Petition against expansion of food irradiation

lin_067.gif (542 バイト)

December 10, 2009

To the Minister of Health, Labor and Welfare, Mr. Akira Nagatsuma
To the Pharmaceutical and Food Sanitation Council Members

Japan Liaison Against Food Irradiation
Masae Wada (Japan Housewives' Association)
Eriko Tobita (Tokyo Regional Federation of Women’s Associations)
Yoko Tomiyama (Consumer’s Union of Japan)
Hiroshi Satomi (Japan Food Irradiation Network)

Petition against expansion of food irradiation

 In October 2006, Japan Atomic Energy Commission issued a document "Regarding the Application of Irradiation to Food Products", notifying the Ministry of Health, Labor and Welfare to lift the ban on irradiation of spices and common food products. We visited and sat in on the deliberations of the Atomic Energy Commission's Special Committee on Food Irradiation and have also gone over the deliberation materials. We have then reached the conclusion that irradiation would undermine the safety of food products and animal feeds.

 It had been said that no harmful substance would be formed through the irradiation process, but since then it has been shown in an animal study that substances (2-Alkylcyclobutanone) formed through irradiation have a strong tumor promoting effect. It is also known that irradiation reduces the quality of the food. If foods are irradiated, everyone from children to the sick will have no choice but to eat these foods. We strongly believe that irradiation should not be applied to foods that are vital to all our lives, just for the benefit of a handful of stakeholders. To declare our opinion that consumers do not need or want to eat irradiated foods, we here present to the Minister of Health, Labor and Welfare 200,000 signatures gathered for the petition.

 The Ministry of Health, Labor and Welfare paid the Mitsubishi Research Institute, Inc. (hereafter referred to as Mitsubishi) 29,925,000 yen to "research and gather information on scientific knowledge and findings on the application of irradiation to food products", in which the institute was commissioned to collect original reports, surveys on the regulation and operation status in different countries, statistical data, and other information deemed necessary for the food safety authority to consider, as well as to survey on the food processors’ and consumers’ needs. The ministry was planning to forward this report to the Pharmaceutical and Food Sanitation Council for deliberation.

 The Ministry of Health, Labor and Welfare received the report on May 22, 2009 and posted it on its website. It became clear, however, that the report had serious factual and rudimentary errors. The ministry told Mitsubishi to resubmit the report, and is now waiting for the revised version. But these are not errors that can simply be corrected by replacing the words. It is highly inappropriate for the Pharmaceutical and Food Sanitation Council to hold deliberations based on the revised report. Hence, we propose the following:

- Do not use the revised Mitsubishi report for deliberation. The ministry should be responsible for making reliable deliberation materials.

- Irradiated foods should be deliberated under Section 6, Paragraph 2 of the Food Sanitation Act because 2-Alkylcyclobutanone in irradiated foods "pose risk to human health."

- The 94 kinds of spices currently proposed for irradiation are required to be " deliberated individually", but the necessary data including chronic toxicity study, carcinogenicity study, and teratogenicity study are not yet complete. Deliberation on such food materials should be postponed till all requirements are met.

- Verify the information, including the heretofore released reports, before proceeding on with the deliberation.

 We ask the Minister of Health, Labor and Welfare to consider the fact that scarcely any consumers or food processors are needing food irradiation, and to not consult the Food Safety Commission on the application of this technology with safety issues.

Reasons we oppose food irradiation:

1. Irradiated food may be harmful to human health.
2. There is no established method to measure the dose of irradiation or the number of times the product has been irradiated.
3. Management and oversight is impossible.
4. The danger of misuse or abuse cannot be avoided.
5. There are established methods which could replace the benefits (sterilization, killing pests, inhibiting germination, etc.) of food irradiation.
6. It reduces the quality of the food.
7. Commercial use of atomic energy for the benefit of a handful of stakeholders such as the atomic energy industry should not be permitted. The approval of food irradiation led by the atomic energy industry and its stakeholders is a mistake.
8. Opposition against food irradiation is not the result of lack of understanding on the part of the consumers.
9. The Japanese food industry is not strongly demanding food irradiation either.
10. Scarcely anyone is needing food irradiation, and there is no urgency or need to go out of the way to change the codes and standards to approve food irradiation.
11. Decisions should be made with a perspective into the future considering the global trend: most countries are pulling out from food irradiation.
12. Do not make the mistake of labeling them, thereby leaving the consumers to decide on their own.
13. There is the danger of radiation exposure accidents.
14. Food irradiation has not been thoroughly studied yet.

b39_001.gif (494 バイト)