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[Letter to Consumer Reports]

July 30, 2003

Julia Kagan
Vice President and Editorial Director
Consumer Reports
101 Truman Avenue
Yonkers, NY 10703

Dear Ms. Kagan:

As a subscriber to Consumer Reports for more than 20 years, I anticipated with great eagerness reading your article, "The Truth About Irradiated Meat" in the August 2003 issue. However, as a public health scientist who has been at the forefront of investigating many of the largest and most significant foodborne outbreaks in this country since 1975 and as someone who has as my number one priority the prevention of disease, I was extremely disappointed to see the same article was in fact misleading and lacking in an understanding of the basic principles of foodborne disease prevention. Unfortunately, instead of providing the scientific facts about the benefits versus the risks of utilizing irradiated food products, you perpetuated myths about this lifesaving food technology. In addition, I believe there are serious ethical considerations with regard to the conduct of your investigation and subsequent reporting. I appreciate the seriousness of this latter statement. As such, I will detail my concerns with regard to each of the above points.

First, let me address my concern with regard to the ethical consideration. The article did not report or refer to information provided to Doug Podolsky, the author of the article, by several sources that specifically address claims made in the article that a recent European research article offered by a group of researchers including Dr. Henry Delincee, a scientist at the Institute of Nutritional Physiology at the Federal Research Center for Nutrition in Karlsruhe, Germany. Consumer Reports indicated that Dr. Delincee had stated the need for further study of the possible impact of 2-alkylcyclobutanones (2-ACB), a by product created by irradiating fat in food such as ground beef. However, he never stated that irradiated food are not safe for human consumption. Dr. Delincee's conclusions have been extensively misstated by such groups as Public Citizen, and unfortunately repeated in similar fashion in your article. Public Citizen continues to state that Dr. Delincee concluded that additional research is needed before the safety of irradiated meats can be determined even though Dr. Delincee has provided Public Citizen with a refutation of their conclusion. In fact, Mr. Podolsky was provided with a letter from Dr. Delincee that stated, "Public Citizen uses my research as evidence in their allegations against food irradiation. However this obvious case of producing distrust among consumers regarding irradiated food in school lunches puzzles me. The statements of Public Citizen are excessively alarmist. This case is founded on mere allegations and not on scientific arguments." Dr. Delincee concludes his letter by saying, "the crucial question is whether the benefits of food irradiation gained by inactivating harmful bacteria such as the dangerous Escherichia coli O157:H7 will outweigh the possible risks. In my view - and this is the opinion of WHO and other international and national organizations - the benefits far outweigh the risks."

In the Delincee et al paper that Consumer Report cites, the study's authors have cautioned "the relevancy of these results for the risk assessment of human consumption of irradiated food remains to be elucidated." Neither Dr. Delincee nor anyone else can actually claim that 2-ACB data in this study is directly relevant to the discussion of the human safety of irradiated food products. For example, feeding studies conducted over the past 40 years involving irradiated meats, all of which would have presumably contained 2-ACBs, were not found to increase tumor incidence in laboratory animals or humans. If scientific articles are to be presented to the general public then they ought to be fair and balanced and consideration both what they show and the context and qualifications that surround those results. Your article failed to do this.

The refutation of the claims by Public Citizen regarding the Delincee work were provided on more than one occasion to Mr. Podolsky, but he and your editors chose to ignore them rather than include them in your article. This flagrant omission once again leaves the reader with unnecessary distrust of food irradiation. I look forward to your explanation as to why this selective reporting occurred and what steps Consumer Reports will take to provide the necessary facts to their readers as they relate to this issue.

Next, I will address a series of factual errors, half truths and misleading over simplifications, of information emphasized to make scientific conclusions meaningless. In order for me to systematically provide you with such a review, I will refer to the actual page and paragraph of this information.

Page 34 (last paragraph) - Page 35 (first two paragraphs)
You suggest that it is necessary to "wipe out all bacteria in meat." This is a fundamental error in the scientific understanding of food safety. At no time do we attempt to achieve sterilization with a pasteurization process. (Note that I will address your inappropriate use of the term pasteurization below). The concept of pasteurization of a food or beverage item is to kill or inactivate all potential pathogens of note in a given item without sterilizing the product. The best example of this process is the use of heat pasteurization for the purposes of destroying disease causing bacteria in milk while allowing other harmless bacteria species to survive the process. Your statement misleads the reader into believing that somehow not killing all bacteria in meat without using a higher dose of irradiation is problematic. In this regard, your statement "irradiated meat generally harbors far fewer bacteria than non irradiated meat, so there is less chance that it would make you sick if they were not cooked thoroughly." is meaningless from a scientific perspective. The risk of foodborne disease has nothing to do with the actual level of bacteria, it has to do with the level of "specific pathogens" or disease causing bacteria. In fact, the food items that are top priorities for irradiation, including red meats and poultry also are the single greatest documented sources for cross contamination of other food items in the kitchen. It is not just the drippings from these items that may contaminate a cutting board (as you indicated in the article) but many of the food items are more likely to be contaminated by the preparers' hands despite evidence of hand washing. By irradiating food items with an increased risk of contamination prior to arrival in the kitchen we eliminate a major source of the foodborne pathogen into the kitchen area. This point has been documented in many outbreak investigations. You missed this critical conclusion in the article's discussion.

