[NukeNet] Alert: Demand radiation standards that use precautionary principle

[Michael Mariotte]

ALERT: Demand radiation standards that follow the precautionary
principle

 

Comment and sign-on letter by March 14, 2007

 

A radiation exposure-setting body, the International Commission on
Radiological Protection (ICRP), is poised to release their report,
Recommendations, to allow more and higher radiation exposures to people,
animals and the environment. ICRP says it is accepting comments on their
document Draft ICRP Recommendations, but they are not issuing an
official comment period. Further, Recommendations is missing its
abstract, editorial and summary. Since these are the portions that many
of the public and press will read, it should go without saying they need
to be included for comment before this document is approved and
finalized. 

 

Go to http://www.icrp.org/draft_progress.asp for further detail. 

 

Click
http://www.icrp.org/docs/ICRP_Draft_Recommendations_12_January_2007.pdf
for the document Draft ICRP Recommendations. 

 

Click http://www.icrp.org/remissvar/listcomments.asp to read past
comments. (choose "Recommendations" and/or "2005 ICRP Recommendations"
on the optional pull-down menu.) 

 

PLEASE TAKE ACTION:

 

1)      IMMEDIATELY: Send comments asking for an official comment period
of 90 days. Tell ICRP the document must include the abstract, editorial
and summary for public comment. Tell ICRP that they must adopt the
precautionary approach in their standards. Many comments have expressed
a serious concern that ICRP is making recommendations which ignore
scientific data in favor of more exposure, essentially ensuring that
national radiation regulators will adopt unprotective radiation
standards. ICRP has tried to justify its positions without actually
addressing the concerns expressed repeatedly by the public. We reiterate
the need for ICRP to take a precautionary approach in their standards.
Send comments by email to Scientific Secretary of ICRP, Dr Jack Valentin
(scient.secretary at ircp.org <mailto:scient.secretary at ircp.org> 

 

2)      MARCH 14, 2007: Sign the letter below which details the many
problems with the ICRP recommendations. Send your name, organization and
address to cindyf at nirs.org. View the letter at www.nirs.org
<http://www.nirs.org/> . 

 

For further information contact Cindy Folkers at cindyf at nirs.org or call
301-270-6477.

 

ICRP sign on letter

 

Dr. Lars Eric Holm:

 

The undersigned organizations and individuals are writing to denounce
the ICRP's intended adoption of Draft Recommendations for ionizing
radiation exposure and the lack of a formal comment period. We ask that
people's comments be reviewed by the ICRP members and added to the
record before the final decision meeting of ICRP beginning on March 19,
2007. Additionally, the Recommendations document is incomplete. It lacks
an abstract, an editorial and the summary of the report. Since these are
the portions that many of the public and press will read, it should go
without saying they need to be included for comment before this document
is approved and finalized.

 

NIRS has written ICRP in the past during formal comment periods as have
many other concerned groups and individuals. NIRS has commented on
Annexes A & B which underlie the Recommendations as well as the
recommendations themselves, urging ICRP adopt a precautionary approach
when recommending radiation exposure standards. We and many others have
expressed a serious concern that ICRP is making recommendations which
ignore scientific data in favor of more exposure, essentially ensuring
that national radiation regulators will adopt unprotective radiation
standards. 

 

ICRP has tried to justify its positions without actually addressing the
concerns expressed repeatedly by the public. We reiterate the need for
ICRP to take a precautionary approach in their standards. The need for
such action is obvious and has been shared with ICRP in the past. Late
lessons from Early warnings: the precautionary principle 1896-2000
written by the European Environment Agency (EEA) states: 

 

... the risk rate for radiation-induced cancer was perceived (by ICRP)
as four to five times higher in 1990 as compared to 1977. This resulted
in changes in dose limits but was a belated response to mounting
incontrovertible evidence, a situation which has been a recurring theme
in the history of radiation protection...

 

To our dismay and the public's detriment, ICRP is about to repeat this
history.

 

For many diseases and many populations, ICRP concludes that we don't
know enough about low-doses to predict what damage may occur. Where ICRP
thinks science is unclear, they should have precaution inform their
recommendations. Instead, they are choosing to allow greater exposures
and less protection. While ICRP believes that the linear-no-threshold
model (LNT*) is "the best practical approach to managing radiation
exposure" for lower doses, their recommendations do not reflect this.
The recommendations also do not reflect the conclusions of scientific
research and other recommending bodies: there is no safe dose of
radiation for cancer induction.

