Statement on the proposed update of ICRP Publications 109 and 111
Citizens’ Commission on Nuclear Energy (CCNE)
24 October 2019
This statement, together with our previous open letters (dated 9 Aug and 9 Sep 2019;http://eng.ccnejapan.com/?p=120) already presented to the secretariat of ICRP,
constitutes a public comment from CCNE on ICRP’s draft report: RadiologicalProtection of People and the Environment in the Event of a Large Nuclear Accident Update of ICRP Publications 109 and 111 (hereafter ‘the ICRP draft’). More specificcomments on the ICRP draft, including alternative wording, have already been
submitted individually by members of CCNE and thus will not be repeated in thisdocument.

CCNE appreciates ICRP’s recent decisions, partly upon our request in the open letters,
to invite Japanese stakeholders to submit their comments to ICRP in Japanese, and toassure that all the public comments submitted in Japanese will be treated fairly in the
consultation procedures onward.
CCNE must request, however, that ICRP should suspend the revising procedures of
Publications 109 and 111 and should instead start a fresh discussion and consultation
process to update its fundamental recommendations of 2007（Pub.103) in order to keep
consistency and improve adequacy in the radiation protections.
When restarting to revise Pub.109 and 111 duly after reviewing their mother document(Pub.103), it would be imperative for ICRP/TG93 to invite the victims of the
Fukushima nuclear accident, who should be regarded as the most significant
stakeholders to collaborate with, to participate from the very early stage of theconsultation process. ICRP should also be fully aware of the diversity of thecircumstances in which different victim groups stand.
Key reasons for making such a call as above are illustrated in 6 sections below:

1

New reference levels - a deviation from the 2007 framework?

The ICRP draft contains substantial changes in the handling of the referential doselevels. The proposed changes appear to be deviant from what is prescribed in the 2007
recommendations of ICRP, which is supposed to be the mother framework for Pub.109
and 111. Suggestion to introduce 10mSv per year as a new reference level in the existing
exposure situations, along with the previous 1-20mSv range, will just bring about aconfusion and mismanagement. The conventional annual standard of 1mSv as thetarget of exposure reduction seems to become less hard-and-fast accordingly. This
would make the notion of ALARA less ambitious, against the welfare of the residents in1

the areas affected by a nuclear accident.
In dealing with the Fukushima nuclear accident, a number of radiological professionals
and Government officials publicly and repeatedly stated that radiation exposure below
the effective dose of 100mSv would pose no health risk, quite against the LNT model
adopted in the ICRP 2007 recommendations [Para (36)].	
  The Japanese Government
failed to make adequate use of the reference levels as ICRP recommended. This caused
serious confusions and doubt, not only among the residents in the affected regions but
also more widely among the general public, over the dose thresholds set out by theGovernment without reasonable explanations.
What ICRP should do is to reconfirm the LNT model as the basis of radiation
protection and to give firm advice to the Japanese authorities to take progressive
measures to reduce exposures below the reference level. Should individual dose levels
to refer to for optimization purposes be modified, then the fundamental
recommendations of 2007 as the mother directives of Pub.109 and 111 would need to berevised on the basis of new research findings and verifications.
(CCNE tends to be unconvinced of the ICRP notion of the reference levels as set downin its current Pub.103, but we do not go into debate on it here. )2 Poor recognition and bias about the serious damage caused by
the Fukushima accident
The ICRP draft is about the radiological protection of all affected individuals and theenvironment [Para (5)], and the experiences of the Fukushima in addition to those of
the Chernobyl have obviously been a strong reason to update the ICRP guidelines.
Notwithstanding, the draft, particularly in Annex B, reveals limited understanding ofwhat the deep and long-term impacts of a large nuclear accident on people and theenvironment is like.
After more than 8 years now, on-site treatment works with the melted-down reactors
still bear poor prospect due to the extremely high radiation in and around the reactor
buildings; extensive areas off-site remain exclusion zones where the population is notallowed to enter or stay; and tens of thousand of people continue to be taking refuge. Asa matter of fact, no ministry or authority can tell exactly how many the refugees are,since a considerable number of people have been obliged to leave their homes with orwithout an official evacuation directive.
Radioactive plumes and the fallout flowed across regional boundaries, thus seriously
contaminating quite a few towns and environment outside Fukushima Prefecture.
Notably a large population suffered from radiation exposure externally and/orinternally during the early phases of the accident. The ICRP draft has only scarcereferences to such early exposures of the general public (largely due to the2undervaluation made by UNSCEAR - see 6.2 below) in and outside Fukushima
Prefecture, and to the necessity of long-term protective measures for those exposed.
On the other hand, the ICRP draft praises the value of the Fukushima Dialogue
workshops as a successful “co-expertise process” (B.4.5). The draft especially focuses on
the “self-help protective actions” taken by residents of the affected areas andemphasizes the role of such actions in developing what is called “radiological protection
culture”. The Fukushima Dialogue is, however, a framework of a restricted nature
mainly aimed for those who bear continued residence in the lastingly contaminatedareas and those who have returned from temporary refuge. Its emphasis on the
self-help of the residents is too narrow a perspective and is hardly regarded as a major
lesson of the large nuclear accident that had at one time over 200,000 people exiled
from their home.
Proper compensations are essential for the victims to reconstruct their livelihood.
Scores of litigations and outside-court mediations (ADR) have been proceeding, during
which dreadful experiences are testified by those who had to evacuate and also by those
who were, due to circumstances, obliged to stay in the contaminated areas. The ICRP
draft seems indifferent to those valuable testimonies. It would be a shame if a newinternational guidance for radiological protection were ever compiled only based onsuch a scanty recognition of the actual lessons of the severe nuclear accident ofFukushima.
Since the extensive radioactive fallout of the Fukushima accident became evident, while

