Letter to Governor General from Major Alan Batchelor

29 March 2011
Her Excellency Ms Quentin Bryce AC
Governor-General of the Commonwealth of Australia
Government House
Dunrossil Drive

Your Excellency


This submission is made to the Governor General in Council in accordance with Australian Military Regulations and Orders as they existed in the 1950s. It requests a review and cancellation of the currently accepted study of the health of Australian nuclear veterans contained in Australian Participants in British Nuclear Tests in Australia by Dr Gun et al. Both the hazardous environments and resulting detriments to the health of many nuclear veterans have been incorrectly assessed in this document, leading to many false exposure and compensation assumptions that also need revision and remedial action.

[A summary is available on page10]


The basis on which the Cancer and Mortality Study was constructed omits several important areas of consideration and makes no effort to explain the effect of these omissions.
• It confined the study to the carcinogenic effects of ionising radiation, ignoring:
o Non-carcinogenic effects following exposure to internal radioactive emitters with long biological half-lifes resulting in;
• Loss of immune competence,
• Short and long term sterility, miscarriages, stillbirths, etc,
• Heredity defects in subsequent generations,
• Accelerated aging, and/or
• Psychological damage;
o Carcinogenic effects of non-ionising materials also present at the tests such as;
• About 30 kg of beryllium used as a fast neutron reflector in some weapons,
• Asbestos wool particulate filters used in WW2 gas masks as an expedient in protective clothing;
• The range of health effects (such as “radiation sickness”) suffered by nuclear veterans during the tests was concealed from the study by the non-production of relevant records from:
o Operation Hurricane “Health” ship (HMS ZEEBRUGGE);
o The Emu and Maralinga hospitals and related outstations.
o RAAF Base Hospital Amberley:
o RAAF Woomera Hospital.
• The availability of a dosage document by the UK Government “Listing of Persons at UK Overseas Defence Nuclear Experimental Programmes – Citizens of Australia” (known as the “Blue Book”) has resulted in a lessened appreciation of the hazardous dosages actually present
o Servicemen working in highly exposed situations have been omitted, eg;
• Crew of HMAS KOALA responsible for dragging the floor of the Monte Bello Lagoon almost immediately after detonation and many subsequent days,
• Aircrew, ground-crew and decontamination parties involved with fallout cloud collection sorties after Hurricane and Totem 1 (film badges were not issued);
• Yellow entry training during inter-trial period at Maralinga;
• Vehicle mechanics recovering yellow vehicle breakdowns;
• Buffalo and Antler military engineers engaged on tasks such as telemetry retrieval functions commencing shortly after detonation;
• Many “Indoctrinee Force” servicemen;
o No mention was made of doses resulting from inhaled/ingested radioactive material, particularly where long biological half-lives were involved;
o Many other film badges had not been processed;
o In any case, the UK denied responsibility for the document’s content (page (ii)).
• Statistics collected before 1982 were mainly collected from Death Certificates, leaving both cancer and cancer mortality incidence between 1952 and 1981 open to question;
• Work program, re-entry schedule and task allocation documentation have long since disappeared. The linking of individuals to the possibly numerous range of their employments and then summing the total dosage for each individual was well beyond the capabilities of the Dosimetry subcommittee. This resulted in guesswork based on a person’s basic trade, ship’s name, corps designation, etc (limited by the entry in the “job” field of the information spreadsheet);
• An estimated constant gamma dose rate of 0.01 mSv/hr was used for calculations involving gamma exposure. No adjustments were made for weapon yield, distance from GZ, time post detonation or other environmental factors. This formula tends to level out dosages resulting from high exposure situations, particularly Immediate and Early Re-entry tasks involving dusty inhalation/ingestion conditions.
• The above background discussion provides a number of conditions that reduce the viability of the Cancer and Mortality Study and should have, as a minimum, been taken into account in the findings. In addition, Royal Commission Conclusion 201 (15.6.13) goes even further and questions the feasibility of attempting such a study:

“Because of the deficiencies in the available data, there is now little prospect of carrying out any worthwhile epidemiological study of those involved in the tests nor of others who might have been directly affected by them.”


There are a number of factors that have adversely affected the integrity of the Cancer and Mortality Study.

Scientific Bias. Bias is the act of presenting a partial perspective at the expense of possibly equal or better alternatives. If a study is to be scientifically coherent, it must avoid bias and present facts and other valid points of view that may have a bearing on the outcome. Government influence, including overt and covert censorship, bias in the media, market influence ((including the nuclear industry), author selection, etc, are all areas of potential bias.

