Review of the radiological monitoring programmes
Source: environment.data.gov.uk (2025-10-10)

Radiological Monitoring Data. Radioactivity monitoring reports used to ensure that any radiation present in the environment or food chain does not compromise food safety.

REVIEW OF  
FOOD STANDARDS AGENCY  
RADIOLOGICAL MONITORING PROGRAMMES 
 
 
 
 
February 2006 
 
 
 
 
 
 
 
 
 
 
 
1 

GLOSSARY 
CBRN 
 
Chemical, Biological, Radiological, Nuclear 
CEFAS 
 
Centre for the Environment, Fisheries and Aquaculture Science 
CFIL  
 
(European) Council Food Intervention Levels 
COGEMA  
Compagnie Générale des Matières Nucléaires 
CoRWM 
 
Committee on Radioactive Waste Management 
Defra 
 
Department for Environment, Food and Rural Affairs 
DTI  
 
Department of Trade and Industry 
EA 
 
 
Environment Agency 
EC 
 
 
European Commission 
EU 
 
 
European Union 
Euratom 
 
European Atomic Treaty 
FSA  
 
Food Standards Agency 
HPA-RPD  
Health Protection Agency, Radiation Protection Division 
KMEI 
 
Key Marine Environmental Indicators 
LoD  
 
Limit of Detection 
NDA  
 
Nuclear Decommissioning Authority 
NRPB 
 
National Radiological Protection Board (now HPA – RPD) 
OBT  
 
Organically-Bound Tritium 
OECD 
 
Organisation for Economic Co-operation and Development 
OSPAR 
 
Oslo and Paris Convention 
PSRE 
 
Public Sector Research Establishments 
RIFE  
 
Radioactivity in Food and the Environment 
RSA 93  
 
Radioactive Substances Act 1993 
SEPA 
 
Scottish Environment Protection Agency 
TDS  
 
Total Diet Study 
TNORM 
 
Technologically-enhanced Naturally-Occurring Radioactive Material 
UKAS 
 
United Kingdom Accreditation Service 
VLA  
 
Veterinary Laboratories Agency
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CONTENTS 
 
EXECUTIVE SUMMARY 
1.  INTRODUCTION 
2.  OBJECTIVES OF THE RADIOLOGICAL MONITORING PROGRAMME 
2.1  Background 
2.2  The Agency’s statutory requirements 
2.3  The Agency’s radiological programmes 
3.  THE REVIEW OF THE RADIOLOGICAL PROGRAMMES 
3.1  The aim of the review 
3.2  The terms of reference of the review 
3.3  The review panel 
3.4  The review panel meetings 
4.  THE REVIEW 
4.1  Approach adopted 
4.2 The Framework of the review  
4.3  The Agency’s statutory and EU commitments 
4.4  The benefits of the programme 
 5.  OUTCOME OF THE REVIEW 
5.1  The stated aims of the programmes 
5.2  The future size and scope of the programmes 
(i)   Resources 
(ii)  Duplications, overlaps and gaps 
(iii) Site specific aspects 
(iv) Dose trends 
(v)  Programme management 
5.3  The Strategic value of the programmes 
5.4  Scope for savings within the programmes  
5.5  Flexibility within the programmes.  
5.6  Scope for innovation and horizon scanning 
6. CONSIDERATIONS OF THE PANEL 
7. ACKNOWLEDGEMENTS 
 
 
3 

ANNEX 1 
DOCUMENTS SUPPLIED TO THE PANEL 
 
 
4 

EXECUTIVE SUMMARY 
 
This report describes the review of the Food Standards Agency’s radiological 
monitoring programmes, the outcome and objectives and the panel’s 
recommendations for the future size and scope of the programmes. 
 
The overall aim of the review was to consider the overall balance between the 
benefits of the programme; namely ensuring that intakes of radioactivity in the diet 
are not harmful to health, delivering the Agency’s statutory obligations and the 
strategic value of the programme, against the resources required to deliver the 
programme. 
 
The specific objectives of the review were: 
• To consider whether the Agency was meeting the stated aims of the 
programmes. 
• To advise on the future size and scope of the programmes, balancing the 
resources required against the stated aims and obligations, and taking into 
account the trends in results. 
• To comment on the strategic value of the programmes. 
• Specifically, to consider the scope for reducing the number of samples and 
costs whilst maintaining the strategic value of the programmes. 
• To comment on the flexibility within the programmes to meet potential future 
needs. 
• To consider what scope there may be for innovation in the programmes. 
 
The panel considered that the programmes met the Agency’s remit to protect public 
health and ensure that doses of man-made and natural radioactivity in foods did not 
pose an unacceptable risk to consumers.  
 
For man-made radioactivity and also natural radioactivity enhanced by man, the 
programmes were of sufficient size and scope to ensure that annual doses to critical or 
vulnerable groups of consumers could be calculated to compare to EU dose limits, as 
defined in UK legislation by the Basic Safety Standards Directive 96/29/Euratom. 
 
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The panel considered that the programmes fulfilled the Agency’s obligations for 
monitoring and reporting on concentrations of man-made and natural radionuclides in 
foods to show compliance with Euratom Treaty Articles 35 and 36 and OSPAR 
commitments.  
 
The panel also considered that the programmes were of sufficient breadth to ensure 
that any new or potential pathway of significant exposure to consumers would be 
identified and monitored, if necessary. 
 
However, the panel concluded that the ability of the programmes to meet the four 
stated aims of the radiological monitoring programmes and the minimum requirements 
of EURATOM and OSPAR could probably be met by a smaller programme than that 
currently in place.  Although this would be at the expense of losing some data, the 
panel considered that some savings could be made without compromising the strategic 
value of the Agency’s programmes.  
 
Potential savings in resources were identified on merit against the framework 
assumptions and equally covered work funded by industry (cost-recoverable) and 
that wholly funded by the Agency (non-cost recoverable) programmes.  
 
 
 
6 

1. 
INTRODUCTION 
 
This report describes the review of the radiological monitoring programmes that are 
currently the responsibility of the Emergency Planning, Radiation and Incidents 
Division (EPRI) of the Food Standards Agency (the Agency). 
 
