Ministry of Defence consultation on proposed introduction of voluntary screening programme
Response by the Low Level Radiation Campaign
11th March 2001
1 Scope of MoD proposals
The Consultation on voluntary screening can and must be seen as part of a broader exercise which may well have good intentions, despite the frequently voiced suspicion that government and military establishments are bent on concealing the truth.
Good intent is, possibly, visible in NATO's Committee of the Chiefs of Military Medical Services (COMEDS) who require  "the development of a coherent strategy, process and standardised procedures that will enable known and future health hazards to be identified and addressed". They "note that it is in the interests of the military personnel [including veterans] ... and local populations that health risks related to the operational environment be followed on by Medical Services from a multinational perspective in a transparent and in an independent manner." "The timely investigation of all reports of an increased incidence of symptoms or pathologies is necessary ... in an open, scientific peer-reviewed manner."
Thus the strategy sounds reasonable and open, but we have reservations.1) It is proposed that mortality and morbidity data should be collected and correlated with known health hazards in the theatre of operations. Limiting the analysis to "known health hazards" is questionable, and the NATO approach contains nothing to indicate any intention of testing the validity of assumptions about what is "known".The MoD Consultation Document does seem to open the possibility of testing the validity of assumptions about what is "known":
2) It appears that the study is to be done at the national level, rather than using the greater statistical power of combining the data sets.
3)There is no proposal to match mortality and morbidity data with actual levels of uranium contamination.
"the UK is ... considering what further research is specifically required into DU".
However, this is apparently to be part of the investigation co-ordinated by NATO, so the reservations listed above may apply. What is worse is that since the NATO programme is to be set up as early as May 2001 further doubt is cast on its capacity to test basic assumptions.
The MoD has repeatedly said that it will take account of the current Royal Society investigation. This brings us to
4) - a further reservation about the timing of the present proposals for "additional screening". The Royal Society WG is not expected to report until summer 2001, so moves by either MoD or NATO before that time would seem to be pre-emptive and might have the effect of weakening international co-operation.
The "additional screening" announced by John Spellar on 9th January 2001  is predicated on the need to reassure, as shown by Hansard and numerous extracts from the Consultation Document, for example:- "... quantification of exposure and comparison of exposure to other accepted occupational and day to day hazards may enable concerned individuals to view their exposure with less concern."
This approach indicates that the MoD is out of touch with lay attitudes. Announcements of programmes undertaken to educate and reassure the public are commonly met with the comment "We don't want to be reassured, we want to know the truth." The Consultation Document's many references to "educating concerned individuals" all proceed from the assumption that MoD knows the truth [MoD statements outside the Cons Doc are quite outspoken in this respect] The Consultation Document contains no explicit reference to finding out the truth of whether the veterans' symptoms are caused by DU exposure. MoD thus risks exacerbating the well established crisis of confidence in scientific advice to Government.
The EAG concludes  that ".... ill effects can not be ... excluded ... ". This is reasonable, but the subsequent statement that since there is "no proven mechanism linking DU exposure to increased mortality or specific health effects ... risks are likely to be ... insignificant ..." only serves to sharped suspicion about a cover-up. As we ,  , and others  have pointed out, the known propensity for thoracic lymph nodes to accumulate and retain insoluble Uranium Oxides , the disproportionately high doses to TLNs following inhalation  and the fact that they are a "critical organ for leukaemogenesis  must alert responsible investigators to the need to determine the Uranium burden of TLNs in exposed populations. The Consultation Document's strong emphasis on urine analysis is therefore worrying, since urine is a poor indicator of TLN burdens.
Ignorance of a mechanism of harm is not evidence that there is no harm. A mechanism has been identified  and has not been refuted; Cox and Edwards' reply to Busby  fails to address the issue of local doses from incorporated hot particles. This is clearly relevant to DU.
