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Wednesday, 29 June, 2011 4:13 PM
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Dear Ms Partridge
Thank you for passing on the CEO’s comments in your email of 14 June. He does not seem to have extrapolated the results of the high doses of radiation, such as those recorded at Nagasaki and Hiroshima, to the low levels of radiation inferred by others. The answers appear to be constrained by a continuation of past political, commercial and compensation requirements.
The statement that ‘”detailed advice on these work programs was provided to the study by those with first hand knowledge including yourself,” lacks research.
Below are two emails describing errors in this statement:
* The second identifies my comments on Volume 1 – Dosimetry, when it was sprung unannounced on the Consultative Forum. There was unacceptable time for comment and little opportunity, for many years, for input by the Consultative Forum;
* The first is the reaction by Dr Jack Lonergan. He was a former defence scientist and was representing the RAAF on the Consultative Forum.
All the best
From: Jack Lonergan
Sent: Saturday, April 22, 2006 11:39 AM
To: Alan Batchelor ; Chris Clarke ; Rob Robotham ; Richie Gun ; Mike Carter ; Wilson, Eileen ; Johnson, Mark ; ‘Lyons, Beth’ ; Lynch, Leanne ; Baxter, Jan ; AVADSC ; ‘Alex O’Shea (CF – Comcare)’ ; Spiers, Carolyn ; Small, Allison ; ‘RSL NHQ’ ; ‘Ron Usher’ ; Ric Johnstone ; Ray Spring ; ‘Peter Cooke-Russell (CF)’ ; ‘Mike Dowsett (CF)’ ; Lewis Rice ; ‘Lance Halvorson’ ; Keith Horsley ; ‘John Rice (for Lewis – CF)’ ; Devlin, Helen ; Charles Whiting ; Bruce Armstrong ; Barry Telford ; Ann Munslow-Davies ; Allistair Leahy
Cc: Bruce Billson
Subject: Re: DOSIMETRY REPORT
Alan has compiled a devastating commentary on this study, from its genesis, through its management, and on to its implementation.
Unless the project manager can mount an effective rejoinder, the Secretary of DVA will need to consider whether the whole project should get a re-run under a manager with the competence necessary to understand and control its many facets.
I will be forwarding a commentary on the scientific integrity of the dosimetry draft per se. As such, my remarks will be complementary to Alan’s but not covering the contextual and health territories traversed by him.
Since I did not receive a copy of the draft till Good Friday I will be constrained to putting as much together as I can by 26 April on which date I shall e-mail what I have.
My copy of the mortality/cancer study reached me on 20 April.
Circulation of these reports for consideration on 27 April is an absolute disgrace and an insult to the organisations that many of us represent.
In the time I have been associated with this study I have been consistently amazed at Alan’s unmatched grasp of the issues involved, at his dedication to see that the interests of the participants are served, and at his persistence in the face of Departmental indifference and/or ignorance.
We are all very much in Alan’s debt for speaking out as he has and for doing the extraordinary amount of work that enables him consistently to put his money where his mouth is.
—– Original Message —–
From: Alan Batchelor
To: Chris Clarke ; Rob Robotham ; Richie Gun ; Mike Carter ; Wilson, Eileen ; Johnson, Mark ; ‘Lyons, Beth’ ; Lynch, Leanne ; Baxter, Jan ; AVADSC ; ‘Alex O’Shea (CF – Comcare)’ ; Spiers, Carolyn ; Small, Allison ; ‘RSL NHQ’ ; ‘Ron Usher’ ; Ric Johnstone ; Ray Spring ; ‘Peter Cooke-Russell (CF)’ ; ‘Mike Dowsett (CF)’ ; Lewis Rice ; ‘Lance Halvorson’ ; Keith Horsley ; ‘John Rice (for Lewis – CF)’ ; Jack Lonergan ; Devlin, Helen ; Charles Whiting ; Bruce Armstrong ; Barry Telford ; Ann Munslow-Davies ; Allistair Leahy
Cc: Bruce Billson
Sent: Friday, April 21, 2006 5:50 PM
Subject: DOSIMETRY REPORT
Dear Consultative Forum Members
Given the amount of time that the Study has been stagnating, there should have been time for some background research by Forum Members. The ability to agree or disagree with the work carried out by the Study must be of importance to the organizations that are represented on the Study. This importance increases when it is considered that the Forum’s representative on the SAC (Ann) has not been allowed to report proceedings back to the Forum and all of the Study sub-committees lack a continuing practical nuclear veteran overview. I attended two Dosimetry meetings and was no longer invited when my views on uranium, and probably beryllium, were advanced.