Page 35 (paragraph 7, 8)
While the article does detail the number of cases of illness that would be eliminated with the use of irradiation if half of all ground beef, poultry, pork and processed meat were irradiated, you indicate that such reductions would amount to only 6% of foodborne illness reported each year. You then state that "the rest of those illnesses can be attributed to other foods, like eggs and seafood or problems such as improper food storage." This is simply not true. Today eggs and seafood contribute to a very small percentage of foodborne outbreaks (See 2002 National Foodborne Disease Surveillance Data - Centers for Disease Control and Prevention). Well over 40% of foodborne disease is caused by a class of viruses known as Noro-viruses or Norwalk-like agents. The primary source of this pathogen is from contamination of the items by infected food handlers and which are not subsequently cooked. Fortunately, most of these illnesses are of short duration (i.e. 24-36 hours) and very few cases experience severe illness. By far, the most serious infectious agents that we encounter with foodborne disease in this country are caused by the very pathogens that are routinely eliminated with the use of food irradiation such as Listeria monocytogenes, E. coli O157:H7, Salmonella and Campylobacter. Thus, many of the "serious" foodborne disease illnesses will be prevented with the use of irradiation even if milder illnesses like Noro-viruses illnesses are not prevented.

Page 35 (paragraph 10)
The article states that the Department of Agriculture report eliminating 99.9% of E. coli O157:H7 in spiked beef samples with a low-tech steps. However, irradiation averages a five log reduction (99.999%) in harmful pathogens. The difference between these two methods of pathogen reduction is significant with more than a hundred fold greater reduction in the organism with irradiation versus other approaches. This is a significant finding in that many of our outbreaks of foodborne disease, particularly those involving E. coli O157:H7, result from extremely low doses of E. coli (<10 cells per gram) in the food. For example, we've documented numerous outbreaks of E. coli O157:H7 where the infected individual likely consumed fewer than 10 viable organisms. The difference between the level of contamination after spraying beef with lactic acid or steam and the use of irradiation is very significant. Your article totally missed this point. For example there is one particular meat slaughtering operation in this country that routinely utilizes a series of these "low-tech" steps, and emphasizes high levels of slaughter plant hygiene. Despite these efforts, their meat has been documented to be the source of several recent E. coli O157:H7 outbreaks. Short of pasteurization (i.e. 5 log reduction in pathogen levels) we will never be able to assure the public of a safe red meat product.

Page 35 (Paragraph 11)
It continues to amaze me that the quote by Carol Tucker Foreman appears to have some relevance in the discussion about using food irradiation as a tool in preventing foodborne disease. We all agree it's important to take steps to avoid contaminating food to begin with. Irradiation is not, nor ever will be, a primary method for cleaning up a problem after the fact.

Let me illustrate why Ms. Tucker Foreman's comment is not helpful. Today in our hospitals throughout the United States, approximately 3% of patients will experience a post-surgical site infection as a result of bacteria contaminating the wound site during a "clean surgical procedure." This means that a patient who had no discernable infectious agent present, was operated on in a sterile field in an environment where sterility is a premium, yet they ultimately had their incision site contaminated with an organism during the surgical procedure. If we cannot eliminate contamination from a surgical incision with a potential pathogen in a sterile surgical field in the controlled environment of a hospital, how can one ever imagine the complete elimination of possible pathogens from an animal carcass being disemboweled in a slaughtering plant. In short, the comment by Ms. Tucker Foreman suggests that there is gross contamination of carcasses in this environment that could be eliminated if someone were just to clean it up! I have personally witnessed carcasses coming off a slaughtering line with absolutely no discernable fecal contamination on that carcass, yet with subsequent studies microscopic bacterial contamination was found. Ms. Tucker Foreman's argument is largely a red herring and does not put into context the impossibility of removing all of the microscopic contamination that can occur during the highest quality slaughtering operation that money can buy. Again, at no time should we accept anything other than the highest level of sanitation in the slaughtering process, yet, to suggest that all carcass contamination can be eliminated at slaughter casts serious doubts on the professional competencies of the individuals making that statement. When we can eliminate all surgical site infections in our hospitalized patients, we can then begin to attempt to eliminate carcass contamination in our packing plants.

