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PREVENTING PATHOGENIC FOOD POISONING: SANITATION NOT IRRADIATION

Samuel S. Epstein and Wenonah Hauter

Bacterial food poisoning can be readily prevented by long overdue basic sanitary measures rather than by ultrahazardous irradiation technologies.

The food and nuclear industries, with strong government support, have capitalized on recent outbreaks of pathogenic E.coli 0157 meat poisoning to mobilize public acceptance of large scale food irradiation.  Already, the Food and Drug Administration (FDA) is allowing the use of high-level radiation to “treat” beef, pork, poultry, eggs, vegetables, fruit, flour and spices, while the United States Department of Agriculture (USDA) proposes the imminent irradiation of imported fruit and vegetables.

Caving in to powerful corporate industry interests, both House and Senate Appropriations Committees have recently proposed to sanitize the FDA’s already weakened labeling requirements for irradiated food by eliminating the word “irradiated” in favor of “electronic pasteurization” (1); this term was proposed by the San Diego based Titan corporation, an erstwhile major defense contractor using highly costly linear accelerator “E-beam” technology, originally designed for President Reagan’s “Star Wars” program, which shoots food with a stream of electrons travelling at the speed of light.  However, the proposed electronic pasteurization label is a euphemistic absurdity, especially since the FDA’s approved meat radiation dosage of 450,000 rads  is approximately 150 million times greater than that of a chest X-ray, besides circumventing consumers’ fundamental right to know.

             Furthermore, the new labeling initiative is reckless.  Irradiated meat is a very different product from cooked meat.  Whether irradiated by linear accelerators or pelletized radioactive isotopes, the resulting ionizing radiation produces highly reactive free radicals and peroxides from unsaturated fats.  U.S. Army analyses in 1977 revealed major differences between volatile chemicals formed during irradiation or cooking meat (2).  Levels of the carcinogen benzene in irradiated beef were found to be some tenfold higher than cooked beef.  Additionally, high concentrations of six poorly characterized “unique radiolytic chemical products”  admittedly “implicated as carcinogens or carcinogenic under certain conditions,”  were also identified (2).

Based on these striking changes in the chemistry of irradiated meat, FDA’s 1980 Irradiated Food Committee explicitly warned that safety testing should be based on concentrated extracts of irradiated foods, rather than on whole foods, to maximize the concentration of radiolytic products (3).  This would enable development of sufficient sensitivity essential for routine safety testing.  In 1984, Epstein and Gofman more specifically urged that “stable radiolytic products could be extracted from irradiated foods by various solvents which could then be concentrated and subsequently tested.  Until such fundamental studies are undertaken, there is little scientific basis for accepting industry’s assurances of safety” (4).  In an accompanying editorial comment, FDA was quoted as admitting that “it is nearly impossible to detect (and test radiolytic products) with current techniques” on the basis of which the agency’s claims of safety and regulatory abdication still persist (5).

While refusing to require standard toxicological and carcinogenicity testing of concentrated extracts of radiolytic products from irradiated meat and other foods, FDA instead has relied on some five studies selected from 441 published prior to the early 1980’s, on which its claims of safety still remain based.  However, the chair of FDA’s Irradiated Food Task Committee which reviewed these studies insisted that none were adequate by 1982 standards (6), and even less so by the 1990’s (7).  Furthermore, detailed analysis of these studies revealed that all were grossly flawed and non-exculpatory (8).

             These results are hardly surprising since a wide range of independent studies prior to 1986 clearly identified mutagenic and carcinogenic radiolytic products in irradiated food, and confirmed evidence of genetic toxicity in tests on irradiated food (9).  Studies in the 1970’s, by India’s National Institute of Nutrition, reported that feeding freshly radiated wheat to monkeys, rats, mice and to a small

group of malnourished children induced gross chromosomal abnormalities in blood or bone marrow cells, and mutational damage in the rodents (10).

