[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]

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