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

[BLHamrick at aol.com]

In a message dated 2/5/2005 1:40:06 P.M. Pacific Standard Time,  
jjcohen at prodigy.net writes:

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.
Ah, but it is not enough for one person, or even twenty to  comment.  There 
are a number of things that need to be done.  First,  more HPs need to comment 
- hundreds or a thousand -  and provide their  professional background.  Many 
agencies do give some weight to experts in  the field versus comments from the 
lay public.  In addition, political  representatives need to be contacted.  
They need to know that an agency is  going in the wrong direction, because in 
my experience, when a senator contacts  an agency about something, the agency 
jumps to attention.
 
Do not expect agencies to respond personally to comments.  They  generally 
will not.  Usually, if the comments are made on a draft  rulemaking, the 
response to comments will be included in the final  published rule, and your comments 
will likely be incorporated into a list of  general comments made.
 
In addition, once a rulemaking is final, the rule can always be challenged  
in the courts.  This can be expensive, and it is generally more  cost-effective 
if a coalition of affected parties joins together in the  suit.  One such 
type of challenge might be under the Data Quality Act,  potentially challenging 
regulations or even such public  published statements as "there is no safe 
level of radiation."  

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.

With respect to the possibility that radiation safety professionals do not  
actively oppose excessive regulation, I still take umbrage to the inference 
that  it is done for some kind of personal benefit.  If anything, I think that  
many of them do not realize that the LNT is a tool used for simplifying the  
establishment of regulatory limits, and does not represent any confirmed  
scientific reality.  I believe it is easier to turn to the ICRP/NCRP, and  say, 
"I'll just do what they're doing," but that does not make the model real,  and 
that's a flaw that we need to correct in our education of health  physicists.
 
I think I understand what I'm up against.  I am concerned that so few  health 
physicists seem to be engaged in the process of correcting the excesses  
wrought by our propensity to take a problem such as milk production, and using a  
"spherical cow" to model it, because the public now believes there are 
spherical  cows (i.e., that the LNT demonstrates "real" deaths down to zero dose).  
We  need to take responsibility for fixing that misperception.
 
Barbara L. Hamrick