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RE: www fallout (radiation, AIDS etc)
I like the suggestion of ANSI. However, both NRC and EPA standards are
rulemakings. I think it is important to initiate rulemakings in this area.
Clearly only my own opinion
Ruth F. Weiner, Ph. D.
Sandia National Laboratories
MS 0718, POB 5800
Albuquerque, NM 87185-0718
505-844-4791; fax 505-844-0244
rfweine@sandia.gov
-----Original Message-----
From: Al Tschaeche [mailto:antatnsu@pacbell.net]
Sent: Wednesday, February 10, 1999 6:10 PM
To: Multiple recipients of list
Subject: Re: www fallout (radiation, AIDS etc)
This is a multi-part message in MIME format.
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Gerald brings up a nub of the problem. If we don't know absolutely and
without
question that an agent is harmful or beneficial, who makes the decision in
the
regulatory arena? Unfortunately (opinion) for us in the United States, it
is
not our elected representatives. Or even a government agency established by
our elected representatives. But only the NCRP, an organization set up by
our
elected representatives to make recommendations on radiation protection
standards. There is no recourse if the NCRP recommendations are wrong or
result in huge costs. Except, perhaps, to dissolve the NCRP.
Of course most of the government agencies accept the NCRP recommendations
uncritically. The NRC seems to be the only agency that might question the
NCRP
recommendations. I trust that those RADSAFERS who work for or have
influence
on the NRC (the Commissioners particularly) will exert their influence to
see
to it that the NRC critiques the Arthur Upton NCRP Committee 6.1 draft
report
Evaluation of the Linear Nonthreshold Dose-Response Model. The critique
should
include considerations of cost, social implications of not having the
nuclear
industry, etc. as well as the science (non-science) of the information in
the
report. Anyone have any ideas on how to get such a critique done?
Also, should there be a session at the next HPS meeting on that report with
input from disinterested, but knowledgeable, third parties as to their
thoughts and feelings about the information in the report? If y'all think
that
might be a good idea, I would be happy to donate my time to set up the
speakers/panel.
I think a better system would be to have radiation protection standards set
by
the voluntary sector such as the American National Standards Institute
(ANSI).
That way ALL interested parties could participate and consensus reached on
what
standards are appropriate. OMB Circular A119 mandates federal agencies to
use
applicable voluntary standards. If we had a voluntary ANSI standard on
Radiation Health, we wouldn't have the infighting between NRC and EPA (and,
sometimes DOE, etc.) that we currently observe. Obviously, setting up an
interagency committee like the old CIRRPC(?) doesn't work to get interagency
agreement on such things. I forget what the current counterpart of CIRRPC
is,
but I suspect it will do no better.
Gerald Falo wrote:
>
>
>
> Al Tschaeche wrote:
>
> But, to require absolute proof of hormesis or other beneficial
> effect before we can get rid of the LNTH is also irrational and
> irresponsible. We should put the shoe on the other foot and
> require absolute proof of damage at low doses, based on
> acceptable whole human data before we are willing to spend
> limited resources to reduce <doses to very low levels.
>
> Here, he calls into question the rationality and resposibility of
> those who disagrees with him. This approach is not scientific and at
> best alienating to those he wishes to educate.
So, one cannot call into question the rationality and responsibility of
someone
who disagrees with one? Why not, as long as one talks about the facts of
the
case and doesn't use ad hominem attacks? Oh, I forget, it's not about
facts.
It's about emotions. Well, we're certainly not scientific when it comes to
emotions. And one cannot ignore emotions in humans, even scientists. So,
if
one questions rationality and responsibility, should the response be anger
or
alienation, or should the response be rational, adult-to-parent, instead of
child-to-parent (pardon my reference to "I'm OK, You're OK.)?
> Furthermore, the
> decision to spend limited resources is made by the public through
> their representatives - at least in theory. If the representatives
> make the wrong/questionable decision, then more education is
required.
Too true, too true.
> And further along in his post, Al states,
>
>
> Actually, all we need to say is: "Doses below X (5) rem per year
> are safe."
>
>
> I must disagree with Al on his implicit definition of what safe
> means. According to the Webster Dictionary on line the 6
> defintions of the adjective safe are:
>
>
> 1 : free from harm or risk : UNHURT
> 2 a : secure from threat of danger, harm, or loss b : successful at
> getting to a base in baseball without being put out
> 3 : affording safety or security from danger, risk, or difficulty
> 4 obsolete, of mental or moral faculties : HEALTHY, SOUND
> 5 a : not threatening danger : HARMLESS b : unlikely to produce
> controversy or contradiction
> 6 a : not likely to take risks : CAUTIOUS b : TRUSTWORTHY, RELIABLE.
>
> This agrees well with what I have learned when talking to people like
> my non-HP friends and parents. To most people safe means "without
> harm". It is an absolute statement.
Unfortunately, you are right. People are binary animals. If one says, "Is
it
safe?" and you say, "Yes," and they believe you, they will do it without
much
further thought. However, the shoe is on the other foot, if you say, "No."
They will not do it. So, since we do not know that low doses are unsafe, we
are in a similar box. This box is significantly different from the first
box.
If we say that low doses are not safe, and people accept that, they will
have
nothing to do with radiation and the nuclear industry will die. In the
first
box, saying low doses are safe, we will have the benefits of the nuclear
industry, because people will not fear low doses. I prefer the first box.
This seems to me to be a matter of philosophy. If you are one who is
optimistic about most things, you probably will do most things unless you
KNOW
they are not safe. If you are pessimistic about most things, you won't do
them
unless someone proves to you (or you believe on some basis or other) that
they
are safe. You won't need absolute proof, only an indication, no matter how
tenuous, of unsafety to set your mind on the path of not doing it. To me
the
question is at this point in time, are there more optimists or pessimists in
the radiation health field?