The essence of the problem is that ICRP, the source of radiation risk factors world wide, understands radiation "dose" in terms of energy transfer averaged over considerable volumes of tissue - for various predictive purposes the target is taken to be an entire organ, the whole body, or even the populations of whole countries. This is at odds with radiation biology, since genetic damage is effected by discrete tracks of individual charged particles impinging on individual cells. 
The failure of ICRP and its satellite organisations such as NRPB to understand the importance of local variations in energy transfer is amply illustrated by an Opinion recently published by the European Commission:-
The worst scenario envisaged in the preliminary assessment made in October 1999 by UNEP was inhalation (at the site and times of an explosion of a DU penetrator, of up to 100 mg inhaled DU. The committed effective dose would correspond to a maximum of about 10 mSv (using the current ICRP models, and assuming ICRP default Type S absorption), and the highest organ dose [committed effective dose] calculated to be to the lungs, at about 80 mSv (for adults). Compared to the dose to the lungs, doses to bone surface, kidneys and red bone marrow, would be 150, 400 and 1400 times lower, respectively, and the dose to the thoracic lymph nodes (treated by ICRP as a region of the lungs) about 10 times higher. 
This means that if the dose to red bone marrow is taken as 1 unit, doses to the organs listed are:
red bone marrow 1 kidneys 3.3 bone surface 8.3 whole body 175 lung 1400 thoracic lymph nodes 14000
In the EC analysis [admittedly a "worst case", but not an impossible one] the thoracic lymph node dose is taken to be 800mSv averaged over 50 years. This gives an average of 1.6 mSv - equivalent to a doubling of natural background.
In the case of a civilian returning to live in the vicinity of a vehicle hit by DU and disturbing DU dust the EC says:- A two-hours stay in the target area would lead to doses in the range 0.1-10 ÁSv. It does not seem very likely that an individual would reside permanently in close proximity to the target area, nor would wind or human activities perturbing the soil cause a constantly high dust load, but even in this assumption the annual dose would be of the order of 1 mSv only. 
It is not clear that individuals will not be residing pretty close to DU struck targets. Many returning civilians are.
The "mere" 1 mSv annual dose means that the victim's TLNs are getting 80mSv. Even if exposures were 40 times less than the worst case the TLN dose is equal to Natural Background.
In both the acute (soldiers) and the chronic (civilians) exposures peak values would be far higher than the committed effective dose average. Local doses will be higher still if we take account of the "non-uniform nature of particle deposition in individual lymph nodes and ... the lack of sufficient data to describe [tissue clearance] trends accurately" reported in one study which is widely though selectively cited in the current debate over DU .
This leads us to the Consultation Document's Question 1:-To what extent should MOD reply on current ICRP recommendations and advice?The answer is:-
To the extent that ICRP underestimates inhomogeneities they are not to be relied on at all.One is entitled to ask, for example, what is ICRP's justification for treating thoracic lymph nodes as a region of the lungs.
[Incidentally we congratulate the Article 31 Group for passing that buck to ICRP, though it must be said that the same Group of Experts advises the entire European Union to depend on ICRP's advice; certain amount of double standards there!]
Structurally and functionally the thoracic lymph nodes are entirely distinct from lungs - the only relevance of their geographical proximity to the lungs is that they are in the front line for deposition of inhaled particles.
