Understanding history of risk assessment models for chemicals and radiation

Edward Calabrese has published a fascinating and terribly important paper in the University of Chicago Law Review titled US Risk Assessment Policy: A History of Deceptionthat needs to be widely distributed and discussed. Here is the quoted introduction:

Strategies to limit the  general  public’s  exposure  to toxic  substances—via national standards such as community-based drinking water and air quality standards, food residue regulations, hazardous-waste siting decisions, or other strategies—are based on multiple factors including social, political, cultural, historical, economic, technological, as well as public health–related concerns. At the core of these decisions is the need for risk assessment estimates to be based on a sound foundation, using scientifically validated procedures and having high reliability. However, while it may be hard to believe, and even more difficult to accept, the foundation of our fundamental dose-response model—that is, the threshold dose-response— upon which all public health standards were originally based, and upon which we still highly depend, was never validated by the regulatory and scientific communities prior to its adoption by the FDA, EPA, OSHA, and other agencies in the United States and elsewhere in the world.


Calabrese’s paper is not a scientific work; it is a masterful work of scientific history, tracing the evolution of underlying assumptions about dose response. By explaining how the underlying basis for many regulations associated with both chemicals and radiation was never properly tested, Calabresse helps us understand why we have so many nonsensical regulations that seem to be based on solid mathematics.

Though only one dose response model is mentioned in the introduction, Calabrese actually discusses three available dose-response models: threshold, hormesis and Linear No-Threshold (LNT). He also explains how thoroughly testing available models shows that only one of the three – the one that is not currently being used by regulators – consistently makes predictions that align with observed scientific data.

Though there are many who reject her out of hand, Ayn Rand was perceptive enough about human behavior that her works have been on best seller lists for several decades. One of her frequent admonitions is that if something does not make sense, you need to check your premises. In my own educational journey, I have repeatedly experienced the fact that one can perform math perfectly, but obtain incorrect answers when using the wrong initial assumptions.

Since US voters agreed a long time ago to ask the government to help to protect our health and safety by issuing regulations, we should at least demand that our regulators reevaluate those rules in the face of better science and history that proves their fundamental assumptions were so wrong that they have led to harmfully inaccurate regulations.

In many discussions with professional colleagues regarding the LNT, I have run into people who generally agree that it is not correct, but they like the answers that it provides. They have also told me that they are unwilling to advocate for any changes unless we have something that can be used to replace it as the basis for regulation. Calabrese and his colleagues have shown that there is a better model that more accurately predicts health effects, both positive and negative.

The excuses continue to fall away. It is time to push regulators to change their modeling assumptions and then redo the math to produce regulation that truly protect our health and safety without putting us at risk of not beneficially using safe materials and processes because of poor assumptions about their risk profiles.

About Rod Adams

38 Responses to “Understanding history of risk assessment models for chemicals and radiation”

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  1. Steve Skutnik says:

    The more I think about these issues, as well as the larger issues of NRC regulation, I feel like Public Choice Theory has a strong role to play. Consider the issue brought up many times before – the fact that the NRC has a mandate toward safety, but no corresponding mandate toward economic impact – i.e., the balance of their incentive structure always tips against reactor operators. The NRC has every incentive to order unnecessary tests, analysis, and systems, regardless of marginal benefit – partly to maintain the perception of “independence” from the industry, and partly to maintain their status – (i.e., it is always safer to prophylatically regulate rather than take the blame later on if they decline to intervene and something goes wrong, regardless of the relative cost-benefit balance).

    The same goes for general safety regulation. Given that the public is generally not composed of scientific experts, nor is risk perception at all a rational phenomenon, public attitudes invariably lean toward over-estimating risk. Government regulators, sensitive to public perception, inherently will err on the side of caution to avoid the perception of being “captured” by industry.

    Basically, what is the incentive structure of the regulator? What incentive do the NRC and other safety regulators have to pin risks as close as possible to science as opposed to being conservative? There is little consequence to said agencies for over-regulating (economic costs for overly conservative are borne entirely by industry); meanwhile, there is substantial incentive in terms of public perception (and even job security) if the regulator is seen as overly lax. Hence, there is inevitably a bias toward conservativism.

    Unless the incentive structure changes, this will be the inevitable result of any regulatory system. So, a more important question in my mind is, how do you structure those incentives? How do you incentivize actually balancing economic costs imposed by agencies when they have no economic stake in those decisions (but conversely do have political stake in them…)

    • donb says:

      Steve Skutnik wrote:
      Consider the issue brought up many times before – the fact that the NRC has a mandate toward safety, but no corresponding mandate toward economic impact – i.e., the balance of their incentive structure always tips against reactor operators.

      The problem is that this mandate toward safety has been interpreted too narrowly. It has been interpreted as a mandate towards safety regarding nuclear energy only.

      In a larger sense, the NRC has failed its safety mandate. The NRC has made building nuclear power plants so difficult and expensive that most often other types of power plants, more dangerous than nuclear, are built. The net effect is that NRC regulation has made electric power generation more dangerous.

