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

Doss, Mohan Mohan.Doss at fccc.edu
Thu Oct 8 17:33:47 CDT 2015

Dear Peter,
    You asked "What has changed in the past 10 years?". Let me answer and explain. Ten years ago, BEIR VII report, declaring that the atomic bomb survivor data are the most important data for estimating health effects of radiation, concluded that these data do not show any evidence for beneficial effects of low-dose radiation, and the conclusion of the report was that the data are consistent with the LNT model. They also quoted the 15-country study of radiation workers to support the radiation cancer risk coefficients derived from the atomic bomb survivor data.  The conclusion of the 15-country study has been discredited as major flaws have been found in the Canadian data. The latest update to the atomic bomb survivor data published in 2012 has a major difference from the data at the time of the BEIR VII report in that the dose-response has a significant curvature because of lower than expected cancer rates at ~0.5 Gy. This decrease in cancer risk, when doses increase from ~0.2 to ~0.5, cannot be explained using the LNT model. But these data are consistent with the radiation hormesis model as shown in my publications in 2012 and 2013. This view, that the atomic bomb survivor data do not support the LNT model any longer, is being recognized implicitly and explicitly by scientists that used to use these data to support the LNT model. E.g. in the 2013 debate on low-dose radiation health effects in Medical Physics, Dr. Mark Little did not use these data to support his claim for low-dose radiation carcinogenicity, in contrast to a similar debate in 2009 where these data played a major role. In a recent publication in Radiology, the radiologists (who supported low-dose radiation cancer concerns in an earlier publication), acknowledged that the atomic bomb survivor data are not consistent with the LNT model, and also quoted many evidences against the LNT model and for radiation hormesis. 
    There are also data from Taiwan apartment residents study published in 2006 that show ~20% reduction of cancers in low-dose irradiated residents. The Tubiana study published in 2011 showed reduced second cancers per kg of tissue in parts of body that were subjected to ~20 cGy in comparison to un-irradiated parts of the body in radiation therapy patients, indicating low-dose radiation reduced cancers. The Sponsler/Cameron nuclear shipyard worker study, published in 2005 but not considered in the BEIR VII report, showed reduction of cancers in the radiation workers in comparison to non-radiation workers. 
   Of course, there have also been many publications that have claimed increased cancer risk from low-dose radiation. However, such publications have had a pathetic record, with the conclusions of such studies being discredited because of major flaws in data, analysis, and or interpretation. This includes publications Mathews et al (2013), Pearce et al. (2012), etc. 
  Therefore, a lot has indeed changed in this field in the past ten years.
  You expressed concerns about children's higher radiosensitivity. However, this relates to high dose radiation, as increased cancers in children were observed following high-dose radiation only (in atomic bomb survivor study). Only by LNT extrapolation one can claim the higher radiosensitivity at low doses. Since the LNT model does not have any definitive supporting data and radiation hormesis model has many supporting data, there is no credibility to the claim children are more radiosensitive at low doses and so need lower dose limits. 10 cGy annual dose limit proposed by Carol Marcus is far below the threshold dose for cancer induction and would be in the hormetic zone. So there would be no concerns about such dose limits for everyone.
  Regarding your statement that the 69-year conspiracy by the world's scientists and regulatory bodies is a bit hard to swallow, you are underestimating the motivating power of money. There is plenty of money to be made using the LNT model while doing little productive work, as the effects on public health from such work is not measureable according to the LNT model proponents themselves. In reality, their work is causing more cancers and deaths by spreading the fear of low-dose radiation and preventing radiation hormesis studies. 
    Regarding increased thyroid cancers detected in Chernobyl among children: High doses would indeed cause thyroid cancers, but the dose limit Carol Marcus has suggested is low. Therefore, referring to Chernobyl data where the children had high doses to thyroid, and had increased cancers, has no relevance to the issue at hand.  In the above argument, the effects of increased thyroid screening do not come into the picture at all.
    I would suggest you provide evidence for the LNT model or state reasons why so many publications supporting the radiation hormesis model should be rejected, if you wish to object to the petition. Otherwise your objections have no merit.
  With best regards,
P.S. If you are not familiar with any of the studies I have quoted above please let me know, and I will provide links to the publications.

Mohan Doss, Ph.D., MCCPM
Medical Physicist,
Fox Chase Cancer Center,
Philadelphia, PA 19111-2497.
Website: http://www.fccc.edu/research/pid/doss/
Blogs: http://mohan-doss-home-page.blogspot.com/

-----Original Message-----
From: radsafe-bounces at agni.phys.iit.edu [mailto:radsafe-bounces at agni.phys.iit.edu] On Behalf Of Peter Crane
Sent: Thursday, October 08, 2015 4:48 PM
Subject: [ RadSafe ] Marcus/Miller/Doss Hormesis Petitions to NRC


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) _______________________________________________

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