Critical Analysis of the WHO’s health risk assessment of the
Fukushima nuclear catastrophe
Dr. med. Alex Rosen
German Section of the International Physicians for the Prevention of Nuclear War
stMarch 1 , 2013
On February 28th, 2013, the World Health Organization (WHO) published its „Health risk
assessment from the nuclear accident after the 2011 Great East Japan earthquake andtsunami“. This report concluded that “for the general population inside and outside of Japan,
the predicted risks are low and no observable increases in cancer rates above baseline rates
1
are anticipated.” The assessment is based on preliminary dose estimations, published by the2
WHO in May 2012 , which were severely criticized by the German Section of IPPNW,
3
independent researchers and Japanese civil organizations. This analysis discusses the eightmain objections to the current WHO report and shows why it should not be considered aneutral scientific assessment of the actual health risks of the affected population, nor a valid
basis for future decisions and recommendations.

1. The report is based on faulty assumptions
Scientifically speaking, the main point of criticism to this report has to be the fact that the health risk
assessment is based on dose assessments which are dubious, if not to say plain wrong. The source
term estimates (the total emission of radioactive particles) used in the WHO report were significantly
lower than those of independent research institutions and in some cases also lower than TEPCO’s
own measurements. The exposure of the population living in the 20-km zone around the nuclear plant
was omitted, even though this population may have been exposed to high levels of iodine-131 before
and during the chaotic evacuations. The quantity and selection of food samples used in thecalculations of the internal radiation dose were shown to be inadequate and in stark contrast to
samples published by the Japanese authorities. Finally, and perhaps most crucially, the report was
mainly composed by scientists working for organizations with stakes in the continued and profitableutilization of nuclear energy, casting doubts on the neutrality of the report’s findings. All of thesedetailed points of criticism can be found in the report by IPPNW Germany entitled “Analysis of WHO
4report on Fukushima catastrophe“, which is freely available online. No matter how expertly
undertaken, a calculation of health risks can only be as exact as the assumptions that it is based on.
An assessment that relies on data, whose validity has to be questioned on the grounds of lacking
neutrality, selective sampling, distortion and omission of relevant facts, cannot be accepted by thescientific community as a basis on which to make health recommendations.

2. The report ignores the health risks for people outside of Fukushima
While radiation was spread to a large area of northeastern Japan, including metropolitan Tokyo, andcontaminated foodstuff, soil and waste were distributed beyond the borders of Fukushima prefecture,
only the fourteen most affected residential areas (Group 1 and 2 of the WHO report) were considered
5
for the total health risk assessment ,v thereby negating any measurable health effects for the
population of the rest of Fukushima province, Japan and the world. In fact, the report makes the claimthat “outside the geographical areas most affected by radiation, even in locations within Fukushima
1WHO. „Health risk assessment from the nuclear accident after the 2011 Great East Japan earthquake and tsunami, based ona preliminary dose estimation“, 28.02.2013. www.who.int/ionizing_radiation/pub_meet/fukushima_report/en/index.html
2WHO. „Preliminary dose estimation from the nuclear accident after the 2011 Great East Japan Earthquake and Tsunami“,
23.5.2012. whqlibdoc.who.int/publications/2012/9789241503662_eng.pdf
3
Rosen, A. „Analysis of WHO report on Fukushima catastrophe“, 3.8.2012.
www.fukushima-disaster.de/fileadmin/user_upload/pdf/english/ippnw_analysis_WHO-report_fukushima.pdf
4
Rosen 2012.
5
WHO 2013. p. 52.

prefecture, the predicted risks remain low and no observable increases in cancer above naturalvariation in baseline rates are anticipated.”
We know from the Chernobyl catastrophe, however, that while the most affected populations were theones living in the highly contaminated fallout zones, a great number of people living in the lesscontaminated areas in the former Soviet Union, Europe and Asia Minor, were also affected, leading to6
increased incidences of morbidity and mortality . As the health effects of low-dose radiation arestochastic in nature and as the generally accepted tool for calculating cancer risk is the linear nonthreshold (LNT) model, the exposure of a small population with a high amount of radioactivity canhave the similar results in absolute numbers of cancer cases, as the exposure of a large population
with a relatively small amount of radioactivity. While the effects by small amounts of low-dose radiationon large populations are generally more difficult to detect in epidemiologic studies, discounting themaltogether disregards a large amount of cases in absolute numbers and can only be seen as an
attempt to downplay the expected health effects of the nuclear catastrophe.
In the case of Fukushima, the high amount of marine contamination through leaks, deliberatedischarge of highly radioactive waste and fallout has to be taken into consideration, especially due tothe large role that sea-food like fish or algae play in the Japanese diet. Levels of radioactive caesium
measured in North Pacific sea bass rose continually from March until September of 2011, with ath7
maximum contamination of 670 Bq/kg found on September 15 , 2011. With total radioactive marine
contamination of about 15-27 PBq, the Fukushima fallout constitutes the single highest radioactive
8 9 10discharge into the oceans ever recorded.
As many of the critical food samples and findings were
not included in the original dose assessment, the importance of contaminated sea-food for the generalpublic outside of Fukushima prefecture has not been properly accounted for in the current WHO
report.