Busby and Scott Cato  have tested ICRP's risk factors for leukaemia induction at low doses. After the Chernobyl reactor accident in April 1986, rainfall precipitation caused measurable radioactive contamination of Wales and Scotland. Using risk models developed by themselves and by the International Commission on Radiological Protection, the UK National Radiological Protection Board advised that no measurable increase in leukaemia was predicted at exposures which they estimated from measurements of contamination. However, cancer registry data from both the Wales and Scotland registries show a sharp increase in cases of infant leukaemia age 0-1 in the eighteen month period January 1st 1987 to June 30th 1988. This period is that in which the birth cohort who were in utero in the exposure period following the fallout would be in the age group 0-1. Compared with an "unexposed group" consisting of the period 1975 to 1986 the Wales exposed group had a relative risk (RR) of 4.4 (p=0.004), the Scotland group a RR of 3.7 (p=0.001) and the combined Wales and Scotland group a RR of 3.87 (p=0.0001). A second unexposed group, those aged 0-1 in 1989-91 had no significant increased risk although after 1991 rates increased slightly. This finding supports earlier reports of infant leukaemia effects in Greece, Germany and the U.S. following Chernobyl. The data cannot entirely distinguish between pre-conception or in utero effects but also reported here are increases in very low birthweight births in Wales following Chernobyl, suggesting a genetic component to both effects. The existence of good quality leukaemia and exposure data makes it possible to calculate an error in the presently accepted risk factors for radiation induced leukaemia of about 100-fold or more. The possibility of errors of this magnitude in the contemporary risk estimates of ionising radiation effects has many implications which include suggesting that a thorough investigation of the health effects of DU is needed.
Other Sources of advice
It is not our intention to conduct yet another literature review. However, it's worth mentioning Professor McDiarmid's review of reviews , on which the MoD Cons Doc replies heavily. Her editorial elicited the following reply :-Curiously, McDiarmid does not mention a special and very prominent review of Department of Energy occupational epidemiological studies undertaken at the request of the President in July 1999. ( National Economic Council, Interagency Working Group No. 1, January, 2000). ... It is remarkable that this White House review was not mentioned by McDiarmid since it received widespread attention as it prompted the Department of Energy to officially concede on January 29, 2000 that its nuclear weapons workers were placed at risk of increased disease and death. This Presidential review also served as an underpinning for the recent creation of a major worker compensation entitlement program by the U.S. Congress ....There is a plethora of information on Uranium, and if Alvarez is right it does not all support the "no problem" point of view.
Just as remarkable as Professor McDiarmid's failure to cite the White House review is the fact that the MoD also fails to mention it. Robert Alvarez's letter to the electronic BMJ is dated 29th January 2001 - early enough to have been incorporated into a document dated 12th February. MoD incorporates a letter from Richard Mould from eBMJ dated only a few days earlier, and it is hard to avoid the conclusion that Mould's contribution is included because he does not challenge opinions convenient to the nuclear establishment, and that the Alvarez letter is excluded because it clearly is a challenge. In view of Alvarez's position as a Senior Policy Advisor to the U.S. Secretary of Energy between 1993-1999 his opinion is surely worth being included and openly considered. Editing of this kind serves only to increase suspicions of bias.
The Expert Advisory Group identifies  inhalation of aerosolised insoluble oxides as ... the main hazard from DU ... We agree. However, EAG's conclusions about its extent -
... only personnel in the vicinity of the target at the time of the strike would be exposed
and effects -
... health risks are associated with ... intakes of DU are well understood ...
We are aware of no human studies of the effects of insoluble DU (or U) in lymph nodes (see Note  ) The paper cited by MoD  to show no evidence of ill health effects related to DU exposure in US veterans is a study of people who have shrapnel embedded in them. This is very different from the type of exposure involved in inhaling microscopic ceramic Uranium particles. Their persistence and environmental mobility expose large numbers of non-combatants (including the unborn) to inhalation hazard.
Having used Depleted uranium, the NATO governments have a responsibility to use information on their service personnel as a means of informing the international community about its effects, with special reference to the civilian populations in areas affected by the fighting. Most NATO nations have good quality data on the health of their own nationals and have therefore the opportunity to make comparisons between those who been exposed and controls who have not, especially if studies of veterans are also controlled for service in conflicts where DU was not used. On the other hand, epidemiology in war zones is very difficult. This allows the authorities to deny the significance of reports that in war zones where DU was used cancer, leukaemia and congenital defects are far higher. The case of the Balkans is exacerbated by the fact that the civilian population is divided against itself, which has consequences for the reliability and availability of essential data, as Robert Fisk of the Independent has reported. If truth and public confidence are to be served there must be some observably genuine attempt to investigate these health phenomena, and the military has a vital role.