The Cancer and Mortality Study includes references to a number of other studies that provide support in a mutually cyclic manner. They omit mention of many other studies by reputable scientists/organisations that question the methodology adopted by the Cancer and Mortality Study. Some examples are as follows:
• Dr Keith Baverstock, previously head of the Radiation Protection Division of the World Health Organisation and currently Department of Environmental Sciences, University of Kuopia, Finland. In his paper “Science, Politics and Ethics in the Low Dose Debate,” he points out the following problems in the British NRPB study of UK Nuclear Veterans (many references in the Cancer and Mortality Study) and other study areas;
o When a large excess of leukaemia was found in comparison with the controls, a scientifically unacceptable alternative comparison was made with the general population where the undesirable excess disappeared,
o Further UK Nuclear Veterans discovered in 1988 were not included in the original NRPB Study, revealing the omission of 30% of multiple myeloma cases,
o The lack of dosimetric data did not justify the lumping together of exposed and unexposed individual dose assessments,
o It is clear that the science and associated ethics have been perverted for political ends,
o Uranium is chemically toxic and its geno-toxicity should be assessed together with its radioactive properties and bystander effects,
o The ICRP routinely uses essentially untested models to determine the risks from internal emitters.
• Professor Shoji Sawada is a theoretical particle physicist and Emeritus professor at Nagaya University. He has written a paper titled “ Cover-up of the Effects of Internal Exposure by Residual Radiation from the Atomic Bombing of Hiroshima and Nagasaki” accepted 3 Oct 2006. The paper, based on inadequate dosage assessments, inappropriate comparison groupings and US concealment of weapon effects, disagrees with the epidemiological research carried out by the Radiation Effects Research Foundation (RERF). The ICRP dosage model is identified as being based on the RERF studies where the effects of internal exposures were given little attention. The Protocol for the Cancer and Mortality study places a great deal of reliance on the RERF studies (Vol 2, pp 119-124) as well as the ICRP dosage model.

The following abstract from the Professor’s paper identifies the origin of many of the incorrect findings in the Cancer and Mortality Study and referenced studies:

“The criteria certifying atomic bomb disease adopted by the Japanese government are very different from the actual state of the survivors. The criteria are based on epidemiological research by the Radiation Effects Research Foundation, the successor to the Atomic Bomb Casualty Commission (ABCC). The ABCC studied only the effects of primary radiation from the atomic bombing on the survivors of Hiroshima and Nagasaki, and ignored the damage from residual radiation. Analysis of acute radiation disease, the rate of chromosomal aberrations, and the relative risks of chronic disease among the survivors, shows that the effects of residual radiation from fallout exceeds that of primary radiation in the area more than 1.5-1.7 km distant from the hypocentre of the Hiroshima bombing. The effects of internal exposure due to intake of tiny radioactive particles are more severe than those of external exposure, explaining the difference between the official criteria and the actual state of the survivors.”

• Australian Institute of Criminology. In a book titled “Wayward Governance: Illegality and its Control in the Public Sector,” Chapter 16 is devoted to “A Toxic Legacy : British Nuclear Weapons Testing in Australia”. It provides a brief but comprehensive coverage of the British nuclear tests held in Australia. The Chapter illustrates some of the many ways in which nuclear veterans may have been harmed by the actions of the two governments concerned:
o Public debate on the costs and risks borne by the Australian public was discouraged through official secrecy, censorship, misinformation and attempts to denigrate critics;
o D-notices were applied in such a manner that Australian journalists were forbidden from reporting items which had already been published freely in the UK;
o The Atomic Weapons Tests Safety Committee (AWTSC) was more sensitive to the needs of the British testing program than to its Australian constituents.;
o The AWTSC was criticised as ‘deceitful’ and having allowed unsafe firing to occur;
o Agreed with the Royal Commission statement that Professor Titterton (AWTSC) may have been more a de facto member of the British Atomic Weapons Research Establishment than a custodian of the Australian public interest;
o 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 minimise outlays for compensation. The generosity which led previous Australian governments to spend millions of dollars to host the British tests had become a thing of the past;
o The major obstacle faced by claimants was the formidable task of proving that their disability resulted from exposure to radiation produced by the tests. The task was compounded by the fact that in these cases, the ex-service claimants are totally dependent upon their former employer for the evidence necessary to present their case;
o Cancer has many causes, and to demonstrate conclusively that a particular case was caused by Maralinga exposure and not by smoking, diet, exposure to X-rays, or some inherited predisposition is extremely difficult. The Royal Commission’s recommendation that the onus of proof be borne by the government was not accepted. For this reason, most claims have thus far been unsuccessful;
o The Commonwealth government, concerned over the possibility of having to defend common law actions alleging negligence in its involvement in the testing program, vigorously contested each claim. Public assurances that the nuclear veterans were being well looked after did not appear to be borne out in the courts and hearing rooms of Australia.

