[ RadSafe ] Re: Radiation Hormesis

Steven Dapra sjd at swcp.com
Mon Dec 31 20:50:11 CST 2007

Dec. 31

         I may have been a little hasty when I said public comment was a 
fraud and a hoax.  You have obviously had some successes, Mike, and I am 
glad to hear of them.  At which level of government were your comments made?

         I have made public comments concerning local level events, and 
have seen other people make comments at them, and our comments were treated 
as if they (and we) did not exist.  It's going to take a lot more than 
public comments to straighten out the mess in regulation.  Congress is 
going to have to start exercising rigorous oversight over the agencies it 
has loosed upon America.  That's a good stopping point, lest I commence 
making a speech.

Steven Dapra

At 09:03 AM 12/31/07 -0800, Brennan, Mike  (DOH) wrote:
>I do not agree with the idea that public comment is useless. I certainly 
>agree that only a tiny portion of the public comments, but as
>long as at least some of that public is knowledgeable about the topic, and 
>as long as the people seeking the comments are willing to listen
>(both points that I grant are not always true), comments can have an 
>effect.  I can think of three cases in which I submitted comments on
>drafts or proposals in which I pointed out flaws or logical fallacies, and 
>the final version was changed.  In one case the changes probably
>prevented millions of dollars of testing and regulation for something 
>that, when you stepped back and looked at it, was not a viable pathway
>(I pointed out that for radioactive material in sewage sludge there was no 
>worker ingestion pathway, as the workers take great care to never get
>it in their mouths, and if they do not to swallow, and certainly not to 
>have it happen on an ongoing basis, and if they did the rad wouldn't be
>in the top ten of problems that needed to be addressed).
>I am not claiming that these changes were made on my input alone (though 
>in one case the wording in the final was closer to my comment than it
>was to the wording in the draft), but I do believe that in many cases 
>comments are taken seriously and can make a difference.
>-----Original Message-----
>From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
>Behalf Of Steven Dapra
>Sent: Friday, December 28, 2007 5:52 PM
>To: radsafe at radlab.nl
>Subject: Re: [ RadSafe ] Re: Radiation Hormesis
>Dec. 28
>          Public comment is a de facto fraud and hoax.  It's an 
> opportunity for a minute portion of the public to blow off steam, or to
>think it may have some salutary influence, while the regulators, etc., go 
>right ahead and do what they planned to do all along.  Besides, who
>has the time to read that dry-as-dust legalese (in what --- six point 
>type?) and decipher what the writers are trying to say, let alone
>compose a response or a suggestion.
>Steven Dapra

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