Acting EPA administrator appoints Dr. Brant Ulsh to head radiation advisory council

Sometimes, there are benefits to breaking things. It’s often the only way to eliminate barriers and walls that prevent progress. The process can create dust and debris that must be cleaned up to allow erection of a solid, stable path, but without the initial sledgehammer attack, nothing gets done.

For more than 20 years, I’ve been studying and writing on the issue of the health effects of low level radiation. Despite the sustained efforts of hundreds of scientists and thought leaders, the establishment has stubbornly defended an out of date, never proven model that assumes every dose of radiation increases the risk of cancer development.

The questioners have written books, published hundreds of peer reviewed articles, filed petitions for rulemaking, provided sworn testimony, held major meetings and even obtained congressional support for a decade-long research effort. The enormous bureaucratic marshmallow that defends the continued use of the LNT has refused to budge.

There are powerful forces that like the current situation, where the public–and much of the nuclear energy and medical radiology professions–have been carefully taught to fear all radiation, even down to a single gamma ray or tiny amount of radioactive material. This battle is not about corporations attempting to weaken protective regulations in pursuit of higher profits.

It’s about scientists and technicians seeking to inform and regulate based on accurate science. As a side benefit, evidence-based rules will result in a far more productive allocation of resources and unleash enormous opportunities to improve the human condition.

I’m now optimistic that progress will be made, though there will continue to be vociferous wailing and gnashing of teeth.

Last week, the acting EPA Administrator appointed Dr. Brant Ulsh to chair the EPA’s radiation advisory council.

Last year, Dr. Ulsh partnered with John Cardarelli, a career Uniformed Public Health Service officer, and published a detailed, peer-reviewed paper titled It Is Time to Move Beyond the Linear No-Threshold Theory for Low-Dose Radiation Protection. That document clearly identifies the weaknesses of the current model and the benefits that can accrue to society from replacing it with a radiation protection model that is based on modern science.

Not surprisingly, the forces that support and depend on the continued adherence to the old, disproven paradigm are working diligently to discredit Dr. Ulsh and to attempt to paint him as being part of a fringe that is trying to endanger the public. Supposedly, he and his colleagues are only motivated by evil nuclear energy corporations that seek to weaken protective regulation in hopes of making larger profits.

That portrayal is patently false. In fact, the “nuclear industry” in the form of the Nuclear Energy Institute has repeatedly refused to support grass-roots efforts to implement better models. They are comfortable with the existing rules and believe it would be counter productive to spend any money helping the public understand that they have been lied to by scientific and regulatory bodies that they are supposed to blindly trust because…?

Ellen Knickmeyer from the Associated Press published a widely repeated article about Dr. Ulsh’s appointment titled Skeptic on radiation limits will head EPA radiation panel. She portrays him as an outlier and quotes a staff scientist for the Natural Resources Defense Council who accused him of representing a “fringe” that is propagating “dangerous theories.”

In her article, Ms. Knickmeyer states that she attempted to obtain a comment from Dr. Ulsh, but had not received a response. I contacted Dr. Ulsh and asked him about that statement.

“Ms. Knickmeyer interviewed me back in late 2018. I sent her several papers to back up my position that hormesis shouldn’t be arbitrarily excluded, but rather objectively evaluated alongside other theories. She apparently ignored all of them. This time around, I decided that it was a waste of time talking to her.”

Ms. Knickmeyer asked whether or not Dr. Ulsh would use his new position to encourage discussion and reconsideration of the “no tolerance” dose protection policy.

I didn’t ask that question; the answer seems obvious to me. As my mentors in the Navy taught me, people put into positions of responsibility and influence are expected to take advantage of the opportunities those positions provide. I expect him to initiate an evidence-based discussion among members the radiation advisory council in the near future.

I responded to Ms. Knickmeyer’s article with the following comment, which appeared for several hours yesterday before disappearing from the ABC News site where it was posted.

I’ve had the opportunity to correspond with Dr. Ulsh and to read several of his well-researched and carefully documented papers. He is an excellent choice to head the EPA’s radiation advisory committee.

The “zero tolerance” model of radiation exposure has enormous holes. It treats radiation and radioactive materials produced as a result of extracting clean energy as somehow being completely different from naturally occurring sources of radiation. There’s no physical or biological reason for this prejudicial treatment; from a cell’s point of view alpha particles or gamma rays from “natural” sources are indistinguishable from those produced by “manmade” sources.

There is no evidence of any direct or indirect harm to humans from exposures below 100 mGy in a short period of time, and there is abundant evidence from studies conducted all over the world during the past 100 years that biological cells have response and repair mechanisms that offer protection agains low doses and low dose rates.

Dr. Ed Calabrese, mentioned in the article, not only has a better model for radiation health risks based on hundreds of toxicological and radiation studies, he has also published a deep and wide series of peer-reviewed papers tracing the historical context under which the LNT became the politically dominant model.

As he has discovered, there was a small group of eugenicists led by Hermann Muller and often funded by the Rockefeller Foundation that decided to push a “one hit” or “target” model of radiation effects on genetic material. Their initial work was aimed at purposely causing mutations to occur, but they later recognized that it was in their interests to exaggerate radiation health effects as a means of stimulating greater support for their research.

They succeeded in obtaining increasingly large research grants from the Rockefeller Foundation with a big burst of funding immediately after they published a widely promoted report claiming that there was no safe dose of radiation. At the time, more than 70% of the RF’s annual income came from interest and dividends on oil, coal and gas related bonds and stocks. 

Some believe that the exaggerated fear campaign was motivated by a desire to activate the public to press for a halt to atmospheric weapons testing. That campaign succeeded by 1963, just a few years after the Genetics Committee report. There’s another obvious explanation for the generosity given in response to effectively scaring the public about the radiation associated with nuclear energy.

If we were not taught to be afraid of any an all radiation, we would use more nuclear fission power and LESS coal, oil and gas power. Hydrocarbon interests have a strong desire to maintain radiation fear. I suspect there will be vociferous, well-funding lobbying directed rear guard efforts to cling to LNT. We shouldn’t let propaganda goals interfere with scientific truth. 

Nuclear energy is cleaner, more abundant, and safer than burning fossil fuels.

Rod Adams
Publisher, Atomic Insights

Several other comments experienced similar treatment of being initially accepted and then removed. Some of the authors of those comments agreed to allow me to attempt to add their thoughts to the discussion.

From Dr. Jerry Cuttler: “Why use the linear no-threshold (LNT) model to assess the risk of health effects induced by ionizing radiation when there is clear evidence of a dose threshold for a short exposure and a dose-rate threshold for a lifelong exposure? https://www.ncbinlm.nih.gov/pmc/articles/PMC6327330/ 

and https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6311660/ ”

From Dr. Mohan Doss: “The article quotes NCRP’s Commentary No. 27 to support the concept that there is no threshold for radiation induced cancer. Please see the brief refutation of NCRP Commentary No. 27 at https://www.x-lnt.org/refutation-of-ncrp-commentary-no-27 and a more detailed refutation athttps://www.ncbi.nlm.nih.gov/pubmed/30262515 where you can see a compilation of a large amount of evidence showing that low levels of radiation actually prevent cancers. Therefore, Brant Ulsh’s criticism of EPA’s policies on low levels of radiation are indeed scientifically justified and he is highly qualified for the position at the EPA.”

PS – The European Journal of Nuclear Medicine and Molecular Imaging recently published an editorial showing that Dr. Ulsh’s position is supported by sound science and isn’t an outlier. That editorial is available online. It’s titled The Good Rays; Let Them Shine