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Radiation Protection after 3.11: Conflicts of Interpretation and Challenges to Current Standards Based on the Experience of Nuclear Plant Workers

Paul Jobin
U Paris-Diderot, CEFC Taipei

“The full version of this paper has been removed at the request of the author, most likely in preparation for publication, but you may contact the author for a preprint or reference to the published article.”

Social construction of invisibility or epistemic constraints?

Since the Fukushima nuclear disaster (hereafter 3.11), nuclear workers have been engaged in the “emergency work” (kinkyū sagyō) at Fukushima Daiichi without clear time limits, meaning the “emergency” could last for decades. This problem has been emphasized by the NGOs engaged in negotiations with the Ministry of Health and Labor. These activists aim to defend the rights of the workers involved in the cleanup of Fukushima Daiichi and of those hired for the decontamination work in Fukushima prefecture. Some workers have come from Fukushima to join the meetings in Tokyo, bringing a dose of reality to discussions that might otherwise lack the proper context. The criticism of these NGOs and workers deals mainly with various aspects of the current working conditions.

Some of the problems addressed are similar to those faced by contracted nuclear plant (hereafter, NP) workers even before 3.11, like the practice of modifying dosimeters to minimize radiation readings—since employers are not obligated to propose alternative jobs when the maximum dose has been reached. There is little pressure to change this situation, since the multiplication of contractors allows the big players, like TEPCO, Tôshiba, Hitachi, GE, etc., to evade any responsibility over such practices. Another major issue is the lack of health insurance or regular labor contracts. Other problems are specific to the post-3.11 context. As regards radiation protection, the biggest problems are as follows:

– The Ministry has decided to deny health follow-ups to workers exposed to a cumulative dose below 50 mSv for external radiation exposure (only those above this dose will receive a one-year cancer test);

– TEPCO declared that there would be no records for internal radiation below 2 mSv;

– There is so far no systematic dosimetry nor health follow-ups for the people employed—mainly on a temporary basis—in the “decontamination” work on the various hot spots of Fukushima prefecture.

The NGOs stress that these decisions regarding radiation protection—and lack of decision regarding labor contracts and decontamination work—seem inconsistent with the declaration made by the government and nuclear safety authorities of “learning from the disaster.” Japanese government experts have argued that, below a cumulative dose of 100 millisieverts a year, the effects of radiation are negligible, basing this assertion of “safe levels” on the recommendations of the International Atomic Energy Agency (IAEA) and the International Commission on Radiation Protection (ICRP), and on the conclusions of epidemiological surveys. These surveys have been conducted on various cohorts; some are related to nuclear disasters (like Hiroshima-Nagasaki survivors, Chernobyl liquidators, or victims of the fallout from nuclear testing), while others refer to the regular occupational exposure of medical radiologists and nuclear installation workers. This large corpus and its interpretation by the IAEA and the ICRP have shaped the current standards of radiation protection.

Labor activists point out that the existing epidemiological surveys posit no safety threshold, either at 100 mSv or at any other level.  Therefore, the decision to eliminate data below 2 mSv is certainly questionable, particularly since keeping such records not only poses no great difficulty, but could also provide “precious data” on low-dose radiation.  Challenges to the current standards of radiation protection are not limited to occupational exposure, however, but apply to the population as a whole. Fukushima “cleanup” workers can therefore be viewed as sentinels of a potential epidemic of radiation-related diseases. It is thus imperative that attention be given by post-3.11 Japan to these workers.  And this raises the question: What importance have STS and disasters studies given to labor issues?

The total number of NP workers who have been compensated for occupational hazards is just 14, which is extremely low compared to the entire labor force for a single year (over 80,000 in 2009). If we exclude the eight workers who died of acute irradiation after the Tokaimura and Mihama accidents (1999 and 2004), there are only six workers who have been recognized for occupational cancer due to radiation exposure: four cases of leukemia, one myeloma and one lymphoma. For these cases of cancer, the total cumulative doses of radiation were between 40 and 100 mSv. Three of them were certified only after a heated public battle. Therefore, as has also been shown in the case of NP workers in France and the United States, and for African uranium mine workers, many workers who might have developed cancer will never appear in the public health data, but remain invisible.

STSers might thus qualify the decision to suppress such low-dose data as a “social construction of invisibility”. Hecht (2013), for example, sums up the situation well, saying that this systemic invisibility implies greater and unrecorded exposure of the true collective dose with few resulting illnesses becoming “occupational diseases”. Combining this rather critical STS approach with a pragmatic sociology of criticism, I think it would be interesting to further examine the arguments of both the Ministry and the NGOs (ongoing fieldwork), as well as criticism within the nuclear establishment before and after 3.11.

