evolution of regs? -Reply

[JMUCKERHEIDE@delphi.com]

Paul,

I don't really disagree with your points, but the real point is to address why 
EPA and DOE and NRC and FDA, etc., come out with regs and programs that cost
$100s Billions, costly changes to Part 20, etc. that are unsupported by
radiation effects data, and lay it on the need to conform to BEIR V, when the
science (and scientists like Warren Sinclair, Arthur Upton, and others have
stated) do not justify those costs; and the science community says only timid
responses, and will talk about fears for budgets and programs in hallway
conversations. <snip>

>despite the admittedly entertaining  comments to the
> contrary, the NCRP and ICRP folk are highly qualified scientists,

Agreed. They are also subject to (and accept) enormous pressures to not upset
the funding agencies; plus many _other_ "highly qualified scientists" have
found other more satisfying things to do since the crunch of the late
'60s/early '70s, and the 1972 BEIR that was recognized in the Washington
nuclear community as the "Budgetary Effects of Ionizing Radiation" report! Of
course other "highly qualified scientists" in radiobiology are kept out of the 
room when the anointed are entertaining ideas and writing reports. (This isn't 
new; the data and the process has been seen in HPJ and HPS Newsletter for the
last 20+ years! Also consider some of the knowledgeable Bureau of Rad Health
scientists that didn't fit the mold of those days. We shouldn't pretend that
the current "concurrence" on the linear hypothesis in the establishment wasn't 
accomplished by eliminating those who didn't concur!) 

Do you forget the threat to the HP and research communities when AEC and JCAE, 
and the Oak Ridge, Argonne, and other science communities, were  increasingly
confident in the effective thresholds seen in their data (though not directly
reported in the literature they defined the baseline research designs) and the 
winds were blowing with substantial reductions in funding in both areas; with
Morgan and others complaining about AEC and Oak Ridge management to JCAE/AEC
critics in Congress and elsewhere that the public and workers were being put
at risk (contributing in some small way to, or just taking advantage of, the
post-Watergate sentiment that led to the demise of JCAE and AEC, working with
the anti-nuclear interests that created political coverage for continuing
work, feeding the anti-nuke critics, then having to fight to keep the whole
ship of nuclear programs, weapons, power, and many other programs, from being
taken down)? 

> they are not selected by bureaucrats, nor are they a cabal of

Interesting. It had never occurred to me that the labs are not run by and
staffed by bureaucrats, directly accountable to funding agency bureaucrats.
Few have the independent scientific standing to withstand job and funding
pressures by drawing independent funding (especially contrary to the primary
mission programming), nor would their appointing managements be responsible in 
allowing such conflicts to affect lab and program funding. Many university
programs are little removed from the same pressures, with the option
(personally and programmatically) to find different work from other funding
sources, but there is little substantial funding of contrary work in
radiobiology (much to the loss of the profession). 

> antinuke conspirators whose job it is to bury epidemiological studies

They are certainly not anti-nuke! They know the justification for continued
work is the continuity of nuclear science and technology. They fight the
Gofmans and Sternglasses with high purpose (within the Federal agency bounds). 
They have had to work hard, with great knowledge and understanding to maintain 
that balance! 

> that don't show a link between cancer and radiation. The selection of

Well, on the other hand, this one isn't true on the simple test of evidence.
See how BEIR dispatches high quality work in favor of ourageous
rationalizations; how programs and people are redirected; how junk like that
funded by the bureaucracy by Steven WIng (a sociologist with a statistics
course and an anti-nuclear ax to grind) gets published and used to "balance"
the integrity and work of serious scientists, and even giants that get ignored 
by NCRP and BEIR. Where did anyone ever respond to Evans 1974, Frigerio's 1973 
Argonne work on the Argonne Radiological Impact Program, and with his towering 
scientific insight and integrity he was put in a box til he died, while other
lesser scientists succeeded very well (consider his observations in the '70s
about the degeneration of a science that had earlier brought in the best, but
was then being rejected by the best because of the evident willingness of
programs to abuse the data in favor of following the funding). 