• European Committee on Radiation Risk (ECRR). This Committee was formed in 1997 by the European Parliament to examine the Basic Safety Standards Directive (Directive Euratom 96/29). There were 46 members and advisors whose research and advice contributed to the “2003 Recommendations of the European Committee on Radiation Risk” published as “Health Effects of Ionising Radiation Exposure at Low Doses for Radiation Protection Purposes”. The listing of members contained in Chapter 15 is preceded by the following declaration:

“At 5th November 2002 the following individuals are members, advisors or consultees of the ECCR. Their inclusion in this list may not mean that they endorse all the contents of the report but does imply that they are convinced that the ICRP system of modeling seriously underestimates the risk from low level ionising radiation from anthropogenic sources.”

The ECCR concluded “that ICRP models have not arisen out of accepted scientific method. Specifically, ICRP has applied the results of external acute radiation exposure to internal chronic exposures from point sources and has relied mainly on physical models for radiation action to support this. However, these are averaging models and cannot apply to the probabilistic exposures that occur at the cell level. A cell is either hit or not hit, minimum impact is that of a hit and impact increases in multiples of this minimum impact, spread over time, Thus, the committee concludes that the epidemiological evidence of internal exposures must take precedence over mechanistic theory based models in assessing radiation risk from internal sources.”

The ICRP risk model makes assumptions that are based on value judgments that do not support its use as the basis for the Dosimetry study. This has resulted in dosage estimates in the Cancer and Mortality study that run counter to actual dosage records and epidemiological results. This is despite the exposure dilution and over-simplification of task identification applied in the dosimetry estimates. The Cancer and Mortality study has not been able to address ionisation density in time and space at the cellular level placing its viability in question.

• Dr Rosalie Bertell Ph. D., GNSH, on 21 Apr 1998, provided testimony to the United States Senate Committee on Veterans’ Affairs. She was a biometrician (specialty in mathematics applied to biomedical problems). In her testimony she addressed two major questions, mainly based on the errors carried forward from the ABCC and RERF studies of the Hiroshima and Nagasaki bomb casualties. Her statement commented on the basic factors used for dose reconstruction in the determination of causality for cancer or other radiation diseases:
o The atomic bomb study radiation risk factors apply directly only to external radiation, high dose and fast dose rate exposure. This research says nothing about the internal contamination with radio-nuclides experienced by any veteran participating in the Hiroshima and Nagasaki cleanup, in atmospheric weapon testing, or in radium implants. This research says nothing about the incorporation of radio-nuclides into bone with the subsequent long term chronic irradiation of the surrounding tissue;
o The Atomic Bomb Research was not designed to establish a dose below which exposure was “safe”. Had this been the case, careful examination of the harm from low dose exposures would have been mandatory;
o The atomic bomb researchers assumed (but did not demonstrate or prove) that below 1 rem exposure from the original bomb blast no radiation related cancer deaths would occur. Therefore this data base can tell us nothing about such low dose exposures because the researchers assumed their exposure was “safe” and did not test for an effect. In philosophy we call this “begging the question” and it results in an invalid “proof”;
o Atomic bomb research generally assumes that the only damage one should care about (clearly a self-serving judgement not a scientific fact) is direct damage to DNA which results in a cancer which is fatal. The Hiroshima and Nagasaki research on cancer incidence rates was not published until 1994. A comprehensive report on other chronic disease prevalence has never been forthcoming.;
o When the un-repaired or mis-repaired damage due to radiation, occurs in the germ cells, sperm (and stem cells which produce sperm) or ovum, that damage will be incorporated into every cell of the offspring made from that damaged DNA. It may show up as a miscarriage, still birth, teen age cancer or mid-life heart disease, but these are not considered to be “detriments” – another value judgment and not a scientific fact;
o It should be very clear that the Radiation Research which had been done by the ABCC and RERF has never clearly addressed the problems of non-cancer effects of exposure, Instead, they have relied on their earlier judgment that these other biological endpoints were “not of concern” and should not be studied. Cancer incidence rates were not even reported until 1994. Incidence rates for other chronic diseases have not yet even been collected in the data base, which is concerned with first cause of death. A disease like neuralgia is not likely to be the first cause of death;
o None of this mathematical reconstruction actually measures the dose which really initiated a cancer process. This dose would likely be localised to a few dozen cells in the immediate vicinity of the internal radionuclide, and these cells would constitute a very small part of an organ or tissue. When this concentrated energy release is converted to an average dose to the whole organ, and that organ dose is weighted to give an estimate of effective equivalent whole body dose, the dose appears to be very small, but locally it is significant because of its concentration.
• Professor C D’Arcy J Holman, University of Western Australia, published an article in the Australian and New Zealand Journal of Public Health titled “A Survey of Suppression of Health Information by Australian Governments” (submitted June 2007). He warned that Australia may be slipping from its formerly enviable position of relative freedom from political censorship and official corruption.

