Mmmm…Cold Pasteurized Burgers Anyone?

By John Conway | July 3, 2007 12:29 pm

Today is the last day left in the FDA’s public comment period regarding changes to the labeling rules for irradiated food. Given the other problems in the world, this may or may not have been on your radar screen, but if you eat meat it certainly should.

Imagine if there were a product, say a soft drink, that sickened upwards of 200,000 people every year, and killed thousands. How would the public react? Clearly there would be outrage on a truly massive scale, legislation, regulation, whatever it took to end the scourge. Just look at the outrage ensuing after the spinach crisis last year.

We have such a product in this country: meat. It is produced in conditions such that the main processing challenge in bringing it to market is simply keeping “filth” – the animals’ own excrement – from infecting the final product. The public has simply accepted the sickness and death as collateral damage, not a problem to be solved. Nothing must get in the way of the steady stream of 99 cent burgers!

The meat industry has a “solution” which I put in quotes because it may be worse than the problem itself: food irradiation. The minute most people hear that their hamburger is made from meat that was irradiated, they don’t want it. And if more read the label that is presently required (but proposed by the meat industry to be removed) then they might not buy it.

Food irradiation kills bacteria, but not all of them. The meat industry wants to irradiate food so as not to have to spend more money making meat processing safer at the slaughterhouse, which would raise the cost to consumers.

The real problem, though, is how radiation kills bacteria. Often the irradiation is performed using an isotope of cobalt which emits gamma rays – very energetic photons, more energetic than x-rays, which are also used for this purpose. These photons travel a long way through most materials and lose their energy by knocking electrons off the atoms of the material. The emitted electrons have a great deal of energy and knock off other electrons, sometimes resulting in breaking up the molecules of the material. These molecular fragments are called radiolytic byproducts. The radiation does not just kill bacteria, but produces new molecules in the meat itself never encountered in nature, some of which may be harmful. We actually don’t know very much about this possibility.

We do know that for irradiated fats, long-chain carbon based molecules, the radiolytic byproducts include 2-ACB, a chemical shown to cause colon cancer in mice. But that is just one of potentially thousands of different radiolytic byproducts of irradtiation. In effect, we are performing an enormous, uncontrolled experiment on millions of human beings – us – for the sole purpose of saving the already heavily subsidized meat industry a few pennies on the dollar. The effects could be devastating, healthwise, or maybe not. Is it worth the risk?

Even more interesting is a study of the change in flavor of irradiated meat products. The irradiated meat was descibred as tasting like “wet dog” or “singed hair”. Yum.

Food irradiation is banned in Europe, largely due to the above concerns. At a minimum, the labelling requirements should stay in place. The meat industry has lobbied to change the label to say “cold pasteurized” or remove it altogether. But we ought to be considering an outright ban on this very questionable practice.

I am not a vegetarian, but I used to be for about eight years, partly for reasons like this. I buy organic meat now whenever possible, and avoid fast food. I want to know what I am getting, and the meat industry doesn’t want us to know! Why don’t we let an informed market decide this one?

Here is a link to the FDA proposed rule change and public comment info.

  • Rev. BigDumbChimp

    Ugh. That’s why it’s always a good idea to only buy meat from quality sources and only buy ground meat that is ground where you buy it or grind your own. Most butchershops in groceries or standalone will be happy to do it for you. The prepackaged stuff is scary at best.

  • elena

    thanks for the reminder – our food system needs to get cleaner, not worse.

  • Rien

    It’s old hat by now, but I read Fast Food Nation about five years ago and have not set foot in a McDonald’s or Taco Bell since. I don’t miss it.

  • Mark Srednicki

    Thanks John. I find that people are often surprised to learn that physicists don’t universally think that food irradiation is a good idea.

    Comments on the rule change are due by TODAY (July 3). To comment, go to

    Here is the summary of the proposed action, extracted from John’s link:

    SUMMARY: The Food and Drug Administration (FDA) is proposing to revise
    its labeling regulations applicable to foods (including dietary
    supplements) for which irradiation has been approved by FDA. FDA is
    proposing that only those irradiated foods in which the irradiation
    causes a material change in the food, or 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. For purposes of this rulemaking, we are using
    the term “material change” to refer to a change in the organoleptic,
    nutritional, or functional properties of a food, caused by irradiation,
    that the consumer could not identify at the point of purchase in the
    absence of appropriate labeling. FDA is also proposing to allow a firm
    to petition FDA for use of an alternate term to “irradiation” (other
    than “pasteurized”). In addition, FDA is proposing to permit a firm
    to use the term “pasteurized” in lieu of “irradiated,” provided it
    notifies the agency that the irradiation process being used meets the
    criteria specified for use of the term “pasteurized” in the Federal
    Food, Drug, and Cosmetic Act (the act) and the agency does not object
    to the notification. This proposed action is in response to the Farm
    Security and Rural Investment Act of 2002 (FSRIA) and, if finalized,
    will provide consumers with more useful information than the current

  • Andy

    Although food irradiation might be banned in the EU, I heard that most spices (salt, pepper, oregano, stuff like that) does get irradiated in Europe too. How about USA?

