Scientists for Accurate Radiation Information (SARI) recently delivered a petition to Scott Pruitt, the new Administrator for the Environmental Protection Agency (EPA).
The letter, signed by 34 members or associate members of SARI, requests that Mr. Pruitt direct his Agency to revise the basis of risk-based radiation regulations. SARI members believe that regulations should be on a firm foundation of sound science that is aimed at the best possible protection of human health and the environment.
The letter includes specific action requests and justifications that are based on solid foundations and references.
Aside: Unfortunately, several of the references for SARI’s letter are behind some discouragingly high academic journal paywalls. Please contact us if you need access to any specific reference. End Aside.
Since the EPA’s inception, responsible decision makers have resolutely defended its initial choice to use a simplistic, straight line model that asserts that the harmful effects of radiation or chemicals at extremely high dose continue to be delivered no matter how low the dose is all the way down to absolute zero.
The linear, no threshold assertion acknowledges that reducing doses reduces the magnitude of the effects, but doesn’t acknowledge that there is any point at which the effects completely disappear or become so small as to have an effect that is below any concern.
After choosing that simplistic model for radiation because it appeared to be an easy [cheap] way to compute numerical limits, the EPA later expanded the application of the “no safe dose” assertion to numerous manufactured chemical compounds and even to elements like lead, arsenic, and radon.
By firmly asserting that there is always some kind of negative effect of exposure to regulated materials or to radiation, the EPA created a situation where there has been continuing pressure to “increase safety” or “improve environmental cleanliness” by reducing limits.
The pressure to reduce limits extends to situations where there is no experimental evidence of harm when humans or animal stand-ins for humans have been exposed to materials at or near the regulated limit. It even extends to situations where solid experimental evidence indicates that subjects receiving the radiation dose or regulated chemical exposure have better outcomes than the “control” populations that do not receive the dose or exposure.
Limits that are continually ratcheted to lower and lower levels as sensing equipment capabilities improve can add enormous cost burdens without any improvement in overall outcome. Clean-up equipment effectiveness has not progressed at the same rate as sensing technology capability. Devotedly cleaning selected locations to meet overly ambitious standards exhausts available resources and leaves many more concerning areas untouched and waiting for their allocation of funding.
The other detrimental effect of government regulations based on assuming that any exposure at all carries a probability of harm is that it provides a seemingly rational basis for irrational fear, uncertainty and doubts about safety. People who believe that they “see” ghosts or assume that there are creatures in the dark just waiting to pounce cannot lead normal, healthy lives.
SARI believes that the Environmental Protection Agency must stop using a similar assumption that harmful effects always exist, even when radiation doses or chemical exposures approach absolute zero. Their petition letter concludes as follows.
LNT-based radiophobia fuels needless evacuations, results in extraordinary environmental cleanup costs, inspires avoidance of life-saving medical procedures, produces pressure to lower the diagnostic quality of radiation-related medical imaging, and promotes nuclear fear. Considerations of the basic sciences of biology, physics, chemistry, and other natural sciences should be either the source or the final arbiter of scientific hypotheses about ionizing radiation. Epidemiological studies that identify associations with disease do not prove causation. Many of the key studies often referenced in support of the LNT suffer scientific flaws(1) , that ignore the manifold findings of those basic sciences and make their conclusions based on the precautionary principle (rather than the precautionary approach) that radiation exposure must be proven safe for it to be considered safe. This is an impossible task and not consistent with sound scientific principles. . Failure to take proven biological reality into account leads to counterproductive statistical exercises, sometimes fraught with numerous errors. It further leads to the appearance of erudition purely through mathematical complexity. These studies are not benign; they do not err on the safe side; and they have deadly consequences.
Thus, we ask that the EPA’s risk-based radiation regulations be revised as above, as soon as possible.
Disclosure: I am a member of SARI and a signatory to the letter.