Draft document: Recommendations
Submitted by Richard Bramhall, Low Level Radiation Campaign
Commenting on behalf of the organisation

Die briete Masse eines Volkes... (fallt) einer grossen Luge 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. 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. The word "Chernobyl" is notably absent. LLRC has submitted a PDF analysing a few examples of the evidence ICRP has excluded. In particular we have looked at issues which the Consultation draft and its foundation documents have explicitly drawn out of the CERRIE Majority Report and endorsed as the Task Group's view without referencing the MINORITY Report. (There is a large membership overlap between CERRIE and the ICRP Task Group.). We see this 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; it attempts to cement a biased account into the world's literature. It is not science but propaganda; hence the reference to Mein Kampf. ICRP has constructed its temple on the dogma The definition of the protection quantities is based on the mean absorbed dose …The principle of Popperian falsification holds that a single genuine counterexample is enough to require the hypothesis to be modified. Post-Chernobyl epidemiology (among others e.g. Seascale) provides abundant evidence of a serious underestimate which cannot be denied by relying on dose models whose theoretical weaknesses are now well rehearsed. ICRP clings, with increasing desperation, to the Japanese LSS studies of acute external radiation, barely modified by internal studies whose weaknesses are no less apparent today than they were in 1995 when Busby analysed them in Wings of Death. Thank goodness the sequel is nearly finished.