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Re: www fallout (radiation, AIDS etc)
Agreed. The rulemakings should be based on the ANSI standard.
Al Tschaeche, antatnsu@pacbell.net
Weiner, Ruth wrote:
> 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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