«The World Health Organisation (WHO) is failing in its duty to protect those populations who are victims of radioactive contamination.»

13 - March - 2013

On 11th March 2013, on the occasion of the second anniversary of the beginning of the Fukushima health disaster, the members of IndependentWHO have sent to WHO the Proceedings of the Forum which we organised in Geneva in May 2012. A letter addressed to Dr Chan, Director of WHO has also been sent, requesting that she meet with representatives of citizen organisations to discuss the violations of the Right to Health associated with the nuclear disaster at Fukushima in Japan. In Dr Chan’s absence, it was Dr Maria Neira, Director of the Public Health and Environment Department who greeted the IndependentWHO delegation at the entrance to the building.

Members of IndependentWHO hand over the proceedings of the Forum as well as a letter to Dr Maria Neira, representant of Mrs Chan, director of WHO


Dr Margaret Chan
World Health Organization
Avenue Appia
1211 Geneva 27

11 March 2013

Subjects: Urgent request for a meeting with representatives of citizen associations to discuss violations of the Right to Health in relation to the nuclear disaster in Fukushima, Japan


Dear Dr Chan,


During our meeting on 4 May 2011, you requested that IndependentWHO(1) provide you with relevant and appropriate “alternative” information from our networks on the subject of radiation and health, in recognition of the fact that the World Health Organization seeks information from as many reliable sources as possible. You pointed out that we had better access than you to alternative networks, including citizen associations.

With this letter, we provide internet links to a small selection of reports of violations of the Right to Health emanating from citizen associations (Annex 1) and to issues and criticism (Annex 2) mentioned in the Press Statement (2) of the Special Rapporteur on the Right to Health, Mr Anand Grover, on the occasion of his visit to Japan in November 2012. This

The material we provide here indicates a significant discrepancy between reports emanating from the Japanese government and TEPCO (3), and reports emanating from citizens’ associations. Mr Grover’s statement reinforces reports and complaints from civil society and provides strong indications of failure, negligence and deliberate misinformation on the part of the Japanese government in relation to radioprotection of the population.

Demonstrators in front of WHO the 11th of March 2013 at the time of handing over of the Proceedings of the Forum to WHO

In order to fulfill its obligations in relation to the Fukushima disaster, the WHO will want to take into account information from all sources in order to assess the health consequences now and in the future, plan its response and assist populations in need.

With regard to the health consequences we note with dismay that WHO’s Health Risk Assessment4 (just published) is based on WHO’s Preliminary Dose Estimation5, which was written by experts all of whom have connections with the nuclear establishment, mostly the IAEA. The latter document has been extensively criticized6 not least for conflict of interest and lack of independence.

Citizens in Japan and elsewhere have lost confidence in national and international nuclear authorities. It is our deepest conviction that, on the issue of radiation and health today, the WHO must assert its independence, assume its responsibilities as the international health authority and work with citizen associations and independent medical and scientific institutes and researchers.

We request that a meeting be organized with you as soon as possible and prior to the World Health Assembly in May 2013, with representatives of citizen associations7, concerned politicians and Mr Anand Grover or his assistant.

Yours sincerely,

Eric Peytremann

For IndependentWHO – health and nuclear power

(1) Collectif Santé et Nucléaire – pour l’Indépendance de l’OMS


(3) Tokyo Electric Power Company

(4) HealthRisk Assessment from the Nuclear Accident following the 2011 Great East Japan Earthquake and Tsunami

(5) Preliminary Dose Estimation from the Nuclear Accident following the 2011 Great East Japan Earthquake and Tsunami. May 2012.

(6) Rosen, Alex. Analysis of WHO Report on Fukushima catastrophe. 3 August 2012.

(7) Delegation to be determined but including if possible representatives from: CRMS, Japan (Citizen Radiation Monitoring Station); CRIIRAD, France (Commission de Recherche et d’Information Indépendante sur la Radiation ; IPPNW, Greenpeace; IndependentWHO – Collectif Santé et Nucléaire.

Copies :

