Food Policy 35 (2010) 548–555

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Food Policy

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Irradiation as a quarantine treatment q

Peyton Ferrier *

Economic Research Service, USDA, Washington, DC 20036, United States

a r t i c l e i n f o

Article history:Received 29 October 2009Received in revised form 26 May 2010Accepted 9 June 2010

Keywords:IrradiationTradeLabelingPhytosanitarySPSInvasive species

0306-9192/$ - see front matter Published by Elsevierdoi:10.1016/j.foodpol.2010.06.001

q The views expressed in this article do not represe* Tel.: +1 202 694 5224; fax: +1 202 694 5820.

E-mail address: pferrier@ers.usda.gov

a b s t r a c t

Poor consumer acceptance and large fixed costs have limited the use of irradiation to increase food safetyand mitigate pest risks. We discuss these challenges to irradiation’s use as quarantine treatment and thegrowth of some irradiated fresh fruits imports since 2006. Lower regulatory barriers, changes to labelingrequirements, and the curtailment of other quarantine treatments may de-stigmatize irradiation on thedemand side while scale economies may reduce costs on the supply side.

Published by Elsevier Ltd.

Introduction ing cellular reproduction, irradiation can neutralize pest and food

In 2006, the USDA approved irradiation as a quarantine treatmentfor nearly all insect pests, a regulatory change greatly enhancing itsscope of application for fresh fruits and vegetables. However, poorconsumer acceptance and large fixed costs have limited the use ofradiation both as a quarantine and food safety treatment. We discussthe outlook for irradiation as a quarantine treatment and its use forfresh tropical fruit imports lacking comparable quarantine treat-ment options. We argue that increased liberalization of permitteduses of irradiation treatments, potential changes to labeling require-ments, and the curtailment of fumigation treatment options may de-stigmatize irradiation on the demand side while scale economies arelikely to reduce costs on the supply side. We review the technology ofirradiation quarantine treatments and their effects on food quality,the alternative quarantine treatments including methyl bromidefumigation, their comparative costs structures, and the market pen-etration of irradiated food.

Background on irradiation

Technology

Irradiation exposes food to radiant energy from gamma, e-beam(high-energy electrons) or X-rays that penetrate objects and breakmolecular bonds including the DNA of living organisms. By inhibit-

Ltd.

nt those of ERS or the USDA.

safety problems. The effect depends on the dose, measured in kilog-rays (kgr, equal to 1000 grays, gr). Low doses of irradiation (less than1 kgr) only disrupt cellular activity enough to prevent reproduction(as with Mediterranean fruit flies on guava) or sprouting (on pota-toes). Medium doses (between 1 kgr and 10 kgr) reduce microbialloads on food, as with Thrichnella on pork (Niemira and Fan, 2006).High doses (between 10 kgr and 25 kgr) kill a comprehensive spec-trum of fungi and bacterial pests (as with spice imports) and extendthe shelf life of perishable foods (such as strawberries). Very highdoses (greater than 25 kgr) sterilize medical equipment, hospitalfood and pet food.

Unsurprisingly, by imparting energy into living tissue, irradia-tion damages food. The extent of this damage and the conse-quences for human health and consumer acceptance are acontentious topic. Higher doses cause more damage. For freshfruits and vegetables, doses are low. With the exception of freshlettuce and spinach,1 the FDA restricts the maximum level of irradi-ation for fresh fruits and vegetables to 1 kgr, a binding technicalthreshold for producers due to the uneven absorption of irradiationas it passes through objects. As Follett explains (2009), processorsmust ensure that the dose reaches the minimum amount necessaryto achieve quarantine security while not exceeding the maximumamount to meet FDA limits in any portion of the good. Problemati-cally, a dosage of irradiation that ensures that the interior contentsof a container receive the minimum dosage may push the dosage

1 Among fruits and vegetables, FDA currently only allows irradiation treatment oflettuce and spinach at the 4.5 kgr level. The FDA is currently evaluating whether4.5 kgr may be an acceptable level for all fresh fruits and vegetables (FDA, 2008).

3 Key exceptions to this labeling requirement are goods that are minor ingredientsor goods that undergo further processing after sale such as irradiated spices in soupsor frozen pizzas and food sold in restaurants, schools, and hospitals. Food QualityNews (2003) reports that some advocacy groups wish to expand mandatory labelingto food in school lunches as well.

4 A systems approach protocol is a set of quarantine protocols determined by bilateralagreement to permit the entry of a commodity into the country if the set of specified

P. Ferrier / Food Policy 35 (2010) 548–555 549

on the exterior over the FDA limits. Uneven absorption limits thesize of containers to boxes, not pallets, and the irradiation itselfnecessitates packaging materials that can maintain theirs look andintegrity through the process (Pauli, 2006; Morrison, 1987).

Quality effects

Irradiation’s effect on quality is controversial. Despite somemisconceptions, exposing food to irradiation does not make thefood itself radioactive (i.e. emitting radiation). While a comprehen-sive review of the (very extensive) scientific literature is outsidethe scope of this article, the substantive criticisms of food irradia-tion surround its potential to: harm sensory characteristics (odor,flavor and appearance) of quality; reduce vitamin content; producecarcinogenic compounds in food; reduce incentives to undertakealternative food safety efforts; and encourage industry concentra-tion (Center for Food Safety, 2007).

For fresh fruits and vegetables, irradiation has a variable effect onsensory characteristics – traits revealed through observation or con-sumption. Where this effect is significant (i.e. grapes getting soft), sell-ers typically seek out other treatments or simply forego the importmarket. A large body of economic literature argues that well-function-ing markets are efficient (i.e. optimally trading off the relative costsand benefits) at providing search and experience production attri-butes for food such as taste, texture, and appearance (Laffont andTirole, 1991). Freezing or heat treatments are examples of acceptablequarantine treatments that similarly harm key quality attributes.