3. Continued radioactive emissions were not included in the assessment
The WHO report treats the nuclear catastrophe of Fukushima as a singular event and does not take
into consideration continued emissions of radioactivity after the initial nuclear meltdowns in March
2011. In the WHO dose assessment report of May 2012, the authors wrote that “the contribution fromiodine to the total exposure was considered to be zero from four months after the start of the release.”
This assumes that radioactive iodine was released only at the very beginning of the nuclear
catastrophe and that no further emissions occurred, allowing iodine-131 levels to fall due to radioactive
decay. However, in June of 2011, Japanese government scientists still found iodine-131
concentrations of more than 200 Bq/kg in numerous municipalities of Fukushima prefecture, with11
maximum ranges found in Namie and Iitate of 1,300 and 1,100 Bq/kg, respectively. As iodine-131th
has a half-life of 8 days, measurements this high, 90 days after the initial fallout on March 15 , 2011,
suggest additional contamination of the area with iodine-131 at a later time. Similarly, the WHO report
includes vegetable samples containing 2,200 Bq/kg of iodine-131 in month three of the catastrophe –12further evidence for continued emissions of radioactive iodine after the initial explosions, mostprobably due to spontaneous fission or recriticality in one or several of the reactors. Beside iodine-131,
other radioactive particles were also emitted continually for many months. As late as January of 2012,6

Lengfelder, E et al. „10 Years of Chernobyl aid programmes of the Otto Hug Radiation Institute: Treatment and research
projects on thyroid cancer in belarus. 3rd International Conference: Health effects of the Chernobyl accident: Results of 15-year
follow up studies. June 4-8, 2001, Kiev, Ukraine“, Internat. J. Radiat. Med. 3, 73, 2001.
7
Weiss, D. „Contamination of water, sediments and biota of the Northern Pacific coastal area the vicinity of the Fukushima
NPP”, Gesellschaft für Anlagen- und Reaktorsicherheit, Berlin. 31.10.2011.
www.eurosafe-forum.org/userfiles/2_2_%20paper_marine%20environment_Fukushima_20111031.pdf
8
JAIF. „Radioactive release intosea estimated triple”, Japanese Atomic Information Forum, Earthquake Report 199, 9.9.2012.
www.jaif.or.jp/english/news_images/pdf/ENGNEWS01_1315542569P.pdf
9
IRSN, “Synthèseactualisée des connaissances relatives à l’impact sur le milieu marin des rejetsradioactifs du site nucléaire
accidenté de Fukushima Dai-ichi“, 26.10.2011.
www.irsn.fr/FR/Actualites_presse/Actualites/Documents/IRSN-NI-Impact_accident_Fukushima_sur_milieu_marin_26102011.pdf
10
Researchers Assess Radioactivity Released to the Ocean from the Fukushima Daiichi Nuclear Power Facility”, Woods Hole
Oceanographic Institution, 6.12.2011. www.whoi.edu/page.do?pid=7545&tid=282&cid=123049&ct=162
11
Ministry of Education, Culture, Sports, Science and Technology (MEXT). „Readings of soil monitoring”, 7.8.2011.
eq.wide.ad.jp/files/110806soil_1000.pdf
12
WHO 2012, Table A8.2, p. 106.

