Petition for the permanent cessation of Full-Body Scanning at UK airports.

We the undersigned hereby petition the government to stop Full-Body Scanning procedures at all
UK airports with immediate effect on grounds of human rights, effectiveness and safety as detailed
below.

Following the failed attempt of a terrorist attack on a flight from Schiphol, Amsterdam to Detroit on
the 25th of December 2009, the then government under Prime Minister Gordon Brown announced
plans to implement a compulsory full-body screening process of air passengers travelling from
selected UK airports. The process which involves scanning passengers with Advanced Imaging
Technology (AIT), also known as Full-Body Scanners (FBS), provides airport security screeners
with a vivid two-tone image of the passenger's naked body as well as certain objects, depending on
their physical density, concealed below the passenger's clothes. The compulsory scanning process
came into effect on the 1st of February, 2010 at Manchester and Heathrow airports, and plans exist
to extend the scheme to all UK airports. (1)

We the undersigned believe that passengers are being unjustifiably coerced into the process with the
threat of being refused the right to fly and therefore losing their investment in that flight (1).

Human Rights concerns

The FBS process reveals the image of the person being scanned as if naked, and therefore Article 8
of the Human Rights Act 1998, which includes the right to privacy, is being infringed. It is a
qualified right and therefore its revocation or limitation is permitted when there is a significant risk
to public safety or a threat to national security.(2) However, the government has not sufficiently
revealed the extent of this threat in order to justify revocation or limitation of Article 8 in airport
FBS processes.

It is also clear that it violates Article 12 of the Universal Declaration of Human Rights (UDHR), the
right to privacy. (3)

Considering the fact that there were somewhere in the region of 2.5(4) billion commercial air
passengers worldwide in 2009 and only one incident with a potential suicide bomber, we the
undersigned believe that the government's response of implementing a compulsory body-scanning
process has been entirely disproportionate. By reacting in this manner and treating all air passengers
as potential criminals we also believe that this process is damaging to British society as a whole by
creating an air or fear and mistrust amongst the general public.

The Council on Foreign Relations, in an report titled 'Hardly Existential – Thinking Rationally
About Terrorism'(5), which analysed the risk posed by terrorist attacks in non-war zones,
demonstrated that the risk from being directly affected by Transnational Terrorism in a non-war
zone is far less than that of being struck by lightning. This assessment of non-war zones also
included areas far more prone to terrorist acts than the UK, such as Israel.

Martin Scheinin, the UN special rapporteur on the protection of human rights, said while countering
extremism scanners were both an ineffective means of prevention and an excessive intrusion into
individual privacy.
"The use of a full-body scanner which reveals graphic details of the human body, including
the most private parts of it, very easily is a violation of human rights. It would be a violation
of human rights in respect to everyone, but there are particular sensitivities in respect of
 women, certain religions, certain cultural backgrounds."(6)

Furthermore, inadequacies in security staff training and vetting, as highlighted in the recent case of
a Heathrow airport security officer who it is claimed “ogled” a fellow security officer after scanning
her body without her consent(7), could give rise to a situation where air passengers are humiliated or
degraded by inadequately trained or vetted screening staff, and therefore lead to a breach of Article
3 of the Human Rights Act(8), which should protect citizens from such degrading treatment.
According to the Interim guidelines on FBS use published by the DfT earlier this year, all
responsibility for training and vetting of security screening staff has been passed on to the
individual airport operators and is not directly controlled by the government. It is not at all clear to
what extent the government has monitored UK airport operators, if at all, on their appropriate use of
FBS equipment, especially in the light of the Heathrow incident.

By failing to provide the public with adequate evidence of the greatness of the immediate threat to
public safety by so-called suicide bombers, we believe the government is in breach of another
qualified right, Article 9 of the Human Rights Act, the Right to Freedom of Belief(9).

