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Radioactive hazards and the public health service
RADIOACTIVE
HAZARDS
AND
PUBLIC
HEALTH
795
Press, the cinema, radio and television--Iz~ay occasional tribute to health education the commercial interests see to it that wherever they can exert their influence there shall be no nonsense of that kind; too often the), lhrive on health miseducation or deliberate "'unhcalth" education. Virtually every aspect of health education includes one or more of three basic things. It asks the public to spend more money, to take more trouble or to give up something pleasant, it is, in effect, against human nalure and starts every evelat for which it enters under a considerable handicap. If it is to succeed at all the climate of public opinion must be influenced in its favour. We believe that the organised opinion of the medical profession can exert very considerable social influence. If the final rcsult of the Cohen Committee's work should be merely to make doctors as a whole conscious of their public duty in health education it will have justified its existence. If, on the other hand, it decides to take no deliberate steps to this end it will have missed a unique opportunity.
RADIOACTIVE HAZARDS AND THE PUBLIC HEALTH SERVICE By
D.
G.
ARNOTT,
B.sc.
Radioisotopes Department, Tke London Hospital, E.I. TIlE impact of applied radiation oll many spheres of the national life is here to stay and rapidly expanding. For reasons which need scarcely be stressed in this article, the problems presented are almost entirely novel and only partially understood, offering few analogies with other situations for which in the past protectivemeasures have had to be devised. For this reason we find ourselves in a delicate position in which wide-scale use of radiation and radioactivity takes place in advance of the development of a sound and comprehensive system of radiation hygiene. Since the end of the war the International Commission on Radiological Protection has been working continuously on the fundamental scientific basis of this matter, but new information comes forward steadily, necessitating frequent revision of the standards which the I.C.R.P. has from time to time introduced. Thus, the situation will continue to be fluid for some time to come ; but a review of how things stand seems appropriate at the present time. Occupational and incidental exposure to ionising radiations and radio-
196
PUBLIC
HEALTH
VOL.
LXXV
NO.
4
television tubes shoe-fitting fluoroscopes high-altitude flying nuclcar test-bomb fallout
(b) Civil-medical, e.g. medical diagnostic radiology radiotherapy with radiations or radioisotopes
(c) Occupational, e.g. occupations associated with (a) and (b) ; and in addition : nuclear power and weapons activities research uses of radioisotopes in industry, agriculture and medicine industrial testing with radiations or radioisotopes (e.g. leaktesting ; gamma radiography ; thickness gauges) mining and processing of radioactive ores (a), (b) and (c) are direct hazards to man. There is, in addition :
(d) Environmental hazard to plants and animals, life cycles and biological chains. These may arise from : radioactive waste disposal nuclear test explosions releasing radioactivity nuclear reactor accidents releasing radioactivity processing of irradiated nuclear fuel elements It is important to realise that under any of these heads either somatic or genetic risks may arise, or both ; and that the ultimate criterion of safe practice must be the genetic consideration. In this long list some hazards, such as those of television tubes and highaltitude flying, are so small that under present conditions they may be ignored. Others are greater but are, or shortly will be, well controlled ; amongst these we may list shoe-fitting fluoroscopes and many of the occupational hazards, such as industrial testing with X-rays or isotopes. There is also a category in which conditions are known to be less than satisfactory and efforts at improvement are being made ; into this category fall the medical applications listed here. Finally, there are those hazards, suspected not to be negligible, where tile risk is ill-defined because of lack of fundamental knowledge. These include all the environmental risks occurring at the bottom of the list and, from the occupational list, nuclear power and weapons activities and the processing of radioactive ores. The hazards of radioactive transport present a special case because here tile danger is of accident, the nature of which it is difficult to forecast and
RADIOACTIVE
HAZARDS
AND
PUBLIC
HEALTH
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should be generated by fission power as the nuclear power stations now building come into operation one after another. This will necessitate increasing transport of highly radioactive spent fuel elements to Windscale for processing, but there is clearly a limit to the capacity of tile Windscale site fi)r this sort of work and it may be that other processing stations will have to be established. The transport risk will, of course remain: but Sir Christopher Hinton stated recently that spent fuel elements from thc nuclear power stations will be carried as far as possible by rail. At present the situation regarding transport regulations is as follows : R a i h v a y s : British Railways have drawn up rules to govern the conveyance of radioactive materials; these are awaiting approval from the Ministry of Transport. Roads : The Ministry of Transport has drawn up regulalions under the Radioactive Substances Act, 1948 ; these are awaiting Ministerial approval and should be closely studied by public health authorities when available. Post Office • It is safe practice to send certain types of radioactive materials by post, and it is the accepted routinc of the Radiochemical Centrc to despatch many of its products this way. The G.P.O. framed regulations long a g o : the author understands that these are under revision. Regulations for sea and air tran.vJort exist ; ~nd a Code of Practice is being prepared by the Ministry of Transport for use in ports and harhours. It may be easily seen from this brief analysis that the danger points are by no means of theoretical interest, but are already of increasing practical importance. Disposal of radioactive waste is the greatest of these, a problem seen at its sharpest in the processing of irradiated fuel elements. Concerning the'hazards of nuclear test explosions, the position, always ill-defined, has recently changed for lhe better with the realisation that the stratospheric residence-time of fallout is very, much less than originally thought. The earlier estimate was of 7 to 10 