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Marler Blog Providing Commentary on Food Poisoning Outbreaks & Litigation

Should Irradiation be adopted by FSIS and the meat industry as another method of minimizing bacterial contamination on animal carcasses?

An interesting question and one that long needs answering.

Thus far I have found a dearth of negative research on the topic. In 2005 the American Meat Institute Petitioned FSIS “To Recognize the Use of E-Beam on Carcasses as a Processing Aid” and attached studies seem clearly to indicate that this is an effective technology in reducing the risks of bacterial contamination from carcasses. In late 2008, a Presentation on the topic was given both in written form and by the below PowerPoint (click on immage). A transcript of the Presentation is also available.

The real questions are:

1. Is the technology effective in killing bacteria?
2. Is the technology safe to humans and the environment? And,
3. Should the meat so produced be labeled with some type of irradiation designation?

I think the answers are yes, yes and yes.

Input from readers?

  • doc

    Yes, yes and no

  • Those against using irradiation (either gamma or electron beam) have often argued that its use will allow unscrupulous manufacturers to become more careless in their process control, effectively allowing them to clean up the mess.
    This argument ignores the fact that an irradiation plant is an expensive piece of equipment; fly-by-night operators will not spend this kind of money to pass off poor quality foods.
    The benefits can be great: low dose radiation can reduce the spoilage and pathogenic microorganisms on the surface of carcasses or fruits and vegetables, rendering the food safer and extending shelf life.
    I have seen claims that irradiation produces chemicals that do not occur naturally in foods. This is true. But it is the case for just about every other type of food processing too. This is a poor argument to use against food irradiation.
    On that basis, my response is Yes, Yes and Yes – the latter because consumers need to know how their food has been processed and to have the informed choice to buy it or not.

  • 1. Yes can be
    2. Yes,can be
    3. Personally, I don’t care. Congress made irradiation an additive in 1958. That was a mistake. Maybe the movies “Them” and the “The Amazing Colossal Man” scared the bejezzus out of them. IMHO, irradiation is a treatment . . .like heat. Congress should make the change . . . or designate heat as an additive. I mean heat destroys vitamins, twists proteins, and forms mutagens. =8^O

  • Larry Andrew

    Two more questions”
    1. If it effectively eliminates ecoli, shouldn’t it be required?
    2. If hamburger was irradiated, would you eat it?

  • Michele

    Yes, yes, and yes; but the label should include a statement of purpose: “irradiated to kill harmful pathogens.” Safe handling instructions would still be needed, but clearly the technology is a safe and effective way to reduce pathogens in the food supply. Given that other methods are apparently not sufficient (for example, HACCP, pathogen testing, farm practices) since we see numerous outbreaks and recalls year after year, it makes no sense not to add this technology into processing. Ultimately, those who oppose industry using irradiation based on superstition and non-factual safety/environmental beliefs are contributing to illnesses and deaths by denying consumers the choice of buying foods with this added protection.

  • William Thomas

    No, no, and no; Anyone remember when they said they were going to give antibiotics to farm animals and birds and they said it was safe. And now it has come back to haunt us.

  • Yes, yes yes. However, I think the same proponents of drinking raw milk will come forward against this procedure, even without compelling evidence of its harm. And once a person’s mind is made up (don’t really want to call them unreasonable- ?) they will not listen to any arguments of the benefits of irradiation, however safe the process may be.

  • Yes, yes, yes. And in reply to Larry Andrews, No and Yes.
    I am inclined toward James Marsden’s Cantaloupe analogy. Decontamination of meat should be moved as far upstream in the process as possible. And the means of decontamination should not be limited to irradiation. I am in favor of a range of effective options.
    Phyllis Entis