      There are some who argue that through conservation and renewables, we can get along without “dangerous” nuclear power. This is just a smokescreen. Unless we go back to the lifestyle of the 19th century, we are going to use electric power. So it behooves us to use to safest method of generating that power, which is nuclear energy.

      • Steve Skutnik says:

        @donb – Fine, but I would argue this is a different problem – that of a fragmented regulatory structure. The NRC is tasked with a relatively narrow scope, and I believe (but could be incorrect) that other radiological sources (i.e., coal emissions) have been specifically exempted from their regulatory scope by Congress. (Even if it weren’t, I imagine the political backlash would be quite severe if they attempted to assert such authority, similar to the EPA with respect to greenhouse gasses.)

        One could argue that a greater harmony of regulatory approaches between the NRC and EPA should be achieved; i.e., that the public protection role of the NRC should be viewed as subordinate and harmonious with the EPA. (While the environmental regulation role of the NRC is, arguably the public safety aspect goes well beyond the EPA.)

        However, none of this really gets to the root of the issue, which is even if we regulated equally, we’d still see the same bias toward conservativism. True, nuclear would not be unfairly disadvantaged among sources. But the most likely outcome would simply be a preference for overly conservative models for risk in other domains. The incentive problem remains the same.

        • donb says:

          Steve, I see your point.

          It would be interesting to see a regulatory environment (EPA, NRC, or EPA & NRC together) where the goal was to facilitate increased safety of power generation. Ideally, this should not mean cranking the screws on regulation of fossil fuel power plants, but paving the way for easy licensing of nuclear power plants, including reducing regulatory burdens so that they can get built. In order words, a “wholistic” approach to power generation safety.

          Unfortunately, regulatory processes flow from governent. Government is a product of politics. Politics focuses on the “practical”. Practical means that (for example) coal mining interests in my district will lobby for a regulatory environment that is helpful to them, even if that means the resulting increased hazard of burning coal to produce electric power. This is the mess we have now. I am not holding my breath waiting for it to change.

        • Engineer-Poet says:

          even if we regulated equally, we’d still see the same bias toward conservativism.

          The solution there is to incorporate the risk to health etc. due to lowered standards of living from high electric prices.

          Considered even more broadly, very cheap electricity would divert consumption away from other fuels.  Since nuclear electricity generates roughly zero fine particles (one major target of recent EPA actions) in either its generation or its consumption, one can argue that “conservative” regulation of nuclear power is risky for public health.

  2. Cheryl Rofer says:

    Rod -

    As much as you may like Calabrese’s arguments, if you want them to change the regulatory agencies, you (and Calabrese) will have to address the BEIR process. That process was set up to provide an extra layer of peer review to make sure that the numbers being used in regulatory and other health-related situations are the best available.

    So the questions that must be addressed include:
    Do Calabrese’s arguments address the criteria developed by the BEIR committee?
    Do Calabrese’s arguments undermine (scientifically) the BEIR criteria?
    Does Calabrese’s preferred alternative meet the BEIR criteria? If it doesn’t, is there a good reason that it shouldn’t?

    I haven’t read Calabrese’s book. As I’ve pointed out before, you can’t refute the BEIR process with a single argument from a single author. The evidence on the other side must be as good as the evidence on BEIR’s side. And so far, that hasn’t been the case.

    • Rod Adams says:

      Cheryl:

      Did you read Calabrese’s paper, even if you did not read his book? The paper indicates that he is not a lone wolf, but the member of a growing team of scientists that are actively testing models, doing detailed research, and publishing papers on the topic.

      I know a little about the BEIR process and the selection bias associated with placement on the committee. The source of that bias comes from the funding decisions largely influenced by a single senior GS in a relatively unknown office in the EPA (Office of Radiation and Air/Office of Radiation and Indoor Air/Radiation Protection Division) that provides the funding for the Life Span Study of Atomic Bomb victims. If you would like, I can even provide the name. Yes, this is an ad hominem point, but I know “just a little” about the bare knuckles political games played in DC; I survived 9 years in that environment and met a lot of people during that time.

      Here is an example quote from a publication titled Risk Assessment of Radon in Drinking Water that provides the tip of the iceberg view that means a whole lot more to the people who have been in the “sausage factory” of Washington, DC money flow than members of the general public:

      NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard to appropriate balance.

      This report was prepared under EPA Contract EPA X825492-01-0 between the National Academy of Sciences and the Environmental Protection Agency.

      • Cheryl Rofer says:

        I’ve read some of Calabrese’s stuff. It’s doing something different than what the BEIR process does, in effect talking past BEIR. And, I think, not understanding that process.

        I know that you prefer a particular way of arguing, trying to show underhanded influence of particular viewpoints and money. That’s okay if you’ve got an ironclad case for financial or other manipulation AND can show that poor science has been done. IMHO, you’ve done neither.

        I know just a little bit about bureaucratic politics too, having been involved in those games for something more than 9 years, and unless you’ve got quite a dossier on that single senior GS, you’ve provided nothing “incriminating.” (And, frankly, I don’t want to see it; it’s not a condemnation of the resulting science.)

