Die breite Masse eines Volkes... (fallt) einer grossen Lüge leichter zum Opfer als einer kleinen. [Adolf Hitler, "Mein Kampf": Vol I, ch. 10] (The broad mass of people... falls victim to a big lie more easily than to a small one) It can be difficult to grasp the sheer scale of the deception that the Commission continues to practise upon the public through its failure to apply scientific method. It amounts to nothing less than a Nelsonian blindness to the health impacts of contaminating the environment with low concentrations of radioactivity, and the theft of mankind's collective opportunity to learn from the post-war nuclear arms race and the Chernobyl disaster. Here we are not embarking on a rehearsal of all the arguments and all the evidence. It is clear that the Commission is impervious to such submissions. At the same time silence must not give consent. For economy we concentrate on the overarching matter of scientific method. Scientific method requires countervailing evidence to be addressed. In this respect the Commission fails. Studies of the effects of weapons test fallout and Chernobyl are not cited. In fact the word "Chernobyl" is notably absent from the consultation draft and its key supporting documents, Annexes A and B. The single exception (a study highlighting the difficulty of reconstructing thyroid doses) is cited because of the Commission's obsessive concern with dose. ICRP clings to the outworn dogma that the assessment of radiation doses is fundamental to radiological protection despite robust criticism even from within its own ranks which, characteristically, it ignores. Thus the CERRIE Majority Report is cited in various contexts but not in the context of its attack on the concept of absorbed dose:- ..... There are important concerns with respect to the heterogeneity of dose delivery within tissues and cells from short-range charged particle emissions, the extent to which current models adequately represent such interactions with biological targets, and the specification of target cells at risk. Indeed, the actual concepts of absorbed dose become questionable, and sometimes meaningless, when considering interactions at the cellular and molecular levels. (CERRIE Majority Report Chapter 2.1 paragraph 11). The work of the European Committee on Radiation Risk (ECRR 2003 [1)) is not cited. Neither is IRSN's recent report on the ECRR (IRSN 2005 ) although ICRP shares staff with IRSN and although IRSN states: Various questions raised by the ECRR are quite pertinent and led IRSN to analyze this document with a pluralistic approach. a. Besides natural and medical exposures, populations are basically undergoing low dose and low dose rate prolonged internal exposures. But the possible health consequences under such exposure conditions are ill-known. Failing statistically significant observations, the health consequences of low dose exposures are extrapolated from data concerning exposures that involve higher dose rates and doses. Also, few epidemiologic data could be analyzed for assessing inner exposure effects. The risks were thus assessed from health consequences observed after external exposure, considering that effects were identical, whether the exposure source is located outside or inside the human body. However, the intensity, or even the type of effects might be different. b. The pertinence of dosimetric values used for quantifying doses may be questioned. Indeed, the factors applied for risk management values are basically relying on the results from the Hiroshima and Nagasaki survivors' monitoring. It is thus not ensured that the numerical values of these factors translate the actual risk, regardless of exposure conditions, and especially after low dose internal exposure. c. Furthermore, since the preparation of the ICRP 60 publication, improvements in radiobiology and radiopathology, or even in general biology, might finally impair the radiation cell and tissue response model applied to justify radioprotection recommendations. It was thus justified to contemplate the impact of such recent observations on the assessment of risk induced by an exposure to ionizing radiation. and The phenomena concerning internal contamination by radionuclides are complex because they involve numerous physico-chemical, biochemical and physiological mechanisms, still ill-known and thus difficult to model. Due to this complexity, the behaviour of radionuclides in the organism is often ill described and it is difficult to accurately define a relationship between the dose delivered by radionuclides and the observed consequences on health. This led the radioprotection specialists to mostly use the dose/risk relationships derived from the study of the Hiroshima/Nagasaki survivors, exposed in conditions very different from those met in the cases of internal contaminations. This