It may not have been by chance that Professor Holman undertook his research after completing his participation as a member of the Scientific Advisory Committee for the Cancer and Mortality study. It should also be noted that the Professor did not attend the last meeting of the Scientific Advisory Committee (May 2006) where the Cancer and Mortality Study received its initial approval.

In the results it was stated that “The rates were higher in 2005/06 than in earlier years. No State or Territory was immune from suppression. Although governments most commonly hindered research by sanitizing, delaying or prohibiting publications (66% of events), no part of the research process was unaffected. Researchers commonly believed their work was targeted because it drew attention to failings in health services (48%), the health status of vulnerable groups (26%), or pointed to a harm in the environment (11%). The government agency seeking to suppress the health information mostly succeeded (87%) and, consequently, the public was left uninformed or given a false impression. Respondents identified a full range of participative, cognitive, structural and legislative control strategies.

It was concluded that “The suppression of public health information is widely practised by Australian governments.”

International Commission on Radiological Protection (ICRP) In its assessments of internal radiation dosages, the Dosimetry study has placed a great deal of reliance on the tables published by the ICRP. The intended result was to make a retrospective assessment of organ/tissue dose for use in an epidemiological study. The legitimacy of the Dosimetry study using the ICRP risk model for this purpose is placed in serious question by the following ICRP statement (http://www.icrp.org/c2_fl.asp). Statement recently removed without explanation.

“It is not appropriate in all circumstances and guidance is given on when its use is not appropriate, for example in retrospective assessments of organ/tissue dose for epidemiological studies, in individual risk assessments after exposures above dose limits and especially after exposures to high radiation doses.”