Because of the limited time available and the importance of the subject report, my comments in the attachment are mainly on the Dosimetry Study, but will include some of the areas of interface with the rest of the Study. I will forward my comments on the Adelaide University study if there is sufficient time.
A large proportion of my comments in the attachment have been provided previously or were contained in my documentary collection that was placed on loan to DVA and the Dosimetry Committee during a period of many months over two years ago. My comments also include references to the Royal Commission Transcript that was not in my possession at the time of the loan. The Study does not appear to have carried out any original research into the later, probably the most important document produced by the Royal Commission. Professional eye-witness accounts and AWRE Reports that have been tested in the cauldron of the Royal Commission interrogations, where many fallacies are revealed, have been totally ignored.
A DVA undertaking to a Budget Estimates hearing on 5 June 2001 stated “The Mortality and Cancer incidence study will examine the effects of the entire experience of participation in the tests.This will include the effects of radiation exposure”. Instead, the medical assessments have attempted to confine its investigations to cancer caused by ionising radiation. This confinement is slowly becoming unstuck but has a way to go, provided that the potential threat of future financial restrictions (based on political expectations) does not influence the level of study considerations.
The scope of the present Study is too narrow to fully address the health concerns of past and present nuclear veterans.
Handling the Interface
The rules used by the University of Adelaide Team in linking the names and data on the Study Roll with the functional (depersonalised) dosage assessments made by the Dosage Panel are vital to the integrity of the Study results and must be identified in detail or the results will appear to be based on guesswork.
Despite many requests, the process involved in interfacing dose categorisation with the Nominal Roll and then with the AIHW and State cancer registries remains a mystery. It is surmised that arrangements will have resulted in the return of depersonalised statistics from the Registries that were linked with a minimum of information, probably service/civilian status, rank, cancer type, dosage category and date of birth.
So far, the process described is fairly typical, but would not have taken full advantage of the work carried out by the Dosimetry Committee. If the original information was forwarded and linked with other vital information, such as ship, work locations, operations attended, similar function groupings, times of exposure, etc, that could be provided as impersonal flags and returned as simple search indicators to particular health effects and their relationship with particular events and/or locations. This opportunity for an innovative breakthrough may have disappeared, and if this assumption is correct, was caused by a lack of experience, forethought and coordination between the various planning, controlling and implementation areas involved in the Study. The work of the Dosimetry Sub-committee may have been wasted, and an opportunity to carry out a number of Case Control Studies, concerning the participants environment, on an almost no cost basis has been overlooked.
The study has used a rule of thumb process known as the “Rule of Seven” that states that for every seven fold increase in time, radioactivity will decrease by ten fold. An example is provided where the level falls to one thousandth after two weeks. This rule was based on a standard decay rate where it was used as an example for training, and in building theoretical models. In actual practice the decay rate is likely to be something quite different and should be determined by the isotopic composition of the matter under consideration, a figure that must be expected to vary with every shot in an experimental nuclear programme.
The inappropriateness of using this rule, without modification, is borne out by practical observations made by the Australian Health Physics Representative at Maralinga when he wrote to CXRL stating “the stuff is hanging on grimly and just won’t fade away”. The persistence of Yellow areas and the need for decontamination procedures during all stages of the Buffalo/Antler inter-trial period, and radiation survey results during the Hurricane/Mosaic inter-trial period provide practical examples of this persistence. These examples are discussed further in the attachment.