The authors of the major epidemiological studies related to nuclear plant workers, when asked, confirmed that their results could not be interpreted as minimizing the risks of doses below 100 mSv. As concerns the current standards of radiation protection, they stress the epistemic constraints inherent to epidemiology and suggest the tendency of institutions like the IAEA to present the results so as to downplay the risks.  The conflicts of interpretation between Japanese government experts and activists thus reflect a larger debate, at a global level, within the community of epidemiologists and radiation specialists. This debate needs to be considered within the longue durée of the controversy over low-dose exposure, particularly in regard to its evolution after Three-Mile Island and Chernobyl. For example, did these disasters induce the modification of ICRP standards in 1990 (which established the current framework)? To what extent has 3.11 created a new context that could lead to the further modification of current standards?

Another global event in the long history of “low-dose” radiation

The Fukushima nuclear disaster cannot be understood solely within the context of Japan, but must be regarded as part of the global controversy over low-dose radiation.  I have therefore tried above to capture some important points of the debate in Japan, and how the apparent contradictions of the Japanese government mainly reflect the dominant international paradigm for radiation protection norms and their epidemiological basis. Or in other (STS) words, the “hybrid forum” between experts and citizens in post-3.11 Japan cannot but be intimately interconnected with the 50-year-old controversy on the unknowns of low-dose exposure for cancer and non-cancer diseases—not to mention the unknown unknowns of mutagenic disorders. The sad irony for post-3.11 Japan and the citizens of Fukushima is that the currently dominant radiation protection model is still based mainly on the legacy of Hiroshima-Nagasaki rather than that of Chernobyl. This is a double irony: first, because this model harkens back to the founding trauma of postwar Japan; and second, because it is based on the first nuclear bomb tests rather than the first “level 7” nuclear power plant disaster. WHO/IARC has produced conclusions that could challenge that model, but so far, they have been disregarded by UNSCEAR itself, as well as by the ICRP’s governing committee.

Any examination of the controversy over nuclear energy in action involves dealing with sources of imperfect reliability.  The obligation to communicate with the public can compel scientists to oversimplify their results, since scientific output is generally complex and hence difficult to explain.  The continuous lobbying of the “nucleocrats,” with its strong bias in favor of their industry, has provoked the radicalization of the antinuclear critique, particularly in the aftermath of disasters like Three-Mile Island, Chernobyl, and Fukushima.  Therefore, to observe the nuclear debate in action, social scientists and journalists must contend with lies and half-explanations, intentional or not, and hence a part of the unknowns, intentional or not.  On the other hand, sociologists must also accept their own limitations to capture the constraints of sophisticated epidemiological surveys, characterized by huge cohorts and long research periods. These epistemic constraints should not, however, impede the sociologist from hazarding some fundamental questions, such as the following: Why has epidemiology become the main reference for radiation protection standards? Why should we wait to have human cohorts of man-made disaster victims such as Hiroshima-Nagasaki, Chernobyl and Fukushima? In that sense, epidemiology looks rather like a post-mortem science. Morbidity would be a better index, but so far, most countries (including Japan) lack national cancer registries.  Why not instead give more attention to animal experimentation and toxicology as a proactive preventive tool as regards the effects of low doses on human health?  Through such questions, STS and disaster studies may bring a significant contribution to the debate.

Paul Jobin  is Associate Professor in the Department of East Asian Studies, University of Paris Diderot, and Visiting Director of CEFC Taipei (French Centre for Research on Contemporary China, Taiwan Branch). His research focuses on industrial pollution in Japan and Taiwan.

  1. Kath Weston permalink

    Paul, thank you for drawing attention to labor and class. It is worrisome that the health screenings even for those who qualify seem to focus on cancer, rather than the entire range of effects linked to radioactive exposure (e.g., heart problems from radioactive cesium). I don’t think there is even comprehensive a registry of Fukushima Daiichi NP workers. Are NGOs organizing to collect their own data as well as fight to change government policy? (In North America, the Navajo Tribal Council ran up against such problems and in response established the Office of Navajo Uranium Workers to collect statistics as part of the fight for worker compensation.) Is anything happening with the call to revive the San’ya day laborers movement as a way to achieve more NP worker protection? Later you speak of the irony that current radiation protection models are based on Hiroshima-Nagasaki rather than Chernobyl. We need to talk more about that, inside and outside STS. What would it take to change this? If we go beyond epidemiological studies as you recommend, what would prevent those results, if inconvenient to industry or governments, from being sidelined as has happened with Chernobyl studies that have found significant health consequences?

