Comment from Michael Bryant

Document ID: FSIS-2008-0028-0004
Document Type: Public Submission
Agency: Food Safety And Inspection Service
Received Date: September 12 2008, at 05:10 PM Eastern Daylight Time
Date Posted: September 15 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: September 8 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: October 18 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80702b85
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Irradiation as a Processing Aid

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While I do not have a problem with irradiation, in fact I think it is one more point of intervention in helping to control pathogenic bacteria, I do not see how it can be considered a "processing aid" when as I read the regulations, a processing aid is a substance that is "added" to the product but is not present in the finished product. I can see how an Organic Acid is a "substance" but not irradiation. How is irradiation "added"? How is irradiation considered a "substance"? If irradiation is to be used to aid in controlling bacteria, I think it needs to be called that. It seems to me that this is a way, by processors, to take the easy way out to not have to label food as being irradiated. Give the public some credit that with a "good" public relations campaign, prior to approval, explain what irradiation is relative to food, how it works and the safety factor it provides. Thank You, N. Michael Bryant