Re: Is radon as dangerous as the EPA says?

["ALDEN N TSCHAECHE" <XAT@inel.gov>]

I'm a little confused about one of your paragraphs. It's the one
starting "I'm not sure about that. The EPA radon model ..."

The EPA states categorically that 20,000 deaths per year from lung
cancer in the USA are caused by indoor radon. So - their model predicts
that number of deaths. Their model doesn't predict "no increase in lung
cancer should be detectable for the radon levels to which people are
exposed in the vast majority of residences." If you could give me a
reference for that quoted statement, I would appreciate it muchly. With
respect to your definition of "health hazard" number 3 -- It is
impossible to demonstrate that any agent is absolutely safe. Those who
are in camp number 3 are not living in the real world (even though they
vote). We should do everything in our power to tell the public that they
can't have number 3.

As for number 2, the only body that can establish an acceptable risk
level for the US is Congress. Although EPA is driven by Congressional
Law, EPA has interpreted the law when it assigns a numeric value to
acceptable risk. Congress has never mandated a numerical value of
acceptable risk. Someone should challenge the EPA's numerical value in
the Supreme Court to see if it is constitutional. I'll bet the Court
would say "no."

That leaves number 1 as the only rational idea. Now, we all know humans
aren't rational exclusively. Even I upon occasion will let my emotions
dictate action. However, rationality is the only thing that makes sense
in this argument. Running on emotion costs too many dollars. So -- I
repeat - we should establish a value such as 5 rem per year as safe and
wait until data demonstrate non-safety. That is the ONLY rational thing
to do. Anything else involves emotions and value judgements that can
only get us into trouble, as we see has happened. Soapbox closed. What
are the other alternatives to: 1. leaving things as they are and 2. 5 rem
per year is safe? I haven't seen any yet in this "debate?" Al Tschaeche

xat@inel.gov

*** Reply to note of 01/18/96 13:27

From: John Moulder
To: RADSAFE --INELMAIL RADSAFE

Subject: Re: Is radon as dangerous as the EPA says?
> The main point is that radon at ordinary levels is not
> a health hazard.

What does "not a health hazard" mean?

1 -- To many, it means no statistically significant effect (at the levels to
which people are actually exposed) in reasonably designed studies (lab or
epi).

2 -- But this is not everybody's definition.  At the other extreme, the EPA is
willing to declare something a health hazard based on extrapolated risks of as
low as 1 in 10^5 (or is it 1 in 10^6?).

3 -- There are also many people in this world who are willing to label
something as a health hazard on basis of the absence of data proving absolute
safety (look at the power line cancer controversy).

> Bernie's work gives strong evidence that supports
> that conclusion.

It does is you use the first definition of a "health hazard", but not if you
use the other two.

> It strongly contradicts the LNT model no matter how
> you look at it.

I'm not sure about that.  The EPA radon model predicts that no increase in
lung cancer should be detectable for the radon levels to which people are
exposed in the vast majority of residences.  How can you "contradict" a model
that predicts "no detectable effect"?   Arguably, the only way to contradict
the model would be to show a threshold.  But if you really believe that there
is no lung cancer risk associated with residential radon, you cannot
contradict the EPA model.

> I have long sought a published debate on the LNT model. It
> is urgently needed. The short anti-LNT articles in the June '95
> HPS Newsletter and Dan Strom's long pro-LNT article rebutting them was
> not a debate in any sense.

Agreed, and in a more widely distributed forum than the HP Newsletter.  I'd
suggest HP itself.  Alternatively, if anyone want's to make a specific
proposal I will take it to the Rad Res Editorial Board.