  • ST

    Gotta love the Luddites. I have to at least give them credit for turning the perception of a method of increasing food safety into a method for excusing proper food handling practices. As is usually the case in these types of arguments, there is plenty of data showing that irradiation does not break down vitamins, etc. As a parent, would I be more worried about my kid getting E-coli from a cross-contaminated or undercooked burger versus some potential but never documented possible degradation of the nutritional value of the burger due to irradiation? Reminds me of the bovine growth hormone nonsense. My understanding is that the resulting milk is chemically indistinguishable from milk from cows not receiving BGH… And then there are the people in a tizzy over genetically modified organisms (another great bit of PR spin). As if people haven’t been doing modification of genomes for centuries by the cruder methods of cross breeding and hybridization… Ah well… Expecting people to be logical about the real and perceived risks in life is always a setup for disappointment.

  • David

    Have any published studies demonstrated that irradiated meat is more harmful than the meat currently available at my local supermarket?

  • G-Jo

    Please correct me if I’m wrong; if I am, I’ve been guilty of spreading misinformation, and I need to stop.

    I’ve heard that it’s possible to irradiate meat to kill E. Coli, etc. using UV; that’s not severely ionizing, but that it still counts as “irradiated”, for obvious reasons. I’ve also heard that it’s commonplace in other countries. I can’t remember WHERE I heard it, and now for the life of me I can’t find any sources.

    That said, I grew up on a farm. Current meat is so far away from the taste of clean, grain-fed beef that if it gets any worse, I may switch to cardboard instead.

  • John

    ST, this is probably the first time I have even been called a Luddite… But you bring up the subject of GMOs and so let’s think about that for a second.

    Did you know that, in an effort to prevent theft of their “intellectual property”, compnies like Monsanto put a genetic sequence which is in effect their corporate logo into the corn and soybean genomes they sell? They put these GTAC logos into the large “unused” portions of the plant’s genes.

    One little problem: it’s recently been discovered that these unused portions are in fact not unused at all. In fact I daresay that we’ve barely scratched the surface of what it is these sections of the genome do, but they do something.

    I wouldn’t object to food irradiation if it weren’t for the pesky fact that the research that has been done is far from reassuring.

  • Ron

    performing an enormous, uncontrolled experiment

    Just think of Europe as the control group and honor the brave U.S. citizens for volunteering as human subjects. This has been going on for a while. Kellogg, for example, will sell the same cereal to U.S. and European markets using GMO ingredients for the U.S. and non-GMO ingredients where so required by law. In a few decades we may be able to tease out some data treating this as a huge epidemiology study for the long term effects. Admittedly, it’s not as clean as a properly designed double-blind study, but you take what you can get.

    (In case anyone reading is parody-impaired: Yes, I am being facetious.)

  • Count Iblis

    I don’t think we should worry too much about extremely small quantities of potentially dangerous substances. The human body is constantly repairing damage done to itself caused by chemicals, radiation etc. You need to overwhelm this repair capacity or compromise it somehow to do permanent damage.

    After the Chernobyl disaster it was predicted (based on simple extrapolations from Hiroshima and Nagasaki) that hundreds of thousands of people would die, most of them in regions quite far away from Chernobyl due to being exposed to slightly higher than background level radiation. Even though the probability of someone dying from low levels of radiation is small, far more people live far away from Chernobyl than close to it.

    However, recent studies have shown that this hasn’t happened. There seems to be a threshold level of radiation you need to be exposed to to increase the risk of cancer. But that’s what you would expect given that the body is repairing damage due to radiation all the time anyway.

  • Lord

    I don’t consider the effects on meat a great concern, rather it is the effects on the meat industry which would be to lower standards. It was what happened with Alar on apples.

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  • Gavin


    I’m going to be blunt here. You are talking about something outside your field, and appear to have fallen for a load of pseudoscientific scare tactics. These arguments are basically what we hear from the anti-fluoride, anti-vaccine, anti-pesticide, etc. folks all the time: “we just don’t know, so is it worth the risk?” The answer is usually that we do know and yes it is. I haven’t studied the meat issue in detail, so maybe there are legitimate concerns, but you certainly haven’t made the case.

