Correspondence included with minutes for the COMARE meeting 10th June 1999
DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS
19 March 1999
Dear Professor Bridges
I recently met with Dr Chris Busby and members of the Low Level
Radiation Campaign
(LLRC) together with officials from the National Radiological
Protection Board and the
Department of Health.
The LLRC is concerned about the health effects of environmental
radioactivity arising from
the discharge or clearance of radioactive material from regulated
premises. Their concerns are
fuelled by Dr Busby who alleges increased incidences of cancer
due to differences in nuclear
fallout deposition from weapons testing arising from rainfall
differences in different
locations, and increased childhood leukaemia in Wales, Scotland,
Greece and the United
States after Chernobyl.
As a result, they believe that the risks from low doses of radiation
from incorporated man-made radionuclides have been greatly
underestimated. If current risk estimates are incorrect
there would be significant implications for the regulation of
radioactive waste and
environmental radioactivity under the Radioactive Substances Act
1993 which is the
responsibility of my department.
(emphasis added)
I would be grateful if you would examine the cancer registry data
for districts around
Sellafield, Welsh nuclear plants, Harwell and Dounreay to see how
far cancer and leukaemia
incidence differs from what otherwise would be expected.
MICHAEL MEACHER
26 April 1999
Dear Mr Meacher
Thank you for your letter of 19 March 1999, which I received by fax on 23
April 1999.
You have requested that my Committee examine the cancer registry data
for districts around Sellafield, Welsh nuclear plants, Harwell and
Dounreay to see how far cancer and leukamia incidence differs from what
otherwise would be expected.
So far COMARE has published Six Reports which have dealt with the
incidence of childhood cancer and leukaermia around various nuclear
installations including those at Sellafield,Harwell and Dounreay. In the
case of Sellafield and Dounreay we noted that the rate of childhood
leukaemia or non-Hodgkin's Lymphoma (a related disease) was greater
than expected. No such increases in adult cancer have so far been
demonstrated in the vicinity of any UK nuclear site. Furthermore, we have
not been able to show any association between the nuclear discharges
from the sites examined and the levels of childhood cancer or leukaemia in
the area near to each site.
However, in our Third Report we noted that the small number of cases of
cancer or leukaemia in these generally remote, rural areas, made the
interpretation of the epidemiological data difficult. In that Report we
recommended, therefore, that studies of the geographical distribution of
childhood cancer incidence on a nationwide basis be carried out. These
studies will provide essential information on the distribution of cases of
childhood cancer throughout Great Britain, thus enabling the patterns
found around all British nuclear sites to be seen in the context of the
disease patterns found elsewhere in the Country.
We further recommended that once the results of these national studies
were available, this Committee should be asked to participate in a review
of the evidence relating to the incidence of childhood cancer around
nuclear installations.
These recommendations were accepted by Government and the national
studies are under way, funded by the Department of Health. That
Department has also asked us to undertake the review we ourselves
recommended and we have set up a Subcommittee containing members
with the necessary expertise to carry this out.
We intend to publish our findings in due course.
Thus, you will appreciate that the work you have asked us to
undertake is already in progress and will include all of the individual sites
which you have listed. I am sure you will appreciate that such large studies
will take some time to complete and we do not envisage being able to
complete our review until next year, given our current large workload. It
will also be apparent that such a data set, when available, could well be
used to test other possible associations between childhood cancer
incidence and other sources of environmental radiation or indeed with the
sources of chemical or other environmental pollutants.
I hope this is helpful. Please let me know if there is any further information
which I can provide. The Secretariat will be happy to send you copies of
our previous reports if you should so wish.
Yours sincerely
Professor BRYN BRIDGES
3: another letter from Professor Bryn Bridges, Chair of COMARE,
30 April 1999
There are three things I would like to draw to your attention following our
meeting last Thursday.
Firstly, I have suggested to Dr Hamlet that he send you details of the work
that the Department of Health are currently finding as part of their
response to COMARE's recommendations.
Secondly, I enclose a copy of part of a letter that I sent as Chairman of
COMARE to the authorising Departments on 22nd January 1993. I draw
your attention to paragraph 9. COMARE's view is that an estimate,
however crude, of the number of deaths thought to be associated with a
given release is more meaningful to those outside the radiation protection
profession than figures of Becquerels released.