Of greater concern is irradiation’s effect on credence characteris-tics, food traits that cannot be verified through consumption andrequire trust in those providing quality assurances. Irradiation’sopponents argue that it reduces the food’s vitamin content and cre-ates furan and other ‘‘radiolytic” products in foods that are carcin-ogenic. Proponents counter that vitamin reduction and furancreation occur at levels roughly equivalent to that of cooking(Grocery Manufacturers Association or GMA, 2009; Fan and Soko-rai, 2008; Center for Food Safety, 2007; Raul et al., 2002). During itsapproval of irradiation for lettuce and spinach (at the 4 gr level),the FDA concluded that irradiation is safe (FDA, 2008). Despite this,however, acceptance of irradiated food appears fragile and sensi-tive to new information (Fox et al., 2002).2

The potential benefits of food irradiation are numerous. In addi-tion to quarantine uses, irradiation (at least 500 grays, Niemira andFan, 2006) reduces the microbial load and was approved as a foodsafety treatment for e. coli and salmonella with spinach, meat, andeggs (Zhang and Etter, 2008). However, this use of irradiation maydiminish the importance of other, less-effective risk-reductionmeasures. The Center for Food Safety argues:

Irradiation . . . creates a disincentive for producers and handlers totake preventative steps in production and handling. The longershelf life created by irradiation also provides greater opportunityfor post-treatment contamination via shipping, handling, etc.

While economists may accept that a risk-reducing innovationcauses substitution away from other measures, consumers, con-cerned with aesthetic aspects of food with extended shelf lives orless-careful handling, may find the practical implications repug-nant (Roth, 2007). Proponents note that now common food safetyinnovations, including milk pasteurization, raised similar concernswhen introduced.

When consumers cannot verify the presence of a product char-acteristic, they must trust the seller or some third party, often the

2 For example, the linking of cat deaths to the consumption of highly irradiated catfood (greater than 50 kgr) in December 2008 recently prompted Australia to suspendits sales although a causal link has not been determined (Burke, 2009; AustralianQuarantine and Inspection Service, 2009).

government. Anania and Nistico (2004) show that lack of trust inthe certifying groups reduces demand for the attribute. However,even with full knowledge of the underlying attributes of good, con-sumers are often poorly situated to individually evaluate eachattribute’s relative benefits especially when effects are disputed.Currently, food primarily consisting of irradiated ingredients mustbear the ‘‘radura” symbol (Fig. 1) in the US.3

In 2007, the FDA proposed revising its labeling regulation forirradiated foods and supplements so that labeling is only requiredif it causes a ‘‘material change” (Heller, 2007; FDA, 2007) in thefood or consequences of eating the food. In its proposed rule, theFDA defines material change as one in the organoleptic (sensory,i.e. smell, texture, etc.), nutritional, or functional properties of afood. For example, irradiation that delays banana ripening may up-set plans to cook banana bread with very ripe bananas by causing amaterial change. On the other hand, extending the shelf life ofspices with irradiation does not cause a material change makinglabeling voluntary. The diverse effect of irradiation on fresh fruitsand vegetables suggests that the material change designationmay be product specific.

The FDA proposed rule also addresses the application of a pro-vision of the Farm Security and Rural Investment Act of 2002establishing new criteria for use of the term pasteurized. Irradiatedfoods could be labeled as ‘‘pasteurized” if they meet the equiva-lency requirements defined in the Food, Drug and Cosmetic Act.The proposed rule would also allow labels to include supplementalinformation such as ‘‘treated with irradiation to inhibit sprouting”or ‘‘treated with irradiation to mitigate insect pests.”

Methyl bromide fumigation and other quarantine treatments

For fruits and vegetables to gain import access to the US, thecommodity requires a pest risk assessment specific to each path-way – the commodity and country (or region) from which the goodoriginates. If a pest is endemic to an area, the pest risk assessmentoutlines a regulatory program to mitigate the pest risk throughpre-harvest measures (field monitoring, spraying), post-harvesttreatments (irradiation, cold treatment and methyl bromide fumi-gation), or a combination of both methods known as a regulatorysystems approach protocol (RSAP).4

Post-harvest treatments, the bulk of which are methyl bromidefumigations, typically address insect pests. Methyl bromide isfumigant gas that kills a wide range of insect pests. Volatile andrapidly dispersing, it poses little threat to consumers but can im-part odors or hasten ripening and decay for certain commodities(as fumigation may break the cold chain). And, because methylbromide fails to penetrate flesh and seeds harboring quarantinepests, it can fail as a treatment for certain commodities bearingthese kinds of pests.

US post-harvest commodity treatments are typically requiredto meet the probit-9 standard, a statistical level of confidencethat specific actionable pests be mitigated through a quarantine

pre-harvest and post-harvest treatments collectively mitigate risk at the probit ninestandard. A system approach may specify which fields and packinghouses throughwhich goods move and establish certification of best practices for the programs such asfield spraying and pest-management. Post-harvest treatments (hot water dips) andmore rigorous post-harvest random testing may also be required (see Petersen andOrden, 2006). Often, USDA officials must be stationed abroad to ensure compliance.

Fig. 1. The radura logo (the specific logo and on shipped items). Sources: USDA and author.

Table 1Fruits permitted US entry using irradiation as phytosanitary treatment.