TEPCO admitted that atmospheric emissions of radioactive caesium were still measured with 60 MBq
13
per hour or about 1,440 MBq each day.
Adding to this are the continued dispersion of radioactive particles from ongoing work at the
Fukushima Dai-ichi plant, reported leaks from radioactive cooling-water tanks and the radioactive
contamination of soil and ground water due to washout. The current WHO report actually goes so far
as to assume a natural “shielding effect”, as radioactive particles like Caesium-137 are washed into
14
the ground and therefore calculates with a decrease in radioactive exposure over the years. While
this may hold true for external radiation risk, this assumption does not take into consideration theincrease in internal exposure through radioactive caesium-137 in ground water supplies and the foodchain. In Southern Germany, radioactive caesium-137 contained in mushrooms and wild boar still
15 16
poses a health threat, even 25 years after the Chernobyl disaster.

4. The report ignores the increased radiosensitivity of the unborn child
The authors of the report claim that the estimated dose levels of the population affected by the
Fukushima catastrophe were too low to affect fetal development, and therefore excluded the possibilityof miscarriages, increased perinatal mortality, congenital defects or cognitive impairments due to in
17
utero exposure. The report also states that the radiosensitivity of a fetus was considerd by theauthors to be the same as for a one-year old child - an assumption that discounts most of what weknow regarding biological factors for radiosensitivity. In fact, the unborn child is the most sensitive formof human life: higher tissue-metabolism and cell-division rates in a fetus increase the chance that
mutations cause malignancies before they can be stopped by the body's self-regulatory mechanisms.
Additionally, as the immune system and cell-repair mechanisms of a fetus are not yet fully developed,
these defensive mechanisms cannot adequately prevent the development of cancer. The claim that
fetuses would have the same sensitivity towards radioactivity as a child becomes even more difficult toaccept, as the report itself clearly states that radioactive particles, such as iodine-131 or caesium-137,
18
reach the fetus inside the womb through the umbilical cord, causing internal irradiation. Additionally,
the fetus can be externally irradiated by radiation from isotopes collected in the bladder.
It has long been established fact that a fetus has to be especially protected from irradiation. The
effects of low-dose radiation on the unborn child are known since the 1950’s, when the Oxford Surveyof Childhood Cancers showed a highly significant increased risk for leukemia in children who had been
exposed to diagnostic x-rays in utero. This association has been confirmed by many case-control
19
studies since. The medical profession has acted on these findings by advising against radiologicalprocedures on pregnant women and by promoting restrictions for pregnant women working in settings
that could expose them to radioactivity. Discouting the higher radiosensitivity of the fetus and thebreastfed child and disregarding the specific health risks of the most vulnerable of the affected20
population has led to a gross underestimation of actual health risk in the WHO report.
The authors explain this procedure, by basing their assumptions on the Lifetime Span Studies (LSS),
performed on the survivors of the nuclear bombings of Hiroshima and Nagasaki – studies that were
21
only started in 1950, five years after the events occurred. How studies on the survivors of the mostly
external radioactive exposure of the nuclear bombs, without any scientific knowledge from the first five
years, including no records of miscarriages, neonatal mortality or congenital defects, could be
13

TEPCO. „Current Status of Fukushima Daiichi Nuclear Power Station”, 27.1.2012.
www.tepco.co.jp/en/nu/fukushima-np/f1/images/f12np-gaiyou_e_3.pdf
14
WHO 2013, p. 41.
15
BMG. „Radioactive Contamination of Wild Boar”, German Ministry of Health.
bmg.gv.at/home/Schwerpunkte/VerbraucherInnengesundheit/Radioaktive_Belastung_von_Wildschweinen)
16
Hawley, C. „A Quarter Century after Chernobyl: Radioactive Boar on the Rise in Germany“, Spiegel Online, 30.07.2010.
www.spiegel.de/international/zeitgeist/a-quarter-century-after-chernobyl-radioactive-boar-on-the-rise-in-germany-a-709345.html
17
WHO 2013, p. 8, 67.
18
WHO 2013, p. 18, 140.
19
International Agency for Research on Cancer. „X- and gamma radiation, and neutrons. Ionizing radiation“ in „Monographs on
the evaluation of carcinogenic risks to humans“, Volume 75, 1999. monographs.iarc.fr/ENG/Monographs/vol75/mono75.pdf
20
WHO 2013, p. 30.
21
Preston DL et al. „Cancer incidence in atomic bomb survivors. III. Leukemia, lymphoma and multiple myeloma, 1950-1987“,

transferred to a scenario where children and fetuses were exposed to mostly internal radioactivity after
a nuclear catastrophe is not adequately addressed by the report’s authors.

