.

With this framework in place, leadersof the global food irradiation movement –mainly those from Canada, Germany, the

United States and other Western countries– sought to utilize the Codex system tocreate global irradiation standards in theirimage. This strategy – which has beenadopted by many other international, quasi-governmental agencies – has becomeknown as “harmonization.”

The pipeline was ready-made: TheFAO and WHO oversee Codex, and theagencies hold two of the three seats aboardthe Joint FAO/IAEA/WHO ExpertCommittee on food irradiation. (Today,Codex standards are enforceable by theWorld Trade Organization, thus intensify-ing efforts to harmonize irradiation andhundreds of other food safety standards.)

IT IS PER-HAPS BE-CAUSE ofthese intimaterelationshipsthat discussionswere brief andto the point.The report fromthe 1977meeting states:“Harmonizationof nationallegislation andregulatory

procedures will enhance confidence amongtrading nations... It is obviously importantfor the relevant national regulations gov-erning food irradiation to beharmonized…as to facilitate the interna-tional movement of irradiated food.”54

With discussions of trade and legalissues well underway, attention was turnedto perhaps the biggest challenge of all:public relations.

Leaders of the global foodirradiation movement –

mainly those from Canada,Germany, the United States

and other Western countries –sought to utilize the Codex

system to create globalirradiation standards

in their image.

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‘Develop a More FriendlyFeeling to Irradiation’IN 1982 – JUST TWO YEARS after anFAO/IAEA/WHO panel concluded thatirradiated foods are safe to eat – the IAEAturned away from health issues and towardthe problem of public relations. To lendassistance, the IAEA hired consultants tocraft a strategy to enhance the image ofirradiated foods in the minds of consumersworldwide.

The meeting at which the consultants’findings were presented – “Marketing andConsumer Acceptance of Irradiated Foods”– was attended by aselect group of 15leaders of the globalfood irradiationmovement.

Unlike mostprevious meetings, thisgathering was not ajoint effort of theWHO, IAEA andFAO. It was organizedby an IAEA divisionspecifically created tofind “applications ofatomic energy for foodand agricultural development.”55

Held in the IAEA’s home city ofVienna, the five-day meeting featured someof the most frank and revealing discussionsever published about marketing strategiesdesigned to enhance the image and expandsales of irradiated foods.

Quoting from the report:“Any word or statement containing the

word ‘radiation’ or ‘radiate’ would inspirefear of a nonexistent danger…and there-fore will cause the product to be avoided.The consultant group does not recommend

that the label carry a statement of theprocess.” (Emphasis in original.)

Efforts to find substitute words for“irradiated” resulted in some comicalsuggestions, including “processed withelectrons” and “gammatized.”

In any event, the consultants recom-mended that “identification of the processshould not be required on the label.”(Emphasis in original.)56

WITH UNUSUAL CANDIDNESS, one ofthe presenters, an executive with a largeSouth African retailer, talked extensively

about the difficulttask of resuscitatingthe image of nucleartechnology:

We have to knowand understand theordinary people…We must conferwith experts in thevarious fields ofadvertising and psy-chology to put thepublic at ease, anddevelop a morefriendly feeling to

irradiation. Symbols, if they must beused, must be developed not to looklike radiation symbols. Names of theprocess must be simple and not nec-essarily related to the words irradia-tion or radiation… We start from atotally negative situation becausenothing has threatened mankind socompletely as total destructionthrough nuclear holocaust… There-fore, it is difficult for the ordinary per-son to accept that anything that is as-sociated with radiation, even indi-rectly, is not going to cause terrible

“Any word orstatement containing

the word ‘radiation’ or‘radiate’ would inspirefear of a nonexistentdanger and thereforewill cause the product

to be avoided.” – IAEA consultants, 1982

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death or disaster.57 *

Another presenter at the IAEA meet-ing suggested that marketing campaigns forirradiated foods resemble those for low-calorie soft drinks and decaffeinatedcoffee.63

The IAEA’s consultants drafted anelaborate marketing plan listing a widevariety of “target groups”: health authori-ties; government agriculture, commerce andconsumer affairs officials; food industryexecutives; food retailers; caterers; educa-tional broadcastchannels; the massmedia; and consum-ers. In most cases,the “appropriatebody to deliver themessage effectively”was listed as govern-ment officials orgovernment-ap-pointed organiza-tions.64

Many of the“messages” listed byIAEA’s consultantswere unsubstantiatedor overstated, includ-ing statements thatirradiation:

! “improves quality;”! “retains original taste, aroma, colour

and texture [of food] for longer periods;”! “reduces dependency on chemicals;”

and! results in “savings in cost.”65

THE PARTICIPANTS INCLUDEDseveral of the most influential members ofthe international food irradiation move-ment. Among them:

! Edward Josephson (chair) – formerdirector of the U.S. Army’s food irradiationprogram in Natick, Massachusetts.

! Jan Leemhorst – a high-rankingofficer with the Association of Interna-tional Industrial Irradiators. Leemhorst, ofthe Netherlands, later became a delegate tothe International Consultative Group onFood Irradiation, which has consistently

dismissed evidencequestioning the safetyand wholesomenessof irradiated foods.

! Jacek Sivinski –engineering consultantwith CH2M Hill,66 aprominent energy,nuclear technology,telecommunications,water, transportationand manufacturingcompany located inColorado. The firm,often the recipient ofgovernment contracts,was hired by the U.S.government in the

1980s to find creative uses for huge stock-piles of highly radioactive cesium-137generated by the production of nuclearweapons. Along with food, the firm alsosuggested irradiating sewage sludge andusing it as fertilizer, and as feed for cattleand sheep. 67 *

“We have to knowand understand the

ordinary people.We must confer withexperts in the various

fields of advertising andpsychology to put the

public at ease, anddevelop a more friendlyfeeling to irradiation.”– presenter, 1982 IAEA conference

* Ironically, five years earlier, the U.S. Nuclear RegulatoryCommission suspended a New Jersey irradiation company’slicense after a worker received a near-fatal radiation dosewhen a safety device failed. The company’s president wasconvicted of conspiracy and making false statements to theNRC, and sentenced to federal prison.58,59,60,61,62)

* Speaking to Congress in 1984 about the possibility ofselling Americans on the cesium program, Sivinski said: “Thosepeople on Madison Avenue have us buying most of thethings that we can afford, and many things that we can’t.”68

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‘All Available MethodsShould Be Exploited’THREE YEARS LATER, in 1985, arobustly attended FAO/IAEA meeting inWashington, DC, entitled “Food IrradiationProcessing” was dominated not by discus-sions of food safety or consumer benefits,but by strategizing ways to speed the“commercial introduction of the foodirradiation process.”

The final panel of the meeting –“Implementation of the Food IrradiationProcess” – was not chaired by a govern-ment official, a food industry representativeor a food safety expert, but by Sivinski ofCH2M Hill.69

Among thepanel’s conclusions:“Acceptance of theconcept of foodirradiation by theconsumer [is] recog-nized as being anessential prerequisiteto the introductionof the process. Allavailable methods ofachieving thisobjective should be exploited; the produc-tion of both written and audio-visualmaterial by international agencies, govern-ments, and representatives of industryshould be encouraged.”70

Retaining their focus on consumeracceptance, WHO, IAEA and FAO offi-cials convened in France in 1988 to discuss– again – not safety and wholesomeness,but “public information on food irradia-tion.”71 The meeting was co-chaired byJohannes Diehl, former director of theIAEA-funded International Project in theField of Food Irradiation in Karlsruhe,Germany, which had conducted food

irradiation experiments that the FDA laterrejected as scientifically inadequate.72

By this point, the problem of con-sumer acceptance loomed so large thatquestions about safety and wholesomeness– even questions about whether the processworked or made economic sense – all butdisappeared from the agendas of irradiationplanners. The big problem was not what,where, why and how foods were beingirradiated, but what consumers thoughtabout eating these products.

