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Misc. News : Consumer Affair Last Updated: Apr 20, 2011 - 9:38:09 AM

Part 2: Consumer Opinions on Food Irradiation
By Arthur Tesla
Nov 2, 2008 - 11:48:43 AM

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The FDA and USDA on Irradiation
Part 2: Consumer Opinions on Food Irradiation

The Food and Drug Administration (FDA) is amending the food additive regulations to provide for the safe use of ionizing radiation for control of food-borne pathogens, and extension of shelf-life, in fresh iceberg lettuce and fresh spinach, both raw and pre-processed vegetables, fruits, and other agricultural products of plant origin at a dose up to 4.0 kiloGray (kGy). This action is in partial response to a petition filed by The National Food Processors Association on behalf of The Food Irradiation Coalition. The petition and addresses only the use of ionizing radiation on iceberg lettuce and spinach. The use of ionizing radiation on the remaining foods included in the petition remains under review.

Three general areas need to be addressed: (1) Potential toxicity, (2)nutritional adequacy, and (3) effects on the microbiological profile of the treated food. FDA concludes that no significant change in carbohydrate nutrient value or functionality is expected to occur in iceberg lettuce and spinach irradiated at doses up to 4 kGy. Based on the totality of the evidence, FDA concludes that irradiation of iceberg lettuce and spinach under the conditions proposed in this petition does not present a toxicological hazard.
              Don't Mess With My Spinach!
FDA has carefully reviewed the data and information submitted in the petition, as well as other data and information in its files, to determine whether irradiation of iceberg lettuce and spinach would have an adverse effect on the nutritional quality of the diet. FDA concludes that the small losses of vitamin A that might result from the proposed irradiation of iceberg lettuce or spinach will have little impact on the total dietary intake of this vitamin. FDA concludes that irradiation of iceberg lettuce and spinach up to a maximum dose of 4.0 kGy will have no impact on the total dietary intake of vitamin K. FDA concludes that radiation-induced loss of folate in iceberg lettuce or spinach will have no significant impact on the dietary intake. In summary, based on the available data and information, FDA concludes that amending the regulations, as set forth below, to allow for the use of ionizing radiation to treat iceberg lettuce and spinach up to a maximum dose of 4 kGy will not have an adverse impact on the nutritional adequacy of the overall diet. Contamination of fresh produce with several specific pathogens continues to be a public health problem. Infections from Salmonella enterica serovars and Escherichia coli O157:H7, for example, have not decreased since 1996. Most of the recent serious outbreaks of illness attributed to consuming lettuce or spinach have resulted from contamination by E.coli. Contamination of leafy greens with Listeria or Salmonella also continues to be a public health problem. Even though other pathogens may be present. Data and information relevant to microbiological considerations presented in the petition included published studies of radiation-induced reductions in levels of different microorganisms in a variety of fruits and vegetables under different conditions of irradiation. Based on the available data and information, FDA concludes that irradiation of iceberg lettuce and spinach conducted in accordance with good manufacturing practices will reduce or eliminate bacterial populations with no increased microbial risk from pathogens that may survive the irradiation process. FDA received several comments from Public Citizen (PC) and the Center for Food Safety (CFS) requesting the denial of this and other food irradiation petitions. FDA has reviewed studies in which animals were fed diets containing irradiated fruits and vegetables. No adverse effects were associated with consumption of these food types. The comment provides no additional information that would alter the agency's conclusion that the consumption of irradiated iceberg lettuce and spinach does not present a health hazard. One comment stated that "FDA has no definitive list of foods that are covered by the petition." FDA disagrees with this comment. FDA also notes that a listing of each and every food covered by a food additive petition has never been required and is not necessary. The agency frequently evaluates food additive petitions intended to cover broad categories of food types. Further, this partial response authorizing irradiation of iceberg lettuce and spinach up to a maximum dose of 4.0 kGy addresses two specific foods, rendering the issue moot. FDA has reviewed a large body of data relevant to the assessment of the potential toxicity of irradiated foods, including irradiated fruits and vegetables. FDA concludes that the proposed use of irradiation to treat iceberg lettuce and spinach with absorbed doses that will not exceed 4.0 kGy is safe DATES: This rule is effective August 22,2008.

DEPARTMENT OF AGRICULTURE-Animal and Plant Health Inspection Service, USDA.
Importation of Mangoes From India.ACTION: Final rule.
SUMMARY: We are amending the fruits and vegetables regulations to allow the importation into the continental United States of mangoes from India under certain conditions. As a condition of entry, the mangoes must undergo irradiation treatment and be accompanied by a phytosanitary certificate with additional declarations providing specific information regarding the treatment and inspection of the mangoes and the orchards in which they were grown.

I would like to offer correction to your statement mentioning the presence of only one irradiation facility in India.There are multiple food irradiation facilities in India. I am quoting the food and water watch article from Nov 2006: "The Indian government has supported food irradiation, and the Department of Atomic Energy has built two demonstration facilities that use cobalt-60, both near Mumbai. The facility at Vashi, Navi Mumbai is a high-dose facility that processes spices and dry vegetables (30 tons/day). A low dose facility in Lasalgaon irradiates onions (10 tons/day), cereals and cut flowers." Also, "India has two additional irradiation plants and three more are being planned" I am not sure about the APHIS certification status of the additional plants but the irradiator, currently in the final stages of completion, at Vasai (near Mumbai) by AgroSurg Irradiators India Pvt Ltd meets all the requirements outlined in 7 CFR Part 305.

The State of Hawaii has requested the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), to allow the interstate movement of mangosteen (Garcinia mangostana), dragon fruit (species of Hylocereus and Selenicereus), melon (Cucumis melo), pods of cowpea (Vigna unguiculata) and its relatives, breadfruit (Artocarpus altilis), jackfruit (Artocarpus heterophyllus), and fresh Moringa pods (Moringa oleifera) into the continental United States. The current regulation titled Hawaiian Fruits, Vegetables and Flowers (7 CFR 318.13) prohibits or restricts the movement of fruits, vegetables, and flowers into the continental United States from Hawaii in order to prevent the introduction and dissemination of plant pests that are new to or not widely distributed within the continental United States.

To permit, under certain conditions, the movement of commercial shipments of mangosteen, dragon fruit, melon, pods of cowpea and its relatives, breadfruit, jackfruit, and fresh Moringa pods from Hawaii into the continental United States
                     following irradiation treatment.

Irradiation treatment involves exposure of the commodity, under controlled conditions, to gamma rays or to electron beams. The amount of energy absorbed is expressed in units of Grays (Gy). Under 7 CFR 305.31, the current regulation calls for a minimum absorbed dose of 150 Gy to neutralize fruit flies and a minimum absorbed dose of 400 Gy for a neutralization of other insect pests, excluding adults and pupae of the order Lepidoptera. Neutralization signifies that the insect has been killed, rendered sterile, or prevented from further development into an adult (APHIS, 2007). Specific requirements for irradiation treatment facilities used to treat commodities imported into the continental United States are provided in 7 CFR 305.31. In compliance with these regulations, specific operational requirements for each irradiation facility in Hawaii will be provided in an operational work plan. Consumption of irradiated fruits and vegetables poses no significant risk to consumers. The U.S. Department of Health and Human Services, Food and Drug Administration (FDA) issued a final rule regarding food irradiation in 1986 (21 CFR 179) which states that absorption rates below 1000 Gy will not make food radioactive, affect the safety of the food, alter the nutritional value of the food, or adversely affect the balance between microbial spoilage organisms and pathogenic organisms. FDA also determined that no adverse environmental effects are anticipated at food processing plants that are designed to irradiate fruits and vegetables (FDA, 1982). Properly designed and correctly operated commercial irradiators have been routinely shown to function without significant radiation risk to workers or the public (CH2M Hill, 1987). A written certification by a licensed engineering and safety inspector will be issued showing that the facility meets all safety and health requirements for safe operation in compliance with 7 CFR 305.31.
Since 2002, 15 different fruits have been approved for irradiation treatment for movement from Hawaii into the continental United States at a minimum absorbed dose ranging from 150 to 400 Gy without any observed adverse effects to human health or the level of pest risk. Fruits and vegetables treated with irradiation in Hawaii and moved to the continental United States have had no live pest interceptions of quarantine significance
(APHIS, 2007).