This under-estimation of dosages is reinforced when a comparison is made of the Report’s theoretical dose calculations with the practical gamma dosage records of the Joint Services Training Unit (JSTU). This unit did not enter the Hurricane Active area until 37 days after the detonation of Hurricane and were present in the Active area on 14 days over a period of 5 weeks. The recorded dose for one member of the JSTU (78.8 mSv) exceeds the theoretical dose calculated for e.g. Buffalo and Antler Engineer Groups (range from 6 to 20 mSv), whose initial entry was shortly after detonation (usually day of detonation or day after), were actively employed during the countdown and recovery periods during a period involving three or four rounds and remained working in Active areas for periods of 3 months, or in some cases, a great deal more. Not taking the employment variations into account, the theoretical calculations provide dosage estimates that are approximately 2% of the practical figures. This subject is discussed further in the attachment.
Nuclear weapons are being treated as generalised producers of nuclear radiation that quickly dissipates from the environment. This is a simplistic viewpoint based on perceived Government policy that attempts to remain strictly within the confines of the Terms of Reference. These have obviously been written by a person who did not have a clear understanding of the undertaking made by DVA to Budget Estimates on 5 June 01, stating that the study would examine the entire experience of participation in the tests including radiation exposure. This pledge has never been publicly withdrawn by DVA or the Minister. Because of the complicated inter-relationships between the many modes of infection and vast range of detrimental health outcomes that could result from participation in a nuclear weapons test program, the constriction of the Terms of Reference to cancer and morbidity should never have been allowed to continue in its present crippled format by the DVA managers. Reinforcing this error in judgement, is the lack of time remaining for follow-on studies after a half-century of procrastination. The Prime Minister has displayed his willingness to accept an extension to a Terms of Reference in the case the Coles Enquiry into the Aaustralian Wheat Board, even to the extent of allowing himself to be questioned (Canberra Times Forum 25/2/06, page B1).
A nuclear weapon produces over 300 radioisotopes, as well as including more than 80% of the very dangerous plutonium and uranium that were present but did not take part in the fission process and other materials used in the construction of the weapon such as beryllium and aluminium. These were all vaporised in the fireball and left behind in an aerosol format. Also, these were experimental weapons, with additives being tested for scientific and military purposes,e.g. cobalt-60, thorium-228, scandium-45, highly enriched uranium, lead chromate, etc. Early tower material (iron), later tower material (aluminium) and HMS Plym were also contained within the fireball and would have been vaporised and distributed, mainly as aerosol oxides.
One of the most important health hazards resulted from the inhalation of these materials into the lung where some stay and the others seek out a particular organ or tissue. Their radioactive emissions are then concentrated within that organ where their localised effects are out of all proportion when they are compared with the diluting effect of spreading this particular dose over the whole body as is done in the Study. It is stated in the study that the dose conversion factor takes account of the organ in which the material is concentrated. Other radionuclides will not necessarily concentrate in the same organ and will therefore not affect that organ. It follows that the material isolated in one organ, and its radioactive daughters, are the only materials available to affect that organ and this will occur from Day 1. The practice of leaving such nuclides out of consideration for extended periods and until they are no longer a minor element of the overall external dose is making an invalid assessment for the range of organs that attract a particular radionuclide.
One particular example occurs when alpha producing plutonium (often described as the most dangerous substance known to man) is lodged in the bony structures surrounding the sensitive blood forming bone marrow. This situation can damage the blood producing system located in the bone marrow resulting in downgraded immune and auto-immune systems. Disorders in these systems can cause cancer, reduce the body’s ability to repel disease as well as provide an inappropriate response to a foreign substance or even the body’s own tissues. The existence of this avenue of infection has also been ignored because the majority of adverse health outcomes are not necessarily carcinogenic.
Because Depleted Uranium (DU) has a comparatively low level of radioactivity, it has been discarded from overall dosage considerations. This action has resulted from a purely dosage consideration that provides no assessment of uranium’s chemical toxicity or possibly related synergistic effects. Highly Enriched Uranium (HEU) was used in large amounts in some weapons and some Minor Trials. The hundreds of times more radioactive isotopes contained in HEU have also been dropped from consideration.
The US has taken the chemically toxic characteristics of DU seriously. The US Federal Aviation Administration has produced Advisory Circular No 20-123 “Avoiding or Minimizing Encounters with Aircraft Equipped with Depleted Uranium Balance Weights during Accident Investigations” which contains the following directions:
* “The main hazard associated with DU is the harmful effect the material could have if it enters the body. If particles are inhaled or ingested, they can be chemically toxic and cause a significant and long lasting irradiation of internal tissues.”
