Draft document: Recommendations
Submitted by Eileen McCabe-Olsen, Shundahai Network
Commenting on behalf of the organisation

--Should radiation from human-made nuclear waste be “exempted” from regulatory control? (Section 2.4 Exclusion and Exemption) In recommending that some level of radiation is too low to worry about and doesn’t warrant regulation, ICRP is inappropriately taking on the societal role of “justifying” unlimited and unknown numbers of unnecessary and preventable public exposures. ICRP is mixing its self-designated roles as provider of scientific information with societal risk decision-maker. Since ICRP is a closed, self perpetuating body, without nuclear power critics, it has no moral or representative authority for making assumptions about the acceptability of risks from involuntary doses to members of the public from the nuclear power fuel chain. ICRP simply does not have public representation, thus has no authority to assess what additional, unnecessary radiation risks members of the public around the world in this and future generations consider trivial or acceptable. ICRP claims it does not have enough certainty about the effects of low dose radiation on large populations (termed “collective dose” estimates) to estimate the number of cancers that will result in that population now or in the distant future, yet ICRP thinks it has enough scientific and socio-political information to actually release radiation to large populations – with no limit on the number of worldwide releases or “exemptions”— with no limit on the number of exemptions per facility or to a community—without their consent or knowledge. ICRP makes a self-determination that the risks are trivial and acceptable by the public (at the same time it discourages estimating what those risks are). ICRP does not know how much total radiation will be released or received when it, across-the-board, recommends not only that countries adopt release levels but also specifies a suggested level or range. There is absolutely no scientific justification for this recommendation – it is purely economic for the sake of the industry. The whole concept of exemptions should be deleted from the ICRP 2006 Recommendations. Furthermore, the ICRP should remove the lower bound (essentially an exemption level) from the radiation levels throughout its text and in its charts on “constraints,” doses, and bands of regulatory control (including Section 5.8.2 para (204) and Table 4, p. 61). Industries should be responsible for and protect the public from all doses not just those above an ICRP-selected level. ICRP suggests governments decide what they want to regulate and what they don’t, then establish “what could be exempted from some regulatory requirements because regulatory action is unwarranted...the legislative framework should provide the regulator with the authority to exempt situations from regulatory requirements, particularly from those of an administrative nature such as notification and authorization…Exemption…relates to the power of regulators to release from specific regulatory obligations…waiving…legal obligation. ” [page 17, paragraph (42) of Section 2.4] Because radiation can travel from a source and be deposited globally, it is inappropriate to allow governments to decide what they want to regulate. Regulation must be global. We suggest ICRP completely get rid of this strongly objectionable and unacceptable recommendation and all of Section 2.4. In the US, the Nuclear Regulatory Commission has delayed its rulemaking that would generically deregulate much radioactive waste and material, but NRC is regularly taking applications for case-by-case exemptions such as those from owners of nuclear reactors undergoing decommissioning —allowing some of the nuclear waste to go to sites without radioactive licenses, permits or controls. The US public actively opposes and challenges these and opposes US and ICRP to allow generic and case-by-case exemptions. We are working to prevent all efforts to allow industry-generated radioactive materials and wastes to be exempted or excluded from nuclear regulation with the goal of preventing public release and exposure. We suggest ICRP acknowledge and accept this perspective on public protection from radiation. ICRP should immediately cease this recommended abrogation of regulatory responsibility by removing all of Section 2.4 from the 2006 recommendations and all subsequent documents. --Should ICRP officially adopt the Precautionary Principle—when in doubt, prevent unnecessary radiation exposures? ICRP’s composition is completely one-sided; its mission is promotional not protective of human health and other living beings or biosystems. As ICRP claims to attempt to open up –become more transparent, it must include members who are not fully committed to the continuation of all nuclear activities as there is no objectivity, balance, credibility when those risking the dose are not even represented. ICRP should be clear about which of its assertions are scientific and cite the sources for those statements, and just as clear about which are value judgments (such as the misguided claim that there is a trivial or acceptable dose that can be exempted, below which resources are not justified to regulate, or a lower band of constraint dose that does not need to be regulated). Removing the unjustified or one-sided societal judgments could potentially help the credibility of the ICRP. ICRP has 3 basic principles for radiation exposure: Justification—a government body (such as the national legislatures or nuclear agencies) or the nuclear industry licensee/operator decides that an activity which releases radioactivity and exposes people to radiation is “justified.” The general public which is exposed does not get to decide but does receive the doses—This is clearly unethical and