Pest Risk Mitigation Measures This EA analyzes potential environmental consequences from amending the Hawaiian Fruits, Vegetables, and Flowers regulation to allow the movement of commercial shipments of fruit from Hawaii into the continental United States. Two alternatives are considered in this EA: (1) no change in the current regulations which do not allow the movement of commercial shipments of mangosteen, dragon fruit, melon, pods of cowpea and its relatives, breadfruit, jackfruit, and Moringa pods from Hawaii into the continental United States (the no action alternative), and (2) amendment of the regulation to allow the movement of commercial shipments of these fruits from Hawaii into the continental United States under certain conditions (the proposed action). A. No Action The no action alternative will leave the Hawaii fruits, vegetables, and flower regulation unchanged. The movement of mangosteen, dragon fruit, melon, pods of cowpea and its relatives, breadfruit, jackfruit, and fresh Moringa pods from Hawaii into the continental United States would continue to be prohibited. B. Proposed Action The proposed action will amend the irradiation regulations under 7 CFR 305.34 and the existing fruit, vegetables, and flower regulations in 7 CFR 318.13 for the purposes of allowing the movement of commercial shipments of mangosteen, dragon fruit, melon, pods of cowpea and its relatives, breadfruit, jackfruit, and fresh Moringa pods from Hawaii into the continental United States. The movement of fruit will be subject to the following measures: Irradiation The fruit must be treated with irradiation in accordance with 305.34 in an APHIS-approved facility in Hawaii or the continental United States; Irradiation treatment must be monitored by an APHIS inspector to ensure that the fruit received a minimum absorbed dose of 150 Gy or 400 Gy. Each shipment containing fruit treated in Hawaii must be accompanied by a certificate of irradiation treatment in accordance with 305.34. The fruit must be packaged, labeled and safeguarded from reinfestation by pests as per the requirements of treatment in accordance with 305.34(b)(4). Treatment with the 150 gray dose Must either receive a post-harvest dip in accordance with treatment schedule T102-c (warm soapy water and brushing) as provided in 305.42(b); or originate from an orchard or growing area that was previously treated with a broad-spectrum insecticide during the growing season and a pre-harvest inspection of the orchard or growing area found the fruit free of any surface pests as prescribed in a compliance agreement. The fruit must be inspected after harvest by an APHIS inspector in Hawaii and found free of spiraling whitefly -Aleurodicus disperses, inornate scale -Aonidiella inornata, green scale -Coccus viridis, red wax scale -Ceroplastes rubens, gray pineapple mealybug -Dysmicoccus neobrevipes, pink hibiscus mealybug -Maconellicoccus hirsutus, spherical mealybug -Nipaecoccus viridis, and citrus mealybug -Pseudococcus cryptus, and melon thrips -Thrips palmi. The fruit must be inspected for signs of damage caused by melon thrips -Thrips palmi. Treatment with 400 Gy dose would not be required to undergo additional inspection for insect pests. Movement of fruit to mainland for irradiation treatment Must be treated with a minimum absorbed dose of 400 gray. Shipments containing fruit to be treated in the continental United States must be issued a limited permit by an officer or official authorized by APHIS.

Historical Performance of Importing Irradiated Fruits
Current regulations 7CFR 305.31 and 7CFR.319.56-4 allow the use of irradiation to treat fruit for importation into the United States. Beginning in April, 2007, India has shipped mangos to the United States irradiated with a minimum dose of 400 Gy targeting arthropod pests and with a systems approach for fungal pathogens. Regulation 7CFR318.13-4 allows interstate movement of fifteen different fruits, including mangos from Hawaii, allowing irradiation using a minimum absorbed dose of 150 Gy and 400 Gy for fruit flies, seed weevils and other quarantine pests. Fruits and vegetables treated with irradiation moved interstate from Hawaii have had no pests of quarantine significance intercepted AQAS-PestID, 2007. On very rare ocassions when live fruit fly larvae were detected in irradiated shipments, they were always found to be moribund and never resulted in further development or completing life cycles (Uyeda, 2005). Evidence for the Effective Removal of Pests of Concern from the Pathway The following paragraph summarizes key mitigation measures for the importation of guava fruit from Mexico and provides a general discussion of their efficacy. The evidence APHIS uses to determine that the measures described above effectively remove pests of concern from the pathway are also discussed. The FAO (2002) defines "pathway" as "any means that allows the entry or spread of a pest." Arthropod Pests Twenty one of the twenty six pests likely to follow pathway are insects. There are no records of importing irradiated guavas from Mexico, but records of interstate movement of mangos from HI into the United States treated with 300 Gy irradiation, show no interceptions of quarantine pests since 2000 (Uyeda, 2005). Additionally, reports of twelve shipments of mangos irradiated with 150 Gy imported from Australia into New Zealand since 2004, provide no record of quarantine pest interceptions from the irradiated mangos (Edwards, 2005). Although the pest complex in Hawaii or Australia is different from that described for Mexican guavas, the 150 Gy minimum absorbed dose has been determined to be effective against all fruit flies (USDA, 2006). As part of the United States requirements governing the use of irradiation as a phytosanitary treatment (7CFR305.31), APHIS and the NPPO of Mexico will jointly develop an operational work plan. The work plan shall incorporate details of treatment and preclearance activities including inspection of articles that APHIS may perform before or after the treatment. Inspection of the guava fruit for the presence of pests not targeted by irradiation during preclearance activities will further ensure that the pests of concern are removed from the pathway.

The Smoking Gun

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 Cosmetics Act. c f052


Produce giant Dole Food Company is considering irradiated lettuce. "We are currently doing extensive testing with irradiation and it looks to be very promising," said spokesman William Goldfield.

A food additive petition filed by the National Food Processors Association (NFPA) on behalf of The Food Irradiation Coalition, to provide for the safe use of ionizing radiation for control of food-borne pathogens, and extension of shelf-life, in a variety of human foods up to a maximum irradiation dosage of 4.5 kilograys (kGy) for non-frozen and nondry products, and 10.0 kGy for frozen or dry products.

The food additive regulations in part 179 Irradiation in the Production, Processing and Handling of Food (21 CFR part 179) be amended to provide for the safe use of ionizing radiation for control of food-borne pathogens, and extension of shelf-life, in a variety of human foods up to a maximum irradiation dosage of 4.5 kGy for nonfrozen and non-dry products, and 10.0 kGy for frozen or dry products, including: (1) Pre-processed meat and poultry; ( 2 ) both raw and pre-processed vegetables, fruits, and other agricultural products of plant origin; (3) certain multi-ingredient food products

Center For Food Safety Objections

1. FDA has failed to determine the magnitude of nutrient losses to be expected from irradiation of fresh spinach and iceberg lettuce at or near the maximum permitted dose of 4 kGy, undermining its analysis.
2. FDA has substantially underestimated the nutritional contributions of fresh spinach and iceberg lettuce to American diets, and therefore underestimated the impacts of irradiation induced nutritional losses in these vegetables on American diets.
3. FDA has failed to conduct a cumulative assessment of irradiation-induced nutrient losses in fresh spinach and iceberg lettuce in combination with irradiation-induced nutrient losses in other foods already approved for irradiation, and should undertake such an assessment. Given the large number of items FDA is presently considering for irradiation approval in food additive petition 9M4697, cumulative assessments of this sort should be undertaken prospectively for the items covered in this FAP.
4. FDA has failed to determine whether irradiation of fresh spinach and iceberg lettuce as permitted in the final rule will increase the risk of food-borne disease from radiation insensitive pathogens such as Clostridium botulinum, despite raising this potential safety issue in the discussion section of the final rule.
5. FDA has failed to consider alternatives to irradiation of fresh spinach and iceberg lettuce that would increase food safety without degrading the nutrient quality of American diets; in particular, FDA has failed to take action on a citizens' petition proposing such alternatives submitted in 2006.

Consumer Comments on Food Irradiation

***Irradiation of food has not been proven to be safe. The public
should be able to buy foods that have not been tampered with.

***Please STOP the radiation of fruits and vegetables. There is a problem in
the processing and handling of the foods that needs to be addressed and taken
care of. As a consumer - I do not want my foods radiated.


*** please clean up feed lots and wash produce instead of trying to use irradiation
to rid the food of germs and toxics.

***I think that all food in the United States should be contaminated with radiation byproducts including novel ions. The more people that die now from cancer, the fewer people will die later when the fossil fuels run out. BRAVO! Keep up the good work, USDA, and great stealth approach waiting until the very last minute to inform the sheeple too. PS can I get a piece of the irradiation contract revenues? Where do I buy my preferred stock?

***Over 1700 studies have been conducted on food irradiation and only 5 of those promoted the use of irradiation. Those five studies were concerned only with shelf life and irradiation does certainly increase shelf life. This rest showed a dramatic loss of food value and some showed carry-over of radiation. The vitamins and enzymes in leafy greens are a tremendous contributor to our immune systems and this process will void their value. E-Coli is something we cannot completely avoid by radiation. We have to wash things. Educate the consumer not to just eat spinach out of the bag but to wash it first, require the producers to label the product with washing instructions. Look back to the practices of food preparation that led to the spread of the plague in Europe. This is a similar "100% dead" treatment of our food supply. If laboratory tests are done on all denatured food the results are always ill health and species death by the 4th generation. Look into it. Pottinger's Cats is one such massive study. Don't appease the Departments of Energy and Defense by helping dispose of their Cobalt and Cesium on our food supply. All of the irradiation studies were done with the much less active Cobalt 60, rather than the abundant Cesium 137. This would be a terrible blow to America's health. Please don't make this mistake.

***It won't matter if you buy organic anymore if you have microwaved food ahead of time killing its nutritional value. It seems that they must think that food irradiation must be a cure-all: Just irradiat the food to kill every last pathogen -- even down to the trichinosis worms in pork (but the prions that supposedly cause mad cow disease are remarkably resistant to radiation). But is no substitution for sanitation measures that have made our food supply relatively safe.

***I am against the irradiation (pasteurization) of all food including greens and organic food. Irradiation removes the nutrient content in the food or actually makes it a toxic substance. This is just another way for the FDA to support the food production industry in delivering lower quality food to the consumer. You are also hiding the fact that you are irradiating the food by calling it pasteurization. I watched a Congressional hearing on TV where it was revealed the requirements for inspection of imported food and the number of of inspectors. What a joke that was. It is interesting how that information never gets into the published media. Your answer to not doing your job is to nuke everything and lessen the nutritional value of our food instead of requiring that food producers follow food safety practices. Agri-business corporations need to take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them more, instead of delivering devitalized food that has little nutritional value to consumers. What is especially interesting is that there is little to no coverage of this issue in the media and that so little time has been given to citizens to voice their opinion to the FDA. Because everyone in this country eats, this should really be front page news in newspapers. Instead, it is only through the alternative media that one even finds out about the next sneaky thing our government is planning on doing that will harm the people of this country and make bigger profits for the huge corporations.

