Re: evolution of regs? -Reply

[Al Tschaeche <ant@pmafire.inel.gov>]

OK.  So how do we get it "fixed"?  Clearly we must respond to the EPA's 
request for comment.  But -- what is the appropriate replacement for the 
linear hypothesis?  We need to "help" the regulators with an alternative, 
not just say the linear hypothesis is wrong.

Al Tschaeche, e-mail: ATSCHAEC@INEL.GOV

On Mon, 6 Feb 1995 JMUCKERHEIDE@delphi.com wrote:

> 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 
>