Irradiation in Organic Production

What forms of irradiation are prohibited in organic production?

Different kinds of radiation have a variety of functions and purposes. For example, governments may use gamma irradiation to perform non-invasive searches of containers crossing their countries’ borders. X-rays are another commonly used method of inspection. Microwaves used in food preparation emit microwave radiation. Are these methods considered “ionizing radiation,” and therefore prohibited under the USDA’s National Organic Program (NOP) regulations for organic food processing?

The USDA NOP regulation at §205.105 states: “To be labeled as ‘100 percent organic’, ‘organic’ or ‘made with organic (specified ingredients or food group(s)),’ the product must be produced and handled without the use of (f) Ionizing radiation, as described in Food and Drug Administration regulation, 21 CFR 179.26.”

The FDA regulation at §179.26 is titled “Ionizing radiation for the treatment of food.” It specifically lists several sources of radiation, and sets maximum levels/rates of use. It restricts use to the control specific pests and pathogens in food, for use to prevent maturation and growth of fresh foods, for microbial disinfection of enzymes preparations, for microbial disinfection of spices, for sterilization of meat used by NASA in the space program, and for control of pathogens in meat products.

Other sections in §179 cover uses of irradiation for food inspection (§179.21) and use of ultraviolet radiation for treatment of food (§179.39) or radiofrequency radiation, including microwaves (§179.30). The NOP regulations do not prohibit these uses.

Ionizing radiation sources permitted for inspection includes X-rays, as well as sealed units producing radiation at levels not more than 2.2 million electron volts from one of the following isotopes: americium -241, cesium-137, cobalt-60, iodine-125, krypton-86. This radiation is permitted by FDA at levels that are orders of magnitude less (grays compared to kilograys) than levels allowed for food treatment use. The complete text of the FDA regulation may be accessed at https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-179.

Since the NOP regulation at §205.105(f) prohibits ionizing radiation “as described in FDA regulation 21 CFR 179.26.” OMRI understands that the use of irradiation for food inspection is permitted, provided that it meets the FDA limitations described in §179.21. All use of irradiation as a preservation technique or to eliminate pests or pathogens as described in §179.26 is prohibited in the production and handling of organic products. 

This article originally appeared in the winter 2003 edition of the OMRI Materials Review newsletter. It was revised in February 2023 by Senior Bilingual Technical Coordinator Tina Jensen Augustine.