The objectivity of the ICRP radiation risk model has been questioned for many years. The following extracts are relevant:
• “Comments by Professor Dr Chris Busby B Sc, Ph D, C Chem, MRSC concerning the death of a soldier exposed to uranium weapons during Gulf War 1;
o “The area of radiation risk from internal exposures is one of major and polarised scientific controversy. However, more and more evidence is appearing in the peer-review literature and the grey literature also, both from epidemiology and from laboratory experiments or theoretical work, that there are many serious shortcomings with the current risk model, that of the ICRP.”
o “The ICRP models cancer on a quantity termed ‘absorbed dose’ which is defined as energy per unit mass. This is an average of the ionisation over large amounts of tissue, kilograms, and is a reasonable unit for quantifying the effects of external radiation e.g. from an atom bomb’s gamma rays but is not scientifically justified for internal anisotropic radiations where there are large doses in one place and no dose everywhere else. An analogy would be to compare the same acquired by warming oneself in front of a fire with eating a red hot coal. This ‘hot particle effect’ has been the basis for most of the arguments about cancer and DU (and indeed also plutonium and fuel particles after Chernobyl and the atomic tests and near nuclear power stations).”
o “To back up their position large sums of money are given to ‘safe’ research scientists to conduct research or to produce reports that back up this position. The veterans have no money for their own research and few scientific advisors. Any other affiliated scientist soon gets to learn the disadvantage of opposing the military, the government or industry (who largely pay for all research, and hence all the wages and mortgages). The bias that exists in the science policy interface is horrifying.”
• In a paper prepared by Dr Rosalie Bertell, “Limitations of the ICRP Recommendations for Worker and Public Protection from Ionising Radiation” she discusses the viability of the data collected from atomic bomb studies (ABCC and RERF) and the closed composition of ICRP:
o “The atomic bomb studies followed, and did not precede the setting of the radiation protection guidelines recommended by ICRP and followed internationally until 1990. The main recommendations were set in 1952, and the first doses assigned to A-bomb survivors were not available until 1965. Moreover, the research was designed to determine the effects of an atomic bomb, not the health effects of exposure to ionizing radiation. The research was undertaken by military researchers from both the US and Japan familiar with and primarily concerned with military use of atomic, chemical and biological warfare agents. The research has come too late for standard setting needs, it has focused on cancer deaths, is uncorrected for healthy survivor effect, and is not inclusive of all of the radiation exposures of cases and controls (dose calculations omit fallout, residual ground radiation, contamination of the food and water, and individual medical X-ray), and fails to include all relevant biological mechanisms and endpoints of concern.”
o “It is normally claimed that biological basis of the cancer death risk estimates used by ICRP, is the atomic bomb studies. However, these studies are not studies of radiation health effects, but of the effects of an atomic bomb. For example, the radiation dose received by the Hiroshima and Nagasaki survivors from fallout, contamination of food, water and air, has never even been calculated. Only the initial bomb blast, modified by personal shielding, is included in the US Oak Ridge National Laboratory assigned “dose”.
o “The data base for the Hiroshima and Nagasaki Life Span Study, the basis for the mortality estimates, was first identified in the 1950 Japanese Census. The information was not collected and ready for analysis until around 1957, and because it depends on first cause of death information, it was based on only a small percentage of deaths for the first seven years. It was heavily dependent on the accuracy of death certificates. Deaths in the Hiroshima and Nagasaki population between 1945 and 1950 are not included in the study.”
o “Although the A-bomb scientists have now admitted that more cancers were caused per unit dose of radiation than previously thought, ICRP has now given itself risk reduction factors for slow dose rate and low dose. This introduction of an unsubstantiated “correction factor” gives evidence of the inadequacy of the data base to answer important questions about worker and public exposures, which are almost all at low doses and slow dose rate. It also indicates that the ICRP knows that it is inadequate. There is no supporting human evidence for this reduction of the risk factors, and considerable evidence that it is not warranted.”
o “The ICRP is profoundly undemocratic and unprofessionally constituted. It is self- appointed and self-perpetuated. Certainly a recommending body could be composed of individuals elected from professional societies such as international associations of professionals trained in occupational health, epidemiology, public health, neonatology, pediatrics, oncology, etc.”
o “The ICRP assume no responsibility for the consequences attributable to a country following its recommendations. They stress that the Regulations are made and adopted by each National Regulatory Agency, and it merely recommends. However, on the National level, governments say they cannot afford to do the research to set radiation regulations, therefore they accept the ICRP recommendations. In the real world, this make no one responsible for the deaths and disabilities caused!”

Elevated Chromosome Translocations.

North Shore Hospital, Sydney. The Centre for Genetics Education, in a Fact Sheet (7) on chromosome translocations stated that a “Change in the amount or arrangement of the genetic information in the cells may result in problems in growth, development and/or functioning of the body systems;” and these may be inherited from the parent. Miscarriages and infertility were among the outcomes identified.

Western General Hospital, Edinburgh. In 1983/4 this hospital was routinely identifying chromosome damage in patients exposed to ionising radiation from industrial or therapeutic sources. Blood samples had been collected from two British Nuclear Veterans. These had been submitted but not processed on the possibility of the Medical Research Council (MRC) being involved in an epidemiological study (blind analysis of random slides) of nuclear participants. When the National Radiological Protection Board (NRPB) accepted the study, the council went ahead and carried out an analysis of the two blood samples. One of the patients “in fact has quite a high degree of chromosome damage present in his blood cells” and “this would not be inconsistent with having received radiation exposure 20 or more years ago.” The MRC, probably on political direction, refused permission to advise the treating physicians, the patient, NRPB or to continue with the epidemiological study.

