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Re: AW: "The Bell Tolls for LNT"
I agree. There is a site not far from here (are you listening Mr. Ricciutti) where the Army Corps of Engineers has spent over 50 million dollars moving soil to Utah (and the cost is still growing), because regulations (based on LNT) are 25 mrem. Change that to 100 mrem and most of the bill goes away. The Army Corps of Engineers is doing this in numerous places around the country. And that is just one aspect of the misuse of LNT.
Of course on the bright side, it is keeping a lot of HPs busy, as well as contributing to the profit margins of a lot of large companies.
In a message dated 10/25/2004 9:21:15 AM Pacific Standard Time, email@example.com 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
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