***Food irradiation in not pasteurization. This is a horrible euphemism. Consumer receives an inferior product that appears fresh, but has depleted vitamins and enzymes. Irradiation damages food by breaking up molecules and creating free radicals. The free radicals bounce around in the food, damage vitamins and enzymes, and combine with existing chemicals (like pesticides) in the food to form new chemicals, called unique radiolytic products (URPs). Some of these URPs are known toxins (e.g., benzene, formaldehyde). Some are unique to irradiated foods and never studied. In the approval of irradiation, the long-term effect of these new chemicals in our diet were never studied. This is most egregious when applying the organic label to irradiated food. Should this measure go through you will undermine both the organic food market and basic food safety principles. Short term profits made by bulk food distributors will not pray for the long term damage done to the organic brand and human health.

***I am against raw green food irradiation. Raw greens have all the enzymes and nutrients.

*** Buying RAW vegetables and greens allows us to get the most nutrition and health value in our foods. Irradiation or pasteurizing kills these necessary enzymes. DO NOT PASTEURIZE our greens and vegetable!!!!

***I'm commenting about the Fed wanting to Irradiate all greens (even organic greens). This is outrageous! Irradiation denatures the nutrients in a veggie and turns the food into a carcinogen. (see below) DO NOT IRRADIATE OUR FRESH PRODUCE; THERE WILL BE RIOTS IN THE STREET IF YOU DARE TO DO THIS ABOMINATION! Liver Cancer: Danger of Radiolytic Products in the Diet June 26, 2000 This scientific materials in this document were prepared by chemist Jeffrey Reinhardt, M.Sc., co-founder of The National Coalition to Stop Food Irradiation. Summary FDA estimates the amount of Radiolytic Products (RP) in foods irradiated at 100 Krad at 0.3 parts per million (PPM). Source. 100 Krad is the maximum permitted dose of irradiation for fruits and vegetables. Poultry may receive 3 x 100 Krad, red meat may receive 4.5 x 100 Krad, frozen meat may receive 7 x 100 Krad, spices receive 30 x 100 Krad. Therefore this calculation is a low estimate if people eat a diet containing irradiated meat and poultry as well as fruits and vegetables. Assumes consumption of 7.5 ounces of irradiated foods with an average water content of 80% (fruits and vegetables range from 75-90%) with 0.3 PPM of RPs. 7.5 ounces is a large serving of fruit or one piece of fruit and one serving of poultry or meat. If only 1 out of 10,000 RP molecules is a potential carcinogen, co-carcinogen or mutagen, then for every 7.5 ounce meal with 0.3 PPM of RPs, 2,560 potentially carcinogenic or mutagenic RP molecules will contact each cell in the adult liver. See the entire calculation. Irradiation depletes anti-oxidant vitamins in food, which help regenerate the liver. Over a long period of time, the RP assault on the liver combined with fewer anti- oxidants in the diet will create a "fertile field for the ultimate growth of cancer cells" and "almost certainly evolve" to produce liver cancer. "Even at one-tenth the concentration of radiolytic products known by the FDA to be formed by irradiation at 100 Krad, irradiation of foods in the human diet represents predictably unacceptable risks to the public's health." --------------------------------------------------------------------------------
FDA estimate of amount of RPs produced "Calculations based on radiation chemistry clearly indicate that irradiation doses of 100 Krad or less yield a concentration of total radiolytic products in food that is so limited that it would be difficult to detect and subsequently measure toxicological properties. In addition, at this dose unique radiolytic products (URPs) will be on the order of 3 parts per million (PPM), and since the number of individual URPs is likely to be greater than ten, the amount of any particular URP will be considerably less than 1 PPM. Finally, our estimates of URPs may be exaggerated.

"Hence, because of the low level of total unique radiolytic products (URPs) produced, it is concluded that food irradiated at doses not exceeding 100 Krad is wholesome and safe for human consumption. This rationale is based solely on an estimate of the concentration of individual URPs produced by the radiation dose to the food, and pertains even if a high proportion of the total human diet is irradiated at 100 Krad." p. 16, Recommendations for evaluating the safety of irradiated foods. Final report, July 1980. Director, Bureau of Foods, FDA. -------------------------------------------------------------------------------- Calculation of number of molecules of RPs produced by 7.5 ounces of irradiated food. Analysis of the Impact of Radiolytic Products (RPs) at 0.3 PPM Mathematical Calculations A. Seven and one-half (7.5) ounces of irradiated "foods" equals 42.5 grams of "food" substance: 1) 7.5 oz. x 28.35 gm. per oz. = 212.63 gm. of "food" 2) 212.63 gm. x 1000 mg. per gm. - 213,630 mg. of "food" 3) If 80% of the "food" is water, then 0.8 x 212,630 mg. = 170,104 mg. of water OR 213,630 mg. of "food" - 170,104 mg. of water = 42,526 mg. of "food" substance B. RPs at 0.3 PPM in 7.5 ounces of "food" substance yield 0.01275 mg. of RPs per 7.5 ounce meal. 1) 42,526 mg. of "food" substance = 0.0425 Kg. 0.0425 Kg. x 0.3 PPM x 1 mg. per Kg. per PPM equals 0.01275 mg. of RPs in "food" substance C. Assuming an average Molecular Weight (MW) of one RP molecule equals 300 Daltons, permits the calculation of the total number of RP molecules ingested in a 7.5 ounce meal of irradiated "food": 1) 0.01275 mg. RPs ? 300 Daltons = 0.0000425 milliMoles of RPs OR 2) 0.0000425 milliMoles RPs = 0.0425 microMoles of RPs OR 3) 0.0425 microMoles of RPs = 4.25 x 10-8 moles of RPs D) To convert to the number of RP molecules, the Mole fraction is multiplied by Avogadro's Number (6.023 x 1023 molecules per Mole): 1) (4.25 x 10-8 Moles of RPs) x (6.023 x 1023 molecules per Mole) = (25.6 x 1015) molecules of RPs in a 7.5 ounce meal of irradiated "food" OR 2) 25,600,000,000,000,000 RP molecules per meal E) Since there are approximately one million liver cells ("hepatocytes") in the adult human liver, there will be 25,600,000,000 RP molecules potentially targeted at each liver cell. 1) 25,600,000,000,000,000 RP molecules ? 1,000,000 cells = 25,600,000,000 RP molecules per liver cell F) If, however, only 1 out of 1,000 RP molecules is actually assimilated from the small intestine into the hepatic portal circulation (ed: blood flow through the liver), then for every 7.5 ounce meal with 0.3 PPM of RPs, 25,600,000 of these reactive RPs will enter the liver: 1) 25,600,000,000 RP molecules per liver cell ? 1 in 1,000 RP molecules actually assimilated into hepatic portal circulation = 25,600,000 RP molecules per liver cell in the "Best Case" G) Further, if only 1 out of 10,000 RP molecules is a potential carcinogen, co- carcinogen, or mutagen, then for every 7.5 ounce meal with 0.3 PPM of RPs, 2,560 potentially carcinogenic or mutagenic RP molecules will contact each cell in the adult liver: 1) 25,600,000 RP molecules per liver cell ? 1 in 10,000 RP molecules as potential carcinogens or mutagens = 2,560 (potentially carcinogenic or mutagenic) RP molecules will come in contact with each hepatocyte (liver cell). H) If, over protracted periods of time, the liver is depleted of protective, anti-oxidant nutrients which are destroyed by irradiation, then the inherent capability of the liver's protective and regenerative mechanisms will be compromised. This reduction in the quality and quantity of functional nutrients available is caused by the consumption of diets containing irradiated "foods" over long periods. This depletion in the intake of functional anti-oxidant nutrients, in conjunction with genetic, lifestyle, and occupational factors, will lead to a tissue environment in the liver which will evolve to unique susceptibility to RP-induced initiator and/or promoter carcinogenesis mechanisms. Thus, I believe that ingesting irradiated "foods" containing even 0.3 PPM of RPs will inevitably lead to neoplastic transformations of liver cells in a fertile field for the ultimate growth of cancer cells; these will almost certainly evolve to produce hepatocellular (liver) carcinoma. Even at one-tenth the concentration of radiolytic products known by the FDA to be formed by irradiation at 100 Krad, irradiation of foods in the human diet represents predictably unacceptable risks to the public's health.

***Informed persons OPPOSE any mandatory rules on food processing which could negatively affect the composition or quality of food. Any form of pasteurization or irradiation alters the molecular and subtle energy qualities of the biological materials subjected to the process. This diminishes the nutritional content and destroys enzymatic activity. Thus, these foods could NOT be considered raw and fully natural after such a process. There are safe methods of protecting against food-borne pathogens such as washing with ozonated water, which don't affect food quality. The hazards of damaging the nutritional and energetic properties of food outweighs the perceived benefit of protection against microbes that rarely contribute to illness and which could be addressed through proper preparation of foods rather than irradiation or pasteurization of food. Irradiation/pasteurization makes food "dead" but not immune to subsequent contamination, so those procedures shouldn't be forced on the industry and public but could be used voluntarily with public notice so the public can choose. There are studies showing rapid health deterioration in animals fed solely or mainly pasteurized food (e.g. milk), so there is reason to consider that these foods can adversely impact human health, even though the adverse affect may be more subtle for humans. Additionally, the proposed rules are expensive and difficult to enforce - there's already too much government bureaucracy! If the government wishes to protect citizens health it needs to stop inciting wars and stop spreading depleted uranium and other hazardous materials around the planet... not to mention a halt to spraying toxic metallic compounds in the atmosphere. We should be reducing the amount of processing occurring with food so that it's more whole, energized, and nutritious - not blasting it with nutrient-destroying heat and radiation. visit and other holistic health news sites for extensive information on adverse effects of food processing.

