Examination of witnesses (Questions 260
- 273)
TUESDAY 30 NOVEMBER 1999
PROFESSOR CHARLES
CURTIS, MRS
CATHY GRIFFITHS
and DR WYNNE
DAVIES
260. Do you think there will ever be such a
thing because it is always moving?
(Professor Curtis) Certainly it is fair to say that
the present policy which we are working to was developed in Cm
2919 by the last administration and that talked very much in terms
of discharges and doses as a basis for developing implementation.
Since the change in government the UK has signed up to other international
obligations which are not in line with the thinking in Cm 2919.
Obviously the government is in a changing position. Nevertheless,
RWMAC believes that it would be possible to develop such a set
of principles and we believe that in the interests of the general
public, who have a right to understand the basis of the regulation
which is for their protection. Just as the industry has an expectation
that it should understand the principles upon which regulation
is based, we believe that these improved principles can be developed
and we think they ought to be developed and that is what we have
been calling for.
Mrs Ellman: Is there only one body of scientific
knowledge and would judgment not be required in looking at the
precautionary principle?
Mrs Dunwoody
261. And are you always agreed on the evidence
that you give?
(Professor Curtis) I will allow my colleagues to say
a word in a moment. They are obviously keen to do so. It is never
easy. We have a range of people on RWMAC who come from different
backgrounds, i.e. we have social scientists, we have independent
consultants, we have academics, we have industrial people. As
I was saying before, we generate considered judgments and those
take a great deal of debate. We think we explore the issues rather
widely. It is not an easy matter. We spend a lot of time developing
our advice. We go through many drafts sometimes.
262. How do you give advice if you do not know
the scientific parameters within which you are working?
(Professor Curtis) I think we do know.[7]
263. Just take the last three years of government.
You are saying there has been a change in their position and you
have asked for the scientific basis and the scientific parameters
to be delineated in a way that you can use. So far you have not
had that and, indeed, for five or six years before that you did
not get it from the previous government. How is it that you continue
to operate on a sound basis and give advice if you are not at
all clear what the terms of reference are that you are really
working to?
(Professor Curtis) Can I try and separate what I think
are two elements? First of all, let us take the matter of discharges.
You can measure discharges in different ways. You can measure
the amount of radioactivity which people will receive as a radiation
dose or the actual discharge in terms of activity.
264. So you can have a dual approach on that,
i.e. you could have one half doing one thing and one half doing
another?
(Professor Curtis) No. For any particular discharge
you can measure and everybody can agree on the measurements of
radioactive discharge in terms of activity or dose.
265. I am asking a bigger question. I am not
asking about the detail of specific investigations in specific
areas that you are asked to undertake, I am asking you something
different. If you do not have the scientific principles on which
you believe the government to be operating, if you have asked
for a number of years for that information and you have not got
it and you now think that whatever the woolly information was
in the first place that has now changed totally, how do you give
sound scientific advice? I am not asking about unsound scientific
advice which I am sure is widely available.
(Professor Curtis) There are different ways of looking
at particular issues. How one goes on from those issues to develop
policy is a matter for government. We can provide what we think
is the best analysis of the information which is available to
us. We have a very reasonable scientific understanding of a lot
of these issues.
(Dr Davies) I think the answer lies in the fact that
the science behind radiation protection has not changed very much
in recent years. The advice that is formulated in Cm 2919 is the
result of advice from the National Radiological Protection Board
coming out of previous issues from the International Commission
on Radiological Protection. So the radiation protection issues
are well understood and, as Charles is saying, the issue then
is how you take that into the political dimension. So we can take
judgments based on the scientific aspects of the radiation protection
side and then ask whether we want to measure in terms of activity
or in terms of dose. We know the consequences of dose from the
scientific point of view.
266. Would you therefore be expected to do a
precis of the implications of both methods and both results?
(Dr Davies) The situation is more complicated than
that because of the relationship between how you get from activity
to dose because it varies depending on what you are testing.
267. Are you always agreed, particularly as
you go across all the disciplines, on the evidence that you give
or is it a common denominator across the whole of the Committee?
(Professor Curtis) It becomes a consensus across the
Committee.
268. Thank you. That is what I wanted to get
to. These are not pejorative questions, Professor. Those of us
who are non-scientists are just interested in how it works
(Professor Curtis) I think we feel there is a good
measure of agreement. I think you will find very little disagreement
on that kind of issue on the science side, both on the radio chemistry
and the medical consequences. There is a fair amount of agreement
amongst those who are concerned about how the radionuclides in
a discharge will find their way to you. So that is another area
of science about which there is somewhat greater uncertainty but
still a lot of sound understanding. If you move to another area
of the advice that we are asked to give. One of our work programme
elements last year was to advise the Secretary of State on the
attainment of scientific consensus, which was a much more difficult
area. In the science area there is little disagreement. The scientists
are concerned to state the quality of their information, the precision
and the reliability of information, but there is not a great deal
of disagreement. There is a great deal more disagreement in terms
of how best to carry forward and achieve the goals which we share
with the Environment Agency, which is protection of people and
the environment.
Mrs Ellman
269. How should any inconsistency in regulatory
practice across the regions be addressed?
(Professor Curtis) May I defer straightaway to Dr
Davies.
(Dr Davies) The "how" is the question you
are asking, accepting that there is some inconsistency across
the regions. I think it comes back to the point that we were making
earlier which is that until you have the principles well defined
you cannot have the guidance documents which actually will help
the inspectors at the ground level. I think the observations we
made in terms of small users earlier on suggested that there you
have inspectors with less experience and if you have less experience
you therefore need very much stronger guidance and so I think
the way forward has to be through the principles and the guidance
that are derived from them.
Christine Butler
270. Would it be fair to say that you think
it is the Government's fault that there is not a sufficient amount
of explanatory material about radioactive waste management rather
than the Agency's fault?
(Professor Curtis) I think there need to be principles
before the Agency can implement.
271. Are you saying yes?
(Professor Curtis) I am saying it is not the Government
necessarily, but the Department has to generate those principles
and those principles must be generated in the context of policy
formulation.
Mrs Dunwoody
272. Yes, you asked for principles, yes, the
Government have to give them, yes, you have requested them for
seven years and no, you have not got them, is that what you are
saying?
(Professor Curtis) Right.
Chairman
273. Whereas most other people have been saying
that they are unhappy with the Environment Agency, you are saying
to us that the Environment Agency is doing the best that it can
given that there is not clear direction from Ministers, are you
not?
(Professor Curtis) I think it would be fair to preface
immediate agreement with that just by saying that of course I
am sure you know better than we that this is one small area of
the Environment Agency's concern. I think what you said was correct
within this area.
Chairman: Thank you very much for your evidence.
7 Note by Witness: In giving this answer, I
am seeking to distinguish between understanding of radiation protection
science on the one hand and the lack of a clear statement of the
principles behind the regulatory process on the other. These two
issues are related but fundamentally different. Lack of the principles
statement does not impinge to any significant degree on the ability
of RWMAC to carry out other aspects of its advisory work. Back
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