 

ICRP must prevent exemption and release of radioactivity. Remove all
references to exemption from these recommendations. Despite its own
stated uncertainties and a nod to the validity of Linear-No-Threshold
model (LNT)*, ICRP is still willing to allow release of radioactivity,
leading to deregulation of radioactive waste and its use in consumer
products. ICRP justifies this by claiming "regulatory action is
unwarranted..." when control measures are excessive compared to risk or
when certain exposures "are unamenable to control with regulatory
instruments". ICRP leaves interpretation of these definitions to
regulatory bodies, which have historically supported release of
radiation and exposure of the public in order to save industry money.
The implementation of this recommendation would clearly lead to
untraceable and irreversible releases of radioactivity into the
environment, work and living spaces without the knowledge or consent of
those exposed. This secret exposure is unpalatable to members of
democratic societies and leaves members of non-democratic societies
extremely vulnerable to avaricious companies and governments. The
world's regulatory bodies should not be allowed to wash their hands of
human made radioactive trash at the expense of public, worker and
environmental health.

 

ICRP must protect the most vulnerable by rejecting gender and age
averaging. By using an average of damage among these groups, ICRP is
building discrimination against women, children and the elderly into its
recommendations. ICRP feels that there are at present insufficient data
for prenatal health so they choose to ignore this damage altogether (see
stillbirths below). These populations are shown to be more susceptible
to radiation damage in several scientific studies including the recent
Biological Effects of Ionizing Radiation (BEIR) VII report of the
National Academy of Sciences. All government recommendations which
follow ICRP will also be guilty of this discrimination.

 

ICRP must recognize that future generations must be protected from
genetic impacts and heritable diseases resulting from radiation
exposure. ICRP should strive for a goal of zero release until we know
the genetic result of long-term, chronic exposures. Instead, ICRP has
lowered its estimated mutation risk from radiation, using exclusively
mouse studies and some very questionable "expert judgment". Also, in a
depraved indifference to human life, ICRP discounts all radiation damage
from the second generation onward, stating "...the inclusion of risk up
to two generations in the calculations can be justified on the basis
that people are generally interested in the well-being of their children
and grandchildren" as if people don't care about their great
grandchildren. This is despite, using ICRP's own model, a clear
increasing curve of heritable disease up to the second generation with
chronic exposure to low dose radiation (Table 6.3 in Recommendations).
What happens after this? ICRP is silent.

 

Even more reprehensible, ICRP claims that assessing damage to only the
second generation, ignoring all future generations, is reasonable
because many mutations will not be carried over or "recoverable" to the
second generation. This is because these mutations will be so
detrimental to new life, the organisms affected will not survive. In
essence, ICRP is saying we should consider ourselves protected because
radiation-induced stillbirths and childhood death will keep our gene
pool pure. They are asking us to accept a man-made increase in still
birth and childhood death as a reasonable alternative to a man-made
increase in future mutation. This contrived and unnecessary choice is
nothing short of premeditated murder. If regulators weren't allowing
exposures in the first place we wouldn't have to worry about adding to
our heritable disease burden.

 

In the instance of heritable disease, the precautionary principle would
provide more protection by preventing the damage in the first place.
Instead, ICRP negligently ignores the data and predictions they do have
in favor of less protection. As a result, the gene pool could grow
increasingly weak from chemical and radiological insults. At some point,
epidemiological data may have to be reevaluated since population
genetics could weaken enough to be even more susceptible to damage from
all radiation sources.

 

ICRP must account for non-cancer diseases found among the A-bomb and
Chernobyl survivors such as heart disease, stroke, digestive disorders,
respiratory disease and nerve injuries. While ICRP recognizes radiation
causes most of these diseases, they argue that there may be a threshold
and therefore, no action is warranted on their part to prevent exposure.

 

ICRP must replace its basic principles for radiation exposure
(justification, optimization, limitation of dose) with the precautionary
approach. Using these three current principles has allowed ICRP to
condone limits that would permit 1 in 3 people to get cancer from 30
years of radiation exposure in certain cases. ICRP must replace their
"bands" of radiation exposures, which allow higher levels of exposure,
with prevention of exposure.

 

ICRP must do its best to account for synergistic effects between
radiation and other chemicals and toxic substances released into the
biosystem. This will be difficult. Presently there are few studies on
synergistic effects of radiation and other toxins such as
organochlorides, heavy metals and even common substances. True to form,
ICRP does not account for any of these potential effects. This issue
would be particularly fertile ground for using precaution. There are
some studies on increased damage from synergistic effects of radiation
and common substances such as caffeine, chlorine and bacteria. Much more
research is needed.

