IICPH Presentation to Science Discussion Meeting for the Development of Air Standards For Uranium (Canada)

INTRODUCTION

Founded in 1984, the International Institute of Concern for Public Health is a Canadian-based nonprofit organization dedicated to helping communities assess and improve their environmental health status. Non-partisan and independent of government or industry, the Institute researches the science of health effects of chemicals and radiation and provides evidence and documentation needed by survivors of environmental disasters.

We also advise governments, groups and individuals. We work in cooperation with native peoples, professionals, grassroots organizations and citizen groups in Canada, the United States, Russia, the Central Pacific, India, South America, and many other countries to further the key principle on which the IICPH operates, that a safe environment is a fundamental human right.

CONTACT INFORMATION

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TELEPHONE: 416-786-6128
Website: http://www.iicph.org/
Email: info@iicph.org

Part I

Has the Ministry considered all relevant and critical scientific considerations?

The Ministry appears to have depended heavily on the opinions of the ICRP,¹ WHO (which usually quotes ICRP), CNSC (which depends totally on ICRP) and the ATSDR (which is partly independent). While the ATSDR does not wholly depend on the ICRP, all three organizations essentially come to the same conclusions. IICPH strongly believes that in relying on the regulations suggested by the ICRP, the Canadian government neglects its obligation as the number one producer of uranium to undertake its own scientific investigation. It has been mining and processing radioactive materials for more than seventy years. The ICRP normally ignores any scientific papers that demonstrate health effects from low levels of ionizing radiation. They prefer their theoretical dose-response model.

The ICRP decided to base their standards on fatal cancers. At one time, they developed a basis for their estimates called the “Standard Man” a young healthy male ignoring the different tolerances to ionizing radiation to be found in women, in the sperm, ovum, fertilized ovum, fetus, growing child, the aging or the immune compromised: all of whom are more vulnerable than the young healthy adult male. The ICRP recognized biological endpoints deemed to be of concern for regulatory purposes are limited to radiation induced fatal cancers and serious genetic diseases in live born offspring.

The ICRP offers a risk/benefit trade-off, containing value judgments about what is acceptable to the individual and society for what it sees as the benefits of the activities. These activities are the peaceful and military uses of ionizing radiation. The recommendations of the ICRP are not health-based but related to the interests of the nuclear industry and the military, sources related to their jobs and income. We note that although they determine occupational and public health “permissible exposures”, no persons trained in occupational or public health serve on The Commission.

At no time has there been any input from the public about what they consider an acceptable risk for the benefit of using ionizing radiation to boil water to produce electricity or to produce military weapons. Teratogenic damage, embryonic and fetal losses, as well as stillbirths, apparently do not count because they do not affect the population gene pool. While the individuals so affected may perceive a loss, it may not be seen as a cost to society. Surely this should be something for society to decide. There is also the consideration of those who live with cancer or immune system disorders. Even benign tumours are not nice for the individual, let alone living with the consequences of cancer.

The ICRP is a self-constituted and self-perpetuating organization. Most members of The Commission (formerly called the Main Committee), the decision making body, are physicists or medical administrators in nuclear countries. The membership term is for an unlimited time. [About half of the doctors are medical administrators of whom many are from nuclear weapons countries who set radiation protection practices in their national ministries of health or labour]. They sometimes include biophysics as a specialty, but not biometrics. By their rules, The Commission responsible for decision-making will not ever include an epidemiologist, occupational health specialist, oncologist or pediatrician.

The ICRP has not mandated itself to be protectors of worker or public health, but rather to recommend a so-called “sensible” trade-off of health for the benefits of the activities of the nuclear industries.

Genetic damage deserves special mention as it affects future generations.

The genetic damage to the DNA in a person will be passed on to their children and their children’s children and so on through the surviving generations.

In the opinion of our founder and immediate past President, Dr. Rosalie Bertell, Ph.D., G.N.S.H., internationally renowned expert on the health effects of ionizing radiation: “all future radiation standards should be based on the prevention of damage caused to future generations. This will significantly lower the limits of exposure which are now considered safe”.

