Dr Christopher Busby, Green Audit, 2 Bridge St. Bideford, Devon EX39 2BU
On behalf of the:
International Foundation for Research on Radioactivity Risk, Stockholm www.ifrrr.org
Baltic Sea Region Radioactivity Watch www.bsrrw.org
International Committee on Nuclear Justice www.nuclearjustice.org
Green Audit, UK, www.greenaudit.org
Low Level Radiation Campaign, UK www.llrc.org
Tel +44 7989 428833
7th December 2016
To Groups in EU States, Sweden, Denmark, Norway, Finland, Germany, Austria, France, Irish Republic, Spain, Italy, Greece and Belgium or any other EU State.
Halting releases of radioactivity to the environment
Halting generation of Nuclear Energy
Halting use of Uranium Weapons
Since 2010, I have been exploring ways of using the law to stop the continuing release of radioactive discharges to the environment, contamination which has killed millions and is poisoning the genome. In the last 20 years and increasingly through evidence emerging from Chernobyl contamination it is clear that internal chronic exposures to radioactive substances like Uranium, Strontium-90, Carbon-14 and Tritium represent hazards which are more than 1000 times greater than the current radiation risk model predicts. There are plausible reasons in Radiobiology and accepted physics for this, but the evidence that it is so comes from epidemiological studies of cancer, leukemia and heritable disease in those exposed.
In the same way that the industry supported false research on smoking and cancer, the nuclear military complex has large amounts of money to pay dishonest scientists to join so-called independent advice committees and sustain the risk model of the International Commission on Radiological Protection (ICRP), publishing biased scientific and false epidemiological papers in tame journals which are edited and sustained by the same dishonest scientists. There are also increasingly internet psy-ops attacking those who draw attention to this situation. Huge amounts of power and money are at risk if it is conceded that there is a major error in the ICRP risk model.
Following a conference on the law and nuclear releases in Salzburg, by 2012 I found a way to stop the releases in European countries by demanding a re-Justification of all practices involving exposures to radiation. This was using a legal clause in the 1996 EURATOM Basic Safety Standards Directive, which was made EU Member State Law in 2001. The clause requires that all practices have to be re-Justified if new and important evidence emerges that the previous justification (in terms of cancer or health detriment per unit dose) is wrong.
I asked you all to use the European Parliament Petitions Committee route to demand such a re-justification and many people did.
About 1000 people told me they had used the templates on the website we set up for this purpose (www.nuclearjustice.org) to bombard the Petitions Committee. Nothing happened except receipt acknowledgement. Later I learned from friends in the European Parliament that the European Commission Directorates were not primarily responsible for the re-Justification but that this had to be begun in the individual member state countries by demands sent to the appropriate authority in that country. This will be different in each member state country, but it will exist, since Justification is a primary requirement of the Euratom law. If, after application to the Member State authority, it turns out that no Justification was ever done, or no new Justification will be carried out following an person triggering the clause on new and important evidence (see below) then they can take the matter to the Commission as an Infringement.
The original petition employed new and important evidence in the field of cancer and leukemia. However, cancer and leukemia causation can be argued about as there is a large time lag between exposure and onset. In the new campaign, which I present here below, I move to consideration of genetic heritable damage resulting in increased levels of major congenital malformations and adverse heritable conditions following from exposures of parents. There is new evidence on this from Chernobyl effects in most countries of Europe which shows that the ICRP model for this is in error by 1000-fold or more. A review on this was published in 2016 and was used in the High Court in London in the Nuclear Test Veteran case to explain the 10-fold increased congenital illness rates in the veterans’ children and grandchildren. Furthermore, evidence which emerged in that case shows that the Japanese A-Bomb study which is the basis for all current radiation legislation was dishonestly manipulated in 1973 by the Japanese US epidemiologists in charge of the project and so its results are unsafe.
I have now had a letter published in a major peer review journal on this issue of the Hiroshima/ Nagasaki studies and their basis for radiation risk coefficients. This is now part of the letter demanding re-Justification under Euratom legislation.
