ML20155J519

Forwards & Attachments Re Model Program for Maintaining Occupational Radiation Exposures at Medical Institutions ALARA

ML20155J519
Person / Time
Issue date:	10/19/1979
From:	Webb Patricia Walker NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	NRC
Shared Package
ML20155J500	List: ML20155J495 ML20155J510 ML20155J519 ML20155J534
References
FRN-50FR51992, RULE-PR-19 NUDOCS 8605230290
Download: ML20155J519 (1)

Text

{{#Wiki_filter:. / 3 - l 9. *y.,. .g,($ UNITED STATES j y ) NUCLEAR REGULATORY COMMISSION g a wasHINGTOfe, D. C. 20556 s a s, / OCT 1 91979 MEMORANDUM FOR: All Interested Persons FROM: William J. Walker, Jr., Ph.D. Material Licensing Branch Division of Fuel Cycle and Material Safety

SUBJECT:

MODEL PROGRAM FOR MAINTAINING OCCUPATIONAL RADIATION EXPOSURES AT MEDICAL INSTITUTIONS AS LOW AS REASONABLY ACHIEVABLE Enclosed for your infonnation is a letter and attachment recently sent to all medical licensees. In view of your previous interest in our activities we felt that you would be interested in receiving details of this action. Should you have any questions or consnents please do not hesitate to contact me at (301) 427-4232. ) $211 r William J. ker, Jr., Ph.. Material L censing Branch Division of Fuel Cycle and Material Safety

Enclosure:

As stated ( /.,. f,# O t t o '*'"***"***e l PDR PR 19 SOFR51292 .PDR. , _)

) ~ o UNITED STATES ~,j [ NUCLEAR REGULATORY COMMISSION c( ,ng - a WASHINGTON. O. C. 20555 km04./ +... September 28, 1979 0 i bI ' s ', # .1 a

Dear Licensee:

Maintaining occupational radiation exposure and releases of radioactive effluents to the environment as low as is reasonably achievable (ALARA) is an important element in radiation safety practice. The principle of maintaining occupational radiation exposure ALARA is an extension of an original recomendation of the National Council on Radiation Protection. The Council's 1949 report introduced the philosophy of assuming that any radiation exposure may carry some risk and recomended that radiation exposure be kept at a level "as low as practicable" (currently referred j to as "ALARA") below the recomended pemissible dose equivalent. When the maximum permissible dose (MPD) levels set forth in 10 CFR 520.101 (enclosed) were first established, the field of nuclear medicine was in its infancy. At the time, there was no sound data base for detemining that lower levels were readily achievable. Our most recent data throughout the medical community (Figure 1) indicates that occupational exposures a 7 f less than 10% of MPD are readily achievable with proper attention to the ALARA concept. With thousands of workers in this field, the sum of all exposures received by these workers, referred to as collective radiation dose (man rem), is an important consideration in detemining the need to control individual doses. 7 under the current regulations,10 CFR 520.l(c), each licensee is expected

1. , to be comitted to the ALARA concept. We believe that this comitment should be made more fomal. Therefore, the Nuclear Regulatory Comission will request that each medical licensee develop and implement by December 4,1979, a specific action program to maintain occupational radiation exposures ALARA. The reporting and record keeping part of this program are subject to clearance by the General Accounting Office (which will publish a notice in the Federal Register) and, unless advised to the contrary, will also be effective on December 4,1979.

After December 4, 1979, each licensee is requested 1) to submit its program when it submits its next 9 a lA 1,9dA 3 b WA Qb q ,,ra 7v u

. amendment or renewal application and 2) to request that it's program be incorporated by a license condition into it's NRC license. NRC Regulatory Guides 8.10 and 8.18 (enclosed) provide guidance for establishing an ALARA program. Two basic conditions are essential to the success of this program: Management must be dedicated to the ALARA goal both with respect to collective dose as well as to the individual dose. Personnel responsible for radiation protection must be continually vigilant for means to reduce radiation exposure. IfA key feature in any ALARA program is the establishment of performance objectives for specific kinds or classes of operations. In the actual program, these performance objectives should take the form of exoosure action level _s which, when exceeded, will trigger investigation'by tM Radiation Safety Connittee and/or the Radiation Safety Officer. As stated previously, current experience (Figure 1) indicates that values less than 10% of MPD are ritadily achievable without resulting in increased lI collective dose. action levels that you specify in your ALARA program in excess of 10% ) Therefore, NRC will request written justification for exposure MPD. This justification should include details of the past exposure history at your institution (or private prectice) for the particular kind or class of operation, a sunnary of efforts taken to reduce this exposure, and an explanation of why further dose reductions are not f_eajsib e. NRC will also request sac in ene ALARA program you submit to NRC you indicate that you will: Maintain on file at your institution for review by NRC an account of the considerations used in establishing action levels. (You need not submit this account to NRC.) Investigate the cause of personnel exposures that exceed the action levels you have established; and, if a personnel exposure exceeds the action level or 10% of MPD, whichever is higher, )f maintain for NRC inspection a written account of the investigation, including the cause of the exposure, the action taken to correct the problem and a description of the follow-up action taken. (You need not submit this record to NRC.)

o A model ALARA program is provided as an enclosure to this letter. Your institution may adopt this program by designating exposure action levels in Section VII and providing the signature of the appropriate certifying \\ official in Section VIII. Othemise, you should develop a'.i equivalent alternative program. Be certain that you submit your completed ALARA program along with your next renewal or amendment request. Sincerely, t Q L 5 -cA, William I. Dircks, Director Office of Nuclear Material Safety and Safeguards

Enclosures:

1. 10 CFR Part 20 2. Reg. Guides 8.10 & 8.18 3. Model ALARA Program 4

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g g ::::- = Ans w. 00sE - Rots 1975 Voluntary Date - Medical t.icensees Reproduced from: Cool. Walter 5.. NUREG-Oa19. Occupational Radiation Exposure at NRC-Licensed Facilities 1975. Office of Standards Development. U.S. Nuclear Regulatory Cossaission The graph above depicts vcluntary one-time personnel sonitoring data for 1975 which were foi.nd to have log-normel distributions.* These are consi:; tent with other distributions of personnel monitoring data reported in the litersture. A reference ' distribution has been developed by tne United Nations Scientific Casuitttee on the Effects of Atoeric Radiation (UNSCEAR) such that the distribution of annual doses is log-normel, the mean or arit.%setic average of the annual dose distribution is 0.5 rem (one-tenth of the International Coeurission on Radiation Protection's recessended maximian permissible averre annual whole body dose). and the percentage of indiviouals exceeding the annual dose of 5 rems is 0.1 percent. (Note that the median or 50% value is about 0.34 res.) These procerties were selected aroitrarily to define the distribution as one complying with the intent of the ICRP. A var 1aole such as the annual occupational radiation exposure of individual workers is said to oe " log-normal

• when the frequency distribution of the lagtrithe of the exposure can be reasonably approximated by the normal (Gaussian) curve, with approp-iate mean and standard deviation.

Plotted on log-probability paper. on which comulative probabilities are laid off on ene vertical axis at distances preocrtional to the corresponding numoer of standard deviations above or below the median with dose plotted on ene horizontal axis on a lagarithme scale, the function becomes a straight line. Any given set of sata from a finite-size sacole can, of esurse, only give an aporuximate reoresentation of a presumed smooth underlying function. The log-probability plot is simple to use and facilitates intercomoarisons between types of activities. between individual facilities concucting similar activities, and batween years of experience.

Model Program for Maintaining Occupational Radiation Exposures at Medical Institutions ALARA (Licensee's Name) (Date) I. Management Comitment a. We, the management of this (medical facility, hospital, etc.) are committed to the program described in this paper for keeping exposures (individual and collective) as low as reasonably achievable (ALARA). In accord with this cmunitment, we hereby establish an administrative organization for radiation safety and develop the necessary written policy procedures and instructions to foster the ALARA concept within our institution. The organization will include a Radiation Safety Committee (RSC)l, 1 and a Radiation Safety Officer (RS0). We are also committed to following the guidance provided by U.S. Nuclear Regulatory Guides 8.10 and 8.18. b. We will perform a formal audit annually to determine how exposures might be lowered. This shall include reviews of operating procedures and past exposure records, inspections, etc., and consultations with the radiation protection staff or outside consultants. A brief summary of the audit will be prepared covering the scope of the review and the conclusions reached. l c. Modification to operating and maintenance procedures and to equipment and facilities will be made where they will significantly reduce exposures at reasonable costs. We will be able to demonstrate that improvements have been sought, that modifications have been considered, and that they have been implemented where practicable. Where modifications have been considered but not implemented, we will be prepared to describe the reasons for not implementing them. d. In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of the doses received by all exposed individuals will also be maintained at the lowest practicable level. It would not be desirable, for l example, to hold the highest doses to individuals to some fraction of the applicable limit if this involved exposing additional people and significantly increasing the sum of radiation doses received by all involved individuals. 1 Private practice physician licenses do not include a RSC, l i ~ Y -m ^

Q II. Radiation Safety Committee (RSC)2 a. Review of Proposed Users and Uses 1. The RSC will thoroughly review the qualifications of each potential authorized user with respect to the types and quantities of materials and uses for which he has applied to assure that the user will be able to take appropriate measures to maintain exposure ALARA. 2. When considering a new use of byproduct material, the RSC will review the efforts of the auttiorized user to maintain exposure ALARA. The user should have systematized procedures to ensure ALARA, and should have considered the use of special equipment such as syringe shields, rubber gloves, etc., in his proposed use. 3. The RSC will ensure that the user justifies his procedures and that they will result in ALARA doses (individual and collective). b. Delegation of Authority (The judicious delegation of RSC authority is essential to the enforcement of an ALARA program.) 1. The RSC will delegate sufficient authority to the RSO for enforcement of the ALARA concept. 2. The RSC will support the RSO in those instances where it is necessary for the RSO to assert his authority. Where the RSO has been overruled, the Committee will record the basis for its action. c. Review of ALARA Program The RSC of our medical facility will perform an annual review of all radiation safety programs. This review will be performed independently of that performed by management. 1. The RSC will encourage all users to review current procedures and develop new procedures as appropriate for ways to implement the ALARA concept. Z The RSO on private practice physician licenses will assume the responsibilities of the RSC under Section III. r ~

. 2. The RSC will review all instances of deviations from the ALARA philosophy. Information in support of the review will normally be supplied by the R50. 3. The RSC will evaluate our institution's overall efforts for maintaining exposures ALARA. This review will include the efforts of the RSO, authorized users, and workers as well as those of management. d. Public Statement of Comitment by the RSC to ALARA All elements of our institution will be informed of the RSC's comitment to the ALARA concept. 1. The RSC will ensure that employees are aware of the RSC's + comitment to the ALARA philosophy. 2. The RSC will demonstrate its comitment to the ALARA concept through the methods employed in its review of proposed users and uses. III. Radiation Safety Officer (RS0) a. Periodic Review and Audit of the Radiation Safety Program for Compliance with ALARA Concepts. (This is the key element in any ALARA program.) Frequent reviews of procedures will be conducted. 1. The RSO will review and audit, on a regular basis (at least annually), the effectiveness of his own radiation protection program in maintaining doses (individual and collective) ALARA. 2. The RSO will review exposures of authorized users and occupational workers to determine that their exposures are ALARA. 3. The RSO will review radiation levels in unrestricted and restricted areas and releases of effluents to unrestricted areas to determine that they are at ALARA level. b. The RSO's Education Responsibilities for an ALARA Program l 1. The RSO will schedule briefings and educational sessions to inform workers of ALARA program efforts. i 2. The RSO will assure that authorized users, occupational workers and ancillary personnel understand the ALARA philosophy and know that management, the RSC, and the RSO l are committed to implementing the ALARA concept. w m

~ .. l c. Cooperative Efforts for Development of ALARA Procedures Individuals who must work with ALARA concepts will be given opportunities to participate in formulation of the procedures j that they will be required to follow. l l 1. The RSO will maintain close contact with all users and workers in order to develop ALARA procedures for working with radioactive materials. 2. The RSO will establish procedures for encouraging, receiving, and evaluaring the suggestions of individual workers for improving health physics practices. d. Reporting and Reviewing Instances of Deviation from Good ALARA Practices 1. The RSO will investigate all instances of deviation from good ALARA practices; and, if possible, detarmine the causes. When the cause is known, the RSO will propose changes in the program to maintain exposures ALARA. 2. The RSO will report all significant instances of deviation from ALARA concepts to the RSC for review. IV. Authorized Users a. New Procedures Involving Potential Radiation Exposures 1. The authorized user will consult the RSO and RSC before using radioactive materials for a new procedure. 2. The authorized user will consider all procedures thoroughly before using radioactive materials to ensure that exposures will be kept ALARA. This may be enhanced through the application of trial runs. b. Responsibility of the Authorized User to Those He Supervises 1. The authorized user will thoroughly explain the ALARA concept and his consnitment to maintain exposures ALARA to all of those he supervises. 2. The authorized user will ensure that his occupational workers are trained and educated in good health physics practices and in maintaining exposures ALARA.

. 3. The authorized user will be responsible to the radiation safety concerns of the individuals that he supervises. c. Continuing Review of ALARA Concepts by the Authorized User 1. The authorized user will continuously review his procedures to ensure that his ALARA program is optimal. 2. The authorized user will maintain contact with the RSO to ensure that he is aware of and employs the most current methods to maintain exposures ALARA. V. Occupational Worker a. What the Occupational Worker Must Consider about ALARA 1. The worker will implement ALARA procedures developed by the authorized user and the RSO. 2. The occupational worker will know what recourses are available if he feels that ALARA is not being promoted on the job. 3. The occupational worker will understand that ALARA concept j and will review his own working conditions and those of l his fellow workers for the implementation of ALARA principles. I VI. Establishment of Action Levels in Order to Achieve Reductions in Individual Occupational Exposures This institution (or private practice) hereby establishes exposure action levels for specific kinds or classes of operations which, when exceeded, will trigger investigation by the Radiation Safety Comittee and/or the Radiation Safety Officer. The exposure action levels that we have established are listed in Section VII below. These levels apply to the exposure of individual workers. The exact levels have been determined based on our institution's radiation exposure history and a thorough analysis of our current program. We will maintain on file at our institution an account of l the considerations used in establishing action levels. Written justification is appended to this program for any exposure i action levels that exceed 10% of MPD (10 CFR 20.201). This justification l includes details of the past exposure history at this institution for the particular kind or class of operation, a summary of efforts taken to reduce this exposure, and an explcnation of why further dose reductions are not feasible. l l

-6 We will investigate the causes of personnel exposures that exceed our established exposure action levels. In the event of a personnel exposure that exceeds our established action levels or 10% of MPD, whichever is higher, we will maintain accounts of our investigation for inspection by the NRC. As a minimum, these accounts will include the cause of the exposure, the action taken to correct the situation and the follow-up action taken. VII. Action Levels (List the kinds or classes of operations at your institution that generate personnel exposure together with the associated exposure action levels that you have established. Be certain to include written justification for levels that exceed 10% of MPD. Include in your justification details of the past exposure history at your institution (or private practice) for the particular kind or class of operations, a sumary of the efforts taken to reduce this exposure, and an explanation of why further dose reductions are not feasible. You may wish to identify such items as cost / benefit analysis and the possible increases in collective dose (man rem) as a result of proposed actions.) The specific action levels established by this institution (or private practice), are as follows: Kind or Class of Ooeration3 Action Level 1. 2. 3. 4. 5. 6. 3 Examples of kinds or classes of operations are: diagnostic nuclear medicine, Radioimunioassay procedures, teletherapy, etc.

. VIII Signature of Certifying Official 4 I hereby certify that this institution (or private practice), is comitted to the ALARA Program set forth above. Signature Name (print or type) Title Institution (or Private Practice) Name and Address: i 4 The individual who is authorized to make commitments for the administration of the institution (e.g., hospital administrator, etc.) or, in the case of a private practice, the licensed physician. l

\\. C:rmients on " Medal PA mu of Main *2ini.g oc=:paticnal Radiaticn Eq:cauras at 94r=1 Institu*dms as Icw as Fa==mably Achievable" dated Octcber 19, 1979. KD.Wpto[f' 2:is docnent contains a c=verirq mencrandum sigz:ed by W4'14= J. Walkar, a lettar addressed to "

Dear 1.icersee" sigrmi by Willi = J. Di.,

ks, a Figure 1 g- ':i to the letter and a copy of a ucdal r,mu.

In p=mW 2 of the lettar it is said "Our nest recent data th::=ughcut tha ::=84 r=1 ccm:enity (Figure 1) 1:xiicates that oc: :paticnal e:qcsures less than 10% of MPD are readily achievable with rw attanution to the AIAPA c.u im." It may be ncted that the auther of this letter forget to emphasize that the "10% of MPD" mk='1 A be r= = Mad as the average dose equivalent to each of the groups indicated in the figure, alt 5xxagn one no.ght infer fran the sentence that all individuals received dose equivalents of less than 0.5 ram. Actually, fran the data given in the Figure, perhaps 11/2 to ucre than 5% of the varic:us groups received done equivalants greater than 1 ram. Further-nere, it is not indicated whether the values given are for rad 4="14d=* in individual organs cr f::tm exposure to external sources. Of a::urse, if it is the lattar, the dose equivalents actually received in the W.ical organs wou.1d be less than those given in the Figure. The next sentence in this parmg..tu may be confusing to the average reader. Sie m11=rti.ve dose equivalent is merely the average dose equivalent times tha r = har of p=mia involved. Cna can hope that the writer haci scanthig nere substantive in mind. On the next page of the lattar a sentance reeds "A key feature in any ( AIAIR program is the es+nh14 =hnent of M -- - e objectives for =p -4*de kinds 3 or clanees of operatims." It ag: mars that the Nuclear Regulatory N=4==4m i a wishan each licenses to indicata an actica level of not unre than 10% of the [ MPD. Via licenema is than to investigata each situation where this new level is =e== dad. Bare again, it isn't claer whether the Pe1==* Regulatory Ccamission la *= M ng about an average for the group, or individual values. It is of 1.m to see idiat would be involved if one uses sczne of the ra==*dr=1 values plottad in Figure 1. With the curve lahallad "gvata practice" it appears that abcnzt 15% of those occupa*4m=11y ---:-M would exceed an=='=1 dcse equivalent of 0.5 ram. Onsa,15% of the 4,700 people acnitcred in that program would require an investigation of their operations in ordar to find out why their values -r==d the magic tunber that will be permitted by the NRC. 21ere is ancther question that is tcund to arise when one starts playing the ":nznbers gema". 2:is has to do with the accuracy of the dose equivalent datacnination. Die ICRP has i:xiicated (Repcre 39, pages 84 and 85) that dose

equivalents f=

xn external exposure at the level of MPD can be obtairmd with an

' =-5 = y of p=95= a factor of 2. 21e ICRP has indicated (Pnh1ir ation 12, parmg. A 101) that when the dose equivalent is less than 2 rums, an uncer-= Sty .of 1 rem is acceptsble. It appears that the NBC bas either not considered this p*1-a er thought this lack of accuracy was t-n4,- %. Frcm the ":ecdel 3, ma" one can cnly wonder whether the authore have Fcr exm:cle, in sec*dm Ic it ever been faced with running such a r,am. speaks of "signi*bntly rar6 rad exposures at reascnable cost". It would appear that big differences of opinien might result unless NBC is wi'4W to specify

a "s-- =hle ccat" per unit of collec* die dose equivalent. It is st=prisi:q ttat the NRC sees t a Padia*% Safeef Carmittee as the group which 1 M. gates the q'=14' h ticrs of each potential user with regard to his ability to maintain awmns as icw as reascrably acceptable. In :: cst sws as, the Raiiation Safety Carinittee would expect the radiation safety officer to perfcz:n such a functicn and merely w en hcw he had dar-ddad that the safeef aspects of the r %&am were to be 1 er*1ad. With a coupetent r*= tion safecy of#%, the Padiatien Safety Carmittee wculd rarely, if ever, 2 everrule his judgment. It was my uiZ-*d---Aig that there wx21d be an attaret to reduce the aucunt / of paper wedc.W of the population by cur Federal Government. De present ( r W s w. - merely to increase the paper work, increase the number of pecple uno have to review it in the Federal Gover:Inant and i m. the cost i of m=d4"=1 care. Perscrally, I believe that before circulating such a document, i there should be an dw statement prepared to justify the additimal cost in tar:ns of the 4 -:=i savings in radiaticm exposure. Figure 1 in this set of documents indicatas that, in 1975 at least, the average expcsure was far below 1/10th of the MPD. Fiu.i.lg, almost all of the exposures Imsst have been f:m low I2T M4=+%_ and as it is now known that the risk coeff4rd=re for such radiations is judged to be frtan 2 - 10 ttnes lower than it was envisaged a few l years ago, the p = = ' risk frem such exposures Im2st be minimal. Perhaps the l 1MI Ccenissicm's ramnmendation on the denise of NBC so far as reactcrs are l concerned should also apply to mad 4-=1 avt-m. t l 1 I l l t l

\\1 \\y '2 - p. Newsletter ae AMERICAN ASSOCIATION OF PHYSICISTS IN MEDICINE Volume 5 N umber 1 January / February 1980 EDITOR: Andrew G. Bukovitz, M.S., University of Pittsburgh Medical School, Presbyterian University Hospital, Pittsburgh, PA. 1 President's Column Last report from past President Bengt Bjarngard A Personal Note BRH-USP Radiotherapy Problem Reporting it has been a great privilege for me to serve Program as President of AAPM. Those of you who may contemplate running for the AAPM presidency in in accordance with the decision by the Board of the future, may be interested in the fact that I Directors 30 November, Robert Morton of BRH spent about 480 hours on AAPM business during was notified that AAPM supports the BRH-USP the year. Judi, my secretary, contributed some-i Problem Reporting Program for radiation therapy what less time, say 360 hours. devices. BRH was informed that AAPM will My overall impression after this year is that not provide a list of " qualified physicists" to AAPM is a stronger and more influential organiza-help analyze these problems. tion that is generally appreciated. The cohesive-AIP Committee on Public Affairs ness and team spirit among the members are both outstanding. Our relations to other or-in response to a request from AIP, James A. ganizations are productive and cordial. The pri-Deye. chairman of the AAPM Legislation and mary weakness that we have is a certain tardi-Regulation Committee, will represent AAPM at ness, ccasionally bordering on inactivity, when a meeting to estab!Ish an AIP Committee on It comes to responding to proposed leg,slation i Public Affairs. and regulation. ABR Trustees It has been a pleasure to serve the AAPM _as its 1979 President. ABR has invited AAPM to nominate two persons far a newly created position for a physicist to ,,,b&********************* serve as a trustee of ABR. Nominees are SCIENCE COUNCIL AND ALARA James O. Kereiakes and Jack S. Krohmer. This is to report on the meeting called by the ACR-NRC ALARA American College of Radiology to discuss ALARA. As a follow-up of the ALARA discussions in The meeting was held in Albuquerque,New Mexico Atlanta, ACR has organized a meeting to draft on January 7,1980. Robert Waggener and I a program of the kind that was outlined by AAPM represented AAPM and some thirteen other gro ups. The AAPM representatives at the organizations were present. These are my 7 January meeting in Albuquerque were Robert personal impressions and are undoubtedly colored C. Waggener, President 1980, and Charles A. by some slant and bias. Kelsey, Chairman of the Science Council. The NRC position was presented by Richard (James Deye was unable to attend.) Cuningham and William Walker. The NRC is the prime mover behind the push for promulga-AIP Video Cassettes on Physics in Medicine tion of ALARA, and the NRC will not be satis-AIP has now produced five 90-second TV fied unless there is some numerical objective or news spots on physics in medicine. AAPM has guideline value toward which an institution shall available a cassette with this material. The strive and against which the institution can be programs have been shown by several TV judged by the NRC inspectors. The NRC believes I stations in the country, that not only must there be a numerical objective, 'y at b leWs, M 2e E mw h h We4 i NBS-AAPM Regional Calibration Laboratories gational capability to investigate excessive ex-l n In accordance with the decision of the Board of pos ures". The value the NRC wants is 10% of Directors 30 November, signed and forwarded MPD, i.e., 0. 5 rem / year. I to NBS were two copies of the memorandtsn of The NRC acknowledges that although numeri-understanding concerning the Regional Calibra-cal guidelines are not supposed to be limits, they [ tion Laboratories, the text of which the Board wl!I be interpreted as new maximum Ilmits. Thus, rpproved. the effect of their action will be to reduce the MPD to 0. 5 rem / year. 111 EAST WACKER DRIVE e CHICAGO, ILLINOIS 60601

• 312/565-4100

k \\ j. 3 The NRC believes the guidelines, that is the will be required. For the past several years t:n percent limit, must be set as individual the Board, through the Comn:ittee on Training Cxposures and cannot be applied on a dose of Medical Physicists of the AAPM, has accepted cverage basis. such applicants when the Committee on Training There was a suggestion that because in-of Medical Physicists determined that ths indi-dividuals expect to receive less than 13 or.25 vidual had extensive experience in the field of (depending on the recommended body) of the Radiological Physics or its branches. The re-MPD need not be monitored. This level (1.25 laxation of the rules of the American Board of rem / year) could be used as an ALARA action Radiology was never intended to provide an level. This was not acceptable to the NRC. alternate pathway toward Board certification, i Other indi riduals expressed concern that if but rather to alleviate a hardship for a small j the maximten permissible dose were reduced to group of individuals who for valid reasons had 3 0.5 rem / year, the oublic exposure limits which not obtained a Masters Der;, ee. It has now been { is also set at.5 rem /per year would be the determined that the an%ations of this group i same as the effective occupational MPD. of individuals have, for tha most part, been i passed out themodel program passed by processed, the AAPM board in Atlanta, but it was not The Committee on Radiological

• Physics of the

- acceptable to the NRC, they still believed a ABR also wishes to announce a change in the numerical limit against which an ALARA program grading of Part 11 of the written examination crn be judged must be included in any program, in Radiological Physics and its branches. In ( Mr Cunningham said that they plan to implement the past, an average grade for all of Part 11 t:se program on March I,1980. The concensus was obtained for each individual and a pass or i cf opinion was that the NRC and interested fail grade was given based upon this verage. members of the medical community should con-For individuals who had been examined in two tinue to work together to attempt to draw a or three portions of the field of Radiological satisfactory ALARA program. There was a Physics (Therapeutic Radiological Physics, t group present who believe that the NRC must Diagnostic Radiological Physics, or Medical N be tested in a court of law on this matter, Nuclear Physics) it was found that a passing tnd the NRC was not particularly opposed to grade often resulted from an exemplary per-that course of action should it occur. formance in one of the fields which over-Implementation of this ALARA program will balanced poor performances in one or two of require lots more work for a hospital or medical the other fields. As a result of this, a decision physicist at almost every hospital doing nuclear has been made that individuals must pass each i medicine, in one way, this might be considered of the fields which they have attempted in i good for the Medical Physics community, but Part 11 of the examination. The rules for grading I I think it would be bed because it really isn't of Part ll are as fnliews: needed. NRC data show that voluntary efforts 1. If an individual is examined in only one ciready have reduced the exposure to about 961 of the three categories, of course, he - must obtain a passing grade in Part cf occupationally exposed persons to less tharr 10% of MPD. Thus, NRC is introducing a 11 of the examination or he will have I fairly complicated reporting and record-keeping to repeat that portion of the exami-program to do something to solve a problem that nation. i doesn't exist. 2. If an Individual takes two of the three I believe AAPM should go on record against fields in Radiological Physics, he must implementation of an ALARA program that contains obtain a passing grade in each of the o specific numerical value and requires records flmids which he has attempted in Part cnd reporting in excess of current requirements. 11 sf the examination. If he does not Please send me your comments on: obtain a passing grade in each field, A) Whether AAPM should take an official he will be considered failed in Part 11 position on the NRC ALARA position, of the examination and will be required B) If it is yes, what should our position to re-take Part 11 In both fields which ber he has attempted. i 3. If an individual is being examined in Charles A. Kelsey, Chairman Science Council all thre. parts of the field (Radio-logical Physics), he must obtain a pas-e................>....... sing grade in each of the three fields ABR EXAM CHANCES FOR PHYSICISTS in Part 11 of the examination. If he i two parts of the field, he w%e in not obtain a msing g The Committee on Radiological Physics ill be af the American Board of Radiology wishes to tnnounce that after September 30, 1980 the amination in all three parts of the field. Board will no longer accept applications for If he obtains,, passing grade in two a cxamination from individuals who have a P* Bachelors Degree. A Masters Degree or higher s g r i n part \\ l

& Q. n. 7/- D y A,ps: t990 P age " ' d We Give BRH Chief Chance to Explain.. 1e We publish the accompanytng i Mr. Villforth requestmi articl ? by John C. Villforth. Director By Samuel H. Madell, M.D. I tion of his anthmette of ti.. Bureau of Radiological Chairman, ACR Commission on have seen it. Form yc { Health, m tne spint of continuing Communications clusions. cooperation between the College The Bureau of Radiological i and the Food and Drug Admmistra. Health was created within the Pub- , tron. We have worked closely that a high govemment official had lic Health Service in partial

together for many years. particu-provided this type of unscientific response to the urgmg of radiol.