***I am outraged by the latest attack the government is making on our food supply. First almonds and now this! I want access to food that has not been tampered with by those that have little knowledge about truly healthy, wholesome food. Irradiation is dangerous and should not be forced upon us! Stay out of my salad!

***The description of this is so generic that it is hard to know what is being done to the food to ensure it is free of pathogens. Whether this is intentional or just incomplete, I want to say that there are plenty of us out here who have studied food irradiation and are ABSOLUTELY OPPOSED TO IRRADIATING LIVE FOODS WE CONSUME. Please note my strong objection if that is your plan, and if you go ahead with this activity despite what the informed citizen desires, it is necessary to CLEARLY label such foods so that the average person can know what we are consuming. Thank you for your attention to this matter..

***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 your 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 have been related to poor farming practices- eg. using sewages 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. Thank you, Maureen Knupple

***Dear USDA Agriculture Marketing Service, This is not a feasible or fair plan for small and med.-size farmers with biodiversity (a number of different crops). Take action at the level this problem was at---large-scale operations that ship long distance--have them clean up their act and perhaps decrease the distance leafy greens can be sent. They have a short shelf life. That is just the way it is. The E. Coli breakout is a message to eat more locally grown foods. It is a message to support our small-scale, local, organic farmers. This proposal would not do that, so if you are going to pass it, exempt the small-scale farmers and organic farmers. I'm a leafy green eater and supporter of sustainable, organic farming practices--these are practices that support our life in every way. I choose to keep my vegetables as nature intended them. Raw and Organic. Please don't try to defy nature with this "kill" approach (irradiation--what is being done to our almonds already, for example). This is exactly what it does. It kills everything, including the life supporting enzymes and nutrients the food was meant to give us. If you kill the enzymes and nutrients, there is no point in eating that "food" any more. It has nothing to give us. Respect and work with the way nature is instead. Raw food isn't meant to last forever. Let's stop trying to make it last forever. This is why eating more locally grown food and smaller-scale farming makes sense. This is why the E. Coli problem was with large-scale companies that ship long distances. That is why action needs to be taken at the large-scale farming operations level only at this time. Thanks for considering my comments, Sincerely, Moses Sedler

***I DO NOT want my leafy greens irradiated! I want to be able to eat raw, unpasteurized, healthy greens. "Pasteurization" of leafy greens is merely a code word for irradiation. I DO NOT want poisons on my greens. The big agribusiness corporations need to use more hygienic handling practices and more prudent methods of shipping our produce to us. I am absolutely against any irradiation of the U.S. food supply. Urge U.S. agribusiness to take the necessary steps I have listed above to ensure the safety of produce shipped to consumers in the United States. Do not expose U.S. consumers to potentially cancer causing irradiation methods.

***All this pasteurization, irradiation, etc. is detrimental to our health. Most Americans have compromised immune systems because every living organism has been removed from their food. Needless to say that taste suffers too, making cheeses bland and lots of other artisan foods impossible to produce and sell. It is amazing that the rest of the world has not long been extinct considering that they don't feel the need to sterilize every one of their naturally grown foods. Don't give in to pressure of industrial agriculture!

***The proposed rule that forces irradiation of leafy green vegetables is a further encroachment of corporate agribusiness on the soveriengty of the people. The biotech industry along with the agricultural industry are trying to control not only the food in this country, but all over the world. Look at what has already happened to third world countries. Our government, under the pressure of the huge agribusiness conglomerate, has gone in and taken over all small farms in order to control all food going into those countries, and have succeeded. It not only has put small farmers out of business, but more importantly has forced upon entire societies worldwide UNHEALTY, GENETICALLY ENGINEERED FOOD, which is causing people to become ill and die. Genetically engineered food is proven to be toxic to the body. The body rejects the food as a foreign substance (because in order to genetically engineer foods, viruses are injected into the cellular structure of the food). People are becoming ill and allergic to GE foods now; therefore people who are conscious and awake are trying to create sustainable communities with their own farms and gardens in order to maintain health, since we can no longer depend on the medical industry to help us to stay healthy because of BIG PHARMACEUTICAL INDUSTRY interested in only making money, not helping people to get better. Taking away our only remaining food that keeps us healthy will mean the destruction of our society. The e. coli which occurred were caused by the very corporatization of foodstuffs (agriculture and cattle) of which I have described above, to create a reason to destroy privately owned agriculture. Please act on the people's behalf. You who are reading this, please think of your children and theirs, who are inheriting this huge corruption. We can stop it now, if we wake up and act. Thank you very much for your attention to this matter.

***Dear USDA & FDA, I am strongly opposed to the irradiation and/or chemical treatment of our food. Both irradiation and adding chemicals to food pose proven health risks to people. This type of sterilization destroys the food value of the produce, and introduces toxic and dangerous substances into the food. Additionally, I don't believe that it is medically sound to isolate our immune systems from microbes that are or will be plentiful in our environment. This serves only to render our immune systems unprepared for the inevitable contact with these microbes, and renders us defenseless against them. Exposure to microbes and viruses is the only way to strengthen our immunity to them. Vaccines don't work. Our bodies need to be allowed to do what they do best - adapt and strengthen themselves. Please take this advise to heart, and don't irradiate or poison our food. Sincerely, Polly Suzanne Cox American

*** I am strongly opposed to the proposal for federal regulations to mandate the 'pasteurization' of all greens. I am adamantly opposed to the FDA using the word 'pasteurize' as a euphemism for irradiation. Americans have a right to eat food which has not been altered. Scientists are now coming forward with information touting the benefits of raw food. Heating food destroys enzymes which are critical to maintaining one's health. The human body has a finite amount of digestive enzymes and is dependent on raw food to obtain the rest. If the body is lacking enzymes it will depend on the metabolic system to create more enzymes, thus overtaxing the body and causing general fatigue. As for irradiation, I do not want to eat irradiated food because of the toxic effects it has on the body. The why's should actually be irrelevant, what disturbs me most is that my ability to choose for myself is being threatened.

***I eat greens on a regular basis, and it is necessary that my greens do not exceed 118 degrees heated or involve chemical treatments. I have learned that this action by the USDA will in essence enforce the pasteurization of all greens. This is unacceptable. I have already begun importing the almonds I eat due to the enforced pasteurization of almonds. Obviously, the USDA is unaware of the number of raw foodists who believe this process seriously affects the nutritive value of foods. Nutritionists such as Victoria Boutenko and a host of others have done significant research on this. Whether it be pasteurization or irradiation (which I believe is the euphemism referenced here) will enforce more and more of us to seek out greens from abroad. This is costly to us, but it is totally inconsiderate to all raw food purchasers. Even in almond pastueirzation Propylene oxide is used: "Propylene oxide is a highly toxic flammable chemical compound. It was once used as a racing fuel, but that usage is now prohibited under the U.S.National Hot Rod Association rules for safety reasons. It is also used in thermobaric weapons. It is an an epoxide." Who is making such outlandish assertions that this is good for Americans? This is outrageous.

***My quick comments on the proposed regulations (please forgive editing, etc. as I wanted to get this out quickly): As a consumer and a college graduate with a scientific degree (B.S. Physics, UCLA, 1979), I have a few concerns about potential leafy greens' Food Safety Regulations. First, if so-called "cold pasteurization" (or "CP" which is actually irradiation of the raw food) is used, I am concerned that certain critical pathogens will not be affected by the treatment therefore leading to a false sense of security amongst consumers. Specifically (in only one example), as the coliform bacteria present in certain recent crop contamination was deemed to come from feed lot cattle sharing water use with the crops, I see a possible significant risk of TSE (Transmissible Spongiform Encephalitis) pathogens also being transmitted. The facts on TSE (a.k.a. the silly sounding term "Mad Cow Disease") include that it is transmitted via a twisted protein isomer known as a prion which is not overly responsive to standard methods of disinfection. Research on prions is limited partly because of the fact that the costs of the public finding that they are risky and to what degree they are present in meat foods is so high. Their potential incidence if they are present at all in meat foods is amplified by the use of rendered protein feed from carcasses of unknown source and health. I.e., the feed for cattle can be from other animals (including other cattle) which are already infected with rogue TSE prions. And, given the industrial nature of both the rendering industry and the feed industry, a single mistake could infect a very large number of food animals. If manure from infected feedlot animals contaminates plants, the trace residue may still harbor infectious prions, thereby endangering consumers wo do not expect to be at risk from plant based food to begin with (and are probably not apprised of any risk from meat based foods). While the "cost" is high in further researching and testing for TSE infectious agents in foods and the cost savings great in "cold pasteurization" of plant foods downstream in the same water cycle, the cost will be much greater if a verifiable outbreak of TSE occurs from a plant based food source. Given that the source of such an outbreak is one *or more* animals upstream and that their pathogens are mixed throughout the water supply (and that consumer confidence will thereby doubt *all* factory farm animal products and *all* downstream plant food products a generalized collapse in confidence in our entire food system with corresponding litigations will result. I and a number of other well-informed and educated consumers like me already doubt the safety of animal based foods. I'm also aware that no universal tests are being done for the incidence of TSE in animal food sources nor in consumers of those products. As citizens (and residents/visitors/world market consumers) sharing the resources of this nation, we are all entitled to a high degree of food safety. Putting aside the pragmatic questions being asked about the safety of the "cold pasteurization" process itself (are beneficial nutrients destroyed?; are dangerous new compounds being created?; etc.), the issue of tenacious pathogens potentially resistant to CP is enough reason, in my opinion, to avoid this process and to, instead, opt for cleaner preventative measures (universally testing and tracking animal feed and animal food products as well as positively determining the incidence of persistent pathogens such as TSEs in consumers who have not to date been protected by our food system; immediate and complete separation of the residues from questionable animal feed operations from all other food sources , etc.) Otherwise, I remain unconvinced of the wisdom of limited Food Safety Regulations and uncertain of the safety of all our large scale food sources. Yours, "Uncle" Don B. Fanning, Flagstaff, AZ.

