Editorial on EPA Proposed Federal Guidance

[Ken Mossman <Ken.Mossman@asu.edu>]

Colleagues:

This editorial concerning the EPA Federal Guidance Report 13  and the
LNT debate may be of interest. It was published May 14 in The Arizona
Republic. Any comments would be welcomed.

EPA GUIDELINES WASTE FUNDS, BASED ON FAULTY SCIENCE
Small doses just aren't harmful

Billions of dollars of public funds may be expended needlessly to comply
with overly restrictive regulations for environmental clean-up and waste
disposal unless the EPA's proposed Federal Guidance on "Health Risks
from Low-Level Environmental Exposure to Radionuclides" is revised to
reflect current scientific understanding. A new Bill in Congress may
force the EPA to do just that.

This EPA report provides federal agencies and other organizations with
consistent methods for the assessment of cancer risks from exposure to
100 different radionuclides in the environment. Cancer risk estimates
are expressed on a per disintegrating atom basis. By expressing risk in
this way, the EPA perpetuates the philosophy that any radiation dose, no
matter how small, is potentially harmful. 

The EPA's position is not supported by current science. During the past
50 years, a large body of scientific information shows that large doses
of ionizing radiation can cause cancer in humans. Increases in cancer
have been detected only when the radiation dose exceeded 10,000 millirem
given in a short time. For comparison, airline passengers safely get
only about 5 millirem traveling from New York to Los Angeles. Patients
get 50 millirem from some medical x-ray procedures--also a safe dose.
The EPA's report would have you believe that 1 millirem is harmful. 

Radiation standards to protect the public have been established at doses
where little information about radiation-induced cancer is known.
Detecting an increase in cancer due to low-level radiation is difficult
because cancer is a common disease with many different causes. According
to the American Cancer Society, cancer is the second leading cause of
death in the U.S. resulting in more than 500,00 deaths annually.
Approximately one in 5 Americans will die of cancer. 

In setting radiation standards, the Environmental Protection Agency, the
Nuclear Regulatory Commission, and other nuclear regulators assume that
any radiation dose, no matter how small, might cause cancer and the
number of cancers produced is in direct proportion to the radiation
dose.  Regulators use this linear, no-threshold philosophy in the
standards setting process to predict numbers of cancers due to exposure
to low level radiation. 

However, recent scientific studies suggest that this approach is overly
conservative, leading to excessive regulatory compliance costs. Low
level radiation may be less dangerous than commonly believed. In one
study of the costs and benefits of federal social regulation--
regulations aimed at reducing occupational safety and health risks--
imposed compliance costs of about $9 billion annually for negligible
risk-reduction benefits. Less restrictive standards would save the
public billions of dollars without compromising the public health or
safety.  Nonetheless, proponents of current standards argue that risk
conservatism is justified because it is prudent public health policy and
low-level risks remain uncertain.

If the linear, no-threshold philosophy is unacceptable, what should be
the basis for standards setting?  Alternative theories to predict risk
at low dose are as difficult to justify as the linear no-threshold
model. There is no requirement that standards be based on any predictive
model. Exposure limits could be based on the average natural background
level to the U.S. population     (about 200 millirem per year).
Scientific studies of populations around the world exposed to background
levels several times the U.S. national average have not detected
increased health effects due to background radiation.

How the linear, no-threshold theory debate will be resolved is anyone's
guess. Prominent organizations such as the Health Physics Society and
Canada's Advisory Committee on Radiological Protection have questioned
the validity of the linear no-threshold theory; the International
Commission on Radiological Protection continues to support it.  The
Environmental Protection Agency and the Nuclear Regulatory Commission
are unlikely to make any decisions to continue using the linear
no-threshold theory in setting limits until the National Council on
Radiation Protection and Measurements and the National Academy of
Sciences have completed their independent reviews and offer
recommendations. That could take one or two years. 

Regardless of how occupational and public exposure limits are set, they
should be based on the best scientific information currently available
and sound policy judgements. However, a dozen federal agencies have
responsibilities for setting nuclear standards. These agencies operate
under different laws, which may result in conflicting, duplicative or
overlapping regulations. Nuclear regulations to protect the unborn child
are in conflict with regulations to protect the general public. Nuclear
Regulatory Commission regulations limit exposure of the unborn child of
a pregnant worker to 500 millirem but exposures of members of the
general public are restricted to 100 millirem per year. The
Environmental Protection Agency, Nuclear Regulatory Commission, and
Department of Energy have all issued duplicative limits on public
exposure to radiation.

The EPA Federal Guidance report is a good example of the need for
legislation such as HR 3234 that addresses the requirement for good
science as a foundation for regulatory decision-making. The Science
Integrity Act was introduced in the U.S. House of Representatives in
February and requires the EPA and other regulatory agencies to have
outside expert review of scientific data used in support of regulations.
HR 3234 requires that reviewers be provided with all scientific data in
support of the proposed regulation and any other related data requests.
Reviewers' analyses are subject to public comment. The proposed
legislation also provides for the establishment of the Office of
Regulations Integrity with authority to review regulations issued by
each department or agency. Although the EPA Federal Guidance is not
"regulation," it may be used in rulemaking.    



Kenneth L. Mossman is professor of Health Physics and Director, Office
of Radiation Protection, Arizona State University, Tempe



Kenneth L. Mossman
Professor of Health Physics
Director, Office of Radiation Protection
Arizona State University
Campus Box 3501
Tempe, Arizona 85287-3501
Phone: (602) 965-6140/0584
Fax: (602) 965-6609/991-4998
E-mail: ken.mossman@asu.edu