Re: Dose Standard Setting

[xat@inel.gov (Alden Tschaeche)]

Christepher A. McKenney wrote:
> 
> NCRP does not set the Federal Standards for permissible
> dose limits.  The standards are set under the power of the
> former Federal Radiation Council, whose powers were
> transferred to EPA when EPA was created.  EPA will
> publish a draft rule based on recommendations by groups
> such NCRP and ICRP but the standard is put through public
> comment.  After the standard goes final, with any changes
> as necessary due to public comment, other Federal
> Agencies will modify their implenting regulations (such as
> was done by the revising of 10 CFR Part 20 to meet the new
> occupational dose limits and dose methodologies set forth
> in the 1987 EPA dose standard).  These regulations again
> are public rulemaking and may be commented on by the
> public.  At this time, the EPA has not actually finalized (to
> my knowledge) the Federal Radiation Protection Guidance
> for Exposure to the General Public it noticed in the Federal
> Register on December 23, 1994.  The previous Standard
> setting for the Public was in 1960.

An excellent summary of the system.  The only problem with the system is
that the general public doesn't even know the Federal Register exists. 
All of the governmental machinations as described above don't really get
public input.  All the govt. agencies slavishly follow NCRP
"recommendations."  So it is the NCRP that really sets the standards no
matter in what language the documents are couched.  

ANSI, on the other hand, has an extensive system for obtaining public
input into its standards.  Admittedly, not many of the public know of
the system.  But it is better than the Federal Government's.  After all,
in the USA, the private sector is the place where standards should be
made, not the Government.  The Government even says, in OMB Circular
119, that all government agencies should use voluntary (e.g.
ANSI/ASTM/IEEE/etc.) standards whenever they are available.

ANSI is the place where radiation protection standards should be
developed.   Al Tschaeche xat@inel.gov (90 minutes left)