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Ted,
What is the point of all
this? To bash the NCRP? Easy to do since you can pick those points
you want to criticize. I notice that you mention that Dr. Luckey's two
books are cited and that Dr. Pollycove received a hearing before the NCRP.
I guess you could call these concessions by the NCRP. Of course, if the
NCRP had put in all of the comments that you and others felt were necessary,
would that have made the report unbiased? Or politically correct from
your position?
I am not sure I would
characterize the members of the NCRP as seekers of truth. (I guess that
only you know what the truth is. I am not that smart, but am willing
to look at more than one side of an issue.) I would characterize the NCRP
organization as a reviewer and summarizer of data. In all of my readings
of NRCP publications, I have not seen them use the LNT as a regulatory
tool. I could be wrong and I am sure that if anyone has, they will let me
know about it.
Exposure recommendations from
the NCRP are found in Report 116. I could not find a reference to
LNT. As you note on p. 10 of the report: "an exhaustive or comprehensive
description of the literature was not the goal of this
Report..." The line continues ". . . but rather (to
preform) a critical evaluation of the linear-nonthreshold dose-response
model." I don't know what you mean, that is what they did. I did not
think their charter was to evaluate hormesis, adaptive response, etc., except in
the context of what model fits the data at low doses. I guess that is what
they did. It seems to me that all of your critisms are based on the
exclusion of data that was either not relevant to the purpose of the report, or
were address but not to your satisfaction.
Have a good
weekend.
-- John
John P. Jacobus, MS
Certified Health Physicist
e-mail: jenday1@msn.com
The comments presented are mine and do not reflect the opinion
of my employer or spouse.
------------------------------------
John:
Get real! NCRP always
makes a great show of being open to everyone, but they don't even bother to
acknowledge, let alone consider, input showing that LDR is not harmful.
Jerry's case is not anomalous, it's typical.
I asked Art Upton publicly
why NCRP-136 did not even reference the definitive works on radiation hormesis
by Don Luckey, two books devoted entirely to the subject, citing several
thousand references. Luckey is a biologist of towering credibility and
has worked in this field, publishing many papers for decades. Upton
replied that of course they were familiar with Prof. Luckey's works and he
would see they were cited. But he made to effort to evaluate
them.
I'll quote from just one
example of a comment to NCRP-136 that was ignored. Zbigniew Jaworowski,
head of the Polish Delegation to UNSCEAR and former UNSCEAR Chair, wrote that
he has NEVER had any of his comments acknowledged or responded to in NCRP
reports, even though his laboratory is an affiliate to NCRP. I've had
the same result in commenting from ANS. Myron Pollycove requested and
received a hearing with the committee, but none of his material was dealt
with, although it totally refutes the LNT.
So pls
don't characterize these people as objective seekers of truth.
I'll attach the Polish commentary for those who can receive
attachments. Since radsafe does not transmit attachments, I'll just
quote the opening words here. In 12 single-spaced pages, he provides
very specific examples.
" In December 1998 Central Laboratory for
Radiological Protection in Warsaw, a participant in the Special Liaison
Program of NCRP, on the formal
request of NCRP, prepared a
critical review of the draft
of NCRP Report No. 136 on
"Evaluation of the Linear-Nonthreshold Dose-Response Model for Ionizing
Radiation". The review, a five page document prepared by us, contained a
general part and 25 specific
comments. We never received an answer to this criticism, and in the final
version of NCRP Report No. 136, almost all of these comments were ignored.
Therefore, most of them are repeated here, and a few new ones are
added.
General comments
The title is inappropriate. The Report,
prepared by Scientific Committee 1-6, is not an objective evaluation of the
validity of the linear-nonthreshold dose response hypothesis (LNT); but rather
is a propagation of LNT. It does not demonstrate that LNT is scientifically
valid, but rather that NCRP holds LNT dear. Because of the longstanding
involvement of NCRP in applying LNT as the basis of radiation protection and
radiation risk evaluation, with all of its far reaching economic, health and
social consequences, NCRP is probably not a proper body to conduct an
objective estimate of the validity of the LNT, because of the group vested
interests that are the case here. In the face of a mounting scientific
evidence of invalidity of this hypothesis, and the increasing number of its
opponents, the Committee's Report can be seen as an attempt to defend the LNT,
and an attempt for an exculpation for its past use. The Committee did not
fulfill the provisions from its Legal Notice: "to provide accurate, complete
and useful information" for impartial and disinterested evaluation of
LNT. Instead, the Committee
correctly states on p. 10: "an exhaustive or comprehensive description of the
literature was not the goal of this Report..."
The Committee has presented an unbalanced
presentation of the pros and contras to the LNT. The Report demonstrates a
biased selection of published results, offering lengthy and often misleading
pro-LNT interpretations and data, but curtailing and deforming the information
to the contrary, and most often ignoring it. The Report concentrates almost
exclusively on detrimental effects of radiation, and ignores totally the
beneficial effects, and even does not mention an existence of the studies of Planel and his group
(e.g. (Planel et al. 1987))
that suggest that ionizing radiation may be essential for life."
And then he proceeds to give
detailed examples of just where and how this was done.
. .
.
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