Questioning Official Standards for Permissible Exposure to Radiation

In Uncategorized on November 14, 2015 at 1:06 am

Official standards for permissible exposure to radiation mislead people. They are not just imprecise; they are inaccurate. In fact, they deny reality. Established to protect people exposed to radiation – nuclear workers as well as the general public – these standards provide false assurance that makes it possible for a harmful industry to operate. We have been told time and again that the standards exist to protect us, and government officials never tire of telling us we are safe, but the protection these standards provide is only partial. They do not for example protect us from exposure to plutonium-239, the exposure most likely to happen to people in the vicinity of Rocky Flats.


I learned about the Rocky Flats plutonium pit mass production plant in 1979 and soon realized that exposure to plutonium endangered plant workers and people in nearby communities, especially those downwind of the facility. My primary focus over the next 35+ years was to learn what I could about adverse health effects from exposure to plutonium. I attended a seminar on this topic by the late Dr. Jock Cobb of the CU medical faculty. And I paid close attention to the work of radiochemist Edward Martell, PhD, of NCAR, the foremost student of radiation health effects in this part of the country. I also closely followed the Rocky Flats related work of Carl Johnson, MD, then head of the Jefferson County Health Department. I participated in public meetings during the decade of the Rocky Flats dose reconstruction study and was actively involved in various advisory and oversight bodies, especially those related to the cleanup of Rocky Flats, a major task of which was establishment of radiation exposure standards that supposedly would protect the public from harmful exposure to plutonium left in the environment after completion of the cleanup. For four years I served on two committees of the National Council on Radiation Protection and Measurements, the major U.S. organization that studies radiation health effects and recommends exposure standards to government and industry. In addition, I studied the work of specialists like Alice Stewart, Karl Morgan, John Gofman, Thomas Cochran, Helen Caldicott, Arjun Makhijani, Steve Wing and others. I carefully read the National Academy of Sciences BEIR (Biological Effects of Ionizing Radiation) V and VII studies on low-dose radiation exposure.


Based on all this, I concluded that, though radiation exposure standards provide some protection by setting limits that make high-dose exposures less likely, they provide insufficient protection from low-dose exposure, especially from tiny plutonium particles taken into the body. The BEIR studies mentioned above affirm that any exposure to ionizing radiation is potentially harmful. There is, in other words, no such thing as a safe exposure. Though this view is accepted by the National Academy of Sciences, the agencies that recommend and set radiation exposure standards allow some exposure. They create a legal framework that allows some people to be harmed, some to die. Also, despite the fact that there will be some exposures, government officials often call contaminated sites “safe.” This has happened and continues to happen with Rocky Flats. In what follows, I explain some of the problems with official standards.


  1. Failure to protect the most vulnerable. All radiation exposure standards to date have been based on studies of survivors of the Hiroshima and Nagasaki atomic bombings. In these attacks, the most vulnerable people died. Those who ended up being studied were thus the stronger survivors. This has been referred to as the healthy survivor effect. The resultant standards, based on Hiroshima and Nagasaki survivors, are biased in favor of a population of healthier survivors.


  1. Bomb survivor studies were unrealistic: Data was not collected until five years after the bombing. Thus, studies depended primarily on the memories of the exposed people who were interviewed rather than on actual exposure data. Much guesswork went into determining the doses these people had received. Add to this the fact that these studies were carried out by the victorious investigators from the U.S., not by Japanese medical personnel or advocates who had observed the suffering of their people at close range for a long time.


  1. Organizations that study and recommend exposure standards are closed to those exposed: After World War II national and international bodies were created to study radiation health effects and recommend standards for permissible exposure to radiation for nuclear workers and the general public. These agencies decide behind closed doors how much radiation other humans may legally be exposed to. Those exposed have no voice in the setting of these exposure standards. The principal organizations that perform this role are the U.S. National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP). These bodies are like a medieval priesthood, a closed society that decides the fate of the excluded.


  1. Exposure standards are based on analysis of radiation that passes through the body, not on radiation lodged in the body. The studies done on the Japanese survivors were of radiation exposure from a one-time bomb blast that emitted penetrating radiation to the whole body. This approach locked in a precedent still followed by organizations responsible for exposure standards. Penetrating radiation exposure may be severe, but it passes through the body and thus is temporary. This is very different from the internal chronic exposure that happens if plutonium particles from Rocky Flats enter the body. Plutonium is harmful only if inhaled or otherwise internalized. Columbia University scientists have shown that a single plutonium particle taken into the body can be harmful. Once inside the body, the plutonium migrates to a specific location where it lodges – a lung, a bone, the liver, the brain, the gonads or elsewhere. Thereafter, typically for the rest of one’s life, the plutonium repeatedly bombards nearby cells with radioactive alpha particles. Alpha radiation is not like gamma and beta radiation, which pass through the body and generally prove harmful only in doses large enough to kill many cells. Plutonium, by contrast, is harmful not because it kills cells but because it damages them, and it is the replication of these injured cells that produces a cancer. Plutonium may also compromise one’s immune system or cause genetic harm that gets passed on to offspring and future generations. One plutonium particle may prove harmful, not instantly but slowly. A cancer may take 30 years before it manifests. Harm from plutonium exposure is best addressed not at the bodily level but at the cellular level. The only sure form of protection from exposure to alpha radiation is to allow no exposure.