5. Recent clinical findings were not taken into considerations
According to the report, “no clinical conditions have been identified” as a result of the Fukushima
22
nuclear catastrophe. Not mentioned in the report are the three cases of thyroid cancers nor thereported increase in infant mortality following the Fukushima nuclear meltdowns. While it is difficult toprove causality and further research is definitely necessary to investigate the extent and the probablecause of these phenomena, omitting them from the report altogether once more throws doubts on thereport’s neutrality.
th

On February 13 , 2013, the Fukushima prefectural government announced that three cases of thyroid
23 24
cancer had been diagnosed and that the children had to undergo surgery.
Further details regarding
the three cases were not published, but these findings are highly unusual, as spontaneous thyroid
cancer in children below the age of 18 are very rare, especially when they appear in clusters such as
25
the one in Fukushima. While the report concedes that protracted exposure to radioactive iodine
could cause thyroid abnormalities and that even low doses of radiation may increase the risk of noncancer thyroid nodules in exposed individuals, quantitative assessment of these phenomena was not
26
undertaken.
While it is extremely difficult to detect the effects of low-dose radiation on large populations, astatistical evaluation of Japanese infant mortality found distinct peaks in May 2011 and December
2011, two and nine months after the beginning of the nuclear catastrophe in Fukushima. An analysis
of West German infant mortality data after the Chernobyl disaster also found peaks in the same timespan after the nuclear meltdown. In December 2011, nine months after Fukushima, the number of live
births in Japan was significantly lower than the average of the past nine years. A similar decline in live
births was found in February 1987 in the most fallout-affected region of Southern Germany. In both27
scenarios, the effect on birth rates appears to be limited to a single month. As stated above, theWHO health risk assessment specifically states that no impact on fetal development or perinatal
mortality would be expected, as the assumed radiation dose was deemed too low for such effects to28
take place. An alternative explanation of the recent findings is not offered by the report, nor are thesefindings included in the final health risk assessment.

6. Non-cancer diseases are not included in the health risk calculations
Non-cancer health effects, such as cardiovascular diseases (CVD), infertility or thyroid disease were
not assessed quantitatively in the report. Furthermore, the possibility of such effects occurring as a29
result of the Fukushima nuclear catastrophe was disregarded altogether. The authors assumed that
only high levels of radioactivity could lead to such effects, discounting the research on the effects of
30 31
low-dose radiation.

22

WHO 2013, p. 27.
„2 more thyroid cancer cases identified in Fukushima”, Kyodo News, 13.02.2013.
english.kyodonews.jp/news/2013/02/209091.html
24„2 more thyroid cancer cases identified in Fukushima“, Mainichi Newspaper, 13.02.2013.
mainichi.jp/english/english/newsselect/news/20130213p2g00m0dm091000c.html
25
Albright JT et al. „Pediatric head and neck malignancies: US incidence and trends over 2 decades“, Arch Otolaryngol Head
Neck Surg, Jun 2002;128(6), p. 655-9.
26
WHO 2013, p. 22,67.
27
Körblein, A. „Infant mortality in Japan after Fukushima“. Strahlentelex, No. 622-623, 6.12.2012.
www.strahlentelex.de/Infant_mortality_in_Japan_after_Fukushima.pdf
28
WHO 2013, p. 8, 67.
29
WHO 2013, p. 67.
30
Yablokov A et al. „Chernobyl: Consequences of the Catastrophe for People and the Environment”, Annals of the New York
Academy of Sciences, Volume 1181, December 2009. bit.ly/mo29TZ
31
Little MP et al. „A Model of Cardiovascular Disease Giving a Plausible Mechanism for the Effect of Fractionated Low-Dose
Ionizing Radiation Exposure.“ PLoS Comput Biol. 2009 October; 5(10). www.ncbi.nlm.nih.gov/pmc/articles/PMC2759077
23

7. The report relies solely on TEPCO’s own data to assess workers’ health risks
The WHO report also comments on the health risks of TEPCO workers and contractors due toexposure to radioactivity. Since the report bases its assumptions solely on measurements provided by
TEPCO itself,xxxv these estimates cannot be considered adequate assessments of the workers’ healthrisks, especially after reports of misleading information, falsified dosimetry readings and other32 33
irregularities have severely compromised the validity of the TEPCO data.

