Short Conversation with Chris Busby

Short Conversation with Chris Busby

It was brought to our attention that Dr. Chris Busby is referring to the radiation risk model of the ECRR (European Committee on Radiation Risk)  having been “recently incorporated into Japanese law” in one of his most recent statements.

As we have not heard such a drastic measure having been taken by the Japanese government, which has always employed the ICRP (International Commission on Radiological Protection) standards, we decided to ask Busby which law it was.

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Following is the link for the statement in question by Busby, “The Current Radiation Risk Model and its affects on Human Rights,” submitted as part of “Formal Report to the UNHRC, United Nations Human Rights Council.”
http://nuclearjustice.org/wp-content/uploads/2012/09/UAJWritten-statements-Busby-UNHRC-13th-Sept.pdf

The statement may also be downloaded here.
https://docs.google.com/file/d/0B68f83tqq7QuYkp2SGVhR2UwV1E/edit

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The phrase in question is seen in the paragraph which begins in the very last part of page 1 and continues into the beginning of page 2 of the statement, as excerpted here.  The questionable part is shown in bold red letters.

“The averaging process leading to ‘absorbed dose,’ whilst possibly accurate for external exposures, cannot be employed for internal exposures especially to nuclides with chemical affinity for chromosomal components. This has been accepted by the ICRP in its latest report ICRP 103 and regulators are advised to employ different methodology for these internal exposure situations. Such methodology has indeed been developed by the ECRR and the use of the radiation risk model of the ECRR (recently incorporated into Japanese law) leads to accurate prediction of the results of such exposures (ECRR2010).”

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Following is a series of e-mails between FRCSR (Fukushima Radiation Contamination Symptoms Research) and Busby.
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September 3, 2012

FRCSR
Dr. Busby, will you be kind enough to answer my question regarding the following statement you made in the attached submission?

"Such methodology has indeed been developed by the ECRR and the use of the radiation risk model of the ECRR (recently incorporated into Japanese Law) leads to accurate prediction of the results of such exposures."

You mention "recently incorporated into Japanese Law."  Would it be possible for you to direct me to which law it is?  I would like to have the information because I think it is important for all Japanese people to be aware of it.  (The government doesn't always volunteer useful information, as you might know.)

Thank you for your time and all the work you do.

Sincerely,
FRCSR
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September 3, 2012

Busby
You need to contact Gen Morita who told me this. I forward this to him.
Chris
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September 3, 2012

FRCSR
Am I correct to understand that you wrote ”recently incorporated into Japanese Law" without verifying which law it was?  Shall I contact Mr. Morita myself, or will he contact me?

Sincerely,
FRCSR
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September 4, 2012

Busby
I registered which law it was at the time. I am too busy to chase this up as i have a deadline on a book chapter and get about 500 emails a day. I would be grateful, if you want to know that you check it. I recall from memory it was a new law, just passed, relating to the building of new nuclear power stations, or the development of nuclear energy.
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End of e-mail exchanges.

We are unaware of any new law that passed which incorporated ECRR standards into it.  In Japan pretty much everything is based on ICRP standards.

By the way, FRCSR was never contacted by Mr. Gen Morita.

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Addendum (as of October 8, 2012)

On October 4, 2012, FRCSR received an e-mail from Dr. Busby as below.

Here is the law:

Dear Dr Busby,

The Japanese government passed the "Law of Establishment of Nuclear Regulatory Committee" in June, with an additional resolution which includes Res. 14 stating:

"Regarding the international standard of radiation effects to health, recommendation by ICRP as well as ECRR to be fully validated and reflected in their policies. "

Regards,

Gen
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FRCSR has confirmed that the Law of Establishment of Nuclear Regulatory Committee became effective on September 19, 2012, and its Additional Resolution 14 indeed contained a clause referring to ECRR.

Additional Resolution 14: In regards to the international standards relating to health effects of radiation, ECRR (European Committee on Radiation Risk) standards, in addition to ICRP (International Commission on Radiological Protection) standards, should be fully validated and reflected in the policies.  In addition, this knowledge should be utilized to consider such effort as risk communication participated by residents.”

Additional Resolution, however, does not seem to be legally binding: it merely asks the government to “honor” it.

FRCSR appreciates Dr. Busby for providing the information.