The Royal Society of Edinburgh (RSE) is pleased to respond to the Food Standards Agency (Scotland) consultation on the European Commission Proposal to Introduce Legislation Controlling Radioactivity in Foodstuffs. The RSE is Scotland’s premier Learned Society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled by the General Secretary with the assistance of a number of Fellows with substantial experience in radioactivity and the environment.

There are still significant levels of Chernobyl-derived radiocaesium in some parts of the food chain outwith the European Community, particularly in Eastern Europe, Russia and adjoining countries. The proposals set out, therefore, are appropriate and broadly sensible in terms of a dose limit in the human diet.

The specific issues identified in the consultation paper are addressed below:
Should the UK support the introduction of European legislation to standardise Maximum Permitted Levels (MPLs) for radioactive contaminants in foods throughout the Community?
The UK should support legislation which standardises Maximum Permitted Levels.

Should such legislation apply to all radionuclides regardless of source?
From the standpoint of risk management, the only suitable approach is to have a single set of standards that apply to food originating from both within and outside the EU. Whether the standards are incorporated in a single piece of legislation or are contained in two separate pieces of legislation is a question of legislative convenience, but they should apply to all radionuclides regardless of source.

How should radionuclides be grouped together for setting MPLs (for example by type of radioactive emission and half-life, or by radiation dose per unit of radioactivity ingested)?
Radionuclides must be grouped to take on board risk, on the basis of radiation dose/unit of radioactivity, whether ingested in the diet or not (e.g. skin contamination). Otherwise it will be difficult to sensibly protect human health and utilise foodstuffs effectively.

What numerical values should be ascribed to MPLs for the various radionuclide groupings for different types of foodstuffs?
It will be important for the MPLs to be adopted on some sound scientific basis of risk assessment for human safety. This requires a proper analysis and understanding of the effects of the levels, types and origins of the sources of radioactive contamination, estimation of the potential dietary intake of the contaminated product and likely health consequences.

Council Directive of 13 May 1996 laying down basic safety standards for the health protection of the general public and workers against the dangers of ionizing radiation (the Basic Safety Standards) states in Article 3 (2f) that no reporting need be required for practices involving "material contaminated with radioactive substances resulting from authorised releases which competent authorities have declared not to be subject to further controls." How would the new proposed legislation take into account the dose limits andrequirements in the Basic Safety Standards?
The RSE has some reservations about the lack of definition of ‘competent authorities’ in article 3 (2f) of the Basic Safety Standards. While competent authorities are trusted to make regulations, there should be some safeguarding mechanism.

Additional Information

In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: Basic Safety Standards Directive Euratom 96/29 (June 1999). 

October 2001

Further information is available from the Research Officer, Dr Marc Rands