Supplementary memorandum submitted by
Blackwater Against New Nuclear Group
HOUSE OF
COMMONS ENERGY
AND CLIMATE
CHANGE COMMITTEE,
MEETING OF
27 JANUARY 2010
Further to the presentation made by members
of the Blackwater Against New Nuclear Group, the following points
might be pertinent to the consideration of the issues raised in
the Annex of the Group's written presentation, on the issue of
health risks from the Bradwell nuclear power station.
CONTRIBUTOR
Professor R J Barry Jones is an emeritus professor
of the University of Reading, a resident of Tollesbury (overlooking
the site of the existing Bradwell nuclear reactor), and a contributor
to the submission by the Blackwater Against New Nuclear Group.
SUMMARY
The debate about the past health effects of
the Bradwell nuclear power station focuses on the public disagreements
between the Committee on Medical Aspects of Radiation in the Environment
(COMARE), on the one side, and Green Audit and the Low Level Radiation
Campaign (LLRC), on the other.
The controversy over Bradwell's nuclear health
impact is interesting in the light of some recent issues that
have arisen over global warming data and the claimed treatment
of unfavoured authors in the "peer" refereeing of articles
on stem cell research.
It remains important, therefore, to secure answers
to some of the persistent questions concerning the assumptions
and methodologies of those on both of the sides of the nuclear
health effects debate.
THE COMARE APPROACH
The position of COMARE has two (public) elements:
First, criticisms of the statistical "evidence" presented
by Green Audit (and to a lesser extent) the Small Area Health
Statistics Unit (SAHSU); and, second, the maintenance of an "orthodox"
position that rests upon mutually reinforcing statistical methodologies
and radiation risk criteria drawn from the experiences of victims
of past nuclear explosions.
Much of the argument used in press releases
from COMARE to dismiss concerns about cancer incidences in Bradwell's
locality rests upon statistical "errors" that were quite
trivial when compared with some of the statistical "anomalies"
that have been revealed in respect to the treatment of the historical
record of global temperatures by researchers at the University
of East Anglia's climate change centre. Some of the Green Audit
"errors" arose as a result of intermittent access to
official data. Moreover, many were corrected in subsequent Green
Audit reports.
A second COMARE line of attack concerned the
choice, by Green Audit, of groups of wards in Maldon and Burnham
for comparison of cancer rates. [see: COMARE press release of
2003 on "Cancer mortality around the Bradwell Nuclear Power
Station, Essex"]. It is impossible for the outsider to resolve
this issue directly. The criticism rests, in part, upon the claim
that Green Audit adopted "Texan sharpshooter targeting"
to identify communities at risk [on which, see: C Busby, Wolves
of Water, Green Audit, 2206, pp 323-5]. Green Audit's claim, however,
is that contamination of estuarine waters and muds by low level
radioactive material may be particularly harmful to residents
over the longer term. Thus, Maldon and Burnham were chosen to
test this proposition directly, given that Maldon abuts the Blackwater,
whereas the nearby Burnham, does not (as a cursory examination
of a relevant map would demonstrate).
A third COMARE line of attack concerned the
lack of peer referencing by reputable journals of Green Audit's
papers on nuclear health risks, particularly those associated
with Bradwell.[see: COMARE press release of 18 March 2003] This
line of attack, however, is seriously flawed in its (naïve?)
neglect of the exclusionary effects of a prevailing orthodoxy
upon prospective publications that adopt a thoroughly unorthodox
approach and that promote unorthodox conclusions. The recent controversy
about publication of stem cell research papers illustrates this
problem.
It is worth noting that the language and content
of COMARE's official reports on the effects of nuclear installations
and of nuclear radiation are noticeably more circumspect that
the language adopted in the periodic press releases, with conclusions
qualified by significant caveats and the highlighting of areas
of additional, necessary research.
THE GREEN
AUDIT APPROACH
Green Audit and the LLRC have also advanced
serious lines of criticism against the work of COMARE or, more
specifically, the "orthodox" research that is used to
support its overall judgements on the health risks of nuclear
installations.
The orthodox position on nuclear health risks
depends, according to critics, on the following integrated procedures:
(a) attempt to deny the existence of any cancer clusters near
nuclear installations; (b) where any cluster appears to exist,
subject it to two powerful caveats: (i) emphasise the multi-causality
of many cancers; (ii) reference the "risk" criteria
based upon the experience of victims of nuclear explosions and/or
major accidents and, hence, (iii) "demonstrate" that
such clusters as have been identified must, therefore, be a result
of one or more of the cancer causing factors other than exposure
to radioactive materials in, or in the vicinity of, nuclear installations.
[see, for example, the concluding paragraph of "Cancer mortality
around the Bradwell Nuclear Power Station, Essex", COMARE,
2003]
The resort to multi-causality in the dismissal
of radioactive materials as a cause of cancer clusters has, however,
been a serious intellectual and tactical mistake. If cancers,
and their clusters, do, indeed, have multiple causes (and, indeed,
complex interactions amongst these causes) then longer term exposure
to low level radioactive material could be one of these causes.
In some areas neighbouring nuclear installations, then, it is
possible that other cancer causes (population "mixing"
for example) might be lower than "normal", but "compensated
for" by the presence of nuclear "causes". Thus,
even if the overall level of cancers (and cancer deaths in particular)
appears to be normal in some areas bordering nuclear installations,
the damaging effects of radioactive material may still exist and
have been making up for the relatively low level of other cancer-causing
factors. The uneven distribution of genetic susceptibility to
damage by radioactive exposure merely compounds this complication.
