To: Food Safety Commission
From: Food Safety Citizens Watch & Consumers Union of Japan
March 24, 2011
Regarding Limits for Radioactive Substances in Food
On March 20, Japan’s Food Safety Commission received a request from the Ministry of Health, Labour and Welfare for opinions regarding regulation limits for radioactive materials in the Food Sanitation Law. A meeting to discuss the levels was held on March 23, 2011, and it was decided that decisions would be made within one week.
We regard this as a very important issue from the perspective of public health and we request that you take note of and carefully evaluate the following points:
1. It must be assumed that radioactive cesium and radioactive iodine are carcinogens.
2. The long-term effects on internal organs and the body must be considered.
3. We respectfully ask you to refer to the WHO guidelines for environmental disasters and health (2003) and the Codex Alimentarius report on common criteria concerning pollutants and toxins in food and feed.
4. Also, specifically regarding drinking water, please refer to the WHO guidelines for environmental disasters and health (2003).
5. Exposure to infants from mother’s milk should be considered.
6. The accumulation of radioactive substances from water pollution in the feeding chain should be considered.
7. Soil contamination should be considered.
8. The evaluation should continue even after the current emergency situation ends.
Furthermore, we are concerned that the Ministry of Health, Labour and Welfare should have consulted with the Food Safety Commission before setting provisional regulation levels for the radioactive substances (including cesium, iodine, uranium and plutonium) in food. These levels were temporarily set on March 17, 2011 (see link below) without prior consultation.
We request that you reflect on why no regulation limits have been set for radioactive substances until now.
Link: MHLW Press Release March 17, 2011: Handling of food contaminated by radioactivity (pdf)