fact raises numerous questions, which should be considered with caution because a wide part of the public exposure in some areas of the world is due to chronic internal contaminations and very few data concern these situations. […] the questions raised by the ECRR are fully acceptable, … " and … we do not possess, in the current state of knowledge, the elements required to improve the existing radioprotection system. In the draft Recommendations  preceding the present one paragraphs 37, 41, 42, 44, 46, 47, 48 , 49 and 50 gave detailed discussion of the circumstances where heterogeneity of energy distribution compromises absorbed dose. Paragraph 51, immediately following, presented a bizarre and risible contradiction in asserting (or re-asserting) that The definition of the protection quantities is based on the mean absorbed dose … The present consultation draft has reorganised or vanished the material from the paragraphs listed. It does not seem worth making a detailed analysis of the fate of this material since the Commission clings to its original conclusion about the assessment of radiation doses. However, we note one example (selected at random, not according to any ranking). Paragraph (44) of the 2004 draft read: Absorbed dose is defined based on the expectation value of the stochastic quantity e, energy imparted, and therefore does not consider the random fluctuation of the interaction events. It is defined at any point in matter and, in principle, is a measurable quantity, i.e. it can be determined experimentally and by computation. The definition of absorbed dose has the scientific rigour required for a fundamental quantity. It takes implicitly account of the radiation field as well as of all of its interactions inside and outside the specified volume. It does not, however, consider the atomic structure of matter and the stochastic nature of the interactions. The final sentence with its inherent caveat about heterogeneity of energy deposition has vanished from the analogous paragraph of the present draft. Section 126.96.36.199 of Annex A, Supralinear low dose responses, discusses a number of disputed areas of radiation risk, citing the CERRIE Minority Report but not the Minority Report . This cannot be dismissed as an oversight, in view of the overlapping membership of CERRIE and the ICRP Task Group which wrote the Annex. We see it as an exercise in misrepresenting the status of a scientific dialogue. A feature of the technique is that it attacks the work of individuals in a manner that allows them to be identified by the cognoscenti but does not cite them overtly — a propaganda technique rather than science. The topics so treated in Section 188.8.131.52 are dismissed in terms of The Task Group agree[ing] with the general view expressed by the majority of CERRIE members that none of the proposals on the gross underestimation of risk that were considered have a sound scientific basis and that some are demonstrably flawed. The following points illustrate the views of the Task Group: a) the interpretation of selected epidemiological datasets. The Annex glosses this as The epidemiological evidence cited did not provide consistent evidence that risk of childhood leukaemia from nuclear test fallout was seriously underestimated by established radiation risk models. XXXX points should be noted. 1) The principle of Popperian falsification holds that a single genuine counterexample is enough to require a hypothesis to be modified. It is not a question of having to provide consistent evidence of a serious underestimate. 2) Rather than accepting the unsupported statements of the Task Group, readers should refer to detailed discussion of the childhood leukaemia in the CERRIE Minority Report pp.30-2. 3) In fact just as much attention was given to INFANT leukaemia post-Chernobyl. The CERRIE Majority Report handled this in a farcical manner which has been analysed in a number of submissions (e.g LLRC to CoRWM) and published in Radioactive Times Vol 6 no 1 without being rebutted. A version is appended as Appendix 1. 4) CERRIE cannot be represented as a thorough examination of even a substantial proportion of the epidemiological datasets available. It is particularly noteworthy that two Russian Academicians attended the 3-day international workshop convened by CERRIE in 2003. They recommended that there were tens of thousands of papers in Russian which were relevant to the Committee's remit and they asked that the Committee should recommend translation of at least the abstracts to make them more widely accessible. The Majority Report ignored this entire topic, but the Minority Report included translations of about 100 summaries showing supralinear effects, both experimental and epidemiological, tending to falsify ICRP's risk estimates. This work has now been augmented