Re: To Be or Not To Be

["J. J. Rozental" <josrozen@netmedia.net.il>]

1 - IAEA as well as, ICRP are international organizations, as you know.
Theirs publications reflects  an international consensus on the subject, and
act only as recomendation. The National Authority in the Country has the
responsibility to adopt or not such recomendations. In the case of the BSS
the document was jointly sponsored by FAO, IAEA, ILO, OECD/NEA, PAHO and
WHO, and if you read the contributors to drafting, review, endorsement and
verification you will find 10 pages of names of expert all of the world.

2 -  Among the 11 principles of the Radiation Protection and the Safety of
Radiation Sources, the first principle is the Justification of practices
(IAEA, Safety Series 120, 1966)
"A practice shall be justified on the grounds that it produces sufficient
benefit to the exposed individual(s) and to society to offset the radiation
detriment that it may cause"
"The likelihood and magnitude of exposures expected from a practice shall be
explicitly taken into account in the justification process. The
justification of a practice, however, usually goes beyond the scope of
protection and safety because the radiation detriment is often just one of
many considerations. Decisions on justification are larged influenced by
broader political, economic and social concerns"
"Some practices are not jusfified in terms of radiation protection because
they result in frivolous exposure. Examples of such practices are the
incorporation of radioactive substances into foods, cosmetics and toys"

J. J. Rozental <josrozen@netmedia.net.il>
Israel

===============
At 09:27 AM 11/18/97 -0600, you wrote:
>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>
>
>