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Re: HPS Position Paper



Bob Atcher writes:
 
> >Date:          07 Mar 1996 11:25:11 MDT
> >Reply-to:      <XAT@inel.gov>
> >From:          "ALDEN N TSCHAECHE" <XAT@inel.gov>
> >Subject:       Re: HPS Position Paper
> >To:            ratcher@creative.vprua.uab.edu
> >
> >
> >That may be true. BUT, if enough of us talk to enough others about the
> >HPS Position Paper and its meaning, and, if enough of us communicate
> >with our elected representatives about the Paper and its meaning, we can
> >change the politics. WE must make the difference now that we have a tool
> >to use. Let's use it!! Otherwise all of the work that went into writing
> >and issuing it will have been for naught.Al Tschaeche xat@inel.gov
> >
> 
> Okay, let me continue to play devil's advocate.
> 
> To date, it appears that you are preaching to the choir.  And, given the 
> fact that the HPS paper is one page long, why wasn't it posted here since a 
> fair number of the choir members can be found here.

First, this is not really just speaking to the choir. Too many 'HPs' are
unknowledgeable about the basic truths behind the words in this position
statement. It is important for the leadership and science experts to
communicate FIRST with the HPS' own membership on bringing this "perspective"
(I disagree with that term in the statement since this is closer to new
fundamental knowledge for many, though is indeed a new 'perspective' for those 
knowledgeable enough of the science behind previous HPS positions) to low-dose 
health effects data and policy issues. 

> You say we will communicate with our elected representatives.  What are we 
> going to tell them?  Abolish agencies or programs within agencies?  Repeal 
> laws?  What is the strategic plan for this initiative?

First, we have to speak to the HPs, the industry, other societies, and others
of our "friends" who themselves believe the "any radiation is harmful"
fiction. We need the underlying information. Then we can really speak to our
"elected reps" (though we should be speaking to our rep "friends" to
"translate" this statement as it affects various issues). 

But even then, there really needs to be some discussion within HPS and related 
societies about what this means for specific issues, like environmental
cleanup, release limits, occupational ALARA, etc. (And to see this is an
opportunity for the HP to become more professional. NOT to see that this
reduces HP jobs (since the HP must still know what people are exposed to, to
know the releases, etc, and to plan and conduct work accordingly). The
"savings" is in reducing the unnecessary requirements on the workers, on the
processing, on the waste volumes, etc. 

HPs must develop the basis to train workers in the basics of the fundamental
knowledge on radiation and health that is behind/embodied in this position
statement. HPs need to take a new look at the RIGHT rad protections and
controls, instead of mindless "dose reduction", at massive cost, for no
public/worker health and safety benefit, (while destroying the role nuclear
science and technology play in human welfare, in energy, medicine, etc.) 

> And what will the tactical plan be when groups like the NRDC start 
> screaming about the risk to the public if we implement these 
> recommendations, whatever they are?

First, do the homework, develop supporting materials. I recommend that the
underlying data that Wade Patterson and others put together in initiating this 
effort, and at the stage especially of the discussions at the July 96 HPS
meeting, that were used by the SPI in producing this statement should have
been, and now should still be, published in the Newsletter. They should be
produced in supplemental materials that should be available to all in the HPS
and related societies and industry managements, plus gov't agencies and the
public policy infrastructure. 

This should include, eg, the GAO re their report on the vagaries of
differences in Fed agency rad protection standards by a factor of 47,000.
They, and their audience in Congress and the Admin need to understand that the 
need is NOT to presume that this discrepancy generally means a need to ratchet 
all rad protection standards to the most limiting in current practice, but
that the most constraining, at least those that are most constraining at
significant cost, should be relieved! HPS should identify the application of
this statement to each of the rad protection standards that are listed in the
GAO report. The summary technical basis, both for the statement re the health
effects data (after all these 'limits' are still very conservative), AND the
comparison of the GAO-identified standards and natural radiation
sources/exposures make it very clear that backing off on standards does not
have any cost or risk to public health and safety. 