official aids and support being quite limited, grassroots groups and individual citizens
in Japan have managed to set up more than 80 independent radiation monitoring
facilities nationwide, with the support of concerned experts, civil-society organizations
and understanding business entities. Many of these monitoring groups are now linked
as a network, which co-operates in calibration and data quality management,
successfully integrating and publishing the monitoring results and analysis. There are anumber of non-governmental programs of ultrasound examination of thyroid, mainly
for children, in and outside Fukushima. There are also a numerous variety of recess andrecreation programs regularly inviting children from the affected regions. ICRP should
pay much more attention to these wider contexts of civil actions for radiologicalprotection.

3

Arbitrary use of the ICRP standards by Japanese authorities

Looking at the official policies and practices of the Japanese Government as to theoff-site radiological protection of the general public in the Fukushima accident, themost serious breach in the light of the current ICRP guidelines was the complete failureof stakeholder participation as required and stressed by ICRP in making decisions that
directly affect the local population. The authorities only “briefed” to the residents about3the unilateral Government decisions of whether or not to issue evacuation directives toparticular areas. Unilateral decisions were also made when lifting the evacuation
directives, sometimes even without local briefings. The ICRP references to the annual
dose of 1mSv and 20mSv were handled quite arbitrarily and inconsistently.
The lack of good consultation and communication has caused an awful lot of frictions
and end up in the public distrust of the authorities. ICRP is urged to investigate,
feasibly with the Japanese authorities and third-party expert bodies, how such a
distrust have emerged in the aftermath of the nuclear emergency; provide the Japanese
Government what measures and considerations to take in order to avoid the problems;and reflect those findings in the next revision of the ICRP recommendations.
(Another grave breach in the Fukushima which would need a serious attention of ICRP
was the poor off-site monitoring and the very patchy thyroid dose measurement, incomparison with the Chernobyl, at the early stage of the accident.)

4

Conflict of interests

The Code of Ethics of ICRP defines that it operates independently from any
Government or other organizations. In the current procedures of updating Pub.109
amd 111, TG93 of ICRP is responsible for compiling the draft recommendations, which
will be advised upon ICRP Main Commission’s approval to the Governments worldwide.
It turned out, however, that the Chair of TG 93 is a Japanese-Government-appointed
member of the country’s official Radiation Council. Additionally, the Deputy Chair of
TG93 is a full-time employee of the Nuclear Regulation Authority (NRA), Japan’snational nuclear regulator. The Radiation Council is the official body that advises theJapanese Government specifically on radiological protection matters. And the Council
is administered by NRA. These obvious conflicts of interest cast doubt about
independence, objectivity and impartiality of ICRP’s advice to the Japanese
Government. The ICRP draft itself points out the fact that Japanese authorities andradiation experts almost lost credibility in the aftermath of the explosions at thenuclear power station. ICRP should observe its own Code of Ethics and strictly review
its membership of the TGs, the Main Commission and Committees.

5

Accident victims should be consulted from the beginning

Before setting out new recommendations, ICRP should study carefully why and how
Japanese authorities failed to protect the people and the environment from the harshradiation caused by the Fukushima nuclear accident, especially why the existing ICRP
principles did not work in Japan as designed and supposed by ICRP experts. We
therefore request that the current process of revising the protection guidelines besuspended. We have proposed earlier, in our August and September letters to ICRP,
several ways to improve the ICRP consultation process with more involvement of4

diverse stakeholders actually affected by the Fukushima disaster. We see a good will of
ICRP as it started to accept public comment in Japanese at ICRP’s official website. Butother proposals, such as holding further public hearings in the affected regions, andprovision of an official Japanese edition of the ICRP draft, have been turned down to
our disappointment.
Substantial participation of the residents of the affected areas and other general-public
stakeholders from the very initial stage of consultation is essential in order to improve
the radiation protective policies, incorporating hard lessons of the large nuclear
accidents.

