Emeritus Professor K Donald AO
Chair
Repatriation Medical Authority
GPO Box 1014
Brisbane QLD 4001
Dear Professor Donald
I would like to express my concern about those SOPs where a minimum ionising radiation dose is one of the factors required by nuclear veterans as proof of a carcinogenic outcome when making a compensation claim. A correct determination of this problem becomes highly improbable when an internally deposited alpha or beta radiation emitter is the source. Measurements of inhaled or ingested radioactive material were not made during the nuclear weapon tests and are still outside accepted procedures, except possibly after an autopsy or organ replacement.
The origin for introducing these minimum dosage levels can be found in “Report of the RMA Subcommittee on Ionising Radiation Dose – July 2000” where they are identified on pages 5 & 6 of the Preface. The Report did not examine the vastly different distribution dynamics, contamination types and distributions, or health effects of the British nuclear tests in Australia. The automatic transference of unsupported figures to the Australian test environment without any attempt to provide an association is unscientific and lacked epidemiological support. No valid reason is provided for the application of the average doses assumed in the Report being applied to an individual as required in the subject SOPs.
The Report did not include a possibly related examination of the strontium-90 assessments of human bone tissue gathered from hospitals and morgues across Australia after the tests. This was carried out under the control of the National Radiation Advisory Committee. These collections, including milk samples, continued from Dec 1957 until about 1974 with some of the samples and donor names still held by ARPANSA. (See National Archives Series Notes B1008, B1010 and B1012). Some of the hospitals and doctors involved, together with individual strontium units, are named in R030/008. It is possible that the cancellation of free milk to schoolchildren at the latter end of this period resulted from the detection of strontium-90 in some of the milk samples.
This approach has avoided a discussion on such contaminations as the “dirty bomb” exploded at Tadje and the work, including the delivery of a meal, to the Taranaki site a few days after it had been covered by fallout from Biak. Also avoided were such consequential occurrences as Operation Sunshine, the Black Mist and the suppressed Health Department Report concerning the deaths of 68 children (including 22 stillborn and 34 newborn) contained originally in the Woomera Cemetery.
You should also note that Dr Loy of ARPANSA was a member of the RMA Subcommittee mentioned above.
It is also fact that different distribution mechanics apply to fission products (subjected to minimum and above critical compression) when compared with those external to the fission zone (did not reach critical compression). The latter includes the left over fission material (about 88% of the original plutonium-239) and the tamper material (about 120 kg of natural or highly enriched uranium). The left over material was explosively ejected from the fireball by the Debris Shock Wave and then the Mach Stem. Plutonium (and uranium) is ejected as an oxide in a near aerosol format that can be easily inhaled or ingested if present during a dust raising activity. The amount distributed will be in much larger quantities than any of the fission products and much more likely to be present in the workplaces adjacent to the GZs. Considering that alpha radiation from plutonium has an RBE 20 times that of gamma radiation and was virtually undetected during the tests, it is unfortunate for nuclear veterans that the RMA has determined in its SOPs that a recordable dose exists. Surveys carried out by ARL/ARPANSA many years later, after the test complexes had been subjected to the severe environmental factors experienced in the Central Australian deserts, as well as after several clean-up attempts, cannot be assumed to be representative of earlier conditions.
Because it has a biological half- life of approximately 90 years, plutonium is unlikely to be detected in urine analysis.
Australian research concerning the doses received from internally fixed ionising radiation emitters (particularly alpha and beta) has been selective, ignoring those studies that do not agree with the dose rates derived from the ICRP risk model. An unbiased assessment would have included comment on the non-supportive findings of Professor Chris Busby. The following example is taken from “CERRIE Minority Report 2004” [ISBN 0-9543081-1-5] .A single particle of plutonium oxide measuring 2 microns in diameter emits 8,000+ alpha particles/day within a sphere of tissue measuring 30 microns in radius. The resulting dose is 1,000+ Sv/day. Depending on the size of the emitter, a large number of the cells close to the emitter will be destroyed; the remainder may become carcinogenic according to the Second Event Theory. The fractions of a Sievert used in the SOPs are overwhelmed by these figures and, because none of these figures can be verified during a normal examination by a doctor or compensation delegate, the dosage factor should be replaced by the possibility of being exposed to an internal alpha or beta emitter.
The use of dose figures derived from the ICRP Risk Model is also open to serious question as identified in the 2003 Recommendations of the ECCR where 46 eminent researchers and advisors stated that:
“they are concerned that the ICRP system of modeling seriously underestimates the risk from low level ionising radiation exposure from anthropogenic sources.”
Also, the ICRP has indicated that doses derived from its model are not suitable for use in a number of areas including retrospective epidemiological studies. This applies in particular to the 2006 Cancer and Mortality Study of Nuclear Veterans sponsored by DVA, where the dose estimates rely on the figures derived from the ICRP Risk Model. At the time of the Study, the ICRP stated:
“Effective dose has been widely used in radiological protection and is a valuable quantity for demonstrating compliance with dose limits in relation to exposure to external radiation and intakes of radionuclides. It is not appropriate in all circumstances and guidance is given on where its use is not appropriate, for example in retrospective assessments of organ/tissue dose for epidemiological studies, in individual risk assessments after exposures over dose limits and especially after exposures to high radiation doses. Further guidance will be given in a forthcoming report being prepared by a Working Part of members from Committees 2, 3 and 4.”
The consequential but non-carcinogenic effects of ionising radiation have been routinely overlooked in SOPs. e.g.
• Accelerated aging;
• Psychological damage;
• Loss of immune system competence;
• Short and long term sterility, often followed by miscarriages and stillbirths;
• Hereditary defects and deformities in subsequent generations.
Not included in the above discussions are the carcinogenic effects of non-ionising materials such as asbestos (filters in protective clothing face masks) and beryllium (neutron reflector in some weapons).
Given the preferential lodgment of plutonium in the surface of bone tissue, it seems obvious that radiation induced damage to the blood marrow cells should have been included as a factor in a number of possible immune system disorders. Myasthenia gravis is an example of a chronic autoimmune neuromuscular disease where anti-bodies produced by the body’s immune system block, alter or destroy the transmitters of nerve impulses to the muscles.
My conclusion is that eligibility for exposure to ionising radiation has been based on the political climate and not on sound medical scientific principles. An earlier SOP requirement was based on time and distance from the Japanese GZs resulting in the exclusion of BCOF personnel. All Immediate and Early Re-entrants during the British tests would have qualified under these conditions. When the compensation potential became apparent, the rules were changed by the introduction of the misdirected RMA Report.
Because the ionising radiation dose factors required in the SOPs cannot be physically measured in the normal course of medical examinations, they should be replaced by a requirement “to be possibly exposed to inhalable or ingestible carcinogenic material.” Priority should be provided to follow-on effects, such as those resulting from a defective immune system. The carcinogenic effects of non-ionising materials present during the tests in dangerous amounts, needs further examination.
Yours sincerely
Major (Ret’d) Alan Batchelor MBE AMIET psc