Re[2]: Is radon as dangerous as the EPA says?

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     In reply to "Is Radon as Dangerous as the EPA Says?"
     
     Remember - these people are the self same people who have determined 
     that 10 mRem/yr should be the "safe" limit for D&D sites.
     
     Any other comments on this?
     
     By the way - This is a very personal opinion and is not the opinion of 
     my employer
     
     R.R.Goodwin
     Ronald_Goodwin@Health.Ohio.Gov


______________________________ Reply Separator _________________________________
Subject: Re: Is radon as dangerous as the EPA says?
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    1/18/96 4:33 PM


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.