“Why are foods with such scientificallyproven health benefits not available toconsumers?” attendees asked in their

report. “Becausemuch of the informa-tion made available isneither accurate norcomplete.” Todistribute this infor-mation, attendeessuggested producinga television docu-mentary for broad-cast throughout theworld, and publishingan international

newsletter “with the broadest possiblecirculation.”73

ON CLOSER INSPECTION, Diehl andthe other meeting planners did not live upto their own standards for distributing“accurate and complete” information. Themeeting report dismisses concerns aboutinduced radioactivity, chemical changes,toxicity, nutritional deficiency, mutantmicroorganisms and radioactive hazardswithout citing any scientific research tosupport these conclusions.74

Further, as will be discussed later (seepage 35-36), the report falsely states that in“more than 25 years” of research, “no

Key participants of a1982 conference

included a consultantwho wanted to irradiatesewage sludge and use itas fertilizer and feed for

cattle and sheep.

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compound has ever been identified in anirradiated food which is unique to theradiation process.”75 In reality, chemicalscalled cyclobutanones, which have neverbeen found to occur naturally in any food,were discovered 17 years earlier.

Later that year, in December inGeneva, the WHO, IAEA and FAO orga-nized a meeting – once again – that dealtnot with safety and wholesomeness, but“acceptance, control and trade of irradiatedfood.” 76

A provision of the “InternationalDocument on Food Irradiation,” a list ofguiding principles that attendees adoptedby consensus atthe end of themeeting, summa-rized 16 yearsworth of brain-storming for waysto distributeirradiated foodsthroughout theworld: “Accep-tance of irradi-ated food by theconsumer is avital factor in thesuccessful com-mercialization of the irradiation process,and information dissemination can contrib-ute to this acceptance.”77

The importance of an orchestratedpublic relations campaign was crystallizedby one of the keynote speakers, a con-sumer affairs official with the Australiangovernment, who attributed the lack ofpublic acceptance of irradiated food to“hysteria and emotionalism.” The officialsuggested that the consumer movementhad been “hijacked” by the “lunaticfringe.”78

The Australian government officialcontinued: “For the first time that I canremember, I see consumer organizationslosing control over their direction and beingled by individuals who have embarked onan anti-food irradiation campaign that hasno room for logic or rationality.”79

DismissingConsumer ConcernsIT WAS AT THIS SAME CONFERENCEin Geneva in December 1988 where theWHO attempted to quiet what littleorganized opposition there was at the time

to food irradia-tion. The WHOwent so far as topublish a 12-page response toa wide range ofconcerns raisedby the Interna-tional Organiza-tion of Consum-ers Union(IOCU).80 Likeseveral previousreports publishedor co-published

by the WHO, this document has numerousshortcomings.

First, of the nine points of contentionthat IOCU raised, the WHO failed tocompletely address two of the most signifi-cant issues: experiments that found healthproblems in animals that ate irradiatedfoods, and the related problems of residualcontamination in irradiated foods and theoverdependence on irradiation as a solutionto food-borne illness.

On the issue of animal experiments,the WHO did not respond to findings of

An Australian governmentofficial attributed the lack

of public acceptance to“hysteria and emotionalism,”

and said the consumermovement had been

“hijacked” by the“lunatic fringe.”

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genetic damage, reproductive problems,tumors, weakened immune systems,stunted growth and kidney damage.81

On the issue of contamination, theWHO did not respond to questions dealingwith quality standards for foods prior toirradiation; storage and handling of foodsafter irradiation; and training for publichealth, food safety and enforcement offi-cials charged with assuring the wholesome-ness of irradiated foods.82

IN ADDITION, THE WHO’s response:! Dismisses concerns over the chemi-

cal byproducts formed in irradiated foodswithout addressingconcerns raised 12years earlier at theFAO/IAEA/WHO meeting inGeneva, at whichattendees statedthat “it is not yetpossible to give anassurance that allradiolytic productshaving possibletoxicity have beenidentified.”83

! Dismisses concerns over the irradia-tion of residual pesticides, food additivesand contaminants without citing anyevidence; and

! States incorrectly that nutrientdestruction caused by irradiation is “insig-nificant.”84

Going GlobalARRIVING AT A COHESIVE strategydesigned to enhance the legalization,commercialization and consumer accep-tance of irradiated foods took 16 years –from the first major meeting in Bombay in

1972 to the 1988 meeting in Geneva.Meanwhile, the most important decision toendorse the safety and wholesomeness ofirradiated foods took only three yearslonger – from the 1961 Brussels meeting tothe 1980 Geneva meeting.

The disproportionate emphasis onexpanding the proliferation of irradiatedfood, versus assessing its safety and whole-someness, widened in the years to come.From 1985 to 1998, legalization andcommercialization dominated the discus-sions at a series of eight meetings. Mean-while, only four meetings dealing withsafety and wholesomeness were held during

that 13-yearperiod.

Initiating atrend that contin-ues to this day,most of thesemeetings onlegalization andcommercializationfocused onpromoting irradi-ated foods indevelopingnations, particu-

larly those in Asia:! At perhaps the most significant

meeting of the eight, irradiation plannersfrom the WHO, IAEA and FAO gatheredin Marseille, France in 1995 to discuss howrecent changes to the General Agreementon Tariffs and Trade (GATT) could beexploited to expand trade in irradiatedfoods. Specifically, new GATT provisionson Sanitary and Phytosanitary Measures(SPS) and Technical Barriers to Trade(TBT) were featured on the agenda. Be-cause SPS and TBT are designed to liberal-ize trade by harmonizing food-safetystandards worldwide, and by banning

The WHO did not addressconsumer concerns that

animals fed irradiated foodsuffered genetic damage,reproductive problems,

tumors, hampered immuneresponse, stunted growthrates and kidney damage.

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import restrictions not supported by “scien-tific evidence,” attendees agreed thatnational regulations should be harmonized“urgently.” Also at the meeting, an “Indus-try Working Group” was formed to expandthe proliferation of irradiated foods world-wide. Members include executives fromtwo of the world’s largest irradiationcompanies, GAMMASTER of the Nether-lands and MDS Nordion of Canada.85

! In 1992, five meetings in Asiancountries were sponsored by the IAEA andthe United Nations DevelopmentProgramme – with noofficial participationby the FAO or WHO.Among the meetings:

- In the Philip-pines, it was recom-mended that irradia-tion be reclassifiedfrom an “additive” toa “process,” and thatthis be accomplishedadministrativelyinstead of legisla-tively to avoid a“protracted and unpredictable” procedure.It was also recommended that the “globaltrend” to broaden the production ofirradiated foods necessitates a “harmoniz-ing and implementing” of laws and regula-tions worldwide.86

- In South Korea, it was recommendedthat the country “permit the irradiation ofall dry spices/seasonings.”87

- In Sri Lanka, it was recommendedthat the country “expedite” the opening ofan irradiation facility using radioactivecobalt-60. Draft food irradiation legislationwas also presented.88

! At a 1985 meeting in Bangkok co-sponsored by the Association of Southeast

Asian Nations (ASEAN), the openingaddress was given by the deputy primeminister of Thailand, who remarked thathis country “has taken an important step toexplore the possibility of commercializa-tion” of irradiated foods.89

THE FACT THAT DISCUSSING the saleof irradiated foods has consumed nearly asmuch time and energy as analyzing thesafety and wholesomeness of these prod-ucts, if not more, is indicative of delibera-tions that have been dominated bystrategizing ways to commercialize irradi-

ated foods at theexpense of analyzingwhether they are safeto eat.

The prime moverof this shift has beenthe InternationalAtomic EnergyAgency.