years and upon this assumption have been based all the estimates of the incidence of leukaemia, osteogenic sarcoma and genetic injury which might accrue as the result of the bomb testing programme. However, towards the end of 1959 it became clear that the level of radioactivity in the atmosphere was less than was to be expected on the 7 to 10 years hypothesis. A sharp rise of 60 % in the Sr-90 uptake of children's bones during the first half of 1959 was reported by the Atomic Energy Research Establishment in March, 1960 ; whilst, from the Agricultural Research Council at the same time came notice of a parallel rise in the contamination of green vegetables. In the autumn of 1960 a further rise in Sr-90 in bone has been reported by A.E.R.E. These findings suggested that fallout was depositing much more rapidly than expected and the matter was put beyond doubt by a statement in the House of Commons on 22nd March, 1960, which gave a period of 15 momhs to four month~ as the lowe~ estimate so far of the s~rat~pheHc
198
PUBLIC
HEALTH
VOL,
LXXV
NO.
4
that the atmosphere is now substantially free of test-radioactivity and also that no further rise in Sr-90 contamination should be reported in either bones or vegetables. Therefore, barring a resumption of tests of high-yield weapons, the public health service need not expect to be concerned with fallout. The well-known M.R.C. repor t of 1956, " The Hazards to Man of Nuclear and Allied Radiations," has been revised and in its new form will provide important new information on this and other subjects. At the moment of writing it is still in press, so cannot be quoted here ; but it should be available by the time this article has appeared. At this point it is useful to review the present and near-future state of the law regarding radiation protection. Although occupational protection as such does not fall within the scope of tile public health service, it is so bound up with the rest that it is clearly better to present the whole picture. There are, or within a few years will be, six Acts on the Statute Book dealing with nuclear energy and related matters, including radiation protection. The Factories Act is one of these and under it there will be certainly two and possibly three Orders concerned with occupational protection. Radioactive waste disposal in all its aspects is now the concern of a single Act (Radioactive Substances Act, 1960), the Public Health Acts not being relevant in this connection. In addition there is the important Code of Practice for the National Health Service, which is at present being revised and is advisory only. To the extent that these regulations concern radiation protection, the basic information from which their standards have been derived arises from the work of the 1.C.R.P., which gives them a measure of uniformity. There has been much understandable criticism of the time which this urgent legislation is taking to appear. There are three main reasons for the delay. The first of these is that the I,C.R.P. is continually having to revise its standards in the light of new information and this has inevitably led to redrafting, notably of the Sealed Sources regulations mentioned below. Secondly, there is the peculiarly complex nature of the legislation itself. Thirdly, the number of people qualified to do the work is severely limited ; it was a salutary shock to the present author, when he joined them recently, to observe from the inside the enormous strain under which some of them are labouring. The legislation in question, present and impending, may be summarised as follows: I.
FACTORIES
ACT
(a) Luminising Order. This is the oldest piece of protective legislation on the Statute Book. It controls the occupational hazards of radioactive luminising in all aspects, whether the radioactive source be sealed or unsealed. It is not concerned with the disposal of radioactive waste. The Luminising Order will disappear from the Statute Book when the Sealed Sources and Unsealed
RADIOACTIVE
HAZARDS
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(b) Sealed Sources. Regulations controlling the occupational hazards of sealed sources are now in their second draft. The intention behind this Order is that it will do for such industrial uses as ~,-ray industrial flaw-testing what the Luminising Order has done for luminising. Industrial research is not covered, nor is radioactive waste disposal. The chief inspector of factories stated recently that these regulations should be in force towards the end of 1961. (c) Unsealed Sources. A committee is at present drawing up regulations which are intended to extend control to the industrial uses of unsealed sources of radioactivity. It may be expected that the requirements will be parallel to those to be found in the Sealed Sources Order already mentioned. No date can be given for the operation of these much-needed regulations, as the first draft has yet to be circulated. (d) Research. Research activities in general have not hitherto been covered by the Factories Act. It has been decided to make a partial exception in the case of radioactivity and ionising radiations ; a committee is now studying proposals which will cover industrial and many other research uses of both sealed and unsealed radioactive sources, excluding waste disposal. It is not at present precisely known how many categories of research will fall within the scope of this Order, but clearly there are a number of marginal uses which should not on that account escape control. It is not yet known whether these proposals will be given statutory form or will be merely advisory. 2. A T O M I C E N E R G Y ACT, 1 9 4 6 This Act has now no bearing on the question of radiation protection. 3. R A D I O A C T I V E SUBSTANCES ACT, 1 948 Section 5 allows regulations to be made regarding radiation protection. None have ever been rrmde because any powers so executed would not affect or set aside pre-existing legislation. This means that if pre-existing legislation were in conflict with any Order made under tlle 1948 Act, the former would stand. The importance of the 1948 Act lies in the Advisory Committee which was estfiblished under it. This is one of the most powerful Advisory Committees ever established by Statute : Ministers are obliged to seek its advice before laying before Parliament any proposed measures regarding radiation protection. This has meant, ill fact, that all such measures, including the Factories Act Orders already referred to, have in practice been drawn up by sub-committees and panels appointed under the 1948 Act. 4. U . K . A T O M I C ENERGY ACT, 1954 Section 5 imposes the duty on the Atomic Energy Authority to secure
200
PUBLIC 5.