* “On arrival at accident scenes of aircraft suspected of containing balance weights made of DU, determine if balance weights have been damaged or lost their cadmium plating coating.”
* “If it becomes necessary to handle balance weights, the following precautions should be observed:
o Personnel handling the balance weight should wear gloves.
o Industrial eye protection should be worn.
o Respirator mask should be worn to ensure no radioactive dust particle ingestion.”
In a book by the Australian Government Institute of Criminology on Wayward Governance titled “Australian Studies in Law, Crime and Justice” a study is made of breaches of law by agents of the state and the many ways in which citizens may be harmed by the actions of their government. The following are extracts from Chapter 16, “A Toxic Legacy: British Nuclear Weapons Testing in Australia” concerning the protection of the uranium industry at the expense of its relevance to the health of nuclear veterans:
* “The Fraser government, anxious to minimise embarrassment in general and to minimise any political threats to the burgeoning Australian industry in particular, quickly asked the British government to remove that plutonium which existed in a recoverable form.”
* “Committed to the continued mining and export of uranium, Australian officials were disinclined to dwell extensively on the mistakes of the past, or to highlight the risks posed by radioactive substances. Concerned about reducing government expenditure, they sought to reduce outlays for compensation. The generosity which had led previous Australian governments to spend millions of dollars to host the British tests had become a thing of the past.”
It took many years and the Navy experience with beryllium tips used in Jason Pistols, to force the Study to accept beryllium (neutron reflecting shell in nuclear weapons) as a carcinogenic substance. The diagnosis of berylliosis depends on the patient’s knowledge of an association with beryllium. Because of the strict secrecy conditions surrounding weapon components, neither the patient nor his physician would have had access to this knowledge. Similar lung diseases such as mesothelioma, sarcoidosis, pneumonia, silicosis, aluminosis, stannosis, siderosis, etc. would have been diagnosed and never associated with the nuclear tests. Chronic beryllium disease is incurable and if the lungs are severely damaged, the patient may experience fatal heart failure resulting from the strain placed on his heart, the underlying cause not being recognised on the death certificate. Death from berylliosis, that had previously been diagnosed as mesothelioma (one of the possibilities), would not have been recorded as either of these diseases before 1997 when ICD-10 coding was introduced. Where any of these diseases have occurred in nuclear veterans, its prevalence needs to be related, or not related, to operations in Active areas and suitable consideration given to the probable origin.
Paragraph 4.6 of the AWRE report R. H. Miscellaneous 2 – Protective Clothing, prepared by Capt WN Saxby, describes the use of War Department Mark VI respirators as part of the protective clothing equipment used during Operation Hurricane. It describes the container screwed to the inlet valve as “The containers carried the filtering material which was asbestos wool, acting as a particulate filter only.” It is understood that these respirators continued in use during the post Hurricane operations and during Operation Totem, and possibly in later Minor and Major trials. It is not within the competence of the Adelaide University Study team to assign a reasonable percentage of test employments to participants, one indicative case being the identification of those who would have worn respirators equipped with asbestos wool filters.
The literal interpretation of the Terms of Reference has resulted in no consideration of lung diseases, many carcinogenic, resulting from inorganic aerosols exiting the fireball. Some examples follow:
* silica drawn from the surrounding surface into the fireball when the shock wave reverses direction.
* Iron from early weapon towers and parts of HMS Plym vaporised in the fireball.
* Aluminium from later weapon towers vaporised in the fireball.
* Material such as generators, weapon assembly sheds and security fences left at the detonation site.
Genetic damage resulting in impaired fertility, miscarriages, stillbirths, deformities and future generational effects that are not necessarily carcinogenic is an area that the Government is historically unwilling to investigate. The Donovan Health Study found 48 out of 339 Australian participants reported infertility for periods over 2 years. Medical enquiries confirmed 21 of these cases, the others could not be identified or their records could not be traced. In a telegram from the UK Prime Minister’s Office to the Lord President’s Office on 16 Nov 55, it is stated “The Prime Minister saw the report from Sir Harold Himsworth about the report of the Committee considering the Genetic effects of Nuclear Radiation. His comment was:- A pity, but we cannot help it.” Sir Harold was in charge of the Medical Research Council Panel set up to assist Dr Penney in the formulation of dosage regulations for Hurricane. This attitude, condoned at the highest level, would not have placed a high priority on the radiological safety of participants.
