Food irradiation violates at least three basic principles
of public health and food security . . .
. . . so why is the Canadian government planning to expand its
list of foods that can be sterilized with irradiation?

By Wayne Roberts

Policy placement affects awareness

Irradiation has not yet gained recognition as a food security and food policy issue, as distinct from a food safety and health, issue. Therefore, most governments, including the United Nations, oversee food irradiation in health departments, not food departments. As a result, food irradiation has not been raised in significant international food documents, despite its relevance for food security and food policy generally.

In a move that has significant consequences for global food policy, the Canadian government is set to follow the U.S. in extending the range of foods that can be sterilized by nuclear irradiation.

Health Canada will be giving thumbs up to irradiation of beef, poultry, prawns, shrimp and papaya. The go-ahead won’t just expand the list of foods that can be irradiated. It expands the functions of irradiation and allows much higher levels of irradiation.

Those who suspect that public policy can be best understood by following the money will wonder why shrimp, prawns and papaya got put on a nuclear hit list alongside chicken and beef. In 1987, as part of the federal government’s many hand-outs to the nuclear industry, Canada’s foreign aid department gave Thailand a $4.8 million food irradiator. In case the Thais feared Canadians, even bearing nuclear gifts, Canada promised to open its markets to irradiated imports from Thailand.

Rolling out an irradiated carpet for Thai food imports indicates how far we’ve come from the days when long distance food referred to imports into Canada from California, Florida and Mexico. The next generation of food imports into the industrialized western world will be coming from the tropical South, mostly countries where the mass of people go hungry so that low-cost exotic foods can be exported to the wealthy North. With irradiation to clear the way for long shelf life, this hot new trend just got hotter.

It’s out-of-this-world food technology applied to a global food system that has lost any sense of homegrown food, and that will accept any tool of mass production that can keep down the prices of what were once rare and special imported treats by keeping up the volume and scale of commodity exports.

Traditionally, food irradiation was positioned as a food safety issue, which is why it has been assigned to health departments of individual countries and to the World Health Organization of the United Nations. Over the years, irradiation has gained supporters in many respected health organizations, as well as from the nuclear industry, and more recently, lobby groups representing the food industry. Indeed, Ronald Eustice, executive director of the Minnesota Beef Council, came to one of Health Canada’s eight wintertime public hearings to describe irradiation as “the fourth pillar of public health,” that will soon rank alongside immunization, pasteurization and chlorination as a standard, presumably compulsory, public health service.

On the anti-side are a range of Canadian environmental and organic activists, U.S. public interest groups, and scientists from senior research organizations in France and Germany, reports from which led the European parliament to give the kybosh to further food irradiation.

The experts on both sides usually debate whether radiation depletes too many vitamins from food, whether the burn from radiation creates Unique Radiolytic Products that cause cancer, and whether radiation kills off good bacteria that keep some food-borne diseases such as botulism in check.

All are issues worthy of public debate. None, however, require much serious research by health regulators, because irradiation has been arbitrarily defined as a “process” rather than an “additive.” That means that Unique Radiolytic Products, sheer creations of irradiation, don’t have to be assessed.

But even leaving aside such traditional food safety issues, food irradiation violates at least three basic principles of public health and food security.

1. The internationally-recognized Ottawa Health Charter, proclaimed in 1986, identifies “enablement”—providing citizens with participatory tools and information to empower them and to assist them in making wise health choices—as a keystone principle. The time, 120 days, which Health Canada provided for public discussion of its impending decision, does not support citizen participation or empowerment; quite the contrary.

Nor do the labelling provisions being considered by Health Canada, almost identical to those in the U.S., support the power of health-minded citizens to make informed personal choices. Irradiated food served by restaurants or school cafeterias, along with irradiated ingredients included in most processed foods, will not be labelled.

2. The internationally-recognized precautionary principle is embedded in Canadian law and public health practice as a result of the Supreme Court decision in 2001 granting municipalities the right to ban the use of cosmetic pesticides. A decision to proceed with food irradiation violates two elements of the precautionary principle.

