RE: Proposed Rule on food irradiation

[William Weis <WEISWE@doe-md.gov>]

The proposed rule change to 9CFR317, 318 and 381 states in the
background section that "Section 201(s) of the Federal Food, Drug and
Cosmetic Act (FFDCA) defines sources of radiation used to treat food as
"food additives.""  The FR continues to use the term "food additive"
repeatedly when referring to irradiation of food.  Doesn't this do a
disservice to the public, industry and health physics profession by
falsely implying that something is "added" to the food, similar to MSG or
other preservative, that is passed on to the consumer?

Bill Weis
Babcock & Wilcox of Ohio
weiswe@doe-md.gov
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