Exportingregion

Fruits Importingcountry

Dose(Gy)

Approvaldate

Ghana Eggplant, Okra, pepper United States 400 October2007

Hawaii Banana, Capsicum spp. (Peppers), Breadfruit, Carambola (Star Fruit), Cucurbita spp. (squash, pumpkins), CurryLeaf, Eggplant, Litchi, Longan, Melon, Pineapple, Papaya, Pineapple, Rambutan, Sapodilla, and Tomato

United StatesMainland

150 Beginningin 2003

Hawaii Abiu, Atemoya, Cowpea, Pitahaya (Dragon Fruit), Jackfruit, Mangosteen, Melon, Moringa pods, and SweetPotato

United StatesMainland

400 Beginningin 2003

India Mango United States 400 March 2007Mexico Guava United States 400 October

2008Mexico Mango United States July 2009Thailand Litchi, Longan, Rambutan, Mango, Mangosteen, Pineapple, Rambutan United States 400 June 2007Vietnam Pitahaya (Dragon fruit) United States 400 July 2008

Source: Follett and Griffin (2006) and USDA APHIS (fact sheets in various years, treatment manual 2009).

550 P. Ferrier / Food Policy 35 (2010) 548–555

treatment.5,6 Probit-9 does not consider economic efficiency andseveral authors including Livingston with oranges (2007), Calvinand Krissoff with apples (1998), Peterson and Orden with avocados(2006) and Wilson and Anton with meats (2006) have consideredthe efficiency aspects of sanitary and phytosanitary (SPS) protocols.Livingston and Peterson and Orden find regulations that are ineffi-ciently restrictive in specific applications. The probit-9 standard,however, is designed to apply as a mitigation standard for post-har-vest treatments generically across all severe pests, regardless ofother factors such as the ease of pest eradication or the effectivenessof regionalization programs.

Follett (2009) argues that a mitigation measure itself is simi-larly generic if it achieves the probit-9 standard for all pests of acertain class. To gain import access, fruits and vegetable must cur-rently undergo country- and commodity-specific pest risk assess-ments that outline the efficacy of mitigation measures. Forexample, potential pests on a commodity and their potential agri-

5 Follett (2009) explains that this standard represents 99.9968% efficacy inmitigating a pest threat. As a practical matter, ‘‘to achieve probit-9 mortality at the95% confidence level, a minimum of 93,613 insects must be tested with no survivors”and ‘‘few countries accept a treatment where there have been failures”.

6 Regulatory systems approach treatments mitigate pest threats using both pre-and post-harvest treatment that are collectively aimed at achieved a mitigationstandard like that of probit-9 but may be a less specific standard given that some pestthreats are less severe and that the effectiveness of some mitigation measures may behard to quantify. For instance, Indian mangoes carry a variety of pests but can enterthe US if they have been subject to both an irradiation treatment and a packinghouseinspection. Irradiation does not typically mitigate risk of fungi or bacterial pests atcurrent doses (required does would need to be approximately 20 times higher) andinspection is used to address these less severe pests.

cultural and environmental costs must be identified and the treat-ment shown to mitigate the pests. Because methyl bromide can failto mitigate all pests, the Animal and Plant Health Inspection Ser-vice (APHIS) must perform a lengthy commodity-by-commodityrisk assessment.

In 2006, the USDA approved an irradiation dose of 400 gr asbeing sufficient quarantine treatment for all insects, excludingrarely occurring adult and pupal stages of the insect family of lep-idotera (i.e. moths and butterflies). Now, approval of irradiation asa pest treatment only requires a cataloguing of the possible insectpests verification that the minimum dosage reaches the interior ofthe commodity, significantly simplifying the treatment process.Table 1 lists all goods permitted to the US using irradiation as aquarantine treatment. Table 2 lists all goods undergoing pest riskassessments by USDA APHIS as of June 30, 2009. The 23 of the121 for which irradiation is being considered are in bold.

Safety and environmental concerns of methyl bromide

Methyl bromide is an ozone depleting substance so the Mon-treal Protocol on Ozone Depleting Substances curtails its use. Since2005, only two uses of methyl bromide are permitted by signatorycountries: critical uses including soil fumigation, dried commoditystorage, and grain processing and quarantine and pre-shipment(QPS) uses including import or export quarantine treatments forcommodities such as food, timber and wood products (EPA,2009). Quarantine and pre-shipment uses of methyl bromide arecurrently unrestricted under the protocol. Critical uses are cappedby agreement, with stricter restrictions applying to 33 developed

Table 2Goods with Pending APHIS risk assessments (June 30th 2009, goods with proposed irradiation treatments in bold).

Country Commodities

Argentine (4) Cantaloupe and honeydew; citrus; passionfruit; raspberryASEAN (1)a Litchi, longan, and rambutanAustralia (6) Custard apple; litchi; longan and rambutan; mango; mangosteen; stone fruit (apricot, nectarine, peach, cherry, and plum)Brazil (1) Japanese squashCentral and/or South

America (8)Blueberries; guava; litchi; pepper; pitaya; longan; rambutan; red pitaya

Chile (8) Baby kiwi; cape gooseberry; clementine orange; fig. and pomengranate; horned cucumber; purple passion fruit; rosemary, sage,tarragon andthyme; tomato