  2. Scott Knowles permalink

    Paul–this essay brings us back very usefully to examining the larger framing of disaster as a political moment or set of moments that rewrites the law and regulatory relationships. If a disaster clean-up is an emergency, and if the clean-up goes on for years (decades?) then emergency (non) rules apply. The NGOs and labor groups challenging the “safe levels” are in a bind if they rely on technical and public health data, right? Such a data collection project won’t protect workers in real time–it can only help in litigation later.

    Are there other sorts of claims to be made for protection of workers in the midst of disasters? Are there any traditions in law or regulatory practice that govern the treatment of workers caught up in normal accidents? It’s another way of coming at a problem that runs through many of these papers: when disasters are defined as unpredictable, unknowable, special, and temporary, then the purveyors of risk are freed of their normal obligations. That sort of freedom is very politically valuable, and also very dangerous in risk society.

    You are right to push these questions back onto STS. These questions have been raised again with the post-Iraq/Afghanistan PTSD epidemic among US military personnel–it was raised in the months following the clean-up of the World Trade Center debris where emergency workers were not monitored and many worked without breathing protection.

  3. A small question: Does the chart on p. 10, and the source from which it comes, purport to be complete? I’m a bit puzzled that Tokaimura is omitted, if that is the case. Or is there some focus of the data that would leave incidents like Tokaimura out?

  4. Phil, thank you for alerting me: see numbers 10, 11, 12 in my table. A stupid mistake, Tôkaimura became Tokkaimura!

  5. We are discussing two sides of the same coin with this low-dose debate, so your paper offers some wonderful food for thought. I find very interesting how you have highlighted the need to understand the longue durée of the radiation protection controversy following Three-Mile Island and Chernobyl, while shortening the genealogy of such models that otherwise comes after Hiroshima-Nagasaki studies. Building on an earlier post, how can this shift occur, but without entirely dismissing a discussion of why and how the common gaze does often reach back to 1945. Perhaps by helping us around the line, “WHO/IARC has produced conclusions that could challenge that model, but . . .” to learn about any scholarly works that have documented the model’s persistence, whether in the public imaginary, scientific practices, or intergovernmental agencies, this could be addressed. Your question about animal models and standards for human health also struck a huge chord with me, for it underscores the need for more historical, anthropological, and sociological studies on the topic of radiation health in Japan. The mention of “sentinel,” brought back memories of a productive STS brainstorming session in Los Angeles on this topic. Cued by my work on the creaturely, I had wondered what is the distinction between the biological indicator used in ecological sciences, and recent interest in sentinels à la STS as identifiers of certain work. Bringing NPP workers in alignment with “sentinel” requires some discussion, which I look forward to very much.

  6. Charlotte permalink

    Thank you for this very well crafted and engaging paper. I am really interested by the possible connections between STS concepts and sociology of critique. Your work shows well the worth and ‘grandeurs’ at stake in the recognition of the low dose radiations. I was wondering if you would, like latour in is hybridized 7th “Polity” (Latour, 1995), think the many reticular connections of risk and disasters are soluble in the market, domestic industrial or the civic “world”. I personally found Latour description of the “cite de la prudence” very promising to elaborate what could be the economy of worth in the “world of risks”. In addition, recent work form Beck (Beck, 2009) has made tremendous advance around integration of the Latourian perspective (but not only) in the initial framework of its risk society.
    Beck, U. (2009). World at risk. New York (Vol. The Report, p. 270). Polity Publisher.
    Latour, B. (1995). Moderniser ou écologiser. A la recherche de la Septième Cité. Ecologie politique, 13, 5–27.

  7. Yasuhito Abe permalink

    Hi Paul, Thank you very much for sharing the informative work, from which I truly learnt a lot. Like Kath, I am also glad that you pay attention to the labor/class issues. As you indicated, it would be useful to discuss data released by Japanese government and TEPCO in relation to the complex nature of NP workers. Given the fundamentally complex nature of NP workers, I would like to know more about the role of gaikokujin rodosha or “foreign labors” (non-Japanese speakers in particular) in your story. Again, thank you for your work!

  8. Thank you every one for your precious remarks. I will try to give some oral answers. Let me first finish my reading of all the papers!