Massey University Report. This is a study investigating sister chromatid exchange in New Zealand nuclear veterans that has been published under the title of “New Zealand Nuclear Veterans’ Study – a Cytogenic Analysis.” and accepted for publication by the prestigious journal “Cytogenic and Genome Research.” It is an assessment of cytogenic damage in naval personnel on two New Zealand frigates that were present at the British nuclear tests code named Operation Grapple. “The result show elevated translocation frequencies in peripheral blood lymphocytes of New Zealand nuclear test veterans 50 years after the Operation Grapple series of nuclear tests. The difference between the veterans and the matched controls with this particular assay is highly significant. The total translocation frequency is 3 times higher in the veterans than the controls who showed normal background frequencies for men of this age group. This result is indicative of the veterans having incurred long term genetic damage as a consequence of performing their duties relating to Operation Grapple.”

Note the use of matched controls, not the local country population as used in the Australian study. In the Summary, it is stated that:

“We submit the view that the probable cause of the veterans elevated translocation frequencies is radiation exposure. This view is supported by the observation of a comparatively high dicentric chromosome score in the veterans which is characteristic of radiation exposure.”

In the Pilot Project conducted prior to the Massey University Study, the psychologic impact on the New Zealand Nuclear Veterans produced the following recommendations:

• “these veterans are offered assistance to help them cope with the chronic stress that some of them are experiencing. As long as the situation they find themselves in remains unresolved, stress levels are likely to remain high. There exist a number of useful techniques that could be taught to these men to help them cope with stress.”
• “given the clear evidence that at least some of the Exposed men are living with a compromised quality of life (in comparison to Controls and NZ men of similar age), there is an urgent need to formulate appropriate strategies that addresses these health inequalities.”

The Psychological Impact study of New Zealand nuclear veterans has been reviewed by Dr W Barclay AM MB BS MSc DPM FRANZCP who states that the findings of the report “might be expected to apply equally to Australian Nuclear Veterans.”

The occurrence of chromosomal damage in nuclear test veterans was first recognised in the UK in 1983. The suppression exercised at the time demonstrated knowledge of the potential harm to the health of a vulnerable group that should have been investigated. The much delayed reinforcing discovery by the Massey University demonstrates a health hazard that must not be ignored. The Cancer and Mortality Study requires drastic amendment as a result.

Dosage Anomolies

Tables 6.8 and 7.5. As mentioned earlier, Table 6.8 of the Dosimetry Study has set the figure for external gamma radiation estimations at 0.01 mSv/hr (as explained in the paragraph under the Table). Table 7.5 listing actual gamma readings for a member of the Joint Services Training Unit (JSTU), shows a reading of 20 mSv on D + 67. This was received during a 3 or 4 hour plant collection exercise (details in Lt Jenkinson’s statement to Royal Commission). This is 5 or more mSv/hr and at least 500 times the constant gamma dose rate used for dosimetry estimates. In addition, Jenkinson’s reading was recorded after 67 days of radioactive decay and because it involved plant collection would have been well outside the blast area. Based on their own Tables, the Dosimetry Study external dose rate estimations can not be justified.

Radiogenic Cancers. Certain cancers have been reported by UNSCEAR to be causally associated with ionising radiation (colon, liver, lung, thyroid, stomach, bladder, non-CLL leukaemia and non-melanocytic skin cancer). The Cancer and Mortality Study has identified:
• An SMR of 1.63 for cancer deaths in this group; and
• An SIR of 1.19 for cancers in this group.

These results were hidden from all but a detailed investigation, at the bottom of Tables 5.6 and 10.1. In a study concentrating on cancers “causally associated with ionising radiation,” these results should have received priority treatment in the Main Findings, not left to a chance unearthing.

Inappropriate Comparison Cohort. The study was unable to find an acceptably matched comparison cohort against which it could compare the cancer and cancer mortality statistics of the nuclear veterans. Instead, it was decided to use the readily available general Australian population statistics for this task. The methodology adopted did not make any allowance for the many differences (confounding factors) in the two populations that should have included consideration of the “Healthy Serviceman Effect”. The error involved is demonstrated when a comparison is made with the Vietnam Veteran’s cancer statistics, where the Nuclear Veterans Standardised Incidence Ratio for cancers increases from 1.23 in the Study to 2.95, despite significantly less confounding factors being involved except for a possible cause of excess cancers resulting from exposure to Agent Orange.


The criteria on which the Cancer and Mortality Study was based, omitted consideration of:
• The total range of adverse health effects (non-carcinogenic effects of ionising material and carcinogenic effects of non-ionising material) resulting from service in a nuclear weapon test area;
• The lack of data available;
• The errors identified in dosage estimation models, particularly in the area of long term, short range, internally deposited radiation emitters;
• The warning by the Royal Commission that “there is now little prospect of carrying out any worthwhile epidemiological study.”

