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Submitted by Dr. K. Shrader-Frechette, Center for Environmental Justice and Children's Health, Malloy 100, University of Notre Dame, Notre Dame, IN 46556 USA
   Commenting on behalf of the organisation
Document Low-dose Extrapolation of Radiation-Related Cancer Risk
 
(Please forward immediately to appropriate committee)

Comments on the Draft 2005 Recommendations to replace Publication 60

The draft 2005 recommendations of the ICRP are severely flawed and, indeed, if they are published in this form, they will discredit the ICRP -- which has, to date, enjoyed unquestioned scientific credibility. This document is far beneath the standards of the ICRP. It does not have references from the best scientific journals, and it relies on "gray literature." The best scientific literature,simply does not support its recommendations. Indeed, the document is mainly a set of value judgments, not well documented science -- even though ICRP scientists have no business making value judgments about how much risk is acceptable. It is the weakest ICRP draft document that I have ever seen. Putting out this document will ensure that most scientists and regulatory agencies no longer trust the ICRP -- and indeed, several top scientific journals in the US and the UK have already scheduled publication of severe critiques of this document in the next several months. It is an embarrassment to the ICRP.

As such, the document covers two topics, (1) human health protections and (2) environmental protections. The document is scientifically and ethically flawed with respect to both topics (1) and (2).

Regarding (1), human health protections, the report (1.1) errs in proposing to ignore all doses except those within the highest exposure class (workplace, public, medical), because, scientifically, all doses are additive and cumulative. and none can be legitimately ignored. Ignoring these doses also (1.2) contradicts traditional doctrines of free informed consent, accepted at least since the Nuremburg Trials of Nazi Germany. In addition, the report (1.3) commits the naturalistic fallacy is presuming to allow scientists, alone, to make recommendations about how much risk is acceptable; this decision should be made, also by ethicists, or else the draft report violates the risk-assessment norms laid out in the 1996 US National Academy of Sciences document, "Understanding Risk." The report (1.4) errs ethically in assuming risk magnitude, alone, can make a radiation risk acceptable or unacceptable. In erring through (1.4), the report errs in rejecting classical norms of consent, fairness, and equal treatment. The report also (1.5) is inconsistent in ignoring some low-dose risks, not encouraging calculation of all low doses, then claiming to accept ALARA and dose minimization. The draft report is full of internal inconsistencies, largely because it omits "counting" certain doses in certain expsosure classes, yet claims to subscribe to theories of risk minimization. Most importantly, because the report (1.6) ifnores certain low doses, it sanctions violation of the disclosure criterion for free informed consent.


Regarding (2), the draft report (2.1) errs in its understanding of Ecological Risk Assessment (ERA), and in making false claims about ERA. It totally ignores half of ERA and focuses only on toxicological ERA. It also (2.2) uses a non-standard, ill-defined, incomplete approach, that of "reference organisms" and its definition of RO is incomplete and inconsistent -- in alleging the ROs should have both political appeal and yet be scientific legitimate for drawing conclusions about other species. The draft likewise (2.3) errs in promoting analysis that is nontransparent and reliant on models and calculated doses, derived from reference organisms, rather than on empirical measures of air and water radionuclide concentrations. The document should endorse ALARA and make recommendations re air and water -- and save the derivative, nontransparent recommendations regarding references species -- to a later time. As such, by relying on calculated doses derived from reference organisms, the report (2.4) also errs in omitting abiotic protections -- such as air and water measures which are more reliable, cheaper, easier to make, and less easy to manipulate. Throughout the document, the draft makes many value jdugments m\asking as science, yet no one on the committee has advanced degrees in ethics. As such, the draft commits elementary fallcies in ethics -- such as the utilitarian fallacy and the naturalistic fallacy. The report is ethically not sound, and the committee needs ethics experts on it.