Letter to CNSC from Families Against Radiation Exposure
Families Against Radiation Exposure
P.O. Box 202
Port Hope, ON L1A 3W3
May 12, 2009
Michael Binder
Chairman and CEO
Canadian Nuclear Safety Commission
280 Slater St.
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9
Dear Mr. Binder:
In this letter we demonstrate to you, and to the citizens of Port Hope and the public at large, that the conclusion of your staff that Port Hope is safe from the nuclear industry does not stand up to scientific scrutiny.
The April 29 meeting of your Commission in Ottawa made it quite clear that the information your staff presented in its “Synthesis Report: Understanding Health Studies and Risk Assessments Conducted in the Port Hope Community from the 1950s to the Present” does not support the Report's own conclusion that our community here in Port Hope is not at any risk because of the operations of the nuclear industry in the past, present or future.
You and some of your staff at that meeting made a number of scientific blunders and assumptions that are embarrassing to the public esteem of the CNSC and its commissioners, mislead the citizens of Port Hope, and ultimately bring disrespect to the CNSC.
F.A.R.E. is very respectful of the dignity of the hearing process and has taken steps to consult an academic adviser, who is a geneticist and who watched the April 29 meeting on webcam. We have since reviewed the transcript of the meeting, in order to substantiate our concerns below.
It is also not clear from the transcript what action the Commission took on two key recommendations of staff – that this document should stand as a “primary reference” on the state of health of people who live in Port Hope vis a vis the nuclear industry; and that no further health studies need to be done. Previous experience suggests that unless staff are told otherwise, they proceed on the assumption that their recommendations have been approved.
This causes us great concern, because we feel the "Synthesis Report" itself is deeply flawed and relies on unwarranted assumptions. We trust that you will give us a proper explanation for the following evident blunders by you and your staff, and provide the public with appropriate corrections of the misinformation that was dispersed at the hearing.
1. The “No Threshold” Principle – the scientific fact that there is no level of radioactivity so low that it does not cause genetic mutation which can result in cancer.
Possibly the most embarrassing of the many scientific blunders was when you, as president of the country’s commission on nuclear safety admitted, and then demonstrated, that you do not understand the fundamental health-safety principle of radioactivity – that there is no safe dose. This has been known to scientists for 70 years.
You said that you do not understand the term “No safe level of radiation” and you went on to ask, as if you found the idea absurd, whether this means that the background radiation is not safe.
Yes, Mr. Binder, it means exactly that. We are disturbed to learn that it is necessary to explain this fact about nuclear energy to the president of the Canadian Nuclear Safety Commission ... but better late than never.
All radiation, even in minute doses, can and does cause damage to the genetic material, DNA. This damage is called mutation. Virtually all mutation is harmful and much of it causes cancer. Just as there is something called “background radiation,” so too there is something called “background (spontaneous) mutation rate.” This is the frequency with which mutation occurs in the population, as a result of “background” radiation and other non-specific effects.
While we are surprised to discover that you did not know this, we are happy to be able to provide what is evidently new information to you.
Relevant scientific references concerning the “No Threshold” Principle are provided in the list of References given below. For the original research work see Muller HJ (1939); Ray-Chaudhuri SP (1939). For more recent work see Nussbaum RH (1998); Wakeford R (2002).
The web site of UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation) states: “Consensus reports by the United States Research Council and the National Council on Radiation Protection and the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) [web sites given in list of References below] have upheld the Linear No Threshold model (LNT), concluding that radiation is dangerous no matter how low the exposure and discounting the existence of radiation hormesis in humans.” (Hormesis is the discredited claim that radiation exposure can be beneficial).
2. The known cancer-producing effects of low levels of radiation.
Closely rivalling our surprise at hearing your pronouncements on the “No Threshold” Principle was our unpreparedness for the remarks by Dr. Patsy Thompson, the CNSC’s Director-General of Environmental and Radiation Protection and Assessment, and presumably lead author of the "Synthesis Report", indicating that she evidently knew of no studies that have ever shown health effects of lowlevel radiation. She stated that when the scientific literature refers to low doses of radiation, the doses they are referring to "are in the hundreds of millisieverts" (emphasis added by us).