The elimination of hospital records for all operations, in conjunction with the discriminatory British dosage records (Blue Book), where those employed in hazardous situations had been removed, could only further degrade an already dubious study.

The study was conducted without any factual information identifying which individual carried out which function (or range of functions), for how long, location(s), potential for inhalation/ingestion of resuspended hazards or handling of radioactive target response equipments. This lack of estimation data for each individual and the fallibility of other records made it almost impossible to approximate exposure levels for an individual shown in the Cancer Registry (initiated 1982).

Many prestigious scientists and scientific organisations have made it clear that the International Commission on Radiation Protection (ICRP) has made assumptions that are based on value judgements that are not soundly based. These have resulted in study estimates that are counter to epidemiological results and a number of practical dosage records. Even more importantly, the Study has not been able to address ionisation density in time and space at the cellular level. Instead it has converted the concentrated energy release to an average dose to the whole organ, and that organ dose is weighted to give an estimate of effective equivalent whole body dose that appears to be very small. This action conceals the significance of a highly concentrated locally applied dose. This was despite the ICRP not recommending the use of its risk model derivations for retrospective epidemiological studies.

The presence of excessive chromosome translocations caused by ionising radiation in nuclear veterans has been dishonestly concealed by the UK Government since 1984. The Massey University Report has rediscovered and published a similar finding, emphasising the need for investigations into the range of adverse health effects overlooked in the Cancer and Mortality Study.


AHQ Directive – Nuclear Warfare (DCGS/517). Any country that places its servicemen in harm’s way, particularly when exposure to the effects of nuclear weapons is involved, has a duty of care for their future welfare. The question of whether this exposure involved overseas service, or otherwise, is irrelevant to this undertaking. The responsibility for treating “all aspects” of any detrimental health effects resulting from exposure to the effects of nuclear weapons was made the responsibility of the Adjutant General’s Branch in DCGS/517 dated 22 Feb 1956 in the following terms:

9 (a). “All aspects of treatment of personnel subjected to the effects of nuclear weapons.”

In addition, paragraph 6 of the same Directive states that current policy requires “training personnel of all units in personal protection and in the use of radiac instruments.”

The majority of Australian personnel posted in support of Ministry of Defence operational requirements did not receive training in health physics, protective procedures or use of radiac instruments and did not receive follow-up health checks or treatment.

When this lack of care began to emerge, the Repatriation Medical Authority undertook a study completed 21 Jul 2000 titled Report of the RMA Subcommittee on Ionising Radiation Dose. The report discarded its original “sound medical-scientific evidence” that service personnel “having been within four kilometres of the epicentre of the atomic bomb explosions on either Hiroshima or Nagasaki within the seven days immediately following the explosion on either of those cities” could potentially contract and also die from certain nominated diseases. If these “sound medical-scientific evidence” conditions were applied to Australian nuclear veterans in the British nuclear tests, it would have been applicable to all immediate and early re-entrants.

The RMA report, without making an examination of the British nuclear tests in Australia, determined that certain sarcomas caused by atomic radiation would require a proven dose 10 times higher if peace service (Balance of Probabilities) was the condition of service involved. To state that operational conditions of service (Reasonable Hypothesis) only requires one tenth of the dose required in peacetime to produce the same cancer, or death from this cancer, is not based on sound medical-scientific evidence, a stated requirement in each Statement of Principles (SOP).

This biased assessment was further expressed in SOP Bulletin No 42 issued on 3 Oct 2000 and titled “New Atomic Radiation Factors in RMA SOPs Interim Advice.” Paragraph 2 effectively ignores the involvement of Australian servicemen in the British nuclear tests in Australia when it identifies those servicemen with known atomic radiation exposure as:

• “POWs who were in the Nagasaki area on 9 Aug 1945;
• Personnel who served in or visited Hiroshima in connection with the occupation of Japan by the British Commonwealth Occupation Force from February 1946”.


The various strategies that have been employed to conceal the adverse health and genetic detriments of nuclear service have culminated in the Repatriation Commission sponsored study Australian Participants in British Nuclear Tests in Australia. The inaccuracies in this document and all that depends on its content should be acknowledged by the Government and purged from all past and future considerations.

After half a century of neglect, nuclear veterans or their widows should be compensated for their relegation to the nuclear scrapheap. To assist in their remaining years, they should also be provided with a proper pension and a supporting gold card.