China (4) Apple; mangosteen; rambutan; sand pearColumbia (6) Arugula; celery; lemongrass; sage; spinach; swiss chardEast Africa (1) PassionfruitECOWASb (3) Mango; papaya; tomatoEcuador (1) CurcurbitaEgypt (1) LettuceEl Salvador (4) Chipilin, chufle, izote, pacayaFiji (2) Eggplant, papayaGhana (2) Eggplant, pepperGuatamela (1) AvocadoHawaii (3) Sharwil avocado; cherimoya and soursop; guavaIndia (1) PomegranateIsrael (2) Barhi dates, Squash blossomsJapan (2) Orange, Persimmon (entire US)Jordan (2) Beans, StrawberriesKenya (3) Beans, Chili Peppers, Sugar snap and snow peasKorea (6) Shepherd’s purse, Sweet potato (entire US), tomato, orange, wild chivesMadagascar (1) LitchiMalaysia (4) Jackfruit; papaya; pineapple; starfruitMexico (6) Avocado (expansion to PR); fig; grapefruit; guava; pitaya; potatoNew Zealand (1) Persimmon (US)Pakistan (1) MangoPanama (2) False coriander; pepperPeru (3) Citrus; fig; and papayaPhilippines (4) Asparagus; banana (continental US and Guam); mango (expansion)Puerto Rico (1) RambutanSenegal (1) MelonSouth Africa (5) Allium; apricots, cherry, plumcots and pluots; avocado; litchi; persimmonSpain (2) Apricots; avocadoTaiwan (2) Longan; pummeloTurkey (2) Black figs; pomegranateUganda (2) Avocado; banana and plantainUnited Kingdom (2) Potatoes; wall rocketUruguay(2) Grapefruit, lemon and orange; melon and watermelonVietnam (1) MangoZambia (5) Green beans, garlic and leek, okra, pepper, sugar snap and snow peas

Source: USDA APHIS (2009).a ASEAN – Brunei, Cambodia, Indonesia, Laos, Malaysia, Philippines, Thailand, and Vietnam.b ECOWAS – equatorial Africa including Benin, Burkina Faso, Cote d’Ivoire, Gambia, Ghana, Guinea, Guinea-Bissau, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone, and

Togo.

P. Ferrier / Food Policy 35 (2010) 548–555 551

countries than to (approximately) 120 developing countries (seeCarter et al. (2005) and Goodhue et al. (2005), for a discussion ofcritical use exemptions). Fig. 2 shows critical and pre-shipmentuses of methyl bromide for selected countries. In 2007, methyl bro-mide for QPS uses was 36% of total US methyl bromide consump-tion of 8078 MT, which itself is 32% of the 1991 consumption of25,529 MT. While prior to 2005, specific uses of methyl bromideare not broken out, they are likely to be roughly constant due tothe treatment’s unrestricted nature.7 As Fig. 2 indicates, methyl bro-mide use has declined significantly for critical uses in recent years,but not for QPS uses.

Despite the declines in non-quarantine use, pressure to reducemethyl bromide is ongoing. In 2008, The EU environmental protec-tion agency notified the World Trade Organization of its intent tode-certify the use of methyl bromide entirely (while continuingto allow methyl bromide-treated imports) in 2010 (WTO, 2008).8

7 Arguably, they could be largely if trade volumes have necessitated increasedtreatment.

8 As a draft policy, the timeline for decertification may be extended.

Presumably, US and Canadian lumber exports to the EU can continueto be pre-treated with methyl bromide outside the EU. However, thefate of horticultural imports (from any source) carrying hitchhikerpests is unclear. Typically, commodities found with insect pestswould receive a methyl bromide treatment at the destination portbefore being released, but decertification would preclude that optionand necessitates an alternative treatment or movement to outsidearea where such treatment is permitted. And, while methyl bromideis safe for consumers, food handlers may be harmed if they contact itbefore dissipation. The EPA currently sets tolerance limits on atmo-spheric methyl bromide9 but concerns persist regarding whetherthis tolerance level is adequate. California currently requires largerbuffer zones and more frequent air monitoring than federal stan-dards. Proposed measures to address the dissipation problem wouldgenerally slow the supply chains and make fumigation a less attrac-tive treatment option (EPA, 2006).

9 Specifically, one part per million time weighted average of methyl bromide overan eight-hour period.

0

1

2

3

4

5

6

2003 2004 2005 2006 2007 2008

USA (QPS)

USA (Critical)

China (QPS)

EU (QPS)

EU (Critical)

Aus./N. Zealand (QPS)

Aus./N. Zealand (Critical)

Japan/Korea (Critical)

Japan/Korea (QPS)

All Others(QPS)

Fig. 2. Methyl bromide consumption, critical + QPS uses (1000 metric tonnes). Source: United Nations Environment Programme, Ozone Secretariat.

552 P. Ferrier / Food Policy 35 (2010) 548–555

Comparative cost structures for irradiation and methyl bromidefumigation

Despite environmental and safety concerns, methyl bromide isrelatively inexpensive (compared to irradiation) and easily imple-mented. Fumigators simply cover a truck or cargo container on aflat surface, such as asphalt, with an airtight tarpaulin, pump inmethyl bromide gas to a certain atmospheric pressure for a speci-fied time, and then allow the gas to dissipate. Because of the flex-ibility of its application (pest exterminators in nearly every portcity can perform fumigations), fumigation remains the standardpest treatment for many goods with pests both regularly occurring(copitarsia on Peruvian asparagus, mites on Chilean grapes) andincidental (i.e. hitchhiker pests). Fumigated goods do not requirelabeling although fumigation disqualifies a good for the NationalOrganic Program.

In general, fumigation and irradiation differ dramatically intheir cost structure. Fumigation’s costs (the cost of the gas andthe time of the fumigator) are primarily variable with few scaleeconomies aside. Irradiation costs are primarily fixed with sub-stantial scale economies. Local opposition to the nearby use ofradioactive materials can be strong (Leone, 2005; Gupta; 2007).Morrison (1987) and Forsythe and Evangelou (1994) provide esti-mates characterizing the decreasing cost structure associated withscale economies to irradiation. Table 3 presents alternative esti-mates of the cost of various treatments per pound (in cents in2009 prices) and, where available, estimates of how it influencesquality. Generally, these average cost estimates suggest that irradi-ation may be three times more expensive than fumigation at largescale facilities, but still a minor part of total wholesale costs.