The review was carried out by a panel of four independent experts. This report 
describes the review, the outcome and objectives and the panel’s recommendations for 
the future size and scope of the radiological monitoring programmes. 
 
2. 
OBJECTIVES OF THE RADIOLOGICAL MONITORING PROGRAMMES 
2.1 
Background 
The aim of the Food Standards Agency’s radiological monitoring programmes is to 
ensure that doses from the presence of both man-made and natural radioactivity in 
foods do not pose an unacceptable risk to consumers. 
 
Doses to consumers are calculated from the measured concentrations of each 
radionuclide in each individual food in the diet, combined with consumers’ annual 
consumption data and with a value representing the radiotoxicity of each radionuclide 
in the body. 
 
For man-made radioactivity, and also natural radioactivity enhanced by man, the 
programmes aim to ensure that doses to consumers are within prescribed EU annual 
dose limits, as defined by the Basic Safety Standards Directive 96/29/Euratom, 
particularly with regard to critical or vulnerable groups of consumers in high-risk areas. 
  
For radioactivity that is entirely of natural origin there are no legal dose limits. However, 
concentrations of radioactivity in foods vary across the UK. For example, 
concentrations in some terrestrial foods may vary because of differences in rainfall 
patterns and soil characteristics, and a range of values is observed in seafood around 
our coast. The programmes include sampling of representative consumer diets in order 
to put the dose from man-made radioactivity into context, to provide information on 
background levels of radioactivity in food and to be able to distinguish if background 
levels have been enhanced by discharges of man-made radioactivity from industry. 
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The programmes also aim to monitor and report on concentrations (not consumer 
doses) of a range of man-made and natural radionuclides in foods to show compliance 
with Euratom Treaty Articles 35 and 36 and OSPAR commitments on monitoring and 
reporting. 
 
Finally, the sampling strategy within the programmes is also aimed at ensuring that any 
new or potential pathways of significant exposure to consumers can be identified and if 
necessary be appropriately monitored.  
2.2 
The Food Standards Agency’s Statutory Requirements 
The Basic Safety Standards require assessments to be undertaken of total 
retrospective dose to the general public, from all sources of man-made radioactivity via 
all possible pathways of exposure.  This is co-ordinated by EA (and SEPA in Scotland) 
with the Agency providing estimates of doses from food, which is the largest contributor 
to the total dose from discharges.  
 
The Euratom Treaty requires Member States of the EU to monitor and report the 
concentrations of a range of specific radionuclides in representative diets and in a 
number of foods every year. The Agency is the relevant nominated competent authority 
for the UK. 
 
In the event of the EU declaring an emergency after a radiological incident, EC Council 
Regulation (EURATOM) 3954/87 would come into force and the Agency would have a 
statutory obligation to ensure that no foods were offered for sale in which 
concentrations of radioactivity exceeded the European Council Food Intervention 
Levels (CFILs).   
 
There is no statutory obligation for the Agency to monitor background levels of natural 
radioactivity in foods. 
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2.3 
The Agency’s Radiological Programmes 
The Agency’s programmes are divided into monitoring around industrial sites or areas 
known to have high levels of radioactivity and monitoring away from these sites.  
In terms of monitoring around industrial sites, the Agency has a set of programmes to 
sample and analyse a wide range of locally grown foods and seafoods that comprise 
local diets around nuclear or industrial sites that discharge or have in the past 
discharged man-made or enhanced-natural radioactivity. The results are used to 
estimate annual retrospective doses to consumers to compare with EU annual dose 
limits, as required by the Basic Safety Standards. 
 
In terms of monitoring elsewhere, the programme samples a range of foods that 
comprise general diets and measures the concentrations of man-made and naturally-
sourced radioactivity. This part of the programme serves to comply with annual 
requirements and recommendations under the Euratom Treaty. Other samples are also 
taken far from nuclear sites, the Channel Islands and Isle of Man and around the UK’s 
coasts, to comply with OSPAR obligations and to track the far effects of discharges of 
man-made radioactivity in seawater. 
 
The Euratom samples are also supplemented and analysed for a further range of 
natural and man-made radionuclides over and above the requirements of the Treaty. 
Although there is no statutory obligation to do this, the Agency obtains the benefit of 
being able to compare the results with the data obtained from around nuclear sites and 
so put the latter into perspective. The data also provides estimates of background 
levels of radioactivity in food and estimates of doses to the general public as a result of 
natural radioactivity. This monitoring also enables the Agency to distinguish if there has 
been any man-made enhancements of natural radioactivity.  
 
The programme of monitoring remote from industrial sites also includes areas known to 
have high levels of radioactivity, both man-made and naturally-sourced, on land and in 
the sea. An example of one of these locations is Hurd Deep in the English Channel.  
 
9 

In some cases, environmental indicators are sampled and analysed and the results 
used in models to predict concentrations in foodstuffs. This can be a cost effective 
method of monitoring, particularly in relation to animal products. 
 
The scope of the Agency’s programmes extends throughout England and Wales, the 
Channel Islands and the Isle of Man; it also includes Northern Ireland dairies and the 
coastal waters of the British Isles. They are undertaken and reported independently of 
the industries that discharge the radioactive wastes. 
 
The scope of the monitoring programme is subject to detailed annual review at the end 
of each year. In addition, the Agency meets with the nuclear industry and the 
Environment Agency to discuss the content of the Food Standard Agency’s individual 
nuclear site programmes. In this way the programmes are tailored for the following year 
to reflect current practices at nuclear sites such as decommissioning or changes to site 
authorisations, the results of local consumers’ dietary surveys, recent research and 
sample collectors’ feedback on local food availability.  
 
The results from the programmes and the calculated potential doses to consumers are 
published annually in the series of reports commonly abbreviated to RIFE 
(Radioactivity in Food and the Environment). The RIFE report also includes data from 
the Environment Agency, the Scottish Environment Protection Agency and the 
Northern Ireland Environment and Heritage Service, thereby providing a single 
comprehensive report on all government radiological monitoring data on food and the 
environment in the UK. 
 