The Ontario Ministry of the Environment would be better served by looking to other sources of information on which to base their standards. Today we are looking at a standard for the amount of uranium allowed in air. The European Committee on Radiation Risk is one such organization on which we might depend since Canada has itself not undertaken the necessary research to protect its population.²

The European Committee on Radiation Risk (ECRR) was founded in 1997 following a resolution in the European Parliament. The terms of reference were to investigate formally the risk due to internal contamination with radioactive materials. They were to make no assumptions whatever about officially used science. They were to consider all available scientific evidence into the health effects of low-level ionizing radiation and ultimately report on the results of their investigations. They were to remain independent from previous risk assessment committees such as the ICRP and UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation), understanding that UNSCEAR often uses The Commission members on its committees. The report of this committee was first published in 2003.

The ECRR Recommendations outlines the committee’s findings regarding the health effects resulting from exposure to ionizing radiation and presents a new model for assessing these risks. The intent is to supply decision-makers and others with a brief but comprehensive description of the model developed by the committee and the evidence on which it depends.

The report begins by identifying the existence of a dissonance between the risk models of the ICRP and epidemiological evidence of increased risk of illness particularly cancer and leukemia, in populations exposed to internal radiation emitters from man-made sources. The committee concluded that the ICRP models have not arisen out of accepted scientific method. The 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 their decisions. However, these are averaging models, which assume solubility of the material and its homogeneous spread throughout the affected organ or even try to make a “guesstimate” of an equivalent whole-body dose to an organ dose. These models are unrealistic for the exposures that occur at the cellular level.

Cellular DNA is either hit or not hit. Minimum impact is that of a single hit and impact increases in multiples of this minimum impact spread over time.

Major Determinations of the ECRR

The epidemiological evidence of internal exposures must take precedence over mechanistic theory-based models in assessing radiation risk from internal emitters.

The ICRP justifications are based on outmoded philosophical reasoning, specifically, the averaging cost-benefit calculations of utilitarianism. Utilitarianism has long been discarded as a foundation for ethical justification of practice owing to its inability to distinguish between just and unjust societies and conditions. The overall benefit is calculated and not the individual benefit or detriment.

Rights-based philosophies such as Rawls Theory of Justice or considerations based on the UN Declaration of Human Rights should be applied to members of the public.

Radiation without consent cannot be justified ethically since the smallest dose has a finite, if small, probability of fatal harm.

It is not possible to accurately determine the radiation dose to individuals in a population owing to the problems of averaging and individual response differences (which may vary over orders of magnitude). Each exposure should be addressed in terms of its effects at the cellular or molecular level. However, in practice, this is rarely possible, especially when the needed health-based research is neglected, for example in Port Hope or in Deline, where generations have been exposed. The Committee admits that there are neurological and pulmonary effects of inhaled uranium but uses the fact that ICRP failed to calculate these effects, to instead base its regulations on kidney burden. This is a serious failure of regulation based on the real biological endpoints of concern to Canadians. It is well known, for example that ultra-small particles of any heavy metal can travel from the nasal passages to the brain. We also know that brain cancer rates in Port Hope are elevated. However, this seems not to concern the CNSC which turns only to ICRP for its recommendations!

The IICPH reviewed sources of radiation exposure and recommends caution in attempting to assess the effects of novel exposures by comparison with exposures to natural radiation, especially when not in its natural state. Novel exposures would include not only exposures to man-made artificial isotopes such as Strontium-90 and Plutionium-239 but also include fine and ultra-fine particles that may consist of entirely man-made isotopes or altered forms of natural isotopes such as processed uranium. NOTE: The ICRP Committee considers “natural sources” to include rocks, humanly pulverized and processed, and made air-borne by human factory methods, as if they were still in their “natural state” under ground. This pollution is known more specifically as “technologically enhanced natural radiation” (TENR). It should be considered under the fine and ultra-fine particulate laws in Canada. Additionally, this pollution is radioactive!

The ICRP uses such comparisons on the concept of the absorbed dose’ that does not accurately assess the consequences of harm at the cell level. Comparisons between external and internal radiation exposures may result in underestimations of risk since the effects at cell level may be quantitatively different.

The ECRR believes that recent discoveries in biology, genetics and cancer research suggest that the ICRP target model of cellular DNA is not a good basis for the analysis of risk and that such physical models of radiation action cannot take precedence over epidemiological studies of exposed populations.

The ECRR reviewed the basis of epidemiological studies of exposed populations and pointed out that many examples of clear evidence of harm following exposure have been discounted by the ICRP on the basis of their invalid physical models of radiation action. The committee reinstated such studies as a basis for estimates of radiation risk. Normally an audit uses the reality not the preconceived model.