Production processes marked by scale economies, such as irra-diation, tend to form local monopsonies as size imparts a costadvantage to large processors that both eliminates redundant costsand deters new entrants.10 Market power, in turn, implies that theprices per service can be significantly larger than its average costs.One Vietnamese source (Fructidor.com, 2008) writes:

He said the irradiation service offered by [a seafood processingcompany] is too pricey at $1 per kilogram. . . . [With] only [one]firm in Vietnam to provide such a service, local dragon fruit pro-

10 Relative to fixed costs, marginal costs are very low for all types of irradiators,especially for cesium and cobalt irradiators that do not require additional electricityto generate radiation (Morrison, 1987).

ducers had no choice but to accept this monopolistic pricing . . . Togive comparison, fruit irradiation costs only 24 cents per kilogramin Thailand.

Typically, movement and reshipment of untreated goods iscost-prohibitive.

Both irradiation and methyl bromide fumigation (and ethyleneoxide fumigation with spices) have alternative applications, oftenmedical, aside from quarantine treatment. Price discriminationmay ensue if contract treatment providers charge differentamounts based on the willingness to pay for treatment of differentcommodities. The good’s mobility (spices and meats in non-quar-antine food safety applications), the alternative treatment’s avail-ability (mangoes from Hawaii can get hot water dips instead ofirradiation), and the strength of local demand may provide a com-petitive check on local irradiation pricing. Because quarantineapplications of irradiation are new, it is difficult to generalize aboutwhether vertical integration through a single large producer orcooperative formation might solve these potential market powerproblems.

Irradiator capacity is also constrained by throughput. Goodsrequiring greater doses require a longer exposure to radioactivematerial. If the irradiator is operating near capacity, these goodsmay entail a higher opportunity cost to the irradiator but as prac-tical matter, the low demand for irradiation services have notmade such constraints binding. If the flow of goods is continuousfrom a single seller, then pricing via a two-part tariff may over-come the inefficiencies inherent to marginal pricing. If producersare seasonal in their demand for irradiation services (bringingone or a few harvests a year), the practical outcome may be indis-tinguishable from per-unit pricing. Frenzen et al. (2000) notes thatmost meat irradiation is performed on a contract basis.

While the US has approximately 50 irradiation facilities, onlyone (in Hilo, HI) is certified by APHIS for quarantine purposesand that primarily exports to the mainland US. Forsythe andEvangelou (1994) note that the irradiation of goods at US facilities(after traveling under safeguarding) would reduce its costs, a rele-vant concern for developing countries considering its use for ex-port (Marcotte et al., 2006). Current regulations allow for suchfacilities,11 but these would need to be located close to port-of-entryto allow for monitoring by customs officials, a reason why a Hono-lulu irradiator has been proposed for a site near the airport (Leone,

1 Specifically, CFR 305.31.b in the code of federal regulations.

1

Table 3Cents per pound cost of post-harvest treatments of fresh commodities (2009 prices).

Commodity Irradiation(large scale)

Irradiation(small scale)

Meth.brom.

Meth. brom.qual. discount

Coldtreatment

Modifiedatmosphere

Forsythe and Evangelou (1994) Grapes 2.42 – 0.93Nectarines/peaches 2.42 5.2 0.93Okra 5.95 5.95 0.93Plums 2.6 5.95 0.93

Calvin et al. (2008) US apples 3 5Federal Register (2003) Sweet potatoes 17.21 8 to 46Aegerter and Folwell (2000) Apple 3.71 1.96 1.49 1.96

Sweet cherry 1.96 0.55Nectarine, peach and Plum 1.96 0.24

P. Ferrier / Food Policy 35 (2010) 548–555 553

2005; Gupta, 2007). Competition for irradiation services mightintensify if exporters could select between different ports of entryfor services. Most irradiation occurs abroad, but this is likely to causeirradiation to be more expensive due to its smaller scale and the ten-dency toward monopolization.

Market penetration of irradiated foods

The introduction and growth of irradiated food has beenmarked with many false starts. Following initial regulatory liberal-ization, many observers expected markets for irradiated food to be-come a common food safety treatment and much researchaddressed its consumer benefits, costs, and regulatory obstaclesfrom this perspective. Yet, the actual market for irradiated foodsremains small, especially with raw meats where its food safetyapplications are most obvious. From 1983 to 2000, irradiationhad been limited to specialized applications including the fumiga-tion of spices and dried vegetable seasonings. In February 2000,irradiation of raw meat and meat products was permitted for con-trol of pathogenic microorganisms, a turning point for the industry.However, the ongoing consumer suspicion of the health effects ofirradiation made wholesalers unwilling to pay the markups neces-sary to cover irradiation’s additional costs. In 2004, Surebeam, aleading supplier of commercial irradiation services and irradiatedground beef, declared bankruptcy (Franklin, 2004), an event thatcommonly acknowledged to have severely impeded the adoptionof irradiation. Surebeam assets, including its food processing facil-ities operations in Iowa, would be acquired by Sadex in 2005 butthe anticipated growth in irradiated meat failed to materialize insubsequent years (www.foodprocessing-technology.com, 2009).Meanwhile, regulatory approval of irradiation for food safety useshas grown, if not being implemented in practice, for items includ-ing shellfish and eggs. In 2006, irradiation was approved as a ‘‘gen-eric” quarantine treatment.

