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Re: AW: "The Bell Tolls for LNT"
In a message dated 10/25/2004 9:21:15 AM Pacific Standard Time,
maurysis@ev1.net writes:
"...It may be used to justify proposals for regulatory limits or , ... "
That clause fits my understanding of a tool (not the only one) used
in the regulatory process.???
I agree. A "regulatory tool" includes those things that support the
promulgation of regulation, and not simply what is contained in the regulations.
Virtually all U.S. dose limits have their basis in the LNT. As a regulator
myself, I would consider the LNT a fundamental "regulatory tool."
The question as I see it is: Has the LNT outlived its usefulness as a basis
for dose limits in the low dose or low dose-rate regions? I think there is
a good argument that it has, not only for radiation, but for other regulated
carcinogens.
The U.S. spends billions of dollars per year, either directly through agency
funding, or by imposition of ultra "conservative" cleanup standards on
businesses. I put "conservative" in quotes, because I think it is not necessarily
conservative to assume harm at low doses or at low dose-rates, even though
harm has been demonstrated at high doses and high dose-rates. I think that
assumption, which is often referred to as (at least an element of) the
"precautionary principle," is a simplistic and narrowly focused response to a complex
problem, which may ultimately do more harm than good. It's a "feel good"
approach that the public can understand, but fails to properly assess a
specific risk in the context of all risks and benefits.
Whether the "true" model is the LNT, a threshold model, a hormetic model, or
any number of other models, we don't know. To invest billions per year to
protect against a completely speculative harm that, even if it were proven to
exist, would be indistinguishable amidst the other risks we face seems the
height of folly, in my opinion, especially in California, where we see
emergency rooms and trauma centers closing routinely, with the result being very real
deaths.
Barbara L. Hamrick