I ask that each of you that receives this letter copies out or adapts the Demand letter attached below, signs it and emails or preferably posts it recorded delivery to the government authority responsible for radiation protection and the administration of the law on radiation exposures in your country. The legal Euratom contact person in your country to receive the letter can be found at
Every State in Europe is subject to these Euratom laws on new and important evidence. Many countries have specific exposure concerns, in Ireland: Sellafield, in Baltic Sea countries, the sea contamination from Sweden and Finland reactors and waste streams. In the UK we are asking those concerned to take the issue on a site by site, beginning with a new proposal at Bradwell where Magnox Ltd apply to dissolve nuclear fuel cans in nitric acid and pump the waste into the estuary of the river Blackwater.
Please email me at email@example.com to let us know what you have done.
Name, address, email
To : (see: http://www.herca.org/members.asp?p=5)
Justification of radiation exposures of members of the public and workers: review of existing practices.
New and important information.
1. This request requires the re-justification of historic and currently on-going practices involving exposures of members of the public and workers to ionizing radiation principally from radionuclide contamination of the environment.
2. Under Article 6.2 of the Council Directive 96/29/Euratom of 13 May 1996:
Existing classes or types of practice may be reviewed as to Justification whenever new and important evidence about their efficacy or consequences is acquired
3. Under Article 19(2) of the Council Directive 2013/59 of 5th Dec 2013:
Member States shall consider a review of existing classes or types of practices with regard to their justification whenever there is new and important evidence about their efficacy or potential consequences.
4. New and important evidence on the safety of the radiation risk model upon which EU Directives and domestic regulation depend.
The issue of the genotoxic hazard from internal radionuclides was considered sufficiently important for UK Environment Minister Michael Meacher and Health Ministers Yvette Cooper to set up the Committee Examining Radiation Risks of Internal Emitters CERRIE in 2001. Mr Meacher was removed from office before CERRIE completed its deliberations and two initially agreed joint studies which would have assisted the process were cancelled. The final report was not agreed by all the members. Since CERRIE new and important evidence which informs this issue has been published in the peer-review literature.
4.2. Evidence for the failure of the Hiroshima Studies.
Directives in the European Union and Regulations in the UK depend upon cancer risk factors published by the International Commission on Radiological Protection, an independent NGO. These risk factors are based primarily on the doses and cancer yield of the Japanese Lifespan Study (LSS). This epidemiological study was set up to depend upon comparison of exposed and unexposed individuals and the cancer yield in those exposed compared with unexposed controls. Forensic examination of the methodology and decisions made over the period of the study reveals that significant errors were introduced which resulted in incorrect conclusions being drawn. In particular it appears that the original control group, those who were not in the city at the time of the bombing, was discarded in 1973 when it appeared that their inclusion was suggesting a high level of cancer in the exposed groups. Furthermore, evidence presented in the Royal Courts of Justice in the Pensions Appeals Tribunal (Abdale and Others vs. Secretary of State for Defence; June 13th 2016) showed that all the epidemiological groups were exposed to rainout and subsequent contamination of the city by Uranium nanoparticles. The LSS study did not address internal contamination resulting from inhalation of the nanoparticles. This evidence and the manifest failure of the ICRP model was not denied nor rebutted in Court by the Secretary of State for Defence. New evidence which has emerged since CERRIE reported in 2004 demonstrates that exposure to Uranium particulates carries levels of genetic hazard which are not incorporated into the ICRP risk model. The matter is outlined in a letter which has been published by the leading peer-review journal Genetics on December 1st 2016. The publication which was reviewed for the Journal by three referees is attached as Appendix A.
4.3. Evidence of genetic damage leading to heritable effects in those exposed to Chernobyl fallout in Europe.
A review of evidence relating to the genetic effects of chronic internal exposure to contamination from the Chernobyl accident was published in a leading peer-review journal in January 2016