             Food irradiation results in major micronutrient losses, particularly vitamins A, C, E, and the B complex (11).  As admitted by the U.S. Department of Agriculture’s (USDA) Agriculture Research Service, these losses are synergistically increased by cooking, resulting in “empty calorie” food (12); this is a concern of major importance for malnourished populations.  Radiation has also been used to clean up food unfit for human consumption, such as spoiled fish, by killing odorous contaminating bacteria.

            While the USDA is strongly promoting meat and poultry irradiation, it has been moving to deregulate and privatize the industry by promoting a self-policing Hazard Analysis and Critical Control Point (HACCP) control program (13); in late 2000, the agency will start a rulemaking process to privatize meat inspection. Moreover, the Department of Energy (DOE) continues its decades long aggressive promotion of food irradiation as a way of reducing disposal costs of spent military and civilian nuclear fuel by providing a commercial market for cesium nuclear wastes.

Irradiation facilities using pelletized isotopes pose risks of nuclear accidents to communities nationwide from the hundreds of facilities envisaged for the potentially enormous radiation market; in contrast to nuclear power stations, these facilities are small, minimally regulated, unlikely to be secure, and require regular replenishment of cobalt (Co-60) or cesium (Cs-137) isotopes, entailing nationwide transportation hazards.  Furthermore, linear accelerators, besides plants using radioactive isotopes, pose grave hazards to workers and are subject to virtually no regulation (9, 14).

The track record of the irradiation industry is, at best, unimpressive.  Robert Alvarez, former DOE Senior Policy Advisor, recently warned that the Nuclear Regulatory Commission files are bulging with unreported documents on radioactive spills, worker over-exposure, and off-site radiation leakage (15).  Strangely, the Environmental Protection Agency has still failed to require an Environmental Impact Statement prior to the siting of food irradiation facilities.

The focus of the radiation and agribusiness industries is directed to the highly lucrative cleanup of contaminated food rather than to preventing contamination at its source (16).  However, E. coli 0157 food poisoning can be largely prevented by long overdue improved sanitation.  Feedlot pen sanitation, including reducing overcrowding, drinking water disinfection and fly control, would drastically reduce cattle infection rates.  Moreover, E. coli 0157 infection rates could be virtually eliminated by feeding hay, rather than the standard unhealthy starchy grain diet, for seven days prior to slaughter (17).  Sanitation would also prevent water contamination from feed lot run off, incriminated in the recent outbreak of E. coli 0157 poisoning in Walkerton, Ontario (18); run off will remain a continuing threat even if all meat was irradiated.

Pre-slaughter, post-knocking and post-evisceration sanitation at meat packing plants is highly effective for reducing carcass contamination rates (16).  Testing pooled carcasses for E. coli 0157 and Salmonella contamination is economical, practical, and rapid.  The expense of producing sanitary meat would be trivial compared to the high costs of irradiation, including possible nuclear accidents, which would be passed on to consumers.  Additional high costs are likely to result from an anticipated international ban on the imports of irradiated U.S. food, and also from losses of tourist revenues.

             We charge that support of the “electronically pasteurized” label by the food and radiation industries, governmental agencies, and Congress, is a camouflaged denial of citizen’s fundamental right to know.  Rather than sanitizing the label in response to special interests, Congress should focus on sanitation and not irradiation of the nation’s food supply.

Note – This article is largely based on a June 6, 2000 P.R. Newswire press release by the Cancer Prevention Coalition and Public Citizen.

REFERENCES

1.        Congress Pressures FDA For Softer Labeling Of Irradiated Foods.  FDA Week, p. 9-10, May 12, 2000.

2.        Federation of American Societies for Experimental Biology, Evaluation of The Health Aspects of Certain Compounds Found in Irradiated Beef.  Report to the U.S. Army Medical Research and Development Command, Bethesda, MD, August 1977.

3.        U.S. Food and Drug Administration.  Recommendations for Evaluating the Safety of Irradiated Food.  Final Report of FDA’s Irradiated Food Committee.  Washington, D.C.,  July 1980.

