Statement to "Irradiated Food in School Lunches", a packet published by Public Citizen

( www.citizen.org/documents/School%20Lunch%20Activist%20Packet.pdf  )

Henry Delincée, Institute of Nutritional Physiology,

 Federal Research Centre for Nutrition,Karlsruhe, Germany

I am writing this statement because Public Citizen uses my research as evidence in their allegations against food irradiation. However, this obvious case of producing distrust among consumers regarding irradiated food in school lunches puzzles me. The statements of Public Citizen are excessively alarmist.

This case is founded on mere allegations and not on scientific arguments. To start with the statement that irradiation exposes food to a dose of ionizing radiation that is equivalent to millions of chest x-rays, disqualifies the writers, who seem to confuse treatment of food with treatment of humans. I wonder whether the authors from Public Citizen would compare bathing of humans in jacuzzi with for example cooking of potatoes, or compare exposure of humans to the sun with barbequing of meat. I am sure they would not survive several food treatments. The only reason for their comparison of irradiated food with chest x-rays for humans is to spread fear and distrust among consumers.

Contrary to Public Citizen I have trust in the WHO and believe that this agency will protect consumers and take care of public health issues. In a recent report "Bad Taste" (Worth, 2002) the executive summary of which is included in this packet, Public Citizen and GRACE accuse WHO of dismissing and misrepresenting evidence suggesting that irradiated food may not be safe for human consumption. However, careful reading of the report reveals that nothing remains of Mark Worth’s allegations. In a review requested by our Federal Ministry of Consumer Protection, Food and Agriculture in Germany (Delincée et al., 2002) we have shown that "Bad Taste" is a collection of allegations, half-truths, misunderstandings and misinterpretations. The tactic is used to emphasize studies with socalled adverse effects, and to claim that these experiments show the non-safety of the process. In the relevant publications of WHO (WHO, 1994, 1999) a number of tables are listed which summarize the toxicology experiments. In those tables it is mentioned whether the authors of the studies declared some adverse effects happening. Careful examination by the joint expert bodies, however, in comparison with many other studies which showed no adverse effects, made clear that most of the alleged adverse effects could be traced back to inadequate experimental conditions, e.g. an inadequate diet given to the laboratory animals, lack of vitamins, faulty statistical evaluations, etc.

It can be agreed that it may be really difficult to evaluate such complicated safety studies. In his section „Dissatisfaction with expert opinions“ it is well explained by Diehl (1995) that for this complicated task really experts are needed with an appropriate scientific background. Hundreds of data in an animal feeding study need to be taken into account. If e.g. an increase in tumors is observed for the animals receiving irradiated food as compared to non-irradiated food, the usual tumor rate and its variations for the applied animal strain needs to be considered. Maybe the increase is just accidental. Thus, evaluation is not a simple task. In addition, effects in scientific studies need to be consistently observed in an adequate number of experiments. They also need to be statistically significant. A scientific evaluation should consider the entire body of evidence, and not be based on a few selected studies.

All the older studies which Mark Worth (2002) refer to in „Bad Taste“ as exerting „adverse“ effects, have been carefully evaluated by the joint WHO expert groups. The whole body of scientific evidence has to be considered, the complete record, and not – as has been done in the report of Public Citizen – simply neglect the very large number of studies which yielded no adverse effects including the follow-up studies of those which caused concern and which were not able to reproduce the alleged adverse effects. Mark Worth has just picked out of the WHO tables (1994,1999) those studies mentioning some adverse effects – as reported by the authors – and has ignored the text in the WHO publications which explains that these effects cannot be relevant. Obviously, this is not a scientific approach.

We were able to clearly show in our evaluation to our ministry that Mark Worth made a number of mistakes by not reading the literature carefully enough. Similarly, a number of his statements just rely on misunderstandings and misinterpretations. Instead of solving the issues directly with the WHO, an unwarranted attack on this responsible agency has been launched. "Bad Taste" is not a responsible report from a conscious consumer organization which is concerned about public health, but is written to cause distrust and to spread fear among consumers.

