ML19224D157
| ML19224D157 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/08/1979 |
| From: | Hawkins D ENVIRONMENTAL PROTECTION AGENCY |
| To: | |
| Shared Package | |
| ML19224D154 | List: |
| References | |
| ACRS-SM-0130, ACRS-SM-130, NUDOCS 7907110008 | |
| Download: ML19224D157 (10) | |
Text
{{#Wiki_filter:. :. ...id.a;..C'f: [. :.,, - ~g. ..-.a....... '..:.an s a....:b a -=.... L a. .p, ,...s....., e d STATEMENT OF DAVID G. HAWKINS ASSISTANT ADMINISTRATOR FOR AIR, NOISE, AND RADIATION ENVIRONMENTAL PROTECTION AGENCY BEFORE THE SUBCOMMITTEE ON ENERGY, NUCLEAR PROLIFERATION AND FEDERAL SERVICES COMMITTEE ON GOVERNMENTAL AFFAIRS UNITED STATES SENATE May 8, 1979 _e Mr. Chairman and members of the Subcommittee. My name r.) is David G. Hawkins; I am the Assistant Administrator for Air, Noise, and Radiation in the Environmental Protection ~ Agency. It is a pleasure to meet with your Committee to ..-j discuss the recent reports assembled by the Interagency Task ~. 1 Force on Ionizing Radiation. The degree of interagency . x4 1 cooperation shown in the development of the.e reports was truly heartening and a goed (xample of what we are able to o. ~ accomplish when Federal agencies work together. It is p.. important to note that the task force recommendations are ? preliminary and should not be taken to pre-judge any final administration proposals. [-, The Environmental Protection agency contributed most i extensively to the reports of the work groups on scientific -)- research and exposure reduction, and I would like to comment v. briefly on these before turning to the most recently released report--that authored by the Department of Health, Education, and Welfare (DHEW) staff on the subject of 1 3 ~ institutional arrangements. y 260 009 m 7 9C 711 coot e O e .pg / _**OF..
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... y..- A ' The science work group report is an objective and accurate description of the current state of the uncertainties that exist in our knowledge of the effects of ionizing radiation on humans. Two of its principal recommendations deserve particular support and careful n. attention. The report recommends that any wide-scale epidemiological studies for radiation effects be preceded by preliminary analyses to determine the population si.ze, doses, and health info nation required to obtain meaningful and useful results before embarking on these long and W necessarily expensive undertakings. We hope this need for proper feasibility studies in order to insure useful results e is not forgotten in the surge of concern that has followed 9 the accident at Three Mile Island. The science work group also recommended that a national registry of occupational exposures be established. It must ~ be recognized that the success of such a registry will } depend on the cooperation of the medical and dental professions, government, industry, academia and labor organizations. On the basis of a comprehensive national survey of occupational exposure that we are just now } completing, we estima te that there are currently approximately one and a half million workers involved, and it will be necessary to demonstrate ? 260 010 i .y. ,. - -- ; p.,,, m .r..- ..f
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m . -J. :. .i. o. ' -m . r s. '. A,.. - ._.o ~> 4 that such a nation-i registry will not be unduly expensive 6 or burdensome. Among the recommendations contained in the work group ~ report on radiation exposure reduction are a variety of measures that could be pursued to reduce unnecessary medical .f radiation exposur e. I will not review them here, but it is perhaps worth noting in passing that the majority of these .2 recommendations are included in the Radiation Protection 3 Guidance to Federal Agencies for Diagnostic X-Rays developed under the sponsorship of EPA and promulgated by the President in January 1978. We urge and look forward to 'T early and vigorous implementation of this guidance and the working group's other recommendations for reduction of unnecessary medical radiation exposure of the U.S. population. The Agency's participation in the report on institutional questions (as well as that of other task group members) has been less direct than for the other work ~. groups. However, we have furnished the DHEW authors with our views, and these are general'ly adequately reflected in .I the draft report. O b kt e dj 260 01I i v-r' e s, , %_s *.. y. =:. r s.- *=== ': 7 s s q;. =t..
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I will address my comments to three areas: coordination of radiation protection, coordination of research, and, fi na".ly, the possible need for establishment of some kind of overall coordinating entity. ~. As the report indicates, EPA's current role in radiation protection includes both our broad authority to recommend Federal guides to the President on radiation matters affecting health, as well as specific authority for promulgation of a variety of environmental standard's under the Atomic Energy Act, the Clean Air Act, the Safe Drinking Water Act, the Federal Water Pollution Control Act, the 7 Resource Conservation and Recovery Act, and finally, the e Uranium Mill Tailings Radiation Control Act. Of particular interest in this case, however, is the function transferred fr om the forner Federal Radiation Council to the c. {, Administrator of the Environmental Protection Agency under Reorganization Plan No. 3 of 1970, to "... advise the President with respect to radiation matters, directly or -{ indirectly affecting health, including guidance for all Federal agencies in the formulation of radiation standards .z;- .*s 4 = I N y ,a ') .*y o-~-
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~. ' :f . ~ ..n . : % ".Y.. and in the establishment and execution of programs of cooperation with States." We, pcrhaps more than most, recognize that there have ~' been so e shortcomings in Gar administration of this Federal ~ guidance function, particularly in the early years. These ~~ shortcomings may be attributable to lack of enthusiasm and support by the Agency due to competing environmental 7 problems in those early years, and even to the lack of clear precedents on how to manage t' e responsibility. These [. dif ficult ies were, in the past, unfortunately exacerbated by '5 lack of a spirit of cooperation from some of the more 'f significant Federal agencies concerned with regulation of radiation exposure. I believe, however, that this phase is now well behind us, and we look forward to a continuation of the fine cooperation that has characterized our most recent e f for ts. In exercising this authority we have consistently } solicited involvement of affected Federal agencies in the development of Federal guides for specific problems. q{1 particular, we have established interagency work groups on _~ medical and dental diacnostic x-rays, on levels of W l transuranic elements (plutonium) in the environment, on .g. e N g fDU \\] \\ J i .. e. :.,,, 7., .g...g - _,c
