Comments on the ICRP Draft Report:
Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident
Update of ICRP Publications 109 and 111
Submitted by Katsumi Furitsu M.D.Ph. D.
On behalf of “Chernobyl-Hibakuhsa Support Kansai”, Japan
October 9, 2019
<cherno-kansai@titan.ocn.ne.jp>
The real radiation protection is achieved by a complete cancelation of nuclear utilization.
We, the members of “Chernobyl-Hibakusha Support Kansai”, visited the affected areas of the Chernobyl accident for the first time in 1991, five years after the accident. Since then, we have been supporting the people affected by the Chernobyl accident and exchanging with them for 28 years. We witnessed that the severe nuclear accident totally changed each people’s whole life, forced various difficulties on the communities and brought irreparable damages to the society and environment. In such a serious situation after the Chernobyl accident, we have been making effort to protect people’s health and life in cooperation with the people in the affected areas. Through our activities with the Chernobyl victims, we leaned the lesson that a severe accident of nuclear power plant should never be repeated in the world. We also became convinced that the use of nuclear energy should be stopped to avoid further sever accidents, and we appealed the message to the world.
However, the countries and the nuclear industry continued to utilize nuclear energy even on the condition that further sever accidents might occur. Giving support to the nuclear industry, ICRP published Publications 103[1], 109[2], 111[3], which include the recommendations actually to force extremely higher dose of radiation on workers and public in case of severe nuclear accidents. ICRP newly proposed the “reference levels” for large nuclear accidents, which is exceptionally higher dose than “dose limits” of “planned exposure” for normal operation. As the consequence of such nuclear policies, they repeated another severe nuclear accident in Fukushima.
Furthermore, ICRP issued a statement[4] on March 21, 2011, soon after the Fukushima Daiichi Accident, which recommend to use the “reference levels” in Japan to “ensure an adequate degree of protection with respect to exposure to ionising radiation in emergency and existing exposure situations” based on their three publications above. Following the recommendations, Japanese government actually adopted the “reference levels” in their policies after the Fukushima accident[5] though such radiation standards were not yet officially introduced into the Japanese legal system. The Japanese government and Tokyo Electric Power Company (TEPCO), which should be responsible for the accident, did not provide adequate radiation protections to the people in the affected areas nor gave proper compensation to the victims of the Fukushima accident.
It is outrageous that ICRP has drafted the report to update Publications 109 and 111, which recommend just a deceptive “radiation protection” at sever nuclear accidents, and continues to support the nuclear industry without reflecting their commitment towards the repeated accidents. They ignore the suffering of the victims of Chernobyl and Fukushima by drafting such recommendations, which might lead to additional sever accidents. Their act is also criminal for the future generations. We insist again that the real radiation protection cannot be achieved without a complete cancelation of nuclear utilization, before repeating another sever nuclear accident.
The ICRP’s recommendations support the benefit of nuclear industry and violate the human rights of radiation victims.
The basic ideas of the ICRP’s recommendations stated in the draft report are the principles of “justification” and “optimisation”[6],[7], which support the benefit of nuclear industry and violate the human rights of radiation victims. We cannot accept these principles.
“Justification” is defined by ICRP that “Any decision that alters the radiation exposure situation should do more good than harm.”[8] This really means that only the protective measures, which produce “net benefit” to the nuclear industry can be “justified”.
“Optimisation” is “the likelihood of….. magnitude of their individual doses should all be kept as low as reasonably achievable, taking into account economic and societal factors.”[9] This principle, called “ALARA”, means to balance “cost and benefit” and manage to get the biggest benefit for the industry.
Just after the Chernobyl accident, not only the nuclear workers but also the general public was exposed to higher dose of radiation. During the following years, a large number of residents in the contaminated areas have been exposed to the continuous low dose of radiation. ICRP approved the situation and supported the nuclear industry which continued to utilize nuclear energy even forcing such a radiation exposure on people. They expressed in Publication 60 (1990) that they would make an additional guideline for the interventions after sever nuclear accidents[10] and published series of reports.[11] In Publication 103 (2007), ICRP newly proposed the “Emergency exposure situation” and “Existing exposure situation” in addition to “Planned exposure situation” and applied the principles of “justification” and “optimisation” to each exposure situation. They abandoned quantification of the risk of stochastic health effects of radiation and fully introduced the “reference levels” as a kind of standards for the “Emergency” and “Existing” exposure situations, which would substantially loose the regulation of radiation exposure in these two types of situations, in comparison to the regulations based on the “dose limits” in “Planned exposure situation”.[12]
The draft recommendations endorse the policies of Japanese government, which force more radiation exposure on people to promote the nuclear power plants in Japan.