NUCLEAR
HEALTH
VOL.
INSTALLATIONS INSURANCE) ACT,
LXXV
NO.
4
(LICENSING 1959
AND
This applies provisions closely analogous to those of the 1954 Act to nuclear power .stations, private reactors and similar equipment. Strictly speaking, the Electricity Generating Boards do not come within the scope of this Act, but both have accepted formal obligation to be bound by its requirements pending consideration of possible further legislation. The Act was promulgated in April, 1960; from that date all nuclear reactors, whether for power or for research purposes, have to be licensed and the terms of the licences are expected to be stringent. The sections of this Act regarding radioactive waste disposal lapsed when the Radioactive Substances Act, 1960, became law. 6. R A D I O A C T I V E SUBSTANCES ACT, 1960 This Act is solely concerned with radioactive waste disposal. It does not supplant the Act of the same name of 1948. The Ministers concerned are the Minister of Housing and Local Government and the Minister of Agriculture in England and Wales, and the Secretary of State in Scotland. These ave empowercd (i) to register all casual useis of radioactivity and to notify these registrations to the relevant public health authorities ; (ii) to require authorisation for radioactive waste disposal; (iii) to prescribe methods and standards to be followed in such disposal; (iv) to establish a national disposal service; (v) to appoint an inspectorate; (vi) to impose penalties for violations, the nature of which is prescribed by the Act. This Act supersedes all incidental powers regarding radioactive waste which may be available, for example, under the Public Health Acts, 1936 and 1937, and the various Acts regarding fisheries and river pollution. There are various reasons why these Acts fail as a means of controlling radioactive nuisance. For example, under some of them action can only be taken once a nuisance has become apparent ; this is inadequate when dealing with radioactivity, where the whole emphasis must be on preventative measures. The system of registration established under this Act will not apply to premises covered by the U. K. Atomic Energy Act, 1954~ or the Nuclear Installation Act, 1959. In addition, numerous Codes of Practice of an advisory nature have been drawn up. The fact that they are advisory only has meant that they have become available much more quickly than could possibly be the case with legislation. The Universities' Code of Practice, ,recently published, is a good example of what such a publication should be. Better known is the N.H.S.
RADIOACTIVE
ttAZARDS
AND
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HEALTH
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Code of Practice, which is several years old. A revised edition is being prepared and this should be available shortly. It is, in the author's view, a serious disadvantage that the N.H.S. Code is purely advisory, and unfortunate that there should be no intention of introducing protective legislation for the benefit of those occupationally exposed to radiation within the Health Service. The difficulties of formulating such control would no doubt be formidable. On the other hand, the service is the largest user of radiations and radioactivity outside the Atomic Energy Authority, yet will shortly find itself in the anomalous position of being the only such user whose activities are not governed by law with respect to occupational hazard, though they will be in respect, of waste disposal. This situation is unhealthy from two points of view. The more obvious of these is that the service is chronically short of money and the claims of radiation protection have therefore to compete against others equally pressing, or more so. The second point is that the Code itself embodies a divorce between power and responsibility: decisions on safe practice can only rest with radiolherapists and--even more so--with hospital physicists; and these, and especially the latter, too often do not have enough authority within the hospital hierarchy to ensure that caution and wisdom prevail. Recommendations which are expensive or inconvenient from other points of view are, therefore, liable to be side-tracked; the author has personal knowledge of instances where this has happened. Because of this criticism of the working of the Code, it should be added that the recommendations themselves are mostly of high standard. There are too many other similar codes in circulation for individual mention here. One problem which arises from this is the necessity to make sure that they all tell the same story, and are broadly in conformity with what has been enacted or will be enacted by statute. Thus a minimum age of 18 is prescribed under the Sealed Sources regulations for occupational exposure to radiation. In tt~e N.H.S. Code this age appears as 16. It is to be hoped that this anomaly will be corrected in the second edition. From this brief review it is apparent that the measure of greatest importance to public health authorities is the Radioactive Substances Act, 1960 and the implications of this act must now be discussed. Local authorities are concerned not with occupational, but with incidental and environmental, radiation hazards. This is the point at which we are least well protected by experience, a situation which suggests that there can be no such thing as too much vigilance. It should be realised that radioactivity is not necessarily only a hazard to life. It can also be a nuisance. Stray radioactivity turning up in places where it is not wanted can, for instance, fog photographic film and interfere with control processes which themselves use sensitive radiation detection instruments. The Government has. in the 1960 Act, removed the question wholly from the competence of local authorities by establishing central control. For doing
2~2
PUBI.