4.        Epstein, S. S., and Gofman, J. W.  Irradiation of food.  Science 223:1354, 1984.

5.        Sun, M.  Science 223:1354, 1984.

6.        van Gemert, M.   Memorandum Re: Final Report of the Task Group for the Review of Toxicology Data on Irradiated Food. April 9, 1982.

7.        van Gemert, M.  Letter to New Jersey Assemblyman John Keller, October 19, 1993.

8.        Public Citizen’s Critical Mass Energy and Environment Program and the Cancer Prevention Coalition.  A Broken Record:  How the FDA Legalized and Continues to Legalize Food Irradiation Without Testing it for Safety.  Special Report, October 2000.

9.        Piccioni, R.  Food irradiation: contaminating our food.  Ecologist 18(2):48-55, 1988.

10.     Vijayalaxmi, and Srikantia, S. G.  A review of the studies on the wholesomeness of irradiated wheat conducted at the National Institute of Nutrition, India.  Radiat. Phys. Chem. 34(6):941-952, 1989.

11.     Murray, D. R.  Biology of Food Irradiation.  RSP Research Studies Press Ltd., Taunton, Somerset, England, 1990.

12.     Food Chemical News, Irradiation compounds vitamin loss from cooking, ARS Reports.  November 10, 1986, p. 42.

13.     USDA Food Safety Inspection Service, Irradiation of Red Meat: A Complication of Technical Data for its Authorization and Control.  International Consultative Group on Food Irradiation, August, 1996.

14.     Trager, E. A.  Review of events at large pool-type irradiators.  Office of Analysis and Evaluation of Operational Data, U.S. Nuclear Regulatory Commission, Washington, D.C., March, 1989.

15.     Alvarez, R.  Food irradiation: 50 years of hollow promises.  Bull. Atom. Sci. 2000, in press.

16.     Elder, R. O. et al.  Correlation of enterohemorrhagic E.coli 0157 prevalence in feces, hides and carcasses of beef cattle during processing.  Proc. Nat. Acad. Sci. 97(7):2999-3003, 2000.

17.     Diaz-Gonzalez, F. et al.  Science 281:1666-1668, 1998.

18.     Analysis of Ontario E.coli Walkerton pollution disaster.  The Gallon Environmental Letter, Montreal, Quebec, May 2000.

ENDORSEMENTS

Robert Alvarez, Former Senior Policy Advisor to the Secretary of Energy and Executive

                  Director the STAR Foundation

Kenny Ausubel, Collective Heritage Institute/Bioneers, Santa Fe, NM

Dr. Neal Barnard, President Physicians Committee for Responsible Medicine, Washington, DC

Tewolde Berhan and Sue Edwards, Institute for Sustainable Development, Addis Ababa, Ethiopia

Dr. Rosalie Bertell, International Institute of Concern for Public Health, Toronto, Canada

Barbara Brenner, J.D. Executive Director Breast Cancer Action, San Francisco, CA

Dr. Barry Castleman, Environmental Consultant, Baltimore, MD

Vera Chaney, Green Network, Leyden, Colchester, Essex, U.K.

Citizens Concerns, USA

Ronnie Cummins, National Director Organic Consumers Association, Little Marais, MN

Dr. Donald Dahlsten, Professor and Associate Dean, University of California, Berkeley, CA

Dr. Robert Elder, Senior Microbiologist Neogen Co., Lansing, MI, formerly Senior Scientist

                  Agricultural Research Service, USDA

Margarita Florez, Instituto Latinoamericano de Servicios Legales (ILSA), Columbia

Dr. John Gofman, Emeritus Professor Molecular and Radiation Biology, University of

                  California, Berkeley, CA

Edward Goldsmith, M.A., Publisher and Editor The Ecologist, London, U.K.

Dr. Jay M. Gould, Director Radiation and Public Health Project, USA

Randall Hayes, President Rainforest Action Network, USA

Luc Hens, M.D., Professor Department of Human Ecology, Brussels Free University, Belgium

Dr. Mae-Wan Ho, Director Institute of Science in Society, The Open University, Milton

                  Keynes, U.K.

Jeffrey A. Hollender, President Seventh Generation, Burlington, VT

Dr. Vyvyan Howard, Professor Pathology, University of Liverpool, U.K.