larly in the area of radiation protec. speculation to the media. ogists a quarter of a century ago. ; tion, and we mtend to continue our in his current response, Mr. Since then, the Coilege has sup-l activities to protect and improve Villforth pleads his desire to lessen ported most of its activities. and has - the well-bemg of our patients. consumers' fear and anxiety created received much support from BRH I Mr. Villforth's comments, engi-by radiation scare stories in the for our own programs. We would all nally published in the FDA Con-press. He should know that when a like to see that these cooperative sumer. Dec.1979-Jan.1980, and high ranking government official efforts for the benefit of the public reprinted in the ACR Bulletin. Vol. makes rough approximations, the are continued. I believe most of the 36 No. 4, Apnl 1980, contam weight of this authority leads the statements in Mr. Villforth's I several far. reaching generalizations public to interpret his conjecture as response reflect his agreement with ! and accusations. My objections. scientific fact. If he is sincere in his this sentiment. Our eagemess to I expressed in a letter also published expressed desire to build "a logical, publish it in the Bulletm demon-in the same issue of the Bullerin, coherent story about medical radia-strates ours. Perhaps this type of were directed at the flimsy assump-tion that consumers can under-dialogue in the Bulletin will pro-tions and crude estimates Mr. stand," he must base the story on mote better understanding and true Villforth used to support his state-solid data, not on pseudo-statistics. cooperation between the College ments. I was especially concerned I encourage all of you to wnte to and our Washington friends. ... and He Defends His Criticisms of X-Rays By John C Villforth statemenu were n m way a mate at 3% of me&al intended as a mass indictment of the x ray procedures may be unnecessary "* " I* F'" ** # $**" Bureau of Rad logical Health progress in using available concepts and I think my wording in the inter. "' I thank the College for this opper-and technology to protect patients view conveyed this lack of precision. It tunity to reply to the radiologtsts who against unnecessary exposure is not as was not totally without foundation, wrote me about the interview origt-rapid as it could or should be. I believe however. The 30% figure was taken nally published in the magazine FDA that to be true, and I thmk available from a survey of the literature which Consumer. I was pleased that it was information, both anecdotal and we performed,in which we looked into repnnted in the ACR Bulletin, and that statistical, would confirm this belief. ! three possible sources of unnecessary readers were encouraged to communi-also pointed out that one source of examinations: (1) unnecessary screen-ccte directly with me regarding their unnecessary x-ray procedures is the ing procedures; (2) unnecessary non-rcactions to the interview. understandable " bind" in which refer-screening, or "one-on one" examina-I have received 18 'etters from nng physicians may find themselves, ttons; and (3) repeat films. Using the radiologists. Ten took issue with the in which they often must practice results of individual studies in various views I advanced and eight expressed without sufficient scientifically based medical centers, and knowing roughly support. guidance as to when particular x-ray the prnportion of various types of Ratner than dwelling on the supper-procedures may er may not be vray procedures which are cerformed tive letters, let me explore the objec-clinically warranted, and at the same in the U.S., we calculated that catego-tions that were raised. They expressed time are faced with pressure from the nes 1 and 2 combined for approx-opposition to my statements which patient for the reassurance of a "nor-imately 19%,2nd that the semainmg were largely focused on three i* sues: rr.al" x-ray, and with what they per-11% are contributed by repeats. (1) a perception that I uniustly accused ceive to be the medicolegal pressure of (Copies of our study are available th2 medical profession of poor prac. . ordering enough diagnostic tests to be upon request.) tices. (2) my use of the estimate that " protected"in the event of future These projections are cbviously 30% of diagnostic x ray procedures litigation. Again, these are not very rough, and certainly subject to m y be unnecessary: (31 my state.nent "accusanons." They are simply obser-constderable error. Note that the thit diagnostic x ravs may produce as vations of a difficult predicament and potential error probably br=ckets our many as several thousand cancer of what I thmk is a more or Iess wtdely d:aths annually m the Ui recogr" zed proolem. fContinued on pcse 61

August 1980 BRH Chief Defends His Criticism (Continued from page 5) estimates on both sides: that is. the Regarding my estimate of the 30% may be too high or too low. For possible caremogenic potential of i i example,in projectmg a hgure for diagnostic x rays, the cancer figures I unnecessary "one-on one" examma-used in the interview are based on the I tions, we did not include several maior 1972 National Academy of Sciences / categenes of x ray procedures, such as National Research Council estimate of CT. IVP's and gps. Also, most of the carcinogenic nsk, and on our estimate [ institutional studies included in our that the average adult per capita bone survey were performed in major medi-marrow dose is abeut 100 mrem per cal centers, staffed by radiologists, year. This projection is oburously very where patient referral procedures may rough, relying on several prudent but be better than the average. And, con-as yet unproven assumptions. sidering that dental radiographs I think my language in the interview account roughly for one-third of x ray properly conveyed the sense of uncer-i procedures in the U.S., our not includ-tainty which surrounds these cancer ing this category could also tend to estimates. Although it was not men-i place our astimate on the low side. tioned in any of the letters. I believe I A few of the letters pointed out could have put the possibility of that I should have been more clearin several thousand annual radiation-delineating the three components of induced cancer deaths into better the 30% estimate, so that readers perspective by comparing them with would be less likely to assume that the 400,000 or so cancer deaths which nearly a third of "one-on-one" x ray occur normally in the U.S. per year. procedures may be unnecessary. I I should also have been more agree entirely, and will see to it that explicit in explaining the difference my explanation is clearer in the future. between the very small statistical risk I also agree with those who observed for any single person and the potential that I should have been more explicit public health impact when this small in acknowledging the many coopera-individual risk is multiplied by the mil-tive efforts which the Bureau has lions of people who receive diagnostic undertaken with the professions (and x rayprocedures. particularly with the College) to reduce patient exposure over the Why use such rough estimates of years. cancer incidence at all? Several cor. l The interviewer did not question me respondents expressed concern tat directly on this subject, but, familiar as these kinds of figures could unduly l I am with our cooperative programs frighten lay readers about radiation with the College, I should have inter-hazards. I shars this concem about the p Jected the information anyway. I will possibility of causing patients to refuse do so in the future. Both of these in-needed x ray examination 1 because of g stances, incidentally, demonstrate to anxiety about radiation exposure, but I ! me the value of an ongoing dialogue believe the public can uitderstand r.nd ! tvith radiologists. deal with the kind of iniormation that I (_ There is a related question which was presented in the interview, and i k was not raised by most of my corres-

• hink that it was suffletently well bal-i pondents: if the 30% estimate!s n acced not to induce radiation phobias.

( crude one, why did I use it at all? ! In my view, this kind of article can l believe the answer is that so long as we help to place the problem of unnecess-explain clearly that these numbers are ary medical y-ray exposure in the con-( rough approximations they can help to text of other modern hazards. It is a I give all of us-government agencies, step, I be.. eve, in buildMg a bgical. l researchers, refernng physicians and coherent story about medical radiation i radiologists-some ides of the mag-that consumers ca 1 unde stand. In i nitude of the problem we are cealing general, I think it is our respcnsibility with and help us delineate a common in putlic health to deal open'y with goal. people abov' hazards.

1 w gnv A Washington Potpourri: ALARA Program Begins An ALARA program should be in trash. This method requires a license 52;mficant health hazard te the operarten by August 15,1980, tne amendment, the NRC noted. Finally, public," the ACR concluded. Nuc! ear Regulatory Commission says certain matenals may be released into BRH Offers Videotape in a letter to medical licensees. Mect-the santtarj sewage ssstem. tf it is The Bureau of Radiological He cai iicensees need not submit an monitored and remains within currut has announced that a videotape ALARA fas low as reasonably achieva-NRC limits. entitied, " Current 'ssues in Radiciogical Heaitn: Fstablishmg ble) program to the NRC until their Transport Regulations efecal Cnteria for Pelmetry js license is up for renewal or amend. Radiopharmaceuticals should be n w avadaWe. d, e Meute color ment, the letter noted. After that time, exempt from h:ghway routmg i3P' C"' '"S a panei dscunion m tne an ALARA program will be a condition requirements. the ACR told the pr ceu W w. ich refen I cruer a for e n of the license. Department of Transportatic,n in a ray examinations were establisned. The controversial proposal had been recent letter. Tht iCR commented on and a review of the new!y developed dtlayed twice because of the concerns a DOT proposal that requires a carrier gwdclines for x ray pelvimetry. 4 he of several professtonal societies. of radioactive materials to fcilow a panelists are Robert D. Moseley, Jr., including the ACR. Accorcing to the route which presents the " lowest risks chairman, ACR Radiation Advisory NRC letter, the new program " reduces to the fewest people." Under the Committee: Robert C. Cefalo, l the paperwork burden while still meet-proposal, only interstate highways or chairman, Committee on Obstetrics. j ing the onginal goal; to provide man-highways designed by the state would Amman Cdlege of Obstetricians and (agement a tool for maintaining be used to move radioactive matenal. occupational exposures as low as Gynecologtsts; and John C. Villforth, director, Bureau of Radiological reasonably achievable and to provide ths NRC with a basis for inspecting J-Health. The videotape is available free of charge for one month from the ALARA programs." BRH, Training Resources Center s The revised program establishes y, (HFX-70) 5600 Fishers Lane, l " investigational ievels." The NRC let- '.gg.. i Rockville, Md. 20857. ter said "these are not new dose limits. but serve as check points above which Y;" l Radiation Monitor Ordet ed s the results are considered sufficiently ?*_ The Naclear Regulatory important to justify further investiga-Commission has ordered holders of tion " The original AI. ARA proposal teletherapy licenses to install a hid been entictzed for its use of te:2 therapy room radiation monitor " action isvels" which were viewed an and to use a portable tsdiation survey meter when the installed monitor is maximum permissible dose limits. The l not working. The NRC order cited NRC emphasized that current methods of recordiag personnel exposures . ~.JL 9 ~ O1.'[-{ qy equipment malfunctions such as faulty q.y gy.y.F @M. ;g 'a ~.t 5 c'W " 4 indication of beam status as the shutter operation and impreper would be used in the revised ALARA program. A model ALARA program is m_ available from the NRC,1717 H tmpetus for these new requirements. Street, N.W., Washington, D.C. The colleg2 letter supported the According to the NRC order,, 20556. federai transpo-tation regulations for teletherapy licensees have until early Reducing Madioactive Waste radioactive materta!L "We believe August 1980 to install radiation The Nuclear Regulatory Commis-that federal preemption of the field nonitoring devices to teletherapy sten has suggested three specific will prevent many ill-advised and raoms. Until that time, portable actions which its medical licensees can conflicting state and local radiation survey meters must be used take to reduce, and in some cases requirements." the ACR said. But by anyone entenng the teietherapy eliminate, the amount of low-level radioactive drugs represent low-level room. radioactive waste shipped to commer-radiation and require frequent and etal disposal sttes. The NRC letter said expedient delivery because many lose these actions can be taken under cur-their usefulness in a matter of days, the tsnt NRC rules but may require certam ACR explained. Additional highway license amendments. restrictions will delay their delivery The NRC suggests that low-leve! and increase their costs, the College All changes of address to ap-radioactive waste be segregated from wamed. pear in the 1981 ACR Member i non radioacnve waste to reduce the "Most importantly, the increased ship Directory must be in the volume of waste. Second. the waste costs will not be followed by any ACR Chicago office no later from snort lived radionuclides may be improved public safety smce highway I than September 15,1980. stored until decav to background acetdents involving !evels. then dispesed of in ordinary radiopharmaceuticais present no l l i ' ' ^

37I IJTTERS TO THE EDITORS It is. of course. 2 very long-standing non-specific physicist is in a position where he can always be generality that one should mammiae radiation critici :d by a bureaucracy that retains a!! exposure. Prov;sion of an acronym makes it no authonty while burdening him with all the respon-more than that and constitutes r. esther a new sibility. ,f 4 " principle" nor a basis for urtambiguous directives HARALD H. Rosst ..l y s toward improvements of health physics practice. ( This is especially importar.t if the pnnciple can be Radiological Research Laboratory ! applied by governmental bodies. The dose reduc. Department of Radiology ' tion measures (screed by ofte inspector may be Colambia (farrerrity deemed insutReient by another one and the heal *h .vew York. NY 1003 h e

g. P, 3 9 > 370,/980 15. V 370 tr ii r.xS TO THE EDITORS ' balance it would thus aepear appropriate to embrace the ALARA philosophy. However by itself the ALARA principle is in-adequate. There is the obvious oejection that opinions can dider on what is reasonably achiev-abic. The decision plainly depends on erreum-stances, but hopefully can be agreed upc'n. This di5culty is minor compared with the question as to what is the lower limit to which ALARA is to be pursued. Such a limit has not been proposed ey those who advance the ALARA principle. but it must nevertheless be selected in those cases where minute radiation levels are readily achievable. A . lead foil a few tenths of a millimeter thick will attenuate the radiation from a Icw energy y-ray emitter tsuch as *D by several orders of mag- ..tutude. Should one wrap lead around the source until the dose equivalent index rate at 1 m is 10-* rem /hr (about equal to background radiation)? Should one bring it down to 10"renuhr? Or lower? Although virtually limitless reduction of radiation may not be as easy in other instances. , one can (and usually does) design shielding of ' most sources so that people in their viemity receive doses that are considerably less than the maxunum permissible limit. What level should one aim for? And why should one stop there? Although there may be various answers to the nrst of these questions there would seem to be only one to the second. One stops when one has reached a level where the radiation hazard has ' become de minimis (a phrase borrowed from legal ' termmology denoting " negligible" or of "no concern"). It follows that a more accurate for-mutation of the ALARA philosophy is that: "It is the obligation of those responsible for radiauen protection to see to it that personal exposures are below maximum permissible !!mits and reduced as near as pracucable to de minimis levels. Further reductions are not required." la should be noted that unlike the issue on what ' ' N 4' , reductions are reasonably achievatle. the choice of a deTninunis level depends little if at all on What are the limits of ALARA? particular circumstances. There are various difsculues with regard to the de mmimis concept

Dear Sir:

(it cannot very well be applied to a given source - THE ALARA principle requires that exposure to because there may be multiple sourcest it cannot ionizing radiauon be kept.vs Low As Beasonably be a dose equivalent because there may be further Achievable. We do not know what the somatic exposures at other locations: it is difcult to apply efects of low radiauon levels (100 miemivt or to inte nal emitters) but a statement that the de less) may be acd we cannot even dismiss the minimis dose equivaient index rate in any ac. nouan that they include redu.: tion of the "nor-cessible,1ccation in or near a radiation installauon mal" incidence of cancer. However. there are is X mrem!hr would go qui e some way tcward strong reasons for believing that any dose of ion-eliminatics sorne of these proolems. Whoever i izing radiauon can cause genetic damage even demands ALARA also has an obligation to provide thougn our knowledge Of its magnitude is poor. On a value for X.

N !i -Vren - / LASL I Ol56 '" 1,. 5. G k r J Estimation of risk to the population of radiation exposare at the above levels involves numerous assumptions. In the past these have been conservatively based upon the linear, no-threshold dose-effect relationship. However, a recent report by the NCRP( has shown that use of the simple linear model for low doses and low dose rates may be over-conservative by factors ranging from 3 to 10. The same concept was subsequently adopted by the National Academy of Sciences (NAS) F. As Low As Practicable (ALAP) or As low As Readily Achievable (ALARA). In its recommended radiation protection standards in the late 1940s, the NCRP vanced to place heavy emphasis upon the meaning of the term " Maximum Permissible Dose" which it had juse introduced. The maximum was not intended as an upper limit to which all radiation workers might be exposed with impunity and it was feared that without cautions against the practice, industry might be tempted to push its employees' exposures to the limit. So the NCRP added the caution that radiation operations should not only avoid exposures up to the maximum, but should endeavor to maintain them "as low as practicable" (ALAP) below the maximum. The same philosophy was subsequently adopted by the ICRP in 1950 and re-named, in 1973, "As Low As Reasonably Achievable" (ALARA). (There is no distinction between the two terms.)

i l Howe;ier, the.ie is an imecrtant point that must be brought out here. The so-called "ALAP principie" was never intenced to be used as a basis or justification for setting numerical radiation protection standards. Its purpose wasito encourage imcgovement in protection operations and practicas witnin the adcoted standards, ,q + t whatever they might be. It shculd be prcperly assumec that any .t numerical standard represents the best overall judgment as tc a value meeting the health and social needs of the country.- It l results frcm a political action, the justification for which can be demonstrated on a technical, scientific, and social basis. They are not pusned dcwn simply on the basis that they can be pushed down. There is#no termination to such a racheting process which can be exercised without restraint and without regard to cost or < deprivation of needed uses of radiation technology. The setting [' of radiation practices primarily on the basis of the ALAP principle is capricicus and without realistic foundaticn. Furthermore, it discourages the initiative and innovation in'the protecticn practices of science, mr4' ".ne, and industry that, up to new, have made the radiati'<n '<4u: > / one of the safest. .i I w, A 3? r f e

.~ Current numerical radiation protection standards have resulted primarily from the studies and recommendations of the NCRP and ICRP. They have been kept under uninterrupted review by both organizations and the basic values reaffirmed several times over the past decade. They are believed to comply with the NCRP principle of bodily injury quoted above; and this belief can be quantitatively justified on a risk basis. It is expected that their operational application would' include the ALAP principle. Nevertheless, we have recently found government agencies that have 7 ( radiation protection roles vying with each other to see who can be the purest and set the lowest standards (e.g., EPA vs. NRC). Since they can N find no demonstrated radiation effects at the low levels with which they are concerned, they fall back on what they call ALAKA. I can see this only as a dodge to cover the absence of knowledge - not just on thsir part, but everyone's. When we start trying to control radiation exposure programs at levels of 1/5 to 1/10 the common variations in natural background, we should first examine our priorities. (Live at sea level, stay out of airplanes, avoid high office buildings, eat no vegetables, ) burn no coal.) Since there seems to be a general misunderstanding and misuse of the ALAP principle, let me repeat and re-emphasize that its main purpose is to encourage innovation, inventiveness, ingenuity, and ; cod prac.cice

o . i within a radiation control structure. Tt is a philosophy. It cannot be codified; it cannot be quantitated; it cannot be regulated...else it loses its entire meaning. And because it cannot be codified, it cannot be adjudicated or audited. i III. The Technical Background for Numerical Radiation Protection Standards It has already been pointed out with emphasis that radiation protection standards cannot be derived on a purely scientific basis. Let us examine some of the more important technical information that we do have. For acute exposures to radiation at dose levels above about 50 rads, there is a reasonably good .and generally accepted evaluation of the effects as a function of dose. The I data are statistical but the samples are large enough in relation to the size of the doses to warrant the statistical conclusions drawn. But no two persons j -are likely to react the same to a given exposure. A chronic arposure of 50 rads over a year is not likely to be discoverable by the exposed individual at the time and probably not over his lifetime. There . may, of course, ultimately be some effect, but it is unlikely that the radiation cause will ever be distinguishable among the 1500 other possible causes. The~re is wide acceptance that acute exposures of less than about 10 rads cannot be detected - certainly by any norral medical means, This statement is made notwithstanding the claims made by Stewart, Mancuso, Sternglass, Gofman, and Bross. Their work fails, for the most part, of acceptance by their' peers.(10) Claims by Morgan, Nader, Fonda, etc., although loudly proclaimed through the media, are based only on their selection of the work of the others - not their own work.

s /'7 f 4.+ :4 7 AIAP/AIAPA It goes without saying that any potentially hazardous levels of a pollutant should be kept as " low as practicable" (NCRP, 1949) or "as low as readily achievable" (ICPP, 1973). However, without a threshold of effect, such a sinple statement provides no base for a useful numerical standard. Se only base for a numerical standard is that used by the NCRP and ICRP and which involves elements of scientific and social judgnents. Se science is to find a level below which no effect can be found (this does not say there are no effects - it only says they are too few and too small to be identified). Frczn that point on, any effect nust be purely theoretical with no chance in sight to test the theories. A theory that cannot be tested, is not worth the paper it's written on. %e basic concept of AIAP hinges on the fact that the MPD's are reascnable and acceptable and that no injuries to workers operating within those levels have ever been identified (Press, etc., not withstanding). But, to discourage industry fran unnecessarily exposing its workers to the " legal MPD", NCRP further adnenished, that actual working levels be as much below the MPD as practicable. Furthermore, the very application of the admonishment is to encourage initiative and imaginaticn to hold down unnecessary radiation exposure. It is a sinple application of the good industrial health practice that has existed for many years. Now will you please explain and justify your suggested changes (lowering or raising) of numerical standards on the, basis of such a good but nebulous principle?

. Under the' AIAP 'or AIARA " principle" how can you deduce changes of. 1/10 or 1/5 or 1/2 of any MPD where you cannot es+=h14ah any effects at that MPD. h t i S e 4 i i 1

'7 [ g [ rnocting report 't y it nana gement think of c!early specided in the regulations.'" Speaking for the NRC, Rcbert _ I / .- +, -~ cems ex. Kathren-a cernfied health physicist. By;-, who is leader of the task group / 7 - I-1 J \\ am1 per. a profes ional engmeer, and a holder cnarged with wntmg the proposed c med M w........ a 4 eccog-of a senior reactor operator license-draft revision of Chapter 20. had only iaen m their "ptight" as post-T5t! noted that in Stay of this year the a few days earlier compieted a " straw l ant operators; worrics. among those NRC indicated that a proposed draft man" draft with his associates, and this uthout a college degree. of being would be ready by October, but that draft was lust aeout to get its Srst dead ended" m &etr jcbs; and "frus-the nna' ruie cou!d be espected to reactien from within an NRC aduscry N .t.c::s" at 5:vmg no mech.:mism for fo!!ow m October 19% 'bree years group. From what he said. the revision fermg suggestiens for improvements 1:.ter "an extraordinanly long time." would not amount merely to "more of a technical and nontechnical areas. Kathren commented. This suggested to the same." but would be much more 5ecause of the study's andings. several him that the approach to makmg re-complex. The approach. Baker said, is

acges were made, itteiudmg a "li-visions would be piecemeal and that based on Publication 2ti (19m of the

.ensmg bonus" to alleviate the situation what the NRC would end up with intemat:onal Commission on Radiolog- .rtere technicians d without a license would oc just "more of the same," ical Protection (ICRP)-althou;h he 7 equirement and worxm3 straight days) with only a tightening of requirements. noted that the recent proposals of the .ere recetving pay perceived by the aperators to be too simt ar to theirs: i 2e institutmg of an on-site college 2ducation program funded by the k reVentiVe

t:lityt and the establishment of an Operations Advisory Group to aid the

= operations personnel in communicating ~4 a"in enanCe

o others at PGE their ideas and con-4lr.

endi-

ms. Barkhurst reported that the I

?ased changes have produced positive efects, be-and that the turnover rate among k, a past operatiors personnel is now approach-erVICeS 3ased ing pre T5tl rates. 4. 'onse a r""====--- 'd Revising 10CFR20 Str. ~ W~. the When the session " Effects on n oned Operations of Proposed Changes to ...y E... be. 10CFR20" was planned (by the ANS [.7 e ';~ -l; h, l ,a ha L es of Radiation Protection and Shielding Di- , I *[ ' [ h

I

,but vision), it was anticipated that the d. ,k "i and NRC would have issued by the time of -,6 ; g7.j {.'

tand the meeting its proposed draft revision

, q' two. of this " venerable regulatory chapter," OS j.j ,f , %bl'h;M.b sf ' ional as one participant in the session de-t' g Re. scnbed it. Said Ronald L. Kathren, Qp s at professor and coordinator of the ra- , vide fiological sciences program for the 8p6 6 57.,, ision University of Washington's Joint Cen-7 J.--h ter for Graduate Study in Richland, nu-Wash.: " Regrettably 10CFR20 has ents. .sks: many defects and linutations, and the ? ll,,,,, L

mu-time for major revision has long been l

t. FOr the most i. due.-

ato, 3

S: He remmded the audience that it Se!d was back on Starch 20,1980, that the ,, [, 4 d mts' s', COST-effect,Ve i . of Chapter 20. Kathren asked, "why has M . y* programs NRC announced its decision to revise s to tain the NRC waited so long to decide to L' gggg med revise? And why, mdeed, once the Lg i" He decision was made, . [has there a

e.,

been] no draft or other real indication N f EW3 E. not of what is to be forthcoming (in the ' e- -

.t.

,ery N ** ' ~ g to revision]?.. Indeed, the NRC appears ked to be reluctant to proceed with what l Q l WW l they themselves concede to be neces-f -s :== e,g q gm not g iur. sary. Such reluctance is difHeult to i 3 understand in view of the strong and ,v g ,nes [h jS 4 damning rhetoric of the NRC's own j O to CA special inquiry group on Three Stile Island, w hich, among other things, l/ tral stated. The NRC similarly treats radia. J meneous. mwwcan , g 2dy tion protection as secondary in impor. 5 I tance.' And, '5fany regulatory require-f0 na-ments of radiation protecuon are not

1. ' " S'~" *" A

81 NUCLEAR NEWS / AUGUST 1981 61 c

-~ ~ ~ ~ ~ - - - - - - - -..

meeting report meeting report Enytronme..:.u rroiseuen arency "had v,9 ment would probably be req.: ired by features tm' Ter.- un mhrt $imilar to .7 - ICRP, but diferent." The EPA, for M-the mvised 10CFR20 ngulations. The example, had changed the recipe that hl document, he said, " appears to reduce goes into a determination of the effect

• -1 the health physics programs down to a co kbook or a 'by-the-numbers' sys.

of dose equivalent. This, he said, would sons with other data-i.e., data from $ tem. . !!k'e those used by the Nava. 1 make it impossible to make compan. nuclear reactor program.' Lewis said other countries. He noted, though, that 6 - - ~ T-that w hu,e this may be necessary fer the NRC, while traditionally inclined g s me nuclear power plants. "it could to go along with the EPA, is not bound 7 be demoralizm; to professional health physicists and others who have deve!- to follow its guidelines, hp oped a customized health physics pro-i [ Baker noted that under ICRP rec. L M gram for their stations since 1: commendations, the ALARA ("as low f [, leaves little to professional judgment. }, as reasonably achievable") principle He added, "Apparently there is a ~ would become a requirement, and he feeling m, the NRC, and perhaps also L} stated his behet that it is possible to j in the ACRS. . that the utility pro-U' quantify ALARA. l[ grams have been so weak and so lack-As to actual dose limits, Baker called the ICRP method a "refatively rational, ing professionally that such a cook-4 book program is necessary. consistent system based on the quan-Kathren also had addressed this tification of risks." The limit for indus-point in his talk. agreemg with Lewis tnal workers would be 5 rem, and in ' that the new regulations should not be this connection, an edective dose equiv-Baker: The t:urcen or knowleoge so spec:6c that experts cannot use pro-I alent (EDE) factor would be em-fessional judgment. Kathren noted.

ployed. The system does not recognize a " critical organ." Baker pointed out; it [the model] would be calculating the

. however, that the lack of qualified instead, each organ that has a substan. dose to the bone, to the kidney, to radiation protection personnel is wtde-tial exposure from internal depcsits is whatever-all the different organs, one spread among NRC licensees (includ-weighted with an appropriate factor. irradiating another one. That's all part ing other than reactor licensees). He The EDE is the product of the dose to of the computer program modeling said. "Many of those who are respon-the specific internal organs, so that that that goes into these ev@ations. It's sible for applying 10CFR20 have little j exposure can be added to the external very complex." or no qualifications in radiation pro-tecnon." He strongly urged that the l doses, "and it is the cumulation that is He said that a computer at Oak new regulations address the quali5ca-restncted to 5 rem per year," Baker Ridge is presently turning out this in, tions required of radiation protection said. formation, and by the end of the year He indicated that this could lead to there should be about ~00 radionu-personnel. As precedent for such a h. a problem, in that "some organs are clides that will have been calculated. censing or qualification process, he not particularly radiosensitive, so that "What they're calculating is the de-Pointed to reactor operators, merchant marme officers. doctors. dentists, etc.- i if you had no other restriction, the per. rived air concentrations, which would 4 Imissible dose could be so high as to be somewhat similar to the current and anyone who operates an automo-i carry it beyond the stochastic area of MPCs (maximum permissible concen. bile.He added that radiation protection risk into the nonstochastic-in other tration) and the annual limit of intake, .? words. it would not be a random effect whether it be oral or inhalation. For Personnel, so qualified, should be ac. countable for their actions and be sub-3*. (chance of carcinogenesis), but rather each radionuclide, that would be the

• /

i you would see some rather prompt equivalent of the annual limit." ject to stift penalties possibly even damage." To protect against this, Baker Baker recognized that it would be fines and Jad, sentences, for wilfully said, there would be a "cappmg dose," " extremely painful" to switch to sei. disobeying regulations "not to men-tion revocation of the certiacation or ll of 50 rem per year, applied to all verts and becquerels after being trained licenses that may be issued. -lon tissue. This would be employed with. under the old system of curies and Payne, E. Michael Blake. John Gra. out regard to weighting factors. (In rems. He acknowledged that there ham, and Christopher Fir:Gerala, addition there would be separate limits would be great resistance to changing for the lens of the eye and the skin over to the metric system in connec-dose; these topics have been covered tion with radiation units. . d.;.... ~ M-i by further revisions to ICRP Publica-Some of that resistance was definite. - '~ ' "' , ty evident in the comments of Lionel ". J ~ w-i , tion 26.) , Baker admitted that if "we go to IfLewis, system health physicist for - M$ quasi-rational risk quantification Duke Power Company, who also spoke t

this

..'J : I system, life becomes just a bit more at the session. Lewis said that m re- - o.d 4 -1 l, complex." But he would chalk that up vising 10CFR20, the NRC "apparently 4 to the extra burden that knowledge intends to write an encyclopedia." The J 7. carries with it. "No longer would it be promulgation of a maior change in 1 - 'uf possible." he said, "to check on the Chapter 20 regulations at this time P l numbers in a handbook by doing a would be disruptive and "would not '"f ~} ~ M" sliderule calculatic's or [a calculation] advance the cause of occupational 1 c on the back of an envelope. It's very radiation safety," Lewis claimed. "= complex. The model, for example, He noted the existence of a draft of. would start summing these actribu-requirements for a radiation protection -Af4 tions to various organs the moment program that the NRC has recently other words, whde it is still in the lung, suggested that the use of this docu. .,""~-y U.c that a radionuclide enters the body. In issued as a NUREG document, and ReaderSernce \\o ~0 NUC1. EAR News / AUGUST 1981 63 198t

R.

