[ RadSafe ] LNT Petition

clayton bradt dutchbradt at gmail.com
Mon Jun 29 18:13:50 CDT 2015

No purpose would be served by changing the current dose limits based upon 5
Rem TEDE.  They are easy to comply with, with a few exceptions, and provide
adequate margins of safety.  The exceptions I can think of are Nuclear
Pharmacists (especially at PET facilities) and Interventional
Radiologists.  Both groups of professionals are well compensated for the
risks they accept and certainly are able to make informed decisions about
their health.  Perhaps regulations could be relaxed somewhat in those
specific cases to accommodate the real social value that these professions

I believe that LNT should be dislodged from the pedestal of "Official
Truth"  and should not be referenced anywhere in regulation or in guidance
documents, except as one possible explanation for the empirical record.
ALARA might be useful as a planning tool, so long as the "Reasonably"
criterion is stressed.  Otherwise as a regulatory construct I find it very
dangerous.  It amounts to a rubber rule that can be stretched to mean just
about anything - not something any regulator should be given recourse to.

Clayton Bradt
Former Radiation Control Program Director
NYS Dept. of Labor

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