The costs of the radiological monitoring programmes undertaken around nuclear sites 
and the Agency staff time involved are recovered from the nuclear industry under the 
Radioactive Substances Act 1993. 
 
3. 
THE REVIEW OF THE RADIOLOGICAL  PROGRAMMES 
3.1 
The Aim of the Review 
The aim of the review was to consider the overall balance between the benefits of the 
programme; namely ensuring that intakes of radioactivity in the diet are not harmful to 
10 

health, delivering the Agency’s statutory obligations and the strategic value of the 
programme; against the resources required to deliver the programme. The general 
trends in the results are one important factor in deciding on the resources that are 
warranted. 
 
The recommendations from the review are those of an independent panel. They should 
be taken into consideration by the Agency in shaping the future scope of the 
programme from March 2007. 
3.2 
The Terms of Reference of the Review 
The specific objectives of the review were: 
• To consider whether the Agency was meeting the stated aims of the 
programmes. 
• To advise on the future size and scope of the programmes, balancing the 
resources required against the stated aims and obligations, and taking into 
account the trends in results. 
• To comment on the strategic value of the programmes. 
• Specifically, to consider the scope for reducing the number of samples and 
costs whilst maintaining the strategic value of the programmes. 
• To comment on the flexibility within the programmes to meet potential future 
needs. 
• To consider what scope there may be for innovation in the programmes. 
3.3 
The Review Panel 
The review was carried out by a panel of experts, each with knowledge of different 
aspects of the field of radiological protection. The review panel was independent of the 
Agency and was comprised of four individuals, one of whom was elected chairman. 
One of the panel members declared an interest in one part of the programme because 
they had research funded with the Agency and they took no part in decisions on this 
part of the programme. The other three experts had not been involved in the 
programmes. 
 
The four panel members were as follows: 
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1. Dr Bernie Wilkins, who acted as chair of the panel (Group Leader of Environmental 
Investigations, Environmental Assessments Department of the Health Protection 
Agency - Radiological Protection Division (HPA-RPD). 
2. Dr Tom Ryan (Radiological Protection Institute of Ireland and a former European 
Commission Seconded National Expert to the Radiation Protection Unit H4 at 
DGTREN, Luxembourg.) 
3. Professor Jack Pearce (President of the Institute of Food Science and Technology). 
4. Professor Gregg Butler (University of Manchester and Director of Integrated 
Decision Management Ltd.). 
The secretariat was provided by the Agency. 
3.4 
The Review Panel Meetings 
The panel met three times. 
Meeting 1: An initial meeting was held on 14 October 2005 to bring the panel members 
together, to clarify procedures, to outline the key parameters of the programmes and to 
explain and discuss what was required for the review. 
The panel was provided with the documents listed in Annex 1 to support the review. 
The panel members discussed and then set out the framework under which they would 
be undertaking the review  
Between meetings one and two the panel members requested and received further 
information by e-mail exchange. 
 
Meeting 2: The purpose of the second meeting on 23 November 2005 was to give the 
panel members an opportunity to discuss their combined response.  
Between meetings two and three the Agency undertook to send details of queries and 
follow-up actions the panel members had requested. A draft report was circulated for 
comment. 
 
Meeting 3: The final meeting on 20 January 2006 discussed the combined 
contributions from the panel members and produced the final draft of the report to be 
presented to the Agency. 
 
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The panel noted that the observations expressed in this report were their own personal 
views and not representative of their organisations. 
 
4. 
THE REVIEW  
4.1 
Approach Adopted 
The panel had been requested to advise on the future size and scope of the 
programmes. To do this they needed to consider the overall balance between the 
benefits of the programmes and the need to deliver the Agency’s statutory obligations 
against the resources required to deliver the results, whilst maintaining the strategic 
value of the programmes. The panel examined each of these issues in turn. 
 
First, the panel set out the background assumptions that they would use as a 
framework for the review. 
4.2 
The Framework of the Review  
 The panel considered it important to determine a framework against which the review 
should be conducted. The factors within this framework included the following: 
• The programmes ought to monitor and assess doses for any foodchain pathway of 
significant exposure to consumers from either man-made or naturally-sourced 
radioactivity.  
• All 23 nuclear sites discharging radioactivity into the environment should be 
monitored. Although the resource allocation should be based primarily on consumer 
dose, it is recognised that the Agency must also take into account local, political 
and international concerns, dose trends and sampling costs. 
• The programmes ought to fulfil all statutory obligations at least at minimum 
reporting levels (the EU annual dose limit, Euratom Treaty and OSPAR 
commitments). Any analyses undertaken over and above minimum requirements 
ought to be justified and have a clear value-added benefit to the Agency. 
• It was essential that the Agency retained the ability to respond rapidly to 
incidents and emergencies in terms of sampling and analysis. The 
programmes ought to maintain resilience for such events by dividing the 
routine programme between two laboratories at different locations. Both should 
be capable of handling a large throughput of samples and be independent of 
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the nuclear industry. Sustainability of the laboratories ought to be maintained 
by keeping levels of skilled staff at the laboratories above purely minimum 
levels (critical mass), to ensure capability to respond rapidly at any time on the 
Agency’s behalf and to ‘escalate’ the programmes in response to emergencies. 
• In order to calculate consumers’ annual dose, sampling strategies ought to include 
all foods locally grown that comprised an annual diet. This would include an 
example from each food type (or indicator material if not available), plus those foods 
identified as eaten in local consumer dietary surveys and foods recognised as 
‘accumulators’ of certain radionuclides e.g. honey. 
• Sampling frequency should be the minimum to reflect the half-life of the 
radionuclide and any seasonal and temporal variations e.g. annually for crops, end 
of summer for animals, milk taken weekly but bulked for monthly analysis, shellfish 
bulked quarterly. 
• Due to the importance of milk in the diet, the number and location of dairy farms 
around nuclear sites that were sampled for milk should be carefully considered. The 
number of farms sampled at each site should be proportionate to the potential for 
site discharges to contribute to consumers’ dose and farms should ideally be evenly 
spread in a circular windrose around the site. In addition there was little justification 
for sampling at milk farms beyond 5 miles (8 kilometres), as past history had shown 
that routine discharges of radioactivity are not detected in milk beyond this distance 
and there were already sufficient baseline data available.  
• Decisions on the analyses to be carried out should take account of all radionuclides 
listed in current or past site authorisations, as well as any radionuclides carried from 
other nuclear sites by long-range transport.  Analyses should be undertaken only to 
appropriate Limits of Detection (LoDs) to obtain a meaningful estimate of consumer 
dose, and use should be made of sequential radiochemistry methods wherever 
possible and strive to use the most cost-effective analytical method to suit the 
required LoD. 
• The review covered the Food Standards Agency’s radiological monitoring 
programmes throughout England, Wales, the Channel Islands, Isle of Man, some 
Northern Ireland dairies and the coastal waters of the British Isles. Scotland has its 
own radiological monitoring programme undertaken by the Scottish Environment 
Protection Agency and was not considered within this review. The review was 
14 