S. M. Mohamed Idris, President, Consumers’ Association of Penang, Sahabat Alam Malaysia (Friends of the Earth Malaysia) and Institute Masyarakat Berhad, Penang, Malaysia

Martin Khor, Director Third World Network, Penang, Malaysia

Dr. David Kriebel, Professor Epidemiology, University of Massachusetts, Lowell, MA

Lynn Landes, Founder and Director Zero Waste America, Yardley, PA

Dr. Marvin Legator, Professor Preventive Medicine, University of Texas, Galveston, TX

Rabbi Michael Lerner, Ph.D., Editor TIKKUN Magazine, San Francisco, CA

Dr. William Lijinsky, former Director Chemical Carcinogenesis, Frederick Cancer Research

                  Center, MD

Dr. E. Lichter, Professor Community Medicine, University of Illinois Medical School, Chicago

                  IL

Dr. Donald Louria, Chairman Department Preventive Medicine, New Jersey Medical School,

                  Newark, NJ

Dr. Sheldon Margen, Emeritus Professor Public Health Nutrition, University of California,

                  Berkeley, CA and Chairman of the Berkeley Wellness Letter

George Monbiot, Health and Science Columnist, The Guardian, London, U.K.

Raymond Monbiot, Fellow of the Marketing Society, London, U.K.

Dr.  Vicente Navarro, Professor Health and Public Policy, The Johns Hopkins University,

                  Baltimore, MD, and Professor Political and Social Sciences, University Pompeu Fabra,

                  Spain

Dr. Herbert L. Needleman, Professor Pediatrics and Psychiatry, University of Pittsburgh,

                  Pittsburgh, PA

Debbie Ortman, National Field Organizer, Organic Consumers Association, Duluth, MN

Dr. Peter Phillips, Professor Sociology, Sonoma State University, Rohnert Park, CA

Dr. Robert Rinehart, Emeritus Professor Biology, San Diego State University, CA

Dr. Janette Sherman, Research Associate Radiation and Public Health Project, and Adjunct

                  Professor Department of Sociology, Western Michigan University, MI

Dr. Vandana Shiva, Director Research Foundation for Science, Technology and Natural

                  Resource Policy, Dehradun, India

Dr. George Tritsch, Cancer Research Scientist, Roswell Park Memorial Institute, New York

                  State Department of Health, NY

Stephen L. Tvedten, CEO Get Set, Inc., President of the Institute of Pest Management, Marne, MI

Dr. Vijayalaxmi, Associate Professor Department Radiation Oncology, University of Texas

                  Health Science Center, San Antonio, TX

Frank D. Wiewel, President People Against Cancer, Otho, IA

Dr. Gesa Staats de Yanes, Professor Fetal and Infant Pathology, University of Liverpool, U.K.

Dr. Quentin Young, past President American Public Health Association, Chicago, IL

NOTE:  Additional endorsements by activist groups and scientists, nationally and internationally, would be welcome. 

Direct reprint requests and further endorsements to:

Dr. Samuel S. Epstein

Emeritus Professor Environmental Medicine,

and Chairman the Cancer Prevention Coalition

University of Illinois School of Public Health

2121 W. Taylor St., Chicago, IL 60612

Wenonah Hauter

Public Citizen

Critical Mass, Energy and Environment Program

215 Pennsylvania Avenue, S.E., Washington, D.C., 20003

FDA urged to ban feeding of chicken feces to cattle

Food and consumer groups say the practice increases the risk of cattle becoming infected with mad cow disease. A beef industry trade group say a ban isn’t needed.

By Jerry Hirsch
 
출처 : LA타임즈 October 31, 2009
http://www.latimes.com/business/la-fi-feed31-2009oct31,0,1227725.story?track=rss

A fight is brewing over the practice of feeding chicken feces and other poultry farm waste to cattle.

A coalition of food and consumer groups that includes Consumers Union and the Center for Science in the Public Interest has asked the Food and Drug Administration to ban the practice. McDonald’s Corp., the nation’s largest restaurant user of beef, also wants the FDA to prohibit the feeding of so-called poultry litter to cattle.

