[ RadSafe ] what the NIRS think of the ICRP draft recommendations

[JGinniver at aol.com]

FYI, apologies for the length but I wanted the full message to be  repeated.  
I wonder how many additional responses to the ICRP this will  generate.
 
Regards, Julian
 
 
RADIATION ALERT—Help stop the international push for  deregulating nuclear 
waste! 
Public Comments on International Radiation  Recommendations (ICRP 2006) 
Due Friday 15 September 2006 (apologies for short  notice) 
HOW TO COMMENT TO ICRP (International Commission on  Radiation Protection) 
Upload or type your comments into the space on the ICRP  website at 
_www.icrp.org_ (http://www.icrp.org/)  
Full link is _http://www.icrp.org/remissvar/remissvar.asp_ 
(http://www.icrp.org/remissvar/remissvar.asp) .  
If full link doesn’t work go to _www.icrp.org_ (http://www.icrp.org/)  
Click on  2006-06-07   2nd round of consultation, draft next  ICRP 
Recommendations 
Click on  comments page and scroll down to box  for comments or  
On left is place to click to Submit comments  
ICRP has accepted comments in the past via  e-mail to _Jack.Valentin at ssi.se_ 
(mailto:Jack.Valentin at ssi.se)  or _scient.secretary at icrp.org_ 
(mailto:scient.secretary at icrp.org)  but prefers  posting on the web site so that others may 
see them. You can see all posted  comments on the website as well. 
Full report can be viewed at ICRP’s  web site 
_http://www.icrp.org/docs/ICRP_Recs_02_276_06_web_cons_5_June.pdf_ 
(http://www.icrp.org/docs/ICRP_Recs_02_276_06_web_cons_5_June.pdf)  
We encourage all to give input on the International  Commission on 
Radiological Protection (ICRP) on its 2006 radiation  recommendations, which most 
nuclear nations will adopt into law or rule to  “regulate” (or deregulate) 
radioactive materials and the nuclear industry and  which have several seriously bad 
provisions. 
2 IMPORTANT COMMENTS TO  MAKE: 
1) Delete all discussion and recommendations for  EXEMPTIONS and Exemption 
levels (delete section 2.4 and any tables supporting  exemptions)  
2) Encourage ICRP to adopt and incorporate the  PRECAUTIONARY PRINCIPLE in 
the overall framework. 
More details on both below. 
ICRP is making recommendations which are stated to  update their 1990 
recommendations.  
KEY QUESTIONS and NIRS  responses 
Should radiation from human-made nuclear waste be  “exempted” from 
regulatory control?  (Section 2.4 Exclusion and  Exemption) 
Be sure to let ICRP know your views regarding  EXEMPTIONS—the latest term for 
deregulating, releasing, dispersing radioactive  materials into the 
marketplace and environment or to regular trash dumps and  incinerators.  
In recommending that some level of radiation is too low  to worry about—
trivial—doesn’t warrant regulation, ICRP is inappropriately  taking on the 
societal role of “justifying” unlimited and unknown numbers of  unnecessary and 
preventable public exposures. ICRP is mixing its self-designated  roles as 
provider of scientific information with societal risk decision-maker.  Since ICRP is 
a closed, self perpetuating body, without nuclear power critics,  it has no 
moral or representative authority for making assumptions about the  
acceptability of risks from involuntary doses to members of the public from the  nuclear 
power fuel chain. ICRP simply does not have public representation thus  has no 
authority to assess what additional, unnecessary radiation risks members  of 
the public around the world in this and future generations consider trivial  or 
acceptable. 
ICRP claims it does  not have enough certainty about the effects of low dose 
radiation on large  populations (termed “collective dose” estimates) to 
estimate the number of cancers that will  result in that population now or in the 
distant future, yet ICRP thinks it has enough scientific and  socio-political 
information to actually release radiation to large  populations – with no limit 
on the number of worldwide releases or  “exemptions”— with no limit on the 
number of exemptions per facility or to a  community—without their consent or 
knowledge. ICRP makes a self-determination  that the risks are trivial and 
acceptable by the public (at the same time it  discourages estimating what those 
risks are). ICRP does not know how much total  radiation will be released or 
received when it, across-the-board, recommends not  only that countries adopt 
release levels but also specifies a suggested level or  range. There is 
absolutely not scientific justification for this recommendation  – it is purely 
economic for the sake of the industry. The whole concept of  exemptions should be 
deleted from the ICRP 2006 Recommendations.  
Furthermore, the ICRP should remove the lower bound  (essentially an 
exemption level) from the radiation levels throughout its text  and in its charts on “
constraints,” doses, and bands of regulatory control  (including Section 5.8.2 
para (204) and Table 4, p. 61). Industries should be  responsible for and 
protect the public from all doses not just those above an  ICRP-selected level. 
