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Application A413 -Permission to irradiate herbs and spices

Clarification of Issues Raised by Canberra Consumers Incorporated

Following the distribution of the final draft report of the application to irradiate herbs and spices, ANZFA met with representatives of Canberra Consumers to discuss a number of issues raised in their submissions to ANZFA in relation to the application. As a result of the discussions, ANZFA agreed that it would be useful, particularly if there is broader concern over any of these issues, to provide additional information on the website to clarify these issues.

In particular, the following matters were raised by Canberra Consumers:

Clostridium botulinum is very resistant to irradiation. Does this present a public health hazard?

Although the spores ofClostridium botulinum are extremely resistant to radiation this bacterium and similar spore formers in plant material, such asBacillus cereus are readily eliminated from, or prevented from growing in food where they may cause concern by methods other than irradiation. In addition botulinum bacteria, which are only occasionally found in food, do not grow in the food and cause a problem unless the air has been completely excluded from the food. The heat sterilisation processes applied during canning of food incorporates a large safety margin to protect consumers against botulism. The exclusion of air will not occur in most food processing.

Viruses are not destroyed by irradiation.

Viruses that could cause illness in humans, while not readily destroyed by irradiation have not been, and are unlikely to be found in the foods that are to be irradiated. They most commonly contaminate foods during preparation in the home or food service industry, or come from contaminated water used in food preparation or growing.

There does not appear to be any uniform regulations for the use of this technology in foods (apart from the Standard in the Food Standards Code). There was concern that proper hygienic practices would not be followed.

The new national Food Safety Standards that regulate the safe handling requirements for foods and premises and equipment will apply to irradiation facilities that irradiate approved foods. These Standards have been adopted by all States and Territories, subject to the amendment of the relevant State and Territory Food Acts.

There was concern expressed about the use of the term ' commonality' in the second paragraph of page 46 of the draft final report in the section titled, ' Toxicological safety and the concept of chemiclearance' .

It was agreed that chemiclearance was a useful concept. By way of clarification, with respect to lipids, the mechanisms by which radiolytic products are formed involve reactions common to both saturated and unsaturated fatty acids as well as reactions specific to unsaturated fatty acids.

There was some concern expressed that it could be misconstrued on page 46 that fish were included in the same class of other foods of animal origin by virtue of their fatty acid profiles as some may be saturated and some unsaturated.

Fish is included in the same class as the other muscle foods, due to the similarities in proteins and since the differences in unsaturation lead to predictable differences in radiolytic products (Diehl, 1995; Elias and Cohen, 1983; and personal communication with an irradiation expert).

Canberra Consumers thought that the statement, ' Furthermore, these concerns were raised in relation to irradiation of nuts above a dose of 10kGy, which the applicant has not requested ' on page 50 in the third last paragraph may be misleading.

It is acknowledged that fatty acid peroxides and epoxides may be produced at doses of less than 10kGy, although the toxicological significance of this is unknown. It should be noted that the production of these fatty acid peroxides and epoxides is not unique to irradiated foods but also apply to the conventional heating of fatty foods.

Canberra Consumers queried the withholding of commercial-in-confidence data provided by the applicant .

It is a requirement under Section 39 of theAustralia New Zealand Food Authority Act 1991that confidential commercial information may not be disclosed.

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