Even when estimates of detriment are made they are frequently given as
man Sv with no attempt to translate them into deaths. More emphasis is
usually given to showing what a small proportion of the natural
background dose they represent. Thus in the case of the application for
the Dounreay programme for 1995-2000 the detriment was given as a
Collective Dose of 22 man Sv, this being the summation of a very large
number of people living in the UK over the next 500 years each assumed
to receive an extremely tiny dose of radiation. Using the ICRP risk
equivalence model (the best we have), 22 man Sv implies approximately 1
cancer death. This is, of course, essentially insignificant and bears no
comparison with, say, the detriment from the releases from Sellafield in
the 1970s. Nevertheless, the presentation of detriment in this way is a
practice I would hope could be continued in future authorisation
applications.
Finally, I would like to say that I know of no reputable scientific opinion
anywhere in the world that holds Busby's view that the ICRP risk factor is
100-fold too low. Indeed, you should be aware that the debate in the USA, Japan and parts of Europe has moved on to consider
whether there is really a threshold for the induction of cancer by
radiation (a view which incidentally may have more evidence going for
it than Busby's view). If a threshold were to be accepted it would, of
course, open the door to potentially limitless discharges. In this country
such a view is rarely, if ever, heard, largely due to the influence of the
COMARE (and NRPB) which maintain the prudent assumption that
there is no threshold.
Yours sincerely,
Professor Bryn Bridges
From: MRC Cell Mutation Unit
4: letter from Dr Ruth Hall, CMO Wales to Dr John Steward,
Director,
Welsh Cancer Intelligence and
Surveillance Unit
24 May 1999
Dear John,
The purpose of this letter is to bring you up to date with a recent
exchange of correspondence between Professor Bridges, the Chairman of
COMARE (Committee on Medical Aspects of Radiation in the
Environment) and Dr Busby of Green Audit.
As agreed at the COMARE meeting on 18 March, Professor Bridges
wrote to Dr Busby requesting him to provide COMARE with a copy of
the original disk provided to him by the WCR (Wales Cancer Registry) in
order to investigate discrepancies with data currently held by WCISU and
by the Childhood Cancer Research Group. Dr Busby has declined to
provide data unless WCISU simultaneously release data "for all cancer
sites by 5-year age groups for the 1974-1990 period aggregated to the
same area of residence level". Professor Bridges has replied that he saw
no good
reason for Green Audit to withhold the WCR data pending release of
further WCISU data but also
indicated that Dr Busby's request for the latter data did not seem
unreasonable. Professor Bridges informed Dr Busby that the COMARE
secretariat would be writing to the Welsh Office
encouraging us to take any necessary steps to obtain the release of the
WCISU data to Green Audit.
The COMARE secretariat have now written to ask if it is possible to
release the data to Dr Busby
under the normal WCISU terms of standard practice regarding
confidieniality etc. As I understand
it the decision whether or not to release data to individual researchers is
uitimately for you as
custodian of the data, taking into account national guidelines and agreed
cancer registry practice.
The purpose of this letter is to request you to take into account the views
of the COMARE
Chairman in coming to a decision. Obviously you will need to reach a
common understanding with
Dr Busby regarding the terms "same area of residence" and "all cancer
sites".
If, after careful consideration, you decided that data should not be
released to Dr Busby it would be
important to spell out the grounds for such a decision very clearly
both to him and to the Chairman
of COMARE.
I would be grateful if you could keep me informed of developments.
Yours sincerely
cc Dr R Hamlet COMARE Secretariat
If you are seeing this page full screen (i.e. without a navigation bar on the left) you can't see how the rest of the site is organised.
1: FROM THE RT HON MICHAEL MEACHER MP
MINISTER FOR THE ENVIRONMENT
ELAND HOUSE
BRESSENDEN PLACE
LONDON SW1E 5DU
TEL: 01718903014
FAX: 01718904499
COMMITTEE ON MEDICAL ASPECTS of
RADIATION IN THE ENVIRONMENT
2: letter from Professor Bryn Bridges, Chair of COMARE,
to Mr Meacher
c/o National Radiological Protection Board,
Didcot,
Oxon OX11 ORQ
Tel. 01235 832447 (Scientific) 01235 822629 Scientific/Administration)
Fax: 01235 832447 / 822630
Web Site. http://www.open.gov.uk/doh/comare.htm
COMARE Chairman
to Mr Meacher
Dear Minister,
Chairman, COMARE
University of Sussex
Brighton BN1 9RR
Dr John Steward
Director
Welsh Cancer Intelligence and
Surveillance Unit
14 Cathedral Road
CARDIFF
RUTH HALL
Chief Medical Officer
This Home page link takes you to the index page, which has links to all the topics we discuss on the site [only use it if this page is full screen]
Use the Flawed Epidemiology button to see what else we have to say on this topic.
Send email to: SiteManager@llrc.org with questions or comments about this web site.