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Consumer Comments on Food Irradiation 6***FEd Register Vol 72, No 192, 10/4/07, Pages 56679-80
If proposed procedures for processing fresh vegetables include irradiation, I am
vehemently opposed. I depend on fresh vegetables as a source of unadulterated
vitamins and minerals and such irradiation would seriously alter the vegetable or
fruit. More study regarding the impact of such practice would need to occur
before widely recommending such practices. Specifically, the link to cancer
should be investigated, as well as the potential degradation of vitamins and
minerals in the food. Thank you. for the opportunity to comment. Priscilla Cobb
***Dear Department of Agriculture,
This email is to comment: Re: AMS-FV-07-0090-0001
I completely disagree with the attempt to sterilize all fresh grown foods by pasteurization. I, or anyone else, is perfectly capable of pasteurizing food as desired immediately before consumption. I demand that the decision to pasteurize be left up to the consumer on an individual basis, so as to preserve the nutritional value of food.
Please spend the money you would have spent on this program on checking for contamination, and for establishing strict standards for cleanliness in the food growing, harvesting, transportation, and storage, so as to provide safe food to the consumer.
Early pasteurization methods destroy vital nutrients that quickly degrade during pasteurization, and immediately after. These methods are not oriented to preserve nutrition and/or have not had the requisite exposure to the American public with a thorough explanation, and definitive testing.
This proposed idea is in the nature of "Ready, Fire, Aim."
Proper growing techniques eliminate the problems you are addressing before picking, with normal food value as a result. Destroying food value reduces nutrition. And I don't want more irradiation or exposure to more chemicals in and around our food supply.
Kindly cease and desist this ill conceived effort to waste taxpayers monies.
thanking you in advance for your cooperation,
Richard Hiersch
The Food Pyramid
***I can't believe how paranoid you guys are getting!!!!! Pasteurizing leafy greens????? What on earth is going on????!!!!! Leave my leafy greens alone!!!
I want them FRESH, not tampered with and KILLED before I get them on my plate!!!!
First almonds, now leafy greens, this is getting way OUT OF HAND.
I have my right to choose what I eat and how I eat it. I prefer RAW
UNADULTERATED UNPASTEURIZED FRESH FROM THE FIELD GREENS WITH ALL ITS NUTRIENTS
IN TACT !!!! So PLEASE Get rid of this stupid proposed regulation, NOW !!! AMS-FV-07-0090 IRRADIATION IS TOXIC. !! Stop tampering with my ability to get healthy foods!
Then again, Let's poison all Americans, why don't we, will save on the amount of
wars we have to fight to defend them.....
Geez, you guys in Govt, WAKE UP !!!!!!!!!!!!!!!!!
LEAVE MY LEAFY GREENS FRESH AND HEALTHY !!!! |
*** Greetings,
I strongly oppose the pasteurization and/or irradiation of raw leafy green
vegetables before sale to the public. Please do not approve this into law.
Please allow foods to be sold and consumed as nature intended. This is so
important for the health and well being of our citizens. Thank you for your careful consideration in this matter. Sincerely, Linda Principato
*** I truly believe this is going too far. Irradiation takes away the life force of the food. Don't you think this is going a bit overboard? Whose interests does this serve?
*** I am thoroughly upset that food & agriculture is even considering irradiation. It is known to destroy vitamin content and it alters the food. In addition the bleaching of leafy green will leave traces of chlorine (a known carcinogen) on the greens even if they are rinsed. Please consider other options particularly related to food handling & water supply sources of food - ensure that they are pristine. Thank you
*** As a longtime consumer of locally grown organic leafy greens, I feel that regulation should be handled on a local basis.
The program's handling regulations should specifically address companies that are distributing greens nationally since any contamination of their greens has the potential to affect a much larger population.
Large growing and processing operations that are located within watershed areas that include stockyards, meat processing plants and other sources of chemical and bacterial toxins is a practice that should raise a red flag at the USDA, and those companies should merit close scrutiny. Regulation should take place at the beginning of the production cycle, starting with where the farms and packing plants are located, rather than the final packing stage. It just makes better sense.