confined to the programmes of sampling and measurements, the assessment and 
publication of data being outwith the remit. 
4.3 
The Agency’s Statutory and EU Commitments 
The panel then identified the Agency’s statutory and EU commitments. These included 
the following components. 
 
The programmes around the 23 nuclear sites should be of sufficient size and scope to 
ensure that the Agency could accurately assess annual total retrospective doses to 
critical or vulnerable groups of consumers from all sources of man-made and industry-
enhanced naturally-sourced radioactivity via all possible pathways of exposure. The 
estimated doses could then be compared with EU dose limits as defined under UK 
legislation in the Basic Safety Standards Directive 96/29/Euratom. 
 
The programmes should fulfil the Agency’s obligations for monitoring and reporting on 
concentrations of man-made and natural radionuclides in foods to show compliance 
with both the Euratom Treaty Articles 35 and 36 and OSPAR commitments.  
 
For the Euratom Treaty this involved three requirements.  
(1) 
Monitoring of milk at monthly intervals from a network of regional dairies, 
sufficient to ensure representative coverage of the Member State (including England 
and Wales, Northern Ireland, the Channel Isles and the Isle of Man). Minimum 
reporting standards under the Euratom Treaty were for concentrations of the 
radionuclides caesium-137, strontium-90 and potassium-40.  
 
(2) 
Quarterly monitoring of samples of complete canteen meals at 3 regional 
locations in England, Wales and Northern Ireland (the so-called ‘sparse network’) as an 
indicator of public exposure from mixed diet. Minimum reporting standards under the 
Euratom Treaty for this requirement were for concentrations of the radionuclides 
caesium-137, strontium-90 and carbon-14.  
 
(3) 
Quarterly monitoring of samples of mixed diet from a number of locations 
sufficient to ensure representative coverage of the Member State (including England 
15 

and Wales, Northern Ireland, the Channel Isles and the Isle of Man (the so-called 
‘dense network’) as an indicator of public exposure from mixed diet. Minimum reporting 
standards under the Euratom Treaty were for concentrations of the radionuclides 
caesium-137 and strontium-90. 
 
Within the UK’s commitments to OSPAR, the Agency had a requirement to monitor 3 
aquatic marine foods (a fish, a crustacean and a mollusc) as Key Marine 
Environmental Indicators (KMEIs) at 9 representative locations around the UK and the 
Channel Islands. Minimum reporting standards under the terms of the OSPAR Strategy 
were for concentrations of the radionuclides tritium, carbon-14, cobalt-60, strontium-90, 
technetium-99, caesium-137, plutonium-239 + 240, and americium-241.  
 
In the event of a radiological incident (originating either in the UK or overseas) being 
declared by the EU, Council Regulation (EURATOM) 3954/87 would come in force and 
the Agency would have a statutory obligation to ensure that no foods were offered for 
sale in which concentrations of radioactivity exceeded the European Council Food 
Intervention Levels (CFILs). In the event of an overseas radiological incident which 
might have widespread consequences in the UK, this obligation demands the ability to 
understand and model foodchain pathways in the UK. It also underpins the need for a 
comprehensive regional monitoring system, rather than one based solely around UK 
nuclear sites.  
 
Finally, in the event of a nuclear site exceeding its routine discharge authorisation limits 
or its weekly discharge Advisory Levels, the Agency would increase the frequency of 
monitoring of local foods. Although this reassurance monitoring is not a statutory 
requirement because no radiological incident would have been declared by the EU, it 
would demonstrate whether enhanced concentrations of specific radionuclides in foods 
were significantly contributing to increased consumer dose.  
4.4 
The Benefits of the Programme 
In addition to fulfilling the Agency’s commitments and obligations, the panel identified 
the following benefits of the radiological monitoring programmes to the Agency and to 
consumers : 
16 

 
• To demonstrate to consumers that intakes of radioactivity in the diet are not harmful 
to health. 
• The monitoring of radioactivity in foods around nuclear sites confirmed compliance 
with existing site discharge authorisations, which would have been set at levels 
using computer model predictions and would not be able to take account of unusual 
situations.  
• The programmes provided radiological monitoring data for judging the adequacy of 
new, proposed or amended nuclear site discharge authorisations by comparing 
past experiences of actual concentration data with predicted data from computer 
modelling.  
• The routine monitoring might detect undisclosed or previously undetected releases 
of man-made radioactivity from sites within the UK or from overseas. 
• The programmes can help the Agency limit radiological pollution at source. The 
results provide early warning of rising concentrations of radioactivity in indicator 
materials (such as seaweeds) before food is affected. If concentrations in food were 
allowed to increase over the course of a year, then estimated annual doses to high 
risk consumers might exceed the EU annual dose limit. This early warning of rising 
concentrations has proved valuable in providing evidence to the environment 
agencies who issue the nuclear sites with authorisations to discharge radioactivity, 
so that preventative action can be taken if necessary.  
• The monitoring results established baseline data for man-made radionuclides in 
foods, both in the vicinity of nuclear sites and elsewhere. This data would be used 
as a benchmark to judge whether foods were recently contaminated and also as a 
possible guide for clean-up levels after a future radiological or CBRN incident.  
• The data gathered over and above the minimum reporting levels for the Euratom 
Treaty Article 35 requirements established background levels of man-made and 
naturally-sourced radioactivity in food and could therefore detect levels of 
technologically enhanced naturally-occurring radionuclides (TNORM) arising from 
industry, such as carbon -14. 
• The consumer dose as a result of man-made radioactivity could be put into context 
by sampling a representative consumer diet well away from nuclear industry 
sources. This enabled the Agency to put the doses from man-made radioactivity 
17 