 

ICRP needs to adequately account for risks and damage from internally
incorporated radionuclides like strontium-90, tritium or cesium-137 from
nuclear reactors and other "civilian" and weapons activities. Currently
ICRP relies on the Atomic Bomb survivor data which was mostly high-dose
external exposure. ICRP should learn from the recent poisoning of the
former Russian intelligence officer, Litvenenko. The amount of polonium
210 which killed him was deemed nearly harmless by the IAEA radionuclide
danger category charts. IAEA says it is considering reworking these
tables (see FT.com at
http://www.ft.com/cms/s/a49f6e2e-8a4e-11db-ae27-0000779e2340,_1_email=y.
html for December 13, 2006). [USNRC adopts the IAEA categories wholly
and would thus underestimate the risks as well.]

 

ICRP must account for "new" science in cell biology. Unexpected
biological effects such as bystander effect and genomic instability are
not accounted for in the recommendations. ICRP claims that any cell
effects are already accounted for in epidemiological studies used for
protection standards. But since ICRP and other recommending bodies
routinely and selectively ignore evidence in many epidemiological
studies that show current standards aren't protective enough, the cell
biology impacts continue to be ignored in the ICRP risk estimates
recommended.

 

ICRP needs to be consistent in its use of and recommendations for
collective dose. When used correctly, the tool of collective dose can
help assess radiation damage to populations. When used incorrectly, as
it has often been by regulators, it can be used to hide the individual
consequences of radiation exposures. Collective dose is defined as "the
sum of the individual doses received in a given period of time by a
specified population from exposure to a specified source of radiation"
(10 CFR 20.1003, USNRC Regulations). The problem is that industry and
government often make their own assumptions about who is exposed, how
many are exposed, for how long and to what kind of radiation. For
instance, during the Three Mile Island (TMI) accident in the United
States, evacuation was recommended only for pregnant women and children
within 5 miles of the reactor, but NRC spread the radiation doses among
the population within a 50 mile radius to calculate their health damage
assessment. In this case, collective dose was misused to dilute or
smooth over higher individual doses by distributing their doses among
others who actually received less. The result was a false claim by NRC
and industry that few people would be harmed. Because the parameters for
collective dose are so malleable, they can be used by industry to derive
preconceived conclusions and justify almost anything.

 

On the other hand, collective dose is a useful tool for a best estimate
of the true cost of radiation practice by allowing medical researchers
to predict how many cancers are produced from medical CT scans and other
radiological procedures. ICRP argues that collective dose is good for
comparing radiological technologies and protection procedures but NOT
for risk projections related to epidemiological studies because these
studies often investigate the health effects of lower doses. ICRP argues
that we don't know what is happening at these lower doses among large
populations, yet ICRP recognizes the merit of the LNT model (see above)
when it suites them. The LNT model allows exactly this kind of
prediction at low doses. In fact, collective dose is based on LNT.
Predicting damage to large populations from lower doses of radiation
using collective dose and LNT is in keeping with the precautionary
principle since ICRP's alternative is lesser or no protection.

 

ICRP is recognizing that organisms other than humans are also at risk
and we commend them for this in principle. However, ICRP is not being
protective enough and has ignored public entreaties to place technically
qualified public members on this panel to ensure balance. On the one
hand, ICRP feels that radiation protections for the general public will
ensure that the biota is fully protected in most cases. However, ICRP
admits that a "clearer framework is required in order to assess..." the
consequences of exposure and dose to non-human species. To address this,
ICRP suggests using a small set of reference animals and reference
plants as they have used reference or "standard" man for humans. The
public demands ICRP adopt a precautionary approach that is geared to
prevent exposures and contamination. ICRP should protect the most
vulnerable species, organisms and life stages. The use of standard man
for roughly a half century has historically left more than 50% of the
human population at risk; and this is within only one species-humans.
Trying to undertake cross species protections using this blunt
instrument even with a few reference species, will leave most biota
unprotected.

 

ICRP must adopt the precautionary principle into its recommendations.
Understanding and predicting damage from radiation is a tangle, but
using the precautionary principle will allow for protection in the
scenarios and at the doses where ICRP claims a lack of scientific
clarity. It is negligent for ICRP simply to refuse to address these
"black hole" areas when instituting precaution could account for this
damage and save lives. But ICRP is also unwilling to protect in areas
where science is clearer. Ignoring the impact of radiation on
stillbirths, women, children, and future generations shows a fundamental
lack of understanding about what people value. This disconnect from
humanity makes ICRP, at best, inept at radiation protection. ICRP must
shed its obvious callous indifference to life and health in order to
protect against radiation exposure. We urge the ICRP to officially adopt
the precautionary principle in all its recommendations by instituting
our above suggestions.

 

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