    Your post is conspicuously lacking and references. What quantities of radiolytic compounds are we talking about? Keep in mind the cooking produces all sorts of crazy new chemicals too, and in much, much higher quantities. Nobody has tested those compounds; we don’t even know what many of them are. Should we stop cooking our meet because it just isn’t worth the risk?

    It has not been discovered that “these unused portions are in fact not unused at all.” What are you talking about?

    I have economic, environmental, and ethical concerns about the way meat is produced in this country, but, as you point out, people are getting sick. The question is, would irradiation cause fewer people to get sick. It seems the answer is a rather obvious yes, but I’d be happy to see evidence otherwise.

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  • Kenton A. Hoover

    In the US, spices, some pharmaceuticals, and medical supplies are sterilized using radiation. Also, we do have a reasonable amount of knowledge about food irradiation’s effects: the former Soviet Union was an extensive user of irradiation and many papers are available. There are a wide variety of products for which it’s been shown suitable or not. You can find a short description of the Soviet finding in “Red Atom”.

  • JerseyBoy

    I have to be honest, I’m pretty disappointed with the level of science here. There’s a lot of talk with very little facts to back anything up.

    First of all, there was an article by Raul in 2000 that showed 2-ACB to be a PROMOTER not a CARCINOGEN. There’s big difference. The promoter can cause cellular malfunction, but it doesn’t induce cancer. It does, however, make it easier for other carcinogens to act.

    Secondly, at no time in any of these articles do they compare quantities of exposure to expected quantities of consumption. There are many compounds out there that are toxic/carcinogenic in large doses but are perfectly benign in normal consumption. For instance tannins in tea leaves can cause liver cancer in large doses. However, you don’t see a large block of liver cancers in the UK or other heavy tea-drinking areas. No one seems to be asking about exposure quantities.

    Food irradiation is normally done at ~0.5 MRads (per CDC). What’s the by-product production per Rad per pound of meat? What’s the toxic level of by-product?

    Lastly, there’s a pretty large history of irradiated foods in this country and others. In 30 seconds of searching, I found that The Journal of Food Safety, for instance, shows a bunch of articles on the short/long term safety of exposure to irradiated food. While individual by-products might show up as toxic at certain levels, none of the short/long term studies in humans/animals have shown that eating irradiated foods has any negative consquences. Granted, I was only skimming abstracts, but I don’t really see any showing that the intended use here is dangerous.

  • assman

    I think this article exhibits a common type of fallacious thinking. The idea goes essentially as follows:

    “We have never tried X before and associated with X are large possible unknown risks. Therefore we should not do X”.
    In fact this is the essential idea behind the precautionary principle. It is also part of the reason people opposed gay marriage, female voting rights etc.

    The problem with this argument is that it assumes that are not large unkown risks associated with not doing X. For instance, there may be large unknown risks associated with a vegetarian diet, organic foods and many natural foods. I would say in fact because there has been a very strong bias towards studying synthetic substances we know a lot more about the risks associated with them than with natural compounds. So if anything the precautionary principle implies that we should be far more wary of natural compounds.

    Many would say that since we have been living with natural compounds for thousands of years we have adapted to them. I think this idea is problematic because evolutionary adaptation does not imply long life, it only implies that a person is healthy long enough to reproduce and raise their young. So it is quite compatible with evolutionary adaptation for a natural compound to cause cancer as long as it takes enough time to do it. Natural designs do not have to be perfect by our standards, they just have to be good enough. So a natural substance that is good enough for a person to live 40 years in the prehistoric past may not be good enough if you want to live to age 80 today.

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  • Maynard Handley

    Jesus. Like ST said.

    We do know that for irradiated fats, long-chain carbon based molecules, the radiolytic byproducts include 2-ACB, a chemical shown to cause colon cancer in mice. But that is just one of potentially thousands of different radiolytic byproducts of irradtiation.

    Numbers please. Don’t give me the old “shown to cause cancer” crap. We all know that practically anything can be made to cause cancer when fed in appropriate doses. How about you tell us how much of this cancer causing chemical appears in a pound of meat, how much it takes to cause cancer in a human being, and thus give us a useful comparison number?