Ultimately, food supply issues such as the recent e.coli contamination cannot be controlled by additional rules and regulation. There must be a common-sense approach to production practices that is realistically enforceable, and the most important way for the USDA to protect the consumer is by requiring truth in labeling. If the consumer knows the conditions under which food is produced, if the label "ORGANICALLY GROWN" could be trusted to ensure a safe growing practices, it would enable consumers to make good decisions to protect themselves.
Without truthful labels and adequate information, consumers will continue to be at risk.
I protect my family by buying locally grown produce directly from the farmers at the farmer's market as much as I can. These farmers need the support of the USDA, not regulations that would require irradiation of chemical treatment, practices which are in conflict with healthy and sustainable farming practices.
Thank you.
***This regulation violates many people's religions. I believe that all food that goes into my body should be natural food that was created by God, and not tampered with or irradiated. Since when did the USDA start passing mandatory regulations that hurt people's health instead of protecting it? The USDA is now mandating that lettuce have nuclear reactive molecules. Every piece of food is now tampered with in an unnatural manner. Amish people should be able to go to a grocery store and choose natural foods without pesticides, irradiation, "pasteurization", etc. This is state mandated religion. This is "Man knows better than God" secular devil's religion where Man can somehow create healthier food by chemically altering it. There needs to be a religious "opt out" choice. Now Amish people aren't allowed to sell natural food in a store?
***
Do not require irradiation of our vegetables - you don't know the consquences.
This will cause more harm than good. You cannot, in any case cannot, require
this treatment of Organic produce as it would a subversion of the very reason for
producing food Organically.
***Any treatment or handling of fresh and fresh-cut leafy green vegetables that utilizes synthetic chemicals or irradiation processes ought to be required to state such on its labling, so that consumers seeking to acquire the healthiest foods possible can make a determination to do so. Joyce DiBenedetto Public Health Education Specialist Miami Florida
***I can hardly believe that you are going to kill our food and then use it to kill us!!! Has anyone looked at what irradiation does? I sure hope there is a sane person among you who will not allow this to pass. I would like to live. This will force us to stop buying in the stores and growing things ourselves. If there is not a healthy populus, there will be an unhealthy world, mentally and physically.
***I'm writing to express my concern regarding the proposed irradiation for raw greens. Irradiation destroys the vitality and life force of food and will in turn seriously undermine the health and vitality of the people of our country. Please do not irradiate raw greens. Sincerely, Christy
***
But irradiation is useful for only a small number of foods, and even in those, there are serious drawbacks. Irradiated foods taste, smell, and feel different from non- irradiated foods. The irradiation process causes molecular changes within foods that form toxins, several of which are known carcinogens, while others are totally unique to irradiation and may have unforeseen health risks. Irradiation speeds up the process of decay in some vegetables that have been cut or bruised during harvesting and actually promotes the growth of certain molds and their natural toxins, aflatoxins-the most powerful of all naturally occurring carcinogens.
Most important, several decades of scientific research, carried out by scientists
around the world, indicate that irradiated food is not safe for human (or any)
consumption. Study after study has shown that eating irradiated food has a variety
of serious adverse health effects, including cardiac hemorrhage and kidney
damage.
***The proposal for federal regulations to mandate the 'pasteurization' of ALL GREENS is the FDA using the word 'PASTEURIZE' as a cover for what they really are up to, which is IRRADIATION.
This zaps all prana, life energy, out of the food. We might as well eat cement.
Profit is not excuse for killing the populace.
Please STOP THIS in the name of God, life, humanity.
If you don't believe in God, you might consider the ramifications for your personal karma.
Thank you on behalf of the human race.
***To Whom it May Concern,
As a nutritionist, filmmaker, wildlife educator and father, I urgently plead
with you to NOT PROCEED with irradiation of organic food products. We as the
citizens of the United States should be given the CHOICE as to whether we want
to eat this denatured food.
