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3 Scientific Basis for Radiation Protection
Pages 75-96

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From page 75...
... The committee explains why it cannot provide a quantitative assessment of the economic impacts. Instead, the committee offers its assessment of whether knowledge from low-dose radiation research can affect the decision-making frameworks in the federal regulatory system and how (Section 3.4)
From page 76...
... In the absence of clear evidence of risks at low doses of radiation, radiation BOX 3.1 Current Assumptions of the Radiation Protection System The radiation protection system does the following: 1. Estimates cancer risks resulting from low-dose and low-dose-rate expo sures based on interpolations from health effects observed in populations that were exposed to higher doses of radiation and to types of radiation that are different from those that may be of most relevance to the general population.
From page 77...
... The LNT model has provided an adequate fit to the data from several major epidemiological studies of cancer risk following radiation exposures, including the Life Span Study of the Japanese atomic bomb survivors. Although no alternative model has convincingly been shown to provide a better fit to these data (Hauptmann et al., 2020; NCRP, 2018a; UNSCEAR, 2020a)
From page 78...
... . The only dose-response curve that predicts more risk at low doses than the linear model is curve "b." Any divergences from the LNT model imply that the current radiation protection system either overestimates or underestimates risks at low doses.
From page 79...
... , but radiation dose estimates were not available in that study.3 3 As discussed in Chapter 5, genome sequencing studies have identified genomic signatures in cancers that suggest specific, non-radiation causative agents for individual tumors (Alexandrov et al., 2020)
From page 80...
... is the lead federal agency responsible for establishing human health and environmental radiation standards for air, surface water, drinking water, uranium mill tailings sites, and deep geologic repositories.4 Various laws authorize other federal agencies to set regulatory limits and issue guidelines to protect the public and workers from exposure to ionizing radiation. The authority of a federal agency to administer those limits and guidance is rooted in statute and tends to vary depending on the setting in which radiation exposure occurs.
From page 81...
... NRC or other federal agencies, such as X-ray equipment, some accelerators, and some naturally occurring radioactive material. OSHA's limits for workers vary by industry.9 The Department of Defense is responsible for military exposure and remediation as well as for setting requirements to operate in environments that could expose personnel to low doses of ionizing radiation.
From page 82...
... ICRP and NCRP recommendations are based on scientific consensus publications such as the National Academies' Biological Effects of Ionizing Radiation (BEIR) committee reports and reports issued by the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR)
From page 83...
... Uncertainties in low-dose radiation risks raise questions about whether dose limits and guidance levels are set appropriately or whether they are set too high and therefore do not sufficiently protect workers and members of the public or too low and therefore result in unnecessary costs to reduce radiation exposure. Federal agencies have been formally challenged by members of the public about the use of LNT to set radiation protection standards at least twice in the recent past.
From page 84...
... The U.S. NRC regulatory limit for the annual exposure to radiation workers is 50 mSv total effective dose equivalent, with an additional limit for the lens of the eye at 150 mSv per year.
From page 85...
... 3.3.2 Decision-Making Frameworks for Radiation Protection Risk-based regulation is a particular strategy or set of strategies that regulators use to target their resources at those sites and activities that present threats to their ability to achieve their objectives. Economic analysis of the impacts of the proposed change (Step 1 in the regulatory development process described in the previous section)
From page 86...
... The committee simplified Lave's typology into four basic frameworks -- negligible risk, lowest feasible risk, net risk, and cost-benefit balancing -- and discusses each framework briefly below. Although these frameworks are only part of the radiation protection risk governance, this discussion illustrates the importance of low-dose radiation knowledge and therefore research in low-dose radiation health effects to inform radiation protection regulation and guidance.
From page 87...
... The concept of negligible risk originated in food law where exceptions were needed to allow minute concentrations of chemical additives or contaminants in food or animal feed that pose at most a negligible risk of cancer to the public. In food law the threshold for fatal cancer was defined as a 1 in 1,000,000 chance on a lifetime basis when an LNT model is used to compute risk (FDA, 1977)
From page 88...
... Concerning fatal cancer risk, OSHA has not precisely defined a level of negligible risk but has indicated that cancer death risk levels above 1 in 1,000 for a career are "significant" enough to justify rulemaking, and risks below 1 in 100,000 might be considered safe (Sunstein, 2002)
From page 89...
... -- of drinking water is associated with both health benefits and health risks. In the Safe Drinking Water Act amendments of 1996, Congress required EPA to weigh such "health-health tradeoffs" when setting maximum contaminant levels (Sunstein, 2002)
From page 90...
... Industry challenged OSHA's definition of feasibility in litigation about new standards to limit worker exposure to benzene and cotton dust. Industry argued that OSHA should be required to support a new health standard with a quantitative risk assessment of worker exposures and with a costbenefit analysis of alternative standards.
From page 91...
... In some laws, Congress expressly uses cost-benefit language. In the Safe Drinking Water Act Amendments of 1996, Congress directed EPA to establish a drinking water standard for radon based on a novel cost-benefit approach.
From page 92...
... NRC may consider a cancer premium on the basis that public willingness to pay to prevent a cancer death could be larger than a death from occupational injury. As knowledge of low-dose radiation health effects advances to quantify non-cancer health effects (e.g., cardiovascular effects, neurological disorders, and other effects)
From page 93...
... . To the committee's knowledge, comprehensive estimates of overall costs to federal agencies and society to comply with current radiation protection standards and guidelines are unavailable.
From page 94...
... When adjustments