Re: [riskanal] Lack of Risk Data

[David W Lee <lee_david_w@lanl.gov>]

        I also believe Barbara raises a good point--both regulators and politicians should be accountable for their actions in general and for the use of the linear, non-threshold hypothesis (LNT) in federal radiation safety laws in particular.  However, as stated in the American Nuclear Society's position statement on the health effects of low-level radiation (pp. 108--109, Aug 1999 issue of "Nuclear News"), the root of the problem is that the LNT has been incorporated into federal occupational radiation safety laws as the basis for regulation of low-levels (occupational levels) of radiation in the United States, despite the lack of credible scientific evidence supporting LNT at such levels.

        I do not know what percentage of the historical blame for LNT as the basis for present radiation safety directives rightfully belongs to radiation safety professionals/nuclear engineers/regulators versus what percentage rightfully should be ascribed as the fault of politicians.  I am of the conviction, however, that the present situation will not meaningfully change until we, as a professional community professing to know something about ionizing radiation arrive at a modicum of consensus amongst ourselves sufficient to delete the use of LNT as the basis of current radiation safety regulations in this country and replace it with a scientifically defensible, realistic basis.

        I realize that it is not Barbara's fault that previous generations of radiation professionals during the early 1950's in the atmospheric fallout radiation hysteria of the Cold War were proponents of the use of LNT as the basis for the regulation of low-levels of radiation.  But given that the LNT has become a codified and politically entrenched regulatory reality, it is at least doubly difficult for the present generation of radiation professionals to attempt to undue the LNT sins of the past.  If the root cause of the over-regulation in the radiation arena is to ever be replaced with a more scientifically defensible basis, then the radiation professional community will need the regulators within it to add their voice to this effort.

        I commend to all RADSAFERS Bernie Cohen's letter in the Aug 1999 HPS "Newsletter" wherein Bernie effectively debunks the idea that the LNT is necessary for quantitative radiation risk assessment.  He points out, for example, that the regulation of air pollutants is not based on LNT, but rather on thresholds.  Bernie's letter echoes what RADSAFER Al Tschaeche has repeatedly stated one way or another; namely, we as a radiation community need to dump the regulatory use of LNT and unequivocally state that occupational doses below a certain level (5 rem/yr; 25 rem/yr??) are "safe," because no human radiation health effects data exist that logically buttress the LNT assumption that all doses of radiation, no matter how small, produce some sort of deleterious effect, however undetectable.

        Best regards  David



At 12:11 AM 08/31/1999 -0500, you wrote:

>  Alfred Brooks wrote:
>
> <<Thr regulators don't have enough data to determine if I am really
> at risk 
> but
> they do have enough data to spend $1.6 billion of the taxpayers' money
> and
> destroy my property.>>
>
> In a message dated 08/28/1999 1:41:56 PM Pacific Daylight Time, 
> faseiler@nmia.com writes:
>
> << You hit the nail right on the head!  This is precisely the
> point that a
>  lot of people try to avoid with an excessive amount of smart
> verbiage.
>  They do not have enough hard science, not enough to know how
> to
>  evaluate this -- maybe it is and maybe it ain't -- kind of risk,
> but they
>  sure know enough on how to throw away billions of taxpayer
> dollars.
>  So they go with what they know and throw!  UGLY!!!
> >>
>
> While it is fun to blame the regulators...There is another piece to this
> puzzle, and that is the politicians (ultimately the taxpayers
> themselves)...
>
> Politicians are pressured by moneyed lobbying groups.  They enact
> laws that 
> are not scientifically defensible, then hand the responsibility for 
> enforcement to the agencies.  Sometimes the agencies literally don't
> do 
> anything, or try desperately to interpret and enforce an unreasonable
> statute 
> in a reasonable manner, and when someone notices, they are taken to 
> task....Sometimes they try to enforce the laws as written no matter how
> absurd...In either case, they are usually the ones who take the heat in
> the 
> press.
>
> I would be the first one to jump on the "governmental agencies need
> to be 
> accountable" bandwagon, if there were comparable accountability
> demanded of 
> the politicians who won their election on some pie in the sky campaign
> promise of absolute protection from radiation exposure...or other such
> nonsense.
>
> Barbara Hamrick
> BLHamrick@aol.com
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DAVID W. LEE
Los Alamos National Laboratory
Radiation Protection Services, ESH-12
X-Ray/Source Control Team Leader
PO Box 1663, MS K483
Los Alamos, NM  87545
PH:   (505) 667-8085
FAX:  (505) 667-9726
lee_david_w@lanl.gov