The ECRR in reviewing the models of radiation action at the cell level concluded that the linear no threshold model (LNT) of the ICRP is unlikely to represent the response of the organism to increasing exposure except for external irradiation and for certain endpoints in the high dose region.

From a review of the published work on low dose exposures, the committee concluded that health effects relative to the radiation dose are proportionately higher at low doses and that there may be a biphasic dose response from many of these exposures owing to inability of cell repair to be completed before a second hit with radiation (as with Strontium 90) and the existence of a high-sensitivity phase (replicating cells). Such dose response relationships may confound the assessment of epidemiological data and the committee points out that the lack of a linear response in the results of epidemiological studies should not be used as an argument against causation.

The present cancer epidemic is likely a consequence of exposures to global atmospheric weapons fallout in the period 1951-63. More recent releases of radioisotopes to the environment from the operation of the nuclear fuel chain will likely result in significant increases in cancer and other types of ill health in the future.

The Recommendations of the ECCR Committee

The TOTAL MAXIMUM PERMISSIBLE DOSE to members of the public arising from all human practices should be not more than 0.1mSv/yr with a value of 2mSv/yr for nuclear workers.

IICPH Conclusions

This Maximum Permissible Dose would severely limit the operation of nuclear power stations and reprocessing plants. This confirms our belief that nuclear power is a very costly way of producing energy when the human health deficits are included in the overall assessment.

All new practices must be justified in such a way that the rights of all individuals are considered.

Radiation exposures must be kept as low as reasonably achievable using best available technology as determined by citizens and industry together.

The environmental consequences of radioactive discharges must be assessed in relation to the total environment. including direct and indirect effects on all living systems.

Part II

Other considerations that should be taken into account.

It has not been uncommon for people who have lived for a considerable time in a community and their doctors to notice what appears to be a rise in health deterioration of one kind or another or even a rise in a number of different health effects that seem to have increased over a period of time. The aftermath of the nuclear accidents at Chernobyl, Three Mile Island, and pollution from mining sites are examples of places where this has happened. People in Blind River and Port Hope have been among the first to be aroused. Medical doctors in some communities have also noted rises of certain illnesses including perhaps rare cancers.

Other sources of ionizing radiation in a community will affect the amount of ionizing radiation the people are receiving.

When deciding on a standard for uranium in air, the other sources of radiation that the individuals are receiving into their bodies must be taken into consideration. However, no properly constituted environmental health studies or cumulative record of exposures, that would meet international standards, have been done in Port Hope or Blind River.

It would have been nice if there had been baseline studies before the nuclear industry started, but, of course, no one was thinking in those terms at the time. Canada could have provided a service to the world if the governments had carried out suitable studies.

Health Canada states that “numerous health studies have confirmed that Port Hope is a safe and healthy place to live.” Epidemiologist Dr.Eric Mintz Ph.D. examined the last one, done in 2002, in 2004. Essentially, the Health Canada study was not an epidemiological one but simply ecological. Dr. Mintz found many errors in this study and revealed that there was a significant rise in fatal childhood leukemia and brain cancer and lung cancer in women, for instance.

The Radiation and Health in Durham Region Report 2007 (RHDRR2007) authored by the Durham Region Health Dept. is an example of how a flawed health study can give a flawed result.

At the request of the Institute, Dr. Rosalie Bertell examined this report and produced a critique for IICPH that can be found on our website³.

The main criticisms were:

RHDRR2007 is an ecological study. This is the weakest design of all types of health studies now available to health researchers. The outcome of a study is pre-determined by the study design and methodology. They used the poorest choices available.

The database used was prone to error and required time-consuming extraction of data. Statistics Canada and the Ontario Ministry of Health should provide readily accessible and relevant data on both incidence rate and death rate of cancer. This is clearly possible with modern computer technology.

They did not address any of the classical Bradford Criteria for causality of health detriment by a noxious agent, although their study claimed to be an attempt to prove that cancer and birth defects in Durham Region were not being caused by the routine radioactive releases from several major nuclear power generators. (No mention was made about the two refineries but the same would apply to releases from those facilities as well.)