2..:

= - r i As.. r1 l q P IAE A-CN-42/3 $ INTERN ATION AL R ADI ATION PROTECTION RECO.\\f.\\lENDATIONS Five years experience ofICRP Publication 26 i B. LINDELL, D. BENINSON. F.D. SOWBY l International Cornrnission on Radiological Protection. l Sur ton. Surrey. '? United Kingdom e i Abstract -[ j t INTERNATIONAL RADIATION PROTECTION RECOMMENDATIONS. FIVE YEARS EXPERIENCE OF ICRP PUBLICATION 26. ~' The international Commission on Radiological Protection has issued radiation protection 2 recommendations since 1928. The latest set of basic recommendations was adopted by the ? Commission on 17 January 1977, and subsequently published as ICRP Pubhcation 26. This l document has met with a wider interest than any of the previous ICRP recommendations. It t has been considered to mark a radical change in the protection pohey advocated by ICRP. It is not of ten appreciated that recommendations which are believed to be 'new'in ICRP f Publication 26 had already been made in ICRP Publication 9 more than ten years earber. In any event. ICRP Publication 26 has had a substantialimpact on regulatory work in countries all over the world. It forms the basis for the Basic Safety Standards of the international organizations I AEA. ILO.OECDiNEA and WHO. The paper refers to the experience gained I e in using the new ICRP recommendations over the five years that have passed since ICRP Publication 26 was adopted and discusses some of the problems that have ansen in the practical appbcation of the new recommendations in vanous countnes. 9 INTRODtCTION I This paper will describe the impact that the recent ICRP recoceen-I ~ ~ dations have had on radiation protection administration, and the experience gained in their practical application over the last few years. Although the authors _are closelv linked to the ICRP. the. l presentation i sJe r.googl antmu ne nne he r =h en n ec e ssarily_ to.rA-flect of ficial psitLion_s 0L1hs Cc::uissi.co THE "NEW" POLICY OF ICRP ICRP issued basic recommendations in 1955, 1959, 1966 and 1977. l Partly because of the nuclear debate, it is not surprising that the 1977 recommendations met with considerably more interest than T any previous ICRP Publication. They were also considered to intro-l duce a startling new protection policy. Many readers did not rea-lize that major parts of this "new" policy had been already recom-mended in 1965, in ICRP Publication 9. In fact, the development h was not sudden but gradual. 9 3 t e = h

LINDELL et at 4 or later exposures, t MAIN FEATURES OF THE "NEV" POLICY no threshold. If thia Basic assumptions on its own serits alc caused by a given set Uatil the mid-1950s, the main objective of radiation protection and harm-total collective dos, was to prevent high exposures that could cause obviout fut biological effects. Such effects. (e.g. skin erythema and mal- ~ andtheiraveragedo'i rage dose of one uni functioning of the blood-forming organs) are the result of massive the same mathematica cell killing that can only occur at doses exceeding a threshold stochastic effects 4 value. The first aim of radiation protection was to keep doses be-

m ne gyjggg g g g absolute protection Iow the threshold. One could then talk about affgo

2, without any reservation.

On this basia, the detriment from any given radiation source or The alternative poss dose increment might practice would depend on the extent to which other sources and accumulated dose and practices had already contributed doses. It was, therefore, not tion. If, eventually easy to specify any source-related restrictions, specific to a par-individual-related limits, concern, each compon ticular source. It was natural to set sult, even if it wou designed to guarantee that dose thresholds for harmful effects effect by itself. Fo would never be exceeded, irrespective of source. able to let each dos At the beginning, such limits mainly related to the working envi. the ultimate detrime It was in that daily or Weekly exposure limits were set. the dose-response cu understood that the dose accumulated over a long period of time

ronment, authorities may ther might also exceed a threshold for harmful effects, in spite of the relation without thr body's capacity of recovery and repair. However, limits over lon.

ting the biological introduced until get periods of time, such as one year, were not The biological prope in the mid-1950s. regards the inductic Even earlier, however, there was a growing concern that radiation and beta radiation. might also cause hereditary harm. In that case, no dose threshold respect to cancer, was expected. It was feared that sufficiently large co!!accgg, type of eadiation. doses, delivered to interbreeding reproductive populations, might about one half of ti cause irrevocable hereditary harm in future generations. This con. exposure, assuming ; cern was inflated by the general fear of radiation provoked by the of the total risk m: use of the atomic bombs in Japan and the subsequent nuclear weapons duction by low-LET - with dose. testing. In parallel, there was also some concern about indications of an Particular eaw poin unexplained increase in the leukaemia incidence in some countries. the same time as studies of the survivors of Hiroshima and Naga-Of the concepts and saki revealed higher leukaemia rates after the bombing. Since one wing seem to have a at of the theories of cancer induction is initiation caused by genetic (1) The definition i changes in the cells (somatic mutations), it could not be ruled astic expectati out that even very small doses of radiation might also cause can-rity of each ha car. The risk of cancer and hereditary harm would be very small and the effects would therefore occur, seemingly, at random. These (2) The quantificat effects are therefore called " stochastic" effects. Since the ef- "*# *f the Uni facts of cell killing, on the other hand, are inevitable at high f Atomic Radia doses, there is no element of randomness in their appearance. They I y are, therefore, called "non-stochastic" effects. (3) The reassessmen Postulation of proportionality between dose and response the recognition If each increment of the probability of stochastic effects is pro-disputable unac independent of previous portional to the causative dose increment, reston; M. --c ,_..,e..-

.h : E e t IAEA.CN.42ns 5 or later exposures, the dose-response relationship is linear with l no threshold. If this is the case, each exposure can be assessed on its own merits alone. It also follows that the overall harm, of rcdiction protection caused by a given source or practice, would be prcportional to the crus 2 obviouc and harm-total collective dose (the product of the number of exposed persons 1 skin erythema and mal-and their average dose) caused by that source or practice. An ave-Ira th2 result of massive rage dose of one unit to 10 000 i persons would be assum'ed to give s excscding a threshold the same mathematical expectation of nu=ber of individuals showing tion was to keep doses be-stochastic ef f ects as a dose of 100 units to 100 persons, providad bout tbsolute protection that no individual dose exceed tha threshold for non-stacinstic effecto. van r:diation source or The alternative possibility is that the probability of harm from a hich other sotrees and dose increment might depend upon the magnitude of the previously It wic, therefore, not accumulated dose end therefore also on each previous dose distribu-icticns, specific to a par-tion. If, eventually, the total dose becomes high enough to cause .:ipidaal-related limits, concern, each component of that dose has contributed to this re-ds fer harmful effects talt, even if it would not have sufficed to cause any significant sourco. effect by itself. For equity reasons, it may therefore seem reason-etcd ts the worktng envi_ able to let each dose increment be " responsible" for some part of o licits.were set. It was r a 1cng period of time p 1 cffcces, in spite of the g g ,g Howev:r, limits over lon_ tra n;t introduced until g g The biological proportionality assumption has been challenged as ng erne:rn that radiation regards the induction of cancer by low-LET radiation. such as gam. ,c casa, no dose threeshold and beta radiation. It is more accepted for high-LET radiation in cntly Icrge collectiV8 dfm W hQdW uctive populations, might type of radiation. Since the hereditary detriment may amount to uro gin: rations. This con-d W W hh b W w d 6 % r: diction provoked by the g g g k subs'quernt nuclear weapons H b-duction by low-LET radiation were shown to be grossly non-linear with done. chout indications of an cid nco in some countries, Particular new points in ICRP Publication 26 v:rs cf Hiroshima and Naga-cr the bombing. Since one Of the concepts and ideas presented in Publication 26, the follo-niti: tion caused by genetic wing seem to have attracted most attention: , it could not be ruled (1) The definition of the radiation health detriment as the stoch-icn cight also cause can-astic expectation value of harm, considering also the seve- .crm would be very small rity of each harmful effect; comingly, at random. These " cffsets. Since the ef-(2) The quantification Jf detriment, in close connection with the , cra inevitable at high work of the United Nations Scientific Committee on the Effects in their appearance. They of Atomic Radiat'an (UNSCEaR), the expectation of severe cff cts. (lethal) stocha nic harm per unit collective dose assumed to be about 2x10-2 per man. sievert; o rnd response (3) The reassessment of the " maximum permissible dose" concept and stich:stic effects is pro. the recognition of dose limits indicating the beginning of in-t, ind: pendent of previous disputable unacceptability rather than the end of the accepted regton; g .5 .7 ~ 7

= ..~v. m. .a a.:. -.. s.. 6 LINDELL et al. (4) The itaration of the three basic principles: gans whe 1 - Justification of the practice; l - Keeping all doses a. Iow as reasonably achievable; (d) If the r - Individual risk (dose) limitation; that the (5) The strong emphasis on optimization of protection by differen-(e) The weii t tial cost-benefit methods as the means of satisf ying the second lent dce basic principle; and her. (6) The use of coll.tetive dose comiment in assessing source-rela-(f) Are "op* ted detriment; low as (7) The introduction of the effective dose equivalent and the aban-(g) Is it r-donment of the concept of " critical organ"; tection assessm (8) The abandonment of " maximum permissible concentrations" (MPC) place t and " maximum pe1nissible body burdens" of radioactive substan-ces and the introduction of the " annual limit of intake" (ALI); (h) How sho

• "*N '

(9) The advice that it may be prudant to avoid continued exposure over many years near the dose limits, since the individual risk hat gr might otherwise not necessarily be considered acceptable. (i) Is it r The following sections will discuss the impact of these statements (; on national and international radiation protection administration over the last few years. (i Should I. M IATE REAtTION (5) LI*I*i' In general, the reaction to ICRP Publication 26 was sympathetic, dO'* EI which is perhaps not surprising, considering the many influential "N*C E' radiation protection experts that had been involved in the prepara-tion of the report. To those for whom the recounsendations seemed Some of th-new and different, the main reactions related to the following key tion menti questions: years earl obscure dr (a) ICRP Publication 26 is dif ficult to read and the recomunenda-less invol tions were considered too abstract and theoretic.a.1, with little Of "id'IY guidance on how they should be applied in practice; (b) The dose limits were no longer presented as " safe" in them-ADMINISTRA </ selves: radiation work would compare favourable to so-called " safe" occupations only if the average' annual dose were an or-The most i der of magnitude below the limit. Those who repeatedly receive ICRP Publi annual doses near the limit would be in the same position as zations, e those subgroups in " safe" industries that are exposed to a was the di higher-than-average risk. This idea disturbed many who were enough gui I still living with the impression that any work below the limits ICRP Conun: j is absolutely safe. The validity of the risk assumptions them-cal guida: selves was therefore questioned; not yet be

• • 1. * " I (c) Abandoning the critiaal organ system and introducing annual In partici limits of intake based u rn a limit for the effective dose equivalent resulted in higher permissible doses for some or-against t:

aw -e

e. = * =

• g g g g@

D 9 WO* b"D' I E w

= .___= 1 I IAEA CN-42/15 7 Ud L: gans when exposed singly. The most obvious example was the thy-roid exposed by radioactive iodine; i _d I'i (d) If the risk assumptions were really valid, would this not mean that the recommended dose limits are too high'- i by differen-(e) The weighting procedure to derive the effective dose equiva-IU 4 ing the second lent does not include all healtb detriment: non-lethal cancer I '- and hereditary harm in later generations are not considered; 'g source-rela-(f) Are " optimization of protection" and " keeping all exposures as low as reasonably achievable" identical concepts?; f* 4 and ths aban-(g) Is it reasonable to expect that the practising radiation pro-M tection officer will be able to carry out involved optimization i '. assessments in his daily operation: can optimization really re-itions" (MPC) tive substan-place the simple guidance that dose limits have offered?; intaio" (ALI); (h) How should one decide upon the amount of money that it is rea-ba sonable to pay, marginally, for the elimination of a unit col-

.4 usd exposure ndividual risk lective dose (the value of "a")? Who gives that value and oc

3 what grounds?;

epttblo. 7 (i) Is it really reasonable to let the collective dose include: [' ss statements r~ (i) extremely small individual doses, although to ministrction large populations, and [_ r (ii) doses expected only in the distant future? Should not such doses be given less weight? i

ymp th

cic, (j) Limiting the corrritted dose in a year rather than the act:4al

' I influential dose that year will cause problems with nuclides with a long 4 n th1 prepara-eff ective lif e time in the body, e.g. plutonium-239. f ions cremed d following key Some of these questions were not new. For example, the recoassenda- [3 tion mentioned in (j) was given also in ICRP Publication 9, ten .a years earlier. Some eroblems arouse from inadequate information and recomm:nda. obscure drafting at. have later been better explained. Other prob-il, with little lems involve policy questions which are still under debate because c. e; of widely different views (e.g. (d) and (i)). in them-I' o so-estled ADMINISTRATIVE ACTION y e w:ro cn or-The most important test of the viability of the recommendations in I tcdly rcceive l ICRP Publication 26 was the attitude of other international organi-positien as zations, such as IAEA ILO, OECD/NEA and WHO. An immediate obstacle ored to a l vas the difficulties described in (a) and (g) above: There was not b. -y who w:re enough guidance from ICRP on the practical application. The various Ei ICRP Consmittee reports that had so far been published with practi-f-f low th3 limits 7tions them-cal guidance were all based on Publication 9. The Consnission had 4 not yet been able to revise these documents and there was some un-ing cnnunt certainty as regards the direction such revision might take. -~~ MW dass In particular, all previous practical guidance on the protection 1 3r som) or-against internal exposure had been based on the critical organ concept d wp _$_a 2

L,

t k a T J* sa V" 8 LINDELL et al. E and on secondary limits, such as maximum pemissible concent- =any other i si ~ rations and maximum permissible body burdens. The new recommenda-compromises Such ambigus, 'l tions required limitation based on the effective dose equivalent, ~ codes for m. ] and the secondary limit for internal exposure was recommended to be other intert J the annual limit of intake. However, the calculation of ALI values will decide to replace the MPC values was a difficult and time-consuming pro-ject. There was therefore, at first, considerable hesitation in more defini accepting the effective dose equivalent before the u.issing infor-Standards c mation was available. However, IC' .a form of var A l* Thanks to the ef forts of the experts in ICRP Comittee 2 and assis-example is cance from the Oak Ridge National Laboratory and the United Kingdem the optim1: Medical Research Council, a complete set of ALI values (and corres-that were b ponding derived air concentrations, DAC) were produced in short L 1 time. This finally offered the basis for a definite judgment of the published t. values and applicability of the new recommendations. It became possible for Q], Publicatior IAEA, ILO, OECD/NEA and WHO to agree upon joint Basic Safety Stan-dards based on ICRP Publication 26. r, (b) The ris Also the European Community's Council Directive of 1980 (on Basic Safety Standards for the Health Protection of the General Public It L now g d' and Workers against the Dangers of Ionizing Radiation) is in essen-aear the IC Attention ! *y* 1 cial agreement with the ICRP recomendaticas. lication 2t - :~- M1 With the maj.or international organizations and the European Cotmu-Of Eh* * #} l-M nity being positive to the basic policy recommended in ICRP Publi-acceptable 5a cation 26 this policy began to penetrate into national legis14-higher rest ,_b tion, albeit not without problems and reservations. Particularly 2.t in the United States, the full acceptance of the ICRP recommenda-Some uncer- ?? tions has been widely d sbated. However, concepts and tems which risk. Howe' had, at first, been received with hesitation and scepticism gradu-radiation - [h ally became recognized and accepted. For example, it is interesting sures near M to note the natural way in which concepts such as " effective dose for which { nT-1 equivalent", " collective dose", " dose cocanitment" and "optimiza-risk estim tion of protection" have been used at seminars and conferences du-doses", al _.4; ring the last year. in a way that was inconceivable only a few fluence th -.A ry years ago. (c) The ef -P QUESTIONS RES0* VED AND UNRESOLVED The overal ference te l.'" The questionable points (a) - (j) already listed seemed te b. the tection. ,1 most imediate obstacles to accepting ICRP Publication 26 without some esset 7r reservations. Some of these points have later been resolved, others Since the ,Q l remain as problems. The explanations snd solations that have been occupatio: offered in the light of subsequent experience may be su=marized as (5 retn), .n -T follows. permitted (a) Lack of practical guidance almost si- .h It is perhaps not always unde; stood that the primary readers of But it ne T mands an !t i documer.ts like ICRP Publication 26 are intendefto be persons in-dose, for I volved in national or international regulatory sork. The 'recomen-for the t y dations deal with principles and will 6herefore be of doubtful value year, the ~ i in the hands of somebody with direct operational functions. As with m .. ?' O = r 2-a

~~ d,

• N, Z.7

L 9

• b b I AEA-CN 42/15 y y i

l o reflect

h 1 many other international documents, ICRP publicat ons a s i

left open.

g 3,,,

compromises on difficult issues, with alternative solut ons in ent-

}

4~ a nda-W !{ d

• application. It l

y authoritiea

ivalent, codes for more direct h

other international organizations and national regu atorhe basic principles to ..A ,ded to be will decide on how they wish to transform t ' Basic Safety L1 values more definite rules. The international organizationsstep in this direction. , 7 g .ing pro-in the y- - ion in Standards may be seen as a first However, ICRP itself is also preparing additional guidan g infor-Y licatien of example is a report with guidance on the practical app 1 and assis-i s committee reports the optimization principle. A number of prev ou +- i d and will be E ted Kingdom that were based on ICRP Publication 9 are being rev sefew years. The compre i and corres-blished as ICRP i short published within the nextvalues and the supporting metabolic data have been pu h s unt of the t g. Publicatiun 30 (in three parts) with appendices. ible for lety Sezn-p- (b) The risk at the dose limit _ [, (on Basic _ is now generally recognized that the risk from life-long exposure ..E r insignificant. near the ICRP dose limits cannot be considered to be It .1 Public RP Pub-Attention should be paid to the warning in parsgraph 102 of

7

s an essen-W lication 26: ld only be {~ of the workers at or near the dose equivalent limits wouh t the acceptable if a careful cost-benefit analysis had shown t a

• een Comu.

e LCRP Publi. higher resultant risk would be justified". I ltgista-f Some uncertainty still remains with regard to the actual level o Y ticularly 1ET risk. However, even if the dose-response relationship for low.the ac Y[ ' ac om:nde-rm3 which i f magnitude as the doses -Y ', radiation is non-l near, d , sures near the limits is of the same or er o cic gradu-for which there is epidemiological evidence of harmful effects. The intercsting high 1 risk estimate is therefore not based on any " extrapolation from~ ~ 4 etiva dose s - ll in-doses", although the time distribution of the exposure may"we i optimize- ~ ~ ~ ~ ~ ~ cc:nc:s du-fluence the.rist. y e f ew ystem (c) The effective dose equivalent versus the critical organ s The overall effect of abandoning the critical organ sy h limit in tection. The debated problem with higher organ doses at t e ted. ! to ba the some cases, a.g. In the thyroid f run iodine-131, has b 26 without is 50 mSv i Olv;d, others occupational annual limit for the effective dose equivalent be (5 rem), it has, wrongly, been concluded that the thyroid could t hav3 b:en i is ummariz:d as permitted an organ dose of 50/0.03 am 1700 mSv (170 rem), wh ch six times the previous critical organ dose limit of 30 rem. ICRP Publication 26 also recom-almostit needs to be pointed out that for the effective mends an organ dose limit in addition to the limit But dose, for the purpose of preventing non-stochastic ef caders cf pers:ns in-factor year, the increase in thyroid exposure could, at most, be by a h3 r:comen- ~ druhtful value .lons. As with .~ ~~~

, L 10 LINDELL et at nized that the expt of 1.7. This is a small change in cumpe l w. with the r?rbar larg, in d har words: to-changes, in either direction, in the annual limits of intake, caused tien of the lower ? by revised metabolic data. The effect of these changes influences the the demarcation of true organ doses at the secondary limit. It would seen to be a bad principle to correct for obviously erroneous data only if the correc-M,9 CF2 P i!" C. 1 tion reduces the dose, but to keep inccrrect values if the correction would have meant an increase in the true dose. The complexity of It should also be remembered that the ICRP system of dose limitation more apparent than gives no excuse for increasing an intake of a radionuclide just be-effective dose equ cause new metabolic data imply that the higher intake would still be lations for assess below the intake that corresponds to the primary dose limit. The that dose to the e I basic recommendation, to keep all doses as low as reasonably achiev-in the initial der If it was reasonable to keep intakes low with mittee 2.

able, always applies.

the previous system, the new system may call for the same intake limi-For the practical I tation,just because it is reasonably achievable, even though higher er:er*;a! exposures intakes would not give doses exceeding the dose limits, dings of dose mete dose equivalent ne (d) Are the ICRP dose limits too high? the new system is ICRP dose limits have been criticized on a number of the dose limit has The present grounds, for example: For tnternal expo! (i) The risk near the dose limit is unacceptably high; sessed and record. by ICRP from cate' (ii) It is une.ecessarily complicated to keep two systems intake, such calc-of limits: one organ dose limit to prevent non-of occupattonal p stochsstic effects, and one limit of the effective ted as regards in dose equivalent to limit the detriment of stochastic yet issued any gu effects; a provisional met (iii) The limits are justified by ICRP with reference to out any need for the average doses in exposed groups, yet there is no international org recommendation that this average should be controlled. Some ALIs have be On this criticism the following has been said: valent, and some the most exposed fi)Unacceptablyhig]}riskat the limits stringent in eact Yes, the risk would probably have been considered unacceptably high* ments for optimir also by ICRP, if the limits had maintained their old meaning as the cally related to maximum doses that should be used for purposes o.f planning and de-the effective dos sign. With the old meaning of the limits, it was always perfectly the dose thresho: permissible to work up to the limit. The limits may now be seen too stochastic detrir bias unless the

• high for that purpose.

However, with the new system it is never a priori permissible to work Apart from the si up to the limit. The highest permissible exposure is that which can by ICRP is v =' still be defended as being as low as reasonably achievable. It is cation in the ca not the intention that competent authorities' should relinquish their mum organ dose w right to impose authorized operational restrictions in order to keep dose limit. This doses considerably lower than the ICRP dose limit. On the contrary

• were reduced to in most circumstances it is reasonable to request a higher degree for the dual sys of safety. Only if all reasonable efforts do not suffice to keep the effects. Only th exposures substantially lower would it be permissible to allow ex-mSv (150 rem) in posures up to the limits. In that case, however, it must be recog-by special requi

'eH H

2C" 2 _. 5% .; _ _._ -~x .3 i I 1 6 Il IAE AO-42/15 } the exposed persons would run a higher-than-normal risk. nized that today the ICRP dose limits may be seen as an indica-thm rcther large In other words: tion of the lower boundary of an v.' : eptai~e region rather than as .C e of intake, caused 2nges influences the the demarcation of a region of unchallenged acceptability. saem to be a bsd l only if the corree-MI)_Com2exityof_the, dose limitation _svstem 1 es if th3 correction l '7"**""**

• D

.w. f* * #'# # '" C "" "'I ' D'# 'in n r=al practice. The comp 1tcated calcu-g of dose limitation " '* 'P'"d se equivalent ionuclida just be-of ective and the contributton by f each organ dose, taka would still be

• ""!*. *** W*"Y I'*"

"'C * *#7 I dosa licit. The l N' ?'." reisintbly achiev-9 p int:kss low with is reco=meaded that occupational tha sam) intake limi-i For the practical application, it even though higher i setermzl exposures be assessed and recorded on the basis of the rea-dings of dose meters. Normally, no assessment of the actual effective inics. dose equivalent needs to be made. For external exposures, therefore, m Me, except that a Mt cMn e pu t new sy? tem on o number of the dose Itmit has a different meaning. is the annual intakes that should be as-For interr.al exposures, it sessed and reco ded. Since each ALI has been derived once and for a tecccpttbly high; by ICRP from calculations of the effective dose equivalent per unit intake, such calculations need not come into the operational practice > k::p two systems of occupational protection. The situation is somewhat more complica-i prev:nt non-ted as regards internal exposure of the public, since ICRP has not of the effective teelt cf stochastic issued any guidance on how to deal with this situation. However, a provisional method, based on the occupational ALI values, and with-yet out any need for effective dose calculations, is recommended in the <ith refcrence to

1. 3*"

I*' " '" "I '** * ** Some ALIs have been derived on the basis of the ef fective dose equi-u b: co trol ed. valent, and some on the basis of the non-stochastic dose limit for the most exposed organ, depending upon which limitation is the most n eac cau. s means e a nc ec e se assen-an Mt m@o-st gen ptWah Wms, decWe he9 d unacc:ptably high 5 cid morning as the I"**

• • **'8
• D f plcnning and de-

1. ""*# 9 ""

c1 ways perf ectly stochastic detriment at the limit. This may introduce an unnecessary may now be seen too bias unless the " stochastic ALIs" are used. Apart from the skin, the lowest organ weighting f actor-recommended 4 P2rtnissible to work = 0.03 for bone and thyroid. The effective dose limi-by ICRP is v tation in the case of single organ exposure, therefore, gives a maxi-T ac e e i which is (50/0.03)/500 = 10/3 of the non-stochastic uld ralgnquish their mum organ dose dose limit. This means that if the effective dose equivalent limit P

• • P**"***"**#*""

for the dual system with special organ dose limits for non-stochastic th3 contra effects. Only the skin might still receive a high dose, at most 1500 est a higher degree suffico to keep the mSv (150 rem) in a year, unless skin exposures were to be limited l b a ow e j by special requirements. e e t I w f .= _ . mar _ h ,----e, h IrO!

C LINDELL et at as A IIIk EO.limi,tation of_ average _ doses w uld then only It is true that one justification of the present stochastic dose exposures are ur limit reco:: mended by ICRP is that the average life-time (or occu. who are expecte-pational life-time) annual dose is, in fact, less than 1/10 of the annual dose limit. It has been assumed that the life-rime average There'are proba.- of annual doses is likely to be much smaller than the maximum annu-ti ns of the ba al dose and that there is therefore no strong reason to limit any-f reed to obser I thing but the annual maximum. The maximum can be controlled by cen-i ' ventional methods, while controlling the occupational average dose [d each year, or the tatal over e lifetime, is a much more complicated ,,,g procedure, which might lead to heavy bureaucracy. , g, What then does recent operational experience tell us? Taking "occu-pation" in a wide sense, with examples such as " industrial radio-f*I graphy", " medical diagnostic radiology", etc., not including nuclear When ICRP deris power production, there is clear evidence that the ICRP assumption is valid. Average annual doses are less than 1/10 of the dose limit, effective dose nor hereditary usually between 0.5 and 5 per cent of the limit. spring. In addi " Nuclear power production" is a tacher tieterogeneous occupation, and sex, de we extending from uranium mining and milling through reactor operation gr ups, e.g. y< to fuel reprocessing and waste management. The average doses in each occupational g-of these steps vary considerably from country to country. There are examples in each category indicating that the average may be less There has been than 1/10 of the limit, but there are also examples where, in some countries, the average may exceed 1/10 of the limit, e.g. reach 40 anticipated wh tion with the per cent or more, as for uracium mining in the United States and in doses was an i same reactor operations.

