Health Canada recently announced a regulatory initiative which would allow beef processors to sell irradiated ground beef. I was invited to speak to Calgary’s Kingkade and Breakenridge on NewsTalk 770 about what this initiative might mean. The interview went well, and Rob and Roger are both thoughtful and insightful radio hosts, but there was a lot that didn’t get covered. I’ll expand on some of those thoughts here.

In 2002 Health Canada (not for the first time) put forward an initiative to allow for the sale of irradiated ground beef, but that was abandoned as a result of resounding negative feedback (from consumers, the public, or “activists” depending on your perspective). Between then and now, a considerable amount has changed. Landmark food safety events such as the deadly Maple Leaf Listeriosis outbreak in 2008 and XL Foods E. coli beef recall in 2012, which remains Canada’s largest – among numerous other high-profile recalls and outbreaks – have coincided with a growing public awareness of food safety and other issues related to food safety and provenance. More than ever, consumers want to know about where their food comes from, how it’s made, and most importantly that it is safe (e.g., Lockie 2002; Busa and Garder 2014). Indeed, the Canadian Cattlemen’s Association is confident that the public (or at least those outspoken members of the public) have changed course. Regardless of the changes in the last 15 years, there is doubt about whether or not Health Canada’s proposal will be successful. Putting aside the perceived risks, the court of public opinion is often a hard sell, and understandably so. The circumstances in which we encounter radiation are almost universally negative: cancer treatment, x-rays, air travel, nuclear disasters, and World War II to name a few.

Despite what critics say, the scientific evidence suggests that nutrient loss and toxics production is limited or non-existent, which is considerably less than what cooking itself would introduce. Moreover, consumers also seem to forget that their pre-washed salads, sprouts, and peeled carrots are treated with chlorine, while other products are treated with ammonia (let’s also not forget the many instances in which lye is used in very traditional foods like hominy, bagels, and pretzels).

Even if we accept that there is a small health risk associated with consuming irradiated beef, as many have pointed out, the risk from foodborne pathogens is far greater and far more immediate. As I said in my interview, if you want to avoid toxins and carcinogens, you’d best stop eating cooked meat altogether.

Health Canada will require beef producers to label irradiated products. I think this is a critical part of the proposal that is non-optional. Absolutely consumers should have the ability to identify irradiated food, and anything that enhances transparency in the food system more generally should be pursued. However, this will be hard for industry who have to convince consumers to buy the meat with the irradiated label, which may well be sitting next to a tray of meat that was not irradiated. It’s a difficult set of choices from a consumer’s standpoint: did something happen to the meat that required it to be irradiated? The non-irradiated stuff is fine as long as I cook it correctly (where’s my meat thermometer again?). Evidence of this consumer ambivalence is demonstrated by Costco in the US, where irradiated beef has not sold well. As Craig Wilson, Costco Food Safety Chief suggests of irradiated beef: “Mom wouldn’t buy it”, even if the risk from foodborne illness is in fact higher, and more dire.

Ultimately, while industry is one of the primary supporters of irradiation, I am not sure how quickly it will be taken up without a coordinated, industry-wide effort. Who in industry will have the guts to be the first on the shelf with the new irradiation label? How will industry and the Canadian government ensure there isn’t an “irradiated ghetto”? How do we prevent competition and marketing based on (non-)irradiation, such as the development of a premium niche of non-irradiated beef? I suspect we’ll see either an irradiated ghetto as demonstrated by Costco in the US, or a non-irradiated premium niche. Either way the beef industry has a marketing challenge on its hands here, should irradiation be permitted in Canada.

The industry challenges aside, I look critically, though not dismissively, on the prospect of irradiation. Numerous commentators, including Rick Holley, food scientist at University of Winnipeg suggests that we’ve run out of regulatory power and that because “pathogen contamination in processing plants cannot be prevented…if we really want to prevent outbreaks, we have to look at expanded use of irradiation”. However, he also suggests that irradiation will not protect against industry incompetence. I don’t entirely disagree with Holley and other commentators who seem to suggest that XL Foods is a shining example of why we need irradiation, that it might have prevented or limited the (already rather small) outbreak, but there’s a lapse in logic. A major contributing factor to the XL Foods recall was a “weak food safety culture” and that ultimately “it was all preventable”. The company failed to clean its equipment, maintain its plant, respond to CFIA corrective action requests, and actively practice its recall plan.

The conclusion of the independent reviewers of the XL Foods incident runs contrary to many commentators’ primary arguments in favour of radiation, using precisely the same case as evidence. I don’t buy the idea that we’ve run out of regulatory tricks to reduce foodborne pathogens upstream. The XL Foods recall didn’t take place because we’re at the end of our regulatory rope; it happened because both the CFIA and XL Foods dropped the ball. Based on the commentary from supporters like Holley, irradiation would have either done nothing at all (being incapable of overcoming industry incompetence, as he argues), or it would have allowed one or both to get away with a (rather protracted) moment of weakness, potentially leaving the profligate issues at the XL Foods plant to remain unresolved.

I hesitate to outright reject irradiation of ground beef and other products. Foodborne illness is a significant burden on the public health system of Canada and can profoundly impact the lives of victims. In line with my own research on food waste, it is also a non-trivial source of food waste. XL Foods alone resulted in over 5.5 million kilograms of beef being landfilled, which is equivalent to approximately 12,000 cattle. Just this week, General Mills announced that it is recalling over 10 million pounds of flour in the US due to potential E. coli contamination. There are over 300 recalls per year in Canada and over 1000 per year in the United States. If irradiation could prevent even a few of these recalls, it would be a significant improvement in terms of public health and food waste. For example, as Holley suggests (alas, we do not disagree on everything!), irradiating poultry alone would reduce foodborne illness in Canada by 25% and an inestimable quantity of recalled food from being destroyed.

Taken together, I don’t buy the popular criticisms of irradiation, but I think we need proceed with caution. I think irradiation is a reasonable compliment to a holistic farm to fork food safety system that includes regulators with teeth and clout working with competent food producers and processors who feel those teeth when they step out of line. It was the absence of this dynamic that contributed to the XL Foods recall, which has become the poster child for supporters of irradiation. As Health Canada moves forward with the public consultation over irradiating ground beef, let’s take a reasoned and critical approach without knee-jerk reactions that dismiss science, or conversely dismiss the concerns of the public (or activists therein). Most importantly, let’s take this as an opportunity to examine how irradiation can fit in to a comprehensive food safety system while we make the system as a whole stronger, because there’s plenty of room to improve.