IC
t tt!:~AL'I'H
VOL.
LXXV
NO.
4
this it has been criticised, but the case is unanswerable : the inadequacy of pre-existing legislation and the need for unified controls and standards in this tield are the positive reasons which underlie the decision. Negative reasons have been equally decisive ; above all the need for economy in equipment, expenditure and trained manpower. The present scarcity of adequately trained specialists in radiation protection would by itself make it impossible to operate an efficient control over radioactive hazard on a decentralised basis. This is only a single consequence of the long-maintained and systematic neglect of the needs of technical education which is one of the most incredible features of the British political scene. On the other hand, each local authority rightly feels that it is responsible fi~r the health and safety of all those within its area. It will in fact be widely consulted and used under the 1960 Act, but it cannot within that framework act as an independent assessor of radiation risk. Thus, where such risks are concerned, the local authority can only rely upon second-hand reassurance. Some of them feel that this is less tha, satisfactory. Clearly the issue is between what is desirable and what is practicable. F'ew local authorities are at present likely to be bothered with the radiation problem. Those which are will be permanently concerned with it and their numbers will slowly grow. How should they face the situation ? In the first place, the Act itself strengthens the hands of local authorities by the detailed information they will receive concerning local radiation activities and mc~les of radioactive waste disposal. In order to use this information public health inspectors should be trained in the basic essentials of radioactivity and radiation hazard to the point at which they are able to appreciate what type of injury or nuisance is potentially likely to arise from a given source and when, where and how to look for it. Such training is already available to a limited extent, which is slowly increasing as a result of the recommendations of the Vcale Committee. This body, early in 1959, urged that the number of people trained in radiation protection needed to be greatly increased. It drew up detailed proposals for courses of instruction at all levels in order to cater not only for those who will be engaged full-time on protection, but also to meet the needs of those who require background information only. Some universities and polytechnics have already begun to give effect to these proposals. Given the training appropriate to its needs, there appears to be no reason why any local authority faced with a potential radiation haz,ard should not equip itself for the simpler sor',s of radiation detection. The basis for this will in many cases already exist in the Civil Defence Service; but certain sorts of measurement are, and will remain, beyond the competence of the average local authority. Such matters as the precise determination of very small quantities of radioactivity, or its exact measurement in a living person, involve complex techniques and much skill. T h e ~ are properly the concern of the
RADIOACTIV]E
HAZARDS
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PUBLIC
HEALTH
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Radiological Protection Se~'ice, whose services, at present overloaded, will of course be augmented when the centralised organisation proposed by the 1960 Act has been set up. These organisations, however, precisely because they are centralised, may not always be able to act effectively in the case of sudden risk arising from a radioactive accident. In such circumstances a measure of immediate action is needed, even if this is less than perfect. Many local authorities could then call in aid the radi.ation specialists of local hospitals. If no such specialists are available in the area the authority might be wise to make a strictly limited provision for its own possible needs. Some may question whether this is necessary. They should reflect that this is a new field, where much remains to be discovered. This is true above all when we are considering risk to the environment. The false notion, which is implicit rather than defined, has grown up that radiation protection is principally a matter of avoiding direct effects, somatic or genetic to human beings. Yet our species might suffer more, in terms of economic loss, through illadvised radioactive dumping acting adversely on the genetic ma,,crial of animals and plants which are of importance to us. It seems to me that this bs the most probable large-scale radiation hazard which faces us, short of nuclear war. The unexpected it is which happens. As a case in point we might recall the hospital which conscientiously monitored the exposure of its radiation staff, only to discover at a later date that the hospital chaplain was more exposed than any of them. Amongst his duties was the visiting of cancer patients; radium plaques were frequent amongst the more seriously ill of these; and, the more seriously they were ill, the longer the chaplain was likely to stay. A situation easily understood~after it had been discovered. The essence of sound radiation hygiene, however, is to be wise before the event, because the effects of radiation are irreversible.
