Select Committee on Environment, Transport and Regional Affairs Minutes of Evidence


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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