RadiaL Phy.s. Chem. Vol. 42, Nos 4—6, Pp. 873—875, 1993 0146-5724/93 $6.00 + 0.

00
Printed in Great Britain. All rights reserved Copyright © 1993 Pergamon Press Ltd

THE PRESENT MODEL OF LEGISLATION ON FOOD IRRADIATION

NEEDS TO BE CHANGED

2
Gagnon, M.t* and de Medeiros, J.F.B.
tCanadian Irradiation Center, 535 Blvd Cartier, C.?. 320, Succ.
L—D—R, yule
de Laval, Qc, Canada H7N 4Z9; 2Tech Ion Industrial Brasil S.A., R. Bento de
Andrade, 496 S. Paulo, SP 04503, Brasil

ABSTRACT

The present model of legislation needs to be changed as it does not permit to

play its essential role as a process that improves public health. It also
creates hidden technical barriers to international and even national trade
while imparting a bad and negative image to irradiated foods.

KEY WORDS

Irradiation, ionisation, public health, cholera, marketing, labeling.

INTRODUCTION
The existing cholera epidemics in Latin America bring up the fact that the
existing legislation on food irradiation all over the world presents serious
deficiencies which need urgent correction to enable Food Irradiation to become
a fully accepted process. Today, the present legislation in most countries,
(1.) prevents improved Public Health, (2) creates hidden technical barriers to
international and national trade and (3) imparts bad image to irradiated food.
1. Prevents improved Public Health to the extent that it forbids eliminating
serious diseases spread by contaminated foods in the application of perfectly
safe irradiation doses (below 10 kGy). When it specifies doses for a certain
benefit (i.e. shelf—life), it ignores if that dose is sufficient to eliminate
epidemic deadly pathogens like cholera (d= 1 kGy). Cholera contaminated
products which have authorized doses below 1.0 kcy cannot be made cholera free
without breaking the law.

Unfortunatly, the same incoherence occurs with all the other most common
pathogens in the foods that host them as we can see from the data below:
TABLE 1. DOSES APPROVED FOR FOOD INDICATh THAT THEY DO NOT REACH
THE IMI1IAL DOSES REQUIREI) TO KILL THEIR RELATED PATHOGF.NS (ICGFI-1992)

Approved Dose () kGy

Food Item Common Pathogen Lethal Dose (kGy)
Mm Max

Fish 1.00 6.00 Anisakis 6.00

Fish Meat 1.00 6.00 Salmonella sentberg 7.20

Fruit + Veget. 0.15 1.00 Entamoeba histolytica 0.25

Fruit + Veget. 0.15 1.00 Vibrio cholera 1.00

Pork 4.00 5.00 Tacnia solium 5.00

Pork 4.00 5.00 Trichinella spirallis 6.30

Poultry 1.00 7.00 Salmonella typhimarium 7.00

RPC 42-4/6-U 873

874 M. GAGNON and J. F. B. DE MEDEtROS

National Public Health authorities are usually the ones responsible for
issuing legislation on irradiated food. They are usually connected to WHO,
and follow the Codex Alimentarius recommendations. WHO has declared since
1983 that up to a 10 kGy dose the wholesomeness of irradiated food was
unconditionnaly established, without any need for any additional toxicological
tests. It further stated that this recommended maximum dose for food
irradiation did not mean a threshold level beyond which irradiation would harm
the food. Since that time, research and present practice have indicated the
validity of that conclusion as American astronauts’ foods are irradiated with
70 kGy doses. Studies are being conducted to raise the 10 kGy level to 30 kGy
of course using combined processes.

