Summary report and analysis of responses from Scottish councils to Scottish CND letter in May 2022.
In May 2022 Scottish CND wrote to the 15 local councils in Scotland through which nuclear weapon convoys regularly pass, asking them to consider their responsibility to inform their public about the risks from the convoys and appropriate emergency measures.
We are aware that Police Scotland have a central role in the response to any serious incident but it will be obvious that local authorities would also be critically engaged. As of 30th June 2022 Scottish CND had received 9 replies (including a holding reply).
Almost all of the responses indicate a misunderstanding of the status of the convoy safety issue within the Scotland Act. Scottish Campaign for Nuclear Disarmament is of course fully aware that defence is a reserved matter, but under the Civil Contingencies Act (2004) community safety is devolved – a fact recognised by the Ministry of Defence when it acknowledges the role of the civil authorities in providing the “off-site” response in the case of an emergency.
This misunderstanding also muddies the question of risk assessment. Risk assessment must also apply to “off-site” impacts. It may be that such assessment has been conducted by “Category One Responders” working in partnership but there is no public information as to whether such assessment has been carried out or what its results may be.
Given that information gap and the statement in a number of the responses that risk assessment is solely a matter for the MoD an assumption that no assessment work has been carried our by individual First Responders or resilience partnerships does not seem unreasonable.
Most of the responses imply a further troubling misunderstanding about risk assessment – that the calculation should be based solely on the likelihood of an incident. For a proper risk assessment a calculation of potential impact must also be included. In the professional context this is called the “likelihood X severity” model.
Most of the responses make no reference whatever to the core request in our letter – that the council should reconsider its decision not to inform its public of the threat of an accident involving a nuclear weapon convoy. This omission is especially marked in the response from Argyll and Bute since that council is obliged by regulation to inform its public of the radiological hazards from the Faslane naval base and does so by means of a leaflet –
yet it makes no effort to make the public aware of the radiological hazards arising from the convoy traffic.
The Argyll and Bute situation has an additional twist. The radiological hazard arising from Faslane would involve gamma radiation which might require evacuation as well as iodine treatment. In the case of the convoys the risk would be from alpha radiation which would require sheltering rather than evacuation. The scope for confusion is clear.
Two councils, City of Edinburgh and Dumfries and Galloway, did address the public information question. Edinburgh’s response mentions the need to avoid alarming the public unnecessarily but offers no rebuttal of our claim that that public panic is more likely if there has not been adequate “pre-event” information and guidance, and that, in the case of a distribution of toxic radiological materials, poor public preparation could lead to problematic public responses such as inappropriate “self-evacuation”.
In defending its decision not to offer information to the public, Dumfries and Galloway cites the Scottish Government Preparedness Review “Road transportation of Defence Nuclear Material in Scotland” and accepts the conclusion of that review, namely that “the decision on what information to provide on convoy movements was a matter best determined by the MoD.”
It is wholly inappropriate for a civil authority to abandon to a UK department its responsibility for public information and genuine compliance with the requirements of the Civil Contingency Act. It is also telling that no respondent was able to provide a rationale or a defence of the inconsistency between the REPPIR requirement to have public emergency information for fixed sites and the absence of parallel and specific regulation for military radiological hazards while in transport.
“We are glad to see that the review exercise has been very broad in its scope, has prompted a good deal of agency awareness of the problem, has already led to the tightening of some procedures and prompted helpful recommendations. We cannot help but note that such a review would not have happened without persistent pressure over the years from Nukewatch and the support of individual parliamentarians.
There are however a number of critical flaws in the review. The agencies concerned have been all too ready to accept without due diligence statements from the UK Ministry of Defence, without engaging with other recognised expertise, as we had recommended. This is especially true on the question of risk assessment. The MoD’s single factor risk assessment – that the likelihood of an incident is remote is accepted without any mention of the second factor in any standard risk assessment, the potential severity of consequence. The review also fails to register adequately the unique hazards posed by the transport, and relies too heavily on generic emergency responses.
There is also no mention of the increase in public concern about the convoys. For those living near Faslane/Coulport there is the Clyde Emergency plan which at least gives basic information to the public about how to act in case of an incident. Also, fixed nuclear sites are governed by the REPPIR regulations. Astonishingly, the review does not deal with the fact that no such such framework exists for the convoys. Members of the public who are aware of the convoys need practical information about what to do in the case of an actual accident to keep them and their families safe. This review does not give this information or indicate where it might be found or accessed.
It is most disappointing that Ash Denham, the current Minister, has endorsed the review in her introduction and given the false impression that all is well. The Scottish Government has a prime responsibility for the safety of citizens and must recognise that this case is far from closed.”
Scottish CND wholeheartedly endorses that critique.
Overall the responses to our enquiry have been very disappointing. Most of the replies suggest that there has been only a superficial reading of our letter. The replies also indicate a general misunderstanding around reserved and devolved matters as they relate to nuclear weapon convoy emergencies and they display a limited understanding of what is involved in risk assessment.
For those respondents who address the issue of public information there is no effort to engage with or to rebut our case, simply a passive and unexamined acceptance that this duty lies mainly with the MoD.
When an activity is undertaken with an attendant and recognised risk for the sake of a perceived benefit, the risk involved is said to be “tolerated”.
At a time when the humanitarian consequences of nuclear weapons are being recognised increasingly at international level – a recognition that has inspired the UN Treaty on the Prohibition of Nuclear Weapons – our earnest wish is that Scottish civil authorities would show some smeddum in responding to the threat from nuclear weapon convoys and declare the manifest risks to be intolerable.
David Mackenzie, Scottish CND