For the past 40years, the IAEA hasbeen the main orga-nizer of internationaland regional confer-

ences on all aspects of food irradiation,including legalization, commercialization,trade, information control and consumeracceptance; published or co-publishednearly all of the key reports on food irradia-tion; and, perhaps most importantly, theIAEA has become the overseer of scien-tific research on irradiated foods via its1959 agreement with the WHO.

With this much power and influence atits disposal, the IAEA has, to a largeextent, shaped the international debate onfood irradiation – a debate that over thepast 20 years has been driven as much, ifnot more, by economic interests thanhealth considerations.

The disproportionateemphasis on expanding

the proliferation ofirradiated foods, versus

assessing its safetyand wholesomeness,

widened in theyears to come.

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CONTROLLINGTHE FUTURE

Another Disturbing TrendAT A TIME WHEN THE IAEA’s effortsto further the acceptance of irradiatedfoods was reaching its peak, the WorldHealth Organization’s final analysis of thesafety and wholesomeness of irradiatedfoods was also reaching a climax.

This analysis was spelled out in WHOreports published in 1994, 1995 and 1999.These three lengthyreports lay thefoundation for anongoing effort toallow any food grownvirtually anywhere inthe world to beirradiated at any dose– no matter howhigh. Each of thesereports cataloguesmore than 100experiments dating tothe 1950s thatassessed the safety ofirradiated foods.

As unsettling asit may seem, a close review of these threereports reveals an effort to dismiss andmisrepresent evidence suggesting thatirradiated foods are not safe for humanconsumption.

Instead of presenting experimentalfindings in a consistent fashion from onereport to the next, research that the agen-cies initially claimed yielded adverse effectsin lab animals were later said to be “nega-tive.”

In other words, the agencies tookresearch that revealed health problems in

lab animals that ate irradiated foods, andstated that the research actually revealedno health problems that could be attributedto irradiation.

Moreover, some studies that theagencies initially claimed yielded adverseeffects were not mentioned later.

In 1994, the WHO published a reportentitled Safety and Nutritional Adequacy ofIrradiated Food. The report stemmed froman FAO/IAEA/WHO meeting held inGeneva two years earlier. The documentlists about 150 studies conducted on the

safety of irradiatedfoods, including thoseinvolving monkeys,dogs, rabbits, pigs,hamsters, mice, ratsand fruit flies. Amongthese studies, thereport lists a widerange of adversehealth effects.90

In the 1994report, 11 studiesclassified as yieldingadverse effects91 werere-classified asnegative in an FAO/IAEA/WHO report

published in 1999, High-Dose Irradiation ofFood.92 Among these studies, the 1994report lists a wide range of adverse healtheffects in animals that ate irradiated foods,including birth defects and genetic damage;fatal internal bleeding and other blooddisorders; fewer offspring; stunted growthand weight gain; and liver malfunction.93

Additionally, 19 studies that the 1994report classifies as yielding adverse effects 94

were not listed at all in an FAO/IAEA/WHO report published in 1995, Review ofHigh-Dose Irradiation of Food.95 Among thesestudies, the 1994 report lists a wide range

The WHO, IAEA andFAO took research that

revealed healthproblems in animalsthat ate irradiated

foods, and stated thatthe research actuallyrevealed no health

problems that could beattributed to irradiation.

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Table 2

Scientific Shell GameHow Research Questioning the Safety of Irradiated FoodsFell by the Wayside

In 1994, 1995 and 1999, the WHO published the three most importantdocuments since international deliberations over food irradiation policybegan in 1961.1,2,3 These documents culminated in a significantendorsement: that any food could be irradiated at any dose, no matterhow high. The agencies arrived at this decision after taking researchthat revealed health problems in animals that ate irradiated foods, andstating that the research actually revealed no health problems thatcould be attributed to irradiation. In addition to reclassifying studiesthat found “adverse effects” as “negative,” many studies that foundnegative effects were not mentioned later. These discrepancies occurred52 times. (See discussion, p. 32, 34-35.)

Studies Finding Adverse Effects in 1994Reclassified as Negative in 1999 ............................................. 11

Studies Finding Adverse Effects 1994Not Listed in 1995 .................................................................19

Studies Finding Adverse Effects 1994Reclassified as Negative in 1995 .............................................. 1

Studies Finding Adverse Effects in 1995Reclassified as Negative in 1999 ............................................. 21

Total Discrepancies ...............................................................52

1 Safety and Nutritional Adequacy of Irradiated Food. Geneva: World Health Organization, 1994.2 Review of Data on High Dose (10-70 kGy) Irradiation of Food. Report of a Consulation, Karlsruhe, Germany,

29 August - 2 September 1994. Geneva: World Health Organization, 1995.3 High-Dose Irradiation: Wholesomeness of Food Irradiated with Doses Above 10 kGy. Report of a Joint FAO/

IAEA/WHO Study Group, Geneva, 15-20 September 1997. Geneva: World Health Organization, 1999.

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of adverse health effects in animals that ateirradiated foods, including tumors, muta-tions and chromosome damage, stuntedgrowth, liver and thyroid malfunction, ablood disorder, prolonged estrous cycles,and atrophied testicles.96

And, one study that the 1994 reportclassifies as yielding an adverse effect –stunted growth in rats fed irradiated or-anges for five months97 – was re-classifiedin the 1995 report as having no adverseeffects.98

NONE OF THE DISCREPANCIESbetween the 1994 report and 1995 reportare specifically explained in the latter. Theonly reference in the1995 report to theissue of interpreta-tion of studies statesthat adverse effectsattributable toirradiated foods“were sometimes notshared by otherobservers or were notconfirmed by laterwork.”99 There is noexplanation in the1995 report of the omission of 19 studiesand the re-classification of another.

The discrepancies between the 1995report and the 1999 report are just astroubling, if not more. In the 1995 report,21 studies that yielded adverse effects100

were re-classified as negative in the 1999report.101 Again, these studies revealed awide range of health problems in animalsthat ate irradiated foods, including in-creased mortality; fatal internal bleedingand other blood problems; decreasedfertility and other reproductive problems;lower white blood cell counts; mutationsand other genetic damage; liver malfunc-

tion; and stunted growth.102

All told, there are 52 discrepancies inthese three WHO reports in which studiesthat yielded adverse effects were later re-classified as negative, or in which suchstudies simply were not mentioned later.(See Table 2, previous page.)

THE DISCREPANCIES BETWEEN the1995 report and 1999 report become moretroubling considering that in 27 of the 102studies listed in 1995, researchers “con-cluded [that] adverse effects” were ob-served in animals that ate irradiated foods.An endorsement of food irradiation whenfully one-fourth of experiments revealed

health problems in labanimals that ateirradiated foods wouldbe difficult to defend.

With little expla-nation, authors of the1999 report attributednearly all of the healthproblems to nutri-tional deficiencies inthe animal feed andother dietary factors.103

This argument isof questionable merit, in light of a 1989WHO statement: “If the animals [that ateirradiated food] are sick from vitamindeficiency, researchers will be hard pressedto determine whether observed adverseeffects have been caused by irradiation orstem from the symptoms of vitamin defi-ciency.”104

These re-classifications were, andcontinue to be, no small matter. The 1995report, which focused on foods irradiated atdoses higher than 10 kiloGray, led directlyto the 1999 report. In this later report, theWHO, IAEA and FAO endorsed irradiationfor any food at any dose – as high as the

In a 1995 FAO/IAEA/WHO report, 21 studies

classified as yieldingadverse effects were

re-classified as negativein a report published

four years later.

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equivalent of several billion chest x-rays.Further, the 1999 report is being used

to support a proposal by the CodexAlimentarius Commission, which sets food-safety standards for more than 160 coun-tries, to completely remove its 10 kiloGraydose cap for all foods.