in publication of a far larger volume of work from Russia, Belarus and the Ukraine . A summary is appended as Appendix 2. b) biophysical proposals on the mode of action of certain internal radiations. The Annex glosses this as The so called Second Event Theory cited in support of higher than expected cancer risk from 90Sr and particulate forms of alpha-emitters [which the majority felt] was inadequately formulated and inconsistent with a wellestablished body of biological data. The manner in which this was treated by CERRIE was highly unsatisfactory. An external reviewer was appointed without reference to the Committee; the criteria he applied were not satisfactory and omitted some key issues. As the Minority Report reveals , Committee members failed to understand key aspects of the debate. Crucially, it was never contended that the Second Event Theory has to be valid in order to demonstrate that there is something badly wrong with the ICRP's modelling. The epidemiological data, allied to the caveats uttered by the ICRP itself, take precedence; the Theory stands as a possible explanation of why the epidemiological data fail to conform to simplistic assumptions based on external irradiation and average dose. This it shares with the next category: c) the role of induced genomic instability/bystander signalling in cancer development; Jury out. It is said that if these mechanisms play a role in radiation induced disease they are already subsumed within existing radiation risk factors. This is hard to sustain since they have potential to cause a far larger range of disease than are currently assumed to be radiogenic — cf ECRR 2006. d) the fitting of bimodal or polymodal dose-responses to epidemiological and experimental data. The Annex glosses this as The data relating to bimodal/polymodal dose responses were generally weak, statistical analyses were inadequate and the phenomena, if real, had no obvious mechanistic basis. Many of the post-Chernobyl reports in ECRR 2006 and the CERRIE Minority Report show bimodal/polymodal dose responses. The Commission fails to examine these data, just as CERRIE did; CERRIE did not undertake enough analysis to allow the conclusion that statistical analyses were inadequate. One does not know how much analysis ICRP has carried out since it cites no post-Chernobyl evidence. It has been pointed out that some of the data sets cited by ICRP and other conventional agencies (e.g. of nuclear industry workers) show anomalously high effects at low dose, though these points are usually dismissed as outliers. Mechanistic bases for bimodal responses have been proposed, including during CERRIE. An example is to be found on page 58 of the CERRIE Minority Report. We know of no logical rebuttal, as contrasted with the Annex's unscientific opinion mongering. This section of the ICRP's Annex A concludes: Whilst recognising considerable uncertainty on estimates of cancer risk at low doses, the Task Group judges that the data and theories concerning supra-linear dose response do not provide evidence that the application of current cancer risk models based upon the LNT hypothesis and application of the concept of effective dose leads to a gross underestimate of cancer risk. Epidemiology takes precedence over theory, and the post-Chernobyl epidemiology falsifies this statement. The Commission assumes on the basis of the LSS external irradiation studies that effects are limited to a small range of disorders. Post-Chernobyl studies showing a wide range of non-cancer diseases falsify this assumption, as does Whyte's metaanalysis of infant mortality at the time of the weapons test fallout (not cited by ICRP). ICRP itself admits that no specific judgement on low dose risk of non-cancer diseases is possible.  Conclusion The Commission's approach is fundamentally unscientific. The Commission's obsession with absorbed dose as an average and its refusal to consider any studies where dose cannot at least be inferred conflict with opinions about the limitations of absorbed dose from a range of authorities including the Commission itself. On the basis of copious epidemiological evidence radioactive contaminants appear to be acting as toxins irrespective of dose considerations, irrespective of whether biological mechanisms are known, and irrespective of assumptions based on the LSS studies about which types of disorder are inducible by radiation. Appendix 1 INFANT LEUKAEMIA: AN ACID TEST A sharp increase in infant leukaemia was observed in several countries after the Chernobyl accident in 1986. It was extensively discussed by CERRIE. Leukaemia is recognised as an early indicator of radiation damage; more specifically, infant leukaemia (i.e. diagnosed before a baby’s first birthday) signals damage acquired in the womb. Scientific journals have published papers by different