        Your example quote at the end is pretty standard boilerplate. I’m not sure why the EPA would be involved in contracting an NRC report, although I have seen stranger things resulting from the arcane rules under which some of these agencies operate: the arrangements get complex, but it is just a way to get the job done. That would be my assumption under Occam’s Razor.

        As to the other part you’ve bolded in that quote, well, that’s the way things should be done. A range of people with the appropriate competencies. I suspect you’re reading “balance” as political, whereas Occam suggests it means a balance of competencies, in the case of BEIR for example, epidemiologists, health physicists, and radiation biologists, along with others. It is the National Research Council that chooses the people on these committees. For a conspiracy to work, a great many people would have to be involved. And these are the kind of people who would talk about it.

        Even if you can show that the balance in BEIR personnel has been tipped in a particular direction, you would still need to show that what resulted is poor science, and you haven’t. Even biased people can do a good job.

        So let Calabrese and others form their own BEIR-equivalent committee to take BEIR’s criteria or develop their own, with appropriate reasoning, and then evaluate ALL the evidence, which would include the evidence BEIR has evaluated.

        • Rod Adams says:

          @Cheryl

          You are coming into a conversation that has been in progress on Atomic Insights for at least 15 years – off and on.

          There are a number of posts in the category of health effects or LNT (http://atomicinsights.com/category/health-effects-2/page/8 and http://atomicinsights.com/category/lnt/page/3) that include links to the science. Measured data disproves the assumption that you can extrapolate health data collected from a population that was exposed to intense radiation for a brief period of time and project it down to provide reasonable predictions of health effects on human beings that have been exposed to a substantially lower total dose administered over a much longer period of time than just a few seconds to minutes. Even the politically appointed BEIR committees (and I am not talking about partisan politics, but politics in the sense of picking people based on their opinions vice based on other performance criteria) have recognized that measured data collected over many decades does not match a linear assumption; they attempt to make the assumption fit a little better with the DDDREF fudge.

          With regard to your dismissal of Calabrese’s work, it was telling that you did not respond to my question: Did you read the paper that was the subject of the specific post on which you are commenting?

          Since you didn’t respond, I will take that as a “no” and assume that you are resisting the information based on your assumptions about the source (me, whom you obviously disrespect, and Dr. Edward Calabrese, professor of toxicology at the University of Massachusetts, Amherst.)

          As Dr. Brian Mays pointed out, Dr. Calabrese is fully engaged in the BEIR process and he is working through the normal accepted methods of changing scientific opinion by publishing in peer reviewed journals that both screen the initial publication and enable other scientists the opportunity to review, comment and rebut.

          BTW, Risk Assessment of Radon in Drinking Water is NOT an NRC report. In the byzantine world of political radiation “protection” the EPA is the bureaucracy that is assigned the role of determining radiation risk and providing the limits that the NRC then uses as the basis for its regulations.

          The EPA’s view on radiation is often unsupportable by real science and logic – I clearly remember the time when I was on a break from an ANS meeting in restaurant with some TVs playing and saw a commercial with a whole family sitting on their living room couch wearing WWI style gas masks. The commercial was sponsored by the EPA and was designed to scare the heck out of people about the possibility that their home might be full of deadly radon gas. The EPA is also the organization that imposed a 15 mRem PER YEAR limit for 1,000,000 years as the standard for evaluating the safety of a geologic repository. Please point me to the science behind THAT piece of complete nonsense in a world with an average dose rate of perhaps 300-600 mRem/yr depending on whether or not you include the doses administered to improve people’s health.

          The office that provides the funding for the Life Span Study skews the results by refusing to include anyone that suggests that low doses might even be beneficial.

          If you are really interested in the topic, you could spend a few days reading the works that Jim Muckerheide, Dr. Ted Rockwell, Dr. Myron Pollycove, Dr. Sohei Kondo, Dr. Jerry Cuttler, Dr. James Cameron, Dr. T. D. Luckey, Dr. Bernard Cohen and other members of Radiation, Science and Health accumulated and made available to all of us on an admittedly ugly and amateur looking web site. http://www.radscihealth.org/rsh/

          They were not web masters or layout artists, they are (or in some cases, were) scientists and engineers who are deeply troubled by the continuing insistence on using a model that fails to accurately reflect measured data AND that causes great harm to society by adding enormous costs to the use of nuclear energy, nuclear medicine and other applications of nuclear technology.

          Note: I used quite a few honorifics in this comment because I think that academic accomplishment means something. On Atomic Insights, I often point out how many of the people who are in the establishment and aligned against the use of nuclear energy have very light resumes in the topics on which they provide wide ranging commentary.

          The tactic of attacking credibility is often used by the opposition, but they want the world to believe that anyone working in the field is tainted and only the “independent” observers have the right to comment. That is a completely absurd notion; the professionals work in the field BECAUSE they have demonstrated their knowledge by passing tests and getting evaluated by other people with knowledge. They get paid to provide good answers to tough questions and to solve real life problems. Few, if any, make any of their income by promoting anything, unlike the people who live off of the income that comes from promoting negative information about a potent competitor to some very wealthy and powerful interests.

          I don’t have a PhD, but I have an acceptable education and a decent resume showing that there are employers who respect my knowledge and willingly pay me to prevent or solve difficult problems.