Statistical measures that purport to dispel
claims of cancer causation in the vicinity of some nuclear installations
may thus fail to achieve their purpose, because the aggregate
statistics are disguising the effect. This serious possibility
is little considered in COMARE's successive reports on the health
risks of nuclear installations. However, the uncertainty generated
by multi-causality of many cancers reinforces the urgency for
the DNA sequencing of those cancers for which nuclear installations
have been thought to be responsible.
Central to the initial attempt to deny the existence
of cancer clusters around nuclear installations is, according
to Green Audit, the deployment of a technique of "Bayesian
smoothing", the effect of which would seem to be to blend
relatively small populations into their surrounding populations
and, hence, dissolve any apparent clusters of cancers in specific
wards (irrespective of other reasons to suspect that there might
be a radiological effect). [Busby, pp 325-7]
At the heart of the justification of such statistic
approaches (which go well beyond anything suggested, or undertaken,
by the University of East Anglia climate research group members)
is a prior supposition that exposure to low level radioactive
material cannot cause cancers, or other serious health effects,
in human beings because the levels of exposure are so much lower
than anything experienced in atomic explosions or other major
nuclear accidents, irrespective of the form of exposure to the
low level radioactive material, the length of that exposure, or
the developmental state of those experiencing that exposure.
A number of issues in the debate between the
orthodox and critical approaches to the health effects of nuclear
installations thus require resolution by a genuinely independent
and impartial authority. COMARE, unfortunately, has failed to
satisfy this continuing, and increasingly pressing, need for a
number of substantive and procedural reasons. The substantive
issues of prior assumptions and statistical procedures have been
reviewed, briefly, above. Procedural issues are also worthy of
attention, however.
COMARE has criticised Green Audit for its failure
to secure peer group refereeing for its proposed and actual publications,
This, however, is naïve with regard to the problems confronting
proponents of unorthodox views. The problem here, is that: (i)
the orthodox position is supported by contested statistical procedures
and (ii), that experimental proof of the cancer inducing effects
of longer-term exposure to, low level radioactive material upon
human beings, especially when embryos and/or during childhood,
would be difficult, if not impossible to obtain (for obvious ethical
reasons).
BALANCE AND
INDEPENDENCE
Caution over health issues is clearly warranted
(as the MMR debacle demonstrates). However, understandable caution
may be substantially reinforced by considerations. Reputations
are at stake when orthodox scientific positions are challenged
and it is all too common for challengers to be dubbed as mavericks
(Richard Lacey during the early days of the BSE crisis) or frozen
out. Dr Chris Busby reports his exclusion from the important forum,
the Oxford conference on childhood Leukaemia in September 2004
[Busby, pp 426-8]. Advocates of politically embarrassing positions
may, moreover, be expelled from official agencies, as shown in
the case of Professor Nutt dismissal from the Advisory Council
on the Misuse of Drugs.
A further, serious issue confronting the ultimate
independence of COMARE is that of research finance. The well-being
of university departments, and the professional progress of their
staff members, is increasingly dependent upon the receipt of research
funds from external sources. This may also be true of more research
orientated departments in major hospitals.
The major source of funding for those undertaking
research into nuclear health effects—whether physical or
statistical—has been the government—directly from
interested departments of state, or indirectly via official agencies
like the Medical Research Council or and Health Protection Agency.
Unfortunately, the government has also been the most heavily "interested"
party in the findings of research into nuclear health effects,
if only because of the very substantial litigation costs that
might arise from any substantiated claims of health damage from
past exposure to nuclear tests and/or the operation of a range
of nuclear installations. The financial interest in maintaining
the orthodoxy of the absence of adverse health effects from nuclear
installations has merely been reinforced by the recent revival
of interest in a new generation of nuclear generators. It is to
be doubted seriously, therefore, whether substantial research
funds are likely to have been secured for serious attempts to
establish a positive link between nuclear installations and health
damage and sensible researchers will have been well aware of this
tacit constraint. Dr. Busby and Green Audit have certainly found
it extremely difficult to secure even the most minimal level of
funding for their endeavours.
Such considerations bear seriously upon the
claimer disinterest of COMARE's membership. COMARE's 9th report,
of 2004, includes a statement of the criteria for declaration
of members' interests. These criteria focus exclusively upon links
with the "radiation industry" [p 37] and members' declarations
of interests are confined to such links. There is no mention,
whatsoever, of governmental funding flows, direct or indirect,
despite their clear salience. Such considerations do not disprove
the orthodox position on nuclear health risks, but they do raise
questions that require further review.
Such difficulties with the "embedded"
character of the nuclear health establishment make it all the
more important that the debate between the upholders of the orthodox
position and their critics is adjudicated, authoritatively, by
experts in statistics and research procedures that have no connection
with the nuclear industry, no need for continuing funding from
government, directly or indirectly, or an existing, strong position
on the necessity for new nuclear generating capacity.
The unresolved questions about the health effects
of nuclear installations remain urgent because of the proposed
programme of new nuclear reactors, many in areas where the past
operations of nuclear power stations have generated suspicions
of damage to the health of local populations. New nuclear reactors
will continue to release low level radioactive materials into
the environment and these materials will continue to wash into
estuaries, like the Blackwater, and deposit on their extensive
mud flats. Worse, high level nuclear waste will now be stored
on the sites of any new nuclear reactors, at least for the time
being, increasing substantially the risks of release of radioactive
material into the waters that they border.
February 2010
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