research teams showing post-Chernobyl increases of between 20% and 330% in various countries as far apart as Belarus and the USA (Busby 2000; Gibson 1988; Ivanov 1998; Mangano 1997; Michaelis 1997; Petridou 1996 ). This is a crucial challenge to conventional radiation risk estimates because only the Chernobyl fallout can have caused the disease in this very precisely defined subset of the population. The number of sick babies was small but they are in effect miners’ canaries, suggesting that radioactive discharges are contributing to the global epidemic of cancer. All the post-Chernobyl studies show between 150 and 800 times more leukaemia than expected. We argued in CERRIE that this was prima facie evidence against the external risk model. Our opponents set out to show it could be ignored. They argued that the statistical power of the individual studies was so low that no reliance could be placed on the overall observation. One strand of this argument depends on ignoring studies of Scotland and Wales where excess risks were high and statistically significant. The second strand began with using wrong data and ended in nonsense. The first draft of the CERRIE Majority Report said radiation doses in Germany were the same as in Greece. This had the effect of reducing the apparent significance of the German study and CERRIE concluded that … the only study to show a large discrepancy with the predictions of external radiation risk estimates is the Greek … study. However, we knew from UN monitoring that fallout in Greece was roughly four times higher than in Germany (Savchenko 1995). We told CERRIE’s Chairman that the stated doses were obviously wrong and the Majority Report was changed. As published, it contains the correct doses but, untenably, still concludes that only the Greek study is out of line with expectation. The third strand of the CERRIE case is an unsubstantiated slur on the quality of data collection in Greece. This was never discussed in Committee, but the Report’s implication is that the Greek study can therefore be ignored. The fourth concerns the study from Belarus, where fallout levels from Chernobyl were more than seven times higher than in Greece ‘though the increase in infant leukaemia was smaller than anywhere else in mainland Europe. The Majority Report says the Greek study (the only one supposed to be an anomaly) is ... statistically inconsistent with … the study in Belarus where the highest doses from Chernobyl contamination were received. Statistically inconsistent with … is code, meaning that the observations challenge the dogma that dose and effect are always linear. We had consistently argued in CERRIE that there are good reasons why disease may not always show linear relationships with dose. Infant leukaemia is just one example. It starts in the womb, so babies carried by pregnant women in high fallout areas will suffer more damage than in low fallout areas. As a result more babies will be miscarried or stillborn or will die before leukaemia is diagnosed. A high fallout area will therefore inevitably have a lower incidence of leukaemia per unit dose than a low dose area and possibly an absolutely lower incidence as well, as in the case of Belarus. Thus we have further evidence of the invalidity of the ICRP linear risk model. The Majority Report thus used a combination of wrong and selective data, innuendo and dependence on assumptions which CERRIE itself had been set up to test, to find that the increase in each country could have happened by chance, so the overall increase could have happened by chance. This ignores the classic scientific dictum of “instance confirmation”; that is, studies which consistently show a trend increase our confidence that the trend is real. The Chernobyl infants’ studies satisfy Professor Sir Austin Bradford Hill’s famous features of reliable epidemiological studies (Bradford Hill 1965: extracts in italics. This discussion of Bradford Hill was part of the CERRIE process — it was as near as CERRIE would get to discussing the philosophy of science, or How do you know what you know?):- • “strength” (Is the observed increase in risk large enough, relative to unexposed people, to draw a firm inference about causation? On this Bradford Hill cautions We must not be too ready to dismiss a cause-and-effect hypothesis merely on the grounds that the observed association appears to be slight.) • “consistency” (Has it been repeatedly observed by different persons, in different places, circumstances and times?) • “specificity” (Is there a specific association between the disease and the type of exposure?), • “temporality” (Does the disease follow the exposure?) • “plausibility” (Is the causation we suspect biologically plausible, bearing in mind that the association we observe may be one new to science or medicine and we must not