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

[William Lipton]

Could you be more specific?  What caused this epiphany?

You seem to site epidemiological studies as "proof" of hormesis.  While I'm
not able to critically review these studies, it's important to keep in mind
that epidemiological studies show association, NOT cause and effect, i.e.,
there seem to be some studies where higher radiation dose is correlated
with certain benefits.  However, this does not prove that the radiation
caused these benefits.  With the right selection of data, you can show an
association between just about anything you want, e.g. increased obesity
can probably be correlated with increased use of cell phones.  Obviously,
the best way to lose weight is to avoid using a cell phone.

Bill Lipton
ALARA Forever



On Thu, Oct 8, 2015 at 5:46 PM, Carol Marcus <csmarcus at ucla.edu> wrote:

>
>
> What happened in the last ten years, Peter, is that I read more and more
> of the scientific literature.  A good scientist changes his/her mind based
> upon reputable data.  Therefore, over my scientific life I have changed my
> mind about numerous ideas.
>
> Carol S. Marcus, Ph.D., M.D.
>
>
> On 10/8/2015 1:48 PM, Peter Crane wrote:
>
>> 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)
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