The dilemma faced between being scanned and therefore having an unknown person viewing an
image of one's naked body, forces the followers of many religions to have to choose between the
teachings of their religion and using air travel. Islam, for example, strictly forbids exposing one's
naked body in this manner. In February of this year The Fiqh Council of North America backed by
The Council on American-Islamic Relations issued a religious ruling that says going through the
airport scanners would violate Islamic rules on modesty. They state:

"It is a violation of clear Islamic teachings that men or women be seen naked by other men
and women. Islam highly emphasises haya (modesty) and considers it part of faith. The
Quran has commanded the believers, both men and women, to cover their private parts.” (10)

Massoud Shadjareh, chairman of the Islamic Human Rights Commission in London, stated that
FBS scanning at airports was “totally unacceptable and outrageous. And worse, it really doesn’t
make any security sense.” (11)

In February of this year two British women refused to be scanned at Heathrow airport citing
religious grounds for their objection. As a result they were refused the right to board their flight. (12)

On the 20th of February, 2010, Pope Benedict XVI voiced his objection to FBS searches on the
grounds that they fail to preserve the integrity of individuals. (13)

Agudath Israel, an Orthodox Jewish umbrella group, has called FBS searches “offensive,
demeaning, and far short of acceptable norms of modesty” within Judaism and other faiths. (14)

David Rosenn, Executive Director of Avodah, a Jewish Service programme stated

“It creates a tension between the Jewish value of protecting lives, which is very strong, and
the Jewish value of modesty for women and for men”(15)

The government has stated that children will not be exempt from the compulsory scanning process.
The Equalities and Human Rights Commission (ECHR) wrote to the former Home Secretary, Alan
Johnson earlier this year, warning him that FBS are likely to have a negative impact on privacy,
especially for disabled people, elderly people, children and transgender people. (16)

Terri Dowty, of Action for Rights of Children, has said that the scanners could breach the Protection
of Children Act 1978, under which it is illegal to create an indecent image or a "pseudo-image" of a
child.(17) Therefore if a complaint is made by a parent or guardian of a child who has been scanned,
the government could face the charge of having committed a criminal offence in obliging children
to pass through the scanning process and subsequently producing an indecent and naked image of
that child. (18)

According to the interim code of practice set out by the DfT(19) on the correct use of FBS at airports,
all responsibility for the correct handling and monitoring of delicate information and imaging has
been put entirely into the hands of airport operators. There exists no clear information on how the
government intends to ensure that private airport operators uphold the rules set out in the interim
guidelines.

In recent months doubts over what exactly adequate training and vetting would involve and of if it
could in fact be achieved, were once again brought into question in the US with clear cases of
breaches in the UDHR. In March, a Transport Security Agency (TSA) employee was reported to
have been mocked after a fellow worker had viewed an image of his naked body through a scanner
they were using at that airport(20). In February of this year US journalist Sandra Fish had to suffer a
strip search following a body scan because the TSA agent that viewed her naked image could not
distinguish between a breast prosthesis and an explosive(21). The same journalist tells of an
acquaintance who suffered similar humiliation at the hands of the TSA due to his colostomy bag
being mistaken for a possible weapon.

Recently, the Backscatter scanner manufacturer Rapiscan Systems has announced plans to add a
software to their product that detects objects concealed below the subject's clothing.(22) They claim
that if airport security screeners use this software, they will only have to examine images produced
by the scanners when the software alerts them to the presence of objects below clothing. This, we
believe, is a token gesture which is likely to further marginalise those passengers who use aesthetic
complements such as breast prosthesis and medical equipment such as colostomy bags.

Effectiveness
It has been claimed, most notably by Conservative MP Ben Wallace who worked for the AIT
technology manufacturer QinetiQ, that the scanners are unlikely to detect certain classes of
explosives currently favoured by terrorists(23), such as PETN, which was used on the 25th of
December on the flight from Schiphol to Detroit and in 2001 by Richard Reid, also known as the
Shoe-Bomber.