*** I am opposed to the pasteurization and/or irradiation of raw foods, raw greens raw nuts & seeds. Stop the insanity. If big food manufacturers can't bring food to market safely, then maybe they should just go away. Let small local farmers thrive again. Small businesses are the backbone of our economy. Big commercial agricultural conglomerates are poisoning and sucking the life out of our economy and our people. Say NO to mandated irradiation/pasteurization of raw foods.

***Please do not do this. Before you do this, you must be able to show that irradiation will not create unhealthy changes in the genetic structure of the greens. Your cure may be worse than the disease you are trying to prevent. After all, if the radiation kills the bacteria and viruses, how will it alter the food? Will these alterations be safe?

***Ref AMS-FV-07-0090 Irradiation of Leafy Greens While there is no room for contamination in our food supply, irradiation is not the way to prevent it from happening. After the tragic situation with spinach, the people involved with the production of spinach have looked deeply into their production and processing of spinach to insure the safety and wholesomeness of their product. (I've spoken with some of them and was impressed with their safety measures.) Irradiation was not a part of our discussion. But it is something about which there is cause for concern. There is something very strange about this idea of subjecting food to poison to make it safe for consumption. It is not good thinking. The way to have good wholesome pure nutritious food is to make sure that it is grown with good farming practices, is harvested and processed with good clean procedures, and moves quickly to consumers to arrive fresh and as natural as possible.

***Irradiation of live food due to poor handling is a very bad idea. Safer handling regulations is a better idea. Irradiation of food has potential long term effects that have not been studied well. Mandating a bad practice to compensate for not regulating good handling practices is foolish.

***I buy local organic and locally grown produce at a co-op in my area. I am concerned to hear that all greens, even organic, will soon be subjected to irradiation too. A primary reason I buy local and organic greens is so that I don't have to eat fruits and vegetables that have been subjected to irradiation. Enough is Enough! Our foods need to be safe and nutritious, not toxic and nutrient poor. I say no to irradiation of greens. It is a big deal to me!!!

***I do not appreciate the direction the agri-business is taking as well as our government officials when it comes to the pasteurization or irradiation of my food. I feel that big business should take the required steps to improve their handling of the food products which they want to sell to the public and not look for ways to shirk their responsibility. The proposed action will reduce the health benefits i.e. our foods becoming more nutrient-deprived and/or toxic. We do not know what the long range consequences will be from such actions, and I for one will not expose my childern to these foods. I may need to resort to growing my own vegetables now. I for one object to this pasteurization of our foods.

***Do not permit the irradiation/ pasteurization of raw greens. This is an untested process which can degrade or harm the quality of our food and the people consuming them. It is an excuse and distraction from the need to grow food with clean water unpolluted by animal waste runoff and pesticide runoff and free from unsanitary processing conditions. Don't treat consumers like ignorant guinea pigs.

***Docket # AMS-FV-07-0090 regarding the irradiation of leafy greens. Please do not do this to our healthy foods! One ecoli scare due to bacteria on worker's hands does not justify spraying our vegetables with more chemicals!!! PLEASE DON'T......for the health of our nation.

***I believe the public has the right to purchase "raw" greens and vegetables. I also believe that we have the right to know what country our food comes from, this should be clearly labeled on the items. We no longer have the safest food supply in the world and it is very disturbing, since other countries do not grow or process their foods they way we once did. There are too many recalls on our food supplies. Its the agri-businesses that have caused this with their careless handling of our foods, its up to them to utilize more hygienic and prudent practices. Agri-business corporations should take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them a little more, rather than passing the burden on to me, the consumer, in the form of toxic, devitalized food devoid of most of its nutritional value. We have already seen our food prices jump dramatically, and a few cents more won't hurt us. I would prefer fresh, raw greens than any that have been pasturized or having irradiation used. Thank you for your consideration, Terri Flynn

***I am writing to comment about the USDA's proposal to irradiate (or "pasteurize") all fresh leafy green vegetables (Docket ID AMS-FV-07-0090). I have heard this is being as proposed as a way to prevent outbreaks of harmful bacteria. I strongly disagree with this being made a requirement for all fresh leafy greens, or for any food. I think there are other approaches better suited to keeping food healthy. I don't think irradiation would make food healthier. I think it would make the food and farming environments less healthy. I think other options need to be explored to deal with the USDA's concerns. I heard that today is the last day that the USDA is open to comments on this issue. With more time, I'd be better able to collect research that backs up what I'm saying. I do oppose a Marketing Order or Marketing Agreement that would impose federal standards for all growers of leafy greens. I am very concerned about being able to eat a healthy diet due to my own health concerns. I believe that eating irradiated food would be a step in the wrong direction in my attempts to stay healthy. Thank you for considering my comments. Sincerely, Romney Boehm

*** Irradiation or "pasteurization" of green leafy vegetables will do nothing more than kill the nutrients in the food. It will not prevent consumers from consuming fecal matter left on the ground by workers in the field or the use of human sludge during the growing stage. What will prevent outbreaks of any known related diseases is to stop using human sludge aka human waste on food used for human consumption.

***The irradiation of all leafy greens is a satanic move. How dare you hairless apes at the controls at the FDA and and USDA force upon millions of children, women and men a poisoned important food source denuded of nutrition due to a process of irradiation!!! EVIL! You are EVIL VILE CREATURES!!! Are you really that stupid that you can not understand the massive negative effects that irradiation does to ANYTHING? Maybe you need to stick your pets into a microwave and see what it does to life. Food is life. Even if it's cut and in transit, it is HOLDING LIFE FORCE ENERGY. Stupid hairless apes.

And if you are doing this on purpose to poison large numbers of people or add that straw that will break the camel's back in the health of every man woman and child in the US, well, there is just no excuse for such blatant fear on your part. Stupid demons. Go back to your own hell and stop trying to make this planet a living hell.

***Please DO NOT require irradiation of all greens and vegetables. It's time for agri-business corporations to take responsibility and use more hygienic handling practices and more prudent shipping methods. It will cost them a little more, but in the long run will even out. PLEASE don't pass the burden on to the public in the form of toxic, devitalized food devoid of most of its nutritional value.

*** Docket ID:AMS-FV-07-0090 In the proposal to "pasteurize" leafy greens by means of irradiation, I would like to comment I disagree with this strongly. I DO NOT to eat irradiated food. I do not agree with the mandatory irradiation of any thing, including "leafy greens" I,as a citizen, strongly advise AND DISSENT against mandatory irradiated food. I DO NOT want irradiated food in my food supply. I Do NOT want mandatory irradiation for any foods in the market place. SAY NO to manditory irradiation.

***I oppose the adoption of widespread "pasteruization" of leafy greens. As a produce consumer, I choose to spend my food dollars to the greatest extent possible on locally grown, organic food. I do this for two reasons: first, I believe that it is crucial to support small, independent farmers, whose care for their crops and the earth best fit my personal environmental ethos. Second, I shop locally in order to reap the benefits of the freshest (and thus most nutritious) fresh produce available. The proposed regulation places a disproportionate burden on responsible farmers who use proper organic management to ensure healthy and safe crops. It will act to push many of my preferred suppliers toward economic inviability. The proposal also spreads the blame for recent e. coli outbreaks throughout the universe of leafy greens producers, when in fact these outbreaks can be traced to large agribusinesses whose crop management practices are far from optimal. I also have concerns about the science of "pasteurizing" leafy greens: I do not believe that current science on this issue is sufficient to demonstrate that the greens' fantastic nutritional content will not be altered or destroyed by "pasteurization," especially if said "pasteruization" consists of crop irradiation. Any proposed "pasteurization" should, if it is enacted at all, be focused upon the agribusiness offenders who first tainted our marketplace by taking insufficient care with their crops and allowing the spread of e. coli in the first place. Please spare our small, local farmers from such burdensome regulation. Family farms are often touted as the backbone of America; let us put into place regulations that support these hardworking families.

***Re:AMS-FV-07-0090 I do not understand how this document means that fresh vegetables are to be irradiated, but I vehmently OPPOSE the IRRADIATION of FOOD for any reason. Ionizing radiation is harmful to living organisms. There is already way too much unavoidable radioactivity exposure in our environment, especially now that we are bombing the @#$%^ out of Iraq with depleted uranium. If I cannot buy food that is not irradiated, I will grow my own.

