As a former federal agency bureaucrat, I should have thought of this long ago. When agencies disagree over matters with significant budgetary impact, one way to arbitrate the dispute is to involve the people in Congress who are responsible for funding the agencies and the programs affected by their differing points of view.
One possible outcome of the discussions is a request by Congress for an investigation by the GAO (now the Government Accountability Office but formerly known as the General Accounting Office).
The continuing dispute over radiation standards, primarily between the NRC and the EPA, is well suited for a GAO investigation, especially since there is fundamental disagreement over the scientific basis for the regulations.
As I learned this morning — again, I apologize for treating history as news just because it is news to me — the GAO has been called in at least twice before — in 1994 and again in 2000 — in an attempt to resolve agency differences over radiation standards. For the 2000 effort, the agency provided both a report and testimony before the U.S. House of Representatives Subcommittee on Energy and Environment, Committee on Science.
In both efforts, the GAO reported that agencies used different models, different standards of protection, and different units of measure, resulting in duplicative, confusing and potentially very costly regulations. The 2000 report went further and was more explicit about its finding that there was no firm scientific basis for any of the regulations because they were derived using a model that had not been proven and could not be supported with measured evidence.
Here is are sample quotes from the testimony resulting from that investigation.
U.S. radiation standards for public protection lack a conclusively verified scientific basis, according to a consensus of recognized scientists. Below certain exposure levels, the effects of radiation are unproven. At these levels, scientists and regulators assume radiation effects according to the “linear no threshold hypothesis,” or model, under which even the smallest radiation exposure carries a cancer risk. However, the model is controversial among scientists, and decades of research into radiation effects have not conclusively verified or disproved the model, including studies attempting to statistically correlate natural background radiation levels in the United States and around the world with local cancer rates. Research is continuing, including a promising 10-year DOE program begun in 1999, addressing the effects of low-level radiation within human cells.
According to a consensus of recognized scientists, below about 5,000 to 10,000 total millirem of exposure, the effects of radiation are unproven. Evidence of these effects is especially lacking at regulated public exposure levels—levels of 100 millirem a year and below from human generated
Some scientists and studies held that there are considerable data to support the view that low levels of radiation can actually be beneficial to health—the highly controversial theory of hormesis. Proponents of hormesis argue that research indicating beneficial effects has not been adequately considered in the “consensus” scientific community.
Decades of radiation effects research have neither verified nor disproved the linear model. The research data on low-level radiation effects generally include two different types of studies. One type follows the long-term health of a studied population, seeking statistically significant cancer effects, and is called epidemiology. Another type subjects animals or tissue or cell cultures to radiation, seeking biological evidence of radiation effects, and is called radiobiology.
The 2000 report expressed high hopes for useful information from the DOE’s Low Dose Radiation Research program, which was initiated in 1999 with an expectation of lasting at least 10 years. Here is a quote from that report.
Radiobiological studies, particularly molecular studies, may eventually develop more conclusive scientific evidence of low-level radiation effects than epidemiological studies, according to scientists. Past radiobiological research has helped to establish, among other evidence, the genetic effects of radiation and its effects on individual body organs.
Recently, there has been interest in research into the cellular processes through which radiation causes cancer, in part in relation to progress in human genome research in the 1990s. Researchers have been obtaining a better understanding of specific phenomena such as DNA damage and repair, chromosomal instability, so-called “bystander” effects on neighboring cells, and cellular adaptation to exposures.
Researchers are looking into such cellular processes for biological signs (or “biomarkers”) of radiation cancer causation. Several stages are apparent in the development of radiation caused cancer: DNA damage, misrepair, cancer initiation, cell proliferation, and tumor promotion (with subsequent malignant transformation). To date, the first stage in the process is better understood than the long-term second stage. Since fiscal year 1999, DOE has funded a research program targeting the biological effects of low-level radiation at the cellular level, with total funding of almost $220 million projected over 10 years.
The program is considered unique in that it is designed specifically to better validate the effects of very low levels of radiation in areas such as cells’ response to radiation damage, thresholds for low-dose radiation effects, and features distinguishing radiation-caused cell damage from damage from causes internal to the cell. Many scientists and regulators we interviewed said this type of research could eventually help to determine more conclusively the effects of low-level radiation and their potential link to cancer causation.
(Paragraph breaks added for improved readability online.)
Aside: I acknowledge that the GAO report states that the program is a 10-year effort, but few scientists would be willing to agree that the duration of investigation required to arrive at a defensible conclusion can be predicted ten years in advance. End Aside.
The DOE Low Dose Radiation Research program was ended several years ago. There have been 15 more years worth of research and published material regarding the biological effects of low dose radiation, the history of the promoted effort to establish a no-threshold model, and the results of continuing evaluations of the various sources of epidemiological information.
Note: At the time this post was written, the DOE Low Dose Radiation Research web page at http://lowdose.energy.gov was not available. It was still listed as the reference site on the following pages DOE Low Dose Radiation Research Program at PNNL and DOE Biological Systems Science Division (BSSD) Radiobiology: Low Dose Radiation Research.
Billions of dollars per year are still being expended to achieve site clean-ups to the disputed agency standards and people are still being purposely frightened by statements regarding health risks of exposures that are within the natural variation of background. Those supposedly worrisome doses are often orders of magnitude below the doses that have been proven to be harmful to human beings.
Bottom line: It’s time for the GAO to take another hard look at the available scientific data and interview the experts in the field.
The GAO is the right body of investigators to consider the psychological, financial, and operational effects of continuing to assert that the tiniest dose of radiation carries a finite amount of health risk even though there is no evidence supporting that claim.