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Nuking the Mail: Questions and
Answers about Mail Irradiation

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Nuking the Mail: Questions and
Answers about Mail Irradiation
by Noel Petrie and Mark Worth, Public Citizen, Washington D.C

The recent threat to the public from anthrax has resulted in unprecedented measures being taken by the U.S. Postal Service (USPS) to sterilize the mail. The USPS’ decision-making process has been marred by a lack of openness. Consequently, many basic questions about the decision to use large doses of electron beam radiation to treat mail remain unanswered.

So far, eight irradiation systems using this technology have been purchased from Sure-Beam, a subsidiary of the San Diego based defense contractor Titan Corporation. The cost for the eight systems is reported to be $40 million and the USPS has an option to purchase 12 more systems. Postmaster General John E. Potter, who testified on October 30, 2001 before the U.S. House of Representatives Government Reform Committee, said that the USPS would seek as much as $2.5 billion to sanitize the mail.

There are serious cost, safety, and logistical challenges presented by the extensive use of irradiation to kill anthrax in the mail. To date, the USPS has been unwilling or unable to answer questions posed to them about the selection of the electron beam technology, the initiation of worker safety programs, how they will address logistical issues including the separation of items likely to be damaged by irradiation, the bidding process for future purchases of
equipment or how they selected the Titan subsidiary, SureBeam.

Q: What is known about the effectiveness of irradiation in killing anthrax spores?

A: The USPS refers inquiries about the effectiveness and the amount of irradiation necessary to kill anthrax spores to Titan, the company that is providing the electron beam (e-beam) irradiation equipment. After repeated inquiries to Titan and their subsidiary SureBeam, on October 31, 2001 we were told to call their Nebraska office for assistance.

A staffperson in the Nebraska office said that their primary information on irradiation and anthrax came from a study done with a different irradiation technology, gamma rays. The study, “Inactivation of Bacillus Anthracis Vegetative Cells and Spores by Gamma Irradiation,” was published in 1996 in the Salisbury Medical Bulletin. The study’s authors concluded that a dose on the order of 41.5 kiloGray was necessary to kill two different strains of anthrax spores, including the Ames strain which has been identified in anthrax-contaminated mail. This study was also cited by the World Health Organization in its “Guidelines for the Surveillance and Control of Anthrax in Humans and Animals.”

In addition, Public Citizen has found an article in a Bulgarian veterinary medicine journal (at present only available in abstract form) which suggests that a 20 kiloGray dose of gamma rays is needed to kill anthrax spores in pelts and wool.
One thing is clear: it will take a large amount of radiation to kill the spores. To put this in perspective, the FDA approved levels for food irradiation are as follows: frozen hamburger patties are irradiated at 7 kiloGray, which is the equivalent of 233 million chest X-rays, eggs at 3 kiloGray, fruits and vegetables at 1 kilo-Gray. Spices are irradiated at 30 kiloGray, which is the equivalent of approximately 1 billion chest X-rays.

Q: What are the different kinds of irradiation technology?

A: Radiation is energy in the form of either high-speed particles (such as electrons) or electromagnetic waves. Low-energy electromagnetic waves are encountered every day in the form of light or radio waves.

Ionizing radiation, on the other hand, has a tremendous amount of energy. It has sufficient energy that in an interaction with atoms (the tiny particles that compose matter), it can remove tightly bound electrons from their orbits. This causes the atoms to become charged or ionized.

Ionizing radiation is very damaging to living cells and is the energy utilized by irradiation technologies. Irradiation technologies create ionizing radiation in three different ways: gamma rays (generated by a radioactive material like cobalt 60), X-rays (similar to gamma rays, but produced differently), or electron beams (in a linear accelerator, electrons reach nearly the speed of light and are carried on radio waves).

One of the key differences between the technologies is how far they can penetrate the exposed material. Gamma rays and X-rays can penetrate further than e-beam, which is estimated to be limited to about 1.5 inches. So the effectiveness of e-beam irradiation on denser items or large packages is uncertain.

X-ray equipment becomes more cost-effective if higher energy levels are used. However, at high doses and high voltage levels, X-rays can induce radioactivity in materials. Because we know so little about the amount of radiation that will be used, the potential for this to occur in the treatment of mail cannot be fully evaluated.

Q: Are there worker safety concerns?

A: Working with irradiation equipment is potentially hazardous to workers. There are two primary concerns: the creation of ozone and the need for proper shielding to prevent radiation exposure. Some forms of irradiation— including electron beams — result in the formation of ozone, a highly reactive form of oxygen that Occupational Safety and Health Administration regulations mandate must be vented when it reaches a certain level inside buildings. Ozone has been associated with numerous health problems, such as aggravating asthma, reducing lung capacity and causing various respiratory problems.

Additionally, elaborate shielding equipment must be installed inside irradiation facilities to protect workers from radiation exposure. This is an expensive proposition and could involve new construction, but it is critical to protect workers, especially in light of numerous injuries throughout the U.S. and fatalities abroad at irradiation facilities.

Workers will have to be trained to operate this equipment and have to wear a dosimeter, that measures the amount of radiation they are exposed to while on duty, just like workers in nuclear power plants and X-ray technicians.

Unfortunately, the USPS has provided insufficient information about the dose of radiation or how the devices will be installed to assure us that this critical issue is being given the attention it deserves.

Q: What are the logistical concerns about irradiating the mail?