• • I I

Even so, however, there seems to be no valid reason to cause higher I'** life-cirte doses than what corresponds to 1/10 of the annual dose limit. On the contrary, it appears likely that such safety will be g y achieved by imposing the present dose limits and those restrictions tions was.inc! which follow frca the optimization principle. exposed indivi There remains the problem with ambulatory maintenance workers who Since the dose move from station to station and who might therefore receive high in -radiott accumulated exposure. There have been a number of proposals for the felt that a er solution of this problem, from " radiation passports" to operational a higher rati. j limits which only permit a fraction of the dose limit for each ope-from other ca-

1. 8"I **

therefore be This is why n The question of principle still remains: Why not limit the life-time dose or the average dose, if these are the quantities on which procedure. i , the acceptability of the dose limitation system rests? The answer. It is true th so far, has been that such limitation is administrative 1y complica-ting factors ted and calls for complete individual records also of minor exposu-differences d res. Why then 30 into this complication if the des red result is since the ICP i achieved anyway? sures at higt 1 would be no s There is still the possibility, within the present ICRP system, to a life-time r set site-or work-specific operational limits much below the basic is the differenc ldoselimits,ifthisiswhatoptimizationassessmentssuggest J d

• eh F * --

I W... f .m, m m ._,_,~,y-, .._.,,,.y-..-yg_ ,_y. __m,m., ,.m._,m,,m, ,v-.-yy y

9 T ~* O i w I IAEA-CN 42!!5 13 reasonable. Alternatively, the desirable result might be indicated l.. ;.c by reference levels rather than forced by limits. The basic limits tochtstic dose would then only become operative in the few types of work where high -tim (or occu-exposures are unavoidable, and justified, in some years. For workers than 1/10 of the who,are expected occasionally to receive doses approaching the limits, fe-tim 2 average a more complicated dose control and record system would be required. th3 maximum annu. p There are probably not many occupational groups for which large frac-ti ns of the basic dose limit would be needed. If these groups were on to limit any-ontrolicd by con. 4'; forced to observe a much lower dose limit than the present one, for nel cverage dose l any one year, the result might be an unnecessary increase in the col-mora cc.mplicated p lective dose. The types of work which have attracted particular atten-tion are uran g ning, some maintsnance work in nuclear po,ver,,s_ta-tions and some work in reprocessing plants. as? Tcking "occu-dustrici radio-including nuclear (e) The effective dose does not express all health detriment ICRP cssumption When ICRP derived the organ weighting factors v for calculation of )f the dose limit, effective dose equivalent, non-lethal cancers v re not considered, nor hereditary harm later than in the first two generations of off-as occup: tion, spring. In addition, since the individual detriment depends on age rc ctor cperation and sex, the weighting procedure would not be relevant to certain rrgo dtsss in each gr ups, e.g. young women. There would also be a difference between ountry. There are occupational groups and the general public. Why then has ICRP given ago may be less only one set of weighting factors? whero, in some There has been a widening use of the effective dose equivalent, not , o.g. reach 40 anticipated when ICRP Publication 26 was written. The original inten-

cd St:tes and in tion with the organ weighting and the sumnation of weighted organ doses was an instruction on how to c.alculate ALI values for workers.

i 7 to cause higher The weighting was aimed at producis.g a single dose quantity, the ef- ,o cnnual dose factive dose equivalent, for the sole purpose of comparison with the 1 snfaty will be occupational dose limit. For this purpose the late hereditary harm usa r:strictions was not relevant, but the hereditary harm in the first two genera-tions was included, because it might add to the adversity of the exposed individual. 1c3 work:rs who re r:ccive high Since the dose limits were justified by the comparison with the risk stop s21s for the in non-radiological occupations usually considered " safe", it was s" to op; rational felt that a comparison of the lethal risks would suffice. There is mit fcr cach ope-a higher ratio of lethal to non-lethal detriment from radiation than from other causes. A comparison on the basis of lethal effects would therefore be oversate from the radiation protection point of view. . cit the life-This is why non-lethal effects were not included in the weighting antitics on which procedure. <ts? Th2 answer, It is true that the risk will vary with age and sex, while the weigh- .tiv:1y complica-of t'in:r exposu-ting factors are the same for both sexes at any age. However, the . red r:sult is differences due to age would be levelled out over a life-time, and since the ICRP reconnendations do not, permit trading low-risk expo-sures at high ages for higher-risk exposures at low ages, there. ICRP system, to would be no way in which exposures below the dose limits would give b low the basic a life-time risk higher than that which justifies the limits. Also ts cugg:st is the differences in risk between the sexes would be insignificant

(.. 14 LINDELL et eL monetary cost assig over a life-time. This has been clearly illustrated in ICRP Publica. dose 4.J. in dolla tion 27, which deals with the problems involved in developing an in. In addition to this dex of harm. "non-objective" cor. On the same basis, however, the weighting factors might be expected collective dose but to be somewhat different for members of the public, because of the dual effecttve dose dif f erent age distribution. In particular, the mean period of expo-aversion attitudes sure of individuals of reproductive age would be 30 years (if 30 notes the number or, years is the mean age of reproduction) for members of the public, of this addittonal but only 12 years (if 18 years is the age of entering radiological work) for radiation workers. The present weighting factor for the gonads overestimates the " individual" hereditary detriment for the radiation worker but is almost "right" for mestiers of the public. T where S is the mont ICRP could have produced two sets of tables with wT **I"*** 0"* radiation workers and one for members of the public. Seeing how a unit of this non-the values would be, however, the Conesission felt be a good approxime little different it would not be justified to imply this degree of precision, authorities may pri that considering that the risk factors are only assessed with a large and then, if they ner (e.g. by decii degree of uncertainty. wish to pay to ach' A new problem has arisen with the need of assessing collective tions and eliminat1 , doses for the purposes of justification of practice and optimiza. might be said to d. g tion of protection. The easiest method is to calculate the collec. terpretation would tive ef f ective dose equivalent and to base the assessments on this. ICRP Publication 2 However, for both purposes, one would wish to have a collective taction. It is then a quantity that reflects the total health detriment. disadvantage that neither non-lethal cancers, nor late hereditary The optimization p hacia are included in the risk factors related to the effective dose a forthcoming repo Radiation Protecti. equivalent. The inclusion of the additional detriment would change the weighting factors somewhat, and if they were still to add up to unity, the overall risk factor would have to be somewhat increased (a) Is it reasonab tion officer s to include the additional detriment. The new weighted dose sum would not differ much from the effective dose equivalent: in the extreme routinet (single organ exposure of the skin or the thyroid) it might be twice The answer is prot as large. Again, it can be argued that this is not a large modifi-Publication 26 is cation, considering all the uncertainties and the fact that the dosi-radiation protect: metric input and the optimization result are only some of the factors and regulating bot that would influence the final decision. It is a danger to imply a - precision which has no foundation. Logic is consendable when it clarifles and helps. One must be careful not to pursue logic in a { system to the extent that complication makes it useless. med typical condi authorities shout (f) Are " optimization of protection" and "keepina all exposures as each operator rep low as reasonably achievable" identical concepts? installation, how rement is unfair In ICRP terminology, " keeping all exposures as low as reasonably sation principle ,s t / achievable" and " optimizing radiation protection" are identical con-an exemption from cepts. At doses below the basic dose limits, non-stochastic effects It.must also be r i i are excluded and the " objective" health detriment may be assigned a 0"IY #"# I"P"E "C monetary value 05, where S is the collective effective dose equiva-f Ilow the optist lent from the source ce practice under consideration and a is the 4 I: 3, .g 4 [,, / / ?~ ~

• ( (./;

J an s

• eo -

r ~. i [h. I I AE MN-42l15 15 monetary cost assigned by the decision maker to a unit of collective . ILRP Publica. dose (c.,J. in dollars per man Sv). celoping an in. In addition to this, the total health detrimeric may also include "non-objective" contributions which are not linearily related to the it be expected e 11ective dose but which may be some function, f(H),of the indivi-acause of the dual effective dose equivalent. H. This function will depend cry risk eriod of expo. aversion attitudes and national or managerial regulations. If S de-g m s (if 30 notes the numbar of individuals having an average dose (, the cost - 7 ths public, of this additional detriment may be written radiological

tor for the OEN f(k) k a

in:nt fer the k ths public. M uss, one for where S is the monetary value that the decision maker would assign to se ing how a unit of this non-linear detriment. At low doses, however, aS would ? mission felt be a good approximation to the total detriment cast and some national [: { prscision, authorities may prefer to make the optimization on this aimple basis tch a Jar;e and then, if they so wish, modify th,* result in a more pragmatic man-ner (e.g. by deciding without femalism how much more they would wish to pay to achieve special goals such as improved public rela-- ollcctive tions ar.d elic inated anxiety). In the extreme, the function f(H) ind optimiza- ) * =, but this in-might be said to define the dose limit if f(H terpretationwouldbecontrarytotheexplicikg31stinctionmadein e th) collec-a m nts on this, ICRP Publication M between dose limitation and optimization of pro-collective tection. . is th:n a .e h;reditary The eptimization policy recommended by ICRP is described in detail ir. offective dose a forthcoming report on " Cost Benefit Analysis in the Optimization of

would change Radiation Protection".

11 to tdd up to (t) Is it reasonable to expect that the operating radiation protec-shat increased fr.os2sumwoulei tion officer will carry out optimization assessments ir the daily tn the cxtreme routine? d- ~ t tright be twice The ansvar is probably no. However, it must be remembered that ICRP 7 Itrga modifi-tat the dosi-Publicat,*on 26 is not a document written for the guidance of operating authorities the factors radiation protection officers but for national competent and regulating bodies. to imply a t The general idea is that these bodies should have gone through opti-bio wh:n it e us logic in a mization assessmeats before they formulate the more concrete rules for the practical operation. If a certain shielding, under some assu- ~ med typical conditions, is found to have an optimum thickness, the authorities should request that thickness instead of requesting that reports his own optimization result. For a non-typical I Exposures as each operatot installation, however, the licensee may argue that the normal requi-is unfair for his particular situation; he may use the optimi-a rement as recionably zation principle as an argument when he asks the authorities to make f o id:ntical con-an exemption from the rule. .chestic effects It.must also be recognized that the optimization procedurej ives only one input to the,dec,ision-making and that it would be unwise to iy b2 essigned a y .vo dosa equiva. foIIoT the optimization _ result in uncompromising, bureaucratic r,igidity. i cnd a is the t ee ..e w -e

J 16 LINDELL et al " Optimization" is not only a quantitative method of assessment but it correct to call ) is also a basic principle which is helpful to have in mind in a qua-dose eliminated litative way. In that sense also operational procedures may be in-competent natio fluenced by optimization in a wider meaning. ch.: result of t expected to ind (h) How should the value of "c" he deter =ined? in their countr {il Cos,t-effectiveness,and,o2 tim {zation {ii,ilShoul,d,no

l The two concepts, " cost effectiveness" and " optimization (of protec-Since the value lI tion)" are sometimes confused. In cost-ef fectiveness, the purpose is national author to find the most efficient use of a given amount of money. This can radiation prote lbe done without knowledge of any value of "a" (the cost assigned to It is therefore

'the detriment of a unit collecti re dose). In this case, the availab-ate for all. He- !!emoneyisalwaysspentonradiationprotection,irrespectiveof national border whether it is reasonable or not. The only objective is to obtain the mum value of o. , maximum r'e' duction of'detricidnt that the allocated money can buy. countries, such mental internac Optimization of protection, on the other hand, as recommended by ICRP, is a way to find out how far it is reasonable to go in dose reduction. through ICRP. At some stage, the additional redu: tion of dose and detriment that can be obtained at a high marginal cost may be seen to be too small {ig) On what ba /pointwherethesumofthecostofprotectionandth to justify that cost. The purpose of optimization is to find the This is entirel e " cost" of the g remaining detriment has a minimum. It can be shown that this is where rarely any atte: all sectors of the differential change in protection cost equals the resulting dif-at present, it farential change in detriment " cost", although with the opposite by most 'uthori a sign - 1.ence the alternative name differential cost-benefit analysis, society would a For this, it is necessary to express the cost of protection and the tion against st ." cost" of radiation health detriment in one and the same unit, for level in radiat example in a monetary unit. This necessitates a postulated value of a. not to underpro and worry. Neve be very appropr fiy')_The_,va,1u,s_of a and, the actual _co,st of,eliminatin,g,a_ unit,c,ol-1ective dose are sometimes confused. (i) How should future be h TVo alternative protection measures, A and B, each involving a change from che existing situation, may both prove to give a collective dose reduction of less than a monetary units per unit collective dose. {il The guestio Alternative dose teductions by measures C D, E, etc., may cost more The ICRP policy per unit collective dose and can therefore not compete. Both A and 5 the collective satisfy the condition that the cost of protection should be reason-26: "It is ofte able. If also going from A to 5 seans a dose reduction for less than . values of (dose i a monetary units per unit collective dose, 8 is the optimum solution. ficantly to the' However, the actual cost per unit collective dose going from the portionality be existing situation to 8 may be auch less than a. vert to a large [Ontheotherhand,additionalconsiderations(e.g.therequirement as a millisieve ( to keep all individual doses below the authorized limits, or the wish the large one. { to maintain good public relations) may cause managements to chose, or There have been authorities to demand, solution C, although it is not the optimum if in the calculat the detriment cost is only supposed to be aS. It would then not be carry a complet .:: ::.=

• ~

q, ,_,p -es e + -##D** e .-+-g w-m n -a- ^ ----

~ ...h.. e IAEA.CN 42!!$ .E* to call the actual cost of protection per unit collective dose eliminated "o". O should be the predatemined value given by the . 'J'* correct but it ', i*d.-- gssnent is not competent national authority as the basis for optimization. It h -ind in a qua* h fo*e the res2 C of the final decision. National authorities are t ere s m:y b2 in- ?. ions with-r, expected to indicate the appropriate value for a for operat I 7 -, -;q - in their country. o a 2c li i). S.hou,1,d,not,ICRP recopend, a value f or o? Ln... l '! T l the willingness and ability of ip Since the value of a should reflect national authorities to enforce a certain level of ambition for '4 on (of protec-radiation protection, it will depend upon each country's resou .M Z "' the purpose is ide of 'F' nsy. This can ate for all. However, for collective dose contributions cucc it t _f .t essigned to on a mini-national borders, it may be reasonable to reach agreement E ,1.. ~ o, th] availab-mum value of a. Since this is a matter of political agreement between "7 esp:ctive of countries, such agreerents are better achieved through inter-govern-i GEE S to obtain the h mental international organizations such as IAEA or OECD, t an T ey ccn buy. armninded by ICRP, through ICRP. lj N DN*t Ms,sM 93galugMghe,Mvgq I n dos 2 reduction. g 9 j This is entirely a national matter to decide. However, there is yet o 1 i- ! rarely any attempt to form a consistent protection policy, covering co Hnd the . @ JJ

all sectors of society. The way radiation protection is ad

nin cast of the A

$at this is where i by most authorities is selected without any csnsideration of whether at present, 4: . rcsulting dif-G.e same arbition level in all areas of protec-

ho oppostte I

bition b-. society would accept tion against stoe.hast M harm. On the other hand, the high acn: fit analysis, tcetion and the d in a field which is subjec,t to quch pub,lic d,ebate '"' ""IC' IO# ld, " g not to underprotect and worry. Nevertheless, more crosschecking against other areas wou I~ altt:d value b h Yy* appropriate. d EE d.un,tt c,ol-(i) How should verv small individual doses and doses in the dist } future be handled? " lev,el ii). Ihg gugsgign_of, a gut-of f value of, dos 3 or,a,"d,e, mini

• sis nvolving a change The ICRP policy on the inc1'ssion of small individual contributions to c

Acated in paragraph 23 of ICRP Publication .. Cy c st more the collective dose is i."It is often not necessary to assess the contributions fro sto. Both A and B 26: i i values of (dose) ac:urately, providad that tuy would not add s gn - ~. ,ould b2 reason-ficantly to the total integral". Mcwever, with the assumption of pro-ion for less than a microsie-optimum solution. portionality between dose increment and risk increment, i vert to a large population is postulated to have the same detr ment oing from the f as a millislevert to a population which has a size of only 1/1000 o th] requirement the large one. inics, ce the wish There have been many proposals to ignore completely very small doses ~ they in the calculation of collective dose, with the argu: ent that ments to chose, or carry a completely negligible risk to the exposed individuals. The tot the optimum if 'uld th n not be 6 w+ t ~ ~ .We+ eme>'e b =

18 UNDELL et d. assumption is certainly correct, but the conclusion is f.lse. The and todine-129, only true conclusion is that the very small dose contributions can relation to uru be ignored by each exposed individual. They may not be ignored in the sion of radon f. assessment of collective dose unless, as ICRF says, they also contri-An OECD/ SEA stu bute a negitgtble amiant to the collective quantity as well. If a reactors and ret large number of Individuals each have a very small doce, they may way, considerin. still contribute a significant amount to the collective dose. calculati m The problem may be compared with that f rom the att pollution f rom many chimneys. Each chimney may contribute a negligible amount, but for h atificati the total effect may still be objectionable, time may be pre Any "de minimis" concept should therefore relate to collective doses

• 1. 8' rather than to the individual dose contributions. However, any opti-mitation effort which involves measurements or calculations would itself cost at least of the order of 100 - 1000 US $. With the values of a often considered (about 100 $ per man rem), this is equivalent to the detriment cost of a collective dose of at least 0.01 - 0.1 for opetmisatic man. sievert (1 - 10 man rem). Thic collective dose would have to be systems, it sho eliminated to make even the assessment as.2uch justified.

any r.unaining r and nach the b Very small it.fividual doses are often found at large distances from chat which woul the release point of radioactive pollutants, e.g. outside the border ~ E lines of the primary jurisdiction. If it is argued that they can be neglected a priori in optimization assessments, the obvious solution

r. d

. nt will exist. The would be to build high chimneys and dilute the pollution, thus elimi-these assessmen nating high individual doses. This may cause a higher collective dose, but by very small individual doses ta large populations far (j) 'iov should away, perhaps in other countries. If all releases were made "accep-tive u tf-I table" by such means, we know from the experience of non-radio e.tive pollutants that, in the long run, there may be a widespread general contamination from many sources, which is not desirable. This would There is a prac that the annual only be prevented if the small doses were given a proportional weight, red from monite t.d. by using an a-value for these con uibutions at least equal to ,,, p,,eggc,g, that applied to doses near the release point, and not neglecting any ,,,,gggyggy og small individual contributions (cf. paragraph 531 of ICRP Publica-ALIs have not t tion 20. maximum permiss lii). Dosed,istributionsin,,the,distv}c, future 3 / f The previous discussion defeads the view that each unit of collec-tive dose should be given the sase weight irrespective of uhere it The answer is t g ! occurs. This may be defended on equity grounds buc also by conunon body burden of senses if everyone neglected harin to neighbouts, everyone would also would really or e be caused haru by neighbours. Life. The limit Dose contribut[ons in the ystan,t,futua._ arc mory,,.ag.tthicaussue--- nd d than something tha: can eastiv be handled with sommon senso: future generations cannot retaliate and bring their own polluti'on b'ack on a nit rgng prol us. Many would say that in the choica between a dose today and a The reason why us),However,otherssaytheoppositeandthematteriscontroverf dose a thousand years frow now, the latter would be preferable (to received dose life-time dett: sial. This ptoblem has been extensively discussed in relation to { posures". An e; releases of long-lived radionuclides such as critium, krypton-85 the same year 1

. C. ' ~.-. I AE A-C%42/I s 19 p- 's false. The and iodine-129, in relation to high-level waste disposal, and in ributions can relation to uranium mining and milling (because of sustained emis-os ignored i9 the sion of radon from tailings), g th2y also contri-An OECD/NEA study of the releases of long-lived radionuclidas from as wall. If a reactors and p rocessing plants approached the problem in a logical foss, they may way, considering the following two main purposes of collective dose tive dos 2.

• • IC"I'***"8

,ollution from .blo amount, bu: For h stiftcation purpoJGS! The accumulation of collective dose over time may be presented in tables or diagrams. Decision makers can then 2 see when the major part of the exposure is expected to occur and how co11cetive doset, large the collective dose will be in the immediate future. No infor-vsyce, tny opti-mation should be omitted and it will be up to the decision maker - not 11ctions would to those presenting the data - to decide how concerned he is about

i. With the values exposures in the distant future.

s is cluivalent ist 0.01 - 0.1 Ear opcirrisation purposes

In assassing the usefulness of reter. tion systems, it should be recognized that, in the very distant future.

could h;ve to be .ficd. any remaining radioactive material will eventually escape containment and reach the biosphere. The collective dose actually eliminated is

• dist:nces from that which would have occurred without retention over the period when sesid2 the border, the retention is effective. This is likely to be a much shorter pe-

h:t th:y can be riod than the millions of years over which, for example, iodine-129 obvious solution will exist. The extreme time periods are therefore not relevant in ttion, thus elimi-these assessments.

ir es11cctive )pulctions far (j) How should monitoring results for nuclides with very lons, ef f ec-1 2rw = d2 "accep. tive half aives be interpreted t ! n n-radioactive f:sprced general There is a practical proble.n in monitoring for internal exposure, in ablo. This would that the innual intakes cannot easily be measured but only be infer-op2rticnal weight, red from monitoring. Yet, the secondary limit recotunended by ICRP Isaat cqual to }frpracticalapplicationistheannuallimitofintake(ALI).The 't nsglecting any sensitivity of monitoring is not always good enough to verify that ICRP Publica-l ALIs have not been exceeded. In the old system, on the other hand, maximum petuissible body burdens could be measured. The question has ~- therefore been raised: Why not continue to measure body burdens ed assess actual annual doses, rather than 1other about annually can-mitted doses? init cf collec-iva of phare it The answer is that, evsn with the old system, a maximum permissible tiso by common body burden of a long-lived radionuclide, st.ch as plutonium-239, r cry:n2 would also would really caly have been permissible at the and of the working j2 life. The limitation of the coussitted dose rather than the actual dose each year is nothing new with ICRP Publication 26. It was also i cthical issue rec cr; ended in ICRP Publication 9 in 1965 (see paragraph 54). The in s:n:2: future monitoring problem is rea*., but not new. .lution back on

• tidry and a The reason why the annually cocznitted dose rather than the annually 3

pref:rtble (to received dose is limited is that the main objective is to limit the e is controver-life-time detriment. This can be done by controlling the annual "ex-i t'ciction to posures". An e-tarnal exposure will commit a worker to a dose in 4 krypton-85 the same year he is exposed, while ines.*:al exposure, in the sense e-

r ..n tC < \\i 20 LINDELL et et of an intake of ra'ioactive materist, will commit the worker to a Q tei lin dose which may be delivered over years to come. The detriment is the fare, d:es eyectation of stochastic harm, most of wnich will appear not only tion for Ic long after the dose is committed but also long after the dose is re-radiation i csived. The fematism by which ICRP recommends this to be centro 11cd, the risk fr is to limit the sum of the actual dose from a year of external ex-high-LET ra posure and the dose cocnitted the same year f rom intake of radio-active substances. It may well be that, in some years, this system (2) The rev s could cause actual annual doses somewhat higher thtn the annual dose The observa i limit, but the actual annual doses are not subject to the limit. the survive These high r doses are compensated oy much lower doses during previ-important t ous years, so that the life-time detriment is still within the inten-titative ri ded limit. The system is logical and in the interest of the worker, referred to but it is not easy to explain. This causes the problem that (to quote Ridge Natto from one international report) "the ALI application is excellent for neutron spe tors tnflue control of the exposure to radiation workers, but less acceptable for dose assessmant purposes". Quite so, but the question remains: What revised at ted results is the purpose of the assessment? If it is to check that no unexpec-earlier ass ted or excessive exposures have occurred, the checking is difficult mation on t t but relevant to radiatinn protection. If someone wishes to assess 1 actual annual doses for some other purposes, e.g. for epidemiological It has beer. { studies, tMs is no part of a control program. would make crease in t NEW PROBLDiS that the ri upwards to Af tac the appearance of ICRP Publication 26, radiation protection indicates t authotities have experienced some new problems which ICRP had not so that any l discussed or at least not commented upon. Some of these problems are prabably be now given high priority, noch by ICRP and by other international last words organizations and national authorities. It would go too far in this (3) The ris report to discuss these problems in any detail, but some will be briefly mentiored: The risk of pregnancy c (l', The quality factor for neutrons and ett er high-LET radiation period is a With the report of the US National Academy of Sciences' Committee on stated to t the Biological Effects of Ionizing Radiations (the BEIR III report, believed tr 1980), the debate about the true shape c4 the dose-response curve missed mens for low-dose exposures was again stimu'.ated. If the dose-response in that the curve f)r high-LET radiation is linear, but the c s ve for low-LET does nc; da radiation quadratic, as some experts believe, then the relative about 10-It biological efficiency (RBE) of high-LET radiation in relation to give an adt low-LET radiation will obviously increase at low doses. pari d, th; i chan the r-On this basis, there has been some concern about the ICRP quality factor, Q = 10. for neutrons. The quality factor m1y be seen at Ihese new i a siderable

• crude approximation of RBE for protection purposes. Would not the ICRP value for Q grossly underestimate the risk frca neu':rons and E*I*EI"E E' other high-LET radiations at Iow doses?

(4) Ceneti. The answer is no. The quality factor used by ICRP does not relate the high-LET curve to a possible quadratic low-LET curve but to a poc-The tradit to changes l l l ~- 1 i 1 l

a m= ~ -- - 21 IAEAC4I!!5

dated linear curve for low-LET radiation. The value of Q there-s worker to a fore, does not depend upon the validity of the biological assump-

strim:nt is the 2psar not only tion for low-LET radiation. If the dose-response curve f or low-LET ICRP has r W res & Jted th3 dose is re" radiation is non-linear, it merely means that the risk from low-LET radiation at low doses, not that the risk from to b3 controlled, f cxtGrnal ex-high-LET radiation has been under-estimated.

aks cf radio-The revised risk estimates f rom Hiroshima and Nagasak_i (2) s, this system The observations of the frequency of various types of cancer among tha canual dose the survivors from the bombings of Hiroshioa and Nagasaki are an o th? limit. important basis f or our present stochastic risk estimates. The quan-so during previ-titative risk estimates have mainly been based on dose assessments, within the inten. ref erred to as the "Tertative 1965 Dose" or T65D, made at the Oakthe Ridge National 1.aboratory. Witn more reliable inf omation about of the worker, em that (to quote neutron spectrum, emission, transmission and build-up, and other f ac-

• n is excallent for tors influencing the dose, these dose estimates have recently been ss rce:ptable for revised at the Lawrence Livarmore National Laboratory, with unexpec-ted results. It seems that the neutron doses were much lower than in remains: What earlier assumed and that there is therefore noo no basis for infor-th:t n2 unexpec.

.ng to difficult mation on the carcinogenic effect of neutrons on humans. It has been suggested that the decrease in the neutron dose estimate sh:s to essess 3r cpidemiological would make the gama radiation alone responsible f or the observed in-crease in the cancer incidence among the Japanese survivors, and that the risk factor for gacuna radiation would have to be revised upwards to account for this. However, the 1.awrence Livermore study the gamma dose was probably earlier underesSated indicates that ion pr:tection so that any revision of the risk f actor for gansna radiation would probably be minor. The situation is under continued review and the h ICRP had net h:s3 petblems are last words have not yet been said. intern:tional ' to3 fcr in this (3) The risk of developmental ef f ects_ The risk of foetal damage f rom radiation depends upon the stage of soto will be sensitive pregnancy during which the irradiation occuts. The most period is assumed to be the period of organogenesis, which is usually LET radiation stated to be within the first two months after conception. It is now believed that this risk is mainly during the weeks after the first icch' Committee on missed menstrual period. However, a "new" risk has been recognized BEIR III report, the forebrain, which is particularly critical for humans, -rcsponta curve in that does not develop until after other organogenesis is ccmpleted, at a dose-response about 10-18 weeks af ter conception. Exposure during this period ma;- rvo f:e low-LET give an additional risk of mental retardation. For the sensitive tha r:1ctive period, that risk would appese to be an order of magnitude higher in r:1 tion to than the risk that has earlier been considered. as:s. These new conclusions vill have to be verified and may have a con-gg sidersble practical impact on future reconsnandations on protection ay be caen as a relating to pregnant women and women of reproductive age. . Would not the om neutrona and (4) Cenetic detriment The traditional way of presenting genetic risk estimatas is to refer do:3 nit relate the to changes in the mutation rate. Geneticists often draw conclusions to but to a pos- \\ 6

• N n -.

no

• 9

g } = ~ 22 LINDELL et al. ~ from equilibrium situations, where many generations of experimental CURT animals have been exposed to mutagenic agents. From this there is a jg f* difficult step to an estimate of the actual total hm that would ensue over all future generations of humans (or over any specified number of generations) from single exposures that are not repeated M.RO: over m.ny generations. Nevertheless, such estimates of " harm com-it-Depart ments" would be needed for comparisons bett.reen hereditary harm and Intern; cancer. For this purpose, it would also be necessary to find some Vienns way, if even crude, to indicate the severity of various types of hereditary harm. This problem is now being studied by both ICRP and UNSCEAR. Abstrac (M Exposure from natural sources of radiation CURRENT NUCLI Doses from natural radiation are usually not included in the assess-The rote of t! ment of dores to be compared with the ICRP dose limits or with any safety is growing. ' authorized operational dose limits. Natural radiation has been con-use of a compreher sidered both as unavoidable and as insignificant from the point of tnatiatives are ta pr view of radiation protection. exchange of inforrr During the last years, however, our estimates of the dose that we shanns of safety re receive from natural sources have been repeatedly increased. In par-co operation and ar ticular, the lung exposure indoors from radon daughter products has way to encourage r been found to be much higher than previously believed. The source of report on nuclear t radon may be building materials at tap water, but is perhaps mainly annual publication the ground. The problem grows because of the efforts of energy con-servation and nsw bu(1 ding techniques, which have led to decreased i ventilation rates in countries with a cold climate. The average an-nual dose from natural sources, which used co be assessed at about a e 1 mil 11 sievert, is now believed to be more f.han 2 millisieverts (ef- . factive dose equivalent) in many industrialized countries. 1. INTRODL ,{ In many countries, the lung doses from radon daughter products in-doors are frequently found to exceed values which would have been There is nt dose limits if the source had been artificial. It happens that some i people receive, in their homes, doses that would not be permitted the Three Mile to workers in a mine. There is a growing interest to find regulatory nuc! car safety, means of dealing with this situation, which is not easily solved. national safety L In several countries, measurements in dwellings have revealed radon have emerged. equilibrium equivalent concentrations of radon daughter products ex-caeding 10 000 becquerels per cubic meter. This may give an ef fective safety analysis l dose equivalent of several hundred mil 11 sievert (i.e. tens of rams) Atomic Energ> per year, and annual lung doses of several sieverts (hundreds of tional commur. rems), clearly unacceptable. Still, remedial action is complicated With man and difficult because of the large number of houses involved. The some r as cost of protection may be difficult to cover, since there is usually no one that can be claimed to be legally responsible for the situa. ready to be co. tion. Because of the long latent period for lung cancer and the sable tool for r likely importance of smoking as a contributing factor, it is also dealing with tt very difficult to verify the risk estimates by epidemiological studies. w de incident t l of government t g { ~~ 1 l

/ , Q'ns, Q not benefit **, This implies that each practice, or activity, involving radiation i ' exposure is submitted to a process of cost-benefit analysis, the outcome of, permissible fluences of neutrons by a factor of 3 some time in the next which should be a positive net benefit. The benefits to be considered in this five to ten years. andysis include all the advantages, ecmomical, social, sanitary, etc. that port of the R8E Committee to the International Cce%s on society can draw from the practice under consideration. Semilarly, the costs P R Wi Mmmt to be considered cover all the negative aspects of the practice, including economic costs and social, health and environmental detriments. , 2, Therefore, justification is essentiah y a political decision-making process, on Radeologecal Protection.The R8E for g neer iund ss high LET radiations with respect to mutagenesis. Omiord, Pergamon 'a in which the technical and purely radiationeetated advantages or detriments 2 Press, ICRP Publication 18 (1972). play an important, but relatively limited role. Radiological protection is only Kellerer, A M and Rossi, H H.The theory of dual radiation action. one of the considerations relev.nt to deciens, and the role of radiologica' protection experts and authorities is generally caly that of supplying accurats 3 Curr. Top. Radear. Res. Guarterfy,8,85 (19721. + Thomson,J F Wdliamson,F S,Grahn,D and Ainsworth, E J Life assessments of the radiation detriment associated with a given practice, whilst shortening in mice esposed to fission neutrons and gamma rays. Radier. the organisms responsible f os Jecisions on justification are usually the politic 4 Ret,36,559 (1981): Radiat. Res.,36,573 (1981). or administrative ones. Jacobi,W and Eisfeld, K. Dose to tissues and of factive dose equivalent There are,however, some practices in which the radiologecal protection 6 by inhalation of radon-222, radon-220 and their short-lived dauahters. impHcaions n predominant,in which cm the decisions on justification GSF Report S426 (1980). bgpg reside primarily with radeological protection and public health authorities. I Examples of this are the introduction of consumer goods containing radio-i MO,4-8 active substances or the implementation of a new radiological practice in 3 m-NEAstatementson m

3. The bases for justification are usually contained in nationallaws or regulations instituting or authorising given practices. For this season, it appene k,gl,g{

g=g pg hg. not to be appropriate that requirements for justification be included in the 1 ge ua %s awJ narrower field of radiological protection regulations. In particular,it seems f, u% essuse l LA def ficult and of limited utility to introduce into radiological protection i standards clear and specific instructions of relevance at the operationallevel ~ The following two staarments have been procksced by the Committee on

4. An additional consideration to support this is that any requirements Radiation Arosection and Public Healeh of the Nucisar Energy Agency of in radiation protection regulations need to be supported by a workable DECD, and have been formW/y transmitesd to the national aushorities of h mechanism for inspection and demonstration of compliance. in th Member states through officialchannelt The suggestions made in these requirement for justification such demonstration of comphance would need

,to l statements are, of course, not binding on Member states-extensive record keeping, covering all aspects including those of a social and economical nature for each action undertaken. This information is usually beyond the reach of those responsible for the implementation of radiologic; l protection standards and the inspection on their compliance. Even the sima cai-ti-ad eab=>iwa' -* ia'-ima = 'd aa h -a-l Statement on the applicability of the effective in the light of the potential resulting improvement of protection. ! 5. ro, these,easons, me Commiiiee on n ICRPpn.naple of.lusfif. cation of a pract. ice l "'d * -a'id-d ** aaiaa *"*-i*' *"i* * aa*"a 'adia'a'ic

protection regulations and standards for appgicatio to radiolonical nrotection standards a

r-

1. The system ol dose limitation recommended by the lCRP in its Publication cation in these standards.

g 26 of 1977 is based on three basic principles in application of radiation However, the Committee believes that in view of the importance of the protection to all situations involving exposure of workers or the public: principle of justification from the conceptual viewpoint the need for justi-l justification of practices, optimisation of protection and limitation of fication of practices should always be kept in mind in operational decisions individual doses. l

6. In conclusion, the Committee on Radiation P otection and Public Healt The principle of justification, as stated in ICRP Publication 26, requires that agreed on the following statement which should be beought to the atte

• • No practice shall be adopted unless its introduction produces a positive, h

O N

>f national authorities responsitde for radiological protection and putdic i f commumty of tealth, and should be communicated to the internat o.u radiologicd protezion experts.

