Washington, D.C., December 18, 2007

Citizens for Health has joined with the American Herbal Products Association to oppose the irradiation of dietary supplements

Citizens for Health supports AHPA's opposition to this petition on the following grounds:

• Proper handling of dietary supplements under current good manufacturing practice is usually sufficient to ensure that they are not subject to microbial contamination that presents any risk to the health of consumers of these products
• If approved, the use of ionizing irradiation on herbal dietary ingredients will mask one of the factors that is currently relevant to the determination of ingredient quality, since information about microbial levels and the presence of pathogens or yeasts and molds at any time during the handling of a treated ingredient would be lost. Of particular concern are pathogens, since even if pathogenic organisms are eliminated through irradiation, pathogenic by-products such as endotoxins or exotoxins may remain in the material
• Irradiation is currently allowed in the United States for eleven food categories, and in proposing that the limitation of ionizing radiation for dietary supplements be established at 30 kGy, the petition is suggesting that this limit be from 3 to 30 times higher that is currently allowed for all but two food categories. Dietary supplements may be consumed in quantities of several grams per day. Thus, dietary supplement consumers will be exposed to much higher levels of any material changes that occur in a supplement’s or ingredient’s characteristics or in its consequences of use, if any, as a result of the irradiation.