[ RadSafe ] Re: Fw: Low-Dose Radiation "quibbles"

[jjcohen]

  ----- Original Message ----- 
  From: BLHamrick at aol.com 
  To: jjcohen at PRODIGY.NET ; radsafe at list.vanderbilt.edu 
  Sent: Friday, February 04, 2005 6:40 PM
  Subject: Re: Fw: Low-Dose Radiation "quibbles"


  .
  *I maintain that the HP community has not done its duty with respect to commenting on proposed regulation.  

  Take a look at the EPA's Advanced Notice of Proposed Rulemaking regarding "Low-Activity" Radioactive Waste (see, http://www.epa.gov/radiation/news/lawr_comment.htm).  The EPA receive 1500 or so comments.

  (To view the comments, go to EPA's "Advanced Search" page at: http://docket.epa.gov/edkpub/do/EDKStaffAdvancedSearch, then input docket number OAR-2003-0095.  There are 57 "pages" listing documents related to this rulemaking, including background documents, and comments received.)

  Of the 1500 or so comments received, I would venture to estimate that 95% or more were submitted by the lay-public, and that most of those simply cut and pasted rhetoric from an anti-nuclear advocacy group.

  Yes, the National HPS commented, but that's not enough.  The individual chapters need to comment, and individual HPs, as members of the public, need to comment; state agencies need to comment (and, as a tax-paying citizen of your state, you should demand they do so; call your representatives and ask them to put pressure on the agencies to comment; they will listen if you are a constituent); local agencies need to comment (talk to your County Board of Supervisors about it); and, industry and academia need to comment.  Our community needs to participate fully in this process.

  It is arrogant and naive to think that a single letter from HPS should carry adequate weight to balance the other 1400 or so letters an agency receives with contravening opinions, no matter how ill-supported and technically incompetent those opinions may be.

  Barbara---You betcha! I, for one, have submitted many comments on proposed regulatory actions. IMHO, my comments were thoughtful, logical, and insightful in pointing out where the proposed action would be contrary to the best public interests. Every time, my comments were ignored.  From this lack of response, I have never learned where my reasoning might be fallacious, and I am left with the impression that such commenting is simply an exercise in futility.
      BTW, have you considered the possibility that the reason most  radiation safety professionals do not actively oppose excessively restrictive regulation of low-dose exposures is because prefer things just the way they are. It is easy to rationalize such positions simply by referring to ICRP/NCRP recommendations (i.e. if radiation were not harmful at all dose levels, why would we need LNT, ALARA, etc)?
      Before getting into a fight, it is a wise policy to understand what you will be up against.