Consultation response for ICRP’s draft Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident publication
General comments
One of the main purposes for updating ICRP Publications 109 and 111 was to take “into account the lessons learned from the experience of the Fukushima nuclear accident”. In this regard, it should be recalled that following the Fukushima Daiichi accident the ICRP convened a task group (Task Group 84) to compile lessons learned with respect to the ICRP system of radiation protection. A main recommendation of that group was that “the radiological protection community has the responsibility, if not the ethical duty, to learn from the Fukushima accident and suggest improvements in the system of protection”. We firmly believe that this report falls short of achieving this aim. We do not see that it takes a holistic approach to risks & hazards and therefore jeopardises the principle of doing more good than harm, and it omits key aspects of emergency response to radiological accidents. We believe that a holistic perspective is required, and indeed this was one of the key lessons learnt from the Chernobyl and Fukushima Daiichi accidents. However, this draft publication fundamentally fails to establish such a perspective.
Overall, we are disappointed to see that the ICRP has focused on its own recommendations rather than utilising the lessons learned from the Fukushima Daiichi accident to properly evaluate the costs and benefits of protective actions in terms of holistic human consequences. It is well-established that the primary health impacts of the Chernobyl and Fukushima Daiichi accidents were psychological (e.g. severe mental health issues) and socio-economic (e.g. stigmatisation), and were not due to radiation exposure. Furthermore, these accidents have served to highlight how disproportionate and unjustified protective actions can have severely detrimental effects. One such example is the mass evacuation of elderly and sick patients around Fukushima, where patients died as a result of evacuation from areas where doses were well below levels that could cause harm. We believe that the proven psychological and socio-economic detriment that can result from protective measures must be considered systematically, and in balance with possible radiation risks.
We believe that the draft publication does not offer sufficient justification for its proposed actions, based on the Linear No-Threshold hypothesis. We fear that the ICRP‟s application of the ALARA principle throughout the publication prevents the holistic implications of the proposed guidelines, if implemented, from being fully examined. For optimisation, the ICRP states that its guidelines are the result of an evaluation that carefully balances the detriment from the exposure with the relevant economic, societal and environmental factors. However, the draft report places too much emphasis on dose-related (numerical) criteria, with the use of „standard‟ radiological values (1, 10, 20, 100 mSv) giving the impression that the rationale behind the report is still focussed on radiological effects, even though the prior experience demonstrates that psychological and socio-economic impacts are likely to dominate. For example, the report recommends that no emergency responders should receive exposures in excess of 100mSv, due to the very small increased risk of cancer in the distant future. This sends the wrong message to the public, as it perpetuates the notion of radiation as a unique hazard, fuelling “radiophobia”.
Additionally, the draft publication is in contradiction with the IAEA GSG-11 on termination of the emergency, where GSG-11 has already established 20mSv effective dose as an adequate level. This draft, without proper justification, attempts to set this level at 10mSv. We believe this is misguided and that the IAEA GSG-11 safety standard, which is in use across the world, is to be used.
Given natural background radiation levels, there is no justification for setting an annual reduction target of 1mSv, as a level of exposure that will inevitably become to be regarded as some form of limit. We therefore believe that the approach in this draft report is strongly reflective of radiological-based reference levels, which is out of balance with the reality of the combined experiences of past accidents. We would therefore strongly support a move away from rigid numerical values for reference levels.
We note, with great concern, the omission of risk communication from this draft report, apart from brief and fleeting references to information needs of affected populations (Para 89). In the aftermath of every large radiological incident that has taken place, one of the perennial conclusions is the need for stronger communication efforts. The repeated failure to adequately, and accurately, communicate radiological risks in context, especially during emergencies, has resulted in considerable and avoidable detrimental effects, including social stigmatisation, fatalistic behaviour, medically unjustified abortions, deaths due to evacuation and widespread mental health issues.
In recognition of this, the importance of effective risk communication in relation to radiological and nuclear accidents has over the past few years increasingly been highlighted. Several high-profile events, such as the IAEA-hosted International Symposium on Communicating Nuclear and Radiological Emergencies to the Public (2018) and the OECD Nuclear Energy Agency-hosted Workshop on Stakeholder Involvement: Risk Communication: Dialogues towards a Shared Understanding of Radiological Risks (2019), have reaffirmed its importance. The fact that this draft publication has failed to reflect upon the vast literature and efforts post-Fukushima restricts its usefulness.
The report‟s mention of a “co-expertise approach”, whilst laudable, is unlikely to succeed unless trust between authorities, experts and stakeholders is established beforehand. It is therefore regrettable that the ICRP has failed to include any mention of this crucial issue.
We believe that this updated document is not fit for purpose. We therefore strongly recommend that Task Group 93 redrafts this publication. Whilst we recognise that the ICRP‟s remit is within radiation protection, collaboration with non-radiation experts should be sought, drawing upon the vast risk and hazards expertise that exists outside the radiation protection community. Putting radiation risks in proper context and perspective against other hazards and any socio-psychological impacts is essential, and would be fully in line with the principle of justification and ensuring that actions do more good than harm.
List of specific comments included in the pdf.