• Decasons about the justification of a practici or activity involving radiation Theter exposure usually involve a broad range of sodJ, ernnomical and political issues in addition to those conc =rning rodeological protection. As such the sustification requirement is usually embodsed in national laws or in aegulations issued by national authoritias to ispplement this legislation.

While the principle of 1, stificatico in theory applies at all levels of decision-making in matters involvingiadiation exposure, in practce it has limited, if cgical protection standards applicable to activities any,Etility in rad.c8 authorised by nationa! authorities, la particular,it is dalficult to inchde cleat and specific instructions for justification of practicesin radiol # calI partecthn standards to be applied at the operational level. Such instructions / would be simost impossible to inspect for compliance without extensive record keeping. The analysis and record keeping required to show sudi com-plianca asa probably not costeifactive in terms of the esultingimptovement ~j of radiological protection in a system that already applies the principles of optimisation of r. otection and of limitatisa of individual doses. "Theretoe2,it is suggested that specific requirements Ior justification are not mcluded in national radiological protection standards applied to operation. Ihther, it should be noted in the preiace to national standerds that the justitecation of practices is *be first stage of the system of dosa limitation t, which should be kev. in r und un operational decisions.** i I ~ I l i e.. 9 l 8 O 9 L_ s A

NRFB -% / s. h= g ()*f ' ~~ -q Opt..imisat.ionofprotect. ion m, ore te,mmmg its or-. As _th AS,,the opimon of others the subject so that the Boatd can takrinto account

3. th...d_ _,8 concern only routine exposures during normal operations, but it w.il ar 4 ly, of rad. t.ia ionwor rs-workers withsn the nuclear industry, medacine, general industry, sesranc =

- ' - - " - - ~ ~ - - and teaching. a consultat*ivedocument on -r, ~ rue of -t -efit -1,,.s -f te ~ e ALARA in the workplace, the consult.ove document (*) distinguish a G A M Webb and A B Reishman

• -a *"9a "d *"a d '"9 "a """*' ~ ^'- "' - ""- """ ' -

about working prucedures and day to day decisions concerning the.mut actio i NATIONAL RADIOLOGICAL PROTECTION BOARD, CHILTON of specif.cindividuals.The suggestions Imt forward on the costs to be as egned ' to collectin doses received by irradsated workforces are of necesuts erwersc, it is now over five years since the intemational Commission on Radiological i' 'etating to

• average" eadiation workers in ' typical' working envuonme nts.

Pr:tection issued their last set of recommendations (a) and about nine years The princspies underlying this valuation are the same as those des:rited m sincs they introduced the technique of cost benefit analysis (8) to examine ASP 4(*). placing greater emphasis on protection of those endsviduals receiving the reduction cf radiation exposures to levels that are "as low as reasonatAy doses approaching dose limits. This again results in a costng schemir Nt achierable, economic and social factors being taken into account" or assigns a higher cost to collective doses made up of higNr individort doses. i " ALAR A". During this time, the principle of optimisation of protection, The proposed scheme for workers is intended to be beoar*Jy compatible with previous Board advice for members of the public but the numerical values plwhich is just another way of saying ALARA,has become established as a major objective of practical radiological protection. Quantitative cost benefit i reflect a number of judgements on the relative weighting or public and studies to com9are the costs of protective measures with the benefits from occupational expor,ure. Similarly, while the Board continues to advocate in reduced radiation exposure have also remiv.d encreasing attention as a means principle the discounting of future deuiment costs,its views on appsoptiate ci setting out some of the inputs to decisions cea ALARA. discount rates for occupational exposure are somewhat different f rom those expressed in ASP 4(*l, Against this background, the Board has been working over the par,t several yIars to develoo the ICRP framework of cost benefit analysis into a scheme By developing such advice on the appropeiate value to be assigned to collective for practical application. This requires numenical values to be assigned to the doses under dif ferent circumstances, et is hoped that the Board's overall components of the cost benefit analysis;in particular,it cannot be carried framework of r3st benefit analysis will eventually help to resolve so a sensalde out without setting a snonetary waluation on radiation induced health detri. manner some < J the conflicting iactors commonly involved in decasions on ment under various circumstances. It was decided to concentrate initially on ALARA, particularly those involving trade off s betwren individual and the optimisation of protection of the public, and the first cc;nsultative collective doses received by workers and the pubhc both now and in the documentOI on this subject was issued in 1980. This discussed a number of future. alt;rnative approaches to the valuation of health detriment and put forward a range of monetary values of unit collective dose (ie, E per man Sv). In 1981, References (f;r due consideration of the many comments received, the Board publiahed 1 ICRP, Recommendations of the international Commrssion on R d.o-its formal Advice on Standards of Protection (*) (ASP 4), together with a logical Protection. Oxford, Pergamon Press. ICRP Publication 26. stan. supporting docurr at s8, on the application of cost benefit analysis to the ICRP,1, No. 3 (1977). t radiological protection of the public. 2 ICRP, implications of Comanassion reconunermiations that doses be kept in preenting the advice in ASP 4(*) it was stressed that the recommendations, as low as readily achievable. Om ford Pergamon Press, ICRP Publication and particularly the values assigned to health detriment, should not be 3 he plication of cost benefit analysis to the radiological protection applied to occupational exposure. The Board nonetheless retx>gnised that for of the public: A consultative document. NRPS(1980). (London

• full implementation of cost benefit analysis as an input to ALAR A, the framework wot.ld need extending io include radiation workers. Following a 4

nefit analysis in optimising the radiological protection of the lasge number of informal discussions betweer, Board statf and others an the public: A provisional framewos A. NRPB, ASP 4 (1981). (London, field, proposals for achieving tfus objective have now been outlined in a consultitive document (*3 on the optimisation of protection of radsation 5 sk J. Fleishman, A B and Webb. G A M Optimisation of the workers. This document is being widely circulated to worker representatives. M iol prme ts of the pubhc. NRP8-III20 (1981). (London, mmagements, regulatory bodies, and others with a professional interest in ifMSO). 4 5 N 3\\' ..." e or

l Cost benefit analysis,in the optimisation of protection of radiation Develop *ing guidOnceforthe 6 wor,ersm._It.t.e d_ent. NePB oom Radiationandtheworker-draft Protectionofthepublicin regulationspublished thelatterphasesfollowing an OCCidentOIreleOseof I I The rediological protection of workers in this country has been governed by a variety of provisions applicable to dif ferent types of workforce. The Health and Saf rty Commission, acting under the Health and Safety at Work etc. Act 1974, has published consultative versions of regulations and an approved code gnng g c ng y% g. BIV a ci practice. The NRPB is publishing a consultative version of medical and uvi Ivbu J dental guidance notes and two other guidance notes in dur course. HSC and N RPB have invited comments on the consultative documents. The new documents incorporate the Recommendations of the International Commission on Radiological Protection published in 1977. These are already n IJ l L incorportted in a Directive of the European Communities, compliance with 15 I I IOrre which is mandatory in EC Member States. The objective in the UK is to achieve NATIONAL RADIOLOGICAL PROTECTION BOARD, CHILTON this through the system of regulations and approved codes and the consultative versions are a significant advana towards that objective. The following is on sale through HMSO: Consultttive Document: The Ionising Radiation Regulations 198. The following will shortly be on sale through HMSO: Accident sequences can be categorised into three broad time phases during Consultttive Document: Draft Guidance Notes for the Protection of Persons each of which dif ferent considerations are required in decidmg whether to institute countermeasures to avert potential doses to the public. These are the Against lonising Radiations Arising from Medical and Dental Use. Consultitive Docurnent: Draf t Guidance Notes for the f-rotection of Persons early phase, the interrnadiate phase and the recovery phase. Exposed to lonising Radiations in Research and Teaching. The early phase of an accident sequence is defined to cover both the period Consultttive Document: Draf t Guidance Notes for the Protection of Persons when there is a threat of a release, that is from the time when the potential Erposed to lonising Radiations Arising from Veterinary Use. for unplanned irradiation of the public is secognised, to the time when exposure begins and the few hours immediately following. Decisions con-Rad *lat* ion andtheworker-cerning the protection of the public in this phase can usually only be made on ,he bas,s o, in,o,ma, ion about the in,,a,,a, son i, i,,or,h,s phase th., one-daysymposium rR1R "'-"" '-" ' "- "'*" ""~~""'" " """ '" A ons day symposium is being organised by NRPB, the Health and Safety in the intermediate phase, which is defined to be that period from a few Ex:cutive and the British Association for the Advancement of Science, with hours to several days af ter activity is first released,it es peesumed that most the title " Radiation and the worker - where do we go from here?'*. It will be of the potential release from the installation to the atmosphere has taken held on 7 January at Fortress House, Savile Row, London W1. The meeting is place and, unless the release consists mainly of notJe gases, measuralJe being held during the period of consultation on the publications referred to amounts of radionuclides are likely to have been deposited on the gsuund. In abov3. These docurnents show more clearly than in the past that for society this phase, the primary routes of exposure of the population are external to hws the benefits arising from the use of radiation it has to accept some radiation doses from the deposited activity and intesnal irradiation due both risk. In deciding on the acceptance of that risk the process of consultation is to inhal; tion of material resuspended into the air and to the consumption of assentiil and this meeting is intended to assist that process, contaminated water or foodstufis denved from contaminated areas. In ERL2 For further information contact Mrs U Laver, BAAS, at the above address or NRPB stated that it envisaged there wou,d be time to twing together a group of people competent to advise on the continuing limitation of rad.ation on 01734 6010. Ext 377. 7 6 i. lpg. q

OQ TTERS TO THE EDITORS LETTER HE EDI he dosage Cr71 Cronquist A..Pochin E. E.and Thompson B. (3) A trivial concentration of a emitters in air-Shiue (C and adop-D.,1971, Health Phys. 21,393. water is one which in the maximum exposed in-I cm, the for adults. Hast Halperin J. A.. Sh!cien. B., Kahan4 S. E.and disidus! would not result in a risk of cancer in-per unit 50mg for Bilstad, J. M.,1981. HHS Publication FDA SI-duction in excess of 10. from the once only 8158. Close to the limit of detectability for many about 7! m even to Po62 Pochin E. E. and Barnaby C. F. 1%2, Health nuclides, the adoption of such levels would permit 40% at i ed thyroid Phys. 7,125. screening and elimination of many below back-interactit ground environmental samples. equivale:

iodine as Acceptance and introduction of such guidelines obviousi as cut-od criteria in computer models may result Since thi on proper in redirection of priorities toward other, more proportic ase and to

.uztion and imminent health hazards and societal problems city, an) ninistratio2 associated with radiation dose levels. energy d """w s s' " *

• surface evacuation ccident th2 GEOFFREY G. EXCHHOL.Z equivaler sde of any m.n es,,va <s.us eow n.nas-nes. nas School of Nuclear Engineering give an y apparent.

and Health Physics sponse f P'=8 'a 'a' U S A Atlanta, GA 30332 suitable e necessq .y.g, normahz g within it References cident n own t3 be (Receired 6 December 1982) Da82 Davis J. P. and Harris S. J.,1982, "The proportit ip t2 3-4 hr Concept of 'de Minimis* Dose and its Ap-per unit line (Po62)

Dear Editors:

plicability to a Regulatory Cut-off Policy", to separ FOR MANY years widespread concern has been Paper P/80 presented at the 27th Ann. Meeting, reflected given indis-expressed about the enormous dedication of effort, Health Physics Society, 27 June-I July 1982, intent w ):s is to be manpower and funds to estimating and technically Las Vegas, NV. Obvious; reducing radiation dose levels, envirr amental Ei80 Eichholz G. G.,1980, " Statistical Cut-off element

iodide ts a pathways, and population exposures of negligible Criterion", Health Phys. 38,443.

appropri upationally consequence (EiS0). Of late, even the U.S. We82 Wens!awski E. A.,1982, "De Minimus in the IC e should be Nuclear Regulatory Commission appears willing to Radioactivity: Toward a Better Understanding", operatior accupation-accept some limitation of concern, for instance, Paper P/47 presented at the 27th Ann. Meeting, d rely upon for purposes of ALARA criteria, with dose levels Health Physics Society, 27 June-1 July 1982, es, i.e. the of truly negligible consequence (Da82; We82). For Las Vegas, NV. Nationa. val of the this purpose the term "de minimis" has appeared

Chilton, ament by in the literature recently, derived from "de minimis Ozon. O l

non curar lex" (thc Law does not concern itself Entfand tablets and with trifles). ailable f:r Since "de minimis" is neither noun nor ad-il prescrip. jective,it might be better to retain the concept, but e n-Q s iz 60 mg of replace it with the term " trivial dose" or " trivial CH81 ( l four times concentration" for regulatory purposes.

• • • • rhyws vd 49. Na i OWA p. W. Mt3 Report

) h"' " *. u s

• ose. These No single trivial dose level or trivial concen-Sphere i.A. under tration can be defined for all purposes. However, 4th Sy er medical for starters, the following are proposed:

Measurement of Neutron Dose Equivalent berg,J be just as (1) A trivial-dose rate for S-y emitters is one from Thermal Energies up to 10 kev ets. that is estimated to contribute no more than (Reces.eed 8 October 1982) 5 mremlyr (0.05 mSvlyr) to the natural background . BoNNEll. exposure of any individual or less than 250 mrem

Dear Editors:

(2.5 mSv) to his 50 yr dosc commitment. THE RECENT calculations of neutron dose (2) A trivial concentration of radioactive s-y equivalent in the ICRU sphere by Chilton and emitters in air or water is one that does not lead to a dose equivalent in the maximum-exposed in-dividual, by all pathways comiined, to an in-tegrated body dose exceeding 5 mremlyr %2, Health (0.05 mSvlyr) or a 50-yr dose commitment of 0.25 rem (2.5 mSv) from that cause. _g X -Q~. a -~ 1

\\ %N M EV m 1 V .L 'INE BALTIMORE-WASHINGTON CHAFUER s ( 0 dk o(., 3 \\ m W_ Volume 1 No.3 Washington, D.C. I February 1934 ~ ME EEE N NU cau rsa orriccas PflESIDENT Is the ALARA principle serving those practicing radiation protection as intended? J.W. Thiessen, M.D. When the founding fathers of modem health physics (post World War 11) laid down the basic tenets of radiation protection, the ALAP (as low as practical) concept was meant PIIESIDENT-ELECT . to be an admomtion to the health physicist and others responsible for radiation William A. Mills protection to do a good job by good practice. It was intended to provide protection for those exposed that reflected good judgement by the health physicist in carrying out his SECRETAIIY responsibilities. George W. Siebert This concept was indeed a FRIEND in that the practice of ALAP demonstrated a . responsible attitude by the health physicist and likely gained him acceptance by those TREASUllER exposed. It produced a workable attitude of protection that has resulted in an unequal larry Smialek ! protection record for a very complex industry. ALAP complemented the numerical limits which were established to control maximum exposures. PAST PRESIDENT Allen Brodsky Recently, however, we appear to have strongly emphasized ALARA (as low as reasonably achievable) that we may have caused it to be a FOE and a detriment to our betterjudgment as professional health physicists. We have so strongly emphasized how imponant ALARA is that we even have ALARA engineers and specialists. Standards j are being set at ALARA levels (somqtimes even giving the appearance of quantified EDITOR ,! optimization levels) and those become new reference points for establishing other John Serabian standards. (In retrospect AEC's 10 CFR Part 50 (Appendix I) and EPA's 40 CFR Part 1421 Bayshire lane 190 rnay have set unintended precedents by setting ALARA limits below limits -but Herndon, VA 22070 that is Monday morning quarterbacking). The result of this strong emphasis on ALARA appears to be that of negating the "real" value of maximum exposure limits. ggg ALARA has become the backbone of regulations and even a goal of those who so acicly criticize the regulators. ASSOCIATE EDITOR Perhaps the time has come to reexamine what protection we are seeking by ALARA. Ray Johnson The reason we push ALARA appears to be based on our belief that any radiation 557-8610 exposure has some finite (calculable) risk associated with it. Given that this is a prudent assumption, made in the interest of public heal %, it does not follow that all actions must be ALARA first and foremost. If our numerical limits are established on the basis of some logical criteria (unacceptable risk, natural background levels, or whatever) how i strong should our push for ALARA really be? Do we enhance the possibility ofloss of confidence in our numerical limits if we are continuously putting fonh in even stronger terms a "but" clause that emphasizes ALARA? Can we not just communicate to the radiation worker or the public that the limits provide adequate radiation protection and LOGO CONTEST that we expect good practice to avoid exposures that may be caused by stoppiness? Obviously, if we do not feel comfonable with this approach for existing standards, then the numerical limits may not be the correct ones. However, my guess is that most health Q g*

• g g O '= g physicists view ALAR A in the context of the original intent of ALAP and thus perhaps H.ag. e o n nn, sam s, %. wo.

we should stan the pendulum to swing more to the use of ALARA as a FRIEND that complements rather than negates our numerical limits.

+ k BROOKHAVEN NATIONAL LABONAIURY ({({-[ ASSOCIATED UNIVERSITIES. INC. Upton. Long Island. New York 11973 (51c)282 2004 Nationci Center for Analysis of Energy Systems FTS 666 ' g, D, ((e ;,.3G - March 26, 1984 TE Dr. Terry F. Yosie Director Science Advisory Board (A-101) U.S. Environmental Protection Agency 401 M Street, S.W. ] Washington, D.C. 20460

Dear Dr. Yosie:

In my brief comments at the February 21, 1984 seating of the Science Advisory Board's Subcommittee on Risk Assssment for Radionuclides, I could only touch on a few of the points that should be called to the subcosmitee's attention. At that time, I left with you and members of the subcommites, in addition to a copy of my statement, my review of the inactive and active uranium mill site standards, my analysis of EPA's reply to comments on health risks contained in the Fine.1 Rule and Final Environmental Impact Statement (FEIS) for the active mill sites, and some highlighted excerpts from EPA's " Final Environmental Impact 3tatement for Stsudards for the Control of Byproduct Materials from Uranitsa Ore Processing" (40 CFR 192), Vol. II. One subject that I was unable to address, but which I believe must be considered by 3e subcosamittee, is the role that risk aspessment has played in EPA's setting of radiation protection standards. The prpose of this letter is to address that subject. Therefore, I ask that copies of this letter, which I have provided, be conveyed to the aanbers of the subcouaittee. l l It appears to se that EPA's approach to setting radiacion protection standards is not really based on risk analysis at all, but rather is based solely on an application of the ALARA princiole. This is confirmed by the documentation a supporting EPA's standards. For example, Volume II of the FEIS for active uranium mill sites states: e In response to Comment 10 on page A.1-18, [E]xposures should be kept as low as is reasonably achievable [ emphasis added}. e In respon-= to Coneent 12 on the same page, These organizations [ referring to " national and scientific organizations, and adopted by the NRC"] also require specific sources to maifttain radiation exposure at levels that are as low as reasonably achievable. EPA's standards, in effeet, represenc the lowest reasonably achievable, generally' applicable levels for uranium mill tailings. These standards, therefore, are consistent with the approach of these organizations [eephasis added). c

\\ e In respoese to Comment 6 on page A.3-2, EPA hr.s shown in the EIS and RIA, that the 20 pCi/m2 see limit represents the lowest reasonably achievable long-tem esission rate from tailings, which will result in the lowest reasonably achievable health impact on the general public [ emphasis addedJ. Similarly, in the preamble to its proposed nuclear fuel-cycle standard (40 CFR 190) EPA stated that, due to the lack of scientific information concerning j radiation exposures frou transportation operations, "every effort [should be] l ande to asintain doses to individuals se low as reasonably achievable" [40 Federal Register, 23420.23422: May 29, 1975). The ALARA principle was also used to justify the 25-srea standard for long-lived radionuclides. EPA stated that, due to the "large uncertainties concerning their environmental behavior... prudence dictates that the environmental burden of these materials be minimized to the lowest levels reasonably achievable" [ Federal Register op cit]. That EPA's 40 CFR 190 standards were based on ALARA was unequivocally emphasized by Mr. Glen Sjoblom, Director of EPA's Office of Radiation Programs, in testimony before the House Subcommittee on Procurement and Military Nuclear Systems in BASC No. 97-55, Management of Coianingled Uranium Mill Tailings, August 17-18, 1982, page 355: The thing you are speaking of I believe is the 40 CFR 190 study unich EPA issued a few years ago. There was an evaluation there of nearly all of the facilities that make up the nuclear fuel cucle, the reactor, all the way to fuel reprocessing. There was a cost-benefit analysis made at the time which looked to the derivation of the limits contained within the standard. The Nuclear Regulatory Commission was doing a similar derivation at the time for just the reactor alone, and their standard is comparable to what the EPA j standard is for the fuel-cycle facilities as a whole. So, basically it was derived from the point of view of a cost-benefit analysis. l e** l That was the intent, yes, sir, to get the releases from such facilities to as low as reasonably achievable level, and that is b&sically what the L standard was based on [eaphasis added). It is transparently evident that EPA's proposed standards for airborne radionuclides also are not based on health risk analysis, but rather are based on an application of the ALARA principle. This is also true for the agency's standards for high-level nuclear waste contained in 40 CFR 191. Thus, the driving force behind all of EPA's radiation standards has been and continues to be the_ALARA_ principle. In light of this approach, it is not cAsar to as that health risk assessment has played any significant role in decisions leading to EPA's radiation standards. -

i 16 1. my understanding that radiation protection standards should be health-based limits that protect the public from unnecessary health riska due to radiation exposures. General radiation protection standards should thus be similar to the numerical guides for federal agencies, published by the Federal Radiation Council (FRC) on May 18, 1960. The PRC guides are: 1. For the individual in the population, the basic Guide for annual whole body dose is 0.5 rea. This Guide applies when the individual whole body doses are known. As an operational technique, where the individual whole body doses are not known, a suitable sample of the exposed population should be developed whose protection guide for annual whole body dose will be 0.17 res per capita per year. It is emphasized that this is an i operational technique which should be modified to meet special situations. 2. Considerations of population genetics impose a per capita dose limitation for the gonads of 5 reas in 30 years. The operational mechanism described above for the annual individual whole body dose of 0.5 res is likely in the immediate future to assure that the gonadal exposure Guide (5 rea in 30 years) is not exceeded. 3. These Guides do not differ substantially from certain other recommendations such as those made by the National Committee on Radiation i Protection and Measurements, the National Academy of Sciences, and the International Commission on Radiological Protection. One notes that although tha basic guide for annual whole-body dose is 0.5 rea when " individual whole body doses are known," for operational purposes "when the individual whole body doses are not known," the protection guide is 170 area per capita per year. This is also the guide derived from consideration of population genetics from a per capita dose limitation for the gonads of 5 reus in 30 years. In addition to establishin5 these numerical guides, the FRC siso provided the following: 1. There should not be any man-made radiation exposure without the expectation of benefit resulting from such exposure. Activities resulting in man-made radiation a2posure should be authorized for useful applications provided in recommendations set forth herein are followed. 2. The term " Radiation Protection Guide" be adopted for Federal use. This term is defined as the radiation dose which should not be exceeded without careful consideration of the reasons for doing so; every effort should be made to encourage the usintenance of radiation-doses as far below this guide as practicable. [enphasis added] s j l RFA's use of ALARA for setting generally applicable radiation protection i standards is wrong. ALARA was never intended to be the basis for setting radiation protection standards. Radiation protection standards should be based on sound analysis and consideration of radiation health risks, and represent the i lower boundaries of unacceptable levels of health risks. The principle of ALARA J 4 l

should then be used at individual sites and operations undar particular practices and operations to keep all doses as low as reasonably achievable. ALARA principle includes consideration of numerous factors that will vary i In fact, the, considerably depending upon a specific context. \\ l l EPA's approach to radiation protection standards aisperceives the intent of FRC guidance. As I have noted above, FRC establishes numerical guides based on health risk analysis and directs the implementation of those guides on an ALARA. basis. EPA misses this distinction. l is also evident in EPA's characterization of NRC's Appendix I.The fail'are to apprecia / m In the late 1960's and early 1970's, Gofman and Templin bombarded the public and the nuclear industry with estimates of the number of cancers that would be induced annually in the U.S. population if all members of the population received the 170 area of the FRC guide. Their estimate ranged from 10,000 to 120,000 cancers annually. Although at the time, scientific scrutiny of their these estimates was the reality that the radiation dose receiv l i on the post-boundary of a reactor was approximately 5 area a year. Since reactors sre point sources irradiated the U.S. there is no way in which they could have uniformly guide. population to the hypothetical 170 area figuce of the FRC Nevertheless, to dispel the confusion and alarm generated by such estimates, several scientists including myself urged that the AEC specify design and operating requirements for nuclear power reactors that would conform to existing reality. We believed such design and operation requirements would be consistent with the FRC's recommendations that "every effort should be made to encourage the maintenance of radiation doses as far_ below this gride as practicable." The AEC then initiated extensive hearings oa AppenaLx 1 to 10 urn Paf E 55 'to provida numerical guides for design objectives.and technical specification requirements for limiting conditions for operation for light-water-cooled nuclear power reactors." The record developed during this rulemaking supported the need to define "as low as practicable." In adopting i Appendix I, the NRC states: l It should be emphasised that the Appendix I guides se here adopted by the Commission are not radiation protection standards. The numerical guides of Appendix I which we announce today are a quantitative expression of the meaning of the requirement that radioactive material in effluents released to unrestricted areas from light-water-cooled nuclear power reactors be kept "as low as practicable." The Commission's radiation protection standards, which are based on recommendations of the Federal Radiation Council (FRC) as approved by the President. are contained in 10 CFR Part 20, " Standards for Protection Against Radiation," and reasin unchanged by this Commission decision. in the case of parallel recosamendations of the National Council on As Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP), these FRC standards which have been previously adopted give appropriate consideration to the overall requirements of health protection and the beneficial use of radiation and -

e atomic energy. The Commission believes that the record clearly indicates that any biological effects that might occur at the low levels of these standards have such low probability of occurrence that they would escape l detection by present-day methods of observation and measurement. } The Commission fully subscribes to the general principle that, within established radiation protection guides, radiation exposures to the public should be kept "as low as practicable." This precept has been a central , one in the field of radiation protection for many years. The term "as low jas practicable" is defined in the Commission's regulations (10 CFR to mean "as low as is practicably achievable taking into l'50.34a(s)) account the state of technology, and the economics of improvements in relation to the benefits to the public health and safety and in relation to (theutilizationofatomicenergyinthepublicinterest." We note that during the pendency of this rulemaking the International Cosmaission on Radiological Protection, in ICRP Publication No. 22, has replaced the phrase "as low as practicable" with "as low as is reasonably achievable" in its recommendation on dose limitation. Its recomendation has also been expanded to identify two specific considerations-economic j and social-that are to be taken into account in determining a level of exposure that may be considered "as low as is reasonably achievable." Other \\{ considerations, such as ethical ones, are not excluded by this wording and } t may indeed be cor.sidered to be included by the adjective " social". The t ICRP has clearly stated that the changed terminology does not reflect a change in the objectives of does limitation, but rather a choice of language which "more closely describet its intentions" [ emphasis added). j Although it is clear that the guides in NRC's Appendix I to 10 CFR 50 are f radiation procaction standards but are guides for " design objectives and ji not limiting conditions," for operations, they were misperceived by others, includingfor E I ( EPA, as radiation standards. It is claar that the primary basis ) standards governing the nuclear fuel cycle, 40 CFR 190, was its desire not to !) i ( appear to be more lenient in the regulation of radiation than the NRC. The -! maxima annual whole body dose of 25 aren had no relation to health risk analysis l but was based empirically on uppin6 the guides set in 10 CPR Part 50 Appendix I f which covered reactors only to a roughly comparable level to cover the entire i nuclear fuel cycle. This le indicated by Mr. Sjoblon's teatimony referred to ) . above, when he stated: The Nuclear Regulatory Commission was doing a similar derivation at the l time for just the reactor alone, and [KRC'sI standard is comparable to what ( the EPA standard is for the fuel-cycle facilities as a whole [ emphasis l j added). I appreciate that Mr. Ruckelshaus has emphasized in his memorandum on the SAB teview of risk estimates due to radionuclides that " risk assessment and risk j annagement are distinct aspects of regulation development." However, I believe it behooves the Subcommittee on Risk Assessment for Radionuclides not only to detsemine whether EPA's risk assessment methodology is " based on sound scientific i infounation and principles," but also to determine whether risk assessment has 1 l )

a been properly used by EPA in setting generally appli standards, and, indeed whether EPA used ritk assessment cable radiation protection standards. at all 40 shtting such Sincerely, { b L.D. Hamilton, M.D., Ph.D. Head, Biomedical and Environmental Assessment Division LDH:jg Dr. Roger McClellan ec: l l 1 i l i l l l { i i m