The impact of internally produced radiation on the neurological system has been foreshadowed by the Japanese “Bura Bura” disease, related to the atom bombs detonated high over Hiroshima and Nagasaki, and the chronic fatigue syndrome (“Vegetative-Vascula Dystonia” and “Osteoalgetic Syndrome”) observed after Chernobyl. It has been indicated to DVA that a genetic study of NZ nuclear veterans is being conducted by the Institute of Molecular Bioscience at the Massey University. This study does not appear to hold any interest for DVA. It is understood that the Massey University has made the following strong interim recommendations resulting from their findings in the Pilot Study:
1. The nuclear test veterans be offered assistance in helping them cope with the chronic stress that at least some of them are experiencing. As long as the situation they find themselves in remains unresolved, stress levels will remain elevated. Learning stress management techniques is not to be seen as a solution to the issues arising from nuclear radiation exposure: rather, it offers a way of reducing the risk of ill health that accompanies chronic stress, until a solution is found.
2. Compared to the Control participants, it is clear that quality of life is compromised for at least some of the nuclear test veterans. Developing strategies for addressing these health inequalities is a matter of some urgency.
Both the Minister and DVA have been advised of the New Zealand Nuclear Test Veterans Study, but have selected to ignore its existence. Mr Ric Johnstone has approached an eminant Australian scientist and asked him to comment on the Pilot Project (Psychological Impact). He agrees with the methodology and the findings and stated that the findings might be expected to apply equally to Australian Nuclear Veterans.
Restricting the Study to cancer and mortality statistics from this complexity of medical outcomes is not only superficial but continues the lack of a duty of care practiced by the Government in its treatment of nuclear veterans. It seems remarkable that some indication of this medical inter-relationship was not forthcoming from the range of medical expertise involved in the Study. Delaying this study for half a century is negligent in the extreme and does not reflect the speed or size of compensation afforded to a parliamentarian when he fell off his pushbike.
Not undertaking a complete and integrated health investigation of the nuclear veterans has resulted in a severely repressed medical assessment.
The Dosimetry Study has concentrated on the requirements of planning documents and regulations when investigating radiological safety, but has not examined the implementation changes and errors that were revealed during the Royal Commission interrogations. Any discussion of mismanagement and regulation violations were treated as low level and isolated incidents. There has been no attempt to put together a complete picture of the errors and violations that occurred in the implementation of the Health Physics plan. One of the early examples is the minimisation of the importance of the lack of health physics safety procedures, including the availability of decontamination facilities, that were not provided to the crew of HMAS Koala and the RAAF air and ground crews during Operation Hurricane. Also, it is surprising that the Study did not notice that the first re-entry to the vicinity of the Hurricane GZ was Australian and may have been by the crew of HMAS Koala, the vessel responsible for dragging the Lagoon floor and recovering parts of HMS Plym on the day of the explosion (the alternative candidate, in charge of the initial entry from HMS Tracker was Wing Cmd Thomas, also Australian). The attachment must be read to understand the full impact of non compliance with safety regulations.
Many of the AWRE Reports, currently quoted by the Study, were not so acceptable to senior AWRE staff. An internal AWRE memo written by Pearson (JT Tomblin dept) on 22 Aug 55 stated:
“There remains the question of reporting on these tests, and here we are very conscious of the delays that have occurred in publishing and distributing information from past trials, for which we have been subjected to criticism both at home and overseas. Apart from the general difficulty of getting staff to write reports after the event, much of the trouble has been that each past trial has been an urgent ad hoc affair under a planning staff pressed into service from different departments, none of them with a continuing interest.”
The memo goes on to discuss the difficulty experienced in obtaining Australian and Canadian participation in the preparation of these reports. An example of a major misleading statement, concerning the unexpected exposure of an Australian health physics surveyor (the Sgt Smith incident), can be seen in the Health Physics Report for Antler (Maj McDougall et al), where this particular task was described as being undertaken by the RAF Regiment. See attachment and Royal Commission Report for controversial detail.