  • Pat Buck

    RE: Comments on AMI’s petition for “Irradiation as a Processing Aid” Notice found at 73 Federal Register 52001 (September 8, 2008)
    The Center for Foodborne Illness Research & Prevention (CFI) appreciates the opportunity to comment on USDA’s Food Safety & Inspection Service public meeting held on September 18, 2008, to discuss the use of low dose, low penetration, electron beam irradiation on chilled beef carcasses. These are CFI’s initial comments on this topic and should not be considered complete.
    CFI is a national, nonprofit health organization dedicated to preventing foodborne illness through research, education, advocacy and service. Founded in 2006, CFI hopes to lead America in creating innovative, science-based solutions for the food challenges of the 21st Century. CFI’s programs and activities are designed to develop better food protections for all Americans. CFI believes that federal, state and local government, as well as farmers; food processors/distributors/
    retailers; medical providers; educators; policy makers and consumers share the responsibility of building an environment that promotes food safety throughout the farm to fork continuum. No one sector can achieve this goal alone, so CFI is committed to collaboration in its efforts to improve food safety.
    Foodborne illness is a serious public health issue, and the cost to American society is high. The Centers for Disease Control and Prevention (CDC) estimates that 76 million Americans are sickened, 325,000 are hospitalized and 5,000 die each year from food-borne illnesses.1 Children, seniors, pregnant and post-partum women, and individuals with compromised immune systems are at highest risk of developing complications from foodborne illness. Further, there are new food safety challenges on the horizon, ranging from the threat of bioterrorism to avian flu. Clearly, foodborne illness will remain a serious public health issue in the years to come.
    For more than forty years, irradiation has been explored as an intervention to reduce pathogens/molds in food, to control insects/parasites in food or to sterilize food as well as health and consumer products, such as surgical gloves, contact eye solution or baby pacifiers. With food irradiation, an item is exposed to ionizing energy, which kills organisms in or on the food, as the energy passes through the product. During this process, the energy waves break down the molecular bonds in the DNA of exposed organisms, causing them to die or be unable to reproduce. The food itself remains raw, and while the food does experience some chemical change, the process does not make the food radioactive. Today, irradiated foods are sold in the United States, and those items include some spices, tropical fruits, strawberries, as well as poultry and meat products. According to the FDA, American astronauts have eaten irradiated foods in space, and some hospitals provide irradiated food to patients with weakened immune systems to reduce the chance of a life-threatening infection. 2
    There are three types of food irradiation: gamma, electron beam and x-ray. Gamma irradiation uses high energy gamma rays that are emitted by radioactive Cobalt-60 or Cesium 137. Gamma irradiation has been the preferred method of irradiation by food processors since whole pallets of product can be treated at one time. Electron beam irradiation accelerates electrons in an electric field to a velocity close to the speed of light, but the penetration level is limited to just a few inches, depending on the type of the product. X-ray irradiation, the newest of the irradiation processes, can penetrate deeply and be more directed than gamma irradiation; however, this type of irradiation can be costly. Both x-ray and electron beam irradiation use accelerators, which can be turned on and off, and since they do not use radioactive sources, these two irradiation processes have no link to nuclear energy. However, all three of these irradiating processes require special equipment and a multiple-hurdle environmental and worker safety protection plan. For Cobalt-60, a combination of concrete and water is used as a protective barrier, while for x-ray and electron beam processes, concrete walls are used.
    Over the years, food irradiation of all types have been endorsed by several leading health organizations, including but not limited to: World Health Organization, U.S. Centers for Disease Control and Prevention, American Medical Association, American Academy of Pediatrics, American Veterinary Medical Association, American Council on Science and Health, and the New England Journal of Medicine.
    On July 8, 2005, the American Meat Institute (AMI) submitted a petition to FSIS requesting that the Agency approve low dose, low penetration (Ld/Lp) electron beam irradiation applied to the surface of chilled beef carcasses as a processing aid. Further, the petition requested that information concerning irradiation treatment not be required on the label of any products derived from the carcass.
    While CFI believes that the petition from AMI seeking approval of Ld/Lp, electron beam irradiation as an additional intervention to reduce pathogenic load of E. coli O157:H7 on chilled beef carcasses has merit, CFI does not agree with the petition’s request to consider this treatment as a FDA approved “processing aid” that does not require package labeling for the treated product(s). At the September 18, 2008 public meeting, hosted by FSIS, CFI expressed this view and is now offering these comments as further support of CFI’s position.
    Using Ld/Lp as an Intervention
    Based on various studies available, including the study attached to the AMI petition 3 and the American Academy of Pediatrics’ (AAP) Technical Report on Irradiation4, CFI agrees with the American Meat Institute’s claim that Ld/Lp, electron beam irradiation is a safe intervention for reducing E.coli O157:H7 on beef carcasses. CFI also agrees with AAP’s concluding remarks in the above cited report, that “the science of food irradiation is mature, and the scientific consensus on its efficacy and safety is strong” (Pediatrics, p. 1509).