It has been known for over half a century that a single X-ray given to a pregnant woman (a dose of about 10 millisieverts) can cause leukaemia in the baby that was exposed as a fetus in the womb (Stewart et al., 1956: Stewart et al., 1958).
In case any CNSC personnel are tempted to cite work by the famous Sir Richard Doll and co-worker Court Brown, with Bradford Hill, which disputed those original findings, we mention that Doll later recanted that opinion, admitting that the work with Court Brown had been “not very good,” that the results were “unreliable,” that the study “was too small” and that he had “never been happy with that study.” The original findings of Stewart and colleagues were confirmed and reinforced by a large study by MacMahon in 1962 (see Reference list), and later by many others including R. Doll himself in 1997.
The latter concluded, in an article with R. Wakeford, in 1997, that a dose of the order of 10 mGy (equivalent to about 10 millisieverts) received by the fetus causes a consequent increased risk of 40% for childhood cancer, and that the results of their study “strengthens belief in the idea that there is no threshold dose below which no effect is produced” (Doll and Wakeford, 1997).
Since CNSC appears to have been unaware of the above, it is possible that this information may give CNSC co-workers the impression that cancer from low-level radioactivity concerns only fetuses. We mention therefore, as just one example amongst many reports on cancer in workers in the nuclear industry, the Hanford study (Mancuso et al., 1997). This study is well known also for the pernicious persecution of the researchers by U.S. government agencies, because of the scientists having exposed the risks of the industry, even at low levels of exposure. This notorious tradition of persecution is a very disturbing fact of the history of radiation research (Hardell et al., 2007; Nussbaum, 2007).
The literature is rife with reports on cancer-producing mutation at low levels of radiation (e.g. also Nussbaum and Koehnlein, 1994). It is astonishing and unacceptable that your senior CNSC spokesperson publicly declared herself unfamiliar with these facts at your meeting on April 29.
3. Citations in the “Synthesis Report” showing significantly elevated frequencies of diseases, including cancer, in Port Hope, compared to other areas.
In response to the "Synthesis Report" FARE's written Submission (which we will refer to as FARE's Submission) cited verbatim comments from the Report which indicated the occurrence in Port Hope of various diseases, in frequencies statistically significantly higher than in the control areas that the Port Hope figures had been compared to.
The list included statistically significant elevated frequencies of:
"Coronary heart disease and cirrhosis of the liver";
"Male lung cancer";
"Influenza and female skin infections";
"Cancers of the pharynx";
"Lung cancer (trachea, bronchus and lung)";
"Lung cancer in women";
"Cancers of the nose and sinuses";
"Excess nose and sinus cancer";
"Childhood brain and nervous system cancer";
"Circulatory disease, cancer and respiratory disease";
"Brain and nervous system cancers in women";
"Lung cancer";
"High blood pressure (hypertensive disease)".
It did not escape the notice of at least some Commissioners that the "Synthesis Report" had not accounted for these data. In response to a question by Dr. McDill on this issue, Dr. Thompson gave the astonishing answer that “there are elevated diseases but we also make the comment that these diseases are not associated with radiation doses at those levels of uranium or other contaminants...”
This appears to have satisfied you, as President, and the CNSC as the official body designated to care for the Nuclear Safety of the nation. We might naively have thought it unnecessary, but now realise it is indeed necessary, to point out to the CNSC that:
a) This list contains repeated mention of numerous cancers. For anyone even peripherally in contact with the issue it is well known, or should be, that radioactivity is causative of cancer. It is unacceptable for a senior CNSC official to brush aside these data with the off-hand comment that we say "these diseases are not associated with radiation....”
b) With respect to the non-cancer diseases in this list, and other long lists of diseases known to be abnormally frequent in Port Hope, the following applies: If a disease occurs in excess numbers in an area of high exposure to a cancer producing agent, both good science and good ethics dictate that the compelling and imperative working hypothesis is that there is a causal relationship, until proven otherwise.
That there may be no previous proof of a relationship is most probably because no adequate studies have been done.