6

Biased or partial references

References cited in the ICRP draft are rather biased, or at least partial, allegedly
excluding a number of important scientific works and key first-hand reports whichreflect more serious outcomes of large nuclear accidents. Given below is a tentative listof the titles ICRP would have to take a serious look at. Most of these appeared after the2007 release of ICRP Pub.103. Note that the list is not exhaustive.

6.1 Health risk of low-level (under 100mGy) ionizing radiation
Cardis E et al (2007), The 15-Country Collaborative Study of Cancer Risk among Radiation
Workers in the Nuclear Industry: Estimates of Radiation-Related Cancer Risks. Radiation
Research 167(4): 396-416.
Grant EJ et al. (2017), Solid Cancer Incidence among the Life Span Study of Atomic Bomb
Survivors: 1958-2009. Radiation Research 187(5): 513-537. doi: 10.1667/RR14492.1.
Epub 2017 Mar 20.
Kendall GM et al (2012), A record-based case–control study of natural background radiationand the incidence of childhood leukaemia and other cancers in Great Britain during
1980–2006. Leukemia (2013) 27: 3–9.
Krestinina LY et al (2007), Solid cancer incidence and low-dose-rate radiation exposures in the
Techa River cohort: 1956–2002. Int. J. Epidemiol. 36 (5): pp.1038-1046.
Leuraud K et al. (2015), Ionising radiation and risk of death from leukaemia and lymphoma inradiation-monitored workers (INWORKS): an international cohort study. Lancet
Heamatol. June 22, 2015.
Lubin JH et al. (2017), Thyroid Cancer Following Childhood Low-Dose Radiation Exposure: A
Pooled Analysis of Nine Cohorts. J Clin Endocrinol Metab. 102(7): 2575-2583. doi:
10.1210/jc.2016-3529.
Mathews JD et al (2013), Cancer risk in 680 000 people exposed to computed tomography scansin childhood or adolescence: data linkage study of 11 million Australians. BMJ 346 f2360.
National Council on Radiation Protection (2018), Implications of Recent Epidemiologic Studies
for the Linear Nonthreshold Model and Radiation Protection. NCRP Commentary No.27

5

Nikkila A et al. (2016), Background radiation and childhood leukemia: A nationwide
register-based case-control study. Int J Cancer. 2016 Nov 1;139(9):1975-82. doi:
10.1002/ijc.30264. Epub 2016 Jul 22.
Nikkila A et al. (2018), Effects of incomplete residential histories on studies of environmental
exposure with application to childhood leukemia and background radiation. Environ Res
166: 466-472.
Ozasa K. et al (2012), Studies of the Mortality of Atomic Bomb Survivors, Report 14, 1950–
2003: An Overview of Cancer and Noncancer Diseases. Radiation Research 177(3):229-243.
Pearce MS et al (2012). Radiation exposure from CT scans in childhood and subsequent risk ofleukaemia and brain tumours: a retrospective cohort study. The Lancet, Vol.380, Issue
9840:

499–505.

Richardson DB et al. (2015), Risk of cancer from occupant exposure to ionizing radiation:
retrospective cohort study of workers in France, the United Kingdom, an the UnitedStates (INWORKS). BMJ 351: h5389.
Spycher BD et al. (2015), Background ionizing radiation and the risk of childhood cancer: acensus-based nationwide cohort study. Environ. Health Perspectives,123: pp.622-628.

6.2	
  Criticism of the UNSCEAR Report on Fukushima
Annex B of the ICRP draft seems to heavily depend on the findings of UNSCEAR
mission to Japan. It should be noted, however, that the UNSCEAR’s Fukushima report
does not stand without objections, particularly its underestimation of the radiation
exposure. Just to give one example here:
Baverstock K (2014), 2013 UNSCEAR Report on Fukushima: a critical appraisal. Kagaku 84(10)electric edition: e0001-e0008. Tokyo: Iwanami Publishers.

www.iwanami.co.jp/kagaku

6.3 Diverse aspects of the damage caused by the Fukushima nuclear accident
CCNE has found that Annex B of the ICRP draft fails to recognize the seriousness of thesocial and communal consequences of the large nuclear accident. The following articles
and reports depict what sorts of damage have socially taken place and are ongoing andeven worsening partly due to the Government’s mismanagement so far.
Funabashi H (2012), Why the Fukushima nuclear disaster is a man-made calamity.
International Journal of Japanese Sociology 21: 65-75.
https://onlinelibrary.wiley.com/doi/pdf/10.1111/j.1475-6781.2012.01161.x
Kimura AH (2018), Fukushima ETHOS: post-disaster risk communication, affect, and shifting
risks. Science as Culture 27(1): 98-117.
www.tandfonline.com/doi/full/10.1080/09505431.2017.1325458