Note: A more comprehensive coverage is available in my witness statement (132 pages supported by 2,000 plus pages of exhibits).

Yours sincerely

Major Alan Batchelor (Ret’d) MBE AMIET psc

Copies to:

Parliamentary Secretary to the Prime Minister (Senator the Hon Kate Lundy)
Minister for Defence (The Hon Stephen Smith MP)
Minister for Health and Ageing (The Hon Nicola Roxin MP)
Minister for Veterans’ Affairs (The Hon Warren Snowden MP)
Minister for Resources and Energy (The Hon Martin Ferguson AM MP)
➢ Repatriation Commissioner (Maj Gen Mark Kelly (Ret’d) AO DSC)
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* Letter GG Redress.docLetter GG Redress.doc

Dear Professor Johnston

I have just received a copy of the British Nuclear Veteran’s comments on the ARPANSA critique of the Massey University study that re-discovered elevated translocation frequencies in Nuclear Veterans. Also included was your summary reply with little explanation of your reasoning.

Despite not receiving a copy of your paper, it seems to me that the critique was a desktop study that did little research outside of the content of the Massey University study. I would like to examine the critique in the light of past experience with ARL/ARPANSA.

As you know, I was a member of the Consultative Forum that was supposed to assist in the writing of “Australian Participants in British Nuclear Tests in Australia”. ARPANSA was represented by one member (Dr Burns) at one of the many meetings. Dr Williams was a member of the Dosimetry sub-committee with Dr Wise being co-opted as a member of the Dosimetry Exposure Panel because of his excellent reputation in the field of mathematics. On the other hand, how is it that Dr Wise stated on page 2 of ARL/TR105 that the ADORED computer program had excluded calculations for “personnel involved directly in nuclear test activities,” yet this same program appears in the Calculation Addendum of the Cancer and Mortality study? Perhaps the fact that Wise had hearing problems and did not take part in discussions unless he was addressed in a near shout may explain his lack of association.

Despite this wealth of experience, I am still amazed at the level of omissions and bias that were built into the study. Some of these problems are identified in the attached letter to the Governor-General in Council and should have been worthy of comment in a Minority Report at the time.

Incidentally, for a short time, I was part of the Dosimetry sub-committee until it became obvious that it had no knowledge of who did what, where, when or for how long. This was a basic requirement (to some degree) if dose was to be linked to those in the Cancer Registry (only available from 1982). From the time that this problem became apparent, no assistance was requested from the Consultative Forum.

Another interesting factor, Dr Loy was a member of the RMA sub-committee that produced the “Report of the RMA Subcommittee on Ionising Radiation Dose”.This report identified the minimum cumulative dose that had to be applied to a specific organ before a cancer could be accepted as being of nuclear test origin. The Report did not address the British nuclear tests and therefore could not be quoted as sound medical-scientific evidence when stating that particular cancers were not of British Nuclear Test origin. The extension of these figures into the Statements of Principles, as applied to individuals, where they had never been measured previously or instruments for their current measurement are not available, must have been known to Dr Loy. No attempt was made in the Report to calculate the dose received from internally deposited ionising radiation emitters.

There should have been calculations for such situations as a particle of plutonium oxide, measuring 2 microns in diameter and emitting 8,000 alpha particles per day. How many sieverts/day are produced by this particle in a sphere measuring about 5 cells in radius (approximate range of an alpha particle in tissue)? Perhaps one of your experts could explain how it was possible for such a large ionising radiation dose at the cellular level to be diluted to such a small whole body dose in the Cancer and Mortality study.

As you can see, I need convincing that ARPANSA has made an unbiased assessment of the Massey University study.

Alan Batchelor
End Quote

Well done Alan.

This folks is maybe some indication of what some victims of Fukushima will be going through still in 60 years time.

Diggers do have some tenancity regarding the truth, so the intervening decades have not wearied survivors as far as the opponents can see. And the whites of the offenders’ eyes are clearly visible in contrast to the dark condemnation of the deciept. In my opinion. Par for course in regard to nuclear victims vs nuclear authority. In the case of using Australian troops as “proxy enemy”, some people might consider the events to be various forms of treason. Perhaps. I think its reasonable to think along those lines at any rate.

What do you reckon honest answers and full disclosure to the above submission would mean for nuclear industry? Radiation Health, as authorities use it, is built upon what authorities have gotten away with since 1945.

3 Responses to “Letter to Governor General from Major Alan Batchelor”

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