  1. Very low doses from internalized radiation are more harmful than larger doses of radiation passing through the body. Internal alpha emitters like plutonium 239, cesium 137, and strontium 90, to name a few, are much more harmful than the equivalent dose from penetrating gamma or x-ray radiation, because, as noted above, alpha particles lodge at a specific location in the body and continually irradiate nearby cells, while penetrating radiation passes through the body and is gone. To account for the difference, the ICRP refers to the “relative biological effectiveness” (RBE) of alpha emitters (This has also been called the “weighting factor”). Looking at the potential harm to different organs and for different disease end-points, ICRP concludes that the average RBE for alpha emitters is 20. This means that, on average, internalized plutonium is 20 times more harmful than penetrating radiation of the same dose. But because 20 is an average, for some body organs and certain cancers as well as for particular individuals the actual RBE can be higher, sometimes much higher. For example, the RBE for bone cancer ranges as high as 320, 16 times 20. But agencies that set standards use in their calculations the RBE of 20. This is one more way that radiation exposure standards fail to protect the most vulnerable.


  1. Reference man: Almost all radiation exposure standards have been calculated to protect “Reference man,” a Caucasian male 20 to 30 years of age, 5 feet and 7 inches tall, weighing 154 pounds, and living in a mild climate, such as in Western Europe or North America. Again, the standards have not been designed to protect those who are more vulnerable – females, infants, the elderly and the infirm.


  1. Distinct character of standards for nuclear workers. The foregoing points apply to the general public as well as to nuclear workers. The latter are noteworthy in that they are the only people who wear dosimeters to collect real-time data on their exposures. Also, official radiation exposure standards for them are much higher than those for the general public. In 1990 ICRP recommended that standards for U.S. nuclear workers be reduced 150%. This recommendation was not followed. Standards for nuclear workers remain at the level established in 1968.


  1. Excess cancers have been found among Rocky Flats workers who were exposed to plutonium well below official standards. In 1987 Gregg S. Wilkinson of DOE’s Los Alamos Lab published in the American Journal of Epidemiology results of a study on Rocky Flats workers, comparing those exposed to plutonium to those not exposed. Some of the exposed workers had internal plutonium deposits as low as 5% of DOE’s permissible lifetime body burden. The study showed that even these workers developed cancers in excess of what was normal for unexposed workers. Wilkinson was ordered by his supervisor to alter the results to “please the customer” (namely, the DOE), but he refused and published his study without change. A physician at Los Alamos told him that if his study was correct, it would shut down the nuclear industry. Rocky Flats workers I interviewed had not been told about this study.
  1. Follow-up study points to inadequacy of worker exposure standards. James Rutttenber of the University of Colorado Health Sciences Center spent a decade studying records of 16,000 Rocky Flats workers at the plant between 1952 and 1989. His conclusions, published in 2003, were similar to Wilkinson’s. They call into question, he said, whether current standards are sufficiently protective. However, Doug Benevento, then head of the Colorado Department of Public Health and Environment, called the results “reassuring,” since they don’t conclusively prove that cancer increases came from workplace exposures. Thus the State of Colorado’s leading public health administrator dismissed a central conclusion from years of research that his agency had supported.


  1. Those exposed often have no remedy: Nuclear workers exposed at DOE production sites like Rocky Flats often find it impossible to get medical coverage available from the federal government for which they helped produce nuclear weapons. With very few exceptions, neighbors downwind of nuclear facilities, whose health has been compromised, were never monitored and have received no medical attention or compensation.


Conclusion: Standards for permissible exposure to radiation rest on a questionable foundation. They are misleading and inadequate. They do not protect the most vulnerable. They downplay and sometimes altogether ignore the effects of radiation emitted internally, and they are established with no participation of those most likely to be exposed. Though it has been recognized for decades that low levels of exposure to ionizing radiation are potentially harmful, we are repeatedly told that official radiation exposure standards have been protecting us. These standards are not simply misleading; they are not merely inadequate; they are in fact a sham.


For more details on this topic, see Recommendations of the European Committee on Radiation Risk: The Health Effects of Ionising Radiation Exposure at Low Doses for Radiation Protection Purposes: Regulators’ Edition (ECRR, 2003) http://www.euradcom.org/2003/ecrr2003.htm This is dense technical reading, but worth the effort.



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