[ RadSafe ] Re: [ RRadSafe ] Re: Radiation Hormesis Why regulator is always on the receiving end! The action of Canadian Nuclear Safety Commission I request your views

parthasarathy k s ksparth at yahoo.co.uk
Sat Dec 29 01:51:14 CST 2007


Friends,

I must confess at the very outset, I have some conflict of interest in any discussion on the role and behavior of regulators.I was a regulator for over 17 years in my earlier avatar and had defended the role of my organization then and since then!.There is a general tendency of regulator-bashing in the list (in all lists!!) and I do not see the views of any one from the regulator's side in the list, I thought that I must react:

A few years ago when Dr Merril Eisenbud visited India, in a private discussion, he told us about  the mushrooming of US Federal Acts related to safety and environment. He traced the inspiration for generating such legislation to books such the "Silent Spring".. He had a nice graph showing the steep rise in laws with time.

Yes I agree there should be some balance in framing laws, there is no point in having a plethora of laws which cannot be enforced.

Laws are made by legislators or by bodies empowered to do it.  They collect inputs and feed back from all stakeholders. It may look very tempting to say that the lawmakers do not do a good job! Rather than leaving every item to activists, specialists should get involved; it is worthwhile to spend some extra time in highlighting issues for the benefit  of law makers. How many of us can say that we have done it?

The recent isotope shortage in US and Canada due to  the  AECL/CNSC  conflict  is a case in point. I read references to it in  this list and in the media. I have the following views  I shall appreciate  points and counter points on the issue.

I believe that the Canadian  system (CNSC plus the Parliament) acted swiftly and tried to resolve the issue. I believe that CNSC's responsibility is to enforce safety regulations. The transcript of the Commission's deliberations indicated that AECL was taking its own time to comply with the stipulations in their licence. How long CNSC can continue condoning the operation of the reactor? I feel that CNSC need not worry over isotope shortage etc. 

Some of you raise your hand in horror arguing that isotope shortage may cause the deaths of many patients and the regulator should factor in this in their decision. May be AECL and CNSC should have found a way out. They should have explored ways of  avoiding the crisis. Under the prevailing situation I endorse the decision of CNSC.

I endorse the decision of  the Canadian Parliament as well  in withdrawing CNSC's control over NRU for 120 days. They have every right to weigh the different factors to take the decision. It was appropriate that they exercised their right! But unfortunately the Canadian Prime Minister invoked sinister political motives in the action of  CNSC. The concerned authorities were ham handed in denying CNSC legal assistance.  Ultimately some one has to take a decision. The onus is on the Parliament which empowered the regulator.

 I expect some of you to contribute your views on the subject . Was it the first time a Parliament acted against a regulatory body? The Atomic Energy Regulatory Board took action against the Nuclear Power Corporation of India Limited which operates Indian nuclear power plants on several occasions.Some of the restrictions led to loss of millions of Rs. Though there was a legal remedy to appeal to the Government it has never done it. Thus far, that is


Regards
K.S.Parthasarathy

----- Original Message ----
From: Steven Dapra <sjd at swcp.com>
To: radsafe at radlab.nl
Sent: Saturday, 29 December, 2007 10:12:19 AM
Subject: Re: [ RadSafe ] Re: Radiation Hormesis

Dec. 28

         John Jacobus wrote, "Generally, those who believe in
 "hormesis" 
say that there is a benefitical effect as a blanket statement.  If you 
disagree, then you are a regulator who is imposing undue restrictions."

         If indeed people are saying this about regulators they are
 taking 
a clumsy and heavy-handed approach.  Hormesis may prove to be false.
  To 
state the obvious, lack of a hormetic effect does not mean exposure is 
harmful.  Proponents of hormesis who say regulators who deny hormesis
 are 
imposing undue restrictions are just as wrong as  regulators who
 regulate 
(or try to regulate) below a level where no harm has been shown.  Or as
 
wrong as regulators who try to regulate based on junky studies.

         To back up again, it seems that the attempt to regulate
 phthalates 
is based on a questionable study published in Environmental Health 
Perspectives.  See this blog link 
<http://thestatsblog.wordpress.com/2007/12/18/media-overstating-phthalate-risk-say-doctors/>. 
It has an excerpt from the editorial column in the LA Times,  the one
 that 
Barbara Hamrick mentioned earlier in this thread.  If readers go to
 this 
link, scroll down a short distance to an area that is highlighted in
 pale 
orange, and read the three links in this area.  In particular, read the
 
third link (click on "overstated").  It is an article from the
 Statistical 
Assessment Service at George Mason University about how Time magazine 
played fast and loose with the truth about phthalate studies.

         The key study about phthalates in the context at hand appears
 to 
have been published in Environmental Health Perspectives. [Environ
 Health 
Perspect. 2005 August; 113(8): 1056-1061.]  This link is to the
 abstract, 
and to some related 
materials: 
<http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1280349&rendertype=abstract>.

         This link is to the paper (not in PDF): 
<http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1280349>.
  If 
you read nothing else, read the Discussion.  The qualifiers alone "are 
worth the price of admission."

Steven Dapra








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