Hidden Harm?ANOTHER DISTURBING TRENDrelates to the WHO’s handling of researchconducted on unique chemical byproductsformed in certain irradiated foods calledcyclobutanones. Thesechemicals – whichhave never been foundto occur naturally inany food – haveemerged from threedecades of obscurityto centerstage of adeepening interna-tional debate thatcould have majorrepercussions for theglobal food irradiationmovement.

Cyclobutanoneswere discovered in1971 by University of Massachusetts foodscientists Wassef Nawar and Paul Letellier,when they exposed fats commonly found infoods to ionizing radiation.105

Because irradiation is responsible forforming these chemicals, which are com-pletely distinct from any known foodcomponent, they are referred to as “uniqueradiolytic products.” Subsequent researchfound cyclobutanones in many commonfoods after irradiation, including chicken,pork, lamb, salmon, cheese, eggs, peanuts,certain fish and certain fruits.106

Six years later, in 1977, Nawar madereference to cyclobutanones in a paper hepresented at an FAO/IAEA/WHO meet-ing held in the Netherlands.107 He alsostated during open discussion that “we stilldo not know all the compounds producedin [irradiated food] and, in some cases, wecannot even measure them.”108

At that same meeting, Nawar co-presented a paper with Charles Merritt ofthe U.S. Army’s food irradiation program inNatick, Massachusetts.109 (which was soonto be shut down due to a scandal andshoddy research). Merritt frequently col-

laborated with Nawar,who has conductedperhaps more researchon radiolytic productsthan any scientist inthe world. From 1978to 1983, Merritt andNawar coauthored sixpublished articles onradiolytic products.110

DESPITEMERRITT’S FIRST-HAND, in-depthknowledge of Nawar’swork on radiolytic

products, and despite being well-versed onthe subject himself, Merritt went on tomake one of the more notable errors in the40-year history of international foodirradiation deliberations. In 1988, at anFAO/IAEA/WHO conference on “publicinformation on food irradiation” held inCadarache, France, Merritt wrote:

Radiation chemistry studies [haveshown] that the radiolytic productsof major food components are iden-tical, regardless of the food fromwhich they are derived… In all stud-

Unique chemicalbyproducts formed inirradiated food calledcyclobutanones haveemerged from threedecades of obscurity

to centerstageof a deepening

international debate.

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ies on radiolytic products, no prod-uct has ever been identified in an ir-radiated food which is unique.111

Merritt’s error would go uncorrectedfor 11 years, during which four majorWHO/IAEA/FAO reports were published– none of which addressed the issue.

Even when the agencies publiclyacknowledged in 1999 that cyclobutanonesare unique radiolytic products, the scien-tific evidence related to these chemicalsand their toxic properties was misrepre-sented.

The toxic proper-ties of cyclobutanonesare downplayed in thesame 1999 WHOreport that question-ably re-classified 21studies. The reportstates that a recentexperiment on humancolon cells found oneparticularcyclobutanone – 2-DCB – caused “somecytotoxicity and anassociated but weakeffect in DNA.”112 Thestudy, however, found that “a cytotoxiceffect with increasing dosage [was] clearlydemonstrated,” and that “the results clearlydemonstrate a genotoxic effect of 2-DCB.”113

The 1999 WHO report also states thatan experiment on rats found a “small butpositive effect” of 2-DCB.114 The study,however, found “slight but significantDNA damage.”115

And, the WHO report states thatresearchers used an “extremely high level”of 2-DCB.116 In reality, the researchers useda level of 2-DCB commensurate with an

irradiation dose that would be permittedunder a proposal being considered by theCodex Alimentarius Commission andendorsed by the WHO, IAEA and FAO.Additionally, when researchers applied theFDA’s standard toxicological safety factorof 100, 2-DCB was shown to have agenotoxic effect, thus failing the safety testrequired by the U.S. Code of FederalRegulations.117

TWO YEARS LATER, at a meeting inThe Hague in March 2001, the WHO’srepresentative to the Codex Committee onFood Additives and Contaminants

(CCFAC) stated that“the available evi-dence did not indicatethat 2-DCB posed apublic health risk.”118

This statement wasmade despite the factthat toxicity experi-ments on 2-DCB werestill underway, anddespite several warn-ings from scientistsconducting the experi-ments that additionalresearch is necessary.

In 1998, forexample, these scientists wrote: “[F]urtherclarification is needed to determinewhether these results are relevant to thesafety of irradiated foods... The results urgecaution, and should provide impetus forfurther studies.”119

Also at the 2001 CCFAC meeting inThe Hague, a representative from theInternational Consultative Group on FoodIrradiation (an FAO/IAEA/WHO projectthat recommends food irradiation policiesto Codex) said in regard to ongoingcyclobutanone experiments that “prelimi-

U.S. Army researcherCharles Merritt falsely

stated in 1988:“In all studies on

radiolytic products,no product has ever

been identifiedin an irradiated

food which is unique.”

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nary results were negative with regard togenotoxicity and cytotoxicity.”120 In reality,these experiments attributed geneticdamage, tumors and cellular damage tocyclobutanones, and found that thesechemicals “promote the colonic carcino-genesis process” in rats.121

THE EUROPEAN COMMISSION citedthis discrepancy in formal commentssubmitted to the CCFAC last December.The EC said it “considers it as prudent notto proceed” with the Codex proposal toremove the 10 kiloGray dose cap.122

Two months later, in February 2002, akey EC food safetypanel voted to delay aproposal to legalizeirradiation for severaltypes of food –including frozenherbs, dried fruit,cereal flakes, eggwhites, frog legs,peeled shrimp andcertain chicken meats– in all 15 EuropeanUnion nations untilthe ongoing experi-ments on cyclobu-tanones are completed.

A preliminary report on these experi-ments, conducted by a team of Germanand French scientists, states:

[Cyclobutanones] potentiate the ef-fect of an inducing carcinogen on thelong term. This was revealed by theincrease of colonic preneoplastic le-sions and the development of a highernumber of colon tumours with largersize... This suggests that, in themodel experiment [cyclobutanones],although they do not induce carcino-

genesis per se, rather promote the car-cinogenic process. Finally, it wasshown that small fractions of [cy-clobutanones] had been stored in ratadipose tissues and excreted in faecesof the treated rats. This indicates thatmost of the [cyclobutanones are]metabolically transformed or storedin other organs… In our opinion fur-ther investigations, including confir-mations of our results by other labo-ratories, will help to elucidate a pos-sible risk associated with the con-sumption of irradiated fat-containingfoods.123

At the CCFAC’slatest meeting, heldthis past March inRotterdam, the EC’sconcerns over cyclobu-tanones led theCCFAC to delay by atleast a year the Codexproposal to remove the10 kiloGray dosecap.124 Formal concernsover cyclobutanoneshave been expressed tothe CCFAC since

2000, when Germany went on record asopposing the Codex proposal.125 Since then,Poland126 and Sweden127 have also come outin opposition to the proposal.

Despite the fact that toxic propertiesof cyclobutanones have been demonstratedin four consecutive experiments since1998; despite the fact that research is stillongoing; and despite warnings from re-searchers that their findings “urge cau-tion,”128 IAEA officials stated at theRotterdam meeting: “No scientific groundshave been established for [cyclobutanones]to be considered a public health risk.”129

A recent study foundthat cyclobutanones

“promote thecarcinogenic process”

in rats and caused“a higher number ofcolon tumours with

larger size.”

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RECOMMENDATIONS

DUE TO THE IRREGULARITIES in theprocess by which the World Health Organi-zation, the International Atomic EnergyAgency, and the United Nations’ Food andAgriculture Organization have endorsedfood irradiation, Public Citizen makes thefollowing recommendations:

! The WHO, IAEA and FAO shouldpromptly place amoratorium on anyfurther recommenda-tions to expand foodirradiation in anyfashion.