dismiss it too light-heartedly as just too odd.) • and “coherence” (Does the cause-and-effect interpretation of our data …. seriously conflict with the generally known facts of the natural history and biology of the disease?) The Biological gradient criterion is not satisfied, but Bradford Hill envisages circumstances in which a linear dose response would not be seen, and I have already given good reason why infant leukaemia would not display one. As the CERRIE Minority Report’s appendix of studies from the Chernobyl affected territories of Russia, Belarus and Ukraine shows, many disease phenomena show non-linear relationships with dose. Statistical significance, so crucial to CERRIE’s dismissal of the infant leukaemia, is of minor importance according to Bradford Hill. Nonetheless, we can amalgamate the statistical tests contained in the various studies. The Scottish, Greek and German studies combined, for example, have a p value of 0.00065, meaning that an event on this scale occupying a two year period would not happen by chance in more than two thousand lifetimes. Common sense says that if the events were truly random, at least some of the data points would have been below the dotted line. FOUR-WAY SPLIT NOT EXPLAINED On this key issue the Majority Report shows a bizarre four-way split: In the judgement of a large majority of Committee members, it is likely that radioactive fallout from the Chernobyl accident resulted in an increased risk of infant leukaemia in the exposed populations. A substantial fraction of members thinks that this increase is at the level anticipated from current risk models. However, another substantial fraction feels that these models may have underestimated the level of this increased risk. Of this latter group, two members further believe that the evidence for infant leukaemia suggests that the current risk estimates are appreciably in error. The remainder of the Committee believes that there exists relatively little evidence that lends support to this view. There is a consensus within the Committee that leukaemia incidence in infants post-Chernobyl merits further study. [CERRIE Majority Report Chapter 4 para. 26] The reasoning behind some of the views remains a mystery even to CERRIE members, since the Committee never went through an open process of identifying members’ opinions. One faction - its size is not stated - seems to think Chernobyl had no effect on how many babies got leukaemia. Most members thought it did have an effect, but were split three ways on how big it was; some thought all the data points could be interpreted as being in line with ICRP expectations, others thought the risks might have been higher, but the report doesn’t say how much higher, nor who thought so, nor why. Two members insisted that the various scientific papers unequivocally show radiation is at least 100 times and maybe up to 1000 times more dangerous than conventional estimates. The majority felt there was relatively little evidence of this. The Committee’s remit required differences of opinion to be explained, but the Majority Report leaves the reader only to guess whether there were any scientific grounds for this wide divergence (as opposed to the obvious political motivations). The implications are huge, for if the risk factors are so grossly in error we have an explanation not only for the Seascale leukaemia cluster but for the global epidemic of cancer which started when the nuclear industry began to spread radioactive pollution around the planet. On this key issue, as on many others, the Majority Report completely fails to produce any reliable advice for policy makers. The Committee on Medical Aspects of Radiation in the Environment colluded with the cover-up. Professor Bryn Bridges, Chairman of COMARE, attended every meeting of CERRIE as an observer. Professor Eric Wright was a member of both CERRIE and COMARE and also sat on the COMARE sub-Committee shadowing CERRIE, so despite the opacity of CERRIE’s treatment of the infant leukaemia, COMARE was fully aware of its importance. However, its 9th Report, which advises ministers on CERRIE’s findings, contains not a word about it. Professor Bridges retired as Chair of COMARE at the end of 2004 but he defends his report against this criticism. In an email to LLRC he cites a paragraph which refers to the forthcoming European Childhood Leukaemia/ Lymphoma Incidence Study (ECLIS). This he says will investigate trends in incidence rates of childhood leukaemia and lymphoma in 20 European countries, in relation to [...] Chernobyl [...] Such large studies are much more likely to produce firm results than those proposed in the CERRIE report. As ECLIS is unpublished it does not falsify studies published up to 18 years ago. CERRIE’s own study is part of the body of evidence which the Majority Report