ACTION ALERT:  LAST CHANCE TO STOP FOOD IRRADIATION
COMMENTS TO FDA NEEDED BEFORE MAY 18
PLEASE PUBLICIZE THIS ISSUE

        The FDA is planning to remove all current labeling 
requirements for irradiated food.  The FDA has approved irradiation for essentially all
foods, including fruits and vegetables.  Without labeling, there will 
be no way for you to know if your food has been irradiated.  If labels are
eliminated now, only a public health catastrophe can reinstate them.
Irradiated foods could be on your table within a year-some facilities
already exist, and hundreds more could be built.
        The labeling requirement has been the sole impediment to 
widespread use of irradiation.  Irradiation proponents fear that even the current
requirement -- a tiny statement no bigger than the ingredients, and no
statement at all for irradiated components of mixed food -- will scare
consumers.  The FDA proposal to remove labeling practically begs for
'consumer focus' studies that will tell it how to 're- educate' the 
77% of  the public that does not want irradiation.
        Irradiation has powerful friends in the food processing and 
nuclear industries, the medical establishment, and the Federal government.  
For several years they have been engaging in a covert public relations 
campaign to convince us that irradiation is the answer to food safety problems, 
like contaminated Guatemalan raspberries and lunch meats.  But if you look 
at the news, these problems are overwhelmingly concentrated in the meat 
and poultry processing business.  Jack-in-the-Box and Hudson Foods lost a 
lot of money. Irradiation is really just a quick (and temporary) fix for 
poor slaughterhouse sanitation, and a way of disposing of nuclear wastes by
selling them to private industry and leaving the taxpayers to fund the
inevitable clean-up costs.
        It is completely unethical to impose irradiation on people who 
do not want it in order to protect the factory-farmers from the 
consequences of their business practices.
        And the FDA is trying to keep this issue out of the spotlight 
-- it won't post comments on the Internet.

WHAT YOU CAN DO:
        Send a comment to the FDA demanding prominent labeling, the 
use of the terms "irradiation" or "irradiated" and the use of the
radura symbol.  Tell the FDA you feel proposed alternative terms such as "cold
pasteurization" and "electronic pasteurization" are misleading
and should not be used.  Say that the absence of a statement would be misleading
because irradiation destroys vitamins and causes changes in sensory 
and spoilage qualities that are not obvious or expected by the consumer.  

A general statement opposing irradiation will NOT help, because the FDA
requests comments on only two issues:
"1)  Whether the wording of the current radiation disclosure statement
should be revised; and,
2)  whether such labeling requirements should expire at a specified 
date in the future."
(Please read the document following the next set of double lines 
before
writing).

The complete proposal is at:
      http://www.fda.gov/ohrms/dockets/98fr/021799a.txt

Send comments before May 18, 1999 to:
        Dockets Management Branch (HFA-305)
        Food and Drug Administration
        5630 Fishers Lane, Room 1061
        Rockville, MD  20852.


Refer to Docket #98N-1038, "Irradiation in the production, processing 
and handling of food."  E-mail is discouraged, because garbled messages 
will be discarded, and e-mail is MUCH less effective than a letter. Send 
e-mail to:
      FDADockets@oc.fda.gov  and/or
      FDADockets@fda.gov
and put the docket number in the "Subject" line.

        Send a copy of your letter to your congressperson and your
senators, and tell them that as your representatives, they are 
responsible for representing you, and you don't want to eat irradiated foods in 
any form.  At the very least, these foods should be prominently labeled, 
and all irradiated components of a food should be identified.
        Contact the media in your area (alternative weeklies, food
sections, public radio, talk radio) and tell them to report on this 
story.  Tell them you don't want to eat irradiated foods, and why irradiation 
is a risky technology.

ACT NOW! THIS IS OUR LAST CHANCE!!
        If the FDA eliminates labeling, U.S. exporters of irradiated 
foods will be able to successfully claim that other countries' labeling laws 
are "restraint of trade" under international trade rules. Our actions now
are critical!

-----------------------------------------------
INSTRUCTIONS AND BACKGROUND FOR SENDING A COMMENT TO THE FDA PLEASE 
READ!!

WHAT KIND OF LETTER TO WRITE AND WHY

IF YOU ARE WRITING AS AN INDIVIDUAL, SEND ONE COPY TO THE FDA; 
OTHERWISE,
SEND TWO COPIES.
        If you have any expertise or personal status that bears on the
issue (e.g., you are a physician, scientist, chef, farmer, food
manufacturer, parent), state it in your comment.
        Please note that the FDA is only asking for comments on the 
issues of:
1)  whether labeling of irradiated foods should remain; and,
2)  if so, what kind of label.