I have just finished a feature documentary for worldwide distribution on just
this topic with Andrew Kimbrell , of the Center for Food Safety.
Please do NOT allow this unhealthful procedure to become mandatory, for the sake of our freedoms, our health, and the nutritional needs of our children.
The restorative powers of organic produce will be destroyed .
Urgently, Steve Kroschel / Director "The Beautiful Truth"
***I am opposed to this proposal. Irradiation destroys vitamin content of vegetables
and may cause other problems yet unknown when irradiated foods are ingested as
irradiation permanently alters the nature of that food. Bleaching adds chlorine, a
known carcinogen, to our food--rinsing it off does not solve the problem as
vegetables are porous and absorb whatever is applied to them / sprayed on them,
including the chlorine. Most outbreaks of e. coli (etc.) have been related to poor
farming practices--eg. using sewage as fertilizer or letting sewage from nearby
sources leach into crops--or poor sanitary conditions, such as workers not
washing hands--so it makes more sense to solve problems at the source rather
than destroy the food supply.
I do not want to eat bleach, or feed it to my child.
*** I am totally against the proposal for federal regulations to mandate the 'pasteurization' of all greens. Also using the word 'pasteurize' as a euphemism or cover for irradiation of our food.
***
Risk Management Document: Movement of the Fresh Fruit of Garcinia mangostana L. (mangosteen), Species of Hylocereus, Selenicereus (Dragonfruit), Cucumis melo L. (Melon), Vigna unguiculata (L.) Walp, (Cowpea and its relatives), Artocarpus altilis (Breadfruit), Artocarpus heterophyllus (Jackfruit), and Moringa oleifera Pods, from Hawaii into the Continental United States (March 08, 2007)
Notification Notification ...in Hawaii would like to treat each fruit with an APHIS approved irradiation treatment that would mitigate the pathway risks from susceptible insect pests. Analysis...
***I am not against irradiating food, but I believe food treated in this way should be labeled as such. People should know what they are buying. I believe "Pasteurized" is misleading as a description of irradiated foods. Please get to the ROOT CAUSE, and stop trying to put a band-aid on the problem. If we can't even keep the food supply clean in it's raw form, then what good is it to "pasteurize" it after the fact. The FDA is the nation's food supply police, start policing and stop trying to remove barriers to questionable product quality hitting the store shelves. Thanks.
***We have a right to know how food is handled and what is being done to that food. It seems that the FDA makes decisions for the American people without knowing what long term affects of the process. Please try to remember that this is a government of the people and by the people.
***Stop ruining our food and health. Citizens will stop buying meat and become vegetarians, this ONE will.
COMMENTS FROM CHINA ON USA NOTIFICATION G/TBT/N/USA/254
Irradiation in the Production, Processing and Handling of Food
The government of China appreciates the opportunity to make comments on the
notification of G/TBT/N/USA/254 circulated by WTO.
China agrees on the opinion that the irradiated food has been safe as yet. But, we consider that some questions about the notified regulation should be deliberated. Our comments are as below:
1. As the notification states, "FDA is proposing that only those irradiated foods in which the irradiation causes a material change in the consequences that may result from the use of the food, bear the radura logo and the term 'irradiated', or a derivative thereof, in conjunction with explicit language describing the change in the food or its conditions of use.", that is , the notification has prescribed conditions to bear the radura logo and the term "irradiated", and states that "the fact that a food has been irradiated would not by itself require disclosure on the label".
But, CAC international standards (CODEX STAN 106-1983, REV.1-2003 and CODEX STAN 1-1985, REV.2-1999) state that for prepared food irradiated, the label shall carry a written statement indicating that treatment, and for foods in bulk containers, the declaration of the fact of irradiation should be made clear on the relevant shipping documents, and for products sold in bulk to the ultimate consumer, the international logo and the words "irradiated" or "treated with ionizing radiation" should appear on the container. According to Article 2.4 of the TBT Agreement, and based on the right for consumers to know that the food has been irradiated, we consider that all foods irradiated should bear radura logo and be labeled with indications that foods have been irradiated in terms of CAC international standards, to make consumers free choose ordinary or irradiated foods.