          • Cheryl Rofer says:

            Rod, you like to lay out the academic degrees of the people you feel are right, but the academic qualifications of those with whom you disagree are just as respectable. It’s silly to think that laying out academic qualifications will solve the issue you are dealing with. Check out the resumes of the BEIR committee.

            Further, much of what you say, in this response and throughout your comments on this thread, involves innuendo. That appears to be what your quote of boilerplate is in your previous comment. I notice that you haven’t responded to my comments on that quote but have moved on to a more ad-hominem (ad-feminam?) attack.

            The issue, however, is the science, and you don’t address that either. If the anti-LNT crowd really wants to challenge BEIR, they need to do something similar to what BEIR has done and show why their approach is better. You haven’t addressed that either.

            You’re right that I haven’t been reading Atomic Insights for 15 years. But if the science isn’t right now, it never was. And I’m not saying that the science you’re presenting isn’t right, just that you and the people you quote haven’t shown that it is.

          • Rod Adams says:

            I notice that you haven’t responded to my comments on that quote but have moved on to a more ad-hominem (ad-feminam?) attack.

            That is sly, rather insulting question for the proud father of two professional, accomplished women, including one who is succeeding in a traditionally male profession.

            The credentials of the BEIR committee are impressive, but the reason for pointing to the qualifications and credentials of the people who question The Establishment is to show that they are well-qualified to ask those questions and that they are not making stuff up. Science is a process that requires a questioning attitude, but it is not a process where everyone is entitled to their own opinion and certainly not their own facts.

            Here is a segment from Dr. Calabrese’s paper that you might have skimmed over:

            However, after many months of searching for an answer to this question of threshold dose-response model validation, we came to the tentative conclusion that, in fact, such validation had never been done. While we could never be certain since one cannot prove a negative, our continued searching has never yielded such a validation. In my opinion it most likely was never done—that is, until we finally put the threshold, hormesis, and Linear No-Threshold (LNT) models to the test (actually, three substantial validation tests). In each of these tests the threshold and LNT models made poor predictions of responses in the lowdose zone.10 Only the hormetic (biphasic) dose-response made consistently accurate predictions.

            (Emphasis added)

            Here is the footnote number 10 –

            10 – See generally Edward J. Calabrese, et al, Hormesis in High-Throughput Screening of Antibacterial Compounds in E coli, 29 Hum & Experimental Toxicology 667 (2010) (studying the effect of antibacterial compounds on growth of E coli bacterium demonstrates that compounds stimulate growth at some concentrations below the threshold of toxicity); Edward J. Calabrese, et al, Hormesis Predicts Low-Dose Responses Better Than Threshold Models, 27 Intl J Toxicology 369 (2008) (studying the effect of various chemicals on the growth of yeast strains demonstrates that yeast exposed to nontoxic concentrations of chemicals grew more than the threshold model would predict); Edward J. Calabrese, et al, Hormesis Outperforms Threshold Model in National Cancer Institute Antitumor Drug Screening Database, 94 Toxicological Sci 368 (2006) (studying the effect of various chemicals on growth of yeast strains demonstrates that growth patterns of yeast exposed to nontoxic concentrations of chemicals are more often hormetic than they are consistent with the threshold model).

            It seems to me that there is plenty of reason to question the “science” of the LNT, even if it is the model that is accepted by The Establishment. There are also strong moral, economic and environmental reasons for shifting to a model that provides less scary answers to people who might be exposed to low level doses.

        • Rod Adams says:

          I have a simple and straightforward assumption about the way that radiation is regulated that I believe qualifies under Occam’s Razor:

          Nuclear energy is so superior to traditional energy sources that it poses an existential risk to the current business models of all suppliers and supporters involved in the Hydrocarbon Establishment. Since humans have a fundamental motive to protect themselves and their friends, the assumption that radiation is inherently dangerous has been carefully propagated since the incredible energy density of the atomic nucleus first became apparent.

          Spreading this assumption needs no deep, dark conspiracy theory; the process simply relies on the ways that myths are created and propagated.

          Maintaining the fiction requires a little nudging now and then, it is supported by a few carefully selected committees, and it is loudly defended by a large group of gullible people who will loudly profess their fears in public.

    • Brian Mays says:

      Cheryl – Not only have you not read Calabrese’s book, but it appears that you also have not read the BEIR Committee’s latest report.

      You seem to be unaware that Dr. Calabrese was one of the “experts from a number of fields” who gave formal presentations to the committee during the process of preparing the report. BEIR VII cites several of Calabrese’s papers.

      How else is one supposed to “address the BEIR process” other than to be lucky enough to be appointed to the committee itself?

      • Cheryl Rofer says:

        Brian – Giving a formal presentation to the committee is not the same thing as doing the analytical work to set up criteria and evaluate the available data in the way the BEIR committee has done. The latter is what I mean by “address the BEIR process.” It could be done outside the BEIR committee.

        So Calabrese has had his day in court, and apparently didn’t carry the argument.

        • Brian Mays says:

          Cheryl – So let me get this straight.

          You assert: “you (and Calabrese) will have to address the BEIR process.”