Colin McSeveny, a spokesman for Smiths Detection of Watford which makes millimetre-wave body
scanners said that “Politicians like Gordon Brown want to get a move on, but these technologies are
still in trials. They are not ready yet.” He went on to say
“They have not yet been certified by the Transportation Security Administration (TSA) in the
US or the European Union, for example. We're not going to make 500 of these £100,000
machines until they are certified.”(24)

The current director of Interpol claimed earlier this year that the technology was “flawed”.
Speaking at the World Economic Forum in Davos, Interpol Secretary-General Ronald K. Noble
argued that better intelligence and information sharing between countries was required, rather than
wide-scale body scanning technology.(25)

The US and Canadian Association of Airline Pilots (ALPA) have described the use of FBS at airport
security points as an “inadequate response” which leaves current airport security procedures little
more than a “patchwork of band-aids”.(26)

We the undersigned also believe that the concept of using AIT machines as a means of protecting
the public from potential terrorist acts, specifically so-called suicide bombings, is not only
fundamentally flawed but also contradictory. The addition of a body scanning process in itself
causes further delays and the possibility of an accumulation of large quantities of air passengers at
airport security checkpoints. This in itself could create a significant target for terrorists.
Furthermore, it appears that there is inadequate methodology or training of security staff in dealing
with the possible discovery of a person with explosive materials concealed within their clothing. In
the highly unlikely event of discovering such a person, we believe that there may be a danger of
said person detonating their explosive during the scanning process and harming the public and
airport workers in the vicinity. In the case of the Backscatter type AIT machines currently in use at
Heathrow and Manchester airports, an explosion adjacent to the device during the scanning process
would have the potential of significantly damaging that machine and releasing radioactive material
contained inside out into the environment.

Health and safety concerns: Backscatter type scanners (Rapiscan Secure 1000)
The Backscatter type AIT machines use ionising radiation to produce a two-dimensional image of
the person being scanned as if viewed naked.

The previous government implemented the above mentioned FBS plan claiming that the
Backscatter type scanners posed no risk to public health due to the fact that they only emit a low
dose of radiation. The Health Protection Agency (HPA) published a risk assessment report on the
use of the Rapiscan Secure 1000 Backscatter type AIT machine(27). In their report the HPA
recommend a maximum radiation dose constraint of 300 mSv per year and claim that the maximum
yearly dose received by frequent flyers was unlikely to exceed 20 mSv per year.

Firstly, there is no clear definition of what may constitute frequent exposure and no monitoring
controls have been put in place to measure exposure among frequent air passengers.
Also, it appears that no safeguards have been put in place to ensure that a passenger who is scanned
at a UK airport and who then proceeds to be re-scanned at airports outside of the EU on other stages
of his/her journey, does not receive a dangerous amount of scans.

Despite the HPA's report there is some disagreement within the scientific community on what
exactly would be a safe and acceptable dose of radiation, and we the undersigned believe that
further independent research must be carried out before any use of the Backscatter type machines in
UK airports continues.

Furthermore, in the HPA's report no mention is made of security screening staff who need to work
alongside the AIT machines on a daily basis. No risk assessment whatsoever has been undertaken to
evaluate the potential risk of cancer due to radiation exposure in said security staff (28), and there
exists no physical protection or barrier (e.g. lead barrier or personal radiation dosimeters) to
monitor and protect airport security screeners from radiation emitted by the backscatter type AIT
machines.

If each scan emits one-fifth of the “allowable dose”, as is the manufacturer's claim(29), and security
staff are overseeing potentially hundreds of scans per day, the question arises of how much of a
daily dose of backscatter radiation airport security staff and other airport staff are effectively
receiving due to working in the vicinity of the scanners.
The findings of a comprehensive, 700-page advisory report to the U.S. government, titled
"Biological Effects of Ionizing Radiation (BEIR) VII," by a National Research Council (US)
committee conclude that even very low doses of radiation can produce cellular injury. The
committee defined "low-dose" as a range from near zero up to about 100 mSv per year. According
to one of the committee's members, Stanford University's Herbert L. Abrams, a radiologist and
member of the Institute of Medicine of the National Academy of Sciences
“There appears to be no threshold below which exposure can be viewed as harmless.”(30)