2. The notification states that only those irradiated foods in which the irradiation causes a material change in the food, or material change in the consequences that may result from the use of the food, bear the radura logo the the term "irradiated", or a derivative thereof, in conjunction with explicit language describing the change in the food. In fact, there are much more kinds of foods, and different kinds of foods suffered different irradiation dosage would be with different material changes. In this case, It is difficult to specify the material changes of every kind of food in different conditions, and then, it would bring into trade disputes and result in unnecessary barriers to trade. According to Article 2.2 of the TBT Agreement "Member shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade", we advise USA to cancel such a provision. Or else, please explain the science rationality of the method demarcating material changes.
3. The notification specifies that "These changes are typically process specific and will vary with the food and the irradiation conditions. In addition, these changes and the degree of the changes may be measurable and of consequence to consumers...Rather,the need for labeling must be determined on a case-by-case basis by appropriate testing of the food irradiated under specific conditions, e.g., time and dosage, because the effect of irradiation on the properties of concers depends on the particular food.". But, in the notified regulation, the material changes to be detected, of particular food and corresponding methods have not been specified. We hope that USA should offer more information about those. In addition, general methods for the detection of irradiated foods as stated in the codex standard(CODEX STAN 231-2001,Rev. 1-2003) are still used to qualitatively analyze whether or not the food has been irradiated. So, based on the development and present status of methods for detection of irradiated foods, it is difficult to quantify the material changes. As a result, we suggest that USA should cancel the provision that the need for labeling must be determined on a case-by-case basis by testing of the irradiated food.
***I strongly object to the proposal to change the labeling of irradiated food to something other than "irradiated." The public has an absolute right to know what it is ingesting!
***We the people want to have a choice. If the irradiation is so harmless then why hide it?
***I want to know what is being done to the foods I buy. I would also like a country of origin noted.
***As an investigator responsible for conducting inspections in the food area, I am opposed to the text addition to the irradiation symbol of "Cold Pasteurization" when using gamma-irradiation. The Juice Industry, especially small apple cider manufacturers, have long requested to be able to use the term "Cold Pasteurization" when using UV to provide the 5-log pathogen reduction in their Cider. They have been refused as CFSAN informed them that pasteurization utilizes a thermal process. As UV is a form of irradiation, to allow gamma-irradiated products to carry the statement "cold-pasteurization" and not UV-irradiated product would be unfair to the Cider manufacturers.
***I find all of this most concerning. It seems something is always being added to our food processing and always said to be safe!! Isn't that what you guys said about tobacco???????????
***
DO NOT REDUCE LABELING REQUIREMENTS FOR IRRADIATED FOOD
***Do not make the proposed change to 403(h)3 to allow the word "pasteurized" in lieu of the word "irradiated" to describe the use of a gamma rays to destroy bacteria in food. The 2 processes are not the same and consumers who want to avoid irradiated food will not know that is what they are buying. Thank you.
***
Irradiating is not pasteurized....leave the wording alone.
***
Introduction
The pest lists provided herein have been completed by the Center for Plant Health Science and Technology (CPHST) in response to a request from the Government of Thailand to export Litchi chinensis (lychee or litchi), Dimocarpus longan (longan), Mangifera indica (mango), Garcinia mangostana L. (mangosteen), Nephelium lappaceum L. (rambutan), and Ananas comosus (pineapple) to the United States. The importation of these fruit has the potential to create a pathway for the introduction of unwanted plant pests into the United States. In order to reduce or eliminate the pest risk that may be associated with the import of these fruit into the United States, Thailand has proposed to have the fruit treated with irradiation using an APHIS-approved generic treatment (400Gy) as a condition of entry. By developing these pest lists, APHIS is able to identify pests of potential concern in order to determine if the generic irradiation treatment is adequate or other measures are required.