\\ O R PE - s1 -s e y 33,,, i exity for use Of the large number of French contributions at the seminar,one of 1 al:ng with particular interest was a study of the enWlunmental behaviour of O'Cs on cf subsequent to an accidental release of 6 fTw tens of curies of the nuclide j artm t:r of a i at the Cap de La Hague reprocessing plant in 1981. Doses to the public from i t is s:ldom the release were negligible but the data collected in the time since the ibutigns htve occident provide a useful addition to the fairly small data base of time. ' param:t:r dependent transfer parameters. Measurements of soil migration of actual caesium. and its transfer into plants and milk were reported. and the values th31occtirn of of transfer factors derived from the data were found to agree fa:Ily well with l values quoted in standard publications on the subject. is cft:n in the last period of the meeting the session Chairmen summarised the it:r vilu:s and papers presented in their sessions. They commented. sometimes criticially, redicted Cose 6 on the presentations and gave views on possible areas for future work. The iths inh:r:nt proceedings of the meeting will be published by lAEA and willinclude these ded far use session summaries, inen it is Aslowasreasonably m re sita ssumpiens is th] principle = achievable m.d., snderestimate Report on the 2nc' European Scientific Seminar on Radiation Protection Optimiantion, orpeniard by the CEC, Luxembourg,8-9 November 1983. ping countries >t al**v= J R Croft

• and A B Fleishman

, ora i thos) NATIONAL RADIOLOGICAL PROTECTION BOARD, LEEDS

• AND CHILTON snt 6

dealt m: inly svidenc3 cfihe se assessments ate ta local The first CEC scientific seminar on optimisation,in 1979, was primarily l s the mott concerned with possible methodologies for quantification of the ALARA i i up12 fiv3 requirement and their associated difficulties of application. Since then t odiff rences there have been advances both in the refinement and extent of the methodo. ich as soil pH logies available and in their degree of practical implementation. The former d lysimetr was amply illustrated in the recent ICRP Publication 37. " Cost Benefit which cannot Analysis in the Optimisation of Radiation Protection".The purpose of this r m:y show seminar was to provide a forum for an exchange of experiences and views on , ifferences is aspects of practical implementation.To this end the two day meeting attracted use sturies in some 70 participants from 14 countries (including the 10 member states of , sfined cnd the European Community) and from 5 international organisations. A total of C partcf the 20 papers were presented, including 16 case studies, and this review article ' UR),cnd are attempts to summarise their highlights. N -i s' i [7 / "' eL cot.' ?f~,f gr~

Scientific and regulatory aspects of optimisation The first session consisted of axtended presentations by three invited speakers, and was opened by Gonzales (IAEA) who reviewed the present status and future outlook for the optimisation requirement within the ICRP system of x dose limitation. While leavmg the door firmly open for other decision. aiding techniques, this, in line with other papers, was mainly related to the use of cost benefit analysis. More specifically, as Chairman of the former ICRP Task GrW6n 6ptirdisation, much of his presentation was directed towards defining and clarifying the terminology and concepts introduced in ICRP Publicatien 37. This was to prove helpful in subsequently identifying the inconsistent use of terms adopted by some participants; a feature which often hinders constructive discussions on optimisation. Of particular relevance in this context was the ICRP formulation of the cost of radiation induced detriment and here it is perhaps worth digressing, in the early development of the subject it was assumed that detriment cost was simply proportional to the collective dose commitment, with the propor. tionality constant, a (alpha), referred to as the ' cost of the man rem *, it soon became clear that many people considered other parameters of the dose distribution of importance, especially the individual dose levels making up the collective dose, whether the doses were to workers or the general public, and the point in time at which doses would be de!ivered. The recent ICRP formulation consists,therefore,of the sum of two components: an ' alpha term','olely related to the cost of statistical health detriment based on collective dose considerations, and a ' beta term *, which is a function of individual dose levels and allows dose distribution characteristics to be addressed within the cost benefit framework. Bischof (Goettingen Univers!ty, F RG) examined the problem of incorporating the ICRP principles of justification and optimisation into legislation in a way that was enforceable, but did not place unnecessary constraints on users. He concluded that it would not be opportune to introduce ' concrete clauses',

and that the regulators should content themselves with more flexible ' general

~ L 'g ' clauses *, leaving unresolved matters to the courts. Cunningham (NRC, USA) then described the optimisation policies and practicas being pursued in the l USA w thin.the three stages of the NRC regulatory system. la the

• rule-i i making process', federal regulatory agencies are required to support the i

I establishment of significant regulations by some form of cost benefit analysis. i ' For a category of pisctice this provides only a crude estimate of the optimum i radiation protection standard. This is then refined for individual facilities in .is. reviewing applications for licences. Here the optimisation process was stated y y as being largely one of negotiation *,although written guidance is provided for regulatory staff and the applicant to avoid this degenerating into a mere k i: contest of wills. Finally,in the optimisation of operating procedures, a generalisad ALARA requirement is in the process of being implemented.This requires licensees to establish a formal administrative programme for the optimisation of occupational exposure, containing specified elements. To 28 l l

e 0 t i further cover types of practices where operations are fairly standardised, og,in nuclear medicine, 'model'optimisation programmes have also been developed which incorporate trigger levets of individual dose for~internat f investigations, td speakers, status and e sv a m of I Casestudies ," [ f As might be expected, the majority of case studies related to the nuclear mdustry; applying some form of cost benefit analysis to design featuras or ser ICRP J operational procedures influencmg occupational and/or public exposures.

td taards primarily from reactors and reprocessing plants, Other case studies meluded d in ICRP the management of mill tailings, redon in mines,transoort of radioactive dying W material, nuclear medicine and brachytherapy, The variety and detail inherent re which in these papers was such that it would not be possible to summarise each one.

I However, a number of general problems,thornes and conclusions emerged n cf the cost that deserve a mention, I " The procedure for evaluating protection costs, accounting for both capital investment and running costs, was an area of reasonable consensus with only " P'IPO slight di!ferences concerning the use of discounting technioues. It was, how. ' "

• II 800" ever, noted that in some situations protection and production costs could be W dow interdependent,where the introduction of protective sneasures affected mawg up

'"I P" general productivity, in such cases, some estimate of this indirect impact on scent ICU ' productivity would also need to be taken into account. This was exemplified in Fleishman's (NRP81 paper on brachytherapy where the introduction of new practices and equipment reduced both doses and hospital bed occupancy cn ction of l times - and savings from the letter were deducted from direct protection costs.

s12 be The availability of suitable data for quantitative optimisation studies was incorporating clearly a problem area, and most prospective studies employed some form of ati n in a way predictive modelling to estimate the likely changes in dose distributions s on users. He arising from specific protective measures. These difficulties may have influ-7te clauses',

enced the fact that over half of the case studies were retrospective reviews of emibl> ' general past decisions, providingas wide range of implied values of unit collective (NRC, USA) dose from about $300 to $500,000per man Sv. In the discussion of the papen, reued in the it became apparent that there were potential misconceptions of the signifi. the ' rule. 4 cance of such valuations, in particular, there was a tendency to use the phrase > port the 'the alpha value' for 'the value of unit collective dose', whereas in many cases >enefit analysis, involving high individual exposures, allowance had also been made to reflect >f the optimum components of the beta term, This affected the conclusions of some papers, and suggested that future studies should be more explicit and careful in refer-4 i al facilities in ess was stated ring to ' values of unit collective dose'. Having clarified the terminology there eis pr;;vided were a number of calls for an internationally accepted value of alpha, to act g int 3 a mere I as a lower limit for costing detriment arising across national boundaries as a toures, a result of regional or global dispersion of radioactive effluents.Jammet (CEA, ,lemented. This France) indicated that an lAEA Advisory Group would shortly be considering me for the tftis matter, ements. To j The only comprehensive system for costing detriment incorporating both i alpha and beta terms is that developed in the UK. This was used in a number i 29

of prospective studies, such as that by Pepper (CEGB) which described the i ;, .L. application of the ALAR A principle in the design of the pro dose in addition to cost benefit analysis. Such design targets w Union, F RG). Both concluded that cost benefit techniques ha was challenged by Webb (NRPB) who noted that if design targets were initially set below optimum levels of exposure,then quantitative ALARA studies cannot reveal anything beyond the fact that the initial targets were too low. Several papers raised the possibility of bounding assessments of collective dose commitment for resource allocation purposes, by either establishing de minimis dose levels (below which exposures are of no concern for decision making), truncating such calculations in time, or discounting the costs of future detriment. While no consensus emerged,it tion to probabilistic events remained unresolved. This was touched upon by Richardson (EPA, USA) and Hubert (CEPN France),and was reported to be "a matter of considerable discussion at present in a number of international forums", I Conduding session This session contained an extensive review paper by Webb (NRPB) and l Lochard (CEPN. Francel which examined how successfull I papers, they highlighted a number of methodological problems that had arisen in the use of the cost benefit analysis, and proposed that effort should ( be devoted to investigating other decision siding framew noting that a number of people in a number of countries are undertauing 7 quantitative optimisation studies and are finding these g e ( Many of the points raised in this review paper were picke degree of acceptance of optimisation as an input to the regulatory process ARA the further development of the ' beta term' to address tradeoffs in AL decisions between, say, individual and collective dose,or public and occu-pational exposure, and 'he presentation of these ideas t 1 ( extent there were opposing views between those developing new concepts to address the complexity of ALAR A decisions in the rea tion. But this reflected more a question of emphasis than any matters of principle and,for us, demonstrated the need for a dialogue between these two groups,if the theoretical advantages of decision aiding techniques are l [

M tM to be realised through practical implementation, in this respect the meeting W R at proved highly successful, and the proceedings, which are to be published by the CEC in due course, should provide a valuable contribution to the litera-ture on this developing subject in radiation protection. twerk lowandmedium e,oin, '?:a adioactivewastedisposal e, Rep 'C1,'vt. on the CEC Seminor on Testing, Evaluation and Shallo w Land Burial shin 9 of Lo and Medium Radioactive Waste Forms, Geel, Belgium, 28-29 Septem 1983. C"', C R He ming o timise-NATIONAL R pon by IOLOGICAL PROTECTION BOARD, CHILTON

ed 13 be iati:nal This two4ay seminar was orga ' sed by the Commission of the European Communities (CEC) to present t id 1981-82 as part of the Communitiresults of research work carried out during

• research programme into radioactive RA weste management. The majority of t papers dealt with the testing and "I"*'

evaluation of waste forms for low-and i sad while the final two papers covered some asermediate level radioactive wastes. s of the work done on the t should shallow land burial of these wastes. The semi r was attended by over 60 multi-people, including representatives from nine of member states of the EC,

ouraging, as well as delegates from Finland, Sweden, Switz and, the USA, the Nuclear Energy Agency and the international Atomic Ener Agency.

The seminar opened with an introductory presentatio Krischer of the n e;,;,,,, CEC, in which he outlined the structure of the program of research into 'inal weste characterisation and summarised its objectives. The ramme involves rethe the selection and development of appropriate methods of tes g potential weste forms, and the investigation of the behaviour of the west ocess* orms under . ARA disposal conditions. A wide range of waste forms has been investi ed and twelve laboratories throughout the EC have been involved in the wo i Subsequent papers presented the results of this research programme. i, ost interest in the characterisation of the waste forms is the rate at which red. nuclides immobilised within the waste form may be released into water. Th majority of the tests described were, therefore, concerned with the measure-f ment of the leach rates of radionuclides from the waste form and the way these properties may change under disposal conditions. In particular, the influence of radiation, water uptake, and microbiological activity has been \\ studied. ,,g 31 y.

- - - - ~ - .-_--.,v y h e 9 ISSN 0308-4272 NoS7 Marc,~9pL / RADIOLOdICAL PROTECTION BULLETIN / l \\aiono Rac o.ocica roecion 3$ arc 3 1/ C,iton;[ic'ca,Oxon i i l

= [g ~ L z- - -... sm~ 2.r . 3_ ._ gm ~ ~ 34 s 684 LETTERS TO THE EDITORS ~ st'ack in the "on" position (New York Times, 3 of Health Physic: has taken us with considerable decides hc No' ember 1980, p. 2). While the situation is tp6 surprise. It indicates that there may be a wide-reasonable invo ed and lengthy to describe here, the wyter spread misunderstanding of the meaning of the i money per level. rm was ignored for 2 weeks, during vthich ALARA principle (to keep all radiation doses as dose redut time 10g000 gal of salt water from the fan ep'olers low as reasonably achievable, ICRP73 ICRP77). even at ver cverflow the sump into the cavity belpw the The recommendation to keep all doses as low as by definitic reactor. though there may have begn some reasonably achievable is a recommendation to The only mitigating chnical factors, ignoring an' alarm-optimize radiation protection. This means that, in l! seem to me even one sulgected of malfunction-is'hardly in-each situation, there is a level of dose below which level for th dicative of conscientbus safety-first bfhavior. it would not be reasonable to go because the cost involved ir. Regretat,1y, ty above incidents ar but part of a con nuing series of ev/n. not unique, of further dose reduction would not be justified by One would { lesser magnitude (,that indicate to ts,largely of the additional eliminated detriment. That level of mization ef j safety is, for whargver reasons {Jne at least that dose, however, is not a de minimis level below j tive dose is subordinate to which there is no need of concern, nor can it be i sidering it 4 cperations, and that the attitud'e towards safety determined once and for all for general ap-reduction. I may be less than sathfactory.i'n some areas and plication. It is the outcome of an optimization type of de among some people \\espons,ible for operating assessment which involves marginal cost-benefit dose and nc nuclear power plants. I weTate to reap the full considerations. One obie benefits of nuc! car powe to regain the public There are cases where the concept of a de dose redue trust we have lost, some nges in our methods minimis Icvel may be helpful. For example, presupposes and attitudes, at least U.S. depending upon the assumed dose-response rela-as in the ca ( , appear to be warranted.

• t tionship, a dose can be indicated below which the ship. This is probability of cancer and hereditary harm to the avoid small f

Ro[41.D L. KATHREN exposed individual and his/her progeny is in-implied fad d Note added in proo/. Since the or\\ signiacant in comparison with the total probability However, at igi this reply, the NRC has acted uponal drafting of of such late effects from other causes. Such low small doses ; g the Niagara doses should be of no concern to the exposed without any Mehawk case reducing the fine fron $225,000 to individual. is the possibi $215,000 and whhdrawing its restriction (gr3ainst the Such low doses, however, may still be of some small doses I two individual' employees of the compagy, noting concern to the radiation protection authorities, for to an undes that " strqng enforcement actions were neces-a number of reasons. They might imply a trend i might wellju sary " anf that the alleged false stateg;ent in towards higher future exposures from accumulat l doses. question rssulted from poor managements [{ather ing long-lived environmental contamination from than a yillful attempt at deception (NRC tews continaed practices or from the combined effect of Releases 7(10): 2,24 March 1981). However the a multitude of sources. In the past, sulphur NationalInst recent* incidents in Japan te deliberate hidin(gof releases from individual chimneys caused little Box 6024 activityimproperly released to the environment at,a. concern and were implicitly considered to be S-104 01 Stoc poyer reactor provide shocking support of thg below de minimis levels of release (ahhough such Sweden t)esis in the reply, and point out that the'problernt levels might not have been speci6ed). Yet we ,may not be restricted to the U.S.

• know that the Anal result of many such sources Comision No, brought about an air pollution which is quite Avenida dell R.L.K.

offensive in many countries. 1429 Buenos, f"" The ALARA principle also invites source-I Argentina y relat.d as distinguished from individual related I J assessments.In these assessments one may meet the paradox that a practice may not be justiaed even if l e H84 Hede hw saw,, l Pers==. rm ud. me a pe =, vu. w come.cr. es4 6ss. im allindividuals receive negligible doses. This can be r i en.=4 = m. u.s* illustrated by an analogy with money: It would not be justified for all Americans to buy the president a regular television set for 2 million dollars even ALARA Ddnes hs own limit though the individual expense of I cent may be ICRP73 Inter considered entirely negligible to each individual. gical Protec (Recticed 4 November 1980) In the source related assessment there is there-(Oxford: Per fore neither justification nor need for a de minimis ICRP77 Inter Dear Sirs level below which one should not go in dose I gical Protec THE LETTER from Prof. Rossiin the August issue reduction. The optimization procedure in itself (Oxford: Per % as-. C

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.j. --- LETTERS TO THE EDITORS 685 nsiderable (' decides how far it is reasonable to go. It is not ,g',{ aon-ar w m as.c_se m o e e a wide-f reasonable to pay more than a certain amount of C 1W1 Heerm P%,,es socien f ng cf the money per unit of co!!cetive dose reduction, but if g d:ses as dose reduction can be schieved at a lesser cost rn. e m u n ICRP77). even at very low individual doses, the reduction is, l as low as by definition, reasonable. Reply to Drs. Beninson and Lindell l dation to The only further boundary condition that would l is that, in seem to meet Prof. Rossi's request of a de minimis ow which level for the optimization results would be the cost Receired 11 February 1981) involved in the optimization procedure as such. l r the c st istified by One would have tetter not bother with any opti-

Dear Sirs:

l t lev 11 et mization effort if the potential reduction in collec. THE INTERPRETAT1oN of ALARA presented by f t el below tive dose is so small that the cost of even con-Drs. Beninson and Lindell is a good deal more can it be sidering it would put the balance against the sophisticated than that by U.S. government i ieral rp-reduction. It should be noted, however, that this agencies,

which, in the publications 3 / A,t

! imizatio2 type of de minimis level relates to the collectice I have seen, merely demand dose reductions to latter !,87 a' st-benefit dose and not to the individual deses. unspecified low levels rather than One objection against ALARA efforts is that quantitative optimization. The I cf a de dose reduction at very low individual doses could in fact indicate that some current practice

example, presupposes a biological effect at these doses, e.g.

should be alerted in ways to increase the radiation i nse rela-as in the case of a linear dose-response relation-exposure of individuals. The letter by Drs. Benin- <hich the ship. This is fully true only if the only reason to son and Lindell thus offers an alternative resolu-t avoid small doses were the wish to avoid the tion rather than an endorsement of the conditions 1 n 13 the , implied radiation detriment from these doses. which I criticized. l y b in- ! obability However, an additional reason to take account of Here can be little doubt that the ICRP position l uch low small doses and therefore also of collective doses is based on scrupulous reasoning and that it can be exposed without any de minimis cut-off of individual dose defended against various objections. Rus, while, is the possibility that.the combined effect of many the basic assumption of proportionality between ' 7,,W ,/*4 of some small doses from a multitude of sources willlead risk and dose may be dubious for carcinogenesis it ities, for to an undesirable situation in the future. This is very likely holds for genetic effects. Concern over

• a trend might well justify a price on dispensable collective the collective impact of small doses received by

umulat-

doses, many persons may be justified (perhers more dras-

)n from tically than in the T.V. simile) by the consideration sfhet of Bo LINDEt.L that exposure of 10 people to a cancer risk of 10"is ( sulphur NationalInstitute of Radiation Protection very unlikely to cause any cancer while exposure of ' rd little Box 6024 100,000 people to the same risk is almost certain to to be S-104 01 Stockholm result in several cancer cases. Sweden Any decisions regarding radiation safety must I l gh such l Yct we DAN BENINSON result from a balancing, concio.as or not, of I s:urces Comision Nacionalde Energia Atomica various considerations. Although this process will s quite Arenida del Libertador 8250 probably never be perfect the value of the ICRP 1429 Buenos Aires optimization procedure must nevertheless be sr.ac. Argentina questioned. As indicated in the recent report of the rchied BEIR 111 Committee of the U.S. National netthe Academy of Sciences,there is disagreement on the ev22 if magnitude of the risks of radiation carcinogenesis ca: be that spans up to two orders of magnitude, even for l uld not doses that are large relative to those involved in population exposures. Another grave uncertainty ident a References arises from the need, inherent in the ICRP ap-i sve2 say be ICRP73 International Commission on Radiolo-proach, to assign monetary value to human vidual. gical Protection,1973, ICRP Publication 22 suffering and death. Thus the seemingly logical there-(Oxford: Pergamon Press). process must be based on a selection of values ICRP77 International Commission on Radiolo-that is perhaps even more capricious than that of a rizimis i dose gical Protection,1977, ICRP Publication 26 de minimis dose rate that is, say,30% of that due itself (Oxford: Pergamon Press). to natural background. 1 i l r . r -- f

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g== ^ ^ ' ' ' - l l I 686 LETTERS TO ifE EDITORS 1 do not believe that optimization can be mean-radioactive decay constant (A. = 0.00758th L = of su: ingfully performed in the forseeable future and it 13.7/hr, A. = 1.55/hr and Ac = 2.lllhr), an ,and article would seem that the pragmatic acceptance of the k are dimensional conversion factors (3 9 x 10-* The de minimis concept is a more eNective solution. It o and 2.13 x 10-', respectively). far thi certainly is much simpler and therefore more This equation predicts that, whe ventihtion enviro likely to be implemented. However, the principle of rate is reduced from 0.75 to 0.30/hr,a' factor of 2.5. Never c,ptimization is sound and consideration of its. the working Icvel would increase /by a factor of due tc elements (costs, detriment, number of persons 1 more than 3, whereas the exppcted increase in 'LiF : exposed, etc.) should be part of responsible plan i radon concentration would be/only 2.5. Greater dosim-ning and design of radiation sources at least when I changes in ventilation rate siteuld produce a larger while discrence (e.g., by reducins* ventilation rate from the su it is not practical to achieve de minimis conditions. l 1.5 to 0.3thr, a factor of 5, the working level field e HARAt.D H. Rossi should increase by a factor of more than 9). Use of dose i Radiological Research Laboratory the procedure descriped in this article (Co80), 'additic Columbia University , therefor =, would cause one to underestimate depen. New York, NY l energy-conservatiochelated cancer fatalities. neutro I of this / STEPHEN N. RuoNicK unkno ~ Schoolof Publj$Nealth The non-se?sisvenoses-osse 1mo Marcard Unin;ersity detects e lut He sa,ts s", " 665 Huntington Aca. called Boston, MA 02115 sonnel u.w.n en, v.s. a. w coc.n.t,..as. im: threshi ri e = m u.s.A. / meter / Reference IMeV Co8 " Cohen B. L 1980, " Health Effects of ponse on From Insulation of Buildings". Health to-rem Comment on " Health Effects of Radon from hys.39.937. tracksi Insulation of BalWings" by B L. Cohen bonate [ weight (Receload 12 February 1981) strengt (So74;

Dear Sirs:

an.estsism - ther im IN A RECENT Nealth Physics article (Co80),[k-45% K e increase in radon concentration, rather than wor u inn n,,ns vet a. w cocen.6,,. as.4se. inn when t ing level, was used to estimate the increase id fatal en d is b U1A. 40 g C Iung cancers attributab!c to energy consp'rvation ECE-p by insulating buildings. Although radopfconcen-upper trons trations in residences would be, expected to be The Review of Recent Developments la been. inversely proportional to ventilation. rate as was Personnes Neutron Dosimeters tracks / suggested (Co80), the working level doors would solutio not.The relationship between wor 'ng level and (Received 20 February 1981; accepted 2 March strengt ventilation rate can be approxiqfated by a material 1981) while balance for radon progeny irus well. mixed room. efficier When incoming air is free of radon or its progeny

Dear Sirs:

tageou and plate.out of the progeny is unimportant, the IN A RECENT article by Griffith et al. (Gr79), a major following equation is obtained: comprehensive review of different types of neu-above [ tron personnel dosimeters was given with ments emphasis on the albedo type neutron personnel develo ").k' + A s + V 1 + Ac + V.dosimeters and solid state nuclear track personnel The WL =(An + V)(AA+ dosimeters. Some advantages and disadvantages diglycc S l where WL is potgritial a-energy concentration of of such dosimeters were also reviewed. Since that cellulo l short. lived rados progeny in units of working time, further developments have been advanced heavy j levels S is radon exhalation rate per room volume which have solved some of the stated problems. nology in Bql(hr mi) V is ventilation rate in 1/hr, A is a Therefore,it is my intention to give a brief review link ur >f -m ~,, a :~.L.7.. T M,". c;.M;:: ;. - - - g,,, -e N 8 T. m5, ai. 7 =u .M e ,_=m ,c._,.,:.::..f;;n;.~.3w;,.,; y.. -ew-a., 7.s.g. n j 4 - Y

\\N .r. c g g38 < ~. ~ g' Q LETTERS TO THE EDITOR / a(ay accumulate enough additional exposure to It is not; it represents a real and significant cogipletely swamp any small diferences. We have diference of objectives, alshdisregarded the occasional very large solar Predictably, the rest of the letter is logically injections such as that on 23 February 1956 when impeccable, but it rests on the basic aim of reduc-l sea level radiadon rose by a factor of seven, or ing the objective harm to the minimum. This aim is similar events on 12 and 15 November,1960 when also impeccable in logic and ethics. I suggest, increases of factors of about 2 and 1.5 at sea level however, that a cursory examination of human were observed. At higher elevations, these solar behaviour shows that it is not the aim of society. It events must have been spectacular indeed. appears to me that the views of society as dis-played by its elected representatives and by at SERGE A. KORFF least some of its self-appointed spokesmen, do not j Physics Department suggest that society wants its resources applied to New York University the reduction of risks that are already very small, New York, NY 10003 even if they afect very many people. There are exceptions to this, such as carcinogenic food ad-References ditives, and continued emphasis on the existence Ad64 Adams J. A. and Lowder W. M. (Editors), of very small but widespread radiation doses may 1964, The Natural Radiation Environment well induce a corresponding phobia (already ap-(Chicago: University of Chicago Press). parent in some respects). B159 Blatz H. (Editor),1959, Radiation Hygiene At the practical level, neither ALARA nor the Handbook (New York: McGraw-Hill). selection of de minimis values is easy. I think both Bo36 Bowen L S., Millikan R. A., Korf S. A. concepts are necessary and that we should see and Neher H. V.,1%3, Phys. Rev. 50,579. them as equally legitimate. Their relevance Bo38 Bowen I. S., Millikan R. A. and Neher H. depends on our aims. V.,1938, Phys. Rev. 53, 855. If the aim is to minimise the objective harm,, Lindell and Beninson have an unassailable posi-tion. If the aim is to use society's resources in th Ga49 Gagnes, Jenkins and VanAllen J.,1949, " Cosmic Ray Measurements Carried by Rockets to 200 km", Phys. Rec. 77, 57. way that society appears to prefer, the de minimis Li35 Libby W. F.,1955, Science H2,57-58. concept is appropriate. It was, after all, invented Me56 Meyer P., Parker E. N. and Simpson J. A., to avoid society's squandering its efforts on seek-1956," Solar Cosmic Rays of February,1956 and ing legal solutions to problems of no significance. ; Their Propagation Through Interplanetary It is to the credit of lawyers that they invented it Space", Phys. Rev. 104(3), 768-783. despite the obvious financial disincentive to their profession. Perhaps there is a moral here for the radiation protection profession. een mss 2minemasos.ne. H. J. DUNSTER en'etH*** %==s==9 Health and Safety Executive rersamen Press Ltd. mean Nsere Vol 43. No. 3 (sepiomberk p. 43a.1952 b ngon pr d is e. USA. ALARA or de minimais? References Li81 Lindell B. and Beninson D.,1981,"ALARA (Received 16 November 1981) defines its own limit", Health Phys. 41,684. Ro80 Rossi H. H.,1980, "What are the limits of ALARA7", Health Phys. 39,370.