misrepresents. Appendix 2 ECRR 2006 contains a vast amount of information on conditions that could be described as generalised ill-health. We summarise some of them here. The discussion commences: Since 1986, in the USSR, life expectancy has noticeably decreased. On average, infant mortality has noticeably increased, as well as death rates for those of advanced ages. There is no proof of a direct connection between these parameters and the Chernobyl catastrophe, but THERE IS PROOF OF SUCH CONNECTIONS FOR PARTICULAR POLLUTED TERRITORIES. AFTER 1986, IN THE RADIOACTIVELY POLLUTED AREAS OF UKRAINE, BELARUS AND RUSSIA, THERE IS AN INCREASE IN GENERAL MORTALITY BY COMPARISON WITH NEIGHBORING AREAS. (EMPHASIS added.) The following list of conditions has been taken from Chapter 1 of ECRR 2006. The presence of a condition here indicates that the parameter has worsened since the accident and many of the studies report a dose dependent relationship . Stillbirths, miscarriages, infant mortality, general mortality, cancer mortality, sudden deaths. Thyroid cancer. The 40 % increase in all malignancies between 1990 and 2000 correlates with radioactive fallout levels. The list of cancer sites includes retinoblastoma, lung, intestines, colon, kidneys, female breast, bladder, respiratory organs, nervous system, pancreas, all cancers in children. Psychological diseases correlate with levels of radioactive pollution. There is a steep and continuing increase in diseases of the nervous system, e.g. congenital convulsive syndrome, brain circulation pathology, general neurological diseases, short-term memory loss, deterioration of attention function in school-children. In adults there is growing evidence of a syndrome marked by deteriorating memory and motor skills, occurrence of convulsions, and pulsing headaches. This is caused by the destruction of brain cells and in the region has been dubbed Chernobyl dementia. In the Chernobyl territories cataracts have become a common disease. Urogenital illnesses correlate with levels of radioactive pollution, and include interruption of pregnancy, gestosis, premature birth, inflammation of female genitals, ovarian cysts, uterine fibroma, menstrual irregularities, kidney infections, kidney stones, stones in urinary passages, infringements of sexual development, complications of pregnancy and births, failures of pregnancy, medical abortions, infertility, pathology of sperm, sclerocystosis, early impotence in men aged 25 - 30, structural changes of testiculus, spermatogenesis disturbances, lactation in 70- year old women, and delayed puberty as well as accelerated sexual development. Diseases of the cardio-vascular system and blood are one of the most common consequences of the Chernobyl radioactive pollution:- anaemia, illnesses of the blood circulation system, arterial hypertensia or hypotensia, disturbances of heart rhythm and digestive systems, macrocitosis of lymphocytes, diseases of the blood and circulatory organs in adults, early atherosclerosis and ischemic heart disease, leucopenia, infringement of the blood supply in legs, changes in abundance and activity of leukocytes. There is much evidence correlating fallout levels with endocrine/hormone diseases, e.g. incidence rate for Type 1 diabetes mellitus in Belarus. Similarly thyroid gland diseases (autoimmune thyroiditis, thyrotoxicosis, diabetes etc.). In 1993 more than 40 % of the surveyed children in the Gomel area of Belarus had an enlarged thyroid gland. Experts think up to 1.5 million people in Belarus are at risk of pathology of the thyroid gland. In some of the Chernobyl-polluted territories immune systems are compromised, with changes to cellular and humoral immunity, decreased maintenance Т- and В- lymphocytes, reduced resistance to infections and other diseases, raised frequency and expressiveness of tonsillitis, lymphadenopathies and lowered resistance to cancer. In the radioactively polluted territories the typical consequence of infringement of the immune system appears as an immuno-deficiency. An increase in frequency and intensity of both acute and chronic diseases is observed everywhere in the Chernobyl polluted territories. Sometimes the weakening of the immune system in these radioactively polluted territories is referred to as Chernobyl AIDS. There is accelerated ageing among the people in radioactively polluted territories in the Ukraine: their biological age exceeds their actual age by 7 - 9 years. In highly polluted territories in Belarus the mean age of men and women who died from heart attacks was 8 years younger than the average across Belarus. The array of diseases commonly considered exclusive to the elderly is now typical for children in all of the heavily polluted territories. The immune system activity of these children is similar to the type of immune system activity