! The WHO,IAEA and FAOshould promptlywithdraw the conclu-sions and suspend therecommendationsissued in the 1999report, High-DoseIrradiation: Wholesome-ness of Food Irradiatedwith Doses Above 10kGy, which endorsedirradiation for allfoods at any dose –no matter how high. The agencies shouldinform all member nations of this actionand recommend that they not proceed withfood irradiation of any kind.

! The WHO should promptly conduct,commission or otherwise foster published,peer-reviewed research into the core safetyand wholesomeness issues raised at theFAO/IAEA/WHO meeting on the whole-someness of irradiated food held in Brus-sels, 23-30 October 1961. Research shouldalso be conducted into key safety andwholesomeness issues raised since theBrussels meeting, including the toxicity of

cyclobutanones, and the radiation-inducedformation and increased concentration ofchemicals known or suspected to causecancer, birth defects and other healthproblems. These chemicals include ben-zene, toluene and methyl ethyl ketone.

! A 1959 agreement giving the IAEA“the primary responsibility” to research anddevelop nuclear technologies, and torequire the WHO to consult with the IAEAon overlapping projects should be dis-

solved.! The United

Nations shouldpromptly appoint anindependent panel ofexperts from the fieldsof toxicology, foodscience, radiationchemistry, nutritionand other relevantfields to conduct acomprehensive reviewinto the activities ofthe WHO, IAEA andFAO related to foodirradiation.

This panel inde-pendent should reviewall WHO, IAEA andFAO publications, and

identify and correct all inaccurate, mislead-ing and incomplete statements regardingfood irradiation.

This independent panel should alsoinvestigate the role played by the IAEA inthe process of endorsing food irradiation,and whether the agency’s role has cor-rupted the integrity of the analysis of thesafety and wholesomeness of irradiatedfoods. Meetings of this panel should beopen to the public, and all materials andfindings should be distributed to membernations and be made available to thepublic.

The WHO, IAEA andFAO should place a

moratorium onrecommendations to

expand foodirradiation. Theagencies shouldwithdraw their

endorsement forirradiation for all

foods at any dose –no matter how high.

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NOTES1 Preamble to the Constitution of the World Health

Organization, as adopted by the International HealthConference, New York City, 19-22 June 1946.

2 World Health Organization, Web site, <http://www.who.in>

3 High-Dose Irradiation: Wholesomeness of Food Irradiated withDoses Above 10 kGy. Report of a Joint FAO/IAEA/WHO Study Group, Geneva, 15-20 September 1997.Geneva: World Health Organization, 1999.

3a Metta, V.C. et al. “Vitamin K deficiency in rats inducedby feeding of irradiated beef.” Journal of Nutrition,69:18-21, 1959.

Mellette, S.J. and Leone, L.A. “Influence of age, sex,strain of rat and fat soluble vitamins on hemorrhagicsyndromes in rats fed irradiated beef.” FederationProceedings, 19:1045-1048, 1960.

Poling, C.E. et al. “Growth, reproduction, survival andhistopathology of rats fed beef irradiated withelectrons.” Food Research, 20:193-214, 1955.

Anderson, D. et al. “Irradiated laboratory animal diets:Dominant lethal studies in the mouse.” MutationResearch, 80:333-345, 1981.

Moutschen-Dahmen, M. et al. “Pre-implantation deathof mouse eggs caused by irradiated food.” Int JourRad Biol, 18:201-216, 1970.

Vijayalaxmi. “Cytogenetic studies in monkeys fedirradiated wheat.” Toxicology 9:181-184, 1978.

Lofroth, G. et al. “Biological effects of irradiated food.II: Chemical and biological studies of compoundsdistilled from irradiated food.” Arkiv Zool 18:529-547, 1966.

Vijayalaxmi.”Genetic effects of feeding irradiatedwheat to mice.” Canadian Journal of Genetics andCytology, 18:231-238, 1976.

Vijayalaxmi and G. Sadasivan. “Chromosomalaberrations in rats fed irradiated wheat.” Int Jour RadBiol, 27:135-142, 1975.

Renner, H.W. “Chromosome studies on bone marrowcells of chinese hamsters fed a radiosterilized diet.”Toxicology, 8:213-222, 1977.

Vijayalaxmi and K.V. Rao. “Dominant lethal mutationsin rats fed on irradiated wheat.” Int Jour Rad Biol,29:93-98, 1976.

Vijayalaxmi. “Immune response in rats given irradiatedwheat.” British Journal of Nutrition, 40:535-541,1978.

Renner, H.W. et al. “An investigation of the genetictoxicology of irradiated foodstuffs using short-termtest systems. III – In vivo tests in small rodents and inDrosophila melanogaster.” Food Chemistry and Toxicology,20:867-878, 1982.

Spiher, A.T. “Food irradiation: An FDA report.” FDAPapers, Oct. 1968.

Reichelt, D. et al. “Long-term animal feeding study fortesting the wholesomeness of an irradiated diet witha high content of free radicals.” Federal ResearchInstitute for Food Preservation, Institute forRadiation Technology, Karlsruhe, Germany, 1972.

Bugyaki, L., A.R. Deschreider, J. Moutschen, M.Moutschen-Dahmen, A. Thijs, and A. Lafontaine.“Do irradiated foodstuffs have a radiomimeticeffect? II. Trials with mice fed wheat meal irradiatedat 5 Mrad.” Atompraxis 14:112-118, 1968.

Raltech Scientific Services Inc., Madison, Wisconsin.“Final Report: Evaluation of the mutagenicity ofirradiated steilized chicken by the sex-linkedrecessive lethal test in Drosophila melanogaster.”Contract DAMD 17-76-C-6047, submitted to U.S.Army Medical Research and DevelopmentCommand, Fort Detrick, Frederick, Maryland. June15, 1979.

Swaminathan, M.S. et al. “Mutations: Incidence inDrosophila melanogaster reared on irradiated medium.”Science, 141:637-638, 1963.

Rinehart, R.R. and Ratty, F.J. “Mutation in Drosophilamelanogaster cultured on irradiated whole food orfood components.” International Journal of RadiationBiology, 12(4):347-354, 1967.

Rinehart, R.R. and Ratty, F.J. “Mutation in Drosophilamelanogaster cultured on irradiated food.” Genetics,52(6):1119-1126, 1965.

Tinsley, I.J. et al. “The growth, reproduction, longevity,and histopathology of rats fed gamma-irradiatedcarrots.” Toxicology and Applied Pharmacology, 16:306-317, 1970.

Johnston-Arthur T., M. Brena-Valle, K. Turanitz, R.Hruby, and G. Stehlik. “Mutagenicity of irradiatedfood in the host mediated assay system.” StudiaBiophysica, Berlin 50:137-141, 1975.

Kesavan, P.C. and Swaminathan, M.S. “Cytotoxic andmutagenic effects of irradiated substrates and foodmaterial.” Radiation Botany, 11:253-281, 1971.

Schubert, J. “Mutagenicity and cytotoxicity ofirradiated foods and food components.” Bulletin ofthe World Health Organization, 41:873-904, 1969.

4 Marketing and Acceptance of Irradiated Foods. Report ofthe Consultants’ Meeting on the Marketing, MarketTesting and Consumer Acceptance of Irradiated Foods,Organized by the Joint FAO/IAEA Division ofIsotope and Radiation Applications of Atomic Energyfor Food and Agricultural Development, 27 September– 1 October 1982. Vienna: International AtomicEnergy Agency, 1983.

5 Preamble to the Constitution of the World HealthOrganization, as adopted by the International HealthConference, New York City, 19-22 June 1946.

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6 World Health Organization, Web site<http://www.who.in>

7 World Health Organization, 1999.7a Op. cit., note 3a.8 International Atomic Energy Agency, 1983.9 “Agreement Between the International Atomic Energy

Agency and the World Health Organization.”Approved by the Twelfth Health Assembly, Geneva, 28May 1959. Resolution WHA12.40.