See comments in the attachment on data reviewed in the Dosimetry Report for a list of critical Royal Commission documents that do not appear to have been researched by the Study. Important records that are still missing, such as Ship’s Logs and Reports of Proceedings for the month of Hurricane and Hospital records for Maralinga, Emu Fields and Amberley should have been acknowledged as areas of deficiency in the Study. Available in the Australian National Archives are some indispensable files, compiled by the Royal Commission, that appear to have been overlooked by the Study:
* The Australian Collation, consisting of 96 Volumes in chronological order. RC800 Series.
* Bundle of paginated documents collected from the Ministry of Defence, London, consisting of 11 Volumes. RC558 Series.
* Bundle of documents collected from the Foreign Commonwealth Relations Office, London, consisting of 6 Parts. RC559 Series.
* Transcript of Proceedings, consisting of 17 Volumes. A6448 Series.
* Keyword Index to Transcript. A6483 Series.
Ignoring the content of these files will prove disasterous to any study concerning nuclear veterans. A consequential outcome is that the Study may have relied on material from studies and investigations that have also not taken these very comprehensive collections into their considerations.
It must also be explained in the report that if DVA has not acessed material that is closed to the Public, then the Study cannot be effectively completed until the years 2015 – 2016.
Too much importance appears to have been placed on the completeness of ARPANSA records. These were collected in the main by Mr Turner, the Australian Health Physics Representative who was only present at Maralinga and was not privy to the majority of UK classified material. Except for certain restricted releases after the Royal Commission, ARPANSA would have gathered very little on the Monte Bello Islands or on the tests at Emu Field. I have records showing that much of the material collected by Mr Turner and Mr Moroney (CXRL employee involved during and after Antler) was destroyed or handed to other Departments where it is no longer accessible.
Where Have all the Dosage Records Gone?
Dosage records for participants that were not collected, were surmised, were removed from the records or have been lost, include groups that were represented in all tests and who operated in areas of higher contamination risk e.g.:
* RAAF Lincoln air and ground crews collecting cloud samples during Hurricane and Totem 1. No safety precautions and no records initiated.
* HMAS Koala crew, who dragged the bottom of the Lagoon for parts of HMS Plym immediately after the Hurricane detonation and later recovered and disposed of a sunken and contaminated landing craft. Most of the crew changed with the crew of HMAS Karangi and were involved in the later recovery of contaminated marking and mooring buoys after Hurricane. No safety precautions and no records.
* HMAS Hawkesbury crew present during and 3 1/2 months after Hurricane, where a universal dose for the crew stated a highly suspicious “below 20 millirem”.
* Various ships crews and others carrying out surveys and recovery tasks at the Monte Bello Islands during the Hurricane/Mosaic inter-trial period, as well as the post Mosaic period. Health Physics safety procedures were only available at a primitive level, if at all, and no records kept.
* The 13 Australian VIPs that inspected the target response equipments five days after Totem 1 included the Scientific Advisor to the Military Board and his Staff Officer. They stated in their after action report that all individual dosimeters exceeded full scale readings and it was estimated that the party received one roentgen by driving around the centre of the contaminated area (contamination from equipment inspection not estimated). UK BDRSS advised a controversial statement of exposures that ranged from 0.05 – 0.13 R for gamma, and when aggregated with beta 0.16 – 0.24 R. DVA has omitted these people from the Nominal Roll and therefore from cancer and mortality considerations.
* Indoctrinee Force at Buffalo was almost all shown with a dose of “below 400 millirem” that does not fit the variety of circumstances of their indoctrination and assistance to the Target Response Group.
* Engineer Group at Buffalo. Almost entirely employed in the Forward Area with no dosages recorded.
* Various groups employed during the Buffalo/Antler inter-trial period (see attachment for some of the functions carried out in the Yellow area). Film badges were processed by CXRL, but are no longer available. A dosage list for the month of May 1957 has been recovered from other sources.
* Engineer Group at Antler. Almost entirely employed in the Forward Area with few (about 5) dosages recorded. Film badge issue and recording sheets have been found for one day, about 2 weeks prior to Antler for a Blue Area showing some otherwise unrecorded dosages. Blue was the lowest level of contamination, no special protective clothing required, it was unmarked and was not otherwise defined except as being the Forward Area, where they were accomodated.