experienced in old age. The pathology of the digestive system epithelium in children from the polluted areas of Belarus also shows similarities with elderly people. There are many studies showing a wide range of chromosomal aberrations in the Chernobyl radioactively polluted areas. Examples:- higher frequency of chromosomal aberrations in somatic cells, lowered mitotic index in polluted districts, increased mutation rates in satellite DNA, chromosomal aberrations and satellite DNA mutations increased in children with thyroid cancer, chromosomal mutations de novo higher in polluted territories. In the polluted territories, compared with clean ones, there is increasing morbidity by intestinal toxicosis, gastro-enteritis, dysbacteriosis, sepses, respiratory viruses, herpes infections, trichocephalisis, pneumocistis, cryptosporidosis, tuberculosis, viral hepatitis, cytomegalovirus (CMV) infection. Microsporia occur in the radioactively polluted territories of the Bryansk areas (Russia) more frequently and in a more virulent form. There are increases in children’s general morbidity, and increases in rare illnesses in the Chernobyl polluted territories of Ukraine, Belarus and Russia; It is clear that children in heavily radio-polluted territories really do suffer, to a much greater degree, from a variety of diseases. Practically all forms of studied nosology are more prevalent […] [there is] a convincing picture of sharply worsening health in children from the polluted territories. Conditions listed under this heading are:- chronic gastritis, chronic duodenitis, chronic gastro-duodenitis, bilious dyskinesia, vegeto-vascular and cardiac syndrome, astheno-neurotic syndrome, chronic tonsillitis, caries, chronic periodontitis. Total child morbidity in Ukraine increased by 2.9 times between 1986 and 2001, newborn morbidity in Belarus increases year-on-year at a rate of 9.5% with greatest increases in the most polluted Gomel area. The spectrum of children’s noncancer illnesses in the polluted territories includes lowered birthweight in those irradiated in utero in Ukraine, reduced head circumference in newborns in the polluted territories of Ukraine and Belarus, infringements of the rate of physical development in those irradiated in utero, premature birth more common in the polluted territories of Belarus, delayed rate of growth in the radioactively polluted parts of Belarus. Respiratory system diseases occurred everywhere in the polluted territories and tend to correlate with levels of radioactive pollution:- asphyxia was observed in half of the 345 surveyed newborns irradiated in utero in Ukraine 10. Other pathologies were latent bronchospasm, bronchial asthma, chronic bronchitis, chronic nasopharyngeal pathology, acute respiratory diseases. Cardiovascular system diseases in children occurred more frequently in the polluted territories, including infringements of cardiac rhythm, infringements of vegetative regulation of cardiac activity, arterial hypertension, reduced numbers of В- and Т—lymphocytes, lymphopenia, brachycardia, lymphoid hyperplasia, haematological disease, heart conductivity, and reduced elasticity of arterial vessels even in apparently healthy children. Dental diseases in children are more frequent in the Chernobyl radioactively polluted territories. The frequency of some dental diseases correlates with levels of radioactive pollution. Congenital malformations. Increased rates of teratogenic effects all over Europe, with a dose dependent relationship found in a Bavarian study. It reports that in Europe there were also widespread increases in still birth, premature birth, low birth weight, Down's Syndrome, perinatal and neonatal deaths, and reduced birth rate. In Belarus, according to the Belarus National Genetic Monitoring Registry, there were post-Chernobyl increases in anencephaly, spina bifida, cleft lip, cleft palate, polydactyly, limb reduction, oesophageal atresia, anorectal atresia and multiple malformations. Many of the authors explicitly state that these phenomena are radiogenic. One, a researcher known for her caution, says only a third of congenital deformities of the face and jaw could be attributed to radiation. But it is a third, and those which are so attributed are said to be anomalously severe. The proportion of children with impaired intellectual development is consistently greater in polluted areas. Irradiated children have not kept pace with other children. Disorders of intellectual development in children irradiated in utero in the polluted territories are described as the most tragic consequences of the Chernobyl catastrophe’s impact on health. The ECRR 2006 book has an entire chapter on the topic. Its author observes that the official French agency IRSN has recognised that the Central Nervous System is radiosensitive. Children irradiated