          I point out that Calabrese was one of the 14 experts who did, in fact, address the BEIR Committee, which is the only possible avenue available to participate in the process unless one is selected as either a member of the committee, a consultant, or a reviewer.

          Now you tell me that Calabrese needs to set up his own committee to compete with the BEIR Committee’s work?

          Are you **** kidding me?!

          Once again, you demonstrate that you don’t have the first clue and that you haven’t actually read the BEIR VII report. What are these “criteria” that you keep harping about? Where in BEIR VII do these “criteria” appear?

          Since you clearly don’t have a copy handy, please let me educate you on what the BEIR VII-Phase 2 Committee was supposed to accomplish. The primary objective of the committee was to develop risk estimates for exposure to low-dose, low linear energy transfer (LET) radiation in human subjects. To this effect, the committee was charged with the following tasks:

          (1) develop appropriate risk models

          (2) provide examples of specific risk calculations based on the models

          (3) describe and define the limitations and uncertainties of the risk models and their results

          (4) discuss the role and effect of modifying factors

          (5) identify critical gaps in knowledge that should be filled by future research

          Items (3) and (5) are the most relevant to the discussion here. With respect to item (3), the report clearly states that “at doses less than … 100 mSv [per year], statistical limitations make it difficult to evaluate cancer risk in humans.” It then goes on to state that the committee uses the “assumption” that “the risk would continue in a linear fashion at lower doses without a threshold and that the smallest dose has the potential to cause a small increase in risk to humans.”

          The fact that this is merely an assumption on the part of the committee is, in itself, an important limitation and uncertainty in their model.

          Given this uncertainty, it is not surprising to discover that hormesis finds itself included in item (5), critical gaps in knowledge. In fact, hormesis appears in 2 of the 12 “research needs” identified by the committee — i.e., research needs 3 and 4. Obviously, the committee felt that the evidence presented for hormesis warranted further study. According to the recommendations in the report, the main weaknesses in the theory were insufficient mechanistic data and clearly identified molecular mechanisms to explain the observed phenomena. OK. That was seven years ago.

          Frankly, BEIR VII was a bit of a disappointment. It was probably the most conservative of these committees in that it seems, in hindsight, to have been more interested in preserving the status quo than truly investigating in depth and seriously considering the entire set of research that is out there. This just shows the amount of inertia that builds up in a field as it becomes more entrenched and reluctant to change over the years. Of course, this is simply my opinion, and you are welcome to yours.

          Oh well. Time marches on. Eventually, there will be another BEIR report on low-dose and low-dose-rate radiation, and until then, researchers like Calabrese will be doing scientific research that will be considered in the next report. Meanwhile, mediocre voices on the Internet will continue to lecture us all on the latest results of “committee science.” (sigh)

        • Rod Adams says:

          So Calabrese has had his day in court, and apparently didn’t carry the argument.

          Cheryl, you’ve been claiming rather loudly that your acceptance of the LNT is based on science, but this comment is far more revealing. As you imply, the issue is legalistic and political.

          • DV82XL says:

            One of the joys of debating with Ms. Rofer is that she clearly does little in the way of research on a topic before extending a strident opinion and then when caught out on the facts attempts to escape by shifting frame and accusations of personal attack.

            I have engaged with her elsewhere twice before, and I’m afraid it won’t get any better.

        • siphon06@gmail.com says:

          Cheryl, the BEIR process you mention explicitly rejects data that do not support LNT. It rejects hormesis at first sight even if the study is scientific and significant. It rejects any data points that show a threshold.

          Calabrese is not the only one to have pointed this out. Please read this excellent paper by the late radiation health physicist Cohen:

          http://www.world-nuclear.org/sym/1998/cohen.htm

          The very fact that BEIR focuses on prompt radiation exposures – overwhelming any body repair mechanisms – shows their bias. Drinking 365 glasses of wine in one day is not the same as drinking 1 glass of wine a day for a year.

          We see threshold and hormesis in almost any field of biology, be it chemical or physical abuse, sports excercise, etc.

          You would need very good scientific arguments to accept the argument that ionizing radiation is somehow different. The arguments, if anything, point in the other direction.

  3. Robin Holt says:

    Steve, I think you need to consider Rod’s position more closely about LNT and safety. I believe Rod would argue that LNT actually decreases safety by forcing the regulated industry and government to respond in a fashion which is harmful to the people that were supposed to be protected.

  4. Bob Applebaum says:

    I like Prof. Shrader-Frechette’s characterization of Calabrese…he’s an ideological toxicologist. In fact, that’s quite nice…based on this paper he doesn’t seem to understand the difference between medical efficacy(homeopathy vs. medicine) and toxicity.

  5. Leslie Corrice says:

    Another great informative article. Calabrese has been one of my best sources of scientific information on the low level rad exposure issue for a long time. The question I have is how do we get stuff like this out to the public-at-large? Unfortuneately, the vast majority of our readers are “the choir”, if you will. I’ll be including a piece on this in my blog, later this morning, and what few “non-choir members” I have will at least get the opportunity to spread the word.

  6. Bonfim says:

    Steve raises interesting questions; would suggest he reads Cass Sunstein’s book “Laws of Fear: Beyond the Precautionary Principle”.