10 Report of the Meeting on the Wholesomeness of IrradiatedFoods. Organized by the Food and AgricultureOrganization, the World Health Organization and theInternational Atomic Energy Agency, Brussels, 23-30October 1961. Rome: Food and AgricultureOrganization of the United Nations, 1962.

11 Ibid.12 The Technical Basis for Legalization on Irradiated Food.

Report of a Joint FAO/IAEA/WHO ExpertCommittee, Rome, 21-28 April 1964. World HealthOrganization Technical Report Series No. 316. Geneva:World Health Organization, 1966.

13 Ibid.14 Ibid.15 “Status of the Food Irradiation Program.” Hearings

before the Subcommittee on Research andDevelopment of the Joint Committee on AtomicEnergy, Congress of the United States. 18/30July1968. Washington, D.C.: U.S. Government PrintingOffice.

16 U.S. Food and Drug Administration Memorandum.From Isabel S. Chen, Scientific Support Branch toWilliam J. Trotter, Regulatory Policy Branch, 11December 1998.

17 World Health Organization, 1966.18 Ibid.19 Ibid.20 Ibid.21 Ibid.22 Ibid.23 Op. cit., note 16.24 Wholesomeness of Irradiated Food with Special Reference to

Wheat Potatoes and Onions. Report of a Joint FAO/IAEA/WHO Expert Committee, Geneva, 8-12 April1969. World Health Organization Technical ReportSeries No. 451. Geneva: World Health Organization,1970.

25 Ibid.26 Ibid.

27 Bugyaki, L., A.R. Deschreider, J. Moutschen, M.Moutschen-Dahmen, A. Thijs, and A. Lafontaine. “Doirradiated foodstuffs have a radiomimetic effect? II.Trials with mice fed wheat meal irradiated at 5 Mrad.”Atompraxis 14:112-118, 1968.

28 Ibid.29 Ibid.30 Schubert, J. “Mutagenicity and cytotoxicity of

irradiated foods and food components.” Bulletin ofWorld Health Organization, 41:873-904, 1967.

31 World Health Organization, 1970.32 Wholesomeness of Irradiated Food. Report of a Joint

FAO/IAEA/WHO Expert Committee, Geneva, 27October - 3 November 1980. World HealthOrganization Technical Report Series No. 659. Geneva:World Health Organization, 1981.

33 Wholesomeness of Irradiated Food. Report of a JointFAO/IAEA/WHO Expert Committee, Geneva, 31August – 7 September 1976. World HealthOrganization Technical Report Series No. 604. Geneva:World Health Organization, 1977.

34 World Health Organization, 1981.35 World Health Organization, 1977.36 Ibid.37 Ibid.38 Ibid.39 Ibid.40 Ibid.41 “The Department of the Army’s Food Irradiation

Program – Is it Worth Continuing?” U.S. GeneralAccounting Office, PSAD-78-146, 29 September1978.

42 World Health Organization, 1977.43 World Health Organization, 1981.44 Ibid.45 World Health Organization, 1977.46 U.S. Government Printing Office, 1968.47 World Health Organization, 1981.48 World Health Organization, 1977.49 World Health Organization, 1981.50 Ibid.51 Aspects of the Introduction of Food Irradiation in Developing

Countries. Proceedings of a Panel Organized by theJoint FAO/IAEA Division of Atomic Energy in Foodand Agriculture, Bombay, 18-22 November, 1972.Vienna: International Atomic Energy Agency, 1973.

52 Ibid.

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53 International Acceptance of Irradiated Food: Legal Aspects.Report of a Joint FAO/IAEA/WHO Advisory Group,Wageningen, 28 November – 1 December 1977. LegalSeries No. 11, Vienna: International Atomic EnergyAgency, 1979.

54 Ibid.55 Marketing and Acceptance of Irradiated Foods. Report of

the Consultants’ Meeting on the Marketing, MarketTesting and Consumer Acceptance of Irradiated Foods,Organized by the Joint FAO/IAEA Division ofIsotope and Radiation Applications of Atomic Energyfor Food and Agricultural Development, 27 September– 1 October 1982. Vienna: International AtomicEnergy Agency, 1983.

56 Ibid.57 Ibid.58 United States of America v. Martin Welt. U.S. District

Court, District of New Jersey. Criminal No. 88-87.59 Wakin, Daniel; Associated Press. “Irradiation Company

Founder Accused of Safety Violations.” 18 March1988.

60 “Former Chief, Welt, Indicted in Radiation TechnologyInc. Case.” Wall Street Journal, 22 March 1988.

61 “Food Irradiator Found Guilty: Faces Up to 22 Yearsin Prison, $1 Million Fine for Lying to NRC.” BergenRecord, 14 July 1988.

62 “Food Irradiator Gets Prison Term.” Bergen Record, 12October 1988.

63 International Atomic Energy Agency, 1983.64 Ibid.65 Ibid.66 Ibid.67 “Beneficial Uses of Defense Nuclear Materials

Byproducts.” Hearing before the Procurement andMilitary Nuclear Systems Subcommittee of theCommittee on Armed Services, House ofRepresentatives, Congress of the United States. 5March 1981. Washington, D.C.: U.S. GovernmentPrinting Office.

68 “The Status of the Technical Infrastructure to SupportDomestic Food Irradiation.” Hearing before theSubcommittee on Energy Research and Production ofthe Committee on Science and Technology, House ofRepresentatives, Congress of the United States. 26July 1984. Washington, D.C.: U.S. GovernmentPrinting Office.

69 Food Irradiation Processing. Proceedings of anInternational Symposium Jointly Organized by theInternational Atomic Energy Agency and the Food andAgriculture Organization of the United Nations,Washington, DC, 4-8 March 1985. Vienna:International Atomic Energy Agency, 1985.

70 Ibid.71 Safety Factors Influencing the Acceptance of Food Irradiation

Technology. Report of a Task Force Meeting on PublicInformation of Food Irradiation Convened by theInternational Consultative Group on Food Irradiationand Held in Cadarache, France, 18-21 April 1988.Vienna: International Atomic Energy Agency, 1989.

72 A Broken Record: How the FDA Legalized - and Continuesto Legalize - Food Irradiation Without Testing it for Safety.Washington, DC: Public Citizen, Cancer PreventionCoalition, Global Resource Action Center for theEnvironment, 2000.

73 International Atomic Energy Agency, 1989a.74 Ibid.75 Ibid.76 Acceptance, Control of and Trade in Irradiated Food.

Proceedings of an International Conference JointlyOrganized by the Food and Agriculture Organizationof the United Nations, World Health Organization,International Atomic Energy Agency, Geneva, 12-16December 1988. Vienna: International Atomic EnergyAgency, 1989.

77 Ibid.78 Ibid.79 Ibid.80 Consumer Concerns About the Safety of Irradiated Food. The

WHO Reply to Questions Raised by the InternationalOrganization of Consumers Unions. Geneva: WorldHealth Organization, 1989.

81 Ibid.82 Ibid.83 World Health Organization, 1977.84 World Health Organization, 1989.85 Workshop on the Implications of GATT Agreements on

Trade in Irradiated Food. Marseille, 13-15 November1995. Vienna: International Consultative Group onFood Irradiation, 1996.

86 Food Irradiation Process, Control and Acceptance:Regional UNDP Project for Asia and the Pacific.Mission Undertaken in the Philippines. Vienna: UnitedNations Development Programme, InternationalAtomic Energy Agency, 1992.

87 Food Irradiation Process, Control and Acceptance:Regional UNDP Project for Asia and the Pacific.Mission Undertaken in the Republic of Korea. Vienna:United Nations Development Programme,International Atomic Energy Agency, 1992.

88 Food Irradiation Process, Control and Acceptance:Regional UNDP Project for Asia and the Pacific.Mission Undertaken in Sri Lanka. Vienna: UnitedNations Development Programme, InternationalAtomic Energy Agency, 1992.