in utero whose mothers had been evacuated or who lived in a zone contaminated with between 5 and 40 Ci/km2, suffered a greater frequency of neurotic disorders, CNS pathology and delay of mental development, compared with children in the less polluted areas of Belarus. The depression of intellectual development was massively greater in the irradiated group than in the controls; pathologies include neurotic disorders, asthenic syndrome, vegetative dystonia, CNS organic pathology, delayed mental development, EEG pathology, delayed development of speech, lowered psycho-emotional development, low IQ indices, deviations in mental development, memory impairment, immaturity for school, organic pathology of the brain, decreased and delayed psychomotor development, epilepsy and epilepsy-related conditions, and schizophrenia. Overview of health in Lugyny district Here are some health statistics for one remote Ukrainian administrative district from the Zhytomir area – Lugyny district, which is not one of the most contaminated regions. Comparison is made between two years just before the accident (1984 – 1985) and 1995 - 1996, ten years after. All the medical information for this study was collected by the same people in the Central Hospital before and after the catastrophe, using the same equipment and the same protocols. The proportion of detected tuberculoses which were of a very aggressive type doubled. Endocrine pathology in children increased 10-fold. Goitres were not registered before the accident but ten years later were found in 12 or 13 children per 1000. Neonatal morbidity increased between 4 and 13-fold. Total mortality increased from 10.9 per 1000 to 15.5. Life expectancy declined from 75 years to 65. Life-expectancy remaining to a patient in Lugyny District after being diagnosed with lung or stomach cancer shrank from 38 – 62 months before the accident to 2 – 7 months afterwards. The CERRIE Minority Report (p. 126) observes that this reduction in life expectancy runs counter to the view that increased incidence of cancer since the Chernobyl accident has been an artefact caused by increased vigilance and hence better ascertainment. Better ascertainment ought to mean earlier detection and hence more effective treatment and a better prognosis. In the Lugyny overview we see a dramatically worse prognosis — after a lung or stomach cancer diagnosis the average patient now survives for only 4½ months, instead of between 3 and 5 years before Chernobyl. Only four explanations are readily apparent: • doctors are not looking for cancer as assiduously as before Chernobyl, so they detect it very late in its course; • treatment resources are much reduced; • cancer patients fear that their cancer was caused by radiation; • the post-Chernobyl cancers are of a more aggressive type. The first of these is contrary to the general pattern. The second is possible and should be investigated. The third is, to put it mildly, contentious. The fourth is consistent with many observations in the region including non-cancer diseases. Low Level Radiation Campaign, Contact: Richard Bramhall, email@example.com, 15th September 2006  2003 Recommendations of the ECRR The Health Effects of Ionising Radiation Exposure at Low Doses and Low Dose Rates for Radiation Protection Purposes: Regulators’ Edition Edited by ChrisBusby with Rosalie Bertell, Inge Schmitz-Feuerhake, Molly Scott Cato and Alexei Yablokov. Published on Behalf of the European Committee on Radiation Risk Comité Européen sur le Risque del’Irradiation, Brussels by Green Audit, 2003. ISBN: 1 897761 24 4  DRPH/2005-20: Health consequences of chronic internal contamination by radionuclides. Comments on the ECRR report “The health effects of ionising radiation exposure at low doses for radiation protection purposes” and IRSN recommendations.  2005 Recommendations of the International Commission on Radiological Protection  Minority Report of the UK Department of Health / Department of Environment (DEFRA) Committee Examining Radiation Risks of Internal Emitters (CERRIE); Sosiumi Press Aberystwyth. ISBN 0- 9543081-1-5  ECRR Chernobyl 20 Years On: Health Effects of the Chernobyl Accident. European Committee on Radiation Risk Documents of the ECRR 2006 No1 Edited by C.C.Busby and A.V. Yablokov Published on behalf of the European Committee on Radiation Risk Comité Européen sur le Risque de l’Irradiation, Brussels by Green Audit, 2006. ISBN: 1-897761-25-2  CERRIE Minority Report Technical Annex 2  Table 7.1 of Annexe A  For references to this section see Radioactive Times Vol 6 No 1 on www.llrc.org  This section is intended to be indicative rather than scientifically robust; please refer to the ECRR 2006 or the original researchers. We list health conditions in the order they appear in the book.  Presumably this was a study of peri-natal mortality.