    Low dose (1kGy), low penetration (15 mm), electron beam irradiation to treat the surface of food products is documented as a safe intervention that is effective in reducing the presence of live E. coli O157:H7 on food products. “A minimum dose of 1.5 kGy would destroy at least 6 logs of E. coli O157:H7, which has a D value of about 0.24 kGy. Irradiation, therefore, would be extremely effective at eliminating this pathogen, declared an adulterant in ground beef in 1994.”5 CFI understands that AMI’s petition requests a 20 mm penetration as its maximum depth. CFI believes that this request is reasonable and necessary to assure a consistent minimum 15 mm depth of penetration on the product(s) being treated by Ld/Lp electron beam equipment.
    Ld/Lp electron beam irradiation does not seriously affect a food’s nutritional value. Various reports have documented that irradiation does not impact on proteins, carbohydrates, trace elements or minerals.6 On the other hand, irradiation does affect some water soluble vitamins, in particular the B vitamins and vitamin C, as well as some fat vitamins, particularly E, A and K.7 However, when using Ld/Lp irradiation, the loss of these vitamins is minimal and does not seriously reduce a food’s nutritional value. Overall, food treated by Ld/Lp electron beam irradiation does not experience any greater nutritional loss than what would occur in normal cooking or canning.
    Ld/Lp electron beam irradiation has been documented as being a safe technology for workers to use and does not impact on the environment by producing a toxic waste. Ld/Lp irradiation facilities and in-plant equipment generally have multiple safeguards to protect workers from accidental exposure. Unlike gamma irradiation, which uses a radioactive Cobalt or Cesium source, electron beam accelerators produce ionizing radiation in a beam, which stops forming when the accelerator is turned off.8 Further, since Ld/Lp electron beam accelerators do not use nuclear reactors, a “melt-down” is not possible and the facilities/equipment are designed to assure that little or no waste is released into the surrounding environment.9 Currently, the U.S. Occupational Safety and Health Administration (OSHA) is responsible for regulating worker protection from all sources of ionizing radiation.
    It is important to note that Ld/Lp electron beam irradiation does not produce a sterile product. As a result, Ld/Lp must be used in conjunction with Good Manufacturing Practices (GMPs), good sanitation standards and as part of a full HACCP plan. CFI agrees with the following statements made by the American Academy of Pediatrics: “Irradiation of food cannot substitute for excellent food production, processing and preparation . . . Irradiated food is safe and nutritious and produces no unusual toxicity as long as best management practices are followed . . . Irradiation is a complement to established techniques that can add to food safety . . . As with any technology, unforeseen consequences are possible; therefore, careful monitoring and continuous evaluation of [food irradiation] and all food processing techniques are prudent precautions.”10
    While Ld/Lp electron beam irradiation is an additional tool that can help reduce the presence of E. coli O157:H7 within a well designed food safety program, it should NOT be a required step. The cost of using Ld/Lp electron beam irradiation could be prohibitive for small and very small plants. Further, since small and very small plants can employ other interventions that are effective in controlling pathogen loads on their products (such as, increased worker skill during slaughter or hide-removal), the use of Ld/Lp electron beam irradiation should be an option, not a requirement.
    Ld/Lp electron beam irradiation ‚Äì both the equipment and the process — must be closely monitored by regulatory agencies. In the case of Ld/Lp electron beam irradiation of chilled beef carcasses, the regulating agency would be the USDA/FSIS, which may or may not choose to delegate monitoring the equipment and/or process to OSHA.
    CFI believes that the USDA/FSIS must do the following to ensure proper oversight of this technology:
    o USDA/FSIS must establish jurisdiction for inspecting and verifying in-plant, Ld/Lp electron beam equipment and the process used to treat products.
    o USDA/FSIS must clearly define the HACCP requirements that must be fulfilled before allowing a plant to use Ld/Lp electron beam irradiation as an additional tool.
    o USDA/FSIS must verify that a plant using Ld/Lp electron beam irradiation is applying the process at appropriate critical control points and that the process is actually producing a product with a low level of pathogenic contamination.
    o USDA/FSIS must verify that a plant using Ld/Lp electron beam irradiation is meeting all requirements for worker safety and environmental protection.
    o USDA/FSIS must establish that it has authority to conduct research on the use/outcomes of Ld/Lp electron beam irradiation on the products that the Agency inspects.
    Ld/Lp Labeling Requirements
    Ld/Lp electron beam irradiation information must be provided on a label and affixed to treated products. CFI believes that food wholesalers and retailers, as well as consumers, have a right to know that a product has been treated with Ld/Lp electron beam technology. CFI recognizes that past educational efforts on food irradiation have not been effective in achieving U. S. public acceptance of irradiated food as safe and nutritious. However, labeling the product is essential.
    Today, most consumers are not knowledgeable about food irradiation. In fact, when asked, most people have never heard of the term, so it is unclear how many consumers would purchase an irradiated food product without the benefit of an educational campaign to inform them about the benefits of irradiated food.
    According to CDC’s 1998-99 FoodNet Population Survey, the most frequent reason why adults did not buy irradiated meat or poultry was insufficient information about food irradiation.11 In fact, multiple surveys have shown “considerable consumer confusion and ignorance about food irradiation.”12