  9. Dear Professor Jobin: your work highlights the importance of contextualizing our case studies in respect to forms of neoliberal governance – asking how does it affect/shape nuclear and public health policies and governmental responses in face of crises. Professor Scott’s review paper (sent by email) points to a tension that cross-cuts different national contexts in respect to de-regulation versus regulation of nuclear industries (having unpredictable and tragic outcomes). As you showed in your paper, another type of de-regulation (of labour contracts) allows for exposition of nuclear industry (temporary) workers to harmful health conditions. Your account of the criminal activities of covering-up the registry of accumulated dosage for temporary workers is simply striking and overwhelming sad. I wonder how many of those invisible cases continue to be so, despite wide access to information technologies (and technical possibilities for leaking governmental and corporate information without revealing the identity of the person who leaked).

    More importantly and beyond the rigorous treatment of your (rich) empirical data, I read your paper as a call for ethical responsibility of our position as STS researchers in making those invisible and tragic stories widely known and debated. Your work sets a guiding example by connecting, at the same time, the sociology of labor and the study of critical judgement of the actors themselves (via Boltanski and Thevenot). By the way of your narrative, we transferred to the arena of the dispute among experts and non-experts and reach a better understanding of (a chapter in) the history of a the controversy over health risk of low-dose exposition to radiation.

  10. Jen Schneider permalink

    I wish I could add something substantive to the already excellent comments, especially Luis’s, above. I guess I would only echo that I see a significant relationship between neoliberal movements to deregulate industries such as nuclear and a technocratic approach to measurement and data management. Data and measurement is often used, particularly in energy industries, to support hegemonic systems of power (power both in the sense of control and of electricity/transportation production). Epidemiology as a field is ill-equipped and underfunded when faced with this system, and the tools may not be apt in any case. So I think the question of how to organize labor–which has also been dismantled by neoliberal policies–is perhaps an area that is rich for further inquiry.

  11. Karena Kalmbach permalink

    Thank you for this very important paper! There is especially one aspect that I would love to learn more about (particularly in relation to my own field of research: Western European debates about health effects of Chernobyl): To what degree is the Japanese way of challenging the current standards and models in radioprotection linked to European networks such as ‘IndependentWHO’? For example, you mention Busby in one of your footnotes: I am familiar with the way his activities and statements on Fukushima have been perceived in Britain, so I am very interested to hear more about how these kind of activities by European anti-nuclear activists have been perceived in Japan, and if European groups, such as ‘IndependentWHO’, have been successful in developing a network with Japanese activists. Thank you!

  12. Nicolas Sternsdorff permalink

    Paul — this is a fascinating essay, and you have interviews with some really interesting figures who were in positions to handle the Fukushima fallout.

    The first part of your essay with the logic of sacrificing for the sake of the nation reminds me of some dynamics I found in my own research about food safety. The ministry of agriculture had a campaign to support tohoku farmers (tohoku tabete oen shiyo), and some of the people I worked with saw this as a perverse attempt to get the nation as a whole to suffer together. Satsuki Takahashi has presented in conferences about this, connecting Petryna’s concept of biological citizenship to what it means to be a citizen when your state asks you to eat potentially radiated food.

    I think there’s a connection between your paper and Scott Knowle’s. In his seven areas of inquiry, one of them touches on the deregulation of the energy sector. I think your paper could be in dialogue with his framework to think about the implications of this deregulation. What you show is not so much deregulation as government/private sector incompetence/negligence, or a lack of resources to adequately monitor the ongoing situation.

    From your paper, it sounds to me that you’re suspicious of the ability of the nuclear industry to regulate itself. On the other hand, it doesn’t sound that the government is doing much better either (and some people working on Fukushima and the nuclear village talk of regulatory capture). I wonder what kind of alternatives were envisioned by your interviewees, or your own take on this situation.

    A final question — from your comparative work, is Japan a unique case for the role the mafia plays in supplying labor, or does this also happen in other places you’ve done work in?

  13. Bill Kinsella permalink

    Wow. Paul, this is a compelling essay that links so many important themes together effectively and concisely. The ethical issues stand out most starkly for me–but beyond making them clearly evident, you’ve dug into their institutional and political foundations. Institutional power, epistemic uncertainty inherent in the technocratic policy model, and the opportunities for ethical neglect opened up by a “state of emergency” are all entangled here. It’s easy for me to see that, now that you’ve laid it all out so clearly. Thanks for this “dose of reality,” to play again with the phrase you used.

    Having looked at the case of the Hanford downwinder community in the US, I agree that a reliance on epidemiology is deeply problematic. In that case, that approach led to an institutional denial of the lived experience of an affected community, which engendered deep distrust of government and science (and the apparent collusion of the two), followed by a protracted lawsuit that hasn’t resolved the issues at stake.

    So much to talk about, and the comments on your essay have set us up for that nicely.

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