“Better safe than sorry” expresses one element of the precautionary principle. When scientific opinion is divided over the safety of food irradiation, particularly as regards the damaging bio-chemical results (the creation of Unique Radiolytic Products, for instance) from irradiation, and the depletion of nutrients by irradiation, then the wise course is to postpone a decision until such important scientific controversies can be resolved.

A second element of the precautionary principle was expressed by senior scientists and science philosophers involved in the Royal Society report on genetic engineering, commissioned by the federal government in 2000. This report drew public and professional attention to the precautionary principle’s all-important role in preventing “type two” errors, mistakes that arise from a failure to anticipate “unintended consequences.”

The possibility of such errors has not received serious consideration by Health Canada. There are a wide variety of scenarios that need to be considered. What will happen when the high costs of irradiation equipment encourage the trend toward large, centralized slaughterhouses and meat processing plants? This will have negative consequences for family farmers and other small-scale livestock producers, and thereby eliminate sources of local food in many areas of the country; that wouldn’t improve food access or food security. What if the large and centralized meat processing plants create tiny overlooked niches in which certain food-borne diseases can fester, possibly contaminating millions of pounds of meat? We already know this is not a “what if.” Such outbreaks have happened many times before, and seem to be inevitable in the nooks and crannies of super-sized processing plants. By provoking large-scale and centralized facilities through its support for expensive irradiation procedures, the government may actually be creating conditions for reduced safety of the meat supply.

Almost impossible to believe, health regulators do not seem to be considering the potentially catastrophic health hazards associated with the proliferation of nuclear facilities that supply irradiation services. In this post-9/11 era, has anyone wondered whether meatpacking plants with nuclear fuels have the ability to deny access to criminals or terrorists? Instead of taking such possibilities into account—so urgently needed when dealing with inherently dangerous and unforgiving nuclear technologies—Health Canada’s review focussed narrowly on questions of food safety instead of public safety. It’s precisely this kind of narrow focus that creates conditions for “type two” errors.

3. A decision to proceed with food irradiation also violates the longstanding principle of “do no harm,” first enunciated by Hippocrates, commonly thought to be the founder of western medicine. The “do no harm” principle requires that health authorities move toward invasive procedures—and irradiation certainly constitutes an invasive procedure—only after every consideration has been given to less invasive and dangerous options. This principle is embedded in federal environmental assessments, which require that due consideration be paid to the viability of safe alternatives prior to approval of hazardous innovations.

If a “do no harm” methodology had been adopted in the review of food irradiation, due attention would have been paid to the many superior strategies that protect against food-borne disease. Proper feeding and handling of livestock prior to slaughter are known to reduce the incidence of e coli at slaughterhouses, for instance. There’s no substitute, including irradiation, for strict supervision and regulation of butchering and meat processing operations. Food handling is the weak link in the food-borne disease chain, as evidenced by the fact that produce, prepared salads and mixed preparations—not, as is commonly thought, meats—are the most likely sources of food-borne disease. Finally, there is no substitute for proper food preparation and cooking methods; this, much more than packing plants and warehouses where irradiation facilities will locate, is where effective disease prevention strategies need to be directed. That’s also where disease prevention strategies are low-cost, non-invasive and perfectly safe.

There’s little, in short, to recommend food irradiation, and many reasons to oppose it. Several of the reasons for opposing irradiation are relatively long-established—the general dangers of nuclear technologies, as well as the specific dangers of nutrient depletion and Unique Radiolytic Products, for example.

But a new set of reasons for opposing irradiation is also emerging. These reasons relate to the impact of irradiation on food systems—intensifying pressures against family-scale farming and community-based processing in industrialized countries, and intensifying pressures against self-reliant, domestically-oriented agriculture in the developing world, for example. For these reasons, food irradiation is no longer just an issue of food safety or nuclear safety. It is now an issue of food security.

(This article has been adapted from an article by the author in NOW Magazine, March 20, 2003, and from a brief submitted to Health Canada by the author on behalf of the Toronto Food Policy Council.)