***Hello, How can the USDA require all greens to be irradiated leaving consumers no freedom to choose non-irradiated green produce? There are many unanswered questions to the process. Does the USDA know the long term consequencies to irradiating food? Does the USDA know the effects of consuming irradiated food over 20 or 30 years? Is it safe? What about the nutrients in the food? It is irresponsible to leave consumers no choice and limited time to comment on this very important topic. Consumers should have the right to choose the food they want to consume. Irradiation is not proven safe over a long period time, spanning many years. Sincerely, P. Romano

***General Comment:Are you folks KIDDING me?? NO to irradiation; yes to FOOD as FOOD -- natural. We don't need any quick cheap dirty fixes! Just proper handling. "Radiation is a carcinogen, mutagen, and teratogen. At doses of 100,000 rads to fruits and vegetables, the cells of the fruits and vegetables will be destroyed, but fungi, bacteria, and viruses growing on the fruits and vegetables will not all be killed or inactivated at these doses. They will be mutated, possibly leading to more virulent contaminants. Has anyone addressed this problem?" Geraldine Dettman, Ph.D. Radiation Safety Officer, Biosafety Officer, Brown University Scrap these sets of proposed regulations TODAY.

*** 'Pasteurization' is a euphemism for irradiation. Also, almonds are to be 'pasteurized' by burning them with carcinogenic, banned rocket fuel. Our food supply is already lacking in minerals and other nutrients necessary for good health. Not only are many obese Americans eating "empty" calories, but more and more, ingesting needless toxins. This insanity of "pasteurization" must be stopped!

*** AMS-FV-07-0090 Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA) Document ID AMS-FV-07-0090-0001 Handling Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 Required irradiation of consumer 'leafy greens' is not a good option. If it is done at all, at the very least, it must be an option only, and products treated thus must be CLEARLY LABELED. Untreated products must also be made available at similar prices in all markets. And, the labels must not use obfuscation such as 'pasturization.'

***Upon reviewing the materials proposed it saddens me to find that our leaders are requesting regulation of our food based on unfounded claims. I wish that we as a society were more aware of our food producers and safe handling of the elements we consume to nourish our bodies. However; I do not believe that the government should infringe on the rights of all people in depleting our food of the nutritional value that is so desperatly needed in food through methods or solvents, irradiation, chemical preservation. Our food supply is challenged enough with out these unecessary precautions that will ultimately harm more people than help. I urge our leaders to not approve document AMS-FV-07-0090. Thank you, Julie Peltier, Michigan

***I am extremely disturbed to hear of the USDA's plans to require all leafy greens to undergo irradiation or cooking prior to sale to consumers! These proposed treatments are unnecessary and potentially harmful, particularly irradiation. It is a scientific fact that cooking and irradiating food destroys the majority of the vitamins, enzymes and other healthful nutrients contained in leafy greens and other foods. I eat all my leafy greens in their raw natural state for the express purpose of benefitting from these excellent, nutrient-dense vegetables as the basis of a healthy diet. If the problem is the **rare** occurance of E. coli or other bacteria in leafy greens such as spinach, then the regulation should be addressed toward requiring much stricter sanitary standards for farms and food processing facilities, not by destroying the life-giving qualities of these vital foods in their natural state. Please reconsider other more viable solutions to an issue that has occurred very rarely with raw leafy greens over the past several years - certainly not deserving such a drastic response. Thank you in advance for considering my comments, Mary Caldwell, Folsom, CA

***Irradiation is poison. The fruit that I buy at the grocery store is hard as a rock when I buy it and two days later its does not ripen..I dont want my greens to be needs to give life not take life..if all the nutrients and enzymes have been killed by radiation then the people who eat it die prematurely diseased..I am opposed to irradiation..thank you

*** Cleanig vegetables with chlorine and irradiation is more harmful and destroys the food itself than fighting ecoli problems at the source. Poisoning our food and saturating with cancerous agents is worse than leaving alone. Stupid meddling and wrong target.

***I very much object to using pasteurization and/or irradiation to treat leafy greens, because this will significantly reduce the vitality/health benefits of such foods. Raw live foods are very helpful in reversing a number of chronic systemic ailments in our society that have reached epidemic proportions. I believe that pasteurization and/or irradiation of these living foods will do more harm than good.

***I strongly OPPOSE the irradiation and/or bleaching of vegetables. 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 your 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 ecoli (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.

***As a consumer and proponent of organic raw foods, I am strongly opposed to the proposed irradiation of greens in "Advance Notice of Proposed Rulemaking for a Marketing Agreement for Leafy Greens". This regulation is clearly aimed at undermining small organic farms and limiting the choices of consumers. If the USDA is terribly concerned with e. coli, stop dumping livestock-contaminated irrigation water and other sewage products on crops. It is obvious that in recent years the USDA is acting solely in the interests of large corporations, not human beings, and is increasingly responsible for the degradation of food quality.

***I just found out about this proposed change in the safety regulations. I am so shocked by this that I am not prepared with extensive comments, however I do wish to convey the absolute devastation to my health-maintaining raw-food lifestyle this regulation change would effect, as well as comment on the over-all travesty of prudence this idea represents. I have a very sensitive, overweight-prone body, with many allergies. I have worked to maintain my health by consulting nutritionists, going on many diets through the years - monitored by doctors, following extreme regimens suggested by allergists, participating in exercise programs, and restricting myself from many many foods and substances that my body just can't handle. I had my gall bladder removed over 21 years ago, and I cannot digest meat or most fats. Six years ago I?had a big health challenge arise, and my cholesterol and blood pressure were getting high. This was not suprising since many people in my family have suffered from diabetes, high blood pressure, high cholesterol, and congestive heart failure. I went on a 100% raw-food diet for 6 months. In that short time I lost 65 pounds, gained strength, stamina, and incredible energy, as well as lowered both my cholesterol and blood pressure to healthy normal levels. My lump cleared up entirely, and my second mammogram was normal. Since then I have continued to eat a primarily raw diet, although I have had lapses in that pattern. When I have lapsed into eating more cooked foods, my weight has increased, and my blood pressure and cholesterol levels have risen. After my last physical, my doctor wanted to put me on some cholesterol medication. I went back on 100% raw food, and within two months, reduced weight and cholesterol again. It is quite obvious that my body thrives on a raw food regimen, and does not on cooked foods. Raw almonds and almond butter have been a mainstay in my diet. All of a sudden, several months ago, the almonds and the almond butter started not tasting right, and I suddenly tested allergic to them. Recently the FDA changed the regulations about raw almonds, mandating ?pasteurization? of all raw almonds (by irradiation). This kills all the enzymes in the almonds. Therefore, my body is no longer able to digest them. I?ve had to cut almonds out of my diet entirely. This is a big loss for me. Now you are proposing to do the same thing to all of our greens. I can?t help but take this personally. You are planning to remove that which supports my good health - raw greens. The reason, in my understanding, for the existance of the FDA is to protect our citizenry, promoting health by making our food and drugs safe. This particular proposal would have the exact opposite effect on everyone. How can you possibly consider ?pastuerization? ? really, irradiation (I?ve heard by use of carcinogenic, banned rocket fuel) ? of our raw and organic foodstuffs at all? It is shamefully ludicrous. And then, once the food has been killed to continue to call it raw is a thoroughly unethical misnomer at best. If someone suggested such a practice in a casual conversation, it would be laughable, but within the context of proposed FDA regulation this is tantamount to mass food and therefore health degeneration and it is seriously wrong. I understand that there have been a couple instances where food was tainted because of unclean conditions. It is well documented that facilities operated by agri-business corporations are not necessarily utilising hygenic handling practices, nor focused on producing organic health-providing food. Far more to the point would be for the FDA to regulate the policies of farm factories, rather than to kill all of our food, making it devoid of most of its nutritional value. Require hygenic practices and more prudent shipping methods. Clean up their dirty practices. Don't throw out the baby with the bath water. Enough is enough! Do not make this a regulation.

*** I do not want my leafy greens irradiated!! I am tired of the continual degradation of our food supply in the United States through irradiation, chemical additives, and genetic modification. I also am greatly angered at the FDA's flagrant efforts to block public opposition to their proposals. They support the Big Pharma industry and are not in thruth concerned with people's health. We are the only pharmacy driven country in the world. I believe in natural health care, and good wholesome food sources are vital to our health!! Every time a food supply is altered, or contaiminated, our health is affected.

***Healthy, nutrient rich leafy greens are essential to human health and vitality. If tampered with through irradiation, they are no longer nutrient rich and no longer support human health and vitality. Irradiation of these vegetables will negatively affect the health and basic constitutions of every american that must and will partake of such compromised food. I do not support the irradiation of leafy greens and almonds.