into perspective and demonstrated that consumer doses were usually dominated by 
naturally-sourced radioactivity.  
• The programmes provided data to inform Agency policy on EU and international 
initiatives such as the recent CODEX proposals. 
• The surveys of consumers’ consumption patterns that support the programmes 
were able to identify new or emerging pathways of radiological significance to 
consumers that might require regular monitoring or indicate a need for specific 
research. Examples include the discovery of high levels of radioactivity in sea-mice 
from fishermen’s by-catches at Sellafield and higher levels than predicted of tritium 
in fish near Cardiff. 
• Finally, the programmes were able to track the far effects of marine discharges of 
man-made radioactivity in seawater and provided an independent evidence base of 
data on radioactivity in foods. This data could be for used for example, in dealing 
with radiological food safety issues raised by either green Non-Governmental 
Organisations (NGOs) in the UK or other Member States.  
 
5. 
OUTCOME OF THE REVIEW 
The panel had been requested to consider the following specific objectives under the 
terms of reference of the review 
1. To consider whether the Agency was meeting the four stated aims of the 
programmes. 
2. To advise on the future size and scope of the programmes, balancing the 
resources required against the stated aims and obligations, and taking into 
account the trends in results. 
3. To comment on the strategic value of the programmes. 
4. Specifically, to consider the scope for reducing the number of samples and 
costs whilst maintaining the strategic value of the programmes. 
5. To comment on the flexibility within the programmes to meet potential future 
needs. 
6. To consider what scope there may be for innovation in the programmes. 
5.1 
The Stated Aims of the Programmes 
18 

The panel considered that the programmes met the Agency’s remit to protect public 
health and ensure that doses of man-made and natural radioactivity in foods did not 
pose an unacceptable risk to consumers. 
 
For man-made radioactivity and also natural radioactivity enhanced by man, the 
current programmes were of sufficient size and scope to ensure that annual doses to 
critical or vulnerable groups of consumers could be estimated for comparison with EU 
dose limits, as defined in UK legislation by the Basic Safety Standards Directive 
96/29/Euratom. 
 
The panel considered that the programmes fulfilled the Agency’s obligations for 
monitoring and reporting on concentrations of man-made and natural radionuclides in 
foods to show compliance with Euratom Treaty Articles 35 and 36 and OSPAR 
commitments. In some cases the Agency had taken the opportunity to analyse the 
existing samples for radionuclides in addition to those required. The panel had 
considered all the evidence and agreed that in most cases the extra analyses were 
justified on both cost and scientific grounds. For a very little extra cost the Agency had 
gained valuable data on variations in concentrations of radioactivity in foods across the 
UK and in seafood around the coast. The data allowed the Agency to put the dose from 
man-made radioactivity into context, to provide information on background levels of 
radioactivity in food and to be able to distinguish if background levels had been 
enhanced by discharges of man-made radioactivity from industry. 
 
However, the panel did make recommendations for some resource savings in this part 
of the programme. 
 
The panel also considered that the programmes were of sufficient breadth to ensure 
that any new or potential pathway of significant exposure to consumers would be 
identified and monitored if necessary. This was considered essential as discharges 
were invariably specified in terms of activity (Becquerels), while the risks being guarded 
against were measured by dose (Sieverts). These include contributions from both 
current discharges and those from previous years and would only be revealed by 
monitoring programmes such as these. 
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5.2 
The Future Size and Scope of the Programmes 
In the terms of reference of the review, one of the specific objectives for the panel was 
to advise on the future size and scope of the programmes, balancing the resources 
required against the stated aims and obligations, and taking into account the trends in 
results. The panel was also asked to consider any duplication, overlaps or gaps 
compared with other programmes. Finally the panel was asked to consider whether the 
relative importance of site specific aspects had been correctly addressed and the 
effectiveness of the project management framework. 
(i) 
Resources 
Having examined the four stated aims of the radiological monitoring programmes and 
the minimum requirements of EURATOM and OSPAR, the panel considered that the 
benefits of the programmes could be retained in the future by a smaller programme 
than that currently in place.  Although this would be at the expense of losing some 
data, the panel considered that some savings could be made without compromising the 
strategic value of the Agency’s programmes.  
 
The panel also recommended that the supporting laboratories should be situated in the 
UK so that the Agency could command a full national, committed and rapid response to 
UK emergencies. 
 
In addition they noted that the programmes had been extensively reviewed in 2001 and 
resource savings worth almost £500,000 and a loss of 2 staff posts at the Agency had 
already been implemented.  They also emphasised that the Agency staff already 
undertook an annual review of the size and scope of their monitoring programmes. 
Taken together, this meant that the potential for rationalisation and savings was limited 
compared with what would have been expected had the programmes remained static 
for a number of years. 
 
The panel wanted it noted that the potential savings in resources were identified on 
merit against the framework assumptions and covered both the work funded by 
industry (cost-recoverable) and that wholly funded by the Agency (non-cost 
recoverable) programmes.  
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 (ii) 
Duplication, Overlaps and Gaps 
The panel considered that on the whole there was very little duplication or overlap with 
other radiological programmes, but where there was a clear case of duplication they 
had made recommendations for resource savings.  
 
