Truth in Labeling: What a Concept!

March 9th, 2001

Sunday, February 25, 2001 12:09 AM
To: fdadockets@oc.fda.gov
Subject: Irradiation Labeling, Docket No 98N-1038

Food and Drug Administration, Dockets Management Branch
5630 Fishers Lane, Room 1061
Rockville, MD 20857

Dear Food and Drug Administration, Dockets Management Branch,

I am at a complete loss to understand why consumers should need an interpreter to understand the labels on their food. Any proposal to hide the actual process by which food is prepared or to disguise the actual ingredients is a betrayal of the public trust in which the FDA is held by the public.

Approving the euphemism of “cold pasteurization” rather than requiring the explicit term “irradiated” food, makes the FDA just another Madison Avenue advertising firm for industry. The same industry which prefers to substitute an insufficiently tested procedure for their failure to create and maintain sanitary conditions for the production of our foods or to remove sick livestock from our food supply. If industry is to be permitted to sidestep these crucial steps to quality food as yielding a poor return on their investments, then the purchasing agents must be permitted to clearly make the choice between irradiated versus traditionally prepared products.

The purchasing dollar should be the determining factor in the marketplace with consumers directing production with the power of their wallets. In Europe where GMO foods failed to capture consumer interest, clear labeling enables consumers to make informed choices. Americans are required to turn grocery shopping into a research project if they do not wish to choose GMO foods. Feel free to permit industry to make whatever claims are accurate to make their irradiated products more appealing to US citizens. However, labeling it pasteurized in any fashion is to hide the facts of the matter from those the FDA was brought into being to protect.

If it turns out that there are any detrimental effects to eating irradiated foods, do you want it known that you failed to permit shoppers to know what they were purchasing? If it turns out to be a superior way to process food, should the public not enjoy a clear expression of the reason for success? Any industry that prefers to hide the facts from consumers is also keeping data from them which would indicate their product is a poor choice. This is true whether it is a failure to label inerts in pesticides, to state the actual chemical composition of fragrances or to reveal that an engineered grain produces its own insecticide and kills certain lifeforms which attempt to feed on it in the fields. It certainly applies to the application of radiation to the food supply.

Why is truth in labeling such an unacceptable concept in this country?

Sincerely,

Barbara Rubin

Categories: FDA, Letters

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