8. The authors’ neutrality has to be doubted
One of the main points of criticism of the WHO dose assessment of May 2012 was its apparent lack ofneutrality. With an expert panel comprised mainly of scientists associated with the International Atomic
Energy Agency (IAEA) and members of nuclear regulatory bodies accused of collusion with thenuclear industry, and with findings that differ so significantly from other, independent research
publications, the dose assessment gave the impression of attempting to downplay the effects of thenuclear catastrophe, rather than constituting a meaningful scientific approach to the issue of radiation
exposure in Fukushima. It remains unclear why a report, written mainly by the IAEA and collaborating
nuclear institutions, would need to be published in the name of the WHO.
This current WHO report was again composed in large parts by scientists with an evident conflict ofinterest. The report has not undergone the usual scientific process of peer-review, nor were scientists
with more critical views of the health effects of radioactivity invited to join the expert panel. Concerning
the very relevant issue of childhood leukemia, the WHO’s health risk assessment relies heavily on theexpertise of one Prof. Wakeford, who is cited as an expert on “radiation effects in infants and children,
34
particularly on childhood leukaemia.” However, Prof. Wakeford has worked for more than thirty years
for the company British Nuclear Fuels plc and has been paid for consultancies at the nuclear powercompany EDF Energy plc, Augean plc, which makes money by handling radioactive waste, British
Nuclear Fuels plc and Sellafield Ltd, a company battling with the legacy of numerous nuclear
35
accidents and spills. Unlike in the first WHO report on Fukushima, these obvious conflicts of interest
have been disclosed in the current report, but it remains unclear why, for a critical assessment of a
nuclear catastrophe, the WHO relies on a scientist, who has worked most of his life for the British
nuclear industry.
In order to understand why the WHO has to rely so heavily on experts from the nuclear sector, it has
to be reiterated at this point that the WHO is subordinate in questions of nuclear safety to the IAEA.
According to Articles 1.3. and 3.1. of the “Agreement between the IAEA and the WHO” from 1959, theWHO is bound by agreement not to publish anything concerning radiation without consent by the36
IAEA. The IAEA, however, was founded with the specific mission to "promote safe, secure andpeaceful nuclear technologies" and to “accelerate and enlarge the contribution of atomic energy to37peace, health and prosperity throughout the world.” With these motives, the IAEA and its national
member organizations cannot be seen as impartial voices on nuclear energy. The influence of the
IAEA on the work of the WHO has therefore rightly been criticized for obstructing independent
research on the health effects of nuclear radiation.

32„63 workers exposed to higher radiation than logged in their records.” Asahi Shimbun, 2.3.2013.
ajw.asahi.com/article/0311disaster/fukushima/AJ201303020048
33„TEPCO subcontractor used lead to fake dosimeter readings at Fukushima plant.” Asahi Shimbun, 21.7.2012.
ajw.asahi.com/article/0311disaster/fukushima/AJ201207210069
34
WHO 2013, p. 120.
35
WHO 2013, p. 120.
36
WHO. „Agreement between the International Atomic Energy Agency and the World Health Orgnization.“ WHO Website.
apps.who.int/gb/bd/PDF/bd47/EN/agreements-with-other-inter-en.pdf
37
IAEA. „Atoms for Peace“, IAEA Website. www.iaea.org/About/

Conclusion
As doctors and scientists, we are fully aware of the difficulties in calculating comprehensive healthrisks of a large catastrophe for such a large population and know of the problems that naturally arise insuch an attempt. It is extremely important to base calculations such as these on reliable and validdata, which has been approved by a scientific consensus either through an impartial expert panel
composed of scientists with contrary views, or through a critical peer review process. The possibility ofa manipulation of data by a group, organization or industry with vested interests should be avoided at
all costs. The calculations should encompass the entire population affected by the catastrophe andshould give special consideration to groups with heightened vulnerability. Clinical findings should bethoroughly assessed and included in the final considerations.
After careful lecture of the WHO’s health risk assessment, none of these fundamental principles seemto have been adhered to. The true health risks for the people of Fukushima and Japan remain to beassessed by independent scientific researchers, free of the suspicion of collusion and interference by
the nuclear industry and the nuclear regulatory bodies. Attempts by the nuclear lobby, including the
IAEA and many of the authors of this current WHO report, to downplay the effects of the continued
emission of radioactive isotopes in air, soil and water through dubious risk assessments are to be
disregarded by scientists, doctors and politicians, primarily concerned with giving the affected people
proper recommendations and support. What is needed is for the WHO to regain its independence inassessing health risks related to radiation and reaffirm its claim to be guided solely by concerns forpeople’s health and not by the interests of a specific industry.