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Tuesday, May 29, 2012

Dalgety Bay - Food Standard Agency's Reply to FoI

  On May 17th I sent this FoI to the Food Standards Agency in Scotland in their ban of fishingm & received this today, so at least they deserve some credit for not waiting till the last legal moment, or beyond. My questions are in normal, their answers in bold and my comments in bold italics.

1 - What evidence, from the FSA's knowledge, do you have of "radium" being found on the beach? If none write "none".

     Radium contamination was first detected in 1990 as part of the routine environmental monitoring report. Subsequent surveys bring the total number of radioactive particles and items recovered to date to over 2,000. ... results are available on SEPA's website.

     This is false. Radium has not provably been detected. All that has been detected is radiation, some clumped in what are described as "particles". SEPA have repeatedly refused to produce any actual evidence of radium in response to FoIs asking that precise question, indeed this refusal to do so or admit the lack is now subject to an appeal..
2 - What background readings of radiation has the FSA made at this beach and at others nearby, as a control, and have you found the radiation level higher at Dalgety Bay? Of none and no write "none and no".

None. The FSA does not directly undertake monitoring...

    SEPA does not undertake such monitoring either. So it is accepted that there is no evidence whatsoever that the Dalgety Bay radiation exceeds that of neighbouring beaches in intensity or particularity/clumpiness.

3 - Does the FSA accept SEPA's evidence that the radiation at Dalgety Bay is "less than 2/3rds background in Aberdeen" and that this also makes it as low as 1% of the radiation level in various places around the world from which the FSA does not ban imports? If yes answer "Yes".

    The issue of concern does not apply to the levels of background radiation but to the possibility that highly radioactive particles could enter the food chain. Although the answer to the question is Yes

    Since he has admitted is no evidence that the "particles" are more common than on neighbouring beaches let alone as common as across Aberdeen. On the question of whether being in particles is more "dangerous" than normal background radiation see answer to #5.
4 - Does the FSA dispute evidence that the maximum theoretical level of radium from these dials, had all of it been deposited on the beach and none of it washed or blown away over the last 60 years, would not exceed 25% of naturally occurring radium there or 1/35,000,000,000th of the total naturally occurring background radioactives there? If you do not dispute it answer "no".

Yes. A "theoretical level" is simply a theory not evidence. It is evident from the heterogeneity, of the items discovered, the uneven distribution of deposits and historical accounts that the contamination derives not just from luminised dials, but as a result of debris from repair, reluminising work, and disposal of luminised items carried out on-site.

    The maximum amount is based on the historical accounts and unlike by the FSA, has not been disputed by SEPA in any way, even under the legal pressure of FoIs. He is misusing the English language here using "theoretical" as if it meant "drawn from theory" when in fact it clearly means "an absolute maximum, from the known facts above which the radium level could not go, though in non-theoretical conditions it is likely much of it will have been lost over the last 60 years". The distribution cannot be said to be uneven since, as acknowledged, there has not been a search elsewhere. I am not sure in what way the particles/clumps discovered can be said to be particularly heterogeneous. While one would expect any painting to be purely of the aircraft dials in question claims that the radiation comes from other "luminised items" rather than just dials have not been made in previous FOIs. It would seem to require some evidence that Dalgety Bay airfield was also a radium watch factory or laboratory for refining pitchblende to obtain natural radium. This is an extraordinary new claim for which no evidence has been produced and goes against all common sense.

5 - If the answers are as I suggest then it is obviously impossible to honestly claim there is a real radiation threat to food there, let alone one which, if the rules are applied honestly, would not  Is there another credible option? If no answer "no". If there is please give it.

Yes, the contamination has arisen from local historical activities and is confined to the Dalgety Bay area. Additionally the contaminate is particulate and some particles are small enough to be ingested by seafood such as winkles and mussels. If these were subsequently consumed they could cause direct damage to the human gut and an increased risk of cancer. Laboratory studies have shown that some particles would be soluble in the human gut which would increase the potential dose.
  Again this is untrue. No evidence has been produced of "contamination" as opposed to natural radiation, indeed it is accepted that Dalgety is less "contaminated" by radiation than other places. There is no evidence of the claimed "historical activities" that, alone, could have increased any theoretical radioactives by more
 than a 35 billionth. Nor has any evidence been produced that it is "confined to the Dalgety Bay area" since neither SEPA nor the FSA have looked.

  That being the case and they have not been" closing down all fishing from Aberdeenshire and points north let alone prohibiting any food imports from much of the world" then it is proven that "only possible reason for doing this is to deliberately promote a fraudulent scare story" by a wholly corrupt and parasitic organisation..