This cannot come as a surprise -- there are probably no sites in the world that have as great exposure to radioactivity in residential urban areas as Port Hope, and certainly no adequate studies of these diseases have been done here.
It is relevant to add here that the "Synthesis Report" makes no mention of other studies that have shown statistically significantly increased frequencies of diseases including cancers in Port Hope. In one study alone, titled "Great Lakes Health Effects Program: Port Hope Harbour Area of Concern: Health data and statistics for the population of the Region (1986-1992)", over 40 diseases are listed in which either mortality or morbidity numbers were higher in Port Hope than in the areas being compared.
As we indicated in our Submission, we have previously brought these and other similar data to the attention of the Mayor of Port Hope, and pointed out the fact that she has misled the citizens in telling them that existing studies show no health problems in Port Hope. Your "Synthesis Report" perpetuates this misinformation.
Furthermore, in releasing your "Synthesis Report" in Ottawa instead of in Port Hope, without any opportunity being offered to us or other concerned citizens to respond, you sent the clear message that input from Port Hope citizens would not be welcome, thus reinforcing the Report's conclusion that essentially no further discussion on the issue will be entered into by CNSC. When we heard of the scheduled release in Ottawa, we requested and received the opportunity to participate. The Mayor of Port Hope immediately received permission to also appear, and she used the opportunity to echo the Report's message that there is no problem. Thus both CNSC and the Mayor and Council of Port Hope are denying the facts that are clearly revealed in our Submission and explicitly summarised above.
The data are being brushed aside. To err on the side of complacency rather than on the side of caution, as the CNSC has done here, is unconscionable.
Port Hope citizens legitimately demand that the CNSC distance itself from the comments made in the "Synthesis Report", and instead take immediate action to deal with the fact that there is a large number of diseases that have been shown to have occurred in excess in Port Hope, that the list includes cancers of various types, and that a causal relationship to the nuclear pollution is presumed until proven otherwise. We feel the time has arrived when the public must be informed of the facts.
4. Statistical significance.
In the context of the above-mentioned long list of diseases, including cancers, that have occurred in statistically significantly increased frequency in Port Hope, a question from the floor raised the issue of a previous review of the Port Hope problem by Dr. Eric Mintz, a distinguished professor of epidemiology, commissioned by the CNSC. Dr. Mintz had found problems in Port Hope, but curiously this report, done for the CNSC, was not mentioned in the "Synthesis Report". Almost incredibly, the explanation for this given by Ms. Rachel Lane, CNSC Staff Epidemiologist, was that "the CNSC does not agree with" Dr. Mintz. Thus results that the CNSC does not agree with are excluded from consideration.
Ms. Lane did give further explanation. She stated that "Dr. Mintz makes very basic misinterpretations of statistical concepts and epidemiological methods", and that he was dealing with small numbers, on which "any epidemiological university book on epidemiology" (sic) advises "to take great caution". Indeed, she went on to point out, as if in criticism, that the numbers were often small, and that a difference of one or two cases can make the difference between highly statistically significant and not significant.
This demonstrates a deeply concerning misunderstanding of the concept of statistical significance on Ms. Lane's part. As anyone who understands the concept knows, the techniques for determining whether results are significant (meaningful) or not take into account the size of the samples being compared. An apparently big difference in frequencies of a disease between e.g. Port Hope and the rest of Canada could be non-significant, and an apparently small difference could be significant, all depending on the size of the samples from Port Hope and Canada respectively.
And one case more or one case less in a sample can indeed make the difference between significant and non-significant - the techniques are so designed precisely to allow the observer to decide what is meaningful and what is not.
After having heard Ms. Lane make her facile comment on statistical significance, we question whether she is qualified to comment on the work of a recognised expert such as Dr. Mintz. Because Ms. Lane's comments could leave a totally incorrect impression in the minds of listeners and viewers, we plan to bring her remarks to Dr. Mintz's attention, to give him an opportunity for rebuttal.
5. Scientific Peer Review
FARE'S Submission pointed out that the author(s) of the "Synthesis Report" had demonstrated a serious and disconcerting misunderstanding of the concept of scientific peer review. When scientists use the term peer review it is understood to mean that the reviewers are chosen by a third party (a journal editor), without the knowledge or influence of the authors, and known associates or collaborators of the authors are excluded as peer reviewers.