There was only one small gap in the programme that was identified by the panel. There 
was no uranium monitoring undertaken in animal offal around nuclear sites that 
discharged uranium into the environment. This modest addition to the programme was 
considered to be justifiable because it was identified as a potential pathway of 
significance. 
(iii) 
Site Specific Aspects 
The panel considered that the relative importance of site specific aspects of the 
programme had been correctly addressed, so that the resources allocated to 
monitoring around each site were proportionate. Site specific issues took account of 
the following: total public dose; local, political and international concerns; and historic 
issues. For example. members of the public who received the greatest dose in 2004 
were seafood consumers around the Sellafield site and 60% of the total programme 
resource was devoted to monitoring around this site. Monitoring at other sites was 
generally proportionate with consumer potential dose and minor sites with consumer 
dose less than 5 microsieverts a year only had grass and soil indicator samples taken 
annually. 
(iv) 
Dose Trends 
In addition the panel considered that content of the programmes were suitably tailored 
each year as a result of survey information and dose trends. For instance, monitoring 
resources had been increased around Cardiff due to findings of tritium bio-
accumulation in seafood, whereas monitoring had completely ceased around the ICI 
Billingham site because trends showed that the radiological dose pathways were 
insignificant. Another example was the Ascot site where the monitoring programme 
had been decreased and now consisted of only 2 grass samples per year because the 
discharges and therefore the public dose was decreasing and was estimated to be 
much less than 5 microsieverts a year in 2004. 
21 

(v) 
Programme Management 
The panel considered that the effectiveness of the project management was very good. 
The annual review summarised in section 2.3 ensures that the programmes are 
tailored each year to reflect current practices at nuclear sites and changing 
circumstances in other areas. The panel also considered that the various contractors 
used by the Agency were delivering value for money. All contractors carrying out 
analyses were formally accredited under ISO 17025. In addition, they are part of the 
UK Analysts Informal Working Group. This group meets regularly to discuss 
developments in radiochemical analysis, thereby providing an important input into 
reviews of working practices at individual laboratories.  
5.3 
Strategic Value of the Programmes 
The third specific objective for the review was for the panel to comment on the strategic 
value of the programmes with regard to radiological emergencies. The panel made the 
following comments: 
 
• It was very important to maintain strategic capability at national laboratories with 
UKAS accredited laboratory staff on-call on an all-year-round basis for the analysis 
of samples. In the event of a radiological or CBRN incident the routine analytical 
programme could be shelved and trained laboratory staff diverted to analysing  
samples in support of the response. This response could be rapidly expanded and 
scaled up to reflect the severity an incident originating either in the UK or overseas. 
• The panel considered that the programmes should maintain resilience for 
emergencies by dividing the routine programme between two national laboratories 
at different geographical locations, capable of handling the required throughput of 
samples and retaining independence from the nuclear industry. 
• In order to be of strategic benefit to the Agency, the panel recommended that the 
laboratories should have sufficient flexibility, expertise and staff to be capable of 
resourcing not just radiological incidents, but also either R and N of CBRN 
incidents. This included both the collection and the analysis of samples and again 
emphasised the need for the laboratories to be situated in the UK, rather than 
based overseas. 
22 

• The panel were in strong agreement that the programmes should maintain a ‘critical 
mass’ of suitably trained staff at the laboratories, with equipment and capability to 
reliably analyse and rapidly screen a large number of samples from a variety of 
foods. This capability should encompass the wide range of radionuclides that might 
be encountered in accidents or incidents.  
• They also agreed that it would be an advantage to maintain the current situation 
where the laboratories were members of the Public Sector Research 
Establishments (PSREs) partnership known as the Interlab Forum (reference 
http://www.hsl.gov.uk/news/collaboration.pdf of 16th August 2005). These 
laboratories have signed a co-operation agreement to work closely together to 
increase effectiveness and share knowledge on topics of strategic importance such 
as emergency response. Should one laboratory be closed by a crisis or a localised 
radiological or CBRN incident, the facilities, equipment and staff at the other 
laboratory would endeavour to provide assistance. 
• The panel also felt that participation in the UK Analysts Informal Working Group 
should be encouraged. The panel regarded this forum as a platform for exchanging 
best practice to aid resilience for the UK as a whole, whilst still maintaining unique 
practices that made the laboratories individual. 
• The panel considered that the one of the strategic values of the programmes with 
regard to radiological emergencies was the utilisation of the existing network of 
trained sample collectors already in place in England and Wales and familiar with 
sampling strategies and techniques. The collectors were accustomed to the method 
of taking specialised samples and the Agency had in place a logistics set-up and 
contracts for methods for transport of these samples from farms and dairies to 
laboratories by overnight post. 
• In this context, the panel noted that the current system for milk was to collect 
samples on a weekly basis and to bulk as appropriate at a later date prior to 
analysis.  The delay means that weekly samples were available for analysis if, for 
example, an unexpected release of radioactivity occurred from a nuclear site.  The 
panel felt that this system had worked well in the past and should be maintained.  
Any reductions in costs associated with less frequent sampling would be offset by 
the need for larger individual samples and the consequent increase in the cost of 
23 

shipping.  The panel felt that “hidden costs” such as these should be fully quantified 
as part of any review of programme structure. 
• Finally the panel noted that it would be of strategic value to maintain robust IT links 
and compatible software between the analytical laboratories and the Agency. In the 
event of a radiological emergency this would allow the speedy transfer of accredited 
laboratory data so that Agency could formulate timely advice on food safety.  
5.4 
Scope for Savings within the Programmes 
In the fourth specific objective of the review the panel was asked to consider the scope 
for reducing the number of samples and costs whilst maintaining the strategic value of 
the programmes 
 
As noted above, the panel considered that the benefits of the programmes could be 
retained by a smaller programme than that currently in place.  There was some scope 
for a reduction in costs and numbers of samples both in the aquatic and terrestrial 
programmes. Although this would be at the expense of losing some data, the panel 
considered that some savings could be made without compromising the strategic value 
of the Agency’s programmes whilst all of the Agency’s statutory obligations could still 
be met. 
 