On July 26, 2006, we published in the
Federal Register (71 FR 42319-42326,
Docket No. APHIS-2006-0040) a proposal 1 to amend the regulations to
allow the importation into the United States of litchi, longan, mango,
mangosteen, pineapple, and rambutan from Thailand. As a condition of entry,
we proposed to require that these fruits be grown in production areas that are
registered with and monitored by the national plant protection organization
(NPPO) of Thailand and treated with irradiation in Thailand at a dose of 400
gray. The 400 gray dose is approved to treat all plant pests of the class Insecta
except pupae and adults of the order Leipdoptera; we proposed to inspect for
the Lepidopteran pests for which the irradiation treatment is not approved.
We also proposed to require that the fruits be accompanied by a
phytosanitary certificate with an additional declaration stating that the
fruit had been treated with irradiation in Thailand. In the case of litchi, the
additional declaration would also have had to state that the fruit had been
inspected and found to be free of Peronophythora litchii, a fungal pest of
litchi. We solicited comments concerning our proposal for 60 days ending
September 25, 2006. We received 43 comments by that date, from producers,
exporters, researchers, members of Congress, and representatives of State
governments. They are discussed below by topic.Based on the comments we received,
we are making one change to the regulations as they were proposed. In
addition to the treatments and safeguards included in the proposed
rule, this final rule prohibits the importation and distribution of litchi
and longan from Thailand into the State of Florida. We are making this change
based on comments regarding the risk associated with the litchi rust mite,
Aceria litchi, which is present in Thailand and is a pest of litchi and
longan. The comments on this topic are discussed in more detail below under
the heading "Pests Named by Commenters That Were Not Addressed
in the Risk Management Document."
***As a consumer, the term "pasteurized" when used as a substitute for the word irradiated causes consternation. The consumer's wishes would seem to be paramount when any food manufacturer makes the decision to market product. That there is no market for irradiated foods whatsoever requires no argument. Therefore, the use of any term to "soften" people's response and to thereby make the concept more appealing is contrary to the interests of society and to the mandate of the FDA. People go out of their way to purchase products that have not been irradiated. If anything, rules concerning the labeling of these foods need to become more stringent including, but not limited to their use as: fillers; stabilizers; flavor enhancers or additives of any sort or variety. The consumer does have the intelligence to make the appropriate decision only when given the correct and not "watered down" information.
***I do not want to eat irradiated food. Continue to label irradiated food. By not doing so, I am unable to make an educated decision as to what to eat.
***Do not soften the regulations regarding the labeling of irradiated food. We have a right to know if our food has been altered. Our health should not be endangered by people in Congress, by allowing irradiated food to slip into our food supply without our knowing. We have the right to choose whether or not we want to eat irradiated food!
***This proposed revised language is very miss leading to the general public and will cause great harm. Irradiation must be identified and labeled properly. We do not need big business harming the innocent.
***Do not relax labeling on irradiated food by calling it pasteurized or removing the Radura from the package! Irradiation changes the structure of the food's molecules making them into something unrecognizable by the body. In other words, irradiation makes foods toxic!
***If its edible and subjected to radiation it should be clearly labeled. Let adult consumers and the market decide. We just want clear information and not misleading terms like "pasteurization". Thank you.
*** The pasteurization and irradiation processes should be kept separate and their
definitions not allowed to morph together. This would allow for confusion and the
possibility for misleading labels.
I strongly urge against the relaxing and expansion of the pasteurization
requirements.
***Rachel Chaput Federal Government - G0005 EPA
:I do not want someone else making the decision for me whether the
food has been functionally changed by irradiation. If it has been irradiated, it should bear the radura logo. what would be the reason for not doing so? probably because the public is uncertain about buying irradiated products. I am uncertain about buying irradiated products and it is my right to be so. I do not want to be
deceived into buying them. that is fraud and it is a violation of my consumer rights.
