COMARE suicide note

COMARE's suicide note
Yet another official denial of breast cancer risks near radioactive estuary finally destroys COMARE's cred

On March 18th 2003 COMARE (the UK Government's Committee on Medical Aspects of Radiation in the Environment) issued a statement (see this link) on cancer mortality around Bradwell nuclear power station.

The statement destroys any credibility the committee might still have possessed. Unsupported by any analysis (footnote) it endorses flawed reports from the Small Area Health Statistics Unit (SAHSU) which conclude that there is no significant excess of breast cancer mortality near the Blackwater estuary or in Maldon. COMARE ignores Green Audit's latest findings (see this link) which have been in COMARE's hands for many months.

The statement admits that the first SAHSU report contained an error. This is true, and the statement specifically identifies the mistake SAHSU made. It goes on to claim that all three of Green Audit's contain errors that result in overestimation of risk. This is not true, and the statement is not specific.

If you read the COMARE statement (there is a link in para. 1 of this page) note the weasel words; referring to the first SAHSU report it says

... no evidence of excess ...
but after the missing data had been added this ... no evidence ... has to be qualified:
... no significant excess
... no statistically significant excess ...
The point is that the second (secret) SAHSU report does show an excess, and in order to disguise it SAHSU used Bayesian Smoothing - an inappropriate technique which they did not use in the first report.

With an amazing disregard for protocol the COMARE statement pre-empts any findings of the Committee Examining Radiation Risk of Internal Emitters (CERRIE) which nominally, at least, is a sub-committee of COMARE.
In the past year CERRIE has spent a considerable amount of time on the various Bradwell cancer statements and is not due to publish even its first report until June this year (2003). CERRIE's epidemiological expertise is at least as great as that of COMARE.
[Incidentally, COMARE is (at March 20th 2003) so out of date that its web site's Latest News refers to CERRIE as Consultative Exercise on Risk Factors for Internal Emitters (CERFIE) - a title which the Health and Environment Ministers rejected before CERRIE's first meeting in December 2001.]

COMARE's web site contains the following aspirations [LLRC's observations on how the March 18th statement doesn't measure up to them are interpolated in purple text]:-

How Does COMARE Evaluate Inconsistent Epidemiological Studies?

When COMARE is evaluating a particular topic it has to consider all the available evidence. ... no meaningful consideration of Green Audit's third report ... Each of the various published studies is each (sic) looked at individually ... yes, each, individually ... and examined for the quality of its data ... the data were common to both SASHU and Green Audit, and agreed ... and the rigour of its analysis. ... not addressed by COMARE ... What was the power of the study, ... not addressed ... was it seriously flawed by bias in its design, ... not addressed ... was the effect of possible confounding factors adequately addressed? ... not in this case ... One of the major problems with human studies is that no two people have received exactly the same radiation exposure. Sometimes the exposure is not known at all and some surrogate measure has to be used such as the number of years of work in proximity to some source or the distance of residence from a source. COMARE appears to be happy with the the distance of residence from a source criterion, 'though even SAHSU admits its weaknesses. The total available evidence is then weighted according to its quality ... COMARE's statement offer no analysis of the quality of the different SAHSU and Green Audit studies - they just plump for one on the basis of their prejudices ... and an overall assessment is made. Greater weight is given to studies where the radiation exposure is more accurately known and particularly to those studies where there is a quantitative relation between exposure and effect. ... but COMARE will only admit studies which conform with the highly dubious Linear No Threshold model ... In addition, COMARE likes to be able to give an indication of the degree of confidence or uncertainty ... they accept the Bayesian fudge factor introduced in the second SAHSU report to nudge the cluster below the insignificance threshold ... and to indicate where further work is desirable. ... COMARE's statement has a lot to say on preventing public disquiet by means of peer review, and suggests that local Health Authority officials could have pointed out errors in mortality figures before the Green Audit reports became public. COMARE presumably does not know that the Director of the North Essex Health Authority himself got the numbers wrong when presenting the SAHSU report in 2001 (he has not answered the letter in which we pointed this out). The bottom line is that you cannot legislate against mistakes and peer review doesn't prevent them either ...
... where further work is desirable ... ... CERRIE is at least considering what additional epidemiological studies could resolve the differences of opinion. COMARE, SAHSU and the Health Authority think the whole matter is closed.

As the Roman poet Horace predicted Parturient pontes; nascetur ridiculum pus ("The bridges shall go into labour; ridiculous corruption will come forth." This is often quoted thus: Parturient montes; nascetur ridiculus mus - "The mountains shall go into labour; a ridiculous mouse will be born", but this is so silly that it is obviously a transcription error.)

LLRC concludes that:

  1. the March 18th statement is unscientific and politically motivated;
  2. COMARE is prepared to deny any evidence that conventional estimates of radiation risk are wrong;
  3. COMARE has consistently failed to give unbiased advice and has been superceded by CERRIE;
  4. the March 18th statement is one instance of COMARE's consistent attempts to marginalise and derail CERRIE (in due course we shall report on this more fully);
  5. COMARE should be wound up.
The Chairman of COMARE, Professor Bryn Bridges, is quoted in an Essex newspaper (Essex County Standard 21 March 2003) as saying that COMARE had tested some of Green Audit's claims. We have done our own analyses and these tell us that there is no evidence of any of these clusters around Bradwell Power Station.
He is also reported to have said, in respect of errors, that Green Audit was a bigger offender (than SAHSU) as the corrected, final version of its report appeared to him to contain fresh gaffes.
Where is the analysis? What are the fresh gaffes?
Watch this space. We will post updates if Professor Bridges can be persuaded to back up his rhetoric with hard evidence.

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