The panel grouped potential options for resource savings into three categories.  
• Recommended: savings that ought to be made and would have no direct effect on 
the strategic value or benefit of the programmes. 
• Possible: savings that could be made but would have some minor drawbacks or 
disadvantages, although still retain the strategic value of the programmes. 
• Considered, but not recommended: savings that would definitely have 
disadvantages to the benefits of the programme and would adversely affect the 
strategic value of the programmes, especially the ability of the laboratories to 
respond to emergencies as discussed in 5.3 above. 
 
The panel had examined the key parameters of the programme and the stated 
sampling strategy of the Agency and made recommendations for reducing numbers of 
samples or costs for a number of reasons. These reasons included: 
24 

• Areas where there was clear duplication with another Agency’s programmes. 
• Areas where the responsibility for monitoring lay with another government 
department. 
• Reducing and/or dropping completely the number of samples taken, due to 
dose trends, past history of negative results or identification that samples 
contributed to a minor foodchain pathway to consumers’ dose. 
• Reducing the number of analyses undertaken, by bulking samples that were 
required to be analysed. This would be particularly apposite where recent 
data had indicated that levels of long-lived radionuclides were always 
extremely low across the year. 
• Dropping analyses that were excessively expensive for the relatively small 
contribution that they made to the estimation of consumer’s dose. 
• Reducing the programme of sampling from regional towns.  
• Reducing the number of dairies sampled for Euratom Treaty obligations. 
• Reducing the frequency of sampling fish from UK coastal ports (except those 
bordering the Irish Sea).  
5.5 
Flexibility within the Programmes 
In the fifth specific objective of the review the panel was asked to comment on the 
scope for flexibility in the current programmes. The panel agreed that the current 
programmes were sufficiently flexible. Examples included: 
• The sampling capability within the routine programmes could be rapidly 
expanded in the event of radiological or CBRN incident, originating either in 
the UK or overseas. 
• Suitably trained staff at laboratories had the equipment and capability to 
reliably analyse and rapidly screen a large number of samples from a variety 
of foods for a wide range of radionuclides that might be released in the event 
of a future incident or nuclear accident. 
• The current programme was flexible enough to identify new or emerging 
pathways of radiological significance that might require additional monitoring 
or be added to the annual routine programme. 
25 

• The content of the annual programmes were not ‘set in stone’. The scope of 
each programme was regularly reviewed at the end of each year and the 
following years’ programmes were amended in the light of new information.  
• The panel noted that the Agency currently sponsored research on a variety 
of topics relevant to the radiological monitoring programmes and the results 
had been incorporated into the future programmes. The research ranged 
from desk top studies on the potential for significant consumer exposure from 
unusual foodchain pathways (such as the report on Uncommon Seafoods) to 
sampling studies to determine possible seasonal variations in foods (such as 
the report on Seasonal Variations in Crabs and Lobsters).  
The results of these studies were reported in the annual Radioactivity in 
Food and the Environment reports and the conclusions were incorporated in 
the following year’s monitoring programme. For instance, the report on 
Seasonal Variations in Crabs and Lobsters concluded that there were no 
significant seasonal or short term variations that affected the uptake of 
technetium-99 into crustacea and therefore the subsequent sampling 
programme did not need to be modified for seasonal bias. 
Other reports had made recommendations that had been implemented and 
resulted in modifications or reductions in the programmes, for instance a 
reduction in the numbers of lobsters that were required to be sampled.  
5.6 
Scope for Innovation and Horizon Scanning 
Finally, the panel was asked to consider what scope there might be for innovation in 
the programmes and any potential issues on the horizon that ought to be taken into 
account in planning for the future programmes. 
 
The panel considered that the Agency ought to keep a sound base of sufficient 
expertise in all key areas of sampling and analysis that might be needed in the future. If 
all analyses of one particular radionuclide were to cease, then the time and cost 
involved in returning to operational status could be considerable.  In addition, the 
current archive of original laboratory samples which were kept viable in a variety of 
food matrices was an important asset, if it was found necessary to go back to 
undertake additional analyses for other radionuclides. 
26 

 
The panel recommended that the Agency consider that future contracts for collection 
and analysis of samples would benefit from being on a 5 year basis. This would be 
beneficial to both parties because the laboratories could invest in the specialist 
laboratory equipment that was required for the detection of low-level radioactivity while 
the running costs incurred by the Agency would be reduced. 
 
The panel noted that the prospect of further nuclear power station build in the UK was 
currently a possibility.  They considered that this added to the importance of the current 
programmes in maintaining the facilities and expertise to enable future expansion if 
required. It would be extremely difficult to restart some elements of the programme 
again, such as the development of laboratory staff expertise and the network of 
sampling capability.  
 
In addition to the prospect of new build, the panel noted other current initiatives which 
would have an impact on the future size and scope of the programmes. These included 
the publication and recommendations from CoRWM ( http://www.corwm.org.uk ) on 
the Low Level Waste Review which will report in June 2006, and the implications of the 
clean-up of the Magnox nuclear sites which would involve the treatment of radwaste on 
the NDA sites.  
 
It was considered likely that these on-site activities would involve the potential release 
of radionuclides specifically associated with decommissioning, rather than an increase 
in discharges of existing radionuclides. The programmes would need to remain flexible 
to respond quickly to these activities, including the potential to develop new analytical 
methodology for the radionuclides associated with decommissioning and the ability to 
identify and monitor different food pathways if doses were considered to be significant.  
 
On horizon scanning, the panel noted that there was a need to keep the current 
monitoring schedule for the UK’s KMEIs until the OSPAR review in 2009. This was a 
UK commitment from the OSPAR Convention for the Protection of the Marine 
Environment of the NE Atlantic. After 2009 and until 2020 there might be a need to 
increase the current monitoring arrangements to show compliance with the UK 
commitment to reduce the concentrations of radionuclides in the marine environment to 
27 

close-to-zero to historic levels. Therefore, the panel recommended that developments 
in this area be kept under review. 
 