  7. Cheryl Rofer says:

    Okay! I have read this article, which is no different from many other of Calabrese’s articles. He cites his work on hormesis and pours out a great deal of bile on Hermann Mueller. Nothing new here. So my comments above stand.

    He doesn’t mention the BEIR process at all, or the BEIR examination of the three models, of which they found the LNT model best fits the data. So his statement that the dose-response model has never been tested is simply wrong.

    As I’ve been saying, the issue is the science. Not one person’s interpretation of history. Not Rod’s innuendo. Science. So I’ll go back to those questions I asked in my first post on this thread, which remain unanswered by any of the participants:

    Do Calabrese’s arguments address the criteria developed by the BEIR committee?
    Do Calabrese’s arguments undermine (scientifically) the BEIR criteria?
    Does Calabrese’s preferred alternative meet the BEIR criteria? If it doesn’t, is there a good reason that it shouldn’t?

    If you want to talk about history, or compare, um, qualifications, or how long someone has been reading this blog, that’s a different discussion, and one I’m not intersted in.

    • Rod Adams says:

      @Cheryl

      If you want to talk about history, or compare, um, qualifications, or how long someone has been reading this blog, that’s a different discussion, and one I’m not intersted (sic) in.

      If that is how you feel, thanks for stopping by. My blog post is about history and about an article published in the Chicago Law Review, not a science journal.

      It is worthwhile to review previous discussions, that is why I provided the links. One does not have to have been in the conversation for 15 years, but if you want to participate and understand what has already been discussed, the information is as available as I can make it. I also pointed to the scientific papers on the subject published at Radiation, Science and Health.

      The qualifications and professional performance of the people who sharply question the BEIR results is important; it helps to demonstrate that the people questioning the Establishment science are not cranks, not self aggrandizing “skeptics”, and not interested in making stuff up. (Aside: There is at least one regular commenter in the LNT discussions here who keeps trying to compare the people who question the LNT to climate change deniers. That is completely upside down. End Aside.)

      The people who strongly question the LNT and the process by which it became accepted are people who have dedicated their professional careers to understanding and quantifying the risks of using nuclear energy and its associated radiation. Some are deeply interested in the subject because they also understand the incredibly important advantages nuclear energy has over any other energy alternative.

      They understand that the phrase “there is no safe level” is only tenuously supportable and that it is the work of the politically appointed BEIR committees in accepting the Linear No Threshold dose ASSUMPTION that provides that tenuous support. They also understand that acceptance of that assumption in written regulations and in continuously ratcheting enforcement adds enough unmeasured costs to nuclear energy systems that they are not economically competitive when the competition is measured on a different time scale and on a completely different level of “acceptability”.

      This is not a science question. That’s a good thing for me because I am not a scientist. I’ve never claimed to be a scientist and I freely admit that I am not all that interested in theoretical science. I care about the knowledge science can provide so it can be actively applied it to make life measurably better for people. The truth is I am not even an engineer (I do not have an ABET accredited degree and have never attempted to obtain a PE); I’m a technologist.

      One of the many reasons I care about technology – applied science and engineering that actually results in products people will pay money to use – is that I like living a comfortable life and providing a comfortable life for my family. I thoroughly enjoy living in prosperous American suburbs full of people who can move about freely, enjoy good food, support arts and entertainment facilities, and use as many gadgets as they desire. I like participating in activities that help the areas where I live grow and become even nicer places to live as more and more prosperity arrives.

      I’ve also visited many places around the world where people live far more constrained lives, but not by free choice. A life-changing experience was my participation in a mission trip to El Salvador at age 15, before their revolution. We experienced the incredibly unbalanced distribution of wealth that led to that revolution.

      Though there are other components to poverty besides a lack of access to abundant energy, that is a big one. It is also one where I think nuclear professionals can make a significant difference.

      Fission fuels are inexhaustible; using them produces no noxious gas and no gases that pose the risk of completely changing the climate and ocean chemistry. It also does not pose any catastrophic risk in the case of an accident – even if the accident is the relatively complete melting of three large nuclear power plant reactor cores. That is FACT and proven by the results of an unplanned experiment.

      Not only will spreading nuclear fission technology be a profitable, employment creating endeavor because customers really want the features that the products can provide, but spreading that technology will make life measurably more prosperous and allow billions of human beings to be optimistic about the future.

      The LNT is one thing that is in the way of that vision for the future. I plan to continue to do everything I can think of to spread the word that the assumption is a bad one, with an unsupportable technical basis. I didn’t study much science in school; I studied leadership, communication, language, and the use of both fiction and non-fiction writing to successfully alter the political landscape.

      This is a rhetorical battle; I think I am reasonably well prepared.

      PS Soon after posting this comment, I noticed that a friend had shared the following, relevant link:

      http://www.forbes.com/sites/jamesconca/2013/01/11/like-weve-been-saying-radiation-is-not-a-big-deal/?ss=business%3Aenergy

      It looks like there is are reinforcements coming into the battle on the same side I have been fighting on.