After the Fukushima accident, in April 2011, we, members of “Chernobyl-Hibakusha support, Kansai”, started to visit the affected areas of the Fukushima accident every month. We tried to transfer the experiences of Chernobyl to protect the people in Fukushima from additional radiation exposure. We were also involved in the various activities, in cooperation with many citizens and specialists, including radiation protection, health consultation, measuring ambient radiation dose rate, measuring radionuclides of food and soil and supporting the children’s “summer camps” in non-contaminated areas. We also shared the experiences of people in Fukushima through the mutual exchange. We have been seeing and hearing in detail, for these eight years, the wide range and complicated impacts of the Fukushima accident, accompanied with the earthquake and tsunami.
“If the nuclear accident had not occurred, ….” “Give me back our life before the accident.” “I really wish nobody would experience again in the future such a painful life which we have after the accident.” “We have had enough of nuclear power plants.” “The government and TEPCO should take responsibility for the accident.”….these are really direct voices from the people affected by the Fukushima accident. The serious situation and strong opinions of the Fukushima victims expressed by these voices are not described at all in the Annex B of the ICRP’s draft report.
Currently in Japan, the victims of Fukushima accident have been fighting against the government and TEPCO requesting them to take responsibility for causing the serious accident and to restore and establish the human rights of victims. In such a situation, ICRP’s attempt of publishing the updated recommendations in the event of large nuclear accident is considered really intentional and political, as it actually speaks for the nuclear industry which is responsible for the accident,. We should note that the report was drafted by the Task Group 93, which is chaired by the Japanese members of ICRP.[13] Therefore, we concern very much the possibility that the updated recommendations again endorse the policies of Japanese government, which force more radiation exposure on the people in the affected areas of Fukushima and promote the nuclear power plants which might bring further nuclear accidents in Japan.
In Publication 111, it is mentioned that the reference levels in existing exposure situation for “people living in contaminated areas should be selected from the lower part of the 1-20 mSv/year band ……..Past experience has demonstrated that a typical value used for constraining the optimisation process in long term post-accident situation is 1mSv/year. National authorities may take into account the prevailing circumstances and also take advantage of the timing of the overall rehabilitation programme to adopt intermediate reference levels to improve the situation progressively.”[14] Furthermore in this draft report, ICRP recommends the reference levels for the long-lasting existing exposure “with the objective to reduce exposure progressively to levels on the order of 1 mSv per year.”[15] This means that achievement of the dose limit for the public, 1 mSv per year, is shelved as the “long-term goal”[16] and “levels on the order of 1 mSv per year”, that is “levels from 1 mSv to under 10 mSv”, can be actually adopted as “reference levels” for a long term.
In the present Japanese legal system of radiation protection, the “public dose limit of 1 mSv per year” is officially secured[17]. However, after the Fukushima accident, about four million people in the contaminated areas in Fukushima and neighboring prefectures were exposed by the additional radiation dose over 1mSv for the first year. This situation is actually illegal and the human rights of exposed people have been violated. Therefore, people have been strongly requesting Japanese government and local authorities to observe the Japanese law which actually secures the “public dose limit of 1 mSv per year.” The ICRP’s recommendations of reference levels in existing exposure situation might allow the Japanese government and local authorities not to take responsibilities to protect and support the residents living in the contaminated areas of more than 1 mSv per year, in spite of the strong public requests to the authorities to observe the present Japanese legal system of radiation protection. We cannot accept such recommendations.
The draft recommendations lack concrete consideration for children and pregnant women (fetuses).
The residents in the affected areas of the accidents are not only adult people. ICRP emphasizes repeatedly in the draft report that “commission recommends paying particular attention to children and pregnant women, for whom radiological risks may be greater than for other groups of individuals.”[18] It is true that children and fetuses are more sensitive to radiation than adults and children might get higher accumulated dose living in the same dose rate situation with adults as they could live longer than adult people. In spite of recognizing the higher risk of radiation for children and fetues, it is unreasonable that ICRP does not recommend any particular “reference levels” specific to children and pregnant women (fetuses).
ICRP downplays the contribution of radiation protection considering the radiation effect relatively small among the wide range of negative influences from the nuclear accidents.