They eliminated without justification, consideration of pancreatic cancer (the fifth most common), cardio-vascular disease and teratogenic (initiated while in utero) diseases or malformation, known to be caused by exposure to ionizing radiation

The Durham Health Dept. confused the public by mixing together on a chart: people’s acceptance of medical X-ray with permission from and benefit for the patient, deliberate releases of radioactive materials into air and water, randomly contaminating even those who object to this option for electricity and natural background radiation which is neither beneficial nor avoidable. These are not comparable.

They have failed to become current on the literature documenting the human genetic effects of exposure to ionizing radiation.

They do not have the right to declare cancer the only health effect of radiation that is “of concern” to the public.

They devoted much time to blaming “lifestyle” which does little other than interrupt the pathway of toxic environmental hazards for cancer. It did little to convince health professionals that radiation in the public air and water was irrelevant. Breathing and drinking are not optional lifestyle characteristics!

They tried to minimize the international study of atomic workers in 15 countries, and failed to inform the public that CANDU workers had shown more excess cancers than those working in other nuclear reactor types.

RHDRR 2007 failed to explain serious methodological flaws to the public. In addition to weak research design and poor data, it used faulty methodology.

CONCLUSIONS

Processed uranium dust is more dangerous to health than uranium dust from natural sources. The digestive system readily gets rid of a large portion of the natural uranium, allowing only 1 to 2% to cross into the hepatic portal and enter the body. Natural uranium dust readily falls to the ground where it gets into ground water and soil. Humans normally receive it through food and water. The very fine dust produced from a refinery is much smaller and is more readily transported to vulnerable tissues of the body including the brain and lung.⁴

There is 100% absorption of uranium into the body. When inhaled. Insoluble uranium is scavenged into the thoracic lymph nodes and can cause lymphoma or other radiation related illnesses.

The Port Hope Radiological Studies Project 2007 carried out by the Uranium Medical Centre for the Port Hope Community Health Concerns Committee, did demonstrate that urine samples of four of the nine subject people tested had non-natural uranium in their urine. This proved that non-natural uranium was being inhaled by the residents of Port Hope tested. Although it was an extremely small sample the likelihood that other residents also have inhaled processed uranium seems quite evident. This would be particularly harmful for the unborn and small child.

Considering the long history of contamination in the Port Hope area, it must be a given that the public is exposed to other sources of radiation other than the current air emissions.

Barring a properly constituted epidemiological or health study independent of government or industry, there is no way to know what level of uranium is being received into the blood of the residents of Port Hope residents or the extent of the illnesses from which they might be suffering.

The Ministry of Health should collect statistics on sterility, miscarriages, and teratogenic effects as well as heart and autoimmune diseases, not just look at cancer mortality and morbidity. The Ministry of the Environment should be asking for such statistics to give some guidance concerning health effects of ionizing radiation from nuclear facilities of all types.

Because of the genetic effects of processed uranium, the only way to prevent damage to future generations is to not allow any processed uranium in air.

CONSIDERING THE DANGER TO HEALTH FROM TECHNOLOGICALLY ENHANCED URANIUM, THE IICPH IS RECOMMENDING THAT THERE SHOULD BE NO PROCESSED OR MANUFACTURED FORMS OF URANIUM ALLOWED IN AIR.

References:

¹ Limitations of the ICRP Recommendations for Worker and Public Protection from Ionizing Radiation — Rosalie Bertell, Ph.D., GNSH http://iicph.org/limitations_icrp

² 2003 Recommendations of the ECRR. The Health Effects of Ionizing Radiation Exposure at Low Dose Rates for Radiation Protection Purposes: Regulator’s Edition
More information and ordering at: http://www.euradcom.org/”:http://www.euradcom.org/ Avenue de la Fauconnerie 73, B-1170 Bruxelles, Belgium or email: info@euradcom.org

³ http://www.iicph.org/files/bertell-durham-2007.pdf

⁴ RADIATION-INDUCED CANCER FROM LOW-DOSE EXPOSURE: An Independent Analysis by John W. Gofman Medical Physicist. Available from: Committee for Nuclear Responsibility PO Box 11207, San Francisco CA 94101 U.S.A.
DEADLY DECEIT: Low-Level Radiation, High Level Coverup by Jay M. Gould and Benjamin A. Goldman available from Four Walls Eight Windows Press PO Box 548, Village Station, New York NY 10015 U.S.A.