Re: Low doses- opinion

[Lester.Slaback@nist.gov]

An OPINION, possibly contrary .....

>David Lee said, AND, very well ...

>> As a point of further discussion, I think it might be interesting to
>> discuss the WHY of why do we in the ionizing radiation safety field NEED to
>> have a separate dose limit for the public at all?  

Sandy replies ......
>The answer lies in the fact that an occupational worker accepts the  risk
>for doing the work, the risk compared to the benefit. 

While this is the historical rationale I suspect in today's legal
environment no worker would be considered free to make an unfrettered risk
choice.

Further, prior to 1994 NRC and most other regulators simply classified
anyone in the geographical vicinity, i.e., in the restricted area, as
occupationally exposed and subject to that dose limit.  It was not until
the creation of the definition of  'public dose' that this position was
recognized as silly and the definition of occupational dose was changed so
that it was not linked to geography. But even today most folks classify
workers based on geographic proximity rather than function.

In fact, from the point of benefit one could argue that large fractions,
if not the totality, of the 'public' benefit from the radiation uses and
hence occupational limits should be equally acceptable for them (subject
to the same ALARA processes as long as LNT is presumed).

So the point is that the Justification Principle is really a bit of
fiction in the current regulatory environment.  So why shouldn't there be
a single limit (set of limits) regardless of work status, with the limits
simply reflecting risk (age, pregnancy, etc) as Dr. Lee suggests?


                                                                                    >The
rub is  . WHAT >risk???  Perceived risk, yes ... Regulator assumed risk,
yes  ..  >Individuals and entities who prosper when they can continue the 
idea >that there IS risk, yes ...    Someone is profiting, someone 
continues >to receive grants to conduct research, someone gets to sell 
more >newspapers and TV time .. all based on this "risk" ... In  reality,
there >is NO risk ... If there really were a risk, then it  would make no
sense >to exclude some radiation and include others. 

Clearly there is 'no sense' in excluding natural exposure.  Clearly this
historical baggage had practical and political beginnings.  But this
historical precedent is not a basis to assert no risk exists.

                                                                                     >
Radiation exposure is >exposure, no matter where it originates from. 

Agreed, and for much less money we could achieve much larger dose
reductions in the home than we can in our work environment (assuming these
person-rem were of equal interest to the political bodies).  Note that I
did not say regulators since they only control what they are told to
control and I did not say those home exposures represent a risk.

                                                                                        >
What we see is which >groups in society wield the power ... medical is 
excluded ... should it? >Isn't that where the majority of the GSD is 
derived? 

If there is one area where individual benefit can be identified it is
presumably the medical arena.  And clearly if one were to control this one
could not do it on an absolute risk basis.  For certain conditions even
lethal exposures could be, and have been, justified.  So this arena is not
germane to the above discussion <IMHO>.

                                                                                               >If
there really is >a risk, then it should be accounted for.  

Perhaps.  I grew up in the west and carry the personal baggage of a belief
in personal freedom of choice.  I object to big government controlling my
life except where it is needed to control those entities that I cannot
control, i.e., big, bad business and government bureacrats.  So I would
not take it as a given that all dose/risk must be accounted for.  There
are  benefits to a certain amount of ignorance.  So this assertion is
really one that needs to be decided via a political process.

                                                                                   >But,
there is no risk, and LNT >needs to be abandoned, and rational 
regulations need to be implemented >and the ungodly amount of $$$  being
spent need to be funnelled to making >improvements where they are  really
needed. That isn't in dose reduction!

Presumably we can agree there is risk at some level.  Hence there will be
regulation at some level.  Given that one is simply bargining over the
price. Even if there is a threshold presumably some dose increment above
that threshold would be acceptable.
Even if you changed the dose limit to 50 rem I would bet that the overall
regulatory structure would not change that much.  Our technology would
just be much easier.

P.S.
Please do not interpret the above as picking on Sandy's wording.  His
comments simply got a train of thought going that I thought gave an
interesting (to me) perspective on this discussion.  And I could not
resist plinking at the keyboard instead of at a golf ball.

The following most definitely applies!
-- 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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