Food Irradiation Labeling

["Gregg Claycamp" <hgc2+@pitt.edu>]

Since there appears to be further interest...

The USDA's Food Safety and Inspection Service proposal on "Irradiation of
Meat and Meat Products" does indeed state that "FSIS is proposing to require
that package lables contain the radura symbol and a statement indicating
that the product was treated with radiation. The symbol must be placed
prominently and conspicuously in conjunction with the required statement.
(64FR 9093).  They note that the requirement  is consistent with current
labeling requirements for labeling "Product which has been prepared by
salting, smoking, drying, cooking, chopping, or otherwise shall be so
described on the label unless the name of the product implies, or the manner
of packaging shows that the product was subjected to such preparation." (at
p. 9094).

The reader should note that the FSIS attempts to portray the labeling
requirement in a favorable light by stating that "some of the effects
brought about by irradiation, such as antimicrobial effects and certain
changes to product quality, are similar to the effects of other forms of
processing, especially cooking."  (at p.9094).  Elsewhere, the FSIS reports
on their discussions with petitioners to use labeling to indicate a safe
product.

In general, the document shows that the FSIS is attempting to cope with the
ambiguities imposed on them by the FDA's inclusion of irradiation as an
"additive" under the Food, Drug and Cosmetic Act.  Unfortunately, the FSIS
did not "go the distance" by stating from the outset that this is
scientifically ridiculous to continue referring to irradiation as an
"additive."   Personally, I thought they made some headway on the issue at
the beginning of the document where they discussed "forms of radiant energy"
including microwave and infrared radiation and  visible and ultraviolet
light.  Grouping ionizing radiation with its user-friendly cousins was a
step in the right direction toward demystifying food irradiation using
ionizing radiation.  Unfortunately, the FSIS did not discuss the
inconsistency:  none of the other forms of radiant energy are included under
their labeling requirements.

The proposed rule makes a very interesting lesson in navigating science
policy with outspoken stakeholders.  I highly recommend reading it and
forwarding your comments to the USDA by April 26, 1999:
URL:  http://www.fsis.usda.gov/oa/fr/99-4401.htm

H. Gregg Claycamp, Ph.D., C.H.P.
Assoc. Prof. and Assoc. Chair
Environmental and Occupational Health
University of Pittsburgh
hgc2+@pitt.edu



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