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Submitted by Lynn Howard Ehrle, Chairman, International Science Oversight Board
   Commenting on behalf of the organisation
Document Health risks attributable to radiation
In the Matter of the Committee 1 Task Group Report: Principal Conclusions and Proposals

Since several Committee members are co-authors on low-dose risk assessment papers and since all of these members have signed on to summary statements that seriously understate the risk, their obvious bias in their list of conclusions and proposals is easily detected.
a. U.S. Natl. Cancer Institute: C Land and E Ron
b. UNSCEAR 2000 consultants or national delegates: R Cox, E Ron, K Sankaranarayanan, J Preston and A Kellerer
c. PNAS 25 Nov 2003 low dose cancer risk paper: E Ron, C Land, D Preston, J Preston and J Little
d. BEIR VII: R Cox, A Kellerer, K Sankaranarayanan and R Ullrich

Lines 184-186: The following summary statements relate largely to the health effects of radiation in the dose
range up to a few tens of mSv for the purposes of radiation protection.
Comment: The phrase "up to a few tens of mSv" is imprecise and the paper makes no estimate of the
low-dose range, thus leaving the impression that any dose above30-40 mSv should be
considered a high dose. UNSCEAR 2000 submits "a low dose might be considered to be
any exposure up to about 200 mGy" (v. II, Annex G, p.79).

Lines 188-190: For cancer and hereditary disease at low doses/dose rates the use of a simle proportionate a scientifically plausible assumption.
Comment: The European Committee on Radiation Risk (Health Effects of Ionising Radiation Exposure
at Low Doses for Radiation Protection Purposes, 2003) concludes, "there are good reasons
for assuming that effects in the low dose range from zero dose to about 10 mSv are likely to
follow some kind of supralinear or fractional exponent function...the emphasis on initial
radiation damage processes implicit in the ICRP system is only valid for high doses delivered
externally." UNSCEAR 2000 concludes, "a strictly linear dose response should not be
expected in all circumstances" (v. II, Annex G, p. 160).

Lines 192-196: A dose and dose-rate effectiveness factor (DDREF) of 2 recommended in Publication 60
should be retained for radiological protection purposes.
Comment: ICRP Publication 60 was published in 1991. Its conclusions are outdated and obsolete
in light of other authoritative studies over the past 15 years. For example, more recent Life
Span Study data (D Pierce, Y Shimizu, D Preston, M Vaeth, K Mabuchi-- Report 12, Part 1,
Radiat Res 1996;152:1-27) estimate a fatal cancer risk factor of 0.12 per Sv, more than
double the ICRP 60 estimate of 0.05. The underlying premise of a DDREF factor is that
"human dose-response for acute exposure is likely to have a concave-upward shape,
except at extremely high doses...readers are reminded that when RERF analysts
examined all the A-bomb 1956-1985 data (Y Shimizu, H Kato, W Schull, D Preston,
S Fujita, D Pierce--Life Span Study Report 11, Part 1), they found the dose- response
to be either linear or supra-linear" (John Gofman, Radiation-Induced Cancer from Low-
Dose Exposure, 1990, Chap. 22).

Lines 218-219: Cancer risk following in-utero exposure is judged to be no greater than that following
exposure in early childhood.
Comment: Alice Stewart's Oxford Survey of Childhood Cancers (Brit Med J 1958;1:1495-1508)
demonstrated that an in-utero X ray of a 10-20 mGy dose to a pregnant woman resulted
in a 40% excess incidence of cancer and leaukemia in the child before age 10. This study
was confirmed by MacMahon (J Natl Cancer Inst 1962;28:1173-1191) and Doll and
Wakeford (Brit J Radiol 1997;79:130-139). There are no studies demonstrating this
level of excess cancer incidence in infants whose mothers have not been exposed.

Lines 232-236: Dose responses for radiation-induced tissue reactions (deterministic effects) in adults
and children are, in general, judged to have true threshold doses which result in the
absence of risk at low doses.
Comment: "The existence of any threshold, even at the lowest dose, has been thoroughly discounted.
UNSCEAR 2000 notes, Cells are able to repair both single- and doouble-strand breaks
in DNA over a period of a few hours, but this repair can be imperfect, resulting in
long-term cellular damage and mutation...error-free repair is not anticipated... breakage
of both strands of the duplex may be achieved by the traversal of a single ionizing track
and does not require multiple-track action" (v. II, Annex G, p. 80.)

Lines 244-245: Risks of non-cancer disease at low doses remain uncertain and no specific judgment
is possible.
Comment: The ECRR Report examines data relating to populations exposed to low level internal
radiation from fission products released from Chernobyl, following Hiroshima, and also
following exposures to depleted urnium (DU) particles in the war zones of Iraq and Kosovo.
Tables 12.3, 12.4, and 12.5 reference studies that document a variety of non-cancer effects.
Unfortunately, Committee 1 and the ICRP has ignored these and other studies and the
whole subject of internal emitters.

The C1 Foundation Document (FD-C-1) commits sins of scientific omission and comission
and should be rejected. The Comments section does not represent peer review by
independent investigators and there is no assurance they will be taken into account
when the finaldocument is codified. Many papers and books by independent scientists
don't even appear on ICRP reference lists, let alone find their way into the drafts. As noted
in my previous Comment, the revolving door is alive and well at ICRP. Same names,
same faces.