HAZARDS
AND
PUBLIC
HEALTH
795
Press, the cinema, radio and television--Iz~ay occasional tribute to health education the commercial interests see to it that wherever they can exert their influence there shall be no nonsense of that kind; too often the), lhrive on health miseducation or deliberate "'unhcalth" education. Virtually every aspect of health education includes one or more of three basic things. It asks the public to spend more money, to take more trouble or to give up something pleasant, it is, in effect, against human nalure and starts every evelat for which it enters under a considerable handicap. If it is to succeed at all the climate of public opinion must be influenced in its favour. We believe that the organised opinion of the medical profession can exert very considerable social influence. If the final rcsult of the Cohen Committee's work should be merely to make doctors as a whole conscious of their public duty in health education it will have justified its existence. If, on the other hand, it decides to take no deliberate steps to this end it will have missed a unique opportunity.
RADIOACTIVE HAZARDS AND THE PUBLIC HEALTH SERVICE By
D.
G.
ARNOTT,
B.sc.
Radioisotopes Department, Tke London Hospital, E.I. TIlE impact of applied radiation oll many spheres of the national life is here to stay and rapidly expanding. For reasons which need scarcely be stressed in this article, the problems presented are almost entirely novel and only partially understood, offering few analogies with other situations for which in the past protectivemeasures have had to be devised. For this reason we find ourselves in a delicate position in which wide-scale use of radiation and radioactivity takes place in advance of the development of a sound and comprehensive system of radiation hygiene. Since the end of the war the International Commission on Radiological Protection has been working continuously on the fundamental scientific basis of this matter, but new information comes forward steadily, necessitating frequent revision of the standards which the I.C.R.P. has from time to time introduced. Thus, the situation will continue to be fluid for some time to come ; but a review of how things stand seems appropriate at the present time. Occupational and incidental exposure to ionising radiations and radio-
196
PUBLIC
HEALTH
VOL.
LXXV
NO.
4
television tubes shoe-fitting fluoroscopes high-altitude flying nuclcar test-bomb fallout
(b) Civil-medical, e.g. medical diagnostic radiology radiotherapy with radiations or radioisotopes
(c) Occupational, e.g. occupations associated with (a) and (b) ; and in addition : nuclear power and weapons activities research uses of radioisotopes in industry, agriculture and medicine industrial testing with radiations or radioisotopes (e.g. leaktesting ; gamma radiography ; thickness gauges) mining and processing of radioactive ores (a), (b) and (c) are direct hazards to man. There is, in addition :
(d) Environmental hazard to plants and animals, life cycles and biological chains. These may arise from : radioactive waste disposal nuclear test explosions releasing radioactivity nuclear reactor accidents releasing radioactivity processing of irradiated nuclear fuel elements It is important to realise that under any of these heads either somatic or genetic risks may arise, or both ; and that the ultimate criterion of safe practice must be the genetic consideration. In this long list some hazards, such as those of television tubes and highaltitude flying, are so small that under present conditions they may be ignored. Others are greater but are, or shortly will be, well controlled ; amongst these we may list shoe-fitting fluoroscopes and many of the occupational hazards, such as industrial testing with X-rays or isotopes. There is also a category in which conditions are known to be less than satisfactory and efforts at improvement are being made ; into this category fall the medical applications listed here. Finally, there are those hazards, suspected not to be negligible, where tile risk is ill-defined because of lack of fundamental knowledge. These include all the environmental risks occurring at the bottom of the list and, from the occupational list, nuclear power and weapons activities and the processing of radioactive ores. The hazards of radioactive transport present a special case because here tile danger is of accident, the nature of which it is difficult to forecast and
RADIOACTIVE
HAZARDS
AND
PUBLIC
HEALTH
197