    Meanwhile what can you say when you reading something like

    That said, I grew up on a farm. Current meat is so far away from the taste of clean, grain-fed beef that if it gets any worse, I may switch to cardboard instead.

    except to call bullshit? Either you didn’t grow up on a farm or you are an idiot. What the hell is “clean, grain-fed beef”. Grain is not a natural diet for beef. It fscks the hell out of their ruminant stomachs. Current beef cattle have been bred to do the best they can on the diet, which is basically to stay alive with their stomachs not rupturing until the slaughter house; but there is no way that they are happy or healthy on the diet. The only reason the whole insane system exists is because of US corn subsidies. The fact that corn-fed is a complimentary adjective when applied to children does not make it so when applied to cattle.

    There is a common place word for this claim that nefarious people out there are planning to do terrible things to us and our children. That word is witchcraft. The psychology of what is going on here is little different from 17th century Europe, or the occasional stringing of some unfortunate in rural Africa. There is something about the human mind, even the supposedly trained and educated human mind, that immediately leaps to the constellation of ideas that spell witchcraft; no different from seeing faces in photos of Mars, or in grilled cheese sandwiches.

  • Ellipsis

    A question — are the carcincogenic or cancer promotional effects of 2-ACB and other irradiation products known, or thought, to be any greater than the carcincogenic or cancer promotional effects that are known to occur in the “char” that one gets on a burger when one barbeques it? (I know that the latter is supposedly slightly carcinogenic as well — however a lot of people still had barbeques on the 4th of July.)

    Although I know nothing about the subject — my general sense is that, if anything, I’d be a bit more worried that the industry becoming more lax on cleanliness as a result of this, than any actual direct medical consequences of any chemicals produced in meat irradiation. (That’s of course just a guess though.) Of course things should be reasonably labelled so that consumers — well-informed or otherwise — can make their own choice, though. (I would think clealy marking things as “cold-pasteurized” would be fair.)

  • JMG3Y

    John, IMO with respect to filth and industry intentions you are out to lunch on this one. You’re sorta on my turf. Hike over and have a chat with your colleagues at the UC Davis Food Safety Lab, Cliver and Riemann. They are not industry apologists and they can fill you in what the food industry, meat or otherwise, and the consumer are up against.

    The problem is that bacteria are exceptionally resourceful though unseen critters, having been here far longer than us and likely to be so long after we are gone. And they are absolutely everywhere, being very hard to get totally rid of. Your body has something like 10-fold more microbial cells than your own. Body tissues provide excellent culture media; much bacteriological culture media is based on blood, serum or tissue derivatives. Why do you think surgeons go to such great lengths to prevent bacterial contamination during surgery? Bugs are everywhere and the body interior, yours and animals, present fantastic nutrition sources compared to the environment.

    Meat and many other human foods simply represent a fantastic nutritional source to be exploited at every opportunity, particularly if no competitors are present as they are in the gut. Irradiation represents a further control measure against them. I doubt that industry will relax their current practices because the legal exposure is too high and because of the quality effects. Catch one of the bad bugs, have sufficient evidence to prove to a jury that a company was culpable and law firms such as Marler Clark will be happy to make sure you and your heirs never have to work another day in your or their lives. Actually, I suspect this has far more effect on industry behavior than government regulation.

    No doubt there will be some bad actors; there always are even now. But I expect that most firms in the industry do and will continue to exceed regulatory standards. With HACCP, they are already doing considerably more testing than regulations require. Quality effects will limit excess irradiation use to the point of sterility or that heavily contaminated foods would require. I expect the killing is a log reduction phenomenon as it is with other processes so a three log reduction from 10^9 is still 10^6, a huge infectious dose for most things, while a 10^1 is to 10^-2, well below the infectious dose for most agents and people.

    I expect the meat industry would follow the milk industry with respect to pre-pasteurization quality standards. Even though pasteurization controls most of the bad bugs, the industry has tried repeatedly to get the FDA to make the PMO standards stricter because most producers exceed the standards by far and they recognize the adverse quality effects of those producers who just meet the current FDA standards.

    Because of what are in effect sampling effects, I suspect that “local” foods may actually be riskier than foods processed in larger batches. Small local outbreaks due to process errors that result in infectious doses in the tail of human susceptibility are much harder to detect than are nation-wide exposures of the same dose level. My answer is still to minimize the opportunities for temperature abuse and for cross contamination and to cook it well, animal or vegetable. I doubt the cooking process was developed for reasons of taste. And everyone washing their hands at the proper times would significantly reduce the infectious disease burden in the population. Every serving of fast food should come with an alcohol hand rub packet and everyone should stare at anyone spotted not using them. :-) FWIW.

  • Andyfell

    In addition to the UC Davis food safety experts mentioned above, Christine Bruhn at the Center for Consumer Research studies the issue and maintains a FAQ on it. Look for the link under CCR webpages.


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