Comments on ICRP-2005

["Ted Rockwell" <tedrock@starpower.net>]

Friends:



Below are my comments on the proposed ICRP 2005 recommendations, which I am

submitting directly to ICRP.  As you can see, I'm not fond of it.  My

response is not a scholarly, annoted document, because I believe ICRP's

entire intent and purpose as written is wrong-headed.



The evidence showing that low-dose radiation is not harmful and is generally

beneficial has been presented in great detail repeatedly to BEIR committees,

NCRP, ACNW and Congress, and it continues to be ignored.  Ironically,

reports such as NCRP-136 state flatly that LDR is not harmful, yet it and

other reports make recommendations to the contrary.



Of course, the US is not obligated to follow this ICRP report, as it has not

followed others. But nonetheless, I believe the ICRP report is a further

step down the wrong path.



Ted Rockwell



ICRP-2005

A Harmful and Unnecessary Step Backwards



The proposed ICRP 2005 document is ill-advised and harmful, both in concept

and detail.  It makes no mention of the vast amount of literature showing,

to quote NCRP-136, “it is important to note that the rates of cancer in most

populations exposed to low-level radiation have not been found to be

detectably increased, and that in most cases the rates have appeared to be

decreased.”  Supporting data have been published in the professional

literature and presented repeatedly to various regulatory bodies.  See, for

example, http://cnts.wpi.edu/RSH/docs



Perhaps mindful of this fact, ICRP drops all previous effort to justify its

requirements on the basis of risk.  In fact, it offers little justification

at  all for extending its regulatory arm down to a fraction of a percent of

natural background.

It concedes that “there is no major problem identified with the practical

use of the present system of protection in normal situations.”  Despite this

fact, the report virtually scraps all previous guidance and proposes a new

system, based on new principles, with new terminology and more complex and

more burdensome requirements. No justification is given for these changes.



It disguises the concept of ALARA by calling it “optimization,”  stating as

its mission to create a state of mind that looks at every radiation exposure

situation with the question: “Have I done all that I reasonably can to

reduce these doses?”  Since radiation dose generally results from people

attending to operations and equipment in a radiation zone, a regulatory

incentive to minimize such critically important safety functions actually

works against safety without producing any health benefit.



ICRP’s phobic attitude toward radiation is shown by its continued insistence

on treating even natural radiation as a hazard, requiring that natural

radiation be regulated when it is considered “controllable” (e.g. radon and

mill tailings) and ignoring it otherwise (e.g. airplane passengers, dwellers

in high natural radiation areas, medical therapy).

The report warns against misuse of collective dose, but then sets up

requirements that will inevitably increase its use in falsely “predicting”

thousands of deaths were none would realistically be expected.  This is

particularly harmful in dealing with emergencies, where a minor event can be

made into a life-threatening panic, and rescue workers prevented by

unwarranted fear of radiation from doing their duty.



As a final insult to science and common sense, the report suggests that

regulatory authorities will normally set even lower vales “but probably not

by as much as a factor of ten.”  This is after suggesting that where there

may be multiple dominant sources, still further restraints are advised.



The report also recommends that a vast new research program be set up to

determine the effects of low-dose radiation on all non-human species, which

would lead to waste of public resources and even further constraints on our

use of technologies involving radiation.



I strongly recommend that this entire report be rejected out of hand.  It is

a scientific embarrassment and a harmful and unnecessary assault on all

beneficial uses of radiological technologies.

			___________________________________________-

All that is really needed is to amend current regulations with a statement

that “Doses below 5 or 10 rem/year are not harmful and may be beneficial.

ALARA below those levels serves no useful purpose.”  And  “Collective dose

should not be used as a measure of excellence in radiation protection, nor

should it be used to predict detrimental effects such as illness or death.

The only meaningful doses are those to individuals.  Minimizing collective

dose is not meaningful.”