immoral, unfair, unacceptable. Yet ICRP sees it as a basis for permitting doses and proceeds to provide ranges of acceptable doses in various situations…all the way up to 10,000 millirads per year! A level that will give cancer to 1 in 3 exposed for 30 years. (This is the ICRP-recommended level that US Department of Homeland Security adopted in January 2006 as acceptable for moving people back in after a dirty bomb.) Justification makes sense when the exposed person decides, not when that person has no say but the entities making and controlling the potential hazard decide. It is even more questionable in non-Democratic societies, more and more of which are establishing nuclear power and weapons industries right now. Optimization- a convoluted process by which the nuclear promoters determine how much it is worth to regulate and reduce exposures. It is used as a justification for exposing people in all situations. There is no guarantee or mechanism for the exposed individuals to determine if or how much radiation is imposed on their bodies. Includes the concept of ALARA – as low as reasonably achievable – taking the industry’s economic factors into consideration in deciding what is “reasonable.” Limitation of Dose- The assumption that the radiation establishment chooses protective dose limits …A major fault is that public doses are not simply, economically and practically measurable thus are not verifiable or enforceable. Another serious flaw is that low, chronic doses are potentially more harmful per unit dose than single higher doses so simply limiting doses does not necessarily protect people. In addition, doses are calculated based on standard man or, as this update encourages, “gender-averaging” and a “representative individual” who does not have “extreme” habits. Thus, doses are not based on risks to the more vulnerable like women, fetuses, older adults, children, people with AIDS or other reduced immunity or preexisting high cumulative doses. Unnecessary radiation doses should be prevented and avoided, not permitted at low or continuous rates. If they are to be set, they should protect the most susceptible taking uncertainties including synergistic effects into account. ***ICRP should restructure its framework to incorporate or replace its basic principles not only with the Precautionary Principle, but with the Seventh-Generation Principle. *** --What do you think about “averaging” radiation risks? Do you think it is time that ICRP acknowledged and accounted for non-cancer health risks from radiation like cardiovascular diseases, reduced immunity, as well as cancer? Isn’t it about time radiation risks are considered along with those of other carcinogens and pollutants in the environment, workplace and body? How should (relatively new) biological knowledge, like the bystander effect and other uncertainties about the impact of radiation at low doses be incorporated into existing radiation standards? Rather than attempting to protect the most vulnerable, ICRP estimates averages risks to men and women and among age groups to protect the average rather than the most vulnerable of those studies…ignoring those groups and individuals. ICRP also ignores non-cancer health effects--- how much longer can the connections between radiation and other diseases and conditions including cardiovascular and immune deficiencies be ignored by the Commission that claims to be comprised of international experts. ICRP also needs to acknowledge and account for the large potential for much greater health damage from multiple exposures to radiation and other hazardous materials and conditions in the environment. Radiation damage is multiple, additive, cumulative and synergistic and should be considered such by ICRP. Some of these concerns are addressed with suggestions for quantifying the risks and uncertainties in the European Committee on Radiation Risk (ECRR) in its 2003 Recommendations of the ECRR: The Health Effects of Ionising Radiation Exposure at Low Doses and Low Dose Rates for Radiation Protection Purposes: Regulators’ Edition. We recommend ICRP more carefully review this report before proceeding with new recommendations. --Should “acceptable” radiation levels (above natural background) be set for BIOTA (animals, plants and the environment)? We are glad to see that ICRP is acknowledging that protecting humans does not de-facto protect other species or ecosystems (as has been the mantra of the radiation hierarchy until now—and some still espouse it), however, we oppose the legalization or setting of acceptable contamination levels for animals, plants and environments. The motivation is clearly to relieve radiation polluters of liability and should be replaced with the seventh-generation principle approach. ICRP should be asking the question “How can we prevent radiation exposure of nonhuman species?” rather than relieving of liability those that cause contamination and exposure. ICRP suggests it will follow the same framework as it has for human beings—we repeat our call for replacing that framework with precaution—not spreading it to other species who have absolutely no way of participating in “justification” or “optimization” decisions. ICRP, ignoring all previous complaints about the “standard man” now “reference person,” is pursing the untenable concept of identifying and using reference animals and plants, when there is such immense diversity at the cellular and organismic level that such efforts are almost laughable. The complexity of cells, tissues, individuals, populations, species, interaction of species, and ecosystems cannot be simplified to a reference mammal, reference duck or reference fish. Synergistic effects will further compound the equations. These increased uncertainties should be accounted for with increased conservatism and the goal of preventing exposures.