Flash in the Pan

If you've been concerned about the push to irradiate food, a proposed Food and Drug Administration rule will make that a non-issue - by redefining what "irradiated food" means. According to a proposed rule notice in the April 4, 2007 Federal Register, the FDA is proposing to "revise its labeling regulations applicable to foods (including dietary supplements) for which irradiation has been approved by FDA." The agency wants to set labeling requirements so that "only those irradiated foods in which the irradiation causes a material change in the food, or a material change in the consequences that may result from the use of the food" need have the term "irradiated" on their labels.

What's a material change? According to this notice:

For purposes of this rulemaking, we are using the term ``material change'' to refer to a change in the organoleptic, nutritional, or functional properties of a food, caused by irradiation, that the consumer could not identify at the point of purchase in the absence of appropriate labeling.

Quite a mouthful, in a manner of speaking. Breaking things down a bit, organoleptic in this context means something that people can perceive by their senses: sight, sound, taste, smell, or touch. Organoleptic properties would mean, then, how the food looks, smells, tastes, and feels. (Hopefully your food isn't making whimpering noises as you eat.) Nutritional properties would mean the caloric content, vitamins, minerals, protein, fats, and so on. Functional properties are how you use the food.

In other words, so long as they are not obvious, the changes aren't material and, therefore, the food needn't be labeled as irradiated. For those companies that have to admit to some noticeable change in the food, the agency wants to allow them to "petition FDA for use of an alternate term to ``irradiation'' (other than `pasteurized')." That's currently allowed under law. Under the right conditions, the FDA will even allow the use of the term pasteurized.

A number of governments have come out in favor of allowing irradition as a way of treating food. Proponents claim that the FDA has reviewed of "hundreds of studies" and found the process to be safe. For a different view, here's what Public Citizen has to say. I haven't yet checked the claims against the citations of evidence, and, to be fair, I have at times found organizations of all sorts drawing conclusions from studies that could not logically be drawn.

The labeling issues around irradiating foods had been around since 1984 - a number that, given the redefinitions of language we're seeing, some might find ironic in an Orwellian sort of way. Since then, companies in the food business have been climbing all over themselves to find another solution, because businesses don't want to advertise that they expose their food products to radiation as many consumers react negatively. By the late 90s, the FDA was already trying to soften the labeling requirements disclosing radiation and, in 1999, the agency solicited comments on other terms that could be used. Some in industry suggested "cold pasteurization" or "electronic pasteurization." Some filing comments objected to these terms, contending that they would only serve to obfuscate.

In May 2002, President Bush signed into law the Farm Security and Rural Investment Act. Among other things, FSRIA effectively changed the definition of the term pasteurization and directed the FDA:

"to publish for public comment proposed changes to the current regulations relating to the labeling of foods that have been treated by irradiation using radioactive isotope, electronic beam, or x-ray to reduce pest infestation or pathogens."

So this proposed ruling is just another step in a long process to weaken previous irradiation labeling requirements so much that they would effectively become meaningless. For a good understanding of the reason that irradiation and its commercial ramifications have come into play, consider how many stories of food contamination the past six months have brought. When things go wrong, industry can fix the basic processes to eliminate the problems, or it can try erradicating the symptoms. If you can irradiate food and destroy pathagens (though you may not understand what unintended consequences the action would bring), then you don't have to spend the money to literally clean up your act.