***To whom it may concern: It is extremely important that you make
sure that the American public knows when food is irradiated. This type of food is not really healthy for they American public. Your governmental organization needs to be fair to the people and let us know when the food is irradiated. Thank you!
***I don't want my food irradiated,it has not had time to prove it isn't harmful to the body. Please see to it that it is labeled so if it is put on the market that I can make a choice. Thank you.
***
Importation of Fresh Mangifera indica (mango) Fruit from India into the Continental United States; Risk Management (February 2007)
Notification Notification
...pest risks, India proposed to treat mangoes with an APHIS approved generic irradiation treatment that would mitigate pathway risks from all insect pests. All insect...
Agency: APHIS Document Type: SUPPORTING & RELATED MATERIALS Comments Due:
Docket ID: APHIS-2006-0121 Document ID: APHIS-2006-0121-0009
Date Posted: Mar 12, 2007
***
Importation of Mangoes From India
Notification Notification
...conditions. As a condition of entry, the mangoes would have to undergo irradiation treatment and be accompanied by a phytosanitary certificate with additional declarations providing...
***Rep. Corrine Brown
City Washington
Country United States
State or Province DC
Organization Name U.S. House of Representatives
Submitter's Representative Rep. Corrine Brown (FL-03)
Government Agency Type Federal
Government Agency
General Comment
Comment Specific talking points/issues
In the proposed APHIS rule, they state that fruit would be grown only in orchards
registered with the National Plant Protection Organization of Thailand. However,
no where does it describe how that will prevent entry of any of the quarantine pests into the U.S. APHIS also does not describe or state that if a quarantine pest is found in an orchard or Thai packinghouse that they will be prevented from sending their fruit to the U.S.
The known fruit pests listed in the document is incomplete. No where in the
document does it discuss how the following documented fruit pests would be
prevented from entering the U.S.
Lychee
i. Cryptophlebia carpophaga. A fruit borer of lychee.
ii. Aceria litchi. A mite that attacks lychee flowers and leaves.
Longan
i. Longan erinose mites (Aceria longana and A. dimocarpi) attack leaves,
fruit, flowers.
ii. Deudorix spp. Fruit borers.
Mango
i. Deanolis sublimbalis, mango see borer.
Irradiation will not control the pupae of the moth fruit pests of litchi and longan and any ant pests.
The APHIS contention that two fungal pathogens (Peronophythora litchii
(Pythiales: Pythiaceae on lychee and Phomopsis mangiferae (Ahmad) on mango)
do not pose a threat to the lychee and mango industries of Florida, California,
Hawaii, and Puerto Rico because there is no chance discarded lychee and mango
fruit would never be dumped in the production areas of those states is not true.
Imported fruit that is dumped by an importer or secondary handlers (e.g.,
packinghouse) in any of those states or discarded by a consumer in any of those
states production areas would pose a risk of establishing these diseases.
Furthermore, the fungus that attacks litchi also attacks tomato and papaya.
The APHIS proposal (and supporting documents Proposed rule for importation of
litchi, longan, mango, mangosteen, rambutan, and pineapple from Thailand - Risk
management and Proposed rule for importation of litchi, longan, mango,
mangosteen, rambutan, and pineapple from Thailand - Environmental assessment)
states that in addition to the fruit being irradiated that the fruit "could" be inspected at the port of entry if an inspector determines that such an inspection is necessary. The fruit should have to be inspected, not could be inspected. As it
is, a very, very low percentage of the fruit will be truly inspected and the record of APHIS keeping devastating pests out of the US is dismal e.g., citrus canker, citrus greening, Asian psyllid, Asian ambrosia beetle, Sri L! ankan weevil, and fig fruit fly, just to name a few of the recent pests to invade Florida.