should be generated by fission power as the nuclear power stations now building come into operation one after another. This will necessitate increasing transport of highly radioactive spent fuel elements to Windscale for processing, but there is clearly a limit to the capacity of tile Windscale site fi)r this sort of work and it may be that other processing stations will have to be established. The transport risk will, of course remain: but Sir Christopher Hinton stated recently that spent fuel elements from thc nuclear power stations will be carried as far as possible by rail. At present the situation regarding transport regulations is as follows : R a i h v a y s : British Railways have drawn up rules to govern the conveyance of radioactive materials; these are awaiting approval from the Ministry of Transport. Roads : The Ministry of Transport has drawn up regulalions under the Radioactive Substances Act, 1948 ; these are awaiting Ministerial approval and should be closely studied by public health authorities when available. Post Office • It is safe practice to send certain types of radioactive materials by post, and it is the accepted routinc of the Radiochemical Centrc to despatch many of its products this way. The G.P.O. framed regulations long a g o : the author understands that these are under revision. Regulations for sea and air tran.vJort exist ; ~nd a Code of Practice is being prepared by the Ministry of Transport for use in ports and harhours. It may be easily seen from this brief analysis that the danger points are by no means of theoretical interest, but are already of increasing practical importance. Disposal of radioactive waste is the greatest of these, a problem seen at its sharpest in the processing of irradiated fuel elements. Concerning the'hazards of nuclear test explosions, the position, always ill-defined, has recently changed for lhe better with the realisation that the stratospheric residence-time of fallout is very, much less than originally thought. The earlier estimate was of 7 to 10 years and upon this assumption have been based all the estimates of the incidence of leukaemia, osteogenic sarcoma and genetic injury which might accrue as the result of the bomb testing programme. However, towards the end of 1959 it became clear that the level of radioactivity in the atmosphere was less than was to be expected on the 7 to 10 years hypothesis. A sharp rise of 60 % in the Sr-90 uptake of children's bones during the first half of 1959 was reported by the Atomic Energy Research Establishment in March, 1960 ; whilst, from the Agricultural Research Council at the same time came notice of a parallel rise in the contamination of green vegetables. In the autumn of 1960 a further rise in Sr-90 in bone has been reported by A.E.R.E. These findings suggested that fallout was depositing much more rapidly than expected and the matter was put beyond doubt by a statement in the House of Commons on 22nd March, 1960, which gave a period of 15 momhs to four month~ as the lowe~ estimate so far of the s~rat~pheHc
198
PUBLIC
HEALTH
VOL,
LXXV
NO.
4
that the atmosphere is now substantially free of test-radioactivity and also that no further rise in Sr-90 contamination should be reported in either bones or vegetables. Therefore, barring a resumption of tests of high-yield weapons, the public health service need not expect to be concerned with fallout. The well-known M.R.C. repor t of 1956, " The Hazards to Man of Nuclear and Allied Radiations," has been revised and in its new form will provide important new information on this and other subjects. At the moment of writing it is still in press, so cannot be quoted here ; but it should be available by the time this article has appeared. At this point it is useful to review the present and near-future state of the law regarding radiation protection. Although occupational protection as such does not fall within the scope of tile public health service, it is so bound up with the rest that it is clearly better to present the whole picture. There are, or within a few years will be, six Acts on the Statute Book dealing with nuclear energy and related matters, including radiation protection. The Factories Act is one of these and under it there will be certainly two and possibly three Orders concerned with occupational protection. Radioactive waste disposal in all its aspects is now the concern of a single Act (Radioactive Substances Act, 1960), the Public Health Acts not being relevant in this connection. In addition there is the important Code of Practice for the National Health Service, which is at present being revised and is advisory only. To the extent that these regulations concern radiation protection, the basic information from which their standards have been derived arises from the work of the 1.C.R.P., which gives them a measure of uniformity. There has been much understandable criticism of the time which this urgent legislation is taking to appear. There are three main reasons for the delay. The first of these is that the I,C.R.P. is continually having to revise its standards in the light of new information and this has inevitably led to redrafting, notably of the Sealed Sources regulations mentioned below. Secondly, there is the peculiarly complex nature of the legislation itself. Thirdly, the number of people qualified to do the work is severely limited ; it was a salutary shock to the present author, when he joined them recently, to observe from the inside the enormous strain under which some of them are labouring. The legislation in question, present and impending, may be summarised as follows: I.
