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Pros and Cons of Commercial Irradiation of Fresh
Iceberg Lettuce and Fresh Spinach: A Literature Review – Part V. Conclusions Source of Article: http://www.marlerblog.com/ “Never confuse movement
for action.” As this multi-part series on FDA’s new rule approving commercial
irradiation of fresh iceberg lettuce and fresh spinach comes to its conclusion,
it is important to ask if and how this movement by the regulatory agency can
be translated into action by industry and consumers to promote public health.
I embarked on this literature review to help answer these questions, and to
gain a better understanding of the pros (advantages) and cons (limitations)
of implementing commercial irradiation of lettuce/spinach. Follow these links
to read the entire series: Part
I. Definitions and Historical Perspective As mentioned previously, food irradiation is not a “silver bullet” for
food safety, but represents another tool in the toolbox of approaches to
protect the food supply. Below is a summary of the findings from this review: Pros (Advantages) • Like pasteurization, food irradiation has widespread, worldwide
endorsement by nearly every major medical and scientific organization • Enhances food safety and can prevent illnesses, outbreaks, and recalls.
The new FDA rule allows a maximum dosage of 4 kGy,
which is effective at reducing or eliminating the major foodborne
pathogens such as E. coli O157:H7 and Salmonella associated with recent
lettuce/spinach outbreaks and recalls (see Table). Fewer outbreaks and
recalls translates into: o less direct and indirect costs to individuals and society due to medical
bills and other expenses • Unlike other sanitation methods for raw or minimally processed
lettuce/spinach, irradiation will kill bacteria adhered to the outside or
internalized within the edible plant tissues (for example, E. coli O157:H7
inside pores or stomata); regular washing by the consumer likely will not
eliminate these bacteria • Conducive to use by companies that supply institutions (restaurants,
hospitals, nursing homes, long-term care facilities, schools/colleges,
prisons and jails) with large quantities of bagged, minimally processed,
pre-washed iceberg lettuce and spinach, which historically appear more
vulnerable to serious foodborne disease outbreaks • Enhances food quality by extending product shelf-life and promoting less
food waste. Similar to foodborne pathogen reduction,
the approved dosages for irradiation of lettuce and spinach significantly
reduce the levels of spoilage bacteria and molds. • Minor to no significant loss of important nutrients in lettuce and
spinach, especially compared with nutrient loss following other common food
preservation techniques (e.g., boiling and freezing) and losses during
storage • Limited to no detectable problems with sensory qualities - appearance,
taste, texture, and aroma - especially at lower dosages (1 kGy) • No chemical residues left on the product, and a consensus within the
scientific community that the technology is safe and does not produce any
“toxic substances” or “radioactivity” in the food or packaging. Indeed, the
three specific sources (gamma rays, x-rays, e-beam) specifically approved by
the FDA for food irradiation were approved because they do not make the food
radioactive. • Includes a Radura label that allows consumers
to make a choice to buy or avoid irradiated product, depending on their
assessment of the pros and cons. Cons (Limitations) • Lack of irradiation facilities near major lettuce/spinach production
regions such as the • Uncertainty about consumer acceptance of irradiation, especially for
produce items. Some consumers fear of the word “irradiation,” which may be
incorrectly associated with the words “atomic” or “nuclear.” Studies indicate
that the primary reason consumers might not buy irradiated foods is due to
insufficient information about the risks and benefits, thus underscoring the
considerable need for education efforts • Strong opposition to the use of irradiation in organic food production;
FDA’s rule would not apply to organically produced lettuce and spinach since
irradiation at the medium dose range is not allowed by USDA standards that define
“certified organic” (Note: the 2006 E. coli O157:H7 outbreak was traced to
bagged baby spinach grown organically) • Not a replacement for good agricultural practices (GAPs)
and good management practices (GMPs) on the farm
and during harvest, transportation, and processing • Does not prevent post-processing contamination during transport or by
the retailer or consumer during food preparation and handling • At the approved dose, irradiation may not effectively reduce viruses
(e.g., norovirus, hepatitis A); spore forming
bacteria such as Clostridium botulinum, and it does
not eliminate toxins. However, these causes of foodborne
illness and intoxication are rarely linked to fresh lettuce and spinach • Some packaging material may not be appropriate (or FDA approved) for
irradiation processing From Movement to Action Coincident with starting this series last fall, an outbreak of E. coli
O157:H7 involving over 40 illnesses and numerous hospitalizations was linked
to bagged, fresh-cut iceberg lettuce shipped to institutions in Stearns (2006) wisely notes in his chapter on the legal perspectives of
food irradiation: “Food irradiation has the capacity to substantially reduce not only the
risk of lost sales that result from an outbreak or recall but also the
lawsuits that inevitably follow.” He goes on later in the chapter to say: “Because it is clear that the size of the highly susceptible population
[elderly, preschool age children, persons with AIDS, persons on chemotherapy,
etc.] is certain to grow, the food industry has no choice but to take this
increasing risk into account when making decisions about what, if any,
additional steps to take to prevent a parallel increase in the incidence of foodborne illness attributable to its product.” Given the gravity of the situation with continued illnesses and deaths
linked to fresh produce, the “cons” (such as uncertainty about consumer
acceptance and potential costs to implement irradiation), should not paralyze
the effort to go from movement to action. The following are some suggestions
for first steps to maximize the benefits of FDA’s new rule: • All professionals in the food safety arena should work with experts in
food irradiation companies to conduct a modern assessment of the estimated
costs and benefits associated with implementation of the FDA rule for fresh iceberg
lettuce and spinach. Specifically, these professionals should look closely at
potential niche markets or at-risk groups that could benefit from the
technology. For example, irradiation could have a significant impact
(reduction of illnesses and outbreaks) if applied to products shipped to
institutional settings (schools, hospitals, nursing homes, long-term care
facilities, prisons) where populations are especially vulnerable to foodborne diseases. • Government, industry, academia, health care providers, legal
professionals, consumer groups, and other stakeholders need to provide and
advertise an honest and balanced assessment of the pros and cons (advantages
and disadvantages) of food irradiation including application of the FDA rule
for fresh iceberg lettuce and spinach. This information should be readily
available to the public via multiple sources including the Internet to allow
the public to make an informed choice. Pszczola
suggested that the medical and scientific communities “develop closer relationships
with the media so emotionalism is not overemphasized compared with scientific
facts.” • The label for irradiated fresh iceberg lettuce and spinach (plus other
approved foods) should include the Radura, and a
general or incentive statement on the purpose of irradiation such as, “to
kill harmful pathogens,” or “to reduce Salmonella and E. coli O157:H7.” It
would also be worthwhile to consider phasing out the word “irradiation” and
adopting a new term for this processing technology such as “cold pasteurization”
or “electronic pasteurization (for e-beam processing),” which are still
descriptive, but not associated with the words “nuclear” or “atomic.” • FDA should expand the rule to include approval of other high-risk salad
greens linked to foodborne disease outbreaks,
especially Romaine lettuce. Public and private funding agencies should
continue to provide support for research into the optimal conditions for use
of ionizing radiation in different types of leafy greens and packaging
materials that promote both food safety and food quality. |
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