All indications we have had, from officials and Ministerial letters, are that our governments intend to end irradiation labelling. In our view, improving and strengthening the existing deficient labelling and signage regimes should also be an option for the review.
Issues for consumers regarding removal of labelling include governmental conflicts of interest in approvals, the risk of misrepresentation of irradiated foods as fresh, testing for irradiation involves detecting changes to the food (proving it is a additive, rather than a benign process), current point-of sale signage is inadequate Health issues include: insufficient testing of safety, and new studies indicate nutrient loss and allergy issues.
The grounds for our request are based on the following unresolved matters:
Conflict of Interest: State Governments are a voting member of the Legislative and Governance Forum on Food Regulation but also represents the irradiation and horticulture industries’ points of view and promotes the use of irradiation technologies for food processing. The Government has a conflict of interest, as it is already a licence holder and also an applicant for A1092 to licence the irradiation of apple, apricot, cherry, nectarine, peach, plum,honeydew, rockmelon, strawberry, table grape and zucchini/scaloppini (squash). In contrast, the public have not been consulted despite our representations to various Ministers.
Processed or Fresh: Approved irradiation exposures for the processing of ‘fresh’ fruits and vegetables (tomatoes, capsicums, persimmons, mangoes, pawpaw, lychees, longan, rambutan, mangosteen, carambola, breadfruit, custard apples) is a minimum of 150Gy (equivalent to 1.5 million x-rays) and a maximum of 1KGy (equivalent to 10 million x-rays). These doses are delivered by exposure to fuel rods containing Cobalt 60 from Canadian nuclear reactors. FSANZ describes this as similar in effect to cooking but, even if that were true, it is misleading and deceptive to present a cooked food as unprocessed and fresh.
The test for irradiation is the presence of radiolytic products and free radicals. This shows that there are compositional changes of the kind that require labelling under Standard 1.5. FSANZ also confirms: “Irradiation potentially causes both macro and micronutrient changes in foods, depending on the irradiation dose, the food’s composition and environmental conditions.”
Insufficient History of Safe Use: Irradiated foods have not been in the human food supply in Australia and New Zealand for the 30 years that the Blewett Review recommended, before the labelling requirement is reviewed. Foods regulated under Food Standard 1.5 have a small or zero history of safe use in the human food supply. Thus, they must undergo pre-market assessment and must be labelled to meet shoppers’ right to know under Standard 1.5.3. We support the Standard.
Point of Sale Signage: The labelling regime for irradiated fruits and vegetables ought to be strengthened, not abolished. Point of sale signage is ineffective, as it does not fully inform shoppers. Even Country of Origin point of sale labels, which have been required for 8 years, are ineffective. The states have not enforced the signage requirements which fail to inform shoppers, even when they are highly motivated to select local produce. **
We see no evidence of irradiation labelling enforcement either. The current rules on irradiated food labelling should be maintained and strengthened, with the option for adding a label to individual fruit and vegetables being part of the brief for the FSANZ review.
False, Misleading and Deceptive: We will submit for ACCC assessment our strong view that removal of labels and signage from irradiated fruits and vegetables would create a set of false, misleading and deceptive circumstances for shoppers in Australia and New Zealand.
Until the ACCC has made its assessment, the Forum and FSANZ should give no further consideration to the review of irradiation labelling requirements.
A false and misleading situation would be created if the labelling requirement on irradiated foods were revoked, as shoppers would have no way to identify such processed foods.
Without an irradiation label, shoppers would have the false and misleading impression that fruits and vegetables in the market were fresh when they were actually processed. Irradiation is not comparable to freezing, for instance, as the permanent changes wrought by irradiation processing cannot be thawed out of the product.
Shoppers could no longer rely on appearances if irradiation labelling and signage were removed. Shoppers would falsely assume that fruits and vegetables, which appeared to be fresh, had not been processed and that their vitamins were intact. Customers would be deceived and misled as there is no readily available method or test to differentiate genuinely fresh fruits and vegetables from processed ones. FSANZ acknowledges that irradiation processes alter nutritional value, extend shelf life and sanitise treated foods.
Another matter for ACCC to resolve in advance will be the terms and conditions for a claim that a fruit or vegetable is “Irradiation-free” of “non-Irradiated”. ACCC developed a policy for such claims on genetically manipulated foods and it should do so for irradiated products too, before they come to market.
Unresolved Food Safety issues: The Animal Biosecurity Branch of the Commonwealth Department of Agriculture confirms that: “In 2008-9, 87 cats in Australia were reported to have developed severe neurological disease (chronic leucoencephalomyelopathy) associated with eating an imported, irradiated dry pet food. … The department … concluded that there was a reasonable body of evidence that gamma irradiation, applied as an adjunct quarantine treatment of pet food, was a contributing factor to the disease syndrome. ”Yet, FSANZ has not publicly assessed or reported on the implications for human health of this irradiated Canadian Orijen cat food. This must be resolved to public satisfaction before irradiated foods enter the market.
A recent study *** shows that smaller irradiation dosages (~1 Gy) can render protein more allergenic than either non-irradiated protein, or protein irradiated at a higher dosage. This is an ignored but potential emerging food safety risk associated with irradiation.
In light of these matters, we ask the ministers to ensure that the Forum and FSANZ postpone any review of irradiated food labelling and signage requirements until outstanding issues are publicly discussed and resolved to everyone’s satisfaction.
*** Vaz, A.F., et al., Low-dose gamma irradiation of food protein increases its allergenicity in a chronic oral challenge. Food Chem Toxicol., 2012. 51C: p. 46-52-doi: 10.1016/j.fct.2012.09.011.