***Irradiation entails exposing food products to high doses of radiation in order to kill any insects or pests that may infest them. Irradiation reduces levels of salmonella, e-coli and listeria, and delays ripening and rotting so that foods can be completely sterilized and kept for longer periods. Irradiation damages foods by breaking up molecules and releasing tiny pieces of them, known as free radicals. These substances damage vitamins and enzymes (which are essential and why we are in such bad shape now) and also combine with existing chemicals (eg: pesticides) to form new free radicals, some of which may be toxic. The long-term effects of these toxins have not as yet been studied. Also, irradiation destroys 5 to 80% of the health benefits of many vitamins and weakens or destroys the digestive enzymes in many foods. This is a very bad idea,.Please do not allow this to happen to our food. Thank you, Chad Libby

*** I oppose the proposal to mandate irradiation of leafy green vegetables. The long-term safety of irradiation of fresh foods is unproven. Irradiation of fresh foods destroys enzymes and reduces the vitamin content. Consumers deserve the chance to know what they are purchasing and to have alternatives. If some companies prefer to irradiate their produce, they should be required to label it as irradiated so consumers can make an informed choice to either purchase or avoid such products. The problem of contamination of vegetable crops with e coli and other dangerous microorganisms arises from livestock fed and treated with antibiotics and confined in too-small or overcrowded spaces, with wastes flowing into runoff and other surface waters. Irradiation of fresh leafy green vegetables will not solve this problem.

***I am opposed to the new rule requiring irradiation of green vegetables. this will make the availability of organic vegetables difficult to non-existent since organic standards do not allow for radiation. We do not even fully understand how radiating food affects the food. This rule will only help the large, corporate producers and will harm the small farmer and growers. There are far better ways to ensure the safety of our vegetables. Increase funding to the federal agencies that inspect farms and food so that they can more effectively do their job of keeping the conditions within regulations.. Keep livestock and manure piles well away from any area where greens such as spinach are grown and regulate/control run-off from feed lots more effectively. The general public does not want radiated vegetables. we want a safe and nutritious food supply and the right to choose organically grown vegetables. Thank you for your consideration. -Nancy Gilbert

***Subject: FDA Plans to Nuke ALL Our Greens Soon -- Take Action Quickly! The proposal is for federal regulations to mandate the 'pasteurization' of all greens. And as bad as that sounds, it gets worse: the FDA has started using the word 'pasteurize' as a euphemism or cover for what they really are up to, which is irradiation. I've seen this coming (they've already mandated 'pasteurizing' almonds-- burning them with carcinogenic, banned rocket fuel... yes, really!)-- but they've sprung it on us, revealing their plan only recently, and allowing only till Monday, Dec. 3 for public comment. (In the past, the FDA had comment periods of several weeks or even months. This is obscene! We need to take action. Almonds in September 2007; all greens (including organic) in the near future; what's next? If we don't act, we have only ourselves to blame as our food supply becomes ever more nutrient-deprived and/or toxic. We all have to eat, even those of you running the dept of agriculture...shouldn't we at least be able to eat clean, wholesome, fresh food?

We are absolutely OPPOSED to the pasturizaton/irradiation of natural organic foods. We will 100% boycott any producer or retailer that chooses to carry such items, as they are no longer in their natural intended state. We SAY NO. Thank you,

***Our food sources are continually becoming more toxic and less nutritious. Increased governmental regulations via forced irradiation of our greens will add to these concerns. Far more farmers are conscientious, safe farmers than not. Governmental involvement with guidelines or even inspections would be a much better utilization of governmental resources for the good of the people. I am very much against increased processing and irradiation of our food. Thank you, Jodie Stevens, D.C.

*** I tried to select the Department of Agriculture, but the page above wouldn't let me. Anyway, I am very concerned to see the proposal to irradiate all greens, including organic ones. I imagine it is because of Ecoli that people get every once in a while when eating fresh greens. Please do NOT irradiate (they call it pasteurize) the greens. Instead, have the packing companies clean up their act, insisting that the laborers wash their hands, and using safer shipping methods rather than killing any nutrients left in the greens. It might cost them a little more, but hey, do we have to have a whole nation eat dead food because of their greed! No way! We already have to wash our greens well because of insecticide, but to then do it for dead food....this whole idea of irradiation, and even the organic greens is insane. Enzymes are destroyed and the food value is nilch. Have a heart and so NO to this proposal, pl-e-e-e-e-eze! We already have poisoned carcinogenic almonds on our hands now. We don't need our greens to go the same way. This is written on Dec. 3, 2007, Pacific time, so please don't say it was too late. We just heard about this sneaky bill tonight!!

*** Re: AMS-FV-07-0090; Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA); Federal Register October 4, 2007; page 56678 I believe it is very important that the public continue to have access to an abundant supply of safe fresh leafy green vegetables that are NOT pasteurized or irradiated. It must be possible to use good practices that are not dependant upon pasteurization or irradiation. Thank you.

*** I am deeply concerned that our food source (namely greens at this point) will be treated with dangerous chemicals in the process of irradiation. I am asking for the choice as a human hopefully being able to choose my food souce that this does not become a law. My health as well as others depend upon our healthly food supply. Please do not take this right away from us....Thank You!!

*** Please do not madate the pasteurization of all green vegetables. This practice reduces the nutritional value of the food. I understand the e.coli risk. It would be much better if we developed laws that stop e. coli at the source. Please do not process greens by pasteurization or irradiation or any other unnatural method. We need fresh, natural, "unprocessed" vegetables to be healthy human beings. Thank you. The Rev. Catherine Linesch

*** I'm against the practice of irradiation of all raw greens, because this will affect the quality of the food we feed our families. We have the right to choose food that is easily accessible and that contains the unaltered nourishment that we need to build health in a natural and disease-preventing way.
USDA Irradiation Regulations
Consumer Comments on Food Irradiation 2
Consumer Comments on Food Irradiation 3
Consumer Comments on Food Irradiation 4
Consumer Comments on Food Irradiation 5
Consumer Comments on Food Irradiation 6--The Smoking Gun
Importing Fruits & Irradiation 7
Consumer Comments on Food Irradiation 8
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Consumet Comments on Food Irradiation 23
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Consumer Comments on Food Irradiation 25
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Contacts for food irradiation or Genetically engineered foods. Tarantino, Laura M CFSAN Spokesperson for FDA approval of irradiation for iceberg lettuce and spinach

agriculture secretary USDA FDA

Working on Genetically Engineered Foods Ann Marie Thro Title: National Program Leader Unit: Plant and Animal Systems Email:

Charles E. Hanrahan Congressional Research Service--wrote a report saying opposition to genetically engineered foods is strong in Europe, but not so strong in the US.

Robert Brackett, chief scientist, Grocery Manufacturers Association, petitioned FDA for approval of food irradiation (wish I had his email) GMA general email:

The powerful Grocery Manufacturers Association (GMA) believes irradiated foods should not be labeled irradiated--this will cause the consumer to be confused and not want to buy irradiated foods. GMA says irradiation is a process and the Federal Food, Drug, and Cosmetic Act (FD&C Act) does not require the disclosure of food processing methods on labeling. GMA believes the consumer lacks understanding about food irradiation and needs to be protected. GMA believes that irradiation labels look like warnings and cause consumers not to purchase irradiated foods. The FDA says irradiated foods are safe and labeling should not be required. GMA points out the FDA approved bovine growth hormone and no warning labels were required.

NO Robert Brackett!!The consumer is Opposed to food irradiation, and you, the Grocery Manufacturers Association, the Corrupt FDA and USDA are NOT going to Force it on us!!. We don't need BAD FDA policy--It is already AWFUL! Consumers OPPOSE food irradiation and we don't want it FORCED ON US by a deceptive lack of labeling! The CONSUMER will decide if they want irradiated foods--not you-- and we will fight against these poisoned foods and the Grocery Manufacturers Association! We will watch irradiated foods go the way of bovine growth hormone! Let's see if the FDA's attempt to hide irradiating labels from consumers can withstand the Light of Day!

The Grocery Manufacturers Association (GMA) is also in favor of genetically engineered foods (recombinant DNA technology) that it says brings benefits to the consumer. GMA says the benefits are improved nutrition, taste, resistance to spoilage, safety and the new technology reduces the use of pesticides and makes farming more efficient.

False!! Lies!! Deception!! Almost all the genetically engineered crops are herbicide resistant or have pesticide inserted into the plants. They are inserting genes from mutant bacteria into plants so the plants can be sprayed with poisonous herbicide. Dangerous! They are inserting pesticide
(bt toxin) into plants so insects will die when the eat the plants and consumers are eating the pesticide in the food the plant produces. Dangerous!! Poison!! The Sierra Club opposes genetically engineered foods. Greenpeace opposes genetically engineered foods. The Union of Concerned Scientists opposes genetically engineered foods. The Organic Consumers Association Opposes genetically engineered foods. The Center for Food Safety Opposes genetically engineered foods. Europeans oppose genetically engineered foods. Japan opposes genetically engineered foods. Many organizations in the US and millions of consumers are opposed to genetically engineered foods and the Grocery Manufacturers Association is not going to force it on us through deception.

The GMA says they want advertising claims regarding the presence or absence of modern biotechnology in the production of foods to be truthful and nondeceptive and avoid possible consumer confusion. It Petitioned the FTC for a ruling about advertising claims regarding biotechnology in food. What a bunch of Hogwash!!
NOBODY is advertising "This product contains genetically engineered foods." Nobody is advertising "this product is made from biotechnology." Products are advertising-this product not made with gmo or not made with biotechnology because that is what the consumer wants. Maybe it has to do with the recent New York Times poll that shows 53% of Americans won't buy genetically engineered foods. Maybe it has to do with the fact that organic foods are the fastest growing segment of the food industry, growing at 20% market share a year. The consumer is OPPOSED to genetically engineered foods! The consumer is OPPOSED to food irradiation! The Grocery Manufacturers Association is WRONG on both issues.