    In a 2003 Kansas State University survey, subjects were given a brochure explaining irradiation and its benefits to determine if industry or governmental educational efforts would be stronger in securing consumer acceptance of this technology. In the survey, 66% of the respondents who were told that the information came from industry and 76% of the respondents who were told that the information was from a governmental agency said that they would purchase irradiated food to reduce the risk of foodborne illness. 13 Obviously, the American public is ready to learn more about food irradiation, in particular from government sources, but also from food companies.
    In the coming years, will the American public accept Ld/Lp electron beam irradiation? Due to the large number of foodborne illness outbreaks and food recalls in 2006-2008, consumer confidence in the United States food supply has decreased significantly. According to the International Food Information Council’s May 2008 Food and Health Survey, only 45% of Americans are confident in the United States’ food supply; 26% are not confident and 29% are undecided. In the 2007 annual survey conducted by Food Marketing Institute, consumer confidence in the safety of supermarket food went from 82% in 2006 to 66% in 2007, which is a huge drop. Most recent, however, is the October 16, 2008, survey by Ketchum Inc. entitled Food 2020: The Consumer as CEO. In this survey, 75% of consumers said they would like to see food companies place a priority on creating foods that reduce the risk of major health issues and disease.14 Given the changes in food production and distribution, the public’s perception is changing, and these new attitudes are making consumers more willing to expect and accept stronger food protections.
    CFI believes that Americans value food safety and when the benefits and limitations of Ld/Lp electron beam irradiation are explained, CFI believes that the public’s reaction will be increasingly positive and accepting. It appears that now would be a good time to re-introduce irradiation with a proactive educational campaign to inform consumers about this technology.
    Furthermore, consumers have a right to know and they want to know if a food has been treated with irradiation. According to the American Council on Science and Health, “information from market trials indicates that consumers prefer that irradiated foods be labeled. . . Labeling offers the opportunity to inform consumers of the reason why foods are or should be irradiated, as well as giving them a choice.”15 Therefore, products treated with Ld/Lp electron beam irradiation need a modified, informational label. Current irradiation labeling, which basically is the radura symbol, does not indicate the dose of irradiation used to treat a product. Further, since Ld/Lp electron beam irradiation is NOT a sterilization process, consumers need a label that clearly states that Ld/Lp electron beam irradiation was used to reduce the load of pathogens and that further safe food handling practices, including cooking to appropriate temperatures, are necessary. A modified, informational label must be developed and agreed upon by all stakeholders before USDA grants the use of Ld/Lp electron beam irradiation on chilled beef carcasses.
    As a nonprofit committed to improving food safety through research and education, as well as advocacy and service, CFI believes that the AMI petition has merit, but will not accept AMI’s request to not label the product as being treated by Ld/Lp electron beam irradiation. CFI believes that the public is ready to accept irradiated food products and that both industry and government have a responsibility to educate consumers about this technology. Further, CFI believes that continued study on the potential positive and negative outcomes associated with irradiation need to be explored in a timely fashion.
    CFI is committed to working with USDA and FSIS to minimize foodborne illness through more effective food safety management, including the development of appropriate technologies. We appreciate this opportunity to comment on the September 18, 2008, USDA public meeting, and we look forward to continuing our dialog with the Agency on important food safety issues.
    Respectfully submitted,
    Patricia Buck
    CFI Executive Director
    1 Mead, Paul, et al. Food-Related Illness and Death in the United States. Emerging Infectious Diseases, Vol. 5,
    No. 5, September-October, 1999.
    2 U.S. Food and Drug Administration. Food Irradiation: A Safe Measure. January 2000.
    3 Thayer, D. W. Literature Review and Analysis of the Effects of Beef Carcass Surface Irradiation on Micro- and Macro-Nutrients. p. 9. 2004. Article included with AMI petition documents as Appendix 3.
    4 Shea, Katherine M. and the Committee on Environmental Health. Technical Report: Irradiation of Food. Pediatrics. Vol. 106, No. 6, December, 2000, pp.1505-1510.
    5 Institute of Food Technologists’ Expert Panel on Food Safety and Nutrition. “Irradiation of Food.” FoodTechnology: Vol. 52, No. 1, (1998), p. 59.
    6 National Consumers League. Food Irradiation . . . What You Need to Know. Question: “Are irradiated foods less nutritious than other foods?” (No date) http://www.nclnet.org/food/foodsafety/
    7Shea, Katherine, et al. Pediatrics, 106 (6):1507, (2000).
    8 E-Beam Services. Packaging Materials Issues in Irradiation Processing of Foods. Presented at the SPE Polyolefins 2000 Conference in Houston on February 28, 2000. http://www.ebeamservices.com/ebeam_spe_poly.htm.
    9 National Consumers League. Food Irradiation. Question: “Is irradiation safe for workers and the environment?” (No date). http://www.nclnet.org/food/foodsafety/
    10 Shea, Katherine, et al. Pediatrics, p. 1507.
    11 Frenzen, Paul, et al. USDA/ERS. “Consumer Acceptance of Irradiated Meat and Poultry Products.” Issues in Food Safety Economics. Bulletin No. 757/August, 2000.
    12 Osterholm, M.T. and M. E. Potter. “Irradiation Pasteurization of Solid Foods: Taking Food Safety to Next Level.” Emerging Infectious Diseases, Vol. 33, No. 4, (1997).
    13 Fox, Sean. “Knowledge of irradiation improves its consumer acceptance.” Kansas State University. Food Technology Intelligence, Inc. 2003.
    14 Ketchum Global Food and Nutrition Practice. Food 2020: The Consumers as CEO. Executive Summary, October 16, 2008. (http://www.ketchum.com/files/Food_2020_Executive_Summary.pdf)
    15 Loaharanu, Paisan, M.S. ed. “Irradiated Food.” Fifth edition. American Council on Science and Health. May 2003, p. 39.

