COMARE letters

Correspondence included with minutes for the COMARE meeting 10th June 1999


TEL: 01718903014
FAX: 01718904499

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.


2: letter from Professor Bryn Bridges, Chair of COMARE,
to Mr Meacher

c/o National Radiological Protection Board,
Oxon OX11 ORQ
Tel. 01235 832447 (Scientific) 01235 822629 Scientific/Administration)
Fax: 01235 832447 / 822630
Web Site.

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

COMARE Chairman

3: another letter from Professor Bryn Bridges, Chair of COMARE,
to Mr Meacher

30 April 1999

Dear Minister,

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
Chairman, COMARE

From: MRC Cell Mutation Unit
University of Sussex
Brighton BN1 9RR

4: letter from Dr Ruth Hall, CMO Wales to Dr John Steward, Director, Welsh Cancer Intelligence and Surveillance Unit

Dr John Steward
Welsh Cancer Intelligence and Surveillance Unit
14 Cathedral Road

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
Chief Medical Officer

cc Dr R Hamlet COMARE Secretariat

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