Dear Sir:

THE 1.ETTER from Lindell and Beninson (LiSI) commenting on Rossi's suggestion that the tech-niques of ALARA should be replaced by, or at least cut of at, a de minimis level of individual dose (Ro80) deserves further comment. The authors' opening protestations of surprise were i disingenuous and presumably intended to suggest that Rossi's view was merely a misunderstanding. l

pg 198C & b i) y/' gg w The title of this paper is "An integrated approach to the limitation of risk",,, An tegrated a prOach tO the In ie some, esp-is iiis a por ihai shoeid he w,.ttee afier the eed ef ihis ~ seminar.1 had to write it before the seminar started but what I plan to do is .g g l.ImitOt. ion Of rO 10t.IOR RISK tor to present the paper in the light of the other papers and discussions we have had already this week, m the hope that it will sharpen arsd clarify s me f the points discussed. eGr MWer We have talked about dose and risk. l trust we are now all clear that u whatever we use as a con *rol parameter because it is easier to measure, whether it is darkening of a photographic film or activity concentration in G A M Webb seaweed. whai we a,e acimg on is ine iimiiaiion of tisk. we coni,oiii by NATIONAL RADIOLOGICAL PROTECTION BOARD, CHILTON reducing the probability of the incident leadmg to exposure or by reducing

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This paperis an edoted version of an oralpresentation by G A M Webb at po u the NEA Seminar on Interface Questions in Nuclear Health and Safety, The n. k for individuals can. its simplest form he expressed as the s m P;ns, Aprd 1985. probability of incurring a health effect, for populations as a frequency or j The underlying ides of the seminar was to encourage discussion and expected number of health effects. debate between representatives of the three NEA standing committees on in the conteut of this interiace meeting,i want to concentrate os6 two the Safety of NuclearInstallations, Radioactive Waste Management and particular aspects expressed in ICRP terminology as individual limits and Rrdsation Protection and Public Health. Invited speakers introduced topics optimisation al protection (ALARAl, and to see how these concepts apply whsch hadimphcations in allthree areas, but where often there was a in the safety and waste management fields. datistence in philosophy apphed or being developed. Thus, reactor safety and the use ofprobabihstic risk assessment was compared with risk sn1 lysis being undertaken for geologic waste reposotories, and 'de l0b..bUOl l.lmll$ ~ lVl minimis'cnteria for waste disposalwere tested for development of 'de minimis probabihties ' for reactor accidents. As John Dunster said on the first day, one role of ICRP has been to provide l' the simple numerical guides that replac2 thought. ln the dose limets for About 100 senior representatives of regulatory andadvisory bodies twtsne operatsons we have such guides. Their oniy real purpose es to participated, representing North America, Europe,.lapan and Australia. divide the tota lly unacceptable from the possibly eccoutable. They were What emerged was that there exists a large divide between thinking in set, remember, on the basis of a comparison wish.3 centty acceptable, b safety and thanking in radsation protectron and waste management. The or at least not unacceptable, risks from other causes. voew was often expressedthat safety measures were overriding, For much of waste management the dose limits a<e the onty limits regardless of cost in money or occupational exposures. Professor Birkhofer (FRG), leader of the German Reactor Risk Assessment Study, required. Even for solid waste disposal an emportant part of thn anatysis is and Harold Denton, Director of the USNRC Otfice of Nuclear Reactor of the ' normal' scenario that gives doses for comparison (bearing in rmnd Regulation, took the line that inspection and maintenance exposures their uncertainty l with the dose limits. cannot be traded ollagainst possible public exposure and anyway the Fot other events. called probabilistic,lt is necessary to revers to risk limits. resulting occupationalrisks are trivial. Clearly they see it as so important As we have heard, the detir.ition of risk is nos entirely straightforward, but to protect the public (but not necessarily the plant} that the consequences the following definition seems to cover reasonably well both the I to workers are to beignored. stochastic and non-stochastic region provided the words are hberally 5"P'*'*A' The development of acceptable risk criteria and the methods by which decision makers can choose between different sorts of risk, is clearly \\ going to take some time. There is the need to balance large consequences albert with vanishingly smallprobabihties with greater certainty of small Probabihty that Conditional consequences perhaps at long times in the future. Cost benefit analysis Risk = anindividual receives a probability of harm snd optimisation do not help m these trade-off questions and new

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I'**'h*'d*** techniques may be required. G A M Webb tried to bring some of theissues together and the text of his presentation is given here. R H CLARKE y

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A y 39. f g 9 40./o7 p. n 0237 Toxic error Not all the murk is in the air and waer; some is in bo'oks, magazines, newspapers and broadcasts known t man," capable of causing 5 America is being poisoned by By Elisabeth M. Whelan inacant death in minute amounts, che,me=k ard r=Ame mey. responsible for cencer and birth defects in e Our country's health hu never been laboram y ammah; and threacemag the worse and is threacemag to decenorace Like most other Amencans,I get a good deal of my informacion about lie and ! ealth a midents c.f Love Canal even further. health and the eenro unent from in upscate New York; Tunes Beach, a Big business is mpoesh for the kaalra magannes, newspapers and the Miwouri; Newark, NewJersey; MwihaA, . - - - - tal agtmm and cares noc at electroene mesa. And what I have ma, Miclugau, and who knows where elu. all about what it is doing; it is m..ed heard and read in che pese thne years has Limais for acceptable reesdue limits 4 only with ins abort-term pro 6 marsm. led sw to beheve chme when it comes to ethylene &brounde isos), a p.=a4 s Liede people (2ke you and aw) are A-- - - m aflwaldiand the -. - - c, used on a number dagncula ral rir ncases dihis a,., w greed and siw word wer is synonymous with had N-e for some 40 year., won sonic crimw. recendy set by the Ennroamental a nis cumn ned fumre wow d

erwr, Daily we are sub,ect to answay-Proeecaon Asency. Although: e assase acd desch is d,e uhimase price we prodncing reports abour the " poisons"in smdehnes ensure char du risk dcancer pay for eschoology and the

• good Ide."

our _a - c. , 4r== d presumre from nos co c-is a worn e New and comptes a-- u we demh, huma. =ry, defecaw chadan, seghgele, hys=acal cle=s so du m end=== be eidwr t a-A or or ao chddren a all, caused by our comerary have been made br acanse highly,j d ne desch-deshas c-len un deachnology. We m g oups and p,diac-m nos - och.obgy aun be napped.r iy a,s. warned ther e Wie at uur doorssep, esempidies how wif-serving ind%luals (mh one of a sessier eene nee, and du.c and ory==r-a-w can twise public hsalth here does all this bed news we face an i-r.ad m epuleaue ddwease issues for pahacal maaws. come from? It appeara to and d rk. Women on dw Wen Coast have emerge from dinese sources Human enwience ic=J mins to be repeatedly charged anc the wulespread ranges from joarnahsac effoco of jeoparamed, our ecology rumed, with i.ne of herk 3.= pernaalarly 2,4,5-T, subvuk.als widi no apparene espertin in modung left for us to leave co che has caused reproduenve fadures. =e==re, to a few seemingly pronane:ar genersoons to come. And why is all ihis ancludans low spe-m counc, mascarriages academies and opimon leaders who, one ',,.. ;? ne owmage is clear: Our and birth defects. Vietnaci War veeerens would imagme, had sciencine daca in back I d:ecespect for nature end the aswre char all cheir sympeans and up their charges. envvenowne, and our thoughden, duer.sa were iniciaeed by their expoenre First, there has been a mini-epuienne ='- - ! use ofmodern-day ch.=ah so the defohaang A==Je=la of Agent dpopular books on the subject of health low spelled -!+ "7 and ecolog cal Orange in Southan Asia. (or redwr ::l healsh) and du ennroement. - cuenseroplw foe our couscry, and perhaps Ciamen groups have orgammed to A! hough you may have been warned nor the world. marrupe du developawn d=4 e eo judge a book by its cover, the tides of Diams, we read (in stones rich emergy in this country, pointing always to the recent volumes (all of which were subuda like "Dionia:In Search 4a dwir concern about dw poemenal published after 1979) speak for Kike"),is eke " man toxic chem':al caecer-causmg effects oflow-lewi dwmeelves rediscion and solemnly moang the e Anitrica de Poisonal: How Deadly "cragedy" ac une Mile Island. Chemicals Are Destroying Our Emron= cat, I %,,,,,,,,,,3 g,,,,,,,, W-are soli rhat we should noe drink Our Wildis(r, Oirsches by lewis rase renw.e moon wetaan ny sammessi wtwien and pummoned by Jameson the weier or breache the air because it is Regenstem. aeoks*nmemann a co., ottawa. annete. poucaed widi dw "falleur c(afHuence," E Who's Poisonreg America: Corporate C*r,yrtenuses by summeei mween.h and we an advised to avoid livmg in a Po&sers =4 Their Wrims in de Chemical O,'n"s""ienee heavdy ind-malmed nace !:ke New Age, edited by Ralph Nader, Ronald m bened bi New York. She heeds a decieres jersey. (And if we must ncit New Jersey, Brownstein and John Richard. escree in epidemiciegy from use Harvard we are mimonashed to ho'ui our breath.) E Malignant Neglect: The first sensat or punne,eman, and s'* has ne popular wisdom here can be Complene Up e Date Authonterne Report { "'"""."#8**"*- sununarmed as follows on Kno or Suspecard C,ncer Connag j

l l l l Agews m Our Emrcmment by Robert H. Laboratory at New York's Mr. Smai Boyle and the Environmental Defense Hospital. cold Ti-c that " comic wasces wd! T/r irressaSe 6 th==iar==viroa= acal aad pushc Fund. healch problem facmg the U.S. in the s tac Pouon Covupiracy by Karl Grossman. [73 [g d 1950s.... We're foulmg our own nests a tac Polaus ofCencer by Samuel and we can't surtive if we continue." Epstem. gy c[edT*. And c naumer advocacy groups focus a H,rerdous Wuier m America by ksvdy on the problems m the Samuel Fpstein, Lescer Brown and Carl We /jyg j7g environment m their fundraumg ard

Pope, memberslup appeals.Joan Claybrook,

,I a A Biarr fog: Her6 culer ad Human '/pgg g' president of Ralph Nader's Pubbe Cinzen Rights by Carol Van Smun. advocacy group, went so far as to a At Highest Rid: Emron= carol [WCd!Ue ( e -e re s vro = aihealth douters of coday wich the scourge of Nazards to Yoweg ad Ua6ern Chddren by Chrusopher Norwood. foyjg c/g77giCd[f

• ~~"" a kle and infectious ducases m a Pdis, Pestindes nd Profits: tac earlier ages: " Earlier sencrations lived in Insern nonel Trade i. Toric Sds ces, fear ofpolio and smallpon. Nowadays, che ediced by Ruch Norris.

most deadly epidemics we face are e Io.e Cannl: Sewnce, Poluies id man-made. Chemical dumpsites, People by Adeline Gordon levme. radicactive wastes, acid rain, toxic shock a loing Wasse: The Poisoning of In "The Politics of Poison" (praluced syndrome... food ad&nves and more. Amerwe 6y Toric Chemials by Michm! by televisaca sencion KnoN in San 'Dae are the perds that most threaten Brown. Fraacisco), we hear that dionin is a our health today." a Agent Ormage: The Biarr H ncrr by "fe ~ 'l# ; agene one hundnd The polencians have not silendy John Dus and P.S. Young. thousmH cimes more powerful than immented over the. ac. One niight argue that k 4= of this thahdoeude... a synthetic cl===1 so Congr a==a James J. Florio (D - N.I.) type do not have much ofan impace an che powerful char an ounce couki wipe out a complaans,"We are facing a national I general public because ckit circulanon is mibo people "In this same fdm, which che=nl nightmare and the Reagan probably small. But even if relatively few focused heavily on ik aDesed link of the adsunucranon is creaang it hke a joke." copies dahe books were distribuind, the bebicide 2,4,5-T with birdi defects and spinosop-al aracles sad magamme musc.msga, an Ongen woman sells of y tramms and remarch in a puces are med by adhoes of people. developing boils on be face afisc a epideauology and pi,blic heahh make =w== diu ran..-- r.:. _,mahon, amin-spay g and proc.eds = 4.cnbe in Anunca books am frequent guests ca detail bc===e=nage "When I and other. _ - tal coor==-cion radio and selevision esik programs, nuncanied... ciw fetus wasu's enn enn and have caused hu=== disene and l ine'uding dw network shows, and thus recosanable a a baby or anydung. It was death, somenmes thrmagh nervi ar=, l their A-My views are luard by justaemas....I:1 4 ilike '- A., somenmes through human m!.u s. - II- = on many &Eerene oce.-- like chopped meat." For example,in 1968 in Yusho, Japan, The aussages in these books are 'ne " bad news" views of sewnasts, PGs (i.d d.k,.U.sted biphenyls) were 7 ranforced by dw audia chrough aracles federal of5cials, governawn: documents, accidentally mixed with iice oil, and a such a che S.,_ Le 12,1980, cover politicians and caa===a c advocates who verwiy ofsymptoms -including a severe story,"I1w Poisonnag of Asunca "in es brace dw Anwrice-che-pomaned form of acne, Iw=A=4e, vmniang, Tw r, which fumnd a souhas, swanas, plulceophy are also frequendy cowred in diar hen, fewr, neurological disorders skull-like creature sinkms into a muddy dw preu. and jaundice - were naciced throughout take inhabited by swunnung fuh skeletons. In 1980 Julius Pbk=~ J the U.S. the pa-~Icommuni:y. The subset maecer was " chose sonic surgeon seneral. declared thme throughout In du mid-1970s industrial misuse of chenucals." the 19 sos the nation will" confront a kepone, an ' -n + ', led to severe In addioon to books and magname serws of envir== = enwesenews" kepose poisoems and sympcoms soones, we learn about kalth and the pond by reuic Jwmicals ther "are adding including liver danwge, tremors and environment from television so du disease burden in a sigm6 cant, blurnd vuion. These symptoms were not I docunwnieries, like chose femmad on the ahhough a yet noe precsuly A An.d way." seen in the public ac large but were caaAaad o the East Coas plant in which l PBS senes Noow and elsewiwre, with In 1980 Gus Speth, another t l such telling tida as "A Plague on Our gonennwn spok.===a (head of dw du kepose wm manufacmnd under Children," " Serpent's Fruits," and "Be (~~-1 on Environmental Quakey), unsafe e 8M~ - Politics dPoison."In "A Plague on Our noted grimly that " man-made toxic Excess kepone reached Cheap Je Chadren," Harvard biologisc Dr. chemicals are a sigriine=ai nource ofdeath Bay after being dumped into wwers. No Marchew Meutson addrusa che copic of and A-=. in the United Scates today." one has shown kepone poisor.ing the pasence ofdioxin in the environment A few well-crateadal~l scientists have symptoms resulting from ingesting fish or by neang that " thousands of Americans also stepped forward with dire warnmgs water from the bay area. dw every year fron tumors which are about the environment adveruly Industrial dumpmg of mercury in educed because of dwir exposure to aEecting our heahh. Irving SelikoE, Japan's Min.mata Bay and the Agano dionn." director of the Environa-acal Science River durms the 1950s and early 1960s

l e 1 led to time Ca="*-*aa-a[ftsb, tbe inala e_ha'amir*Ia about wb5Cb che nacion is AM sourca of proma for ab roldents. As g shaken up mm no to have afected our u ourbesak of" Minamata Asease" health m any memurable way. Indeed. th technolopcal noewcy chas produced show

• g occurred, rk symp oms of which bDfSN dNFf chemicals has improved our kahh far 8

as meluded los of moeor control, lou of 5 karing and, a somm cases, hi-m, more chan is has harmed it. coma and death. A!! one has so do is look at the f Epismies of air polluaan and, gI gf 4:ameenau W upectancy and j decrease in the deadi race which = speedically, the e#ects of an air inversion Amencans have enjoyed durmg this g t in I.ondon in 1952, and in Donora, O D "L Pennsylvania, in 1948, cauwd an elevated 8 century to realme thu ik sum of allik g health hamed to which w m esposed de chram,paracularly amongcheeldalv.

• *'N[

mun be fea than it was in dw past. Thm a:e addenamel esposura to maa-aude chemucals and circumstances p Certamly, our curren good kalch should noe full us ineo a sense of false shm how mesr- - --Ei caused huanan dissen and dash, but because they have securuy ther w wi!! be forever safe from thepestenelfor harm sky need our our envuonment, no marter what we put ongoing ace -aa-and visdance.The into it. Modera technology has produced, Unimed Scans generates some 344 enthon and wd! no doube connaue to produce, I meine cons of indusinal weser each year, coumery? subcances Eu are proven dangers to our e Is nuclear emergy hasardous to our heakh. Tkse must tw denk with ( heelch, perhaps so pocamaally heredul about 30 to 40 mulboa some of which ( espe &endy and efecawly. l might be hasardous.These need to be handled in as _._ "; sound anc = would be been ogairang eo Th imperam aing = remember, fashaon, widi coassent averemen of du osher sources of energy? how wr,is ther sechnology's bene 6a to fact that dien how been - -p - of e Is die semes of Amenca's haaldi as our heakh how far eaceeded du risks. h i annaasement. bed a du ': wneers say? isnocoiacid =r chasdudramanekahh For saample, some chemmeals like~ m In eachnology making un sick? esias empenenced in dw Unised Senses dioma need to be controlled carefully. how paralleled drammae amovanons and High ea-e-- emons in the soJ are hoews (ihe ame=er so these quesmans is yes, growth in sechnology. It is thus apparent ear ifwe foHow the callofciw so howlulled horses in Times Beach, we do indeed how an. - en ben pesaades, Missoun. Elsewhen, is has caused sewre mahaman wish which so cope. But _-L--- - auelane poww and make air. acne in several meances-incluang whe: 4 the answee as these quessions is among resideas of Seveen,1:aly, aner a undermdy ee? Whe:4eere is evalence and weser-pollusion scandards even ples aceul==r, and esposed weekers is ches Anwncame have never besa h-=him-, sinceer, demometrable healih bene 6a wdl 1949 is Niaro, West Virgens, also aner a es wisin one major encepoca (sobecco. very likely me accrue. plans =ce=l==r Bus, we hen no evalence educed camew), du g ';- ' cancer Inseend, we will face food shariness, ther diosis emused done or any osher desch race has been declimmig owe se pese lugher saaes, fewerjobs, slower.ea-a-e I iHeau anywiwee else. 50 years; ther air and wome palk-growth, smaner depead.=~ upos foreipi accouse for mo one huown desch in the energy sources, a reducaan is our My purpose in i ' = ;thef. j-

claims about Uniesd Senses soday; ther, -

' '. en osaadard ofliving and, probably, a declier heakh and envuommsens in Amenca our beu '-- ' ';, are mo coma 4uang in henkh. bepas wish the '-- ' _' n ther so iD heshh, but recher promaans good Why are the media so sulhble when is masoned ' ' ' -from maawal and heakh; and ther -el = emergy is safer cosmos to swsuowns whole ciw unseamen man-made sources-can p ""; do ihan any asher kind of energy curressly of dw docendayws and thes reporang l seve demses m> humma heehh as well as avadable? shone ieses which sewease see as "siyih" so our mensral resources. But tim yee su be Whe 4,insemed ofischoology or " fantasy" as if they wen full-diedeed answered quesmans here an: d-1

us,it is Kenas us am news soones? Why an dw audie so oIs Amenes being pa a==d so the oppocamury for even more improwmena fasemated with bed news? Z,ui's good

- iher W'=, paLac-and in dw quakey o(14e? If them "ife" lead to news ewe news? When Sweden beamed osher - -- " n claim ? the m '- -- dia: Asunca is inies por in 1969,it was a major media mm O An we empenences an ep A -e of poisoned not by clemucals, but by the is eis coun ry,complem with large i assese, inchaams cancer, which can be pa. a-J pens of alarmise unkare and h-=41-- Whos cim Swe&sh parliament linked causally wah the growth in .f. - - --. hen we would find ourwives racaded its esent bem one month later Amencan eschoology? spemans unknown bilhoes of dollars is and reacroduced dw quehfied use of the o Is air rallnaa-in du Umind Smens our quae for. - =' purity-but j- - - E'= es proacc ia vest forwas,"efw making people sick, and perhaps ewa with no measurable heekh benefit. nience in the Asuncam press was kiihag time? Ewa though a " time bomb" has been deafening," as the authors of Eulerieel O Would 'we be beteer of wnhous ", ackms away for years, no Semity put is. pesocides and herbiendes? If we bem a sciaanfmeellys. '" ' evulence taises for Whrd is ther classac American the "emp amaan" ofdeath and disease cites l Invesagstive reporang style, and why has - l substancial au=h c of them could we reduce the museer cf-memenages, birtii by the. - -'=E=es. Those it so: curned its inquinag teeth and d=4cis, camen med odwr ailmwees in this "mpes," "oomas" and "breweg" skepocal slance to che environawncal DECEMBER 1985'13

movement? SfgtiStics(gll cismnu. And where are the sewntists in this Second. the news me&a chnve on debate? The most unserthng ggygggtpg con &ct. Anyone who hu appeared on a charactensac of the " bad. news. bdPe riever beeri rood a' es. eesuc>aes. n cicar energv telension or ra&o program to defend syndrome" m the me&a is the fact char chere do appear to be leginmate U.S. or any ocher spect of technology knows sciennsts who feel that the end of bed [l/7EeT chat it is de riprur for the me&a to America is near. A handful of them concoct a debate format. even though the repeatedly appear in meernew and are yg jf thg7e pro-technology guest represents 99.9 ciced.4 nauce= in articles. Why do we percent of the sciennfic commurury's not hear more sciennats who represent SOTFI!Kbhad che====tream of thought? Why haven't (The reverse is not necenanly crue. the vast majonty of Amencan sciennses flews dbOldt N)e The alarmists frequendy are not and physicians come forward pubhcly in presented with an opponent because they defense of the truth? g7gyjTOftrFler2t.9 are generally regarded a sincere in their www, unencumbered by a tie to mdusny, e are in fact, the nenms of selBen in their mocivation, and thus not W"overw, helming majority of the comic terronsm" because the requinng a balancmg force; and appaready their views are considered so news we set from radio, television and the h reputacion as a reponer, by pramng Enghiening and newsworthy that debate is pnne audia about healch in the j anybody. You make your reputacion u a s.o necesury.) enviraa-ar is bad news gener=Ily, l reporter by sougmg a bunk ofraw and Tlurd, and relaced to che bad-news-very bad news, despite the fact that p bleeding fluh from the system. And I did sells / .is the much overlooked nanomal henhh --han A== that we thsc, all young reporters do that. You realicy that new inelfis a product. have newe been healdner. socia be able to prove you can snap your Indeed, news is a heavily marketed Thereis no sunple answer as to why we jaws for the kill. But maybe we've gone commodity in a highly s,.w.-.m, get such large helpings dpeuimism soo far and there should be someone to carefully monitored marketplace. mind wich our daily duc daews frain the call us to accouac for this." C my and sensatia==1== draw American andia. But there are some Psychtrise Robert DuPoor oEers wwwers. Unfortunately, science and observacions and clues chac give us at lease some deeper insight into why bad news common unse,in the forms most often an incomplete underscan&ng dwby the sells. He says that what==Im new is presented, do not. Televmon and radio news is not presseted in a more fear, and " fear is news because fear is scacians want to attract an==h ar ; .. " - I way. interesang." He scresses, however, chac that's their 6 s and that's how they Finc, we are facedjvich what appears the me&a are ulecove in using the scay in 6ma.- so be, for better or woru, an inherent powerful elemene of fear so secrect If the. - cal alarmise ao quakty a(the de6amon of dw word erws. anenace to dweselves, focusing dw channel I is reaches 30 pacent a(the North, eut, war and south - news fear-introducoce mededs ce technology vwwmg au&ence while the scuncist ao seems to be, by de6aisson, bad news and " big b-=s" est on everydsy risks channel 2 is reaches his best friend, b d.w w. J by hx.nhsm, h-e=- around us. He writes,"You can neighbor and 6 macher, it's clear who's j chac is appaready what the public wancs, understand how absurd this position is if hanns the greater impact on the public, or what the andia think the public wancs. you think about water instead ofnuckar and at the same time who is keepag which R.M. ^%II. president of the energy. I can see the televmon picture ch==nel's raangs high. Massachusetts Voice of Energy, once closes in on the swunnung pool, and dw It appears that members dthe andia observed that "du dark side of human voice-over sayisg,'Do you realise that are frequendy ink. aced by what has menare seems to enjoy hoeror mones, auto dure is enough water in eb pool to been succesful-and the all-important recms when there is a good ch==ce of drown 100,000 people?'" racings - not by what might be factual (wry desdi and electronic pictures of the Thus,in some casa, there is a desire Bad news is good for businen. As John lacese disuser." to make.. - -tal new dramatic Ma&gan, the seasoned commentator for And George Will, a Newreech and anasety-procluems to ensure our wanM.AM in Qucago put it, the media C S. said much the same ihmg: -" It often seems as if reporters are "cely interested in the guy whc kicks "Only man is perveru enough to feel are reluctant to praene a h=I=ared 6 modwr down dw stairs." most alive when the new is mosc larid.... penpeenve; har is, for eaample. co relate Fourth, and again related to che If some great catastrophe is not theallegedhasardsof-ch ragytoother general underlying bad. news theme, the --==' ewry mornes, we fut a comunon risks,like the risk ddrownmg in awdia representativa who cover certam void. Nadung in the parer today, a pool. ennronmentalissues,like their colleagues we sigh." Perhaps the reason reporters in other specialcies, are in a hurry. Their Theodore White, distinguished presumably are reluctant is char it would deadhr is always yesterday, and they. author, historian andjournalist, alludes to weaken dw impact dcheir nocy. Thus,in have no time to tiscen to che pros and cons the " bad-news phenomenon" in what discuning dioxin creces found in Tima of an inue. amounts to a reporter's credo: Beach, Minoun, we are rarely renunded Even when more moderate scientists "You don't make your reputacion a a char no one has ever died from dioxin - attempe co dinuade them from yet agam reporter, and I did noc make my but 450,000 people will die this year from citing one of the handful of fnnge, 14 = TH E Q UILL

r l l amb-- i'* m sc=ncues, encouraging enough to nport tb news as it really reporters to call a few of the local heFFledh! happens is itse'f ac pohacally skewed, g ummesiews to check our ds person's Sixth for whatever rmon, whuher it repunanon among fellow scientists, the Ojfe?: accept is a th1rst for bea rwe, or a,ues, for i answa is thm dun is too hitle ame.One something sensaional, shockmg or t pre [!FFI!FidFy frightening, the U.S. media an =dhng to wieniin whose wwws m recorded on videotape or in a reporter's notebook is accept sla-r uncriticsHy prelimmary better than none, even af he or she is f scientdie evidence no matter how tenuous o representing a fringe pomt of view. and prelmunary it is. Whether it is What the journalist under prenure is cY5derife FIO l'*<==- of ame preuure, the search for lookmg for is the scientist who can give

"-+ # n simple lack ofesperuse or l

bim che one liner he wenis to make his 773d867 h0W fear cha their m r.;.c.ca =di set the news puch. Most writers and reporters do story Erse, peer review does aos east in not have the ame or esperase io put, for fertgdotg It 15 wievision, radio or print media circles. --pie, the results da new amisial nudy "I1m proceu of peer revww is du ened on ik Iwatch effects a(chesucal X in and true method of applyms du self-perspecove. unposed nandards that scientiscs une to To miempt to do so would awan separate good sewnee frosi bed. When a comung up wuh a dreadfully bones and scianan completes the research for a ~ ' acey which c--- ihaugh heedly unupectal by thou who project, b or slw interpreis the resules, eiw accurnee but ho-hum message che:"a have long suspeceed dw amei-writes ihm up and =#h-dwa to a laborosory saady eoder rmaled sha ---l'" oneesseios of many sciona6e purnalin his or her 6 eld for chesucal X can increen du risk a(Ime --=h-rs of the me&a. r?'--- Scienti6ejr.nenals een' manoes in mice, but semeneas --- a Jourmaksa were mon likely chan ilm suben du informanos dwy acem to asamme rash regulasory acones agmas so come from well-3=-===8 peer rewww and menculous r&ang before dus eh -neal Iwecaase demens of onher high-sanan.l--- - ' fasuhes; du 7'--5. 3 r amuset sandwo and mesy observenans asi jaarnabses recalled ther dwir parones' Hower,unrev.nwed saa&es dip our humans have shown no ill effeca." mcommewas"abovea orase."Monsia dia imeo the public through dw media before when is du :=ory line there? Whas leaders, deush rue socialises (only 12 du resulas or scusa6e validity is <ould stos do fo. reengs? percese dahe easel c oup immeviewed _ : ? For example, as William R. ^ F4th,it appears chas; - favored - - - 't Lrge corporances), Barclay wroen in theJeanielofde p Ily those om dw East Conse,m no ^ > utomsly with du - Amarrican Malical Ad ' n"Many of a' .- -- pahacal youp. In and nacial polmans drn, - ' by the the repore on carcicoesmeses that have pl la.sunse,isapp = ducdu .ew-pohacs ei===,4du Democrene been m.de public hm been a.wed boa esseers press, which dommsens meework party &anns the 1960s and 1970s.'I1 ey indemos andinserpreanos but hminen news and wiro s mce cowwege, sends so wm also, me r.