Where is Sir Richard Doll's 1981 report on the British radiologists; the
Guangdong Province High Background Area, the Japanese survivor data, the
medically-exposed population data, etc. The Argonne CHR gets defunded because
it is too significant to get just redirected (though that happened over 10
years as people and results were contained) as usually happens (even though it 
had substantially obfuscated its data vs. the Evans MIT work). 

Then suffice to say that hundreds if not thousands of quality studies are
explicitly ignored - too many to just happen by accident. Uranium miner data
has been misrepresented, and work to qualify the data with little effort
unfunded, right there in Oak Ridge! It goes on and on. 

(Don't you always find it interestng that when good proposals don't get
supported - and studies like Argonne, or the 5 rem study at Oak Ridge! get
redirected or defunded by "management" - the technical community chalks it up
to the poor, stupid, untutored, technically deficient, managers, instead of
recognizing that the managers know exactly what they want to see and don't
want to see, and the funding and program decision (and publishing, and
technical review morass) is a direct result - and, by the way, the message
about what gets funded gets through loud and clear, and people are busy doing
something else and forget all about it, and no one ever knows there was some
important science that didn't done, or data that didn't get reported, or...) 

> Charlie Meinhold, as president of the NCRP should indicate as much). 

Dr. Meinhold is a quality person and scientist, but like all of us must
support the right answer as defined by the position he holds. I don't think he 
is not working on the truth as he sees it. He, like all of us, is working from 
the cards he is holding. He will and should go at these matters with good
faith and integrity, supporting the model he is wedded to, until the weight of 
the evidence, and the underfunded substantial work that is now going on that
will undermine that structure in biology research and some epidemiology (that
isn't as subject to being as suppressed as the directly funded radiobiology)
does its work and the structure falls as it must. 

I don't have the same sense of honest purpose and integrity in the high
echelons of the funding agencies. They select people and programs and funding
to meet their needs for the purpose of enhancing their agency power and
authorities, feeding and responding to political winds that carry those funds
and authorities, and misusing the science from the scientists to establish
costly, onerous programs. (Do you remember those notes from EPA HPs and
scientists who characterized the agency management as lawyers and english
majors who draft the rules with minimal consideration of technical input
except to refine the terminology and rationalizations? Although, of course,
they are supported by others from grad programs with research funded by agency 
funds that support agency interests and directions. Have you not seen the RFPs 
and grant programs? How do you do good science when the funding opportunites
pretty much pre-ordain the results?) 

The near future should be seen as the great liberation to the radiation
scientists since work on establishing a balance and application of nuclear
science and radiation to great new endeavors will be made possible. There will 
be dislocations in the shift away from simply spending a lot to try to
discredit solid work (like the commitment to discredit Bernie Cohen's solid
radon work with trivial rationalizations that "ecologic studies aren't good"
then getting funding for a study about trivial radiation releases into a small 
population and arguing that the effect of nuclear facilities can be seen); or
doing yeoman service to ALARA paperwork and recordkeeping requirements that
are essentially meaningless in protecting public health and safety. 

Achieving a balance, especially with the biology that is confirming the repair 
mechanisms and the opportunities to expand radiation applications in very
sophisticated ways to human wellbeing (how do you manage health and radiation
protection if 15 rem reduces breast cancer and increases Down's syndrome; and
50 rem  increases leukemia and increases longevity?) Of course, I've always
wondered how HP rationalizes substantial cost to limit exposures to a few
mrem, to workers who get annual chest x-rays, dental x-rays, have 6-10 x-rays
taken when they have a suspected broken bone; and throw people out a hospital
emergency room when a portable x-ray machine is run 20 feet away (last week my 
daughter had 8 x-rays on 2 campaigns - chest then abdomen - because of
undiagnosed pains, then they covered her with a lead apron 3 beds away from a
portable x-ray machine taking a chest x-ray on an elderly patient!?) or work
in the Colorado plateau and go skiing and mountain climbing for recreation?
But who am I to question? :-) <snip> 

> Best of luck
> 
> Paul Frame
> Oak Ridge Associated Universities

Thanks.

Regards, Jim Muckerheide