FACTORIES
ACT
(a) Luminising Order. This is the oldest piece of protective legislation on the Statute Book. It controls the occupational hazards of radioactive luminising in all aspects, whether the radioactive source be sealed or unsealed. It is not concerned with the disposal of radioactive waste. The Luminising Order will disappear from the Statute Book when the Sealed Sources and Unsealed
RADIOACTIVE
HAZARDS
AND
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HEALTH
199
(b) Sealed Sources. Regulations controlling the occupational hazards of sealed sources are now in their second draft. The intention behind this Order is that it will do for such industrial uses as ~,-ray industrial flaw-testing what the Luminising Order has done for luminising. Industrial research is not covered, nor is radioactive waste disposal. The chief inspector of factories stated recently that these regulations should be in force towards the end of 1961. (c) Unsealed Sources. A committee is at present drawing up regulations which are intended to extend control to the industrial uses of unsealed sources of radioactivity. It may be expected that the requirements will be parallel to those to be found in the Sealed Sources Order already mentioned. No date can be given for the operation of these much-needed regulations, as the first draft has yet to be circulated. (d) Research. Research activities in general have not hitherto been covered by the Factories Act. It has been decided to make a partial exception in the case of radioactivity and ionising radiations ; a committee is now studying proposals which will cover industrial and many other research uses of both sealed and unsealed radioactive sources, excluding waste disposal. It is not at present precisely known how many categories of research will fall within the scope of this Order, but clearly there are a number of marginal uses which should not on that account escape control. It is not yet known whether these proposals will be given statutory form or will be merely advisory. 2. A T O M I C E N E R G Y ACT, 1 9 4 6 This Act has now no bearing on the question of radiation protection. 3. R A D I O A C T I V E SUBSTANCES ACT, 1 948 Section 5 allows regulations to be made regarding radiation protection. None have ever been rrmde because any powers so executed would not affect or set aside pre-existing legislation. This means that if pre-existing legislation were in conflict with any Order made under tlle 1948 Act, the former would stand. The importance of the 1948 Act lies in the Advisory Committee which was estfiblished under it. This is one of the most powerful Advisory Committees ever established by Statute : Ministers are obliged to seek its advice before laying before Parliament any proposed measures regarding radiation protection. This has meant, ill fact, that all such measures, including the Factories Act Orders already referred to, have in practice been drawn up by sub-committees and panels appointed under the 1948 Act. 4. U . K . A T O M I C ENERGY ACT, 1954 Section 5 imposes the duty on the Atomic Energy Authority to secure
200
PUBLIC 5.
NUCLEAR
HEALTH
VOL.
INSTALLATIONS INSURANCE) ACT,
LXXV
NO.
4
(LICENSING 1959
AND
This applies provisions closely analogous to those of the 1954 Act to nuclear power .stations, private reactors and similar equipment. Strictly speaking, the Electricity Generating Boards do not come within the scope of this Act, but both have accepted formal obligation to be bound by its requirements pending consideration of possible further legislation. The Act was promulgated in April, 1960; from that date all nuclear reactors, whether for power or for research purposes, have to be licensed and the terms of the licences are expected to be stringent. The sections of this Act regarding radioactive waste disposal lapsed when the Radioactive Substances Act, 1960, became law. 6. R A D I O A C T I V E SUBSTANCES ACT, 1960 This Act is solely concerned with radioactive waste disposal. It does not supplant the Act of the same name of 1948. The Ministers concerned are the Minister of Housing and Local Government and the Minister of Agriculture in England and Wales, and the Secretary of State in Scotland. These ave empowercd (i) to register all casual useis of radioactivity and to notify these registrations to the relevant public health authorities ; (ii) to require authorisation for radioactive waste disposal; (iii) to prescribe methods and standards to be followed in such disposal; (iv) to establish a national disposal service; (v) to appoint an inspectorate; (vi) to impose penalties for violations, the nature of which is prescribed by the Act. This Act supersedes all incidental powers regarding radioactive waste which may be available, for example, under the Public Health Acts, 1936 and 1937, and the various Acts regarding fisheries and river pollution. There are various reasons why these Acts fail as a means of controlling radioactive nuisance. For example, under some of them action can only be taken once a nuisance has become apparent ; this is inadequate when dealing with radioactivity, where the whole emphasis must be on preventative measures. The system of registration established under this Act will not apply to premises covered by the U. K. Atomic Energy Act, 1954~ or the Nuclear Installation Act, 1959. In addition, numerous Codes of Practice of an advisory nature have been drawn up. The fact that they are advisory only has meant that they have become available much more quickly than could possibly be the case with legislation. The Universities' Code of Practice, ,recently published, is a good example of what such a publication should be. Better known is the N.H.S.