  "Laboratory studies have shown that some particles would be soluble in the human gut which would increase the potential dose" is a particularly interesting remark for 2 reasons. Firstly, since the paint was water soluble virtually all, not merely "some" of the "particles" should be water soluble - if they aren't natural particles. Even more importantly it is an acknowledgement that they know all the stuff said in answer to #3 about this radiation being dangerous in a way background radiation isn't is because it is "particles". This is the "hot particle theory and is accepted by wikipedia and apparently even by the FSA when it suits them, as false.

  Calling things "particles" is clearly disingenuous if you don't mention size. Everything is a particle but, by the laws of geometry, the larger a particle proportionately the less surface area it has, to contact  anything outside so for equal amounts of radioactives and background radiation, it would be better for it to be in particles and anybody using particularlity rather than background radiation as the measure of danger is lying. The FSA has done so but has also achieved the remarkable feat of claiming the precise opposite as well in the same letter.
6 - If the answer to 5 is no is there any specific ruling applying to Dalgety Bay but not the rest of the country that prevents this action from representing the very highest standard of honesty the FSA Scotland aspire to or that would make any ruling on any food matter by you infinitely more trustworthy than this. If none and no answer "none and no".

  The FSA has a statutory responsibility to protect consumers through ensuring food safety and has taken a precautionary approach, based on the best available evidence, in order to discharge the responsibility.

   That appears to be "none" and "no" then. Note the use of the term "precautionary approach".  This is basically a way of saying "we don't need no stinkin evidence" & relegates the entire organisation into the realm of unscientific quackery. Of course if they were honest non-scientific quacks, who actually believed a word of their own scare story they would also be banning imports of food from the "various places around the world from which the FSA does not ban imports" but are up to 100 times more radioactive.

My Reply
Dear Dr Will Munro,
                                Thank you for the FSA's reply. I am including my blog comments for you to comment on should you feel you can enhance the FSA's credibility in any way by doing so.
      Your answers bring up obvious further questions which I would be obliged for a reply to under the Act..
1 - What evidence do you have for your claim that some of the 0.25g which might have been spread over the area 60 years ago, has been detected by chemical or other means? If you have none your first answer is untrue and must be corrected.
3 - What is your evidence that the hot particle theory, on which your claim that only the particularity of the materials, not the overall level is important depends, is correct?
4 - What is your evidence for the claimed, but previously unknown, other radium contamination not linked to dial paint?  What is your evidence that the distribution of "particles" is different from that at Dalgety in neighbouring beaches which both SEPA and yourselves admit you have not similarly examined? In both cases, if none answer none and provide a new answer.
5 - See 4 above. If  no control sample has been attempted on neighbouring beaches how can it be possible to say that the radiation is only at Dalgety? The alternative being that it is natural and occurs elsewhere.
Also what is your evidence that the opposite ofv the hot particle theory is true and that radiation reduced to undetectable particles in solution, comparable to background radiation, is the more dangerous?
6 -The evidence free, anti-scientific "precautionary approach" would require the banning of any imported food that might come from an area of up to 100 times more radiation than Dalgety, or even from Aberdeen. Indeed technically it would require you to ban selling haggis on the grounds that it might attract flying saucers - a hypothesis for which there is no evidence, but then that is the point of this principle. Will this principle be applied without prejudice?
I accept your agreement on #2.

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I can tell you that "particularity" matters because of the potential for damage.

Gamma radiation (non-particle, but often produced during fission along with alpha particles) cannot enter the food chain, and would have to be present in high concentrations (so as to be visibly damaging to wild plants and animals) before presenting a substantial risk. Blocking requires high-density materials, denser than the local granite.

Beta particles are ionising, but they are essentially electrons that have gone into business for themselves, and so do not pose any immediate threat, should they enter the food chain. You'll probably have had at least one static shock in your time, you can see why they're not a risk.

Alpha particles, however, are like helium ions - two neutrons, two protons - and occur as a fission product. Because they are positively charged, in nature they ionise much more easily, and so are capable of doing much more damage than beta particles, albeit on a much smaller scale. If a few of those hit your hand, you'd have nothing to worry about, because you have enough going on there in terms of physical protection (the skin itself) and natural chemistry to deal with them, but if you ate or inhaled enough of them, you would begin to have serious issues as the linings of your digestive or respiratory tracts became damaged. That's why "particularity" matters.

While wiki is generally open to edits, and so potentially inaccurate, their articles relevant to this area seem to hit the high points quite well (at least, as at 12.00, 02/06/2012). If you have some reservations on this score, you might like to check out some of the sources cited in their entries for "gamma rays", "alpha particle" and "beta particle".