Not included in the above list. On 1 August 1957, the Australian Health Physics Representative reported to the Atomic Weapons Test Safety Committee (AWTSC) “that only a proportion of the film badges had been processed during the Buffalo operation”. This lack of efficiency on the part of the Buffalo Health Physics management organisation did not appear to draw a rebuke from the AWTSC or any follow-up action for Antler. Many of these groups have theoretical dosage assessments that do not make sense when compared with the practical readings of the inter-trial JSTU unit that was employed between Hurricane and Mosaic.
These situations have had adverse effects on compensation claimants when they have been asked to provide evidence of exposure, an essential prerequisite to a successful claim.
References to Watch
A general comment on the inappropriateness of using comparative health incidence statistics experienced by workers employed by other industry or government installations. These people worked on routine tasks where their dose could be predicted and fully controlled. They were normally protected from inhalation hazards, did not operate under primitive field conditions and were controlled at the working level by Health Physics Technicians who had more than a few weeks training. By today’s standards, much of the implementation of radiological safety requirements during the UK tests would have been criminally negligent.
Epidemiology routinely looks for large scale studies of many people using known contaminants over a long period. The only factor readily available in this study is a long period and this is marred by an initial gap of 30 years from Operation Hurricane before any attempt was made by the government to gather general health statistics that could be relevant to the current Study. The Study has attempted to confine its examination of the proliferation of the many hundreds of radioactive and chemical contaminants resulting in a large variety of deleterious health effects, within an overly restrictive cancer field. Instead of taking a less conservative approach, the Study has operated within a strictly compartmentalized environment, avoiding any attempt to identify the inter-relationship between the multitude of causative agents and the many potential adverse health outcomes.
The methodology used in the Study’s construction and implementation has been enshrouded in secrecy, even the sub-groups involved not being allowed a full and frank interchange of information. Assistance has never been requested from the Consultative Forum, where the circulation of earlier draft reports may have avoided last minute and less than comprehensive comments from the Consultative Forum. This is a ridiculous situation, particularly when the medical-in-confidence information used in the study is confined to a participants health condition, and this is normally contained in the various government registries where it is only released as depersonalised statistics. Some of this health information however, may already be in the public forum, apparently preventing access to co-located data of potential importance to the Study. This circumstance could have been easily fixed by a properly constructed research plan that filtered out health data concerning a particular participant before it was formally presented to the interested area(s). Because of the importance of research to all areas of the Study, this function should have been managed by DVA, where advantage could be taken of its use in other areas, such as the construction of a knowledge base for use by Delegates handling nuclear veteran compensation claims.
Much of the material concerning participant’s health before 1985 is available publicly in the final submission of Counsel Assisting the Royal Commission (Archives RC861). This document should have been of importance to the Study and should not have been excluded from the study because it contained personal information.
Disregarding the biological attraction of certain organs and tissues for particular radionuclides, has resulted in the dose for such a nuclide being diluted as a whole body dose, rather than considering its very much more concentrated effect within its host organ or tissue. It follows that omitting this step will then overlook the unique set of risk factors that can result in a series of particular health outcomes. This significant break in the investigative chain, resulting in the use of external possibly unrelated data, has left the study with no means of firmly basing its health assessments on information that should have been made available from within the Study, placing the overall validity of the Study in question.
This breakdown in Study continuity should have been obvious to the DVA managers and their health specialist, who were represented at most of the committee and sub-committee meetings.
A well designed Pilot Study would have demonstrated these failures and allowed a correct mix of expertise to be assembled. Other areas of improvement that should have been discovered, include a need for overall control of research, as well as improved management and intercommunication facilities between different Study areas. The re-use of data from the discredited Donovan Study, if originally checked in detail, would have avoided the series of adhoc running repairs that still do not appear to have been completed. The lack of a well designed quality assurance check of this data has introduced both selection and information bias.
It is considered that the research, planning and management of this extremely complicated and medically interwoven Epidemiological Study is beyond the current technical competence of DVA. Confidence in the conduct of this Study, that has stumbled from pillar to post during the last five years, must be estimated as well below 50%.