Page 37 (Paragraph 2)
See my comments noted above regarding the incomplete and intentional misreporting of this issue.

Page 37 (Paragraph 7)
Many of us in the foodborne disease prevention area are strongly supportive of labeling product that has been irradiated. However, it should be put in context that "treated with irradiation" suggests that somehow this intervention leaves the product in a "treated" form. In short, the use of this language suggests that we also need to label products as having been treated with heat, pressure, microwaving, freezing or ultra-violet light. Can you imagine someone buying a product that has on its label "Treated with heat or with microwaves". Yet, potential unique byproducts, vitamin degradation or taste considerations are not significantly different with heating or microwaving than they are with the use of irradiation. All that I ask as a scientist is that we make it clear to potential consumers what it means to have a product be irradiated as it relates to other food safety processing techniques.

Page 36 (Sidebar - Close-up)
I feel that the entire taste test that you have detailed here is seriously flawed and does not reference any other taste testing experiments of irradiated product that have been conducted and for which different results were documented. I believe your taste testing work may be potentially flawed in that we have only a limited amount of information with which to judge the scientific methods and accuracy of your study. How many taste testers were involved and what is the appropriateness of using professional taste testers and their expertise in detecting extremely slight changes in product composition or taste compared with the average consumer and the frequency with which they described their findings. You suggest that with 72 pairs of irradiated and non-irradiated meat products, in all but in six pairs, taste testers believed that the product tasted as if it had a scorched taste or a smell reminiscent of singed hair. I was dismayed at the incredible reach that such claims were made without more detailed data. This is so unlike the rigorous type of study methods employed by Consumer Reports in previous comparison studies.

In the August 2003 issue, your editors found space for details on the best paints, stains, washing machines and detergents, but did not provide detailed ratings and finding for irradiated meats. If you can devote space to the noise level of a washing machine, hardly a life-saving aspect of use, you certainly should be able to provide details on what microbes were being tested for the methods for the laboratory testing, what safe guards were in place (if any) to ensure the meat shipped overnight was not contaminated during the purchase, shipping or testing process.

In addition, the use of 72 pairs of irradiated and non-irradiated meat does not make this the largest study of this comparison between irradiated and non-irradiated products. Yet, in both press releases and statements made to the media, a Consumer Report representative continued to maintain this point. We can provide you with a number of additional blinded taste test experiments using consumers (the only real taste testers who matter) that have been conducted for which the results were quite different than what you have portrayed here. The absence of commenting on such studies reflects a severe bias in your conclusions.

Page 37 (What you can do)
Your recommendation for not relying on meat color to judge doneness as opposed to the other recommendation of ordering ground beef "medium" or well done are inconsistent. Today in many restaurants hamburger ordered medium will come with a pink internal core. The consumer will not have ready access to a food thermometer in that setting. Your recommendation for ordering a hamburger medium needs to be corrected for your readers. Frankly, if consumers were to routinely order ground beef done to a medium level you would contribute to the occurrence of E. coli O157:H7, Salmonella and other serious foodborne illnesses.

Page 37 (What CU is doing)
The sidebar box states: "Irradiated food should continue to be labeled 'irradiated'". Calling them "pasteurized" or anything else is misleading." In fact, Webster's Dictionary includes the following definition; pasteurization means "partial sterilization of perishable food products (as a fruit or fish) with radiation (as with gamma rays)." In other words, Webster's concludes that food irradiation is a form of pasteurization. I would suggest that you do additional study on the scientific premises of pasteurization as put forward by Professor Pasteur. You will find that your comment was in error.

In short, I believe your article on food irradiation hardly meets the standards for scientific accuracy and journalistic integrity that has long characterized Consumer Reports. I look forward to learning how you intend to address this serious problem in light of the many lives that may be potentially affected by your conclusions.

Sincerely yours,

Michael T. Osterholm, PhD, MPH
Director, Center for Infectious Disease Research and Policy
Professor, School of Public Health
University of Minnesota
Minneapolis, MN 55455

cc: David Kessler, Dean, Yale School of Medicine; James Guest, President, Consumer Reports; Louis Milani, Senior Publisher, Consumer Reports; Geoffrey Martin, Director, Consumer Sciences, Consumer Reports; Frank Cerra, Sr. Vice President, Academic Health Center, University of Minnesota; Mark Becker, Dean, School of Public Health, University of Minnesota