The APHIS proposal states that prior to harvest that pesticides and fungicides
would be applied to the Thai fruit. No mention is made of what pesticides they will use and whether they are legally registered for use in the US - it is a fact that imported fruit cannot have been sprayed with pesticides not legal in the US! .
The risk management document states that the "portion of the total number of
tropical fruit shipments expected to be transported to the producing areas in
California, Florida, Hawaii or Texas is expected to be small and the likelihood of
fruit being discarded in or near orchards very low." This in not a true statement.
Where is the APHIS data to prove this statement?
The US census data on the Asian American population of the US is 4%, and that
in Hawaii it is 42%, in Florida it is 2%, in California it is 12%, in Texas it is 3%, and Puerto Rico it is 0.2%. This represents over 12.4 million Americans. This
clearly demonstrates there will be demand for these fruits and the APHIS
statement is patently not true.
The most common method of propagation of for polyembryonic Asian mango is by
seed. To insinuate that this will not occur in either the urban or agricultural areas of Florida, Hawaii, California, Texas, and Puerto Rico is not true.
Economic analysis.
APHIS claims mangos are not commercially produced in Florida, Hawaii,
California, and Puerto Rico - this is patently false. There is over 800 acres in
Florida alone, 2,000 acres in Puerto Rico, 200 acres in California, and 250 acres in Hawaii.
APHIS claims imports of these fruits do not compete with domestic production
and that all US mango, lychee, longan, and pineapple production is sold locally.
NOT true - over 80% of the tropical fruit production in Florida alone leaves the
state.
No economic impact was conducted on the tropical fruit industries (more
importantly the small, medium and family farm businesses) of Florida, Hawaii,
California, and Puerto Rico. APHIS uses the excuse that only limited or no data
exists that documents the size of the tropical fruit industries of Florida, Hawaii,
California, and Puerto Rico. The University of Florida, IFAS, Food and Resource
Economics Dept. has documented that the Florida lychee, longan, and mango
industries alone are worth an est! imated $25.3 million and this does not take into account the economic impact those crops have on employment etc.
APHIS further claims that mango, lychee, longan, and pineapple produced in the
US (FL, HI, CA, PR) are only sold locally (directed to local markets) and so are
not hurt by cheap imports. Again not true - look at mangos, lychee and longan in
Florida, grower (farm gate) prices have continued to fall because of competition
from Latin America, Taiwan, Mexico, and now China. This is an out and out
fabrication. They have no idea and have not diligently sought to find out the
economic impact.
APHIS claims there is no data on the mango, lychee, longan, and pineapple
acreage or production in the US. This is not true - information exists from the
state dept. of agriculture of each state and from the state universities that work
with the industries (e.g., the University of Florida, IFAS; Dept. of Horticulture,
Dept. of Food and Resource Economics, Dept. of Entomology, Dept. of Plant
Pathology, etc.). We have published data and a lot of it is on the WWW -
obviously they did not look or call anyone.
Under the APHIS proposal heading "Effects on Small Entities", APHIS states "It is
likely that the entities affected would be small..." and goes on to cite data that is irrelevant to the section heading. It concludes that "thus domestic producers and importers that may e affected by the proposed rule are predominately small entities. Based on the data available to APHIS it does not appear that domestic production of litchi, longan, mango, etc. compete with imports of these fruits"
Basically this section says producers in Florida, Hawaii, California, and Puerto
Rico are not affected by imports of these fruit and its ok of small farmers are
devastated by these imports.
APHIS' confidence that exposure to 400 Gray of radiation will neutralize invasive pests is undermined by its own caveat that fruit destined for export to the US must be "grown in a production area that is registered with and monitored" by Thailand. Doing so, APHIS says, will reduce the number of pests in fruit and thus "maximize the effectiveness of the irradiation treatment" APHIS provides no supporting data - in the Proposed Rule or its Risk Management or Environmental Assessment documents - on the relationship between the number of pests residing in a particular fruit, and the ability of a specific irradiation level to eradicate them.
***Consumer Comments on Food Irradiation
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