Frenzen et al. (2000) show that consumer acceptance of irradi-ated foods was declining in the late 1990’s. Fox et al. (2002) showthat attitudes towards irradiated food are very volatile and sensi-tive to negative information, even if that information is presentedin a non-scientific manner. While avoidance of liability claims forfood safety may lead sellers to market lower-risk irradiated prod-ucts, Buzby et al. (2001) finds that awards won by plaintiffs in tri-als tends to be small. Stearns (2006) counters that out-of-courtsettlements, which are common but typically unreported publicly,are likely to be more substantial.12 If consumers remain unwillingto pay premiums for irradiated products out of self-protectionregarding food safety, then firms may be willing to cover the costs

12 Stearns argues that hospitals and nursing homes serving highly susceptiblepopulations are typically subject to a negligence standard rather than a defectiveproduct standard. In this case, liability typically resides with the manufacturer notintermediate processors of the goods. Because of this different standard, hospitals andnursing homes have been far quicker to serve irradiated food.

of irradiation for liability protection or reputation reasons, as dis-cussed in Frenzen et al. (2000).

Labeling, however, may play a large role. Currently, irradiatedfoods using spices as ingredients are not required to bear theradura logo and these foods seem to be purchased without stig-ma. According to the American Spice Trade Association (ASTA,2009):

‘‘Most spices originate in developing countries where sanitationand food handling practices are not at the levels expected in theUS. Consequently, it is well recognized that raw spices may containpathogens, including Salmonella and E. coli.”

Spices may be fumigated with ethylene oxide (a flammablegas), cold treated, or irradiated. Approximately, 40–85% of spicesare treated with ethylene oxide (ASTA, 2009) and Table 4 indicatesthat a large portion of the remainder are irradiated. Ethylene oxidefumigation requires lengthy aeration and can leave carcinogenicresidues while irradiation can be quickly performed. Typically,contractors (such as Sterigenics International, Inc. and SterisIsomedix Services) perform both ethylene oxide fumigation andirradiation sterilization services for spice importers (Sterigenics,2009a,b). Irradiated spice does not require end-use labeling if itis processed or is used as an ingredient in other food, but is re-quired if the product is sold off the shelf.

Irradiated fruits and vegetables must bear the radura logo.13

Irradiated fruits and vegetables began arriving from Hawaii to themainland US in about 2003 but do not constitute a large marketshare. In addition to the irradiator in Hilo on the big island, anotherirradiator was planned in Honolulu on the island of Oahu butencountered fierce local political opposition (Leone, 2005; Gupta,2007).

Regulatory approval for irradiated fresh fruits and vegetablesimports only arrived in 2006. Tables 1 and 2 lists the goods thatare approved or undergoing approval for irradiation. Table 4 usesAPHIS inspection data to show the changes in trade patterns thathave emerged where the irradiation treatment has been recentlyapproved.14 With dragon fruit (pitahaya), rambutan, and mango-steen from Thailand and mango from India, frozen and fresh exportsto the US were trivial prior to the irradiation. Subsequently, fresh ex-ports became significant but only became a large share for fresh im-ports in the case of Thai rambutan, which itself trades in smallquantities. Mexican guava and Thai longan seem to have switchedfrom frozen to fresh exports with the availability of the new treat-ment. Mexican mango, for which irradiation was just adopted, hasseveral alternative heat treatments, which already allow fresh prod-uct to be imported. Where alternative treatments are available,

13 Processed fruits and vegetables may not require labeling if they only represent asmall ingredient in a processed food item. However, most uses of fruits andvegetables in these recipes would use processed or frozen and are unlikely to requirean additional pest treatment.

14 Irradiated Hawaiian products are excluded from these totals.

Table 4Imports of selected fresh fruits and vegetables in metric tons (shaded when irradiation is permitted).

Source: APHIS PPQ 280 inspection data.

554 P. Ferrier / Food Policy 35 (2010) 548–555

determining the share of irradiated imports may be impossiblethrough the trade or inspection record alone.

The approximate market shares of irradiated food in the UnitedStates are small. About 80–185 million lbs of spice are irradiated,representing about 8–17% of US spice consumption of the approx-imately 1 million lbs of spice consumed in the US. Only about20 million pounds of fresh fruits and vegetables and 20 millionpounds ground beef are irradiated, so that less than 0.3% of groundbeef and less than 0.1% of fresh fruits are irradiated. However, onlya subset of fruits and vegetables require a quarantine treatmentwhere fumigation is infeasible. For some goods such as Thai lon-gans (shown in Table 4), irradiated goods represent a large shareof total imports as domestic supply is small.15 Fumigation is typi-cally a more flexible and lower cost treatment option, but this costdisparity may shrink if irradiation’s large fixed costs could be spreadover more treated goods. As pest risk assessments further liberalizeirradiation and if larger-scale irradiation hubs can be utilized nearcapacity, the cost of treatment is likely to fall.

Specialty fresh fruits and vegetables sell at strikingly highprices. Dragon fruit from Vietnam sells from between $2 and $11per kilogram in US markets, longans from Hawaii sell for $7–$10per kilogram and mangoes from Hawaii for $9 per kilogram(Fructidor.com, 2008; Vietnam Business Finance News, 2009),and mangoes from India for $4–$5 each or 2–4 times the price ofother mango imports at the wholesale level (Chorpa, 2008). Ferrier(2009, 2008) argues that goods are more likely to be traded ille-gally when imported goods do not have domestic sources, few sub-stitutes and highly inelastic demand. Imports of certain specialtygoods and ethnic foods tend to have these characteristics and are

15 Evans and Nalampang (2008) states that less than 5 million pounds of longan areproduced domestically while 1092 million pounds are produced in Thailand, much ofit exported.

often found illegally traded in markets. Immigrant consumersmay overcome the general aversion to irradiated specialty goodswhere acculturation and ethnic identity create a very price-insen-sitive demand.