The other reports which Public Citizen has included in this School Lunch packet are similar to „Bad Taste“, reporting long refuted studies. Public Citizen has not provided new evidence or new information that food irradiation is not safe nor nutritionally inadequate. They only stir up emotions by mere allegations and thus do a disservice to public trust. Exactly the opposite of what they should do as a consumer organisation. The only new information is their story on 2-alkylcyclobutanones (2-ACBs) which however is based on gross overstatements of our research. In our studies on 2-ACBs, we have observed toxic, genotoxic and even tumor-promoting activities of certain highly pure 2-ACBs (Burnouf et al., 2002). However, we always emphasized that these experimental data are inadequate to characterize a possible risk associated with the consumption of irradiated food. It is explicitly written in the English summary of our report (Burnouf et al., 2002) that „we warn against misuse of the data presented here, aiming at disqualifying food irradiation“ and also „Thus, at present on the basis of our results, it seems not appropriate to draw a final conclusion concerning to the risk associated with human consumption of irradiated fat-containing foods“. This is because our studies have been carried out only with highly pure substances and not with irradiated food containing a large number of complex components. Other food components may influence the reactions of 2-ACBs not evident from our experiments on purified 2-ACBs. It should also be pointed out that the amounts of 2-ACBs in irradiated foods are much lower than the concentrations tested in our studies.

Many food constituents expose some toxic properties when they are tested in isolation and at high concentrations. Food contains hundreds of components and every kind of processing will induce some changes in these components. Since analytical chemistry mainly looks for known analytes, we will never know all the chemical entities present in food, be it processed or not. The question is whether the food will exert a toxic effect after consumption. You can never avoid all potential risks in life. If you are concerned about the intake of potentially toxic substances, you should stop eating, drinking and breathing. Man's food contains quite a number of substances which exhibit some toxic properties – the alternative can simply not be to stop eating. You always have to balance the benefits against the risks. The crucial question is whether the benefits of food irradiation gained by inactivating harmful bacteria such as the dangerous E.coli O157:H7 will outweigh the possible risks. In my view – and this is also the opinion of WHO and other international and national organisations – the benefits far outweigh the risks.

References:

Burnouf, D., Delincée, H., Hartwig, A., Marchioni, E., Miesch, L., Raul, F., Werner, D. (2002) Etude toxicologique transfrontalière destinée à évaluer le risque encouru lors de la consommation d'aliments gras ionisés / Toxikologische Untersuchung zur Risikobewertung beim Verzehr von bestrahlten fetthaltigen Lebensmitteln. Eine französisch-deutsche Studie im Grenzraum Oberrhein. Rapport final / Schlussbericht INTERREG II.Projet / Projekt No. 3.171. (Marchioni, E., Delincée, H., Eds.) Berichte der Bundesforschungsanstalt für Ernährung, Karlsruhe, BFE-R--02-02, pp. 1-198. (also available at the web: http://www.bfa-ernaehrung.de/Bfe-Deutsch/Information/bfeber91.htm )

Delincée, H., Stahl, M., Ehlermann, D. (2002) Stellungnahme zu "Bad Taste", einer Broschüre der US Verbraucher-Organisation Public Citizen und Grace (verfasst von Mark Worth, veröffentlicht Oktober 2002), Review to the ministry of consumer protection, food and agriculture, December 2002.

Diehl, J.F. (1995) "Safety of irradiated foods", (2. ed.), Marcel Dekker, New York.

WHO (1994) Safety and nutritional adequacy of irradiated food. WHO, Geneva.

WHO (1999) High-dose irradiation: wholesomeness of food irradiated with doses above 10 kGy. Report of a Joint FAO/IAEA/WHO Study Group, Geneva. Technical Report Series 890.