ICRP suggests governments decide what they want to  regulate and what they don
’t, then establish  “what could be exempted from some regulatory 
requirements because regulatory  action is unwarranted...the legislative framework should 
provide the regulator  with the authority to exempt situations from 
regulatory requirements,  particularly from those of an administrative nature such as 
notification and  authorization…Exemption…relates to the power of regulators 
to release from  specific regulatory obligations…waiving…legal obligation. ” 
[page 17, paragraph  (42) of Section 2.4] We suggest ICRP completely get rid of 
this  strongly objectionable and unacceptable recommendation and all of 
Section  2.4. 
In the US, the Nuclear Regulatory Commission has delayed  its rulemaking that 
would generically deregulate much radioactive waste and  material, but NRC is 
regularly taking applications for case-by-case exemptions  such as those from 
owners of nuclear reactors undergoing decommissioning  —allowing some of the 
nuclear waste to go to sites without radioactive licenses,  permits or 
controls. The US public actively opposes and challenges these and  opposes US and 
ICRP to allow generic and case-by-case exemptions. We are working  to prevent all 
efforts to allow industry-generated radioactive materials and  wastes to be 
exempted or excluded from nuclear regulation with the goal of  preventing 
public release and exposure. We suggest ICRP acknowledge and accept  this 
perspective on public protection from  radiation. 
ICRP should immediately cease this  recommended abrogation of regulatory 
responsibility by removing all of Section  2.4 from the 2006 recommendations and 
all subsequent  documents. 
Should ICRP officially adopt the Precautionary  Principle—when in doubt, 
prevent unnecessary radiation  exposures? 
ICRP should restructure its framework  to incorporate or replace its basic 
principles with the Precautionary  Principle. ICRP  should stop pretending its 
value judgments have a technical scientific or even a  sociological basis.  
ICRP’s composition is completely one-sided; its mission  is promotional not 
protective of human health and other living beings or  biosystems. As ICRP 
claims to attempt to open up –become more transparent, it  must include members 
who are not fully committed to the continuation of all  nuclear activities as 
there is no objectivity, balance, credibility when those  risking the dose are 
not even represented. ICRP should be clear about which of  its assertions are 
scientific and cite the sources for those statements, and  just as clear about 
which are value judgments (such as the misguided claim that  there is a 
trivial or acceptable dose that can be exempted, below which  resources are not 
justified to regulate, or a lower band of constraint dose that  does not need to 
be regulated). Removing the unjustified or one-sided societal  judgments could 
potentially help the credibility of the  ICRP. 
ICRP has 3 basic principles for radiation  exposure: 
Justification—a government body (such as the national  legislatures or 
nuclear agencies) or the nuclear industry licensee/operator  decides that an 
activity which releases radioactivity and exposes people to  radiation is “justified.”
 The general public which is exposed does not get to  decide but does receive 
the doses—This is clearly unethical and immoral, unfair,  unacceptable. Yet 
ICRP sees it as a basis for permitting doses and proceeds to  provide ranges of 
acceptable doses in various situations…all the way up to  10,000 millirads 
per year! A level that will give cancer to 1 in 3 exposed for  30 years. (This 
is the ICRP-recommended level that US Department of Homeland  Security adopted 
in January 2006 as acceptable for moving people back in after a  dirty bomb.) 
Justification makes sense when the exposed person decides, not when  that 
person has no say but the entities making and controlling the potential  hazard 
decide. It is even more questionable in non-Democratic societies, more  and more 
of which are establishing nuclear power and weapons industries right  now. 
Optimization- a convoluted process by which the nuclear  promoters determine 
how much it is worth to regulate and reduce exposures. It is  used as a 
justification for exposing people in all situations. There is no  guarantee or 
mechanism for the exposed individuals to determine if or how much  radiation is 
imposed on their bodies. Includes the concept of ALARA – as low as  reasonably 
achievable – taking the industry’s economic factors into  consideration in 
deciding what is “reasonable.” 
Limitation of Dose- The assumption that the radiation  establishment chooses 
protective dose limits …A major fault is that public doses  are not simply, 
economically and practically measurable thus are not verifiable  or enforceable. 
Another serious flaw is that low, chronic doses are potentially  more harmful 
per unit dose than single higher doses so simply limiting doses  does not 
necessarily protect people. In addition, doses are calculated based on  standard 
man or, as this update encourages, “gender-averaging” and a  “representative 
individual” who does not have “extreme” habits. Thus, doses are  not based on 
risks to the more vulnerable like women, fetuses, older adults,  children, 
people with AIDS or other reduced immunity or preexisting high  cumulative 
doses. Unnecessary radiation doses should be prevented and avoided,  not permitted 
at low or continuous rates. If they are to be set, they should  protect the 
most susceptible taking uncertainties including synergistic effects  into 
account. 
What do you think about “averaging” radiation risks?  
Do you think it is time that ICRP acknowledged and  accounted for non-cancer 
health risks from radiation like cardiovascular  diseases, reduced immunity, 
as well as cancer?  
Isn’t it about time radiation risks are considered along  with those of other 
carcinogens and pollutants in the environment, workplace and  body? 
How should (relatively new) biological knowledge, like  the bystander effect 
and other uncertainties about the impact of radiation at  low doses be 
incorporated into existing radiation standards?  