ICRP explains in the draft report that “large nuclear accidents generate complex situations that affect all dimension of individual and social life”, including health, social, economic and psychological consequences[19]. However, ICRP does not mention any critical assessment nor reflection on the utilization of nuclear energy which actually brought such serious disasters. On the contrary, ICRP considers as if the issue of radiation exposure is relatively small among the wide range and variety of negative influences from the nuclear accidents and downplays the contribution of radiation protection based on the principle of optimisation (ALARA) in line with the ideas of nuclear industry to protect industry’s economic benefit[20]. Such a viewpoint of ICRP is not acceptable because it is totally counter to the benefit of victims of the accidents.
ICRP does not refer to the most recent epidemiological studies on the health impacts of low level of radiation.
It is mentioned in the draft report that ICRP takes into account the “most advanced scientific knowledge on the health effects of radiation.” However, ICRP does not refer to any of the recent papers of epidemiological studies on the health impacts of low level of radiation[21]. They do not revise the radiation risk assessment of cancer after Publication 103 (2007) and still state that “Below 100 mSv, the evidence (for the increased risk of cancer) is less clear.” In addition, they underestimate the risk of cancer induction by using the “dose and dose rate factor” (DDREF) of 2 and describe, “a dose of 100 mSv …adds approximately 0.5%.”[22] They should refer to the most recent papers, which were published after 2007, to promote radiation protection and improve the health care and livelihood support for the affected people by the nuclear accidents.
The problems of the thyroid examination in Fukushima
In the Annex B, ICRP reports that “childhood thyroid cancer cases found in Fukushima Prefecture are unlikely to be the result of radiation exposure after the accident.” [23] It is wrong to make such a statement because the relationship between radiation exposure from the accident and induction of thyroid cancer cases are not yet sufficiently assessed in Fukushima. In the case of the Chernobyl accident, direct thyroid measurements had been performed for more than 400,000 people within two months after the accident, while in Fukushima, direct thyroid measurement was not conducted properly[24] (except dozens of cases measured in Namie town[25]). It should be noted that a lack of reliable estimation of individual thyroid dose based on proper direct measurement is one of the reasons for difficulties of analyzing possible radiation induction of thyroid cancer cases in Fukushima.
The recommendation written in the draft, “a long-term thyroid health monitoring programme should only be conducted for those individuals exposed in utero or during childhood or adolescence with 100-500 mGy absorbed dose to the thyroid”, may violate the right to health of affected people, because nobody can deny the possibility that the exposure of absorbed thyroid dose below 100 mGy could induce cancer.
ICRP’s activities in the affected areas are deceptive as they replace the responsibility of government and industry to the self-responsibility of individual victims.
In the Annex B, it is also mentioned that “despite all the protective actions implemented by local and national authorities, the negative effects arising from consequences of……and counting concerns about radiation exposures had a large detrimental effect on the well-being of individuals and the quality of living of affected communities.”[26] Under such circumstances, ICRP emphasizes the importance and effectiveness of “ICRP Dialogue Initiative” “discussion between stakeholders” “co-expertise process” “self-help protective actions” and recommends developing a “practical radiological protection culture”. However, ICRP’s activities in the affected areas are deceptive as they replace the responsibility of government and industry to the self-responsibility of individual victims. Such interventions do not lead to the real protection of the public and workers against radiation exposure from the accidents. ICRP is just trying to spread the “expertized knowledge” which underestimates the health risk of radiation, without reflecting the nuclear policies which brought the sever nuclear accidents. ICRP should realize that most of the people in the affected areas are feeling great distrust against such attitudes of ICRP.
From the reasons mentioned above, we think the draft report does not protect the human rights of the victims of the serious nuclear accidents, though we do not make every comment in detail on the numerous problems in the draft report. ICRP should withdraw the whole of the draft report because it does not really protect the public and workers from the radiation exposure.
[1] ICRP, 2007. The 2007 Recommendations of the International Commission on Radiological Protection. ICRP Publication 103, Ann ICRP 37 (2-4).
[2] ICRP, 2009a. Application of the Commission's Recommendations for the Protection of People in Emergency Exposure Situations. ICRP Publication 109, Ann ICRP 39 (1).
[3] ICRP, 2009b. Application of the Commission's Recommendations to the Protection of People Living in Long-term Contaminated Areas after a Nuclear Accident or a Radiation Emergency. ICRP Publication 111, Ann ICRP 39 (3).