  • Marion Nestle

    The main argument against it–a good one in my view–is that it removes company responsibility for producing safe meat and gives them permission to produce dirty meat. “Sterilized poop is still poop,” as Carol Foreman puts it. Also, it is no guarantee that the meat stays sterile as it can become recontaminated. I discuss all this in Safe Food. Take a look?

  • Concerned Consumer

    My concern is a gray meat product with less nutritional value and less flavor, smeared with sanitized feces, being sold unlabeled and indistinguishable from a meat product I might otherwise WANT to eat.

  • In response to the earlier comment that Congress should deregulate irradiation (remove radiation from the definition of food additive), this would be a disaster. Giving less regulatory scrutiny to irradiation than lecithin or amino acids would increase public distrust. In addition, just because authorized uses are safe does not mean that all possible uses and dosages would be safe.

  • Bonita Ferus

    Is anyone in Europe doing this and if so, how is it working out for them?

  • Michele

    Marion Nestle,
    “The main argument against it–a good one in my view–is that it removes company responsibility for producing safe meat and gives them permission to produce dirty meat.”
    Your point is well taken, but it is important to look at the science behind irradiation. Irradiation as a processing method is only one part of a multi-hurdle approach. For example, there is some poop getting into beef today despite efforts to keep it out. Irradiation provides an additional step to deal with that level of poop and the pathogens along for the ride before the product reaches the consumer. If companies dropped the current control methods, and depended on just irradiation to fix “dirty meat” with irradiation, they would fail miserably.
    In other words, its an oversimplification to say that irradiation would “replace” other downstream or upstream controls. We simply are not doing enough to deal with the reality of poop in our meat (and some other products); irradiation is an added step to help protect the food supply, and prevent tragedies from foodborne pathogens like Bill has documented on this blog.

  • I agree that there is the potential for meat processors to abuse the use of irradiation and wind up producing “dirty meat”. Another concern to me is the perception on behalf of some in the consuming public that this process somehow “bulletproofs” the product for consumption.

  • Guido v H

    I am just concerned we’re forgetting what the real issue is. It looks like we’re patching problems with new techniques that have some serious unknowns instead of really solving the cause of the issue.
    Why is the E.Coli bacteria so rampant in the first place? This wasn’t always the case. Why not try to change how our food is produced to prevent E.Coli’s growth?
    I guess that in the end, trying to prevent E.Coli or killing E.coli are both solutions, but it seems to me that killing is an approach that again takes us one more step away from having natural, normal food.