', found so be accepeed by L-. _ -

'] assacus chas be es ' : , more pal-ily hberal, more suspicious af and hasale to busia es fundal tium, by the news mesa, sed, asti.corporance, assi-fm esserynse, and much more ennen! o(U.S. 6mrJiy, by the pubbc." and - "'hment and ano-credicional, as insdaations dian wm ihe F ' , Dr. Berclay goes on ea sey,"Although compared widi du me o(du namon's Some journahse in this sumy wm iporance of tk esiseance afa hasard cas

-y ' = =

found to be more "liimral" them odwes. . l= dasserous, falm infonssoon can k Stanley *

• pedemor of For - pl.,a semble pornom ddie staff even more d'aserous, and wiiile one governmises as Seiish College, and on The New h4 her sad The cranos queml wich the concept of a fully S. Rolmet Lacheer, an animane pedessor Washenges. Pae were likely sdeEnve that aformed public or defend senace's a(pobocal semece a: Georg2 Washingian large corporsoons should be =e+-

cloakms itselfin secrecy, one can demand Unmemey,- -- 4 240journaksa (21 perceae of the Tenn news staff ., - " ev L-and reporang of from what are widely r2sarded as Inlieusd that-one wonder, (ther, sciennne leen." Anwnce's man induencial news would ope for the Ers beinIs A rece'as===ple d how as orgemesmons: tar New h4 Tamer, tar, ' " '. and if noi, why nos). unrewwwed nudy can unduly frisheen the Was&=esaw Pac, tar WallStmeJoaniel, ' Tehvueos esecunvws tended es tw public after is is scooped up by the media l br. Neureneet, U.S. News & Worm ,teilwr conservaave on ear Wues as was the report ostelevision and in Repert, dw three e--- -; ! br le. -. compend widi odwr meSe respredena. newspapers of a doubhag of the rees of celevision netwarets and pubhe relevision. Buc, wJ;., to Rodunaa and Lichter, birth defeca in da United Sates over the Rods.ian and Lich= selected from " television news reporters and producers pase 25 years. "I1m li-th= in tar New widun each organsacion indmduals from ..are more Idwralthan any odwr group ..h4 Times read," Physical and Mencal news deparanema, sdnonal produceam 'of awdia pa a== 1 we uu&ed." Disabdines in Newborns Doubled in 25 nafL and working reportars. They also Policical oriencanon is a personal Years." A!: hough the Les ansele .---.<. J a numtwe af auddle-and matter, and one cannot enacine incksled some wumngs and advice about top-level esecssives from six companies indivuluals for their y...C.e.. css. But on, interpressag the results of the study, the tha appear in vuxm Fornar lins of the other hand, there is somedung owwallimpmsion it gave was that top-grossmg 6 tins in key sectors of the disturbang ahque the fact that a group of hairrica is facing a major health problem ecoeomy. The results were fascinating, indmduals ther is supposed to be neutral cbMeterized by a soarms race of birth DECEMBER 1985*15

defects. Reports of defects were not me&a and what the me&a might do to required to be documented; neither was ryg them. The fear goes way beyond the l proofofdiagnosis, anxiety of the luthu and the countdown m i Oc the other hand, the Center for p-an Nac nudio. More important is the Dinase Control regularly coUects p IS d fear of public humihanon. Members of natuacauy sound informanon on birth - the media, though quick to accept defects based on hospital ascharge @?!??!OT! unchallenged the frtghterung and surveys across the country. A foUow-up pesimistic reports of the call to the CDC by the American Council FI enviranawmh3ts, are skepocal of sciennsts who defend technology. "Who j on Science and Health revealed that the ICbf!NIli funds you?" is the common, aggressively l NIH data were totally snrehable. The asked quesnon for the sciennst who coc's data show no such increase in btrth _L defects. In fact, there has been a decrease N brings good news. in some major birth defects and others Many scienastsin the United States bve remamed stable. A spokesman said 8 WI have so me e mac,c. with U.S. mdustry, that there could be an increase in either because they have ofered diagnoud Icarmag duabihaes, a fact consultant urvices or been speakers at which could reflect either incremed corporate convennons, or because their utennon to the problem or a real mcrene. university departments have received In short, stories that go nraight to the tramed to use highly techmcal terms, but grants from one or more members of the pren without bene 6: of sciena6c peer those crue experts in the 6 elds of food, chemical or pharmaceuacal revnw often end up causmg unneeded epdenuology, toxicology and related indurries. Es they deem themselves concern and even panic. And, of course, ascsphnes feel obliged to speak with vulnerable to the probes of the preu who foDow-up nudies discredit ariwr conscant nr 1 Ae ha, chd=h and wpecantaaves who want to reinforce the alarams reports, weu-- that's jun not excepoons to the rule, peo.consunwr versus pro-industry news. It is far easier to be on the ofennve, &ck, _.7 by wing incr~W like, claunmg that Love Canal residents were "Dr. Smith, a profenor at Harvard adly the great majority of this droppmg dead like flies, giving birth to University, admits that his department S naco,n's scunnses remam mute on deformed cluidren and suKering from has received a grant from the Dow environmental concroversies. nervous breakdowns because of u ping Chemical Company." Understandably, the public is left with the 8.--e=t than it is to be an che defensive, Beyond the fundmg phenomenon, opn on ihm dw four or 6ve phy.- nacing char no such problem exists, but in some scientists fear the media because and sewaciscs who are repemadly quoemd all honescy havmg to admit that since no they don't truse nhem and have no control by che media in theirurades against one can prove a negative, the posibdity as to how the material they give them wiD everydung shat makes this country great of disaster always ains. be und. Merril Ea-Ad & rector of the repenent the majority opuuan - or, at / I4gitimaee scientists are er an Laborneor* for En.m,. .catal Scuses at imma&ste asadvantage in interviews New York Ui.iversity Medica' Center, lean, reprewn half of that opuuon. [ with the audia because they, unlike their A number of e p h for this explams this reluctance: f curmus mience come to mind. I pseudoncuna6e counterparts, are "Many of a compla.n that we are It could be argued, for inacance, that moraHy and emocionaDy eMa.d to expected to take the time to be taped for American scientists are umply too busy nicking to the facts. tv oc radio interviews, but have no eo get into public and scr-es Deshng with che media is,like control over whu imally appears. A!! :oo c.,m.mi.ial dialogues on che-.l, the e.;.7d.: g else, an acquired skdl. One often, the most useful chings we say end environment and health. They are busy in does not --. e fly get a Ph.D. in up on the cutting.coom Soor. 1.L,c.e,ss, teachms or, if physicians, in biology from Yale, become a profasor at "Over the years I have grown privn= - Air.1 practice. But "too busy" the Umversuy of Miciugan, and overmaht camera-shy became all too often a single is relative. If somedung is important - become a quahned and at-ease guest for a briefsentence, totally out ofcontext,is all if, for example, your reputacion is at nake debate on the "Today" program opposite that is aired after an interview that - you are never too busy to defend it. L a rabid. -- - lat. mvolved many minutes a(taping. I believe And, too, perhaps sciennses and Sciennses cod phyacians are not that unten the interview is going to be phyncians feelis,.r.y. and tramed to debate in pubhc. They are not publahed in its ennrety, it is proper that urs.f.,.Je apparing in public with educated to be advocaees or to be the scientist be given an oppoemnity to glib, well-rehearmd "envira=== cal avadable for inscant raraa-to "new approve du edi =d version." r..f z..ere." ne tramed sciennst may 6admas."Sciencises are cc = H ' to the nis celuctance to sihmit to editorial never have been on Tv; he's afraid that he plulosophy that dw warch for truth takes whim is growmg not only among might handle it badly. He doesn't want to rime and esort and that one s2r of data scientists like Eisenbud but also among make a fool of himulf, and he's afraid does not neceuardy make a e"h du corporate commumsy where a that his profeuianal colleagues might Certamly they do noc feel comfortable untence out of conter can help to question che propewty of his prexace on evaluating for a reporter the raults of a develop a urious case against industry. a program that also femmres a quack, tww reg 2r they have never seen. In =AAmaa, another funding question, unemployed actrenes and a male scripper. Too, many mainstream scientius and one ar,er raised by the media but an Not only are mon Ph.D.s and M.D.s physicians mey simply be afraid of the important roadblock to some sciennsta / 16

• TH E Q UILL

e who might ockrwue go "pubhe,"is the r_J _ u dayume me& cal dramas are relaavely fear ofloems government money. If a mde accurate, auf many of them have earned sciennst's research program is bemg g high ranngs. hse raungs might funded by the Envvoenantal Procecnon o p6==,c, however,if the actors were l Agency, the Occupaoonal Safety and t_ replaced by real doctors. A haughty, Healch AA-aiatranon or oeer federal No lO mulci-syUmbic prewncation from high in agencies, he might think twice before he the ivory tower does Letle to hold an steps forward to criacne a government COUMUff au&ence. nudy, or to defend the safety of a product gm Unfornmacely, many real-hfe heahh that falls in the juru&cnon oflus fun &ng N prof uonals (unkke their fienonal cos.arparts) cannot commumcate their source. Moreover, ek relectance d the mesuges well, and they're anydung but saenanc - -"ty, paracularly _. ---- tal and public health dndSC$ence entertammg. If the healch pedesmons are to utilae the me&a esecovely for specialiscs. co come to the defense of e ea a-=- aaa cheir spokesmen must pesacides and oEer perspecove to relieve dNNt learn to be believable and pp-f=g-i pubbe anmery about &oma, air and water T1urd, sciencias, whenever pousle polluaan and vanous Love Canals may through penonal contacts, letters to the k rooced in profewmeal self-interesc, or editor, or a call to a Tv producer, should wurvml-or what is w i.a called --ee weU in advance of a breakmg 1 the "anacal audent pheaa-aan " serve public policy by living within the nory their availabihty to answer quesnons E..- al sasace thems ce bad ethics dsaeace, no those d politics. If as spea6e copics. If each session had a news. The more bed news we have aboa: the saena6c ca---ry will noe unfrock continums relacionshsp with a few &asm, love Canal and general ~2- . the charlacens, the pubEe will noe ascern me& cal and =e=aa&c consultano (free as more we win n d _.__ - cal de &Emaca - =~a,. and du mano. du local unmency facuky, pahaps), ir -- 11=re - to be as inkrene, will sufer." would noc be ddlicult to vaify dw self-serving him twee, wish pubGe beakh Firer, saesases mun come so accuracy of a purpor sd i== lek fact or to 2--- - and. - ':- lookmg appreciase how ire -;-M% che asas. decename whedwr a controvernal for prakl.-= which may not esisc, but snedia are in daueaunacing informanon, talk-show gueu would but appear fus&ng ahmou every one dwy look for, or "- - L===. abour d= e 1= - '; iogedwr widia 5-4 or jun m the - A-=1 nudent is sure he has of heahh and the envuoament. People - - for the opposue. +, every &sease he reeds abour. eend to believe whac they hear on radio or Obviously, a# saenases and health Indivuluals treemd in 1' +,j, Tv. After all, if soeweing weree's true, ' can't be espected to ditch public k Irk or a perncular ther man ce the program wouldn't be their careers in favor 4 media inurs, but ! ari a.e are likely en be a allowed to sayit,would he? Ap ciall on is - kl. to ask sewer 4 them, y self-ulected group, hevmg cha a cheir

==aa==l elevision. perncularly acadenue phy -i===, so make i pro (en.on 1,ecaun ddwir feeling ther Of course, people are eBowed to any ek 3ves avadable to the undia from du end dihe world was near and their akaananydung dwywantio on dw air as time so time, and io learn io present dwir servica were needed to passpone char long as ir doesn'tlibel-They are asessages with a pro 6ciency comparable inevitability. procected by the First A '- - c. Mosc to that of the average ey=ck l After rece5ving their pro (ea 1 of us wouldn't want is any oder way. A# heshh prof--a==h, however, I amams, dwy = under ra-Aakly Howmr, eis fradan, _ ' _' wie aka. td make a point dkeepag unck d t ddwir own -- and du our tendency to crum Tv and radio, sin currene fads and frauds beeg L-aaa=1 coe aucment dwy have made makes - Q= = frasi dwse sources pra-an J by the me&a. Even if they so it, makms sure chu alw problems dwy par =Il paesac. never so on the air, heahh profesa==fa y buile dwir careers ce don't go away. The If a ari aei c reads abour a "unidag cen um some social and ec-- I s, withouc.;. - n=dacal ducovery" or a "new deadly tosin premure by presses chose scanons char peoblems, does noc have a job. found in K =l====aa" in a supermarket are fair and r paa ible in dwir coverage sabiwi, or if he hears about it frem the of balth topics. A hhough dwre are a nuaser d guy sining next so him on the plane, his The heahh pedesmons must also nop serious roodblocks in the way d skepticisen is going to be operating er fuD ignones the Amenca-the-poisoned sewerius who weet in, or shouki steam. Unforn nacely, mon raa==-es authors and the like, and the ms&a want m, becce= part dihe pubEe don'c have this high level d==p--- appearances dwy==L, These people &alogue o. kahh and dw x.:.- r, wks hs= g = radio or w. Tiny neet hm a po==ful impact a dw pubhe and the problem is ;olvable - pe==a= an oppomag scientist, with better gain croclibdity with each bra de==. becaw inore aggrasive in defense d credencials. co chaDenge nhe alarmists and Physicians and scientists should noe their pedeuion and more actm in make the viewer think twice before deny or 6sht dw power of the media; they rk=It nging musinfonnanon when i; is. accepang the grim news. should join it. If a charlatan is in town, a wrved up. Second, health pedeuianals shouH quali6ed pedenional should be ~ As aw la Philip Han&u fornwr convmee ik andia, by aample, d.a A ta: a debu. To mand bck is m praident of dw National ArzA. y of =~-4=11y sound n A-me and seence permit facts to be distorted - a Sewece, once aburved, " Scientists best aren't iner'a-Ily dull; prune cfme and dengerous error dcausuon. Is = THE QUILL 1

(' \\,\\, /*- h EDITORIAL EDI'I RIAL EDITORIAL EDITORIAL C J GOAL ABUSE dd Goals have long been valuable management application of a goal to a job, he will soon begin tools. Almost every industry and every program to use goals for otherjobs, and eventually he will imaginable uses goals of some type to focus at. routinely set goals for every definable task. Next, i tention on desired outcomes. In radiation protec. he will set goals for collective exposure for an en. ition, goals have been applied to a variety of per. tire outage, and then for an entire year. He will I ormance factors, including collective exposure, stop monitoring collective exposure in terms of f individual exposure, skin / clothing contamina. " man. rem" and begin to monitor progress 'tions, extent of contaminated areas, and solid towards the goals in terms of" percent of goal ex. radwaste volume (see " Performance Factors Used pended." At the end of an outage or a year, he in Radiation Protection Programs at Nuclear willjudge the success or failure of his radiation Power Stations" in the October 1985 issue of protection program on whether or not collective Radiation Protection Management). Goals of this exposure exceeded the goal. At this point, he will sort can be very helpful to managers and workers have reached the ultimate in goal abuse - he will alike. Goals are like drugs to a radiation protec. be managing the goals instead of the program. tion program - they can be used to revive a lethargic staff and pump up performance. But This may not seem all that bad, but think for they can also be overused and abused. When a moment - what happens when the manager goals are abused, eventually the sole criterion doesn't achieve his goals? Now that he has for success becomes the achievement of the goals. " failed", what should he do? Does he set less The result of this " goal abuse" is, of course, a demanding goals for the next period so that he " junkie" radiation protection program - one that can be " successful" once again? Or could he is out of touch with reality, possibly redefine the goals for the current period and change his failure into success? Or maybe How does goal abuse occur? It starts out in. he could get really creative and count some of nocently enough. For example, a manager, the exposure in the current period against the having used collective emsure as a means of goals for a previous or future period and thereby judging performance in the past, decides to set meet the goals for the current period? If he works a goal for collective exposure for an upcomingjob. hard enough at it, he can probably find a way He sets a goal for exposure that is lower than that to manipulate the goals to achieve whatever accumulated for previous jobs of the same type measure of" success" he desires. Pretty soon, his but that appears to be achievable. He hopes that addiction to goals will cause him to lose all sense the goal will help him focus attention on the job of reality. and marshall the resources necassary to achieve real exposure reductions. During the job, he Still think this is relatively harmless? What monitors the rate at which exposure accumulates if, instead of the manager setting the goals, somi-and takes corrective action when necessary to one from outside his organization sets the goals? keep from exceeding the goal. At the end of the If the organization's performance is judged on its job, the collective exposure turns out to be slight. ability to meet the goals, the results can be ly less than the goal, and the manager proudly devastating. For example, if a corporate 3 observes that the goal was achieved and that his manager, industry committee, or a regulatory { exposure control program was successful, body reviews collective exposures in the industry and then assigns an annual goal to the organiza. So far so good? Wrong! The manager has made tion, the organization itself is no longer able to a key error in the use of goals - he has confused directly influence the choice of the goal. What f the achievement of a goal with the success or then will the organization do if the goal can't be failure of a program. If he continues down this achieved? Postpone necessary maintenance in path, he will soon become a full. fledged goal order to avoid exceeding the exposure goal? Bring junkie. Having been " successful" with this first (Continued on page 10) 8 RADIATION PROTECTION MANAGEMENT l January 1986 f ~ ~~ ~ ~ ~

(Editorial-continued from page 8) in workers from other plants to do high exposure NEW{a{a work and then hide their exposures in the other plants' records? Report only " estimated" ex-FROM NATIONAL NUCLEAR posures based on falsified direct. reading CORPORATION dosimeter records, and hide the actual exposures in the official records? THE sound fantasticmot many - we am rapidiy BETA-MAX FRISKALL ..pproaching just this type of situation as goals become more and more widely used and abused Whole Body Frisk in high and fluctuating within the field of radiation protection. In private background with the new NNC Beta-Max industry and government alike, goals are FRISKALL established at the highest management levels and are used as a means ofjudging the success p or failure of radiation protection programs at (,,. power plants, national laboratories, and 7,.W shipyards. Regulators and evaluators have pro-p posed the use of collective exposure and radwaste volume goals on an industry-wide basis. Even .m without " official" goals in place, radiation pro- ..4 f yJ tection managers and their programs are still judged by their ability to meet the " unofficial" ~ goals that regulators and evaluators derive from industry averages. Let's face it - we've become goal junkies. We're abusing goals and not get-( I ting the benefit from them that we could. 7 How do we avoid goal abuse? Simply by ; understanding what goals are and what they are not. Goals are expressions of some expected or N C~ nestred outcome. By their very nature, they are

• arbitrary, often inaccurate, and easily CHECK OUR FEATURES manipulated. Goals can be used to push perfor-mance in a desired direction, but they are not a '
• Fully equivalent to gas flow without measure of performance. The success or failure i

dead zones or gas. of a manager to achieve a goalis determined as

• Alarm level in sigmas displayed.

'nuch by factors outside his control as it is by his performance. For example, collective exposure

• Alarm history retrieval, could be managed very efficiently during a given outage, yet if extra work is performed that was
• Last count retrieval.

not taken into account in setting the exposure

• Sum channel.

goal, the goal could easily be exceeded. The per-formance is good, but the assumptions used to

• Unique snapshot algorithm.

set the goal are no longer valid, and so the goal cannot be used to determine success or failure. . Demand Recount.

• Procedure alarm.

This points to an additional type of goal abuse - the use of overly comprehensive goals. It is

• RS-232 output.

fairly easy to set an exposure goal for a single

• Beta. Max ' plastic scintillant.

job over a short period of time, but it is more dif-ficult to set a realistic goal for a series ofjobs over a longer period of time. As the scope of work and Call Andy Andrews time period covered become larger, the more dif-ficult it is to establish a realistic goal. Eventual-l National Nuclear Corporation

• l,l ly, the best that can be hoped for is that the uncertainties in the assumptions that are made 1904 Colony Street Mountain View, CA 94043 to arrive at a goal will tend to " cancel each other (415) 962 9220 out" so that the goal will not be too far off the final mark. Comprehensive goals such as collec-Reader Service No. 21 10 RADIATION PROTECTION MANAGEMENTiJanuary 1986 W

L -

l "" ' elm.% T, m'.w." tive exposure for an entire outage or year fall in this category.These aren't so much goals as they are predictions of what will happen. They are When it,Comes to useful for telling you how well you,ve planned,- RCCilGilon and whether or not you need to adjust your plans, but that's about all. In the end, the ability to Protection We're achieve these types of comprehensive goals will be determined more by clairvoyance and luck than performance. So what's the answer? Should we ban the use of goals in radiation protection programs? Cer-J- tainly not! Like drugs, goals can be very f; q.._ y _ .s ..T' %<,Q. y g;.. i h.i K7 beneficial when used intelligently. With careful '7 .% (N]M hs U(4 '.%, L., y f'Y L;;!.: application in limited situations, they can be used to stimulate performance, but when they [/1/\\ h :, i( %.q) are used excessively or misapplied, they can pro-h i(, \\ ' }(f i y duce negative reactions. You should use realistic 'V U i" 4 i goals wherever they are helpful in promoting im. ( l;91 I f 7, I proved performance. But always keep in mind 'F the fact that goals are a means to end, not the 4 t b b ;I l [lt b DY-end result. Don't let the goals become more im-Qi(fj portant than the program itself. Don't become a goal junkie! gb 4. - -a Alan S. Bunker Professional e Dependable e Rualified Editor, Radiation Protection Management In Health Physics, Decontamination, Respiratory Protection and Dosimetry Anyone can sellyou a survey When the ume ccme, to get the he,1 meter you won't use...we're Rce== emtecu= peopte v= c= une. come to Nuclear Support Services. Our Showing y0u One y0u Willg = Radicuon Protecu= Divm= has been a part of the teamin preplanned 8 shutdowns and emergency operations ct NQO AD nuclect stctions from New England to Californic and dozens of places in MEASURESSOTH between. We've ectnee our reputation for RADIATION Protessional. Dependable. Qualiued IN (up to SR/hr) radiction protection supervisors, techni-

• M,'d AND cians and speciclists. We protect that M

CONTAMINATION reputation by constantly upgrcding the ]' (up to 500,000 cpm) qualifications of our teams. When time -l T I ,j M secouseyoucanfititin and skill count. you can count on Nuclect yon $o(u INve"iEwith Support Services' Radiction Protection Y -1 5 N! you whereveryou needit. Dtvision. Give us a cclt We'll be there EU O-Me - The Mini-con-RAD is the E, only rugged, full function, 4 + ' ' NJ he m ot you won'tleave back at = 3 the of fice. I . =. Nuclear Support Services,Inc. ~ OSimeter 1.0. - 3 20 Hershey,PA 17033' DOSIMETER CORPORATION ' 800 338-7333 "o".E N USE4E.pga g m 12s Reader Service No. 6 Reader Service No.15 RADIATION PROTECTION MANAGEMENT l January 1986

e s WRPA A 48 m 41-pt EDITORIAL Detailed advice or self-reliance? One of the functions of the National Radiological Protection Board is to give advice to those who need it. Much of this advice is given at cfose range in the context ofindividual needs, but some of it is of a general nature addressed to Government departments, employers and professional P odies, a Any advice aimed at a wide audience will dissatisfy some recipients, and we expect sc,me criticism. If it is constructive, it helps us to do better; if it is not, we try to identify the underlying difficulty in the hope of removing it. d Some reactions to advice have, however, surprised us. The surprise is t 1: occasioned by the number of people who want their advice to tie up all the l loose ends, to answer all the questions, perhaps even to save them from

h. conscious thought. At first sight, that may seem a sensible aim, but on closer inspection it becomes more puzzling. The more a general advisory f

, statement goes into detail the less likely it is to be truly applicable to 5 special cases. Rather than tying up the loose ends,it ties the recipients down, it leaves them no freedom to exercise judgement. I A recent example has concerned our advice on the replacement of the f so-called '10-day rule' in diagnostic radiography by the advice to ask women patients, "Are you, or might you be, pregnant?". This question [ should be put to the patient before deciding to carry out X-ray diagnostic procedures involving doses to the abdomen. In its advice, ASP 8, the Board deliberately chose not to specify how the question should be put and by whom. The complex relationship between the referring physician, the radiologist, the radiographer, the management of the institution and the patient seemed to the Board to be better left for managerial and professional resolution by those directly concerned. Central advice t Offic:r, National seemed likely to be otiose. j { IX11 ORO. To our surprise, a letter in Radiography News suggested that our position inu:1 subscription charge, indicated an " ivory tower psychology", because we had not dealt with the O stirling, free of bank iers. Extracts from the problems of legal liability if a patient were unintentionally or wilfully to mislead the questioner about her condition. No doubt there are owl;dg; ment is made. it tha snurce is outside the organisational prcblems to sort out, although we doubt that they are very 5 different from those associated with the 10-day rule. Our surprise is om thMuthor or occasioned by the quaint thought that we should be the right body to do 'CTION BOARD 3 ) M l

b h L g mm-W\\$ l ,/ I / Jack has always advocated radiation safety which led, naturally, to his participation in the f 410 CFR Compliance Petition e Health Physics Society. He joined the Society in l On October 23. 1985, Al Tschaeche sent the 1959 and was one of the early diplomates of the t American Board of Health Physics, being certifie7j U.S. NRC a Petition for Rulemaking in which he l comprehensively in 1960. Jack has remained l proposes that " full compliance by a licensee with i' active in the Health Physics Society through the , the Commission's regulations in 10 CFR, and years, being treasurer of the Northeast Texas particularly with the regulations set forth in Chapter from 1961 to 1963, serving on the 10 CFR 20. is evidence acceptable in a court of Board of Health Physics from 1974 to 1977 and as law that the licensee was not n,egligent, and that President of the Great Lakes Chapter 1984-1985. the Commission's regulations must be violated or In April 1985, Jack was honored by the Great the standards of 10 CFR must be exceeded before Lakes Chapter which presented him the 51arie a prima facie case is pleaded on the issues of Curie Award. negligence and causation in any action to the Bill further noted that "The close working extent that the action is based upon injuries relationship (of medical physicists) with physi-claimed to have resulted from ionizing radiation cians .. has been carefully and painstakingly exposure." nurtured over the years by perceptive physicists In support of his Petition. Str. Tschaeche and physicians who have recognized that each points out that our national resources "are being group had much to gain from a collegial working recklessly, wantonly, and uselessly squandered relationship. Paramount in this nurturing on radiation injury claims cases. . against process have been the efforts of Jack Krohmer NRC licensees who have demonstrably complied over the past 30 years: in presenting the with the Commission's regulations." His particu-Coolidge Award, the AAP51 is validating Jack's lar complaint is with "what if" arguments filed in long-held belief that physicists and physicians opposition to experience and data, working together are a much stronger team than Should you be similarly concerned about how is either group working apart." the courts deal with the issue of licensee com-One of his most significant contributions has pliance, Str. Tschaeche urges you to express been his participation with the American Board those concerns to the NRC. Should you wish to of Radiology. Jack has participated in the read the full petition, contact: A.N. Tschaeche, American Board of Radiology examinations since 2277 Rio Linda Lane, Grand Junction, Colorado 1961 and has been a member of the Physics Com-81503. 8 mittee of the Board since 1967 and its chairman since 1976. In 1981 he was elected to the position of trustee of the ABR, the first and only non-NBS Cooperative ReSearch Programs physician to hold such a title on any medical specialty board, lodustrial Radiation Programs The NBS Center for Radiation Research is look-Jack has also been active in other societies. During his tenure as President of the American inE for private firms and organizations interested Association of Physicists in 31edicine, major in establishing Research Associate Programs to advances were made in reuniting the program-pursue cooperative research ventures with NBS in the area of industrial radiation measurements. matic efforts of the AAPat and the Radiological Research will be aimed at the enhancement of Society of North America, as evidenced by the November joint meeting. quality control methods used in high-dose, fon-George W. Cattendine, Jr. i:ing-radiation processtng of foods, medical de-a vices, electronic components, poinmers, *etc. Research areas include radiation chemical mech-anisms and kineti studies of chemical dosimetry 1986 HPS Summer School systems. Experimental techniques available at Plan now to attend the 1986 Summer School on NBS include transmission and fluorescence External Dosimetry from June 23-27, at Pennsyl-spectrophotometry, chemiluminescence photome-vania State University in State College, Pennsyl-try, fiber optics analysis, microcalorimetry, vanis. Academic Dean Rodger W. Granlund has pulse radiolysis and conductivity measurements. assembled an outstanding Curriculum Advisory A variety of x-ray and gamma-ray sources and Committee with members Larry Cross, Tom Gesell, electron accelerators also are available. Glen Hudson, Jerry Rosen, Steve Sims, Bob Organizations interested in setting up such a Wynveen, and Craig Yoder. A schedule of lec-collaborative research program should contact: tures and speakers will be included in upcoming William 31cLaughlin, C216 Radiation Physics HPS Newsletters. Tuition for the 1986 Summer Building, National Bureau of Standards. School is $375. Dormitory roota rates are $14.75 Gaithersburg, Staryland 20899, Ph. 301-921-2201. per person per day for single occupancy and $10.50 per person per day for double occupancy Effects of Radiation on Food Programs (excluding meals). The NBS Center for Radiation Research is Any questions concerning local arrangements looking for organizations interested in sponsor-for the Summer School can be directed to Peter ing Research Associate Programs for cooperative Collopy at Ph. 412-578-3221. studies of the effects of ionizing radiation on John R. Fra:ter foods. Specific topics will include chemical 22 HP5 Netustetter lanuars 1986

x /, . /t 'p Radiation Exposure Limit May Be Reduced & O h Hy George Lobsenz As a ress, separate expose 5 limits for some body parts, such as P") uen. w, The Nuclear Regulatory Com* external radiation to hands and feet. mission, citing improved knowledge would be tightened. Exposure limits % of radiation s health effects, has would be relaxed in other cases. VL proposed the first major revision in such as radioactive elements atV Q its radiation-exposure limits in sorbed by many internal organs. in addition, NRC experts said unpred hwWge led Gem to { changes, updating radiation-protection standards first u occupaW air-concentra-issued by the agency in 1957, would tion lintits fw some radioactive ma-apply to all activities regulated by terials, including uranium. Limits the NRC, including nuclear power plants and nuclear-fuel fabrication plants. Q n7g ggy[} The proposals, subject to public r comment until April 21, would pri-r [fnar((/ adecf nr t' marily affect nuclear-industry work-J/ ers by lowering occupational-expo. gyg[gg7 fygg sure levels for some radioactive materials, such as uranium, com-gg7/gggg* monly used in nuclear-fuel facilities. Exposure limits for the average American, however, would stay at the same level, about one-tenth the for uranium would be five tim 53 allowable exposure for a nuclear-in. lower under the new regulations. dustry worker. "Certain types of radioactive ma-Experts estimate that the aver-terial are more efficient in causing age American receives 100 mi!!i-cancer than previously thought,* rems of radiation exposure from said Robert Alexander, of the radioactive elements that naturally NRC's Division of Radiation Pro. occur in the environment, such as grams and Earth Sciences. radon gas released from under- "Also, we have learned some ground uranium deposits. chemical compounds remain in the A rem is defined as any radiation lung and body Icager than previous-desage that produces a biological ly thought," he said. effect approximately equal to me An NRC notice in the Federal roentgen of X-ray or gamma-ray Register said that, because of the radiatim. Under the proposed regulations, new regulations, "some small de-an NRC-hcensed operation would creates are expected in the number face penalties d it emitted radiation of workers espr=d at the higher exposang an average American to levels and in de doses receivd by more than 500 millirems a year. A Gose wwkers engaged in milling facility would have to report any and fabrication of uranium fuel." exposure greater than 100 milh-The M @tims also g. rems suffered by an average per-h ha e a to, ' s EINiwE " dose-averaging

• pro-visions that allowed workers to ex-y ex posure limit of 5,000 millirems a - ceed yearly radiation limits as leg year, the same as under the previ-as their lifetime exposure limit was ous regulations.

not exceeded. In its place, the NRC llowever, the NRC said im. wmld approve, on an individual ba-proved understanding of radiation's sis, "special exposure

• activities health effects and modern computer that might result in higher than per-technology enabled experts to set missible yearly doses.

new more accurate linuts for indi-e Establish lower radiation limits vidual body organs such as the lung, for women working in the nuclear breast and reproductive organs, industry who voluntarily notify em- , among others. ployers that they are pregnant. - - -}}