Dana Drabova, Chairwoman of The Czech Nuclear Safety Authority (SUJB), has said
“Although it is true that the radiation dose emitted by body scanners is small, the current
experience says there is no safe radiation dose. There is a possibility that every dose of
radiation, even low, can provoke cancer.”(31)

In a recent letter of concern written to the Assistant to the President on Science and Technology
(US), a group of eminent professors in biochemistry and biophysics from the University of
California tried to alert President Obama to the greater risks of using backscatter technology in
screening passengers, claiming that the Rapiscan Secure 1000's safety record had not yet been
“sufficiently demonstrated”. In the letter they also highlight their belief that the comparison
popularly made between the effects of cosmic radiation on air passengers and the backscatter type
radiation to be wrong. They explain how, unlike cosmic (gamma) radiation which passes directly
through the human body, the backscatter type only penetrates the skin. This, they say, is

“largely depositing energy into the skin and immediately adjacent tissue, and since this is
such a small fraction of body weight/volume, possibly by one to two orders of magnitude,
the real dose to the skin is now high.”(32)

and therefore conclude that while the actual amount of radiation measured in Sierverts that passes
through the body during a flight may be higher than that received during a backscatter scan, the risk
to health through being scanned is much more considerable due to the nature of the radiation in
question.

Health and safety concerns: Millimetre Wave type scanners

The Millimetre Wave type scanners produced by companies such as Smiths Detection Ltd. or L3
Communications, and currently said to be on-site at Gatwick and Luton airports although not yet in
use, utilise a radio frequency band at the lower end of the Terahertz radiation (or 'T-ray') range to
produce a similarly explicit image of the subject's naked body in 3 dimensions.
The government has stated that they
“do not have a comparable (risk) assessment for Millimetre Wave Scanners because they do
not use ionising radiation. There are no known health implications from Millimetre wave
equipment.” (33)
However, Boian Alexandrov of the Center for Nonlinear Studies argues that there have been mixed
results from tests of the effect of Terahertz fields on human tissue.
“Some studies reported significant genetic damage while others, although similar, showed
none”(34)

In his studies, Alexanadrov demonstrates how THz fields interact with double-stranded DNA and
how they may allow THz waves to “unzip” double-stranded DNA, creating bubbles in the double
strand that could significantly interfere with processes such as gene expression and DNA
replication.

Until more conclusive studies have been carried out to establish the real health risks posed by both
Backscatter and Millimetre Wave technology, we the undersigned believe that it cannot be claimed
that the risk to health is either “negligible”(35) or that the FBS process is in any way safe.

Summary
We the undersigned hereby petition to government to stop all Full Body Scanning of passengers at
UK airports on the grounds that it
• unjustifiably breaches the rights of citizens from or travelling from the UK
• the technology is too ineffective and therefore does not justify the the rescission of the
aforementioned rights
• the true health effects are yet to be determined

Former US President George Bush once claimed that terrorists wanted to attack us because they
hated our way of life. If this is a view shared by this government, then by rescinding rights that we
have we have struggled for generations to establish, we are effectively surrendering our way of life
to those terrorists in the face of a comparatively small threat. The surrendering of rights in this way
is contrary to the national spirit of resilience on which we as British citizens have prided ourselves
through two world wars and previous, more persistent, terrorist campaigns.

Yours sincerely.

1. Transport Parliamentary Under-Secretary, Paul Clark, made a written ministerial statement

about the introduction of body-scanners at UK airports.
http://www.publications.parliament.uk/pa/cm200910/cmhansrd/cm100201/wmstext/100201
m0001.htm#1002014000009

2. Article 8 of the Human Rights At 1998: Article 8 Right to respect for private and family life
1 Everyone has the right to respect for his private and family life, his home and his
correspondence.
2 There shall be no interference by a public authority with the exercise of this right except
such as is in accordance with the law and is necessary in a democratic society in the
interests of national security, public safety or the economic well-being of the country, for the
prevention of disorder or crime, for the protection of health or morals, or for the protection
of the rights and freedoms of others.
http://www.opsi.gov.uk/acts/acts1998/ukpga_19980042_en_3

