From NIRS

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@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@nirs.org. View the letter at www.nirs.org.

For further information contact Cindy Folkers at cindyf@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.