From: Armchairactivis@webtv.net
Sent: Sunday, February 25, 2001 12:12 AM
To: fdadockets@oc.fda.gov
Subject: Irradiation Labeling, Docket No 98N-1038



Food and Drug Administration, Dockets Management Branch
5630 Fishers Lane, Room 1061
Rockville, MD 20857

Dear Food and Drug Administration, Dockets Management Branch,

I am at a complete loss to understand why consumers
should need an interpreter to understand the labels
on their food.  Any proposal to hide the actual process
by which food is prepared or to disguise the actual
ingredients is a betrayal of the public trust in which
the FDA is held by the public.  Approving the euphemism
of "cold pasteurization" rather than requiring the
explicit term "irradiated" food, makes the FDA just
another Madison Avenue advertising firm for industry.
The same industry which prefers to substitute an insufficiently
tested procedure for their failure to create and maintain
sanitary conditions for the production of our foods
or to remove sick livestock from our food supply. 
If industry is to be permitted to sidestep these crucial
steps to quality food as yielding a poor return on
their investments, then the purchasing agents must
be permitted to clearly make the choice between irradiated
versus traditionally prepared products.  The purchasing
dollar should be the determining factor in the marketplace
with consumers directing production with the power
of their wallets.  In Europe where GMO foods failed
to capture consumer interest, clear labeling enables
consumers to make informed choices.  Americans are
required to turn grocery shopping into a research project
if they do not wish to choose GMO foods.  Feel free
to permit industry to make whatever claims are accurate
to make their irradiated products more appealing to
US citizens. However, labeling it pasteurized in any
fashion is to hide the facts of the matter from those
the FDA was brought into being to protect.  If it turns
out that there are any detrimental effects to eating
irradiated foods, do you want it known that you failed
to permit shoppers to know what they were purchasing?
 If it turns out to be a superior way to process food,
should the public not enjoy a clear expression of the
reason for success? Any industry that prefers to hide
the facts from consumers is also keeping data from
them which would indicate their product is a poor choice.
 This is true whether it is a failure to label inerts
in pesticides, to state the actual chemical composition
of fragrances or to reveal that an engineered grain
produces its own insecticide and kills certain lifeforms
which attempt to feed on it in the fields. It certainly
applies to the application of radiation to the food
supply.Why is truth in labeling such an unacceptable
concept in this country?   



Sincerely,


Barbara Rubin
P.O. Box 224
Locust Valley, New York 11560