Instead, the CNSC chose its own reviewers, and these included Health Canada scientists who were reviewing the CNSC's review of work by, amongst others, Health Canada scientists.
Two astute Commissioners, Dr. Barnes and Dr. McDill, themselves both distinguished academics, challenged Dr. Thompson with this fact, endorsing FARE's statement that Peer Review implies that reviewers are at “arm's length” from authors. These Commissioners pointed out that what had been called “Peer Review” in this case was in fact nothing more than “external review,” and by collaborating colleagues at that.
Both Dr. Thompson and Ms. Lane further compromised CNSC's integrity on this issue by obstinately maintaining the correctness of the claim that the Report had been “peer reviewed,” even though the reviewers had been selected by the author(s) and included Health Canada employees reviewing comments on Health Canada studies.
6. The “Healthy Worker Effect.”
FARE's Submission pointed out that the "Synthesis Report" mentions two studies on former workers at Eldorado (now Cameco), and that these studies found that the “only cancer death, which showed statistically significant excess, was cancer of the rectum, based on 7 deaths.” However, this result is quite different to that reported in the study (designated RSP-0205) from the same series, on Eldorado workers, listed in the Port Hope Mayor's so-called “peer review studies,” which found statistically highly significant levels of lung cancer. We commented that it is most curious that this article, which is in the same series of studies on former Eldorado workers as others mentioned in the “Synthesis Report”, is not mentioned in this Report.
Similarly, a “Health Canada Fact Sheet,” in referring to RSP-0205, erroneously stated that this study showed that “there was no significant relationship between occupational exposure and cancer incidence, cancer mortality or other causes of death.”
At the meeting on April 29, Ms. Lane repeated the claim that studies on Eldorado workers had found no problems and she added, as also stated in the "Synthesis Report", that Eldorado workers were found to be as healthy as members of the general public. In stating this, Ms. Lane has inadvertently drawn attention to an apparent flaw in the studies she was citing.
Epidemiologist Ms. Lane and CNSC appear to be unaware of what is known, in the scientific and specifically the epidemiological literature, as “The Healthy Worker Effect”. This term was coined by the Australian researcher Anthony McMichael (see e.g. McMichael, 1976). Workers in hazardous occupations as in the Nuclear Industry are highly selected on the basis of being in good health to start with. In epidemiological studies of people exposed to health hazards such as radioactivity, the cohort of exposed people should be compared to a “control” cohort of nonexposed individuals who are not only matched in all other respects, including age, sex etc. but who are also selected for being “healthy.” The latter has been historically ignored in studies on nuclear industry workers, with the result that the harmful effects are often masked, because the workers, being healthier to start with, withstand the onslaught of radiation better than average people would. This fact makes the previously reported occurrence of lung cancer and other diseases in former Eldorado workers far more significant than previously suspected.
It is shocking that CNSC appears to be unaware of this fact, is unaware of previous studies on Eldorado workers that show increased incidence of lung cancer, and is willing to uncritically accept a “Synthesis Report” that brushes the data aside.
Besides those scientific points, we would like to draw your attention to two examples of questionable procedure.
1. On two separate occasions, Ms. Lane appeared to be reading out prepared answers to supposedly impromptu questions from commissioners.
On the webcam she appeared to be reading verbatim answers to questions asked by yourself on the Mintz report, and by Dr. McDill on peer review. We would like your explanation for this, because it has the potential to shake public faith in the integrity of the hearing/meeting process, and raises questions about your own role, Mr. Binder, as both CEO of the staff (their boss) and chairman of the commission (supposedly conducting a hearing in the interest of public safety). We cannot imagine anything more hurtful to the credibility of the CNSC than this visual evidence that your hearings and meetings may be staged in advance.
2. Commissioner Harvey asked Dr. Thompson why the "Synthesis Report" was translated and put on the Commission’s website before it came before the Commission and underwent public scrutiny.