The panel found it notable that public reassurance and public understanding were not 
expressly stated objectives of the programme.  Indeed, an examination of Agency 
documentation and the Agency Website showed little that would aid public 
understanding – referring queries directly to technical papers that are far from 
‘stakeholder friendly’.  In fact, the Agency is the custodian of a regime that uses 
conservative assumptions and models to limit the exposure of maximally affected 
groups to risks well below one in 10,000 per annum.  The panel felt that this was surely 
a powerful message deserving more public attention, especially against the 
background of likely near term debates and developments in nuclear waste and 
nuclear power policy.  The panel felt that better integration of the radiological 
monitoring programme into the overall stakeholder and public engagement programme 
was justified, and this would of itself increase the benefit of the programme to both the 
public and the Agency. 
 
6. 
CONSIDERATIONS OF THE PANEL 
• The panel considered that the programmes met the Agency’s remit to protect public 
health and ensure that doses of man-made and natural radioactivity in foods did not 
pose an unacceptable risk to consumers.  
• For man-made radioactivity and also natural radioactivity enhanced by man, the 
programmes were of sufficient size and scope to ensure that annual doses to 
critical or vulnerable groups of consumers could be calculated to compare to EU  
dose limits as defined in UK legislation by the Basic Safety Standards Directive 
96/29/Euratom. 
• The panel considered that the programmes fulfilled the Agency’s obligations for 
monitoring and reporting on concentrations of man-made and natural radionuclides 
in foods to show compliance with Euratom Treaty Articles 35 and 36 and OSPAR 
commitments.  
• The panel also considered that the programmes were of sufficient breadth to 
ensure that any new or potential pathway of significant exposure to consumers 
would be identified and monitored if necessary. 
28 

• However, the panel concluded that the ability of the programmes to meet the four 
stated aims of the radiological monitoring programmes and the minimum 
requirements of EURATOM could probably be met by a smaller programme than 
that currently in place.  Although this would be at the expense of losing some data, 
the panel considered that some savings could be made without compromising the 
strategic value of the Agency’s programmes.  
• The panel recommended that savings should not be made at the expense of 
undermining the ability of the Agency to respond to emergencies, changing 
circumstances, reductions in the programme and hence in resources and income at 
the laboratories which supplied both sample collection and analysis.  
• The panel noted that the programmes had been extensively reviewed in 2001 and 
resource savings had already been implemented.  Together with the annual reviews 
of the size and scope of the programmes this meant that there had been less scope 
for rationalisation and potential savings as might have been expected. In short, 
many of the questions had already been raised internally, debated and responded 
to. 
• Potential savings in resources were identified on merit against the framework 
assumptions and equally covered work funded by industry (cost-recoverable) and 
that wholly funded by the Agency (non-cost recoverable) programmes.  
 
7. 
ACKNOWLEDGEMENTS 
The panel wishes to record its thanks to those staff of the Agency and the contract 
analytical laboratories that responded positively and promptly to requests for 
information. 
29 

 
ANNEX 1 
Documents supplied to the Review Panel 
 
• The Radioactivity in Food and the Environment (RIFE) report number 9  for 
2003 with CD disc of previous editions of RIFE. 
• The Radioactivity in Food and the Environment (RIFE) report number 10  for 
2004, as soon as it was published at the end of October 2005. 
• Papers describing the scope of the programmes :  
• for the aquatic and terrestrial programmes around nuclear sites 
• for the aquatic and terrestrial programmes well away from nuclear 
industry sites 
• All sample contractors’ requirements’ documents plus details of costs. 
• Laboratory analytical requirement schedules and overall costs 
• Article 35 and 36 Euratom Treaty requirements and recommendations 
• Copies of the relevant legislation 
• Documents describing the Agency’s ‘Total Diet Study’ and project costs 
• Documents describing the Agency’s ‘Canteen meals’ project and costs. 
• Map of the location of the dairies sampled in England and Wales. 
• Summary record 2005 of the OSPAR Convention for the Protection of the 
Marine Environment of the North-East Atlantic with locations of sampling 
positions for fish, seaweed and seawater around Europe 
• Examples of other EU monitoring programme report 
• The latest EU Environmental Radioactivity in the European Community 
report 
• Ireland marine monitoring reports 
• Norwegian monitoring report 
• The COGEMA report from France (only available in French) 
• Independent reports of the Agency’s monitoring programmes from the two EU 
Euratom Treaty Article 35 Inspections:  
• around Dungeness in 1999 
• around Sellafield in 2004 
30 

• Relevant research reports that had informed the direction of the monitoring 
programmes 
• CEFAS report on the variability of radionuclide concentrations between 
individual crabs and lobsters (defined the minimum number of animals 
per sample in order to minimise sampling uncertainties)  
• University of Liverpool report on Seasonal Variations in Radionuclide 
Concentrations in Crabs and Lobsters (recommendations for the 
Agency’s strategy on sampling frequencies for crabs and lobsters) 
• Westlakes report on potential pathways of exposure to consumers via 
seaweeds sourced from UK, Irish and Norwegian waters (implications 
for the content of the sampling programmes if seaweeds containing 
significant quantities of radioactivity were getting into the foodchain) 
• NRPB (now HPA-RPD) reports on potential pathways of exposure from 
naturally and artificially-sourced radionuclides in hedgerow and wild 
foods (implications for the content of the sampling programme via this 
foodchain pathway if consumers’ doses were considered to be 
significant) 
• CEFAS study on levels of Organically Bound Tritium (OBT)  and carbon 
–14 around the known UK discharge points (implications for the need to 
include OBT measurements in seafood in the routine sampling 
programmes if OBT levels were significantly elevated above tritium 
seawater levels)  
• CEFAS study on the transfer of OBT through the marine foodchain 
(informs the programmes about the selection of marine species for 
sampling) 
• CEFAS report on the transfer of radioactivity from fishmeal in animal 
feeding stuffs to man (implications for including samples of fishmeal in 
the routine programmes) 
• CEFAS report on the potential for farmed fish to concentrate levels of 
radionuclides as a consequence of feeding with fishmeal (implications 
for including annual samples of farmed fish in the programmes) 
31 

• CEFAS report on the potential for uncommon, non-commercial  
seafoods that could be eaten by ethnic minority groups to be overlooked 
by the monitoring programmes. 
32 

  
33