Rather than attempting to protect the most vulnerable,  ICRP estimates 
averages risks to men and women and among age groups to protect  the average rather 
than the most vulnerable of those studies…ignoring those  groups and 
individuals. ICRP also ignores non-cancer health effects--- how much  longer can the 
connections between radiation and other diseases and conditions  including 
cardiovascular and immune deficiencies be ignored by the Commission  that claims to 
be comprised of international experts. ICRP also needs to  acknowledge and 
account for the large potential for much greater health damage  from multiple 
exposures to radiation and other hazardous materials and  conditions in the 
environment. Radiation damage is multiple, additive,  cumulative and synergistic 
and should be considered such by ICRP. Some of these  concerns are addressed 
with suggestions for quantifying the risks and  uncertainties in the European 
Committee on Radiation Risk (ECRR) in its 2003  Recommendations of the ECRR: The 
Health Effects of Ionising Radiation Exposure  at Low Doses and Low Dose 
Rates for Radiation Protection Purposes: Regulators’  Edition. We  recommend ICRP 
more carefully review this report before proceeding with new  recommendations. 
Should “acceptable” radiation levels (above natural  background) be set for 
BIOTA (animals, plants and the  environment)? 
We are glad to see that ICRP is acknowledging that  protecting humans does 
not de-facto protect other species or ecosystems (as has  been the mantra of the 
radiation hierarchy until now—and some still espouse it),  however, we oppose 
the legalization or setting of acceptable contamination  levels for animals, 
plants and environments. The motivation is clearly to  relieve radiation 
polluters of liability and should be replaced with the  precautionary principle 
approach. ICRP should be asking the question “How can we  prevent radiation 
exposure of nonhuman species?” rather than relieving of  liability those that cause 
contamination and exposure.  
ICRP suggests it will follow the same framework as it  has for human beings—
we repeat our call for replacing that framework with  precaution—not spreading 
it to other species who have absolutely no way of  participating in “
justification” or “optimization” decisions. ICRP, ignoring all  previous complaints 
about the “standard man” now “reference person,” is pursing  the untenable 
concept of identifying and using reference animals and plants,  when there is 
such immense diversity at the cellular and organismic level that  such efforts 
are almost laughable. The complexity of cells, tissues,  individuals, 
populations, species, interaction of species, and ecosystems cannot  be simplified to a 
reference mammal, reference duck or reference fish.  Synergistic effects will 
further compound the equations. These increased  uncertainties should be 
accounted for with increased conservatism and the goal  of preventing exposures. 
ICRP has not proceeded very far in this effort, but we  repeat our concern that 
our nominations of highly qualified members of the  public interest community 
to work on the ICRP committee on this topic were  completely ignored by the 
ICRP. 
Some additional areas being addressed  include: 
àsetting exempt and excluded levels of  radiation exposure that no longer 
need regulatory control (something many of us  have been fighting for decades and 
essentially outlawed in some US  states); 
àdiscouraging projection of “collective” or  population doses— preventing 
estimation of harm to populations now or in the  future from radiation exposures—
supposedly due to the uncertainty of health  effects at low doses and into 
the future.—ex: recommending against calculations  of the numbers of cancers 
from allowable cleanup levels from dirty bombs or from  releasing radioactive 
materials into commerce from regulatory control or from  exposures to populations 
in 10,000 to a million years from the proposed Yucca  Mountain site if it 
were to be used a nuclear waste dump. Unfortunately not  guessing the damage does 
not prevent the damage. Hypocritically, that same  uncertainty does not stop 
ICRP from recommending actually releasing the  radioactivity in its Exemption 
and Exclusion  section; 
àsetting legal radiation exposure levels for  animals, plants, and ecosystems—
in order help radiation polluters escape  liability for environmental 
contamination and exposure to non-human  species; 
àcontinuing to recommend the same public and  worker exposures even though 
known cancer incidence risks have increased  somewhat (by a third in National 
Academies of Science BEIR VII report from 8.46  to 11.41 cancers per 10,000 
person rads or 100 person grays) and new (since the  mid-1990s) biology indicating 
that radiation damages more cells in the current  and future generations of 
cells than those directly hit by radiation (bystander  effect); 
à averaging radiation damage over age and  gender, leaving the most 
vulnerable humans unprotected. This may be an  improvement to protecting the hardiest 
members of the population but ICRP should  adopt the precautionary approach and 
protect us  all; 
à continuing its precedent of disregarding  radiation damage to future 
generations beyond the first 2  generations 
à allowing “low-level” releases of radiation  while claiming not to know 
exactly what damage is done at these doses.  
à recommending use of a “representative  individual”  or “representative 
person” that is who appears to be designed  to prevent anything but average 
assumptions in dose calculations, appears to be  evolving from the standard man, 
the most exposed individual, the average member  of the critical group, all 
created by the radiation establishment to enable  mathematical manipulations which 
in many recent cases, allow more radiation  contamination and reduce real 
public protection, prevention and  precaution. 
Many Thanks! Diane D’Arrigo, Nuclear  Information and Resource Service  
_dianed at nirs.org_ (mailto:dianed at nirs.org) ;  US phone: 301  270 6477 x 16  
9-12-06