[ RadSafe ] Marcus/Miller/Doss Hormesis Petitions to NRC

[Peter Crane]

Fellow RADSAFERs:

There are many people who may be doubtful or agnostic about the validity of the LNT (which is, after all, an unproven theory) but for whom hormesis is a bridge too far. And the notion that the conservative principle of keeping radiation doses ALARA is attributable to a 69-year conspiracy by the world's scientists and regulatory bodies to conceal the truth about radiation's benefits, solely out of self-interest, is a bit hard to swallow.

By the same token, I think many of us would agree that there are many in the public who have a disproportionate fear of radiation, coupled with insufficient awareness of the environmental and health costs of the energy alternatives. Rational decisions on energy sources require us to compare risks and benefits across the range of alternatives, rather than looking at each one in isolation. But even if we stipulate that radiation is less dangerous than many people may think, it is a huge leap from that to the notion that radiation confers positive health benefits, as these petitions argue.

Dr. Marcus proposes that fetuses, embryos, small children, and pregnant women be allowed to receive as much radiation as a worker's occupational dose, with no discrimination as to age or pregnancy status. The puzzling thing is that it was just ten years ago that Dr. Marcus was writing that children were more radiosensitive than adults by a factor of three and should be protected accordingly. In a letter to the FDA dated January 5, 2005, she had this to say: 

"The current RDRC regulations essentially prohibit pediatric research because of the minuscule radiation dose limits permitted (one tenth of that of an adult). This runs counter to the need to obtain pediatric-specific information. While normal children are more radiosensitive than adults, a factor of 10 is without scientific basis and is much too conservative. A working limit of about one third of what a normal adult receives should be sufficient.... "

So what has changed in the past ten years? I hope Dr. Marcus can clarify, for the benefit of the RADSAFE community, what on its face appears to be an inconsistency. 

On another subject, the most important lesson learned from Chernobyl, for most mainstream doctors and scientists, was that children's thyroids were more sensitive to the carcinogenic effects of I-131 than previously believed. The first cancers began showing up near Minsk around 1991, and by now, number over 7,000, almost all in patients who were under four years old at the time of the accident. The major surprise was that the cancers appeared so early, as the latency period of radiogenic thyroid cancer had been believed to be much longer -- 20 years or more. Dr. Marcus turns this finding on its head, arguing that since the latency period for thyroid cancer is known to be so much longer, the thyroid cancers found after Chernobyl were not and could not have been caused by radiation, and are ascribable solely to intensive screening. I do not believe this theory holds up to close scrutiny, to put it mildly.

I have dealt with these issues and more in my comments on the petition, which can be found at the Regulations.gov website. (I've attached to them a paper presented to an IAEA conference in Bonn, Germany, in 2012, dealing with the NRC's Patient Release Rule.) The docket number for the Marcus/Miller/Doss petitions is NRC 2015-0057. The abstract of my comments is as follows:

"Dr. Carol S. Marcus has petitioned the NRC for a rule change that would allow embryos, fetuses, children, and pregnant women to receive as much radiation as workers in a nuclear facility. She asks the NRC to scrap the cardinal principle of radiation protection – that radiation doses should be kept 'as low as reasonably achievable' – in favor of 'hormesis,' the theory that radiation is good for you. Though mainstream science, as exemplified by the National Academies of Science, debunks hormesis as unsupported by the evidence, the Marcus petition does have one virtue: its extreme radicalism may help convince the NRC Commissioners of the grievous error that their predecessors made in granting the previous petition for rulemaking filed by Dr. Marcus, relating to nuclear medicine. The resulting rule change, in 1997, has made the United States an outlier in the world radiation protection community, with the weakest standards in the world, laxer even than
 those of Iran, Indonesia, and other Third World countries. It has put the American public, especially small children, pregnant women, and babies in the womb, at risk from the radiation emitted, excreted, and exhaled by patients given high doses of the radioactive isotope iodine 131 as outpatients. Therefore the Commission should NOT dismiss the Marcus petition out of hand, without a proceeding. Instead it should initiate a rulemaking proceeding that publicly examines not only the merits of hormesis, as Dr. Marcus requests, but also whether the NRC’s rules on the release of radioactive patients should be made to comply once again with international standards and practices, so that this 18-year aberration can be corrected, and the NRC can resume its rightful place in the mainstream of the world radiation protection community."

I look forward to hearing the responses of Dr. Marcus and other RADSAFERs, and I trust we can conduct this discussion in a spirit of objectivity and civility. 

-- Peter Crane, NRC Counsel for Special Projects (retired)