The FDA has already decided that irradiation is 'safe'; the 
irradiation advocates in the medical establishment, big agriculture, the nuclear
industry and Congress know that labels frighten consumers.  The 
irradiators know that most consumers do not want irradiated foods (77% according 
to a CBS poll in 1997).
        But in November 1997, President Clinton signed into law a
Congressional bill reducing the size of the irradiation label.  As an
agency overseen by Congress, the FDA is only able to ask what kind of
labeling it should require. This is NOT the time to tell the FDA you 
are against irradiation.  In fact, if you state that you don't want to eat
irradiated food and that labels will help you avoid it, you will give 
the FDA more reason to eliminate labeling (because the FDA has already 
decided irradiation is safe, and it doesn't want to scare people).  We must 
play the FDA's game -- use its own arguments in favor of labeling.
        The sample letters stress that the FDA's original reason for
labeling is still valid -- that irradiation is a process that can 
change the texture, taste, storage characteristics and nutrients of a food 
and should therefore be disclosed to avoid misleading the consumer.  
The FDA proposal is posted at:
       http://www.fda.gov/ohrms/dockets/98fr/021799a.txt

Feel free to alter the sample letters as desired.

IMPORTANCE OF ACTING NOW
        This really is our last chance to stop food irradiation.  If
labeling is eliminated, hundreds more irradiation facilities will be 
built.  Once built, they have to be used. Not just meat and poultry, but 
fruits and vegetables will be irradiated. And one of the two materials 
commonly used for irradiating foods is radioactive for 600 years.  Do you trust 
any business to be responsible for that long?
        Our actions today have global consequences:  the Codex
Alimentarius, the international rule for trade in food, requires 
labeling of irradiated foods. If the United States eliminates its requirement, 
U.S. food exporters, under the General Agreement on Tariffs and Trade 
(GATT), can say that the Codex's requirements are a restraint of trade. And 
the exporters will prevail. Other countries that want labeling of imported
irradiated foods will not be permitted to require it.
        So it is essential that we write opinion pieces and letters to 
the editor, inform journalists, contact our Congressional representatives 
and senators, get on talk radio, and tell our families and friends.  Most
people don't want irradiation, and they don't like the government 
taking away their freedom of choice. We only have to let enough people know.

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SAMPLE LETTER #1

Date:

Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, Maryland  20852

Re: Docket # 98N-1038, "Irradiation in the Production, Processing, and
Handling of Food"

To whom it may concern:

        The FDA should retain the current labeling law, the current
terminology of "treated with radiation" or "treated by
irradiation," and the use of the radura symbol on all irradiated whole foods.
        Regarding the issue of labeling, in its initial petition, the 
FDA concluded that irradiation was a "material fact" about the processing
of a food, and thus should be  disclosed.  The material fact remains; 
therefore, labeling should remain. Consumer acceptability, storage qualities and
nutrients are affected. Some irradiated foods have different texture 
and spoilage characteristics than untreated foods.  Most fruits and 
vegetables have nutrient losses that are not obvious or expected by the consumer.
        In addition, processing by irradiation causes chemical changes 
that are not evident and are potentially hazardous.  Meat may have a higher
level of carcinogenic benzene.  All irradiated foods contain unique
radiolytic products that have never been tested.
        Whether or not the FDA has approved irradiation as safe, it 
remains a new technology with no long-term human feeding studies.  Consumers
certainly have a right to know if this process has been used on their 
food.
        As to the kind of label used, I believe that label should be 
large enough to be readily visible to the consumer, on the front of the 
package.  The label contains important information regarding the processing of 
the contents.  For displayed whole foods such as produce, a prominent
informational display similar to that used for meats should be used 
(but containing the term "irradiation" and the radura).
        Because of the newness of the technology and the need to 
assess the public health effects of widespread use of irradiated foods, I believe 
that the FDA's labeling requirement should not be permitted to expire.

        Yours truly,
---------------------------------------------
---------------------------------------------
SAMPLE LETTER #2

Date:

Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, Maryland  20852

Re: Docket No. 98N-1038, Irradiation in the Production, Processing, 
and
Handling of Food

To whom it may concern:

        I support the recommendation by the Center for Science in the
Public Interest regarding labeling of irradiated foods:
        "any foods, or any foods containing ingredients that have been
treated by irradiation, should be labeled with a written statement on 
the principal display panel indicating such treatment.  The statement 
should be easy to read and placed in close proximity to the name of the food and
accompanied by the international symbol.  If the food is unpackaged, 
this information should be clearly displayed on a poster in plain view and
adjacent to where the product is displayed for sale."
        Like other labels, irradiation labels are required by FDA to 
be truthful and not misleading.  I believe that the terms "treated with
radiation" or "treated by irradiation" should be retained.  Any
phrase involving the word "pasteurization" is misleading because
pasteurization is an entirely different process of rapid heating and cooling.
        I recognize the radura as information regarding a material 
fact of food processing.  The requirement for irradiation disclosure (both 
label and radura) should not expire at any time in the future.  The material 
fact of processing remains.  Even if some consumers become familiar with 
the radura, new consumers (e.g., young people, immigrants) will not be.  
The symbol should be clearly understandable at the point of purchase for 
every one.  If there is no label, consumers will be misled into believing 
the food has not been irradiated.
        I urge you to place the comments received on the Internet so 
that the public can be informed about who is participating in this comment 
process.

Sincerely,



-----------------------
This action alert has been generated by:
The Campaign for Food Safety (formerly known as the Pure Food 
Campaign)
860 Highway 61
Little Marais, Minnesota  55614
For more information on irradiation:
(213) 387-5122  or
      doder@hsc.usc.edu
Web page with links and background:
      http://www.purefood.org