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LNTM data for EPA
Mark:
EPA itself has declared the LNTM to be in valid, but it is EPA policy to use
it for rulemaking and assessments.
Here's a quote from the Federal Register to substantiate this statement.
Excerpt from: Federal Register 56 (138) 33050-127,1991
"The Scientific Advisory Board (SAB)/Radiation Advisory Committee (RAC)
urged the Environmental Protection Agency (EPA) to base its risk assessment
for radium on human epidemiology data on radium watch dial painters, rather
than on modeled estimates, and urged EPA to present its rationale for
adopting the modeling approach for radium risk assessment. The SAB/RAC also
requested that EPA better describe its dosimetric model in the revised
criteria document, including calculated doses and risks to organs, and that
if EPA continued to use the modeling approach, uncertainties in the modeling
be addressed.
EPA Reply:
The Agency carefully reconsidered this issue. First it should be pointed out
that all risk estimates are based on both epidemiologic data and require
mathematical modeling. The EPA uses the wealth of epidemiologic data on
human exposure and risk of radiogenic cancers, including radium dial painters
and epidemiologic data on bone sarcomas resulting from injection of Ra-224.
The watch dial painter data indicate that the incidence of bone sarcomas may
follow a dose-squared response, especially at higher exposures. EPA policy,
supported by recommendations of SAB/RAC, is to assess cancer risks from
ionizing radiation as a linear response. Therefore, use of the dial painter
data requires either deriving a linear risk coefficient from significantly
non-linear exposure-response data, or abandoning EPA policy and SAB/RAC
advice in this case."
Not only are the radium dial painter data non-linear but also other human
data and observations. Here are some references.
Selected references showing a downward trend in the exposure-response
relation
1. Craig,L.; Seidman,H.
Leukemia and lymphoma mortality in relation to cosmic radiation.
Blood 17 : 319, 1961.
2. Frigerio,N.A.; Ekerman,K.F.; Stowe,R.S.
The Argonne Radiological Impact Program (ARIP), Part I.
Carcinogenic Hazard from Low-Level, Low-Rate Radiation;
ANL/ES-26 Part I, Environmental and Earth Sciences, Sept. 1973.
3. Frigerio,N.A.; Stowe,R.S.;
Carcinogenic and genetic hazard from background radiation.
IAEA Symposium, Biological and Environmental Effects of Low Level Radiation,
vol. 2, pp 285-289, Vienna, 1976.
4. Spalding,J.F.; Thomas,R.G.; Tietjen,G.L.;
Life span of C57 mice as influenced by radiation dose, dose rate and age at
exposure.
Report UC-48, LA 9528, Los Alamos National Laboratory, Los Alamos, 1982.
5. Abbat,J.D.; Hamilton,T.R.; Weeks,J.L.
Epidemiological studies in three corporations covering the Canadian nuclear
fuel cycle.
pp 351-361, Biological Effects of Low Level Radiation. IAEA-STI/PUB 646,
International Atomic Energy Agency, Vienna, 1983.
6. Haynes,R.M.
The distribution of domestic radon concentrations and lung cancer mortality
in England and Wales.
Rad. Prot. Dosim., 25, 2, pp 93-96 1988.
7. Gilbert,E.S.; Fry,S.A.; Wiggs,L.D.; Voelz,G.L.; Peterson,G.R.
Analysis of combined mortality at the Hanford site, Oak Ridge National
Laboratory, and Rocky Flats nuclear weapons Plant.
Radiation Research, 120 : 19, 1989.
8. Wei,L.X.; Zha,Y.R.; Tao ,Z.F.; He,W.H.; Chen,D.Q.; Yuan,Y.L.
Epidemiological investigation of radiological effects in high background
radiation areas of Yangjiang, China.
Journal of Radiation Research, 31, 1, pp 119-136, 1990.
9. Dousset, M.
Radon in dwellings.
Aerobiologica 6:36-38, 1990
10. Nambi,K.S.V.; Soman,S.D.
Further observations on environmental radiation and cancer in India.
Health Physics, 59, 3, pp 339-344, 1990.
11. Wing,S.; Shy,C.M.; Wood,J.L.; Wolf,S.; Cragle,D.L.; Frome,E.L.
Mortality Among Workers at Oak Ridge National Laboratory.
JAMA, 265, No. 11 p. 1397, March 20, 1991
12. Jablon,S.; Hrubec,Z; Boice,Jr.;J.D.
Cancer in Populations Living Near Nuclear Facilities.
JAMA, 265, No. 11 p. 1403, March 20, 1991.
13. Chen,D.; Wei,L.
Chromosome aberration, cancer mortality and hormetic phenomena among
inhabitants in areas of high background radiation in China.
Journal of Radiation Research, 32 Suppl. 2, pp 46-53, 1991.
14. Matanoski,G.M.
Health effects of low level radiation in shipyard workers.
E 1.99 DOE/EV/10095-T1 and T2, DOE Washington, 1991.
15. Kendall,G.M.; Muirhead,C.R.; MacGibbon,B.H.; et al.
Mortality and occupational exposure to radiation; first analysis of the
National Registry for Radiation Workers.
Brit. Med. J. 304:220, 1992.
16. Shihab-Eldin,A.; Shlyakhter,A.; Wilson,R.
Is There a Large Risk of Radiation? A Critical Review of Pessimistic
Claims.
Environment International, 18, pp. 117-151, 1992.
17. Latarjet, R.
Radiation carcinogenesis and radiation protection.
Cancer J., 5, pp 23-27, 1992.
18. Cohen,B.L.
Test of the linear-no threshold theory of radiation carcinogenesis for
inhaled radon decay products. Health Physics, 68, 2, pp 157-174; 1995.
Everyone knows that BEIR and UNSCEAR have manipulated and selected the
Japanese data and then fitted it to the Linear Model. They state such in
their various reports.
However, the data don't fit the Linear Model as evidenced by this reference.
Schull,W.J.; Shimizu,Y.; Kato,H., Hiroshima and Nagasaki: New doses, risks,
and their implications, Health Physics, 59, 1, pp. 69-75 1990.
Quotation from page 73.
"The lowest specific absorbed dose at which unequivocal effects can be
demonstrated among the A-bomb survivors is 0.20-0.49 Gy."
What many have forgotten is that BEIR and UNSCEAR likewise manipulated and
selected the radium dial data.
Just re-read this reference to see exactly what BEIR and UNSCEAR did.
Evans, Robley D., Radium in man, Health Physics, 27, pp 497-510, 1974.
Please let me know if you want more. This is just a sampling
H.Wade Patterson