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Code of Practice, which is several years old. A revised edition is being prepared and this should be available shortly. It is, in the author's view, a serious disadvantage that the N.H.S. Code is purely advisory, and unfortunate that there should be no intention of introducing protective legislation for the benefit of those occupationally exposed to radiation within the Health Service. The difficulties of formulating such control would no doubt be formidable. On the other hand, the service is the largest user of radiations and radioactivity outside the Atomic Energy Authority, yet will shortly find itself in the anomalous position of being the only such user whose activities are not governed by law with respect to occupational hazard, though they will be in respect, of waste disposal. This situation is unhealthy from two points of view. The more obvious of these is that the service is chronically short of money and the claims of radiation protection have therefore to compete against others equally pressing, or more so. The second point is that the Code itself embodies a divorce between power and responsibility: decisions on safe practice can only rest with radiolherapists and--even more so--with hospital physicists; and these, and especially the latter, too often do not have enough authority within the hospital hierarchy to ensure that caution and wisdom prevail. Recommendations which are expensive or inconvenient from other points of view are, therefore, liable to be side-tracked; the author has personal knowledge of instances where this has happened. Because of this criticism of the working of the Code, it should be added that the recommendations themselves are mostly of high standard. There are too many other similar codes in circulation for individual mention here. One problem which arises from this is the necessity to make sure that they all tell the same story, and are broadly in conformity with what has been enacted or will be enacted by statute. Thus a minimum age of 18 is prescribed under the Sealed Sources regulations for occupational exposure to radiation. In tt~e N.H.S. Code this age appears as 16. It is to be hoped that this anomaly will be corrected in the second edition. From this brief review it is apparent that the measure of greatest importance to public health authorities is the Radioactive Substances Act, 1960 and the implications of this act must now be discussed. Local authorities are concerned not with occupational, but with incidental and environmental, radiation hazards. This is the point at which we are least well protected by experience, a situation which suggests that there can be no such thing as too much vigilance. It should be realised that radioactivity is not necessarily only a hazard to life. It can also be a nuisance. Stray radioactivity turning up in places where it is not wanted can, for instance, fog photographic film and interfere with control processes which themselves use sensitive radiation detection instruments. The Government has. in the 1960 Act, removed the question wholly from the competence of local authorities by establishing central control. For doing
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this it has been criticised, but the case is unanswerable : the inadequacy of pre-existing legislation and the need for unified controls and standards in this tield are the positive reasons which underlie the decision. Negative reasons have been equally decisive ; above all the need for economy in equipment, expenditure and trained manpower. The present scarcity of adequately trained specialists in radiation protection would by itself make it impossible to operate an efficient control over radioactive hazard on a decentralised basis. This is only a single consequence of the long-maintained and systematic neglect of the needs of technical education which is one of the most incredible features of the British political scene. On the other hand, each local authority rightly feels that it is responsible fi~r the health and safety of all those within its area. It will in fact be widely consulted and used under the 1960 Act, but it cannot within that framework act as an independent assessor of radiation risk. Thus, where such risks are concerned, the local authority can only rely upon second-hand reassurance. Some of them feel that this is less tha, satisfactory. Clearly the issue is between what is desirable and what is practicable. F'ew local authorities are at present likely to be bothered with the radiation problem. Those which are will be permanently concerned with it and their numbers will slowly grow. How should they face the situation ? In the first place, the Act itself strengthens the hands of local authorities by the detailed information they will receive concerning local radiation activities and mc~les of radioactive waste disposal. In order to use this information public health inspectors should be trained in the basic essentials of radioactivity and radiation hazard to the point at which they are able to appreciate what type of injury or nuisance is potentially likely to arise from a given source and when, where and how to look for it. Such training is already available to a limited extent, which is slowly increasing as a result of the recommendations of the Vcale Committee. This body, early in 1959, urged that the number of people trained in radiation protection needed to be greatly increased. It drew up detailed proposals for courses of instruction at all levels in order to cater not only for those who will be engaged full-time on protection, but also to meet the needs of those who require background information only. Some universities and polytechnics have already begun to give effect to these proposals. Given the training appropriate to its needs, there appears to be no reason why any local authority faced with a potential radiation haz,ard should not equip itself for the simpler sor',s of radiation detection. The basis for this will in many cases already exist in the Civil Defence Service; but certain sorts of measurement are, and will remain, beyond the competence of the average local authority. Such matters as the precise determination of very small quantities of radioactivity, or its exact measurement in a living person, involve complex techniques and much skill. T h e ~ are properly the concern of the
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Radiological Protection Se~'ice, whose services, at present overloaded, will of course be augmented when the centralised organisation proposed by the 1960 Act has been set up. These organisations, however, precisely because they are centralised, may not always be able to act effectively in the case of sudden risk arising from a radioactive accident. In such circumstances a measure of immediate action is needed, even if this is less than perfect. Many local authorities could then call in aid the radi.ation specialists of local hospitals. If no such specialists are available in the area the authority might be wise to make a strictly limited provision for its own possible needs. Some may question whether this is necessary. They should reflect that this is a new field, where much remains to be discovered. This is true above all when we are considering risk to the environment. The false notion, which is implicit rather than defined, has grown up that radiation protection is principally a matter of avoiding direct effects, somatic or genetic to human beings. Yet our species might suffer more, in terms of economic loss, through illadvised radioactive dumping acting adversely on the genetic ma,,crial of animals and plants which are of importance to us. It seems to me that this bs the most probable large-scale radiation hazard which faces us, short of nuclear war. The unexpected it is which happens. As a case in point we might recall the hospital which conscientiously monitored the exposure of its radiation staff, only to discover at a later date that the hospital chaplain was more exposed than any of them. Amongst his duties was the visiting of cancer patients; radium plaques were frequent amongst the more seriously ill of these; and, the more seriously they were ill, the longer the chaplain was likely to stay. A situation easily understood~after it had been discovered. The essence of sound radiation hygiene, however, is to be wise before the event, because the effects of radiation are irreversible.