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

Doss, Mohan Mohan.Doss at fccc.edu
Fri Oct 9 10:32:01 CDT 2015

Dear Bill,
   We are limited to epidemiological studies since ALARA has prevented prospective studies of low-dose radiation health effects. I notice the tagline in your signature "ALARA Forever". ALARA is anti-science, as it prevented prospective study of competing hypotheses to be able to reject the invalid hypothesis, when radiation hypothesis was proposed in 1980, and the LNT hypothesis was already being used.  The LNT hypothesis has survived this long because of this anti-scientific policy adopted by regulatory agencies following recommendations of advisory bodies. In the absence of ALARA, the very first prospective studies of low-dose radiation cancer effects would have resulted in the rejection of the LNT model hypothesis outright.
   If low-dose radiation exposure was followed by reduced cancers in one epidemiological study, and if someone made the claim that this showed evidence for radiation hormesis, you would be justified in your criticism that there is only association, not a causal effect. However, when we observe the same result again and again in many different studies, there can indeed be a conclusion of cause and effect.
   You said you are not able to critically review these studies. I have reviewed many of these studies, and the effects observed are large, and small errors would not negate the conclusions of these studies. 
   You said " With the right selection of data, you can show an association between just about anything you want". Please show me one dataset that shows increased cancers associated with low-dose radiation. Many scientists and publications have made such claims. But such publications have a pathetic record, with major faults being identified nullifying their conclusions.  Such publications keep getting cited by those supporting the LNT model. 
    At the low-dose radiation symposium held during the Health Physics Society Annual Meeting last July, near the end of my presentation, after having displayed over twenty datasets showing evidence for radiation hormesis, I challenged the audience to point me to a single dataset that shows conclusive evidence for increased cancers from low-dose radiation, and no one responded to my challenge. The audience included top officials from NRC, ICRP, etc. If, after more than 60 years of intense study in this area, there is not even a single piece of definitive evidence for low-dose radiation induced cancer risk that the LNT model supporters can point to, I would conclude there is no cancer risk from low-dose radiation. The LNT model is dead. The sooner everyone realizes this, accepts it, and bases actions on the evidence observed, the better it would be for the public.   
    With best regards,

-----Original Message-----
From: radsafe-bounces at agni.phys.iit.edu [mailto:radsafe-bounces at agni.phys.iit.edu] On Behalf Of William Lipton
Sent: Thursday, October 08, 2015 10:54 PM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: Re: [ RadSafe ] Marcus/Miller/Doss Hormesis Petitions to NRC

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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