It is necessary to see this statement as a starting point for HPS and others
in doing the next stage within their own agendas to make this statement mean
something. It is not a "magic bullet" to take to "the government" and expect
changes to "happen", or to deteat the NRDC campaign. The general public is
consistently with us when the "perspective" is put in concrete terms. They
will not be swayed in iota, nor should they, when a "position" or "policy
statement" is produced. The public is not irrational. They are listening to
the misrepresentations that a few mrem is hazardous because gov't and the HPS
tell them all the time, in word and most effectively in every day action, that 
any radiation is hazardous. That needs to be changed. 

> The reason why I am bringing this up is simple.  The Institute of 
> Medicine/National Academy of Sciences just released a report recommending 
> that the NRC withdraw from regulation of medical activities.  In that 
> report they make specific recommendations for action both at the 
> congressional and state level with a designated agency to oversee the 
> process.  With that report in hand, I spent Thursday on Capitol Hill making 
> calls on the House and Senate side lobbying for some concrete action on 
> this report.
> 
> The fact that HPS has constructed a position paper is laudable, but 
> useless.  Take a look at the IOM report, specifically the recommendations.  
> I would suggest that the first plan of action is to call for a NAS panel to 
> investigate the need for regulatory oversight at the levels outlined in the 
> position paper.  THEN, you can use the NAS report as justification for 
> regulatory and legislative relief.

I recommend "that the first plan of action is to call for" the HPS to produce
documents on  the basis that supports the statement and get those out to its
own members, in training materials (remember the need is also to get this into 
the HP curricula in many universities tha provide no fundamental education on
the radiobiology and epidemiology that support theseconclusions), AND to work
on documents about specific areas, "cleanup" standards, release limits,
medical procedures, ALARA, etc, etc, on what this policy statement means for
cost-effective public health and safety in the practice of HP and in the
writing and implementation of regulations, AND to carry that information to
the NCRP/BEIR/Fed agencies, etc before taking on a more explicit "public
debate" and calling for an "NAS panel" (called BEIR !?) "investigate". 

In fact, since BEIR VI and BEIR VII are in process, HPS and other societies
should work expeditiously to produce the input that these panels need from HPS 
and other societies. It is fundamentally wrong to just drop this in front of
these gov't/EPA-funded and led efforts to produce a "recommendation" that will 
continue to ignore the data and reach "linear model" conclusions (see eg BEIR
V and NCRP Report 121). Also note that BEIR V chair Arthur Upton is now
heading the NCRP Committee to reexamine the "linear model". 

These efforts can only succeed if there is substantial input and
accountability to these efforts, not to be left, as the President of the NAS
stated in 1993, to "undue influence from the funding agencies". They need
outside attention and contributions, not a blank charter to continue "business 
as usual". That's what's gotten us where we are, as Marvin Goldman wrote in
the Feb 95 HPS Newsletter, a $Trillion to "cleanup" our nuclear backyard for
negligible public health and safety benefit (and negligible gives it the
benefit of the doubt). But $100s Billions are going for similarly negligible
public health and safety  in other areas throughout while destroying the
contributions (and the goose) of nuclear science and technology applications
otherwise. 

> As it stands, the position paper provides no impetus for the objectives 
> that you have outlined.

It does have impetus for the actions needed to achieve the objectives. What's
needed now is the will to act to engage the knowledgeable science community,
all the affected societies, to produce the material you seek, first for HPs,
industry and public policy analysis audiences who don't really know the basis
for this statement, including BEIR and NCRP, then for the Congress and the
public. 

The organization of the "Radiation, Science, and Health" science and public
policy group, including founding members from HP, ANS, ACNP/SNM, AAPM, and
other societies, with international participation (esp. Europe, Japan, and
China), will be carrying on this effort to salvage the role radiation science
and nuclear technology can provide to human welfare (and stop "killing the
goose" and being well paid to dig the grave of a healthy victim of political
wars). The HPS is a leading contributor to formulating the scientific and
policy basis for re-capturing reason in the formulation of rad protection
standards. Contributions and participation from biology and the many
independent scientists and analysts outside HPS, ANS, AAPM, ACNP, etc., are
critical to bringing this evidence forward. I can provide information on this
effort, HPS contacts, etc., as the group is formalized. Any potential
technical contributors are also welcome, including member interest. 

> Bob Atcher

Regards, Jim Muckerheide
jmuckerheide@delphi.com