6

Kimura AH (2016), Radiation brain moms and citizen scientists: the gender politics of foodcontamination after Fukushima. Duke Univ Press.
Hasegawa R (2015), Returning home after Fukushima: displacement from a nuclear disasterand international guidelines for internally displaced persons. Migration, Environment
and Climate Change: Policy Brief Series 1(4): pp.1-8.
http://reliefweb.int/report/japan/returning-home-after-fukushima-displacement-nuclea
r-disaster-and-international
Shirabe M, Fassert C and Hasegawa R (2015), From risk communication to participatory
radiation risk assessment. Fukushima Global Communication Programme Working Paper
Series 21.

http://i.unu.edu/media/ias.unu.edu-en/news/12850/FGC-WP-21-FINAL.pdf

CCNE (2015), The state of affairs and ongoing challenges of the Fukushima nuclear disaster: acivil society response toward recovery (WCDRR 2015 Edition) - chapter 1: An overview
of the damage caused by the Fukushima nuclear power plant accident and the"Restoration of Humanity".

www.ccnejapan.com/eng/policy_outline_0-2.pdf

Fujigaki Y (ed.) (2015), Lessons from Fukushima: Japanese case studies on science, technology
and society. Springer.
Gill T, Steger B and Slater DH (eds.) (2015), Japan copes with calamity: ethnographies of theearthquake, tsunami and nuclear disasters of March 2011. [2nd Ed.] Oxford: Peter Lang.
Dawe A et al (2016), Nuclear Scars: the lasting legacies of Chernobyl and Fukushima.
Greenpeace International
www.greenpeace.org/archive-international/en/publications/Campaign-reports/Nuclearreports/Nuclear-Scars/
Report of the Special Rapporteur on the right of everyone to the enjoyment of the highest
attainable standard of physical and mental health, Anand Grover: Mission to Japan (1526 November 2012). United Nations Human Rights Council. A/HRC/23/41/Add.3
United Nations Human Rights Council (2018), Report of the Working Group on the Universal
Periodic Review - Japan. A/HRC/37/15
www.ohchr.org/EN/HRBodies/UPR/Pages/JPIndex.aspx
Tuncak B (Special Rapporteur on the implications for human rights of the environmentallysoundmanagement

anddisposalofhazardous

substancesandwaste)

andJimenez-Damary C (Special Rapporteur on the human rights of internally displaced
persons), Joint communication from Special Procedures, 5 September 2018. United
Nations Human Rights Council. (Ref. AL JPN 6/2018)www.mofa.go.jp/files/000416301.pdf

6.4	
  Health consequences of Chernobyl
Annex A of the ICRP draft should have listed Yablokov-Nesterenko-Nesterenko (2009)
below, as a comprehensive and critical review of the medical and statistical records of
the Chernobyl disaster. It is reminded that this monumental title has a Japaneseedition (2013), which is in fact an amply revised, corrected and expanded version of the2009 English edition (New York) and a later revised Russian edition (Kiev).
7

Yablokov AV, Nesterenko VB & Nesterenko AV (2009), Chernobyl: Consequences of theCatastrophe for People and the Environment. Annals of the New York Academy of
Sciences, vol. 1181.
Yablokov, AV, Nesterenko VB, Nesterenko AV and Preobrazhenskaya NE (2013), Chernobyl:
Consequences of the Catastrophe for People and the Environment (Original text for theJapanese edition published on April 26, 2013, from the Iwanamii Publishers, Tokyo)[ End of CCNE Statement ]lCitizens’ Commission on Nuclear Energy (CCNE, eng.ccnejapan.com) is
an independent research and advocacy body, established after the Fukushimadisaster in order to devise a new, comprehensive, ethical and viable policy
concerning nuclear power phaseout and related issues in Japan. The
commission is administered by the Takagi Fund for Citizens’ Science, Tokyo(an authorized charity corporation). CCNE currently consists of a board of 13
commissioners, four Working Groups (commissioners plus additional
members), an advisory panel of experts and a secretariat. It has more than 80
members with a wide range of expertise such as social sciences, ethics, law,
technologies (including nuclear engineering), biological and medical sciences;the members also include a number of the residents directly affected by the
Fukushima nuclear accident 2011 and on.
Contact CCNE at < email@ccnejapan.com > or +81 3 3358 7064
postal address: c/o The Takagi Fund, 3F Arai Bdg, 4-15 Yotsuyahonshio,
Shinjuku 160-0003 Tokyo, Japan	 8