To Be or Not To Be

[JMUCKERHEIDE@delphi.com]

J.J. Rozental <josrozen@netmedia.net.il> notes represent the failure of the
science, policy, and integrity of radiation protection represented by the IAEA 
BSS: 

> The main question with this subject is about the justification of this practice:
> For justification one can understand "No practice or source within a
> practice should be authorized unless  the practice produces sufficient
> benefit to the exposed individuals or to society to offset the radiation
> harm that it might cause; that is:  the practice is justified, taking into
> account social, economic and other relevant factors"

This statement is a political statement that addresses authority with no
consideration of safety and risk. It may be made and reinforced by a political 
organization. It is scientifically indefensible and purely self-serving. It is 
irresponsible and unenforceable, and any attempt to apply/enforce it must be
seen as pure self-serving political opportunism. This kind of action is
leading to substantial question of the integrity of the role of the radiation
protection professional and institutions. 

First, this has nothing to do with the fact that the self-serving linear model 
"risk" being used to support these statements is a pure fiction. Even if there 
were a risk at low doses, this policy has no integrity. This policy is the
equivalent of addressing the most significant public health and safety issue
in modern society, motor vehicles, which does have a "linear model" risk,
"deaths per meter", by automotive engineers and safety professionals as
promulgating rules that do not address crash worthiness or speed limits, but
rather states that "no use of a motor vehicle should be authorized unless the
use provides sufficient benefit to the operator or to society to offset the
safety risk to  individuals (the operator, passengers, other
vehicles/occupants, pedestrians, and persons in residences and commercial
establishments in proximity to roadways)". This doesn't even address the more
justifiable rules that could control vehicle power and speeds to within speed
limits, or to put recorders and transmitters in vehicles to send road/vehicle
data to police who would confiscate your car if you had exceeded posted
limits. At what point does the rad protection military police mindset begin to 
break down? 

Such policies can be enforced by a military dictatorship, but in technical and 
political society, people can and should have fundamental rights and freedoms
that preclude the imposition of such a mandate, as even a politcal statement,
much less a scientific/technical statement. Millions of people use radiation
in many different ways. It is the responsibility of the science/technical
community to provide for basic safety information and rules. The use that
persons make of radioactivity can not be the basis for justifying approval of
its use, any more than you need to "justify the need" to drive on the highway, 
or to be refused the right to use your car for simply pleasure, or going to
entertainment, rather than for transport of essential goods and services and
employment. This policy is simply a typical self-serving attempt to impose
autocratic authority and its associated funding in the hands of any power
elite for despotic authority. 

As a more practical matter, when you close down the radon health spas of
Europe, Japan, US, etc, then you can justify arguing that irradiating
gemstones, which is done to enhance their esthetic and commercial value which
has more "justification" than driving for pleasure, unless you make the
equivalent argument that there is no justification in making/enhancing
gemstones as a commercial enterprize in the first place since they are for
purely aesthetic adornment. 

As a separate matter of the merits of the discussion, it has been disturbing
to see the large absense of discussion about safety and risk regarding the
irradiated gems, even the lack of distinction between neutron and gamma
irradiation, and instead discussing only "authority and approval" and "limits" 
which themselves have little relation to "risk" in much of this discussion
over the last several weeks (except for the obvious significant issues of
irradiating gold or recycling gold from radon seeds). Levels in the range of
naturally occurring materials, including materials used in various consumer
applications, can not be reasonably, arbitrarily, eliminated. 

> The above statement should be applied to all possible consumer products
> containing radioactive substances, specifically to those producing:
> 
> a) Higher  benefit -- Category I (all products specifically designed to
> prevent injury to people and practices involving such products, e.g., smoke
> detector, timepieces and luminous signal)
> 
> b) Lower benefit -- Category II (all other justified products) and
> practices, e.g., lightening conductor
> 
> By the year 90 was proposed to the IAEA The Code of  Practice on Regulatory
> Control of Consumer Products Containing Radioactive Substances. In this
> document was considered that the value 100 Bq/g (CEC),  (~ 2 nCi/g) was too
> high to be considered   as being of no regulatory concern for some consumer
> products, particularly those which may be used close to the body for up to
> 24 hours a day (e.g. Activity concentration of the luminous paint in a
> watch). For these cases much less value was recommended to  be used, as a
> value between 1 to 10 Bq/g, depending of the radioactive substance.   
> In case of gemstones that have been irradiated by neutrons, today, even the
> lower benefit can not be applied since gemstones is an article for personal
> adornment. As a matter of fact, how can a  Regulatory Authority,  after
> justifying the practice in the country, considering the concept of lower
> benefit, to ensure that quality assurance programmes is set up to check that
> released stones are below the level of radioactivity that is of no
> regulatory concern? -- Or such gemstones are  not exported to countries that
> not justify such practices?
> 
> J. J. Rozental <josrozen@netmedia.net.il>