  • Marie

    Assuming food irradiation is safe has led to serious illness in pets consuming irradiated foods. Why make the same mistake with human food?
    “No cases of Fanconi-like syndrome have been associated with VeggieDents outside of Australia, so the product is still available in Europe, Asia and the United States.
    The chews are made in Vietnam. Virbac has said that the product in Australia, unlike those sold elsewhere, is irradiated as required by the Australia Quarantine and Inspection Service.
    Pet food irradiation at the levels used in Australia has been linked to neurological disease, including ataxia and tetraplegia, in cats; dogs are not known to be affected. The Australian government in late May banned irradiation of cat food because of compelling scientific evidence that the sterilization process may harm cats. How irradiation may induce toxicity is unknown.”

  • Mark Robinowitz

    no No NO.
    There’s nothing “low dose” about this. The nuclear industry changed the units from rads to “grays” in order to use lower numbers. Food irradiation starts in the tens of thousands of rads (for zapping onions and potatoes). Meat irradiation is in the hundreds of thousands of rads. We get one tenth of a rad per year from natural background radiation, which isn’t safe but there’s nothing we can do about it. Medical x-rays and nuclear pollution are comparable amounts, the first has a benefit and a choice to offset the risk, the damage of industrial pollution is involuntary and mandated to all who live downwind or downstream.
    100,000 rads looks like a bigger number than 1 kiloGray (1 kGy) but they are the same thing. Linguistic detoxification.
    Irradiation creates numerous new toxic chemicals in food through radiolysis, especially in fatty food like meat. Irradiation also selectively destroys some microorganisms and not others. When food is spoiled, it’s a good idea for the microbes that cause the food to smell to still be around – that’s our basic way to determine that the food is not to be eaten.
    Irradiation is a a way to cover up poor food handling practices, getting the count of bacteria lower instead of stopping disgusting factory farming practices or pouring raw sewage onto agricultural fields (composting humanure is a minimal requirement for safe use along with ensuring that industrial wastes are not in the waste stream).
    Learning about irradiation, factory farming and toxic additives got me to become vegetarian and to learn to grow some of my own food.
    There isn’t any enforcement of the requirement that fruits and vegetables coated with petroleum wax should be labeled in the grocery store even though this is easy to verify (scrape the surface). There is no will power for the food industry and regulators to tell people they’re eating food exposed to radiation doses hundreds of times greater than the full body lethal dose (which is 600 rads, whole body) and that this irradiation changes the basic chemistry of the food in very different ways from canning or cooking (and irradiated food is often still cooked).

  • Kathy

    In response to the commenter who was wondering why there is so much E.Coli now-the film FOOD INC.(consider the source) said that is because of corn being used as a feed for cows rather than grass. That corn is not their natural food, and it produces bacteria in their system as a result of consumption. And that if a cow was fed grass for 10 days, it would rid it’s system of the pathogenic E.Coli. If this is true, how about requiring that all cows meant for consumption be mandated to be fed grass-no corn, prior to their expected slaughter date. Should be cheaper than x-ray units, and somewhat more natural. I would still vote for irridiation of fruits and vegetables

  • ewem

    this web site
    has a lot of information in the comments section about the irradiation of Orijen cat food in Australia, and the paralysis of cats consuming the product. Orijen has blamed the disease on the irradiation required by Australian law. If the comments are accurate, irradiation affects fatty acids, and destroys vitamin A. I do not know if the symptoms have been duplicated by testing. One problem is the possibility the irradiation process in Australia was not to standard, and therefore the ability to duplicate what happened in the toxic pet food is hampered
    Cats have special nutrional needs. They must consume taurine, because they cannot produce it in their bodies so that in the wild, they must be carnivorous or perish. If irradiation destroyed another, undocumented, nutrional requirement of these specialized animals who would know?
    The fact is, irradiation destroys or reduces quality by percentage of complex molecules like fatty acids. We humans know we can tolerate heat destruction of proteins in our food because we have survived with cooked foods over our history. We humans have no similar history to verify long term results of consuming food that has been altered by irradiation. Our meat today is laced with medicines and additives fed to the animals, and any trace additive might become something worse after irradiation.
    We cannot assume that we understand all the possibile new configurations that will be created by irradiating meat, and we cannot know the side effects of all these altered molecules.
    My biggest fear of irradiating meat will be a relaxing of more traditional standards of hygiene and safety, as irradiation will become an ultimate ‘clean up’ for bad handling
    I do not want it and deeply resent the government push to ignore the consumer’s right to choose what they consume