COMARE denies watchdog role

Immediately after the transmission of the TV documentary Windscale - the Nuclear Laundry in 1983 the Independent Advisory Group was set up under the Chairmanship of Sir Douglas Black. Its report 1 made two important recommendations:-

Recommendation 5
"We were impressed by the amount of [epidemiological] data made available to us, and felt that encouragement should be given to an organisation such as OPCS [Office of Populations Censuses and Surveys, now Office of National Statistics] or MRC [Medical Research Council] to co- ordinate centrally the monitoring of small area statistics around major installations producing discharges that might present a carcinogenic or mutagenic hazard to the public. In this way early warning of any untoward health effect could be obtained."

This was the background to the establishment of the Small Area Health Statistics Unit (SAHSU).

In the Chapter entitled "Radiation Exposure of Young People in Seascale" (Chapter 4) the Black Group said:-

"We were surprised at the lack of health input into this area and the lack of co-ordination of the assessment of the overall impact of the discharges on the population. Each organisation we spoke to had considerable expertise in their particular area of environmental monitoring, but we were unable to identify any organisation that had the responsibility for assessing all of the information available and deciding on the overall implication of the discharges with regard to the health of the community. We recommend that there should be such a co-ordinating body, with a strong input by the DHSS [Dept of Health and Social Security - now Dept. of Health] and NRPB, that is able to ensure that more consideration is given to the adequacy of the data provided for dose assessment both in quality and quantity and to the need for research to improve the accuracy of dose assessment."

Accordingly, in Black's Recommendations for Regulatory Mechanisms, Recommendation 10d said:-

".. the responsibility for monitoring and for interpretation of the results of such monitoring this potentially serious environmental pollutant [i.e. radioactive discharges] should be more clearly defined by government; these results of monitoring need to be considered in their entirety on a regular basis by a designated body with significant health representation, thus enabling decisions on action with regard to the control of permitted discharges to take account of all relevant factors." [The emphasis on significant health representation is in the original.]

This was the background to the establishment of the Committee on Medical Aspects of Radiation in the Environment (COMARE).

These recommendations make it clear that Black saw a need for Government to have an overview.
However, LLRC has received a letter from the Secretary of COMARE. Dated 8th April 2004 it says:-

" ... you appear to attribute some kind of watch dog role to COMARE and SAHSU. This is not the case. Primary Care Trusts and Strategic Health Authorities have primary responsibility for monitoring health trends within their appropriate areas. They can call upon the expertise of SAHSU to help them to do this, but if they don't then SAHSU has no role. COMARE's remit as you correctly stated is to advise Government and the Devolved Authorities when and if required. COMARE has not been asked by the Welsh Assembly Government to look into this alleged cluster [near the Menai Strait] so again it has no role. As you can see neither organisation has an independent watch dog role and their initiative for investigation is strictly limited."

This means that the Black Group's benign and sensible concerns have been subverted.

The problem is that if monitoring is done only at local level, as the COMARE letter says, it is easy to overlook patterns.

Our Recommendation:- The Department of Health should scrap COMARE and SAHSU and start again.

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Reference

1 Investigation of the Possible Increased Incidence of Cancer in West Cumbria: Report of the Independent Advisory Group HMSO 1984 ISBN 0 11 321006 X