A: Again, because of the lack of information from the USPS about what type of mail they will irradiate, this is extremely difficult to answer. In addition to the problems related to mail size and e-beam’s limited penetration, mail will need to be carefully sorted to address problems that will occur if some items — including food, pharmaceutical drugs, film, compact discs, and medical samples — are irradiated. Seed companies are already scrambling to make arrangements for their products, which would no longer be fertile if irradiated at a high dose.

The need to protect sensitive materials from the effects of irradiation could create a logistical nightmare and lead to serious loop-holes in the system. What kind of security does this plan offer if it is known that boxes labeled as containing certain materials won’t get irradiated? Surely a terrorist could exploit this loophole.

Q: What would happen to food items irradiated at the high doses that appear to be necessary to destroy the anthrax spore?

A: The extremely high doses of radiation required to kill anthrax spores could chemically alter food sent through the mail. Irradiation at doses higher than 10 kiloGray can affect meat’s odor and cause it to taste rancid.

Furthermore, among the main reasons the FDA has established maximum dose levels for the irradiation of food is to limit the formation of potentially hazardous chemicals, called “unique radiolytic products,” and to limit the corruption of the food’s flavor, texture and odor. Without measures to prevent food from being irradiated, foods that the FDA has not legalized for irradiation, including dairy products, seafood, and processed (“ready-to-eat”) foods, could be irradiated.

Food irradiation, even at legal doses, is very controversial because it destroys vitamins and creates new and untested chemicals in food. It also can create carcinogenic chemicals like benzene and formaldehyde, depending on the food and the dose of radiation. The difficulty
in gaining public acceptance for the technology has prompted the irradiation industry and their allies in the food industry to seek the removal of labeling from irradiated food.

Q: What process did the U.S. Postal Service use to select Titan’s electron beam irradiation equipment to sanitize mail?

A: The U.S. Postal Service media relations office — which is being staffed by Manning, Selvage & Lee, the eighth largest PR firm in the world — is unable or unwilling to answer questions about how the decision to use Titan’s equipment was made. Repeated calls from Public Citizen to the U.S. Postal Service have also gone unanswered.

Q: Who is Titan?

A: Titan, formed in 1981, is a San Diego-based defense contractor with profitable ties to the Pentagon. The company has 7,800 employees and annualized sales of approximately $1.1 billion. Even before the defense buildup associated with September 11, 2001, Titan expected to continue receiving government contracts.

An October 2001 press release about third quarter earnings reported that “approximately 80-85% [of next year’s expected revenue] will come from government customers,
with approximately $750 million to $800 million of that revenue derived from intelligence, surveillance and reconnaissance related activities.” Since September, Titan has won contracts with the military that total more than $700 million.

Although the process suffered from a lack of transparency, which limits what is known about the deal, it appears that Titan Corporation received the USPS contract because of their relationship with the Department of Defense. Additionally, there is no information on how the $40 million dollar price tag for the equipment was determined or if competitive bids were considered.

Q: Do irradiation facilities have accidents or quality control problems?

A: Irradiation facilities do have accidents. Facilities using radioactive isotopes have a particularly bad record, which includes facilities catching fire, equipment malfunctions, radioactive water being flushed into public sewer systems and radioactive waste being thrown into the garbage. Workers at electronic beam facilities have also been injured.

Of interest is the fact that Titan has had a problem with quality assurance in one of its
e-beam facilities. We do not know if the USPS knew about the problem at a Titan irradiation facility in Denver, Colorado when it awarded the contract to the company.

For an unedited version of this article, including footnotes and sources, go to <>.

Action Alert!
Contact Office of Homeland Security on Labeling of Irradiated Mail!

As you know, the United States Postal Service has begun the process of irradiating mail to kill anthrax and other biological agents. Director of Homeland Security Thomas Ridge has announced that before any treated mail is released for delivery to postal customers, it must be labeled by the United States Postal Service to indicate that it has been treated and the process used may have caused damage to the mail contents.

We need to make sure that this label is as explicit as possible and not permit euphemisms such as “sanitized,” “electronic pasteurization,” or “cold pasteurization” to sneak into the approved labeling.

Send a letter to Director Ridge on this issue immediately.
A sample is attached. You can either fax it to (202) 456-6337 or mail it to:

Thomas Ridge, Director
Office of Homeland Security
c/o The White House
1600 Pennsylvania Avenue, N.W.
Washington, DC 20502


Dear Director Ridge:
I am writing concerning the labeling of mail that has been treated to kill biological agents. I applaud your efforts to have the United States Postal Service label all mail that has gone through a process to sanitize it.

Since the Postal Service has been discussing a variety of means to treat the mail, I would strongly urge that an explicit explanation of the process used be included on that label. If the mail has been irradiated, then it should state: “treated with Irradiation.”

The label should also include the dosage level used, and the potential harm the process may have had on the contents of the mail. Generalizations such as “sanitize” or euphemisms such as “electronic pasteurization” or “cold pasteurization” should not be approved. The more information postal customers have of the process used to treat their mail, the better they will be able to judge whether they can still use the contents of the mail.

For example, if a postal customer receives a treated package of pharmaceuticals in the mail, he/she should be able to consult with a physician to determine whether those drugs are still suitable to be used; the label should serve as a guide to those with expertise.

I realize that we are entering a new area with the treatment of the mail. But I believe that the United States Postal Service needs to be explicit with its customers regarding the sanitizing processes it uses. I urge you to ensure that clear and unambiguous labeling is included on all treated mail.

       
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