3. Article 12: No one shall be subjected to arbitrary interference with his privacy, family, home
or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to
 the protection of the law against such interference or attacks.
http://www.un.org/en/documents/udhr/index.shtml#a12

4. ICAO figures: http://www.icao.int/icaonet/dcs/9916/9916_en.pdf

5. Council on Foreign relations, “Thinking rationally about Terrorism.”

http://www.foreignaffairs.com/articles/66186/john-mueller-and-mark-g-stewart/hardly-
existential
6. Martin Scheinin, UN Special Rapporteur on Full-Body Scanners
http://www2.ohchr.org/english/issues/terrorism/rapporteur/srchr.htm

7. “Heathrow worker ogled colleague on scanner”, By Rosamond Hutt, PA, The Independent,
24 March 2010
http://uk.wrs.yahoo.com/_ylt=A0oG75F1EfhLxWcA5ahLBQx.;_ylu=X3oDMTByMTNuN
TZzBHNlYwNzcgRwb3MDMgRjb2xvA2FjMgR2dGlkAw--/SIG=13m19hq00/EXP=12746
34997/**http%3a//www.independent.co.uk/news/uk/crime/heathrow-worker-ogled-
colleague-on-scanner-1926289.html

8. Article 3 Human Rights Act 1998, Prohibition of torture: No one shall be subjected to
torture or to inhuman or degrading treatment or punishment.
http://www.opsi.gov.uk/acts/acts1998/ukpga_19980042_en_3#sch1

9. Article 9 Human Rights Act 1998, Freedom of thought, conscience and religion
http://www.opsi.gov.uk/acts/acts1998/ukpga_19980042_en_3#sch1

10. FCNA statement on Full-Body Scanners and their effect on followers of Islam.
http://www.fiqhcouncil.org/

11. Massoud Shadjareh of the Islamic Human Rights Commission in London, quoted as saying
that the FBS “don't make any security sense.”
http://www.rnw.nl/international-justice/article/muslim-women-barred-flying-refusing-scan

12. “Muslim woman barred from flight after refusing body scan” - Telegraph, 3 Mar 2010
http://www.telegraph.co.uk/travel/travelnews/7358967/Muslim-woman-barred-from-flight-
after-refusing-body-scan.html

13. The Pope, while addressing a congregation of airport workers at the Vatican, was reported as
saying that with “every action, it is above all essential to protect and value the human person
in their integrity. Respecting these principles can seem particularly complex and difficult in
the present context [heightened airport security]”. While FBS were not directly mentioned,
there was a consensus among those present that the Pope was referring to the effect on
human rights that the FBS have.
http://www.telegraph.co.uk/news/newstopics/religion/7285996/Pope-Benedict-XVI-
criticises-airport-body-scanners.html

14. In a letter to the US Senate in June 2009, Agudath Israel, which represents traditional
American Orthodox communities, voiced their opposition to FBS.
http://www.forward.com/articles/123364/

15. Leaders in both Conservative and Orthodox communities are debating how scanners with
the ability to see through clothing intersect with Jewish laws of tzniut, or modesty, which are
 observed differently among denominations but generally require Jews to cover their bodies.
Conservative Rabbi, David Rosenn quote:
http://www.forward.com/articles/123364/

16. The Equalities and Human Rights Commission wrote to Home Secretary Alan Johnson
expressing their views:
http://www.equalityhumanrights.com/media-centre/2010/january/body-scanning-equipment-
concerns-raised/index.html

17. Terri Dowty, of civil rights group Action On Rights For Children, told The Guardian the
scanners could breach the Protection of Children Act 1978, under which it is illegal to create
an indecent image or a "pseudo-image" of a child.
http://news.sky.com/skynews/Home/UK-News/Airport-Scanners-Could-Be-Used-To-Take-
Indecent-Picture-Of-Children-New-Guidelines-To-Be-Drawn-
Up/Article/201001115514402?f=rss