Further, if we, in the radiation health profession, all believe that low
doses
will kill you, why are we allowing anyone to be exposed to any doses
additional
to natural background? And, why are we not doing everything we can to get
rid
of natural background (such as banning buildings with anything but non-gamma
emitting radionuclides in the building materials, evacuating the mountain
states, not flying in airplanes, stopping the manned space programmatic, not
eating Brazil nuts, etc., etc.)? Are we schizophrenic ourselves? Or do we
know something the public doesn't know?
> I agree with the second part of Al's statement," below which
> deleterious effects on humans have not been unequivocally
> demonstrated" - the part he usually omits.
Just as EPA, and others, particularly the antinukes omit, in most of their
writings, that their radiation protection standards and statements are based
on
an idea (the LNTH) that is not demonstrated to be true.
> It is up to the public and
> their representativew to determine what an *acceptable* or working
> definition of safe is.
AMEN. So why won't Congress set an acceptable level of risk on a uniform
basis
for everything in the US and make all the government agencies use that level
of
risk in a uniform manner in all of their calculations and regulations?
> The setting of public policy, by definition,
> is not purely a scientific question.
Very true.
> The responsiblity of the
> scientific community is to present the best available evidence and
> conclusions and to advise those making policy decisions. If the
> conclusions reached by the public are erroneous, if is incumbent upon
> the scientific community to continue to try to educate them.
I guess the question really is, "What is wrong with the current policy and
into
what should it be changed?" I know my answer to that (and so do you). But,
how many of us out there think the policy is OK as it is (except Dan Strom
and
others who have already expressed their opinions that nothing needs
changing)?
If most (51% of all members of the HPS, for example) of the answers are,
"It's
OK as it is," I'll be surprised.
> I have read Art Upton's NCRP 6.1 committee draft report and am
> not unequivocally convinced low doses are truly harmful from the
> "evidence" provided in that report. There still is too much
> guesswork, hypothesizing and extrapolation to permit really
> knowing that low doses are really harmful.
>
> Does this mean that you, yourself, are unsure of the effects, if any,
> of low level radiation?
No. It means that the Upton report does not convince me that low doses are
harmful, nor that we should continue to use the LNTH as the basis for
radiation
protection standards. I am convinced by the current state of knowledge the
low
dose radiation effects, if they are deleterious at all, cannot be observed.
Therefore, low doses are safe. I am convinced that the nuclear industry
will
die if the public continues to believe low doses will kill them. I am
convinced the public's fear of low doses (or higher doses for that matter)
has
resulted in extremely and unnecessarily high costs for the nuclear industry
and
the American tax payer (me). I am convinced that low doses can be
beneficial.
And, I know that I don't know. But what I do know convinces me that we are
not
doing right by the American people with our current radiation protection
policies.
> If there are doubts about the effects (bad, none, or good)
> of low level radiation, then who makes the policy decisions?
And here is the other nub of the question. I think are at least four
possibilities:
1. Low doses are beneficial. We will be hurting people if we deny them low
doses. If this is really true, we are hurting people with the present
policy.
2. Low doses are harmful. We will hurt people by exposing them to low
doses.
If this is true, we are not hurting people with the present policy.
3. Low doses are both beneficial and harmful, depending on the person.
Some
people will be hurt by low doses, others will benefit. If this is true, we
are
hurting some people and not hurting some other people by the present policy.
4. Low doses are neither harmful nor beneficial. We will neither hurt nor
harm people by exposing them to low doses. If this is true, we are spending
a
lot of money for nothing.
There may be other possibilities, but these are enough for the current
argument.
Except, here is an interesting idea. Suppose low doses are like what
vitamin C
is: toxic at high doses - to cancer cells and to normal cells. At lower
doses, however, it apparently has a hormetic effect - suppressing cancer
incidence, but stimulating its growth rate after cancer becomes a part of
the
organism. What do we do if this is the case?
One of my questions about the current policy is: "Should we deny benefits
that
currently appear real (adaptive response, hormesis) to prevent HYPOTHETICAL
harm?
> In the light of scientific uncertainty, and the knowledge that heap
> conservative assumption upon conservative assumption can, in some
> (many?) cases, actually wind up causing more harm than good, the
> question is "What should the public health policy be?" A corollary of
> this would be, "Who should make that policy?"
Agreed. My answer should be obvious by now: establish a threshold below
which zero money is spent to reduce dose further and press on. Congress.
But,
since Congress in all likelihood won't in this or the next century, an ANSI
standard.
> Being the cautious person that I am, I am willing to let the research
> continue and wait for more data.
Well, I'm not. I think the nuclear industry may well be dead by the time
those
data are obtained.
> However, I think that the concept of
> de minimis - whether a Below Regulatory Concern or a Negligible
> Individual Risk - should be persued with full vigor.
Agreed. Does anyone know for sure why the NRC dropped its earlier BRC
efforts? I heard they caved in to the NRDC? Can any of our NRC friends
enlighten us?
> I think that
> these concepts have a much better chance of being accepted (despite
> their rejection so far) by the public someday.
Again, the nuclear industry may be dead by that time at the current rate of
acceptance.
> All in all I still reserve the right to be wrong, nor do I represent
> the views of my employer.
Me too. And I am happy not to have an employer (except my wife and myself)
any
more so I don't need to worry about that after my wife agrees with all I
say.Al
Tschaeche antatnsu@pacbell.net
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