      • Brian Mays says:

        A life-changing experience was my participation in a mission trip to El Salvador at age 15, before their revolution.

        Rod – Have you ever blogged about that? Sounds interesting.

  8. Cheryl Rofer says:

    Let me wrap my response to all the responses above.

    Science has certain processes. If you want to attack people (which is a big part of Calabrese’s argument as well), then you are doing something else. I would think that even if you believe that the “battle” is rhetorical, you would want to be “armed” with truth. Science has ways of getting to the truth. If you want to toss those methods to the side, go ahead, but then you have no argument.

    We are both on the same “side.” I believe that nuclear power is necessary to supply the world with electricity and heat. I would, however, like to see it done well, and I would like to “fight” on the “side” of science rather than “attack” people.

    I’ve put a lot of words in scare quotes. It also matters that you conceive of the interaction in such aggressive, martial terms. Dividing up the world into “sides” is not very conducive to convincing people you disagree with. And destroying them isn’t an option in this case.

    If you were interested in science, you would have known that the UNSCEAR report was coming out soon. I haven’t read that report yet and am very interested to do so, since that group had been rumored to be ready to reject LNT. But it’s not just the few words you quote, it’s the process by which they arrived at them that is important. BTW, a similar rumor circulates about the next BEIR report.

    Which brings me to Brian Mays’s question with all the asterisks and Rod’s supplement. No, I’m not f****** kidding. That’s how science is done. If you didn’t know that, then you’re missing a lot about the BEIR report.

    And if you have to resort to misconstruing words, or if you simply don’t understand the way English is constructed, then you’re not doing the rhetoric thing right either. My parenthetical (ad-feminam?) simply refers to my gender. No implications about Rod’s attitudes toward women were intended. “Day in court” is a metaphor, a rather obvious one, referring to Calabrese’s appearance before the BEIR committee. It has nothing to do with legality or legalisms.

    Accusations like that are ways to avoid the subject, which is science, at least if your argument has to do with the derivation and use of LNT. My questions from the top remain unanswered, and I see that I have no reason to expect they will be in this forum.

    What I object to is that you are making my job of getting facts about nuclear power out much more difficult by placing emotional barriers, the choosing up of “right” and “wrong” sides, in the way of that. I would like it if we could just talk to each other, if you would address my points. But it looks like that won’t happen here or now.

    • Rod Adams says:

      By the way, Cheryl, I have read pre released versions of the UNSCEAR report. That is one of the many bricks that provide the foundation for my confidence that I am speaking with factually correct rhetoric on this topic. You can read Dr. Jim Conca’s interpretation of what the UNSCEAR report says at the following link:

      http://www.forbes.com/sites/jamesconca/2013/01/11/like-weve-been-saying-radiation-is-not-a-big-deal/

      This article about the UNSCEAR report was published more than a month ago and has been a topic of engaged conversation on several of my private email lists:

      http://www.world-nuclear-news.org/RS_UN_approves_radiation_advice_1012121.html

    • Rod Adams says:

      It also matters that you conceive of the interaction in such aggressive, martial terms.

      What do you expect from a retired military officer? Some people talk in sports analogies because they were athletes. I use martial terms because I spent most of my formative years in uniform.

      Besides, the opposition to nuclear energy has never shied away from attacking nuclear energy professionals and attempting to destroy our credibility because “we work for the industry.” Their tactics might bother some, but they have been effective enough for long enough that they are worth being considered for emulation. If a tactic works, why shy away from using it?

    • Brian Mays says:

      My questions from the top remain unanswered …

      Cheryl – Well, if you’re going to whine about it, then I should whine that you have never answered my question. Where are these “BEIR criteria” that you refer to?

      My reading of the BEIR report is that the committee discussed the various issues and based their conclusions on their discussions. I can’t find a single objective criterion in the entire document, and there’s a good reason for that: there aren’t any.

      That’s how committee science really is done, particularly in the Health Sciences. The “experts” get together, and they talk about something, and then they come to some sort of agreement on what they are going to conclude, and BEIR is no exception. Naturally, who shows up to the discussion matters greatly in these processes. Let’s not be so naive as to believe that there are any objective criteria involved.

      I could go on, but since you have chosen to perceive this discussion in “martial terms,” I’ll stop now and allow you to beat a hasty retreat.

    • Cyri R. says:

      Science has certain processes. If you want to attack people (which is a big part of Calabrese’s argument as well), then you are doing something else. I would think that even if you believe that the “battle” is rhetorical, you would want to be “armed” with truth.

      It looks like we’re armed with a whole arsenal of truth. See for example this article by the late Cohen:

      http://www.world-nuclear.org/sym/1998/cohen.htm

      This is 15 years old. How come supposedly scientific groups are still clinging on to LNT when a scientific approach, if anything, debunks the very theory of LNT?

  9. Cheryl Rofer says:

    Hi Brian -

    You’re the only one who actually has addressed BEIR in this fracas. Since Rod has decreed this thread to be about history and rhetoric, we can’t have that discussion here.

    I regret that we haven’t been able to have that discussion. I read the BEIR report quite differently than you do, perhaps because I have done a similar sort of thing – reviewing the literature and making sense out of it – on a smaller scale. My resulting paper was published in a top-of-the-field journal and frequently referenced.