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. e..m..db.'s.... _ c,,,}. y., ,'2.,,,,,',[~*,;., ~- ' radioactive ". ste management, and on occupational radiation exposures. Jurisdictional disputes were most acute between ourselves and'DHEW on radiation protection in the healing arts and for occupational exposures. It is gratifying, particularly to those of us in the radiation protection field, to know, however, that for the first time Federal Guides on the use of diagnostic x-rays in the healing arts now exist. EPA, working primarily with the medical departments in the Department of Defense and the Veterans Administration, developed these radiation protection recommendations which were subsequently co-signed by the EPA 'T Administrator and the Assistant Secretary for Health in e DHEW. As noted earlier, President Carter issued these in 7 January of last year. After many years of effort, we will also soon send to the President recommendations on transuranics in the environment. Finally, we are actively M pursuing the updating of the 1960 Federal Guides for ] radiation protection of occupationally-exposed workers and i expect to announce shortly plans for a joint EPA, Occupational Safety and Health Administration, and Nuclear Regulatory Commission public hearing on this subject. 9 6 a'D' e .T / O d U(~ l* /f 6 t' i i l
.y- ..'g.. ' '..'....- 21 !M... .... s... .. : % h...l.2.i;.., ~, ..i: s, ';T*..j ;l[, s + _7_ ~ We see the resolution of two issues as essential to carrying out the f ederal guidance function effectively. The first is to clearly reaffirm that the responsibility to advise the President on radiation matters rests with,a single designated government official. This is essential to ~ '. I assure that the tunction is carried out in an effective and _~ timely fashion. It would also help assure that controversial matters are resolved in the best interest of the public, and not reduced to an unresponsive common ~ dencminator through a consensus process. Coupled with this j. issue of leadership is the comolementa h sue of ensuring '[ full participation by all affected agencies in selecting what radiation protection guidance is needed and in the development of the guidance. We believe that clear procedures can and should be developed to assure that full participation will occur and that this will result in meaningful participation by all affected agencies. Resolution of these issues should eliminate the " turf - ?. fights" of past years and expedite the development of i A , ), necessary recommendations in a shorter time period. Because x ~ of the importance or these issues, we are pleased that they W m -l have been identifled and discussed in the report. We also ~ u ~ i t ( 0 -? s20d d'" a.
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believe that most of the alternatives presented are viable, and EPA stands ready to do its part to assure effective implementation of the recommendation finally selected. Turning to the recommendations concerning the ~ coordination cf research, I would like to point out that patience is a prime requirement for study of long term radiation effects, and that the need for patience weighs a more heavily on the funding organization than the investigators. The payoff in hypothesis testing usually comes only after years or even decades. The fact that the Department of Energy and its predecessors have recognized '7 this is commendable and perhaps unique. It should also be e recognized that the report notes that the apparent lack of 9. credibility currently given some of their health effects studies does not necessarily mean that bad science has been N 7 performed, nor should it reflect on the integrity of the-individual scientists involved. k Any effort to coordinate Federal radiation research programs must strive to assure that long-term commitments are in place, as well as that improved credibility will be As stated in the Agency's testimony to the attained. W" ~ -i 260 0io h e ' *, * u *,e '",., 5 e s ::.~ a*..:p ogy..=*:.*s y
',s. ' ..., ~. -.~. .nv. _Q ' . u.-:,.: -.,.. G... :. _9 Congress last year *, we continue to believe tha'; coordinated. but multicentered Federal research programs will best serve national needs. As a footnote, in considering the level of funding needed for radiation research, we believe that it should be appreciated that investigations concerned with therapeutic uses of radiation and effects of high level acute exposures have little bearing on the risk to those exposef occupationally or in the general environment. Although this work is important to the programs of some " user" agencies, ~., such research should not be aggregated with that needed for radiation protcetion pruposes lest we assemble a misleading 4 {- picture of what national radiation research expenditures as ,3 related to protection of .e public actually are. Although EPA's current radiation research program is [ small, one of our highest research priorities is to fund periodic comprehensive reviews of low-level radiation u n
- House Committee on Science and Technology, Subcommittee on
] the Environment and the Atmosphere, June 7, 1978. j 260 u. r r ~ i, A
... p.,' ~.. ;...... i.e.% '... :.. -. +.N '. ' '&.m. l. ~ ~ c. . : : h l *.'..' ~ _lo_ l effects information by tue National Academy of Sciences. As you are aware, the Academy provided its new report on this subject to EPA last week. A copy of these most recent fir. dings is appended to my aritten testimony. Finally, I will comment briefly on the concept of an averall coordination group. As stated in the report, one of r. its disadvantages is that it would create an additional Iqer of decision making that would largely duplicate the functions of the research and regulatory groups. This would inevitably slow the process of developing radiation protection guidance, and encourage the tendency to '7 compromise on controversial radiation protection matters. '.-s Mechanisms already exist for resolution of issues between agencies, and it is not clear why a special mechanism should 4 ce required for radiation matters. Indeed, such a precedent I-might well be argued to justify similar entities for a, k variety of other hazards to public health. Since the need ~ for an overall coordinating group is not now clearly established, the prudent course of action may be to await ~ the more important decisions of how the research and , N s regulatory coordination efforts will be managed _. Thank you. I will be pleased to answer any questions you W / ~ g y have. . I, /f fl i (, s b diU e-P N, 8 g,,&*, .(( - e # gg p ea g q, g ( p g e.4, ,,}}