Incidentally, the background radiation in Aberdeen is due to concentration of natural uranium in a few particular minerals which happen to show up in granite. Most of the fission which occurs to produce the background radiation will occur within the main body of the rock. Granite is notoriously hard to drill, or otherwise break through, and water doesn't pass through it easily without holes or cracks to go down, so most of the particles will remain in the rock, while gamma rays, albeit slightly diminished in energy by their passage through the rock, can escape. That's why the background level of radiation is not as significant a concern.
"particularity" means the extent to which the radioactive atoms are clumped together as particles instead of being absolutely evenly spread which SEPA appears to be claiming natural radiation must be. That no materials deposited in the earth naturally are absolutely evenly spread. I am aware of the differences between Alpha, Beta an Gamma radiation but they do not affect clumping.

Regarding Aberdeen - unless the radiation measurement had been taken by drilling into the rock it would be a measures of the background radiation on the surface, to which your point is not relevant. Since it was specifically referred to as bacjground radiation in "any Aberdeen Street" it is clear it was a simple measurement.
And it is clear that you are reading my message but not understanding. The background radiation does not depend so much on where the radioactive material is, because of its nature. The background radiation is of a type which travels through the rock. The potentially dangerous radiation is of a type which, without intervention, remains within the rock. Given the prevalence of granite as a building or facing stone in most of the city, "in the street" doesn't make sense as a distinction from "in the local rock". The radioactive material inside the section of the stone is still inside it, even after it has been cut and moved, and the particles released at the newly exposed surfaces will do much as those at the outer surface of the uncut rock did.

Atoms are particles, and reference to radioactive particles rather than radiation generally only excludes gamma rays. If groundwater flows slowly, they will not travel far or fast, and so diffusion to a relatively even spread is a reasonable assumption to make, provided groundwater movement is slow. You have said yourself that you would expect the majority of the radioactive material to be soluble in water.

Larger particulate pollution is more of a concern purely because it represents a larger concentration of radioactive particles. Hotspots occur with any type of contaminant subject to transport or diffusion, as you can see by simply looking up construction-industry practices for remediation of made ground. The larger accumulations of material would simply be where most of the radioactive material was originally left.
Actually I & SEPA have said that the all the raioactives not naturally there, ie the paint, was water soluble, at least it was 60 years ago. Since it is on a beach there will be a considerable amount of groundwater. So what you are accidentally arguing is that the paint will have to be entirely diffuse and the particles/clumps must, by definition, be natural.

An interesting argument.
There is no reason whatsoever for assuming this lack of groundwater at Dalgety to create such a salt water barrier & you make no attempt to produce any. The claim hovers, unsupported in mid air.

Beyond that you should remember that the place is on the Firth of Forth. Therefore salinity levels will vary widely and thus no such "barrier" of encrusted salt could buiold up. Grasping for straws isn't in it. You are grasping for half a gram, maximum, among millions of tons.

It wouldn't be a physical 'barrier' of encrusted salt, but a horizon of soluble crytals that would have some degree of movement as fresh and salt waters moved and mixed. The point would be that it remains in a relatively restricted area, but that that area may exist within a larger band, depending on how the tides and weather affect the relative availability of salt and fresh water in the vicinity of the particulate waste.

You may also note that your reply makes no sense without my post betweentimes. I'm getting the distinct impression that you're not inclined to admit that you initially misunderstood my words, even though the fact that I rephrased them would indicate a tacit acceptance that they might have been poorly phrased for general discussion.
If you knew what the firth of Forth was you would know why the variation between fresh and salt water must be so great that the concept it provides any permanent or even semi-permanent barrier is risible.

While I acknowledge you are less inclined to idiocy than Skip Evans is I see no reason whatsoever to believe you differ from him idealogically or physically. Of course if you do it is easily within your power to show that your are not using multiple non-names to hide under.

If I didn't know what the Firth of Forth was, I wouldn't be talking in terms of salt water, because the term 'firth' is not in common usage beyond Scotland (and some small parts of Ireland and Canada where it is understood, but not applied to place names).

If you demonstrated that you understood the difference - and significance thereof - between groundwater, surface water and seawater, and how each behaves, I'd be more inclined to argue this out with you, but in the sum of our interactions so far you've being rather obtuse and very rude.

Yes, I could sign in to make a post. But that would potentially involve providing information to you, or to your host, which could allow you to make external direct contact. My dad has forbidden me from doing so, although he does say your shop is okay.

As with the whole "child abuser" thing, or anything else like it, I don't want to get involved with that when I don't know what happened, have no independent source to check things out with, and don't expect to meet the person. That doesn't preclude me getting angry when you make accusations apparently at random, because nobody needs that.
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