Re: FGR-13

["Otto G. Raabe" <ograabe@ucdavis.edu>]

May 17, 1998
Davis, CA

The risk factors for cancer mortality (deaths) and then cancer morbidity
(occurrence) listed in FGR-13 are based on speculative linear mathematical
models of cancer mortality that can be traced to other speculative
mathematical models based primarily on the Japanese atomic bomb survivor
studies. 

EPA considered the current likelihood of surviving cancers of various types
in estimating the ratio between expected cancers deaths and the expected
occurrence of each cancer type. Specifically, on pages 104-107 of FGR-13:
"To obtain estimates of radiation-induced cancer morbidity, each
site-specific mortality risk estimate is divided by its respective
lethality fraction, that is, the fraction of radiogenic cancers at that
site which are fatal." "A list of lethality fractions recommended in ICRP
Publication 60 (1991) and adopted by the EPA (1994) is reproduced in Table
7.5."

Otto
		*****************************************************
		Prof. Otto G. Raabe, Ph.D., CHP
                [President, Health Physics Society, 1997-1998]
		Institute of Toxicology & Environmental Health (ITEH)
		     (Street address: Old Davis Road)
		University of California, Davis, CA 95616
		Phone: 530-752-7754  FAX: 530-758-6140 [NEW AREA CODE]
		E-mail ograabe@ucdavis.edu