In marketing, they say the consumer is KING. Give the consumer what they want, and they will beat a path to your doorway. Try to force on the consumer what they don't want, and they will fight you tooth and nail at every step of the way. The GMA just doesn't get it.

. Warning! This product irradiated!
Warning! This product genetically engineered!

This is truth in advertising!

GMA Board of Directors,Chairman Mr. Douglas R. Conant,President and Chief Executive Officer,Campbell Soup Company

Vice Chairman,Mr. Richard G. Wolford,Chairman and Chief Executive Officer, Del Monte Foods Company

Secretary, Mr. J. Douglas Quick, Chairman and Chief Executive Officer Lakeside Foods, Inc.

Members, Mr. Brad Alford, Chairman and Chief Executive Officer Nestle USA, Inc.

Ms. Brenda C. Barnes, Chairman and Chief Executive Officer Sara Lee Corporation

Mr. Bart Becht, Chief Executive Officer, Reckitt Benckiser,

Mr. Bradley A. Casper, President and Chief Executive Officer, The Dial Corporation

Mr. James R. Craigie, Chairman and Chief Executive Officer Church & Dwight Company, Inc.

Mr. William B. Cyr, President and Chief Executive Officer, Sunny Delight Beverages Company

Mr. George E. Deese, Chairman, President and Chief Executive Officer Flowers Foods, Inc.

Mr. Stanley K. Dunbar

President and Chief Executive Officer, Moody Dunbar, Inc.

Mr. Gregg L. Engles Chairman and Chief Executive Officer, Dean Foods Company

Mr. James B. Ethier Chairman and Chief Executive Officer, Bush Brothers & Company

Mr. Jeffrey M. Ettinger, Chairman, President and Chief Executive Officer, Hormel Foods Corporation

Mr. Thomas J. Falk, Chairman of the Board and Chief Executive Officer Kimberly-Clark Corporation

Mr. Joseph E. Gallo, Co-President and Chief Executive Officer, E. & J. Gallo Winery

Mr. David N. Geise, President and Chief Executive Officer, Furmano Foods

Mr. William G. Gisel Jr.,President and Chief Executive Officer, Rich Products Corporation

Mr. Kenneth E. Guise Jr.,President and Chief Executive Officer, Knouse Foods Cooperative, Inc.

Mr. James Hannan, President and CEO, Georgia-Pacific, LLC

Mr. Neil Harrison, Chairman, President and Chief Executive Officer, Birds Eye Foods, Inc.

Dr. H. Fisk Johnson,Chairman and Chief Executive Officer, S.C. Johnson & Son, Inc.

Mr. William R. Johnson Chairman, President and Chief Executive Officer, H.J. Heinz Company

Mr. Muhtar Kent President and CEO,The Coca-Cola Company

Mr. Donald R. Knauss, Chairman and Chief Executive Officer The Clorox Company

Mr. A. G. Lafley, Chairman and President The Procter & Gamble Company

Mr. Christopher D. Lischewski President and Chief Executive Officer, Bumble Bee Foods, LLC

Mr. Reid V. MacDonald President and Chief Executive Officer, Faribault Foods, Inc.

Mr. David Mackay, President and Chief Executive Officer, Kellogg Company

Mr. Paul Michaels President and Chief Operating Officer, Mars, Incorporated

Mr. John S. Morgan Chairman and Chief Executive Officer, Morgan Foods, Inc.

Ms. Indra K. Nooyi Chairman and Chief Executive Officer, PepsiCo, Inc.

Mr. Randy C. Papadellis President & Chief Executive Officer, Ocean Spray Cranberries, Inc.

Mr. Dean C. Pappas, Chief Executive Officer, Clement Pappas & Company, Inc.

Mr. William D. Perez, President and Chief Executive Officer Wm. Wrigley Jr. Company

Mr. Charles P. Pizzi,President and Chief Executive Officer Tasty Baking Company

Mr. Christopher J. Policinski, President and Chief Executive Officer,Land O'Lakes, Inc.

Mr. Michael B. Polk, President, Unilever Americas Unilever

Mr. Kendall Powell, Chairman and CEO, General Mills, Inc.

Mr. Brian L. Reichart, President and Chief Executive Officer Red Gold, Inc.

Mr. Gary M. Rodkin, Chief Executive Officer,ConAgra Foods

Ms. Irene B. Rosenfeld, Chairman and Chief Executive Officer, Kraft Foods Inc.

Mr. Daniel Servitje, Chief Executive Officer, Grupo Bimbo, S.A. de C.V.

Mr. David P. Skarie, President and Chief Executive Officer, Ralston Foods, Inc.

Mr. Timothy P. Smucker, Chairman and Co-Chief Executive Officer The J. M. Smucker Company

Mr. Todd Stitzer Chief Executive Officer Cadbury Schweppes PLC

Mr. Thomas Stokes, Chief Executive Officer, Tree Top, Inc.

Mr. David West, President and CEO, The Hershey Company

Mr. Alan Wilson President and CEO, McCormick & Company, Inc.

The Produce Marketing Association (PMA), a large trade association representing companies that market fresh fruits and vegetables, is in favor of food irradiation that it says has been proven safe by extensive scientific research, the U.S. government and international food and science experts. PMA supports the government's decision allowing irradiation of fresh fruits and vegetables, but disagrees with the FDA's proposal to eliminate labeling for irradiated foods. The consumer deserves to be able to make a choice. p>

Produce Marketing Association (PMA) appreciates the opportunity to submit comments on the Food and Drug Administration�s proposal to revise its irradiation labeling regulations. PMA is the largest global not-for-profit trade association representing companies that market fresh fruits and vegetables. Some Other Email Addresses: American Frozen Food Institute Leslie G. Sarasin President & Chief Executive Officer 2000 Corporate Ridge Suite 1000 McLean, VA 22102 Tel: 703/821-0770 Fax: 703/821-1350 E-mail: Web Site: The Coca-Cola Company Vail T. Thorne One Coca Cola Plaza Atlanta, GA 30313 Tel: 404/676-5001 Fax: 404/515-2509 E-mail: Corn Refiners Association, Inc. Jennifer Snyder 1701 Pennsylvania Avenue, NW Suite 350 Washington, DC 20006 Tel: 202/331-1634 Fax: 202/331-2054 E-mail: Web Site: Flavor & Extract Manufacturers Association Kim Earle 1620 I "Eye" St., NW Suite 925 Washington, DC 20006 Tel: 202/293-5800 Fax: 202/463-8998 E-mail: Food Industry Environmental Network Jack L. Cooper 33 Falling Creek Court Silver Spring, MD 20904 Tel: 301/384-8287 Fax: 301/384-8340 E-mail: Web Site: Frozen Potato Products Institute Sue Siemietkowski Executive Director 2000 Corporate Ridge Suite 1000 McLean, VA 22102 Tel: 703/821-0770 Fax: 703/821-1350 E-Mail: Grocery Manufacturers of America (GMA) Karil L. Kochenderfer Director, Environment & New Technologies 1010 Wisconsin, NW Suite 900 Washington, DC 20007 Tel: 202/295-3927 Fax: 202/337-4508 E-mail: Web Site: H.J. Heinz WHQ John J. Brown USSB 59th Floor 600 Grant Street Pittsburgh, PA 15219-0057 Mail to:P.O. Box 57 Pittsburgh, PA 15230-0057 Tel: 412/456-6037 Fax: 412/442-3252 E-mail: Web Site: International Dairy Foods Association Clay Detlefsen 1250 H Street, NW Washington, DC 20005 Tel: 202/737-4332 Fax: 202/331-7820 E-mail: Web Site: Institute of Shortening & Edible Oils, Inc. Robert M. Reeves 1750 New York Avenue, NW Suite 120 Washington, DC 20006 Tel: 202/783-7960 Fax: 202/393-1367 E-mail: Web Site: National Association of Margarine Manufacturers Belva Jones 1156 Fifteenth Street, NW Suite 900 Washington, DC 20005 Tel: 202/785-3232 Fax: 202/223-9741 E-mail: Web Site: National Cotton Council Phillip J. Wakelyn, Ph.D. 1521 New Hampshire Avenue Washington, DC 20036 Tel: 202/745-7805 Fax: 202/483-4040 E-mail: Web Site: National Institute of Oil of Oilseed Products Belva Jones 1156 Fifteenth Street, NW Suite 900 Washington, DC 20005 Tel: 202/785-3232 Fax: 202/223-9741 E-mail: Web Site: National Frozen Pizza Institute Robert L. Garfield Executive Director 2000 Corporate Ridge Suite 1000 McLean, VA 22102 Tel: 703/821-0770 Fax: 703/821-1350 E-mail: Web Site: National Oilseed Processors Association David C. Ailor, P.E. 1255 Twenty-third Street, NW Washington, DC 20037 Tel: 202/452-8040 Fax: 202/466-4949 E-mail: Web Site: Northwest Food Processors Association Dave Zepponi 9700 SW Capitol Highway Suite 250 Portland, OR 97219 Tel: 503/327-2200 Fax: 503/327-2201 E-mail: Web Site: Snack Food Association Christopher T. Melchert 1711 King Street Suite One Alexandria, VA 22314 Tel: 703/836-4500 Fax: 703/836-8262 E-mail: Web Site: Unilever Foods NA Ruth M. Adelman, P.E. 800 Sylvan Avenue Englewood Cliffs, NJ 07632 Tel: 201/894-4033 Fax: 201/871-8230 E-mail:

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