  • Anand Grover, UN Special Rapporteur on the Right to Health
  • Rémy Pagani, Mayor of Geneva
  • Katsutaka Idogawa, the former mayor of Futaba Town in Fukushima
  • Commission de Recherche et d’Information Indépendante sur la Radioactivité (CRIIRAD) France
  • International Physicians for the Prevention of Nuclear War (IPPNW)
  • Greenpeace (International)
  • IndependentWHO Collective on Health and Nuclear Power
  • The Fukushima Network for Saving Children from Radiation
  • Citizens against Fukushima Ageing Nuclear Power Plants (Fukuro-no-Kai)
  • Green Action
  • Human Rights Now
  • Human Rights Watch
  • Osaka Citizens against the Mihama, Oi and Takahama Nuclear Power Plants (Mihama-no-Kai)
  • Greenpeace Japan
  • Citizen’s Radioactivity Measuring Station (CRMS),
  • University of Tokyo Nuclear Disaster Support Forum,
  • Fukushima University Forum on Nuclear Disaster,
  • Association for Citizens and Scientists Concerned about Internal Radiation Exposures (ACSIR),
  • The Committee for Citizen Scientist Network for Radiation Protection(CSRP)
  • Pediatricians’ Network for Saving Children from Radiation,
  • 3.11 life-note Project for Saving Children-future from Low-dose exposure
  • Fukushima Health Consultation Meeting,
  • Parents’ Network Protecting Lives of High School Children,
  • Workers’ Executive Committee For Anti-nuclear Power Movements, Inter-Faith
  • Forum for Review of National Nuclear Policy, Peace and Environmental Advocacy for the Child
  • Zensekiyu Showa Shell Labor Union
  • Midori Fukushima
  • The Fukushima Collective Evacuation Trial Team
  • World Network for Saving Children from Radiation
  • Niji to midori no kai
  • Fukushima Women’s Association for the Protection of Children

Attachments: two annexes as mentioned :

Annex 1

Selection of Reports from citizen associations on human rights violations

Human Rights Now (HRN) submitted the following statement to the Human Rights Council, 22nd Regular Session, 25 February to 22 March 2013:

NGOs Call for Immediate Action to Protect the Right to Health and Life of Women and Children Affected by the Nuclear Accident in Fukushima, Japan


Human Rights Watch published the following article on 9 March 2012.

Japan: a year after Fukushima, response falls short
Disclose detailed information about health, food safety


The Fukushima Network for Saving Children from Radiation submitted an appeal to the UN Office of the High Commissioner for Human Rights, 17 August 2011

Violation of the Human Rights of the Children of Fukushima

Annex 2

Issues and criticisms (8) mentioned in Mr Anand Grover’s statement

Tokyo, 26 November 2012

  • Local residents were not aware of nuclear disaster management plans. Mr Grover makes this specific mention “local residents of Futaba city in Fukushima were led to believe by the Safety Agreement signed in 1991 that the TEPCO plant was safe and there would be no occasion for a nuclear accident.”
  • The NRA, Japan’s new nuclear regulatory agency should adopt a policy to disclose any conflicts of interest of members or potential members.
  • The government neither gave instructions nor distributed stable iodine to the affected population. Nonetheless, some municipalities distributed stable iodine tablets in an ad-hoc manner.
  • The government did not make public the data from SPEEDI and that it is crucial that the government provide this information so people may safely evacuate.
  • The government used a radiation dose of 20 mSv/year to determine evacuation areas, the level is too high.
  • The government’s released a number of publications, including school booklets, informing the public that there was no clear evidence of direct risk of cancer if a person was exposed to radiation dose up to 100 mSv/year. This is not supported by medical research.
  • The 20 mSv/year threshold actually violates Japan’s 1972 law on exposures to nuclear workers and the public. The law dictates 2 mSv/year maximum for pregnant women.
  • The mandatory evacuation level at Chernobyl was 5 mSv/year, Japan is not following this historical safety level.
  • That cancer and other diseases could occur in low dose radiation below 100 mSv/year. According to studies, there is no low threshold limit for the occurrence of diseases.
  • That government radiation monitoring stations are inaccurate and show artificially low. Validated independent radiation readings including those taken by the public should be included and made public.
  • The government should monitor the impact of radiation on people’s health in radiation-affected zones through holistic and comprehensive screening and provide appropriate treatment. The special investigator does not specifically state that the Fukushima Health Survey should be the one to do it.
  • Health checks should be expanded to all areas that were affected by radiation.
  • The current health survey is too narrow and relies on a narrow set of Chernobyl data and ignores a large body of evidence that shows cancer as well as other diseases happen in low-dosage radiation situations, even in areas of exposure below 100 mSv/year.
  • The government should conduct a study that would entail examining and monitoring of internal radiation exposure for a considerable length of time.
  • Children who have thyroid abnormalities are being denied access to second opinions and access to their medical records.
  • The government needs to provide health monitoring to all nuclear workers, the current system and subcontractor system is failing to do this
  • Evacuation centers failed to provide for the needs of the disabled and women with small children
  • The government needs to better enforce food safety standards in relation to radiation contamination of food.
  • The investigator applauded efforts to decontaminate soil but condemned the various government efforts to make residents do decontamination work and also in not providing them with proper safety equipment or information about the harmful effects of radiation exposure.
  • The investigator encourage the Government to continue and/or restore financial support and subsidies to all evacuees so that they can make a voluntary decision to evacuate or return to their homes, if they wish to do so.
  • The human rights framework calls for accountability for those who created the situation. The investigator specifically stated that TEPCO should be held accountable and that the public should not end up shouldering the liability.
  • The people impacted by the disaster currently do not have a say in what is being decided and what happens to them. The investigator stated this must change.


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