Re[2]: LNT/ALARA and workable regulations

[steve.rima@DOEGJPO.COM (Steven Rima)]

     Glenn et al,
     
     I don't believe that it is hard. From reading the posts on this 
     subject and the discourse every time the LNT comes up as a subject on 
     RADSAFE, it's obvious that the majority of HPs do not believe that the 
     LNT is accurate in the low dose region. I'm one of those. While we 
     shouldn't make policy or scientific decisions based on opinion polls, 
     I don't believe that we should treat ionizing radiation as a "magic" 
     poison that's different from all other carcinogenic substances, which 
     unfortunately is where we find ourselves.
     
     If we examine the regulations that pertain to the hundreds of 
     carcinogenic chemicals, we find that there is an annual limit set for 
     each one (TLVs, BEIs, etc.) but that ALARA is not mentioned anywhere 
     in any regulation pertaining to chemical exposures.
     
     I would not advocate pushing the chemical exposure limits nor would I 
     make no attempt to minimize my employees' exposures. However (and it's 
     a huge however) the OSHA can't arbitrarily penalize me because they 
     don't agree with my exposure minimization effort. The agencies that 
     regulate radiation have codified ALARA, and then bastardized the 
     system to essentially remove the 'R', resulting in ALAA. This is the 
     real problem.
     
     Why can't we treat radiation like all other carcinogenic substances, 
     with an annual limit but without the capricious ALARA regulation? If 
     the exposure is below the annual limit, then no further 
     exposure-reducing efforts are *mandated* by regulation.
     
     Comments Glenn?
     
     Steven D. Rima, CHP, CSP
     Manager, Health Physics and Industrial Hygiene
     MACTEC-ERS, LLC
     steve.rima@doegjpo.com


______________________________ Reply Separator _________________________________
Subject: Re: LNT/ALARA and workable regulations
Author:  GlennACarlson@aol.com at Internet
Date:    4/3/00 11:56 PM


Well -- okay -- Mr. Chandler has cast his vote -- "LNT - baaaaad; hormesis - 
gooooood."  
     
Now, back to my question (first stated in May 1999), which is NOT whether LNT, 
or LT, or NLT, or NLNT is the more accurate model for calculating risks from 
radiation exposure, but, rather, how any alternative to LNT would be 
implemented.
     
Suggestions so far include 1) reexamining the use of collective dose, 2) 
abandoning ALARA, and 3) relaxing the limits (though to what is not 
specified).  
     
C'mon, folks.  This is not meant to be hard.
     
Glenn A. Carlson, P.E.
glennacarlson@aol.com
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