He did not get an adequate answer to his question, other than that staff did what they understood they were asked to do. This makes it incumbent on the Commissioners to make explicit and public their decision on the staff’s two main recommendations – that the "Synthesis Report" is now a “primary reference” for health effects in Port Hope, and that no new health studies are needed here, despite the fact that our community is supposed to be about to host the largest clean-up of radioactive waste in Canadian history. (Dr. Patsy Thompson’s assurance that health effects will be tracked “indirectly” by environmental monitoring was not adequate, since the Environmental Assessment for the low-level clean-up has already stated that there are not likely to be any adverse health effects.)
But there is an even more fundamental reason to question the Commission’s procedure for dealing with this Report. Asked by Commissioner McDill if the Report is final or will staff amend it, Dr. Patsy Thompson said “the intent is that the Report will stand as a final report” (though suggestions from CNSC Staff could be taken into consideration). Since it was posted on the CNSC website on April 15, well before public comment from F.A.R.E. and the Port Hope Community Health Concerns Committee was received, that means your public consultation on the Report was a sham, and it would appear that the intention has been that none of the concerns raised in our interventions – some of which seemed to be supported by one or more commissioners – would be taken into account.
We absolutely demand your explanation for this, sir, as well as to the other points raised in this letter. In light of the large number of scientific and procedural flaws in the "Synthesis Report" and its release on 29 April, 2009, we respectfully suggest that it is absolutely imperative that this Report be completely revised, to take into account the issues we have raised. Most importantly it must be acknowledged publicly that there is no scientific evidence that Port Hope is safe, and that there is a serious unsolved problem of radioactive contamination.
Sincerely,
Louise Barraclough
Interim President
Families Against Radiation Exposure
C.c. All CNSC Commissioners
Mayor of Port Hope
All Port Hope Councillors
Federal Minister of Natural Resources
Federal Minister of Health
Ontario Minister of Health
Ontario Minister of the Environment
Northumberland Today
Northumberland News
Medical Officer of Health
President, Council of Canadians
Waterkeepers
President, Canadian Medical Association
President, Ontario Medical Association
References
Doll R, Wakeford R (1997) Risk of childhood cancer from fetal irradiation. British Journal of Radiology 70, 130-139.
Hardell L Walker MJ Walhjalt B Friedman LS Richter ED (2007) Secret ties to industry and conflicting interests in cancer research. American Journal of Industrial Medicine 50, 227-40.
MacMahon B (1962) Prenatal X-Ray exposure and childhood cancer. Journal of the National Cancer Institute 28, 1173-1191.
Mankuso T, Stewart A, Kneale G (1977) Hanford I: Radiation exposures of Hanford workers dying from cancer and other causes. Health Physics 33, 369-384.
McMichael, AJ. (1976) Standardized mortality ratios and the "Healthy Worker Effect": Scratching beneath the surface. Journal of Occupational Medicine 18, 165-168
Muller HJ (1939) Report of investigation with radium. Medical Research Council Special Report Series no. 236 (London, 1939).
National Council on Radiation Protection and Measurement
www.Righthealth.com/topic/national_coun ... radiation_
protection_and_measurement.
Nussbaum RH, Koehnlein W (1994) Inconsistencies and open questions regarding low-dose health effects of ionizing radiation. Environmental Health Perspectives 102, 656-667.
Nussbaum RH (1998) The linear no-threshold dose-effect relation: is it relevant to radiation protection? Medical Physics 25, 291-9.
Nussbaum RH (2007) Manipulating Public Health Research: The nuclear and radiation health establishments. International Journal of Occupational and Environmental Health 13, 328-330.
Ray-Chaudhuri SP (1939) The validity of the Bunsen-Roscoe Law in the production of mutations by radiation of extremely low intensity. Journal of Genetics, Supplement (1939).
United Nations Scientific Council on the Effects of Atomic Radiation
www.Righthealth.com/topic/united_nation ... ouncil_on_
the_effects_of_atomic_radiation
United States National Research Council:
www.Righthealth.com/topic/united_states ... ch_council
Wakeford R (2002) Evaluation of the linear-nonthreshold dose-response model for ionizing radiation INCRP Report No 136). Journal of Radiological Protection 22, 331-335.
www.iop.org/EJ/abstract/0952-4746/22/3/703.