Points to Raise in Submissions
- 1. It Is Not Proven Safe
While it can be argued (as ANZFA does) that food irradiation has not been proven unsafe, the converse is equally true - it has not been proven safe. Even the US FDA admitted the vast majority of studies of food irradiation were flawed. Given the level of unknowns and the ambiguities we should operate on the precautionary principle - particularly as many of the possible deleterious (e.g. carcinogenic) effects of food irradiation may not show up for decades
A further problem is the possible effect of irradiation on pesticide residues in food. These are present in foods worldwide, as far as we are aware no-one has done detailed studies on the effects of these residues. Given the chemical structures of many pesticides there is a real possibility that toxic Unique Radiolytic Products could be formed when they are irradiated - 2. It Is Not Proven That It Will Be Effective
It does not ensure safe food. Although it kills most bacteria, irradiation does not destroy the toxins created in the early stages of contamination - it stimulates the production of aflatoxin (a toxin that occurs in fungus spores on grains and vegetables in humid and tropical countries). The bacteria may not be completely killed and there are dangers of creating mutated strains resistant to both irradiation and antibiotics
Food Irradiation is an "end of pipe" technology in the very worst sense of the term. It would be far more rational (and cost effective) to deal with the problem at the source - i.e. Fix the lax practices in the production, processing, and distribution of food - 3. It Is Not Proven That It Won't Affect The Nutritional Value Of Food
There is clear evidence that irradiating food negatively affects the vitamin content of the food (the only dispute is over the level of these negative effects). There are endemic problems in many different societies which result from vitamin deficiencies. The promotion of a method of food treatment which will only sever to further aggravate these problems is senseless - 4. It Is Not Proven That It's Needed
There are viable alternatives to food irradiation (see our Food Irradiation Fact Sheet page for details) - 5. It Is Not Proven Consumers Want It
Despite multi-million dollar PR campaigns worldwide promoting food irradiation, opinion polls show consistently that consumers are suspicious of, and do not want to eat, irradiated food. The bottom line question is - who wants food irradiation? - 6. It Is Not Proven That Rejecting Irradiation Will Harm Our Markets
Food irradiation is not widely used or accepted worldwide. The countries that do allow irradiation of food allow it only for a restricted range of foods and only under tight controls. To say that irradiation is "important to our export/import markets" is dishonest
Destination
Send your submission to:
ANZFA
P O Box 10559
The Terrace
Wellington
If possible, please send a copy to us, so we can keep our own tally of submissions:
Sustainable Wellington Net
P O Box 9608
Wellington
E-mail: elm@clear.net.nz
Deadline
Remember the closing date for submissions is the 26th of March 1999. You could also contact the people listed below and ask for an extension of this deadline. This issue is extremely important and complex, and the time allowed for comment far too short - after all, what's the rush? Australian consumers were given 7 months to comment on a similar proposal
Sample Complaint
Dear...
I am writing to protest the inadequate time given for submissions on the ANZFA Proposal P89B on Food Irradiation standards. The closing date for submissions is the 26th March 1999.
The public notice for this proposal was minimal - small ads in 2 daily papers (The ads were in the body of the papers not the Public Notices section. This is less notice than a routine RMA Resource Consent application) - no Public Interest groups or NGOs were given notice of the proposal. The time given to NZers for making submissions is less than a third of that given to Australians.
Given the wide implications of this proposal and the lack of any apparent need for urgent revision of the status quo, I would urge that the time for submissions be extended by at least 4 months.
Yours sincerely
Deliver To
It's preferable to send copies of the extension request to all 4 of the following addresses. Failing that, the first is the most important
- The Parliamentary Commissioner for the Environment, P O Box 10-241, Wellington
- ANZFA, P O Box 10559, The Terrace, Wellington
- The Minister for the Environment, The Hon Simon Upton, Parliament Buildings, Wellington (no stamp required)
- The Associate Minister of Health, The Hon Tuariki Delamere, Parliament Buildings, Wellington (no stamp required)
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