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89 Proceedings: ASEAN Workshop of Food Irradiation.Organized by the ASEAN Food Handling Bureau incollaboration with the Atomic Energy Commission ofThailand under the auspices of the ASEAN-COFAFSub-Committee on Food Handling, Bangkok 26-28November. Jakarta: ASEAN-COFAF Secretariat,1985.

90 Safety and Nutritional Adequacy of Irradiated Food. Geneva:World Health Organization, 1994.

91 Biagini, C. et al. “Growth and fertility of mice fed anirradiated diet for two years. G Med Milit, 117117:347-368, 1967.

Bugyaki, L. et al. “Do irradiated foodstuffs have aradiomimetic effect? II. Trials with mice fed wheatmeal irradiated at 5 Mrad.” Atompraxis, 14:112-118,1968.

Malhotra, O.P. and Reber, E.F. “Effect of methionineand age of rats on the occurrence of hemorrhagicdiathesis in rats fed a ration containing irradiatedbeef. J Nutr, 80:85-90, 1963.

Malhotra, O.P. et al. “Effect of methionine andvitamin K3 on hemorrhages induced by feeding aration containing irradiated beef.” Toxicol ApplPharm, 7:402-408, 1965.

Metwalli, O.M. “Study on the effect of foodirradiation on some blood serum enzymes in rats. ZErnährungswiss, 16:18-21, 1977.

Phillips, A.W. et al. Long-term Rat Feeding Studies –Irradiated Chicken Stew and Cabbage. U.S. ArmyContract DA-49-007-MD-783, 1961.

Porter, G. and Festing, M. “A comparison betweenirradiated and autoclaved diets for breeding micewith observations on palatability.” Lab Anim, 4:203-231, 1970.

Read, M.S. et al. “Short-term rat-feeding studies withgamma-irradiated food products – II. Beef and porkat elevated temperature.” Toxicol Appl Pharm, 1:417-425, 1959.

Read, M.S. et al. “Successive generation rat-feedingstudies with a composite diet of gamma-irradiatedfoods.” Toxicol Appl Pharm, 3:153-173, 1961.

Rinehart, R.R. and Ratty, F.J. “Mutation in Drosophilamelanogaster cultured on irradiated food.” Genetics,52:1119-1126, 1965.

Verschuuren, H.G. et al. “Ninety-day rat feeding studyon irradiated strawberries.” Food Irrad, 7(1-2):A17-A21, 1966.

92 High-Dose Irradiation: Wholesomeness of Food Irradiatedwith Doses Above 10 kGy. Report of a Joint FAO/IAEA/WHO Study Group, Geneva, 15-20 September1997. Geneva: World Health Organization, 1999.

93 World Health Organization, 1994.

94 Bhaskaram, C. and Sadasivan, G. “Effects of feedingirradiated wheat to malnourished children.”American Journal of Nutrition, 28:130-135, 1975.

Brin, M. et al. “Effects of feeding X-irradiated pork torats on their pyridoxine nutrition as reflected in theactivity of plasma transaminase.” Journal of Nurtition,75:35-38, 1961.

Bugyaki, L. et al. “To study the effect of feedingirradiated wheat flour to mice.” Food IrradiationInformation, 2 (Suppl.): vii, 1973.

Chopra, V.L. et al, “Cytological effects observed inplant material grown on irradiated fruit juices.”Radiation Botany, 3:1-6, 1963.

Fegley, H.C. and Edmonds, R.E. “To examine thewholesomeness of irradiated soft-shell clams (Myaarenaria) in dogs.” Food Irradiation Information, 6(Suppl): 111, 1976.

Gabriel, K.L and Edmonds, R.S. “To study the effectsof radurized onions when fed to albino rats.” FoodIrradiation Information, 6 (Suppl):116, 1976.

Kesevan, P.C. and Swaminathan, M.S. “Cytotoxic andradiomimetic activity of irradiated culture mediumon human leukocytes.” Current Science, 35(16):403-404, 1966.

Osipova, I.N. “Investigation of the possiblemutagenicity of extracts from irradiated potatoes asa function of storage and cooking.” Voprosy Pitanija,33(1):78-81, 1974 (in Russian).

Osipova, I.N. et al. “Influence of the storage andculinary treatment of irradiated potatoes on thecytogenic activity of potato extracts.” VoprosyPitanija, 34(4):54-57, 1975 (in Russian).

Reber, E.F. et al. “The effects of feeding irradiatedflour to dogs: II. Reproduction and pathology.”Toxicology and Applied Pharmocology, 3:568-573, 1961.

Shillinger, I. and Osipova, I.N. “The effect of freshfish exposed to gamma radiation on the organism ofalbino rats.” Voprosy Pitanija, 29(5):45-50, 1970 (inRussian).

Swaminathan, M.S. et al. “Cytological aberrationsobserved in barley embryos cultured in irradiatedpotato mash.” Radiation Research, 16:182-188, 1962.

Swaminathan, M.S. et al. “Drosophila melanogaster rearedon irradiated medium.” Science, 141:637-638, 1963.

Vijayalaxmi. “Cytogenic studies in rats fed irradiatedwheat.” International Journal of Radiation Biology,27:283-285, 1975.

Vijayalaxmi. “Genetic effects of feeding irradiatedwheat to mice.” Canadian Journal of Genetics andCytology, 18:231-238, 1976.

Vijayalaxmi. “Cytogenic studies in monkeys fedirradiated wheat.” Toxicology, 9:181-184, 1978.

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Vijayalaxmi and Rao, K.V. “Dominant lethal mutationsin rats fed on irradiated wheat.” International Journalof Radiation Biology, 29:93-98, 1976.

Vijayalaxmi and Sadasivan, G. “Chromosomalaberrations in rats fed irradiated wheat.” InternationalJournal of Radiation Biology, 27:135-142, 1975

Wills, E.D. Studies of Irradiated Food. Karlsruhe,Germany: Federal Research Centre for Nutrition,(IFIP Technical Report), 1981.

95 Review of Data on High Dose (10-70 kGy) Irradiation ofFood. Report of a Consulation, Karlsruhe, Germany, 29August - 2 September 1994. Geneva: World HealthOrganization, 1995.

96 World Health Organization, 1994.97 Phillips, A.W. et al. “Long-term feeding studies:

Irradiated oranges.” Final contract report, U.S. Armycontract No. DA-49-007-MD-791, 1961.

98 World Health Organization, 1995.99 Ibid.100 Anderson, D. et al. “Irradiated laboratory animal diets:

Dominant lethal studies in the mouse.” MutationResearch, 80:333-345, 1981.

Biagini, C. et al. “Growth and fertility of mice fed anirradiated diet for two years. G Med Milit, 117117:347-368, 1967.

Bugyaki, L. et al. “Do irradiated foodstuffs have aradiomimetic effect? II. Trials with mice fed wheatmeal irradiated at 5 Mrad.” Atompraxis, 14:112-118,1968.

Johnston-Arthur T., et al. “Mutagenicity of irradiatedfood in the host mediated assay system.” StudiaBiophysica (Berlin), 50:137-141, 1975.

Johnston-Arthur, V.T. et al. Investigation on irradiatedstandard diets and their extract components on thepossible mutagenic effect in the ‘Host MediatedAssay’ using Salmonella typhimurium G 46 and TA1530.” Die Bodenkultur, 30:95-107, 1979.

Joner, P.E. and Underdal, B. “Mutagenicity testing ofirradiated herring fillets.” Lebensm Wiss & Technol,13:293-296, 1980.

Koch, F. et al. “Effect of feeding 10 kGy irradiatedbarley on hematological and lipid metabolismparameters in growing quail. BFE-R-93-03. InLebensmittelbestrahlung 2. Gesamtdeutsche Tagung,Bundesforschungsanstalt für Ernährung, Karlsruhe,1993.

