Draft document: Recommendations
Submitted by Joseph Mangano, Radiation and Public Health Project
Commenting on behalf of the organisation

The International Commission on Radiological Protection (ICRP) has issued a draft of its first recommendations since 1991, and has asked for comments. The ICRP has ignored much of the new scientific evidence developed in the past 15 years. Thus, it has produced a document not much different than the previous version, and falls short of assuring maximum protection to the public from radiation exposure. Much new evidence has contradicted the existing belief that exposure to low dose radioactivity is generally harmless. This general assumption is being replaced by specific findings based on empirical evidence, all of which is ignored by ICRP. A truly current and comprehensive ICRP document would include: 1. High Cancer Rates Near Reactors. There have been many descriptive studies in the medical literature since 1991 that document elevated rates of cancer near nuclear facilities. Many of these analyses focus on cancer in children, who are more susceptible to the biochemical effects of radiation exposure. They include - At least 11 studies showing elevated childhood cancer rates near different facilities in the United Kingdom - Articles indicating elevated childhood leukemia rates near reprocessing sites in Europe (Dounreay, Sellafield, La Hague, and Krummel) - A 2003 study showing childhood cancer rates exceeding the national rate near each of 14 U.S. nuclear plants studied 2. Underestimation of Risk. In 2004, the Committee Examining Radiation Risks of Internal Emitters (CERRIE), a blue ribbon panel convened by the British Environmental Minister, concluded that risks from radiation exposure to humans may have been underestimated by as many as 10 times. A minority of CERRIE members projected this underestimate to be as many as 100 times. The CERRIE based its conclusions on a variety of new findings in radiation biology since the 1991 ICRP recommendations, such as the “bystander effect” in which a cell harmed by radiation may affect otherwise healthy cells in the vicinity. 3. Miscalculation of Dose. In 2003, the European Committee on Radiation Risk (ECRR) produced a report that directly challenged the 1991 ICRP recommendations. The ECRR, which arose from criticisms of the ICRP dose model at a European Parliament workshop, used over 500 professional references to support its conclusions, most of them after 1991. The ICRP model is lacking, states the ECRR report, because of recent discoveries in biology, genetics, and cancer research suggesting the ICRP model of cellular DNA is not a good basis for risk analysis. Thus, the maximum permissible dose to the public should be no more than 0.1 millisievert (mSv), rather than the ICRP “safe” dose of 100 mSv. 4. Elevated Risk to Fetus and Infant. In 2003, the U.S. Environmental Protection Agency issued draft paper EPA/630/R-03/003. It concludes that harm from radiation exposure is considerably higher in young persons than in adults (children age 2-16 have three times the risk, while children under age 2 have ten times the risk). This paper officially acknowledges that use of risk models based on “average” humans minimizes risk to those who are especially vulnerable. 5. New Findings on Fetal/Infant Susceptibility. Since 1956, when Dr. Alice Stewart demonstrated that prenatal pelvic X-rays yielding a dose as low as 10-20 mSv significantly raised the risk of cancer deaths by age ten, the risk radiation poses to the fetus and infant has been a focus of research – but largely ignored by the ICRP. In the most recent document the ICRP stated that below 100 milligrays, lethal effects to the fetus are “infrequent” (100 mGy equals 100 mSv). The following are among the more recent studies to identify radiation risks to the fetus and infant (other than childhood cancer): -The October 23, 1999 Lancet published research showing that every additional 100 mSv of radiation exposure to external ionizing radiation before conception added a 25% risk of a child being stillborn. - An article in the January 2004 British Medical Journal documented that males irradiated for cutaneous hemangioma under 18 months had a progressively lower attendance rate in high school, documenting lower rates even at doses of under 20 mSv. - The April 28, 2004 Journal of the American Medical Association presented a study associating risk of low weight births with prenatal dental radiography at a dose of over 0.4 mGy (0.4 mSv). 6. New Findings on Bomb Fallout Risks. In 1991, U.S. public health officials had not admitted that fallout from 1945-1963 atmospheric nuclear weapons tests caused any harm. However, the release of a 1997 report by the National Cancer Institute estimated that Iodine-131 from tests – still considered low dose exposure - caused between 11,000 and 212,000 Americans to develop thyroid cancer. No acknowledgement of this landmark research study was made by ICRP. 7. New Findings of Nuclear Worker Risks. In 2000, the U.S. Department of Energy released a report summarizing many research studies, and concluding that workers at American nuclear weapons plants suffer from disproportionately high rates of various cancers. Congress subsequently passed a law entitling affected workers to compensation. Again, the ICRP made no note of this important development and its implications for radiation safety standards. 8. New Findings on Short Latency Period. Since 1991, much has been learned about risk to humans exposed to Chernobyl fallout. Perhaps the most striking finding has been the short latency between exposure and onset of thyroid cancer in children (as little as four years), and leukemia in infants (under one year). In the latter case, areas far from Chernobyl (Germany, Greece, Scotland, U.S., Wales) were affected, even though exposures were much lower than near the plant. 9. New Findings on In-Body Radioactivity. Since 1991, the first studies of in-body (baby teeth) radioactivity of humans exposed to reactor emissions have been published. Studies in Germany, Greece, and the Ukraine showed elevated levels of Strontium-90 after Chernobyl. Another showed Plutonium-239 levels decreasing with distance from the Sellafield plant. Another showed Strontium-90 highest in counties near 7 U.S. nuclear plants, and rising since the late 1980s. These studies, all documented in the medical literature, constitute the research community’s “gold standard” for dose estimates, but were ignored by ICRP. The importance of the pending ICRP recommendations cannot be emphasized enough. Since 1991, the number of nuclear power reactors worldwide has grown to 439, the amount of highly radioactive waste generated by these reactors has soared, and medical uses of radiation have proliferated. Moreover, the terrorist threat since the September 11, 2001 attacks make potential harm from radiation exposure even greater, in the event a reactor is attacked, a nuclear weapon strike is launched, or a “dirty bomb” is used. The overriding theme of these recommendations should be the so-called Precautionary Principle, which states that if consequences of an action are unknown but have potential for negative consequences, it is better to avoid that action. In the health field, this belief has existed since the Hippocratic principle of “first do no harm” of over 2,000 years ago. The series of assumptions that radiation exposure carries no risk that were later reversed by empirical research – for pelvic X-rays to pregnant women, atomic bomb test fallout, and occupational exposures in nuclear weapons plants – suggests strongly that the ICRP re-evaluate health risks of low-dose exposures, and lower the current limits. Finally, the ICRP makes a statement late in the document that decision makers should inform the public of their decisions on radiation protection. In a democratic and free society, it is the public who actually participates in policy decisions, rather than just being informed by leaders. The history of atomic bomb testing, for example, in which many independent scientists and citizens contended that fallout was harming the public (in the face of assurance of no harm from officials) illustrates why the ICRP must include public participation in their work.