18. The Protection of Children Act 1978 clearly states in its opening line “It is an offence for a
person— (a)to take, or permit to be taken [or to make], any indecent photograph [or pseudo-
photograph]of a child”
http://www.opsi.gov.uk/RevisedStatutes/Acts/ukpga/1978/cukpga_19780037_en_1#IDAAS
PPD

19. DfT Interim Code of Practice passes over responsibility for correct and acceptable use of
FBS to private entities (airport operators): “An effective privacy policy must be put in
place by the airport operator to protect passengers when being screened by body
scanners.”
http://www.dft.gov.uk/pgr/security/aviation/airport/securityscanners/codeofpractice/pdf/cop.
pdf

20. CNN, 7th may 2010, “Anatomical ridicule raises body-scanning concerns” TSA worker
mocked by fellow worker over genitalia seen through scanner.
http://edition.cnn.com/2010/TRAVEL/05/06/tsa.scanner.assault/index.html

21. Sandra Fish, February 2010, from the article “My Left Breast Put TSA Scanner To The
Test”.
http://www.politicsdaily.com/2010/02/06/my-left-breast-put-fancy-tsa-scanner-to-the-test/

22. Rapiscan Systems announce plans to introduce a programme which detects objects hidden
below air passengers' clothes.
http://www.dailymail.co.uk/news/article-1287320/Airport-super-scanner-beats-naked-
images-controversy.html?ITO=1490

23. BBC :Airport body scanners 'unlikely' to foil al-Qaeda – MP

http://news.bbc.co.uk/2/hi/uk_news/8439285.stm

24. Colin McSeveny, of Smiths Detection, UK, states that the scanner technology is not yet
ready to be used.
http://www.civilliberty.org.uk/newsdetail.php?newsid=798

25. Interpol head, Ronald K. Noble criticises FBS use at Davos 2010.
http://www.theregister.co.uk/2010/01/29/interpol_davos/
26. Pilots (ALPA) criticize security as Britain makes body scanners mandatory
http://www.independent.co.uk/travel/news-and-advice/pilots-criticize-security-as-britain-
makes-body-scanners-mandatory-1886628.html

27. Health protection Agency FBS risk assessment for the DfT.
http://www.hpa.org.uk/web/HPAweb&Page&HPAwebAutoListName/Page/1262704915658

28. FOI 6176 DfT reply to Adam Woodward 9th March 2010 “What specific tests have been
carried out on the long-term effects of working with said equipment?” DfT response: “We
do not hold specific information on the effects of working with this equipment”

29. Rapiscan Systems claim on their website. “With a single scan exposure of 0.05
microsieverts (0.05 uSv) per inspection, the Secure 1000 systems are 1/5 the allowable dose
under ANSI Standard 43.17 which states the per inspection dose cannot be more than 0.25
microsieverts (0.25 uSv).”
http://www.rapiscansystems.com/rapiscan-secure-1000-single-pose-health.html

30. Even low exposure to X-rays, gamma rays increases cancer risk, study finds. Stanford
University.
http://news.stanford.edu/news/2005/october26/abrams-102605.html

31. Full Body Scanners Pose Health Risks to Travelers, Says Czech Nuke Official
http://topnews.net.nz/content/21731-full-body-scanners-pose-health-risks-travelers-says-
czech-nuke-official

32. Letter of Concern from group of eminent scientists from the University of California
addressed to Dr John Holdren, the Assistant to the President for Science and Technology.
http://www.npr.org/assets/news/2010/05/17/concern.pdf

33. FOI 6176 DfT reply to Adam Woodward 9th March 2010. DfT “There are no known health
implications from Millimetre wave equipment”

34. (Millimetre Wave Scanners) DNA Breathing Dynamics in the Presence of a Terahertz Field
http://arxiv.org/abs/0910.5294

35. DfT-“the backscatter technology ensures that negligible doses are absorbed into the body ”
http://www.dft.gov.uk/pgr/security/aviation/airport/securityscanners/securityscanner/