Lang, K. “Toxicity of irradiated fat.” Food CosmetToxicol, 1:125, 1963.

Malhotra, O.P. and Reber, E.F. “Methionine andtestosterone effect occurrence of hemorrhagicdiathesis in rats.” Am J Physiol, 205:1089-1092,1963.

Malhotra, O.P. and Reber, E.F. “Effect of methionineand age of rats on the occurrence of hemorrhagicdiathesis in rats fed a ration containing irradiatedbeef. J Nutr, 80:85-90, 1963.

Malhotra, O.P. and Reber, E.F. “Effect of methionineand vitamin K3 on hemorrhages induced by feeding aration containing irradiated beef.” Toxicol ApplPharm, 7:402-408, 1965.

Metwalli, O.M. “Study on the effect of foodirradiation on some blood serum enzymes in rats. ZErnährungswiss, 16:18-21, 1977.

Moutschen-Dahmen, M. et al. Pre-implantation deathof mouse eggs caused by irradiated food. InternationalJournal of Radiation Biology, 18:201-216, 1970.

Phillips, A.W. et al. Long-term Rat Feeding Studies –Irradiated Chicken Stew and Cabbage. U.S. ArmyContract DA-49-007-MD-783, 1961.

Porter, G. and Festing, M. “A comparison betweenirradiated and autoclaved diets for breeding micewith observations on palatability.” Lab Anim, 4:203-231, 1970.

Read, M.S. et al. “Short-term rat-feeding studies withgamma-irradiated food products – II. Beef and porkat elevated temperature.” Toxicol Appl Pharm, 1:417-425, 1959.

Read, M.S. et al. “Successive generation rat-feedingstudies with a composite diet of gamma-irradiatedfoods.” Toxicol Appl Pharm, 3:153-173, 1961.

Rinehart, R.R. and Ratty, F.J. “Mutation in Drosophilamelanogaster cultured on irradiated food.” Genetics,52:1119-1126, 1965.

Rojo, M.M.I. and Fernandez, C.M. “Induction andreversion process of molecular and cytologicalalterations after highly irradiated food ingestion inmice.” Nucleotecnica., 4(6):48-54, 1984.

Smid, K. et al. “Effect of radiation-treated feeds onsome biochemical indicators of nutrition levelachieved with energy nutrients.” Vet Med,30(9):531-541, 1985.

Verschuuren, H.G. et al. “Ninety-day rat feeding studyon irradiated strawberries.” Food Irrad, 7(1-2):A17-A21, 1966.

101 World Health Organization, 1999.102 World Health Organization, 1995.103 World Health Organization, 1999.104 World Health Organization, 1989.105 LeTellier, P.R. and Nawar, W.W. “2-

alkylcyclobutanones from the radiolysis oftriglycerides.” Lipids, 7: 75-76, 1972.

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106 Hidden Harm: How the FDA is Ignoring the PotentialDangers of Unique Chemicals in Irradiated Food.Washington, D.C.: Public Citizen and The Center forFood Safety, December 2001.

107 Nawar, W.W. and Handel, A.P. “Radiolysis ofphospholips.” In Food Preservation by Irradiation:Proceedings of a Symposium Jointly Organized by theIAEA, FAO, WHO, Wageningen, the Netherlands, 21-25 November 1977. Vienna: International AtomicEnergy Agency, 1978; pp. 481-485 (IAEA-SM-221/58).

108 Food Preservation by Irradiation: Proceedings of aSymposium Jointly Organized by the IAEA, FAO,WHO, Wageningen, the Netherlands, 21-25 November1977. Vienna: International Atomic Energy Agency,1978; p. 29 (IAEA-SM-221/74).

109 Merritt, C., Angeleni, P. and Nawar, W.W. “Chemicalanalysis of radiolytic products relating to thewholesomeness of irradiated food.” In Food Preservationby Irradiation: Proceedings of a Symposium JointlyOrganized by the IAEA, FAO, WHO, Wageningen, theNetherlands, 21-25 November 1977. Vienna:International Atomic Energy Agency, 1978; pp. 97-112(IAEA-SM-221/51).

110 Merritt, C., Angeleni, P. and Nawar, W.W. “Chemicalanalysis of radiolytic products relating to thewholesomeness of irradiated food.” In FoodPreservation by Irradiation: Proceedings of aSymposium Jointly Organized by the IAEA, FAO,WHO, Wageningen, the Netherlands, 21-25November 1977. Vienna: International AtomicEnergy Agency, 1978; pp. 97-112 (IAEA-SM-221/51)

Vajdi, M., Nawar, W.W. and Merritt, C. “Comparisonof radiolytic products from saturated andunsaturated triglycerides and fatty acids.” Journal ofAmerican Oil Chemists’ Society, 55:849-850, 1978.

Vajdi, M., Nawar, W.W. and Merritt, C. “Formation ofand lactones in irradiated beef.” Journal of AmericanOil Chemists’ Society, 56:906-907, 1978.

Vajdi, M., Nawar, W.W. and Merritt, C. “Identificationof radiolytic compounds from beef.” Journal of theAmerican Oil Chemists’ Society, 56:611-615, 1979.

Vajdi, M., Nawar, W.W. and Merritt, C. “Effects ofvarious parameters on the formation of radiolysisproducts in model systems.” Journal of the AmericanOil Chemists’ Society, 59:38-42, 1982.

Vajdi, M., Nawar, W.W. and Merritt, C. “Identificationof adduct radiolysis products from ethyl palmitateand ehtyl oleate.” Journal of the American OilChemists’ Society, 60:978-986, 1983.

111 Merritt, C. “Radiolytic products: Are they safe?” InSafety Factors Influencing the Acceptance of Food IrradiationTechnology. Report of a Task Force Meeting on Public

Information of Food Irradiation Conevened by theInternational Consultative Group on Food Irradiation,Cadarache, France, 18-21 April 1988. Vienna:International Atomic Energy Agency, 1989; pp. 39-52.

112 World Health Organization, 1999.113 Delincée, H. and Pool-Zobel, B. “Genotoxic properties

of 2-dodecylcyclobutanone, a compound formed onirradiation of food containing fat.” Radiation Physicsand Chemistry, 52:39-42, 1998.

114 World Health Organization, 1999.115 Delincée, H. et al. “Genotoxicity of 2-

dodecylcyclobutanone.” Food Irradiation: FifthGerman Conference, Karlsruhe, 11-13 November1998.

116 World Health Organization, 1999.117 Public Citizen and The Center for Food Safety,

December 2001.118 Summary Report: 33rd Session of the Codex

Committee on Food Additives and Contaminants. TheHague, 12-16 March 2001.

119 Delincee, 1998b.120 Codex Committee on Food Additives and

Contaminants, 2001.121 Marchioni, E. et al. “Toxicological study to assess the

risk associated with the consumption of irradiated fat-containing food.” (Summary) InternationalConsultative Group on Food Irradiation, December2001.

122 European Community Comments on CL 2001/34-FACof the Codex Secretariat, (Proposed Draft Revision tothe Codex General Standard for Irradiated Foods,ALINORM 01/12A, para 85 and Appendix VII). 4December 2001.

123 Marchioni, E. et al. 2001.124 Report of the 34th Session of the Codex Committee on

Food Additives and Contaminants, Rotterdam, theNetherlands, 11-15 March 2002.

125 Annual Report on Activities Under the 1999Programme, 17th Meeting of the InternationalConsultative Group on Food Irradiation (ICGFI),Geneva, 1-3 November 2000.

126 Agenda Item 10A, CX/FAC 02/11. 34th Session of theCodex Committee on Food Additives andContaminants, Rotterdam, the Netherlands, 11-15March 2002.

127 Codex Committee on Food Additives andContaminants, 2002a.

128 Delincee, 1998b.129 Codex Committee on Food Additives and

Contaminants, 2002b.

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