[ RadSafe ] When Radiation Isn’t the Real Risk

Wed Sep 23 11:53:33 CDT 2015

The biological effect of low-dose radiation is to reduce cancers.  Therefore there is no sense in regulating low-radiation doses. It is like regulating moderate exercise. It is not wise. By regulating low radiation doses, spreading the fear of low radiation doses, and preventing the public from utilizing low radiation doses, the current radiation safety regulations have been a major stumbling block in reducing cancer mortality. As you may know,  our progress in reducing cancer mortality rates over the past fifty years has been very poor, with only about 7 or 8% reduction (in USA), in spite of major advances in cancer detection and treatment. On the other hand, accidental or incidental irradiation at low doses have led to reduction of cancers by as much as 30 or 40%. I have described this in a brief report available on ResearchGate at https://goo.gl/rPghvr .  If we had studied this aspect of health effect of low-dose radiation with prospective studies, we could possibly have optimized the reduction of cancers and have achieved even greater reduction in cancer rates using low-dose radiation. The sooner we get out of regulating low radiation doses, the better it would be for the public.  Regarding the variation in genetic susceptibility, etc., some may not have 30-40% reduction of cancers with low doses but may have somewhat lower reduction.  That would be fine. No need to regulate low radiation doses because of expected genetic variations. 

Of course, high doses of radiation increase cancer risk, and so we should ensure no one is subjected to such doses. Not radiation workers, not the public. This can be done with regulations that are in use currently, but applying them to high doses only. 

In summary, I would suggest dividing radiation use into two categories. One where the workers/public would likely be exposed to low doses only and there is no or little chance of exposure to high doses. For such use of radiation, there should be no regulation. Of course no ALARA.  For radiation uses that have a potential for high radiation doses, the current regulations should be applied, so that no one is exposed to high radiation doses. This radiation safety paradigm would require much less radiation safety workforce, which is fine.  There would be plenty of other work.  For a discussion of this paradigm please see the presentation at: https://goo.gl/A7EcfB in which I suggest annual dose guidance (not dose limit) of 10 cGy.

If you compare the results from Taiwan apartment buildings study  and Fukushima, in the former case radiation safety did not act, and the people had 20% less cancers following low dose radiation exposure. In Fukushima, radiation safety acted, to keep doses as low as achievable, and we had 1600 immediate deaths, and no change in cancers is expected.  For reducing cancers, and for protecting public health, it is best to reduce and eliminate radiation safety regulations relating to low doses, and re-allocate the radiation safety personnel to other tasks. It is better for the public.

If you disagree with the initial premise "The biological effect of low-dose radiation is to reduce cancers", please point to a reliable evidence that shows low radiation doses increase cancer risk. I have been looking for many years and have not found any. There is plenty of faulty evidence in the literature, so please examine the publication closely before suggesting any publication as reliable evidence for low-dose radiation cancer risk. 

With best regards,
                                             Mohan

-----Original Message-----
From: radsafe-bounces at agni.phys.iit.edu [mailto:radsafe-bounces at agni.phys.iit.edu] On Behalf Of KARAM, PHILIP
Sent: Wednesday, September 23, 2015 11:08 AM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: Re: [ RadSafe ] When Radiation Isn’t the Real Risk

I suppose if you really want to get into the weeds then you'd also have to consider someone's age, health history, and genetic susceptibility to radiation. But then you could make the same comments about, say, drunk driving (people have different tolerances to alcohol), speed limits (based on the capabilities of your car plus reaction time plus driving skills), or smoking (some people are genetically more sensitive to smoke). But if we have regulatory limits tailored to each person according to their individual circumstances it will be nearly impossible to have any sort of effective regulation. At some point we have to treat everyone the same in the regulatory realm - or at least to divide the population into just a few manageable categories (e.g. rad workers and non-rad workers).

With regards to regulation, to some extent I suspect that, even if there is found to be a threshold, we will likely not see much change in regulatory limits. 

First, no politician will want to campaign as the person who made it possible for the public to be exposed to more radiation - and any agency head who tries to raise the limits will likely find him/herself looking for work. In addition, consider this. Say we find absolute proof that there is a threshold at 100 mSv (10 rem). Divide that number by, say, 70 and we get an annual exposure limit of about 1.4 mSv/yr for the general public. Add a safety factor (or figure a longer lifespan) and we come up with pretty much the same limit we have today. Finding evidence of a threshold would be scientifically exciting - but I'm guessing it would have virtually no impact on annual exposure limits.

Andy

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu [mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of jjshonka at shonka.com
Sent: Wednesday, September 23, 2015 10:04 AM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: Re: [ RadSafe ] When Radiation Isn’t the Real Risk

Is there any published article that discusses how regulations might change if LNT is no longer the law of the land?  I can see problems with implementation of rules.  With multiple agencies (EPA and NRC in the US), will regulations even have the same basis across all agencies?  

With LNT, the “slope of the curve” or risk per Sievert is same for all levels of exposure.  This makes regulating an activity that irradiates people very simple, in that the contribution from other exposures need not be considered to apply a risk or cost per exposure.  With a variable risk per Sievert (or non-LNT, with an emphasis on non-linear), would one have to consider all exposures to know where on the risk curve you are?  

If an environmental restoration project occurs in a high background area, does the cleanup criteria “differ” from another project in a low background area because the risk per exposure differs?  And by “differ”, limits could be higher or lower for either project, depending on the final “agreed upon” shape of the dose response curve.  If I have a worker with significant exposure from medical issues, or is a frequent flyer with high exposure from his travel, must I consider that as well as his occupational exposure to control his risk?  What if the worker lives in a house with high radon concentration (C. Waltrus at Limerick NPP is a famous example).  Clearly their risk per rem would differ under a non-LNT assumption from other workers.  Do the effluent limits for a reactor change in areas with higher background, such as the Reading Prong area of Pennsylvania as compared to Florida?   

Without the simplicity of the LNT assumption, many issues arise.  Radiation carcinogenesis already has a time (and dose rate) dependency.  Does the risk to a newly hired worker depend on past exposures (occupational and non-occupational) in previous years?  Must I consider past exposures and the time and dose rate of the various past exposures in limiting the exposure of a new employee?  Will my limits for a specific employee change over the years with past exposure history? 

I know some would argue that the limits will be so high because of hormesis that no controls would be needed.  However, I recall that UNSCEAR reports some flyers like couriers have 100 mSv per year from galactic cosmic radiation alone (and there are other sources that occur in flying), and many medical procedures, including radiation therapy have exposures that exceed 100 mSv.  Some high background areas have external gamma background approaching 50 mSv as well.

I do not think the regulatory agencies will no longer be needed.  I wonder how regulations will change.

Joseph J. Shonka, Ph.D.
Shonka Research Associates, Inc.
119 Ridgemore Circle

Toccoa, GA 30577
770-509-7606
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