Conclusion

As a quarantine treatment, irradiation has liberalized trade forspecific goods in the growing market segment of fresh fruits andvegetables. Because the unavailability of treatment options se-verely restricts available supplies, irradiation provides trade accessfor specialty goods for which prices can be remarkably high. Whilehigh costs of irradiation likely constrain the market, they may fall ifits scale and scope is increased and irradiation facilities becomecommon at destination ports. On the other hand, fresh tropicalgoods often must be shipped quickly over long distances, some-times via airfreight. While irradiation mitigates the vexing envi-ronmental problem of invasive species and ozone depletion (asan alternative to methyl bromide), it also encourages carbon emis-sions associated with the burning of fossil fuels when shipmentsare made over a long-distance. Finally, irradiation as a quarantinetreatment may de-stigmatize irradiation as a food safety treatmentwhere the applications may be larger and more significant forconsumers.

References

Aegerter, A.F., Folwell, R.J., 2000. Economic aspects of alternatives to methylbromide in the post harvest and quarantine treatment of selected fresh fruits.Crop Protection 19, 161–168.

American Spice Trade Association, 2009. Ethylene Oxide White Paper (May). <http://www.astaspice.org/files/public/ETO_White_Paper_Updated_May_2009.pdf>.(03.08.09.).

P. Ferrier / Food Policy 35 (2010) 548–555 555

Anania, G., Nistico, R., 2004. Public regulation as a substitute for trust in quality foodmarkets: what if the trust substitute cannot be fully trusted? Journal ofInstitutional and Theoretical Economics 160 (4), 681–701.

Australian Quarantine and Inspection Service, 2009. Safety of Irradiated PetFoods (July). <http://www.daff.gov.au/aqis/import/general-info/ian/09/7-2009>.(06.08.09.).

Burke, K., 2009. Cat-food Irradiation Banned as Pet Theory Proved. The SydneyMorning Herald (30th May).

Buzby, J.C., Frenzen, P.D., Rasco, B., 2001. Institutional arrangements and incentivestructures for food safety and quality assurance in the food chain. In: Hooker, N.,Murano, E. (Eds.), Interdisciplinary Food Safety Research. CRC Press LLC, NewYork.

Calvin, L., Krissoff, B., 1998. Technical barriers to trade: a case study ofphytosanitary barriers and us – Japanese apple trade. Journal of Agriculturaland Resource Economics 23, 351–366.

Calvin, L., Krissoff, B., Foster, W., 2008. Measuring the costs and trade effect ofphytosanitary protocols: a US–Japanese apple example. Review of AgriculturalEconomics 30 (1), 120–135.

Carter, C.A., Chalfant, J.A., Goodhue, R.E., Han, F.M., DeSantis, M., 2005. The methylbromide ban: economic impacts on the California strawberry industry. Reviewof Agricultural Economics 27 (2), 181–197.

Center for Food Safety, 2007. Your Right to Know: FDA Poised to Weaken Labelingon Food Irradiation. Food Safety Fact Sheet, Center for Food Safety (May).

Chorpa, P., 2008. Indian Mango Drive Launched in US, but Price a Hindrance ThaindianNews. <http://www.thaindian.com/newsportal/business/indian-mango-drive-launched-in-us-but-price-a-hindrance_10057452.html>. (07.06.08.).

Environmental Protection Agency, 2006. Report of Food Quality Protection ActTolerance Reassessment and Risk Management Decision for Methyl Bromide,and Reregistration Eligibility Decision for Methyl Bromide’s Commodity Uses.EPA Report – EPA 738-R-06-026.

Environmental Protection Agency, 2009. The Phaseout of Methyl Bromide. <http://www.epa.gov/Ozone/mbr>. (01.08.09.).

Evans, E.A., Nalampang, S.,2008. Importation ofTropicalFruits from Thailand.Universityof Florida, Cooperative Extension Service, IFAS Extension Report #FE719.

Fan, X., Sokorai, K.J., 2008. Retention of quality and nutritional value of thirteenfresh-cut vegetables treated with low dose radiation. Journal of Food Science 73(7), S367–S372.

Food and Drug Administration (FDA), 2007. Department of Health and HumanServices, Irradiation in the Production, Processing and Handling of Food, 72 FR16291-16306.

Food and Drug Administration (FDA), 2008. Department of Health and HumanServices, Irradiation in the Production, Processing and Handling of Food, 21CFRPART 179 49593-603.

Ferrier, P., 2008. Illicit agricultural trade. Agricultural and Resource EconomicsReview 37 (2), 273–287.

Ferrier, P., 2009. The Economics of Agricultural and Wildlife Smuggling. EconomicsResearch Service, Economics Research Report (81).

Follett, P.A., Griffin, R.L., 2006. Irradiation as a phytosanitary treatment for freshhorticultural commodities: research and regulations. In: Sommers, C.H., Fan, X.(Eds.), Food Irradiation Research and Technology. Blackwell Publishing, NewYork, NY.

Follett, P.A., 2009. Generic quarantine treatments: the next steps. Journal ofEconomic Entomology 102 (4), 1399–1406.

Food Quality News, 2003. US Push for Irradiation Labeling Policy. <www.foodqualitynews.com>. (19.09.03.).

www.foodprocessing-technology.com, 2009. Sadex Radiation Processing Centre Iowa,USA. <http://www.foodprocessing-technology.com/projects/sure>. (07.08.09.).

Forsythe, K., Evangelou, P., 1994. Costs and Benefits of Irradiation versus MethylBromide Fumigation for Disinfestation of US Fruit and Vegetable Imports. USDepartment of Agriculture, Economic Research Service, Agriculture and TradeAnalysis Division, Washington, DC (March).