    BEIR does state criteria for accepting data as useful, and they do discuss hormesis. Since Rod’s rules seem to be that one asserts and requires that the other do the research, I’ll assert, and you can check that out. Hint: the appendix on hormesis is entitled “Hormesis.” And here’s the link to the report: http://www.nap.edu/openbook.php?isbn=030909156X

    I’m recalling criteria in the BEIR report; it’s been a while since I’ve read the report in detail, so perhaps that word doesn’t occur in exactly the way you’re looking for. I was looking for criteria, so perhaps I identified criteria without the report’s using that word. Some of the criteria are statistical: the numbers in a study must be sufficient to show small effects, for example.

    So good luck to you! I’ve got a bunch of other posts to work on, so, yes, I’m leaving this discussion. I thought it was about science, but Rod makes it clear that he’s doing something else.

    • Rod Adams says:

      @Cheryl

      Since Rod has decreed this thread to be about history and rhetoric, we can’t have that discussion here.

      You sure like twisting and selecting words – for someone who professes to care about science.

      My exact statement was

      “If that is how you feel, thanks for stopping by. My blog post is about history and about an article published in the Chicago Law Review, not a science journal.” It was in response to an assertion from you that you only wanted to talk about science.

      I am a very liberal moderator and do not try to direct the conversation or even to keep it on topic. I will, however, assert the right to select the topic for my own comments and will resist the efforts of someone who is attempting to steer ME in a certain direction.

      For someone who frequently uses the word “innuendo” to describe the way that I argue and introduce motive as a topic of conversation when discussing committee based science or antinuclear activism, you sure like snide comments – like the following:

      Since Rod’s rules seem to be that one asserts and requires that the other do the research, I’ll assert, and you can check that out.

      There is nothing in this thread, or anywhere else on Atomic Insights that comes even close to being “Rod’s rules” other than avoid direct attack on participants in the discussion. (Attacks on the positions and behavior of public figures are allowable.)

    • Rod Adams says:

      @Cheryl

      You’re the only one who actually has addressed BEIR in this fracas.

      I went back and reviewed my original post. I never mentioned BEIR or the BEIR process. In fact, I was not even talking about just radiation, but also the way that limits for chemicals that have been classified as hazardous or carcinogenic are established. Once again, you are trying to dominate the conversation and establish the rules. That might work in some forums, but not in my house.

    • Rod Adams says:

      For the record, this is the carefully phrased section of the BEIR VII report that defends the committee’s decision to cling to the LNT assumption:

      At doses less than 40 times the average yearly background exposure (100 mSv), statistical limitations make it difficult to evaluate cancer risk in humans. A comprehensive review of the biology data led the committee to conclude that the risk would continue in a linear fashion at lower doses without a threshold and that the smallest dose has the potential to cause a small increase in risk to humans. This assumption is termed the “linear no-threshold model”

      (Emphasis added)

      Since I’ve rarely met any scientist who is willing to speak forcefully about their own limitations, I will translate the bolded section above. It is IMPOSSIBLE to evaluate the cancer risk at doses below 100 mSv because it does not exist. There is also no evidence, certainly not from the “gold standard” Life Span Study, that risk from radiation accumulates any more that mild exposure to the sun’s rays accumulates. Cells recover.

  10. DV82XL says:

    Rod I wouldn’t bother wasting time on Ms. Rofer, based on past experience with her she will only see any criticism as a personal attack. In general her understanding of nuclear matters is shallow and uniformed yet she holds unshakable opinions on the subject that she will defend to unreasonable lengths. I have yet to see her contribute anything of consequence to any discussion on the topic, but she is quick to turn on anyone that attempts to correct her even on matters of fact. Failing that, she will leave in a huff blaming everyone else for the tone which she herself has brought to the thread.

    • Rod Adams says:

      @DV82XL

      Concur with your diagnosis. However, I’ll still engage in order to reach the people reading the exchange. Accusations unanswered remain standing.

  11. Cyril R. says:

    Regarding the main theme, understanding risk models in radiation, I’d like to point out that even if the conservative LNT is used, most of the public outcry and investments in nuclear plants and waste repositories have just been absurd.

    Cohen is (well unfortunately was, as he recently deceased) an expert in this area.

    http://www.phyast.pitt.edu/~blc/book/chapter5.html

    http://www.phyast.pitt.edu/~blc/book/chapter8.html

    Even if we use the worst case model, it’s clear that there’s nothing to worry about in all highly publicised “scandals” involving failures of nuclear plants, waste storage facilities etc.

    The story about the billion dollar vitrification facility that was built that wouldn’t even save 1 life (not even with LNT) is particularly apalling.

    So the point is that something other than a conservative model is going on here. It appears to be largely politics combined with public misunderstanding of anything nuclear. It’s not about the risk models, rather it is a lack of using these risk models (even if LNT) to decide whether to invest billions and billions in nuclear plant upgrades and waste entombment.

    Even if LNT is wrong, it was clearly not even used at all in the decision to invest billions (it wouldn’t even save 1 life so not worth the investment).

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