[4] ICRP ref: 4847-5603-4313
[5] For example, the Japanese government ordered people to evacuate only from the areas where the radiation dose was estimated to exceed 20mSv/year, as the upper dose of “reference level” for the “existing exposure level” was set to be 20mSv/year by ICRP. Those who evacuated from less contaminated areas were not officially conceded as “evacuees” by the government and local authorities and called as “voluntary evacuees”, and were treated as if they themselves decided to move against the government’s decision. After a year from the accident, the government started to promote people to return to their home in condition that the estimated radiation level went down below 20mSv/year. On the other hand, the government gradually started to stop supporting people who would not come back home. The government also set up the standard for cleaning-up schoolyards as 20mSv/year just after the accident. (They reduced the level to 1mSv/year later after facing to the strong objection from citizens, especially from mothers.) The tentative goal for cleaning up the contaminated areas was set to be 20mSv/year with the long-term goal of 1 mSv/year. Moreover, the government does not accept the citizen’s request that the “Support Law for Children” should be applied to all the residents in the contaminated areas of 1mSv/year or more. Note that 1mSv/year is the present dose limit for the public in the Japanese laws of radiation protection.
[6] Draft report (42) – (83), Principles for protection of people and the environment
[7] ICRP proposed the “System of Dose Limitation” in Publication 26, 1977, with its three principles of justification, optimisation of protection and individual dose limitation. They extended the principles to the “System of Radiation Protection” in Publication 60, 1990.
[8] Publication 103, Executive Summery (o)
[9] Publication 103, Executive Summery (o)
[10] Publication 60, (223)
[11] Publication 63, 82, etc.
[12] In “planned” exposure situation, the dose limits are “1mSv/year for the public” and “20mSv (average of 5 years) for nuclear workers”. However, in “emergency” exposure situation ICRP proposes the “reference levels” of “100mSv first year for the public” and for occupational exposure, “no dose restriction if benefit to others outweighs rescuer’s risk, for life-saving (informed volunteers), and 1000 or 500 mSv for other urgent rescue operations.” In the “existing” exposure situation after the radiation source becomes under control, ICRP recommends to choose reference levels in the band of 1 to 20 mSv per year, with the long-term goal of reducing reference levels to 1 mSv per year.
[13] The chair of the Task group 93 is Mr. M. Kai, a member of the Radiation Council of the Nuclear Regulation Authority (NRA) of Japan, and the vice chair is Mr. T. Homma, a staff member of the NRA.
[14] Publication 111 (50)
[15] Draft report (80)
[16] Draft report (Table 6.1)
[17] The Radiation Council under the NRA of Japan, reported the “Opinions on the introduction of the ICRP Recommendation 1990 into the Japanese legal system”, in June 1998. In the report, they stated “as for the limit for the public, the effective dose of 1 mSv per year…….should be secured in the regulation system.”
[18] Draft report (65),(102),(198)
[19] Draft report: 2.2. Consequences of a large nuclear accident
[20] Draft report: EXECUTIVE SUMMERY (n), (222)
[21] The following recent papers which show the scientific evidence of the health impacts of low level of radiation under 100 mSv and DDREF=1:
1) Ozasa, st al., Studies of the Mortality of Atomic Bomb Survivors, Report 14, 1950-2003: An Overview of Cancer and Noncancer Disease, Radiation Research, 177(3), 229-243, 2012.
2) Richardson, et al., Risk of cancer from occupational exposure to ionising radiation: retrospective cohort study of workers in France, the United Kingdom, and the United States (INWORKS), BMJ. 2015 Oct 20;351:h5359. doi: 10.1136/bmj.h5359.
3) Laurand, et al., Ionising radiation and risk of death from leukaemia and lymphoma in radiation-monitored workers (INWORKS): an international cohort study, Lancet Haematol. 2015 Jul;2(7):e276-e281.
4) Pearce, et al., Radiation exposure from CT scans in childhood and subsequent risk of leukaemia and brain tumours: a retrospective cohort study. Lancet. 380(9840):499-505, 2012.
5) Mathews, Cancer risk in 680,000 people exposed to computed tomography scans in childhood or adolescence: data linkage study of 11 million Australians. 346:f2360, 2013.
[22] Draft report (22)
[23] Draft report (B42)
[24] Kim, et al., Internal thyroid doses to Fukushima residents-estimation and issues remaining. J Radiat Res. Vol. 57, No. S1, pi118–i126, 2016 [Measurement was conduced with non-spectrometric devices under the elevated background level at least more than 0.1μSv/h.]
[25] Tokonami S, et al., Thyroid doses for evacuees from the Fukushima nuclear accident., Sci Rep. 2012;2:507. doi: 10.1038/srep00507. Epub 2012 Jul 12.
[26] Draft report (B36)
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