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Issues: Growing and Production

PMA Comments on FDA Irradiation Rule

June 29, 2007

To:       Food and Drug Administration

From:    Produce Marketing Association, Kathy Means, Vice President

Re:       Docket No. 2005N–0272

The 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. PMA's purpose is to sustain and enhance an environment that advances the marketing of produce and related products and services. The association represents companies throughout the food distribution chain that market more than 90% of fresh produce sold at the consumer level in the United States. PMA is funded primarily by members’ dues, revenues from exhibits, product sales, and meeting registrations.

For fresh produce, FDA regulations permit the use of radiation not to exceed 1 kiloGray for the growth and maturation inhibition. 

PMA believes that sound science must be the basis for decisions about all food issues. Based on extensive scientific research and review by the U.S. government and international food and science experts, irradiation has been deemed to be a safe and viable technology. PMA supports the government's decision allowing the irradiation of fresh fruits and vegetables. PMA also believes in providing consumers the choice in the marketplace, including the choice of irradiated and nonirradiated produce.

FDA proposes 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.

PMA disagrees with this approach. The association believes the technology is safe and useful. At this time, we believe consumers still want to know whether a food has been irradiated. We support keeping the labeling requirements for irradiated fresh produce. We also believe that consumers may be confused by a change in nomenclature (to “cold pasteurized” or some other phrase) or may perceive it as misleading. We support using the word “irradiated.”