One of the probable reasons for this approach in the legislation originates
from the fact that the doses required to eliminate a pathogen sometimes affect
the physical properties of the food that carries it, changing their colour,
taste, firmness, etc. It is assumed (without any further considerations) that
the public would not buy such irradiated product (mushy strawberries, purple
mangoes, etc.). It happens that some of those so—called “spoiled” products,
such as “mush strawberries” are still a perfectly valid product for the
preserve industry that needs raw material to operate out of the harvest
season. Also, from the marketing standpoint, a “purple mango” could become
a sign of good quality which would distinguish the irradiated mango. If the
change in the physical properties are of such nature that the consumer of the
product refuses to accept it, this is a business risk which the operator of
the facility has to take, in the same manner that the owner of a restaurant
knows that burnt food is going to be refused by his customers. It is
important to note that these physical changes occur without creating any
toxicological risk or change in the wholesomeness of the food, which is still
safe for human consumption.
The best solution is to free all food irradiation, unconditionally, up to the
10 kGy level without any previous approval. We will see next, that this
approach also has important economic benefits to world trade and economic
development of third world countries.

2. Creates hidden technical barriers to international and national trade of

irradiated food, because national legislations approve doses which are good
to some local varieties of foodstuff, but which may be insufficient to achieve
the same results on other varieties cultivated in other countries or other
regions of the same country. For example, British potatoes (0.20 kGy) cannot
be exported to most countries in the world which have 0.10 kGy as the approved
dose for the same effect. In Brazil, some varieties of onions widely used in
poor areas of the country cannot be irradiated because they require doses
above the approved one. The table below shows that the same is happening for
all other products.
TABLE 2. CLEARANCES ADOP’I’ED BY DIFFERENT COUNTRIES (FAO-IAEA-1958)

COUNTRY CHICKEN SPICES ONION POTATO GRAINS GARLIC

Brazil 7,00 10,00 0,15 0,15 1,00

Canada 10,00 0,15 0,10 0,75

France 5,00 11,00 0,15 0,15 _____________ 0,15

Netherlands 3,00 10,00 0,05 0,15 1,00 ______________

UK 7,00 10,00 0,20 0,20 1,00 0,20

USA 30,00 0,15 1,00 0,50 1,00

USSR 6,00 _________ 0,06 0,30 0,30 _________

Yugoslavia 10,00 10,00 10,00 10,00 10,00 10,00

All these problems would be eliminated if all countries did observe only the
10 kGy (or higher limits) for all irradiated food.

3. Imparts bad image to irradiated foods, when it demands special labeling

for irradiated food. The general public knows that many pesticides used to
 8th International Meeting on Radiation Processing 875

protect the crops are carcinogenic and that some residues are present in many
products. Health authorities do not required special labelling for these
crops. Medical supplies, treated with doses which are hundred time larger
than those applied to foods, go without any special labeling. Irradiated food
presents sanitary conditions and wholesomeness which are equal or better than
those processed by other food preservation methods. How can the public
interpret such special demands, with the words “Irradiated Food” or “Treated
by Irradiation”, if not that irradiated food is dangerous? In fact, if Health
authorities insist in labelling, they should insist on words which reflect the
better quality of irradiated food over the non-irradiated food, such as
“Quality assured by irradiation”, etc. The label should have the same effect
that the label “pasteurized” has for dairy products: a sign of quality.

Our recommendation is that legislation on food irradiation, worldwide, should

be homogeneous and straight forward, to help the public enjoy sooner the
benefits of the treatment. It should state:

1. Any food can be irradiated up to 10 kGy without any previous approval.

2. Special labelling is not required or the wording of it should not induce
the public to a negative image of the process.

CONCLUS ION
It is clear for us that irradiation of food is the only process that could
control epidemics like the cholera spreading in South America. This applies
also to the spread of food borne diseases all over the world.

To profit of this extremely powerful process, the present model of legislation

needs to be modified concerning the doses accepting 10 kGy world wide and
making the labelling positive instead of negative.

REFERENCES
FAO—IAEA—l988 — List of clearances, Food Irradiation Newsletter, Supplement,
vol. 12, no. 1.

ICGFI—l992 — Publication no. 316 — D6.22, Vienna, Austria.