Reliable data on DU contamination must be obtained without delay, correlated with diagnoses in, and symptoms reported by, members of exposed or potentially exposed populations.
In its present state equipment available for whole body monitoring to detect Uranium in or near the lungs is of little use to distinguish TLN burdens .
New equipment employing a large number of detectors to register the gamma lines from the decay products of Uranium must be developed in consultation with NRPB AEATechnology and others. This should be backed up with urine analysis. The results of such monitoring should be matched with clinical diagnoses and reported symptoms. MoD should initiate a programme to obtain consent for the collection of post mortem tissues of deceased veterans and ensure their radiological analysis. Results of analysis should be matched with cause of death, clinical diagnoses and reported symptoms.
Nothing in this response should be construed as undermining the case for screening for Uranium in urine. We recommend that the results of urine analysis should be matched with a programme of whole body monitoring. This would provide a baseline from which to estimate the TLN burdens in civilians in areas where whole body monitoring might be impractical but where urine samples could be collected.
1 Minutes of COMEDS meeting 15th January 2001
2 MoD Cons. Doc. Background para. 4
3 Hansard col. 879 9 January 2001
4 Mod Scientific background para. 4.8
5 see www.llrc.org/medact.htm
6 R. Bramhall "Toxicity of Depleted Uranium": letter to Lancet in press
7 reports on DU New Scientist 13 January 2001, report and editorial 20th January 2001; Daily Telegraph 23 January 2001 page 2 (not all editions)
8 Leach LJ Elliott AM et al A five year inhalation study with natural uranium dioxide dust. 1: retention and biological effect in the monkey dog and rat. Health Physics 1970 18 599- 612
9 European Commission Article 31 Group of Experts Opinion on DU 6 March 2001
10 COMARE 4th report
11 Commentary on the Second Event Theory of Busby by A. A. EDWARDS and R. COX International Journal of Radiation Biology 2000, Vol 76, No 1, 119-125 Busby's reply
12 Commentary on the Second Event Theory op cit Cox and Edwards' response
13 for example Professor Goodhead in Bramhall, R.(ed.) 1997 The Health Effects of Low Level Radiation: Proceedings of a Symposium held at the House of Commons 24 April 1996; Green Audit 1997 ISBN 1 897761 1 14 7
14 European Commission op. cit. para 23
15 European Commission op. cit. para 24
16 Leach LJ, Yuile CL, Hodge HC et al.: A Five Year Inhalation Study with Natural Uranium Dioxide Dust - Part II Health Physics 25; 239-258 1973
NOTE: it is Part I of this study that is usually cited to show that high TLN loadings did not cause low blood counts. See for example the European Commission Opinion para 23. We answered this argument in 1999 - see www.llrc.org/medact.htm
17 Busby, C. Scott Cato, M. 2000 Increases in Leukemia in Infants in Wales and Scotland Following Chernobyl: Evidence for Errors in Statutory Risk Estimates. Energy and Environment Vol. 11 2000, No. 2 127-139
18 McDiarmid MA: Depleted Uranium and Public Health BMJ 2001; 322: 123-124
19 Risks to Uranium Process Workers: letter 29 January 2001, to electronic BMJ from Robert Alvarez, Director, Nuclear Policy Project, Inst. for Policy Studies.
20 MOD Consultation Document: Scientific Backgroundpara. 4.4
21 A literature search on the internet did not return the B. Ritz paper cited in Wenzls' letter in eBMJ. It is hard to imagine that there could be much exposure to micron-sized insoluble oxides from the machining of uranium, or that an epidemiological study of workers could differentiate between that type of exposure and exposure to the soluble forms of Uranium.
22 MoD Cons doc Scientific background para. 4.7: ref. to:- McDiarmid MA, Keogh JP Squibb KS Kane R et al. Health effects of Depleted Uranium on exposed Gulf War veterans: Environ. Res 2000 82: 168-80
23 G. Etherington, NRPB pers.comm. 9 January 2001
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