Members of the coalition are threatening to file a lawsuit or to push for federal legislation establishing such a ban if the FDA doesn’t act to do so in the coming months.

Farmers feed 1 million to 2 million tons of poultry litter to their cattle annually, according to FDA estimates.

Using the litter — which includes feces, spilled chicken feed, feathers and poultry farm detritus — increases the risk of cows becoming infected with bovine spongiform encephalopathy, or mad cow disease, said Michael Hansen, a senior scientist at Consumers Union.

That’s because the spilled chicken feed and the feces contain tissue from ruminants — cows and sheep, among other mammals. The disease is transmitted through feeding ruminant remains to cattle.

“It takes a very small quantity of ruminant protein, even just 1 milligram, to cause an infection,” said Steve Roach, public health program director with Food Animal Concerns Trust, a Chicago-based animal welfare group that is part of the coalition.

Although it is rare, people can contract a fatal form of the disease by eating meat from cows with BSE.

The National Cattlemen’s Beef Assn., the beef industry’s main trade group, said the ban was not needed and that several FDA reviews had determined that the chance of cattle becoming infected with mad cow disease from eating poultry litter was remote.

“Science does not justify the ban, and the FDA has looked at this now many times,” said Elizabeth Parker, chief veterinarian for the trade group.

Parker noted that the FDA this year banned the use of certain types of tissue from any form of animal feed, even that eaten by chickens. Those tissues include brain, spinal cord material and other high-risk tissues where the pathogens believed to cause mad cow disease typically are found. The tissue ban greatly reduces chances that prions, implicated in mad cow, can find their way into the food chain, Parker said. She also said the disease was not a threat to public health.

“We have tested 800,000 cattle in recent years and have not found any evidence of BSE circulating in the herd,” Parker said.

But others remain concerned.

“I still think you need to totally restrict using any ruminant protein in feed that gets back to ruminants,” said Linda Detwiler, a food safety consultant and former U.S. Department of Agriculture veterinarian.

Prohibiting high-risk tissues as a feed source makes the chances of transmitting mad cow disease through poultry litter low but does not remove all risk, Detwiler said.

The practice also makes McDonald’s, one of the nation’s biggest beef purchasers, nervous. “We do not condone the feeding of poultry litter to cattle,” it said in a statement.

The issue has kicked around since the first U.S. case of mad cow disease was discovered almost six years ago in an animal imported from Canada. There have been two known indigenous cases of mad cow infections in domestic cattle since then, but both were in animals born before the enactment of stricter regulation of feed.

Generally, the FDA has left the decision on whether to feed cattle poultry litter up to state regulators. California allows the practice with one exception: Poultry litter is banned in feed for lactating dairy cows.

In 2004, the FDA announced its intention to prohibit the use of poultry litter in cattle feed, but after reviewing the proposed ban decided against it. The agency said its rules prohibiting the use of high-risk tissues in all animal feed were sufficient to keep mad cow pathogens from reaching poultry feed. The FDA also said there was little risk to human or cattle health from the other components of poultry litter.

“With respect to pathogenic microorganisms, drug residues and contaminants in poultry litter, FDA is not aware of any data showing that the use of poultry litter in cattle feed is posing human or animal health risks that warrant restrictions on its use,” the agency said.

But Hansen, the Consumers Union scientist, said that besides the mad cow risk, the feed can contain disease-causing bacteria, antibiotics and even foreign objects such as dead rodents, rocks, nails and glass.

Such hazards are not eliminated by any processing of the feed that might occur, he said.

Feeding farm animals feces may sound gross, but it goes back to the dawn of animal agriculture, said Dean Cliver, professor emeritus of food safety at UC Davis.

“In the old days when people had mixed farms, what came out the back end of the cows was eaten by pigs, and what came out the end of pigs was eaten by chickens. That was the natural way of farming,” he said. “Anything that hit the ground was fair game.”

jerry.hirsch@latimes.com

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