Fox, J.A., Hayes, D.J., Shogren, J.F., 2002. Consumer preferences for irradiation: howfavorable and unfavorable descriptions affect preferences for irradiated pork inexperimental auctions. Journal of Risk and Uncertainty 24 (1), 75–95.

Franklin, P., 2004. Food Irradiation Future Dims as Surebeam Folds; BankruptcySeen Slowing Use of Technology, Nation’s Restaurant News (9th February).

Frenzen, P., Majchrowicz, A., Buzby, B., Imhoff, B., 2000. The Foodnet WorkingGroup, Consumer Acceptance of Irradiated Meat and Poultry Products.

Agricultural Information Bulletin No. 757, U.S.D.A. Economic Research Service,Washington, DC.

www.Fructidor.com, 2008. Irradiation Costly for Dragon Fruit Exporters (23rdNovember). <http://www.fructidor.com/news/irradiation-costly-for-dragon-fruit-exporters-4763.aspx>. (01.08.09.).

Goodhue, R.E., Fennimore, S.A., Ajwa, H.A., 2005. The economic importance ofmethyl bromide: does the California strawberry industry qualify for a criticaluse exemption from the methyl bromide ban? Review of AgriculturalEconomics 27 (2), 198–211.

Grocery Manufacturer’s Association, 2009. Food Irradiation, Science Policy Paper.Gupta, S., 2007. Zapped, Honolulu Weekly (7th February). <http://honoluluweekly.

com/cover/2007/02/zapped-will-an-irradiator-save-the-agricultural-industry-or-threaten-us-all/>. (01.08.09.).

Heller, L., 2007. FDA Proposes to Relax Labeling for Irradiated Foods, Food QualityNews (5th April).

Laffont, J.J., Tirole, J., 1991. A Theory of Incentives in Procurement and Regulation.The MIT Press, Cambridge, MA.

Leone, D., 2005. Isle Firm Plans New Facility for Irradiation. Honolulu Star Bulletin (7thJuly). <http://archives.starbulletin.com/2005/07/27/news/story3.html>. (01.08.09.).

Livingston, M.J., 2007. The Mediterranean fruit fly and the United States: is theprobit 9 level of quarantine security efficient? Canadian Journal of AgriculturalEconomics 55, 515–526.

Marcotte, M., Al-Hassan, R., Humado, K., 2006. Ghana and West Africa – feasibilityof irradiation as a quarantine method for export development. In: Proceedingsof 2006 Annual International Research Conference on Methyl BromideAlternatives and Emissions Reductions, November 6–9, Orlando, FL.

Morrison, R.M., 1987. An Economic Analysis of Electron Accelerators and Cobalt-60for Irradiating Food. USDA Economic Research Service, Technical Bulletin#1762.

Niemira, B.A., Fan, X., 2006. Low-dose irradiation of fresh and fresh-cut produce.safety, sensory, and shelf-life. In: Sommers, C.H., Fan, X. (Eds.), Food IrradiationResearch and Technology. Blackwell Publishing, New York, NY.

Pauli, G.H., 2006. Regulation of irradiated foods and packaging. In: Sommers, C.H.,Fan, X. (Eds.), Food Irradiation Research and Technology. Blackwell Publishing,New York, NY.

Petersen, E., Orden, R., 2006. Linking Risk and Economic Assessments in the Analysisof Plant Pest Regulations: The Case of US Imports of Mexican Avocados ERSContractor and Cooperator Report No. (CCR-25)61, Economic Research Service,USDA. <http://www.ers.usda.gov/publications/ccr25/>.

Raul, F., Gossé, F., Delincé, H., Hartwig, A., Marchioni, E., Miesch, M., Werner, D.,Burnouf, D., 2002. Food-borne radiolytic compounds (2-alkylcyclobutanones)may promote experimental colon carcinogenesis. Nutrition and Cancer 44 (22),188–191.

Roth, A., 2007. Repugnance as a constraint on markets. Journal of EconomicPerspectives 21 (3), 37–58.

Stearns, D.W., 2006. A future uncertain: food irradiation from a legal perspective. In:Sommers, C.H., Fan, X. (Eds.), Food Irradiation Research and Technology.Blackwell Publishing, New York, NY.

Sterigenics, Inc., 2009a. Food Irradiation: Questions and Answers. <http://www.sterigenics.com/services/food_safety/food_irradiation__questions_answers.pdf>. (03.08.09.).

Sterigenics, Inc., 2009b. Personal Communication with Steve Markus, Director ofCommercial Products.

USDA Animal and Plant Health Inspection Service, 2009. Current In-progress PPQRisk Analyses. (June 30).

US Federal Register, 2003. Irradiation of Sweet Potatoes from Hawaii. US FederalRegister, vol. 68, pp. 37931–37935.

Vietnam Business Finance News, 2009. Eleven Shipments of Dragon Fruit Flown tothe US (27th June). <http://www.vnbusinessnews.com/2009/06/eleven-shipments-of-dragon-fruit-flown.html>. (01.08.09.).

Wilson, N.L., Anton, J., 2006. Combining risk assessment and economics inmanaging a sanitary–phytosanitary risk. American Journal of AgriculturalEconomics 88, 194–202.

World Trade Organization, 2008. Committee on Technical Barriers to Trade,Notification G/TBT/N/EEC/196 (29th May). <http://ec.europa.eu/enterprise/tbt/tbt_repository/EEC196_EN_0000.doc>. (01.08.09.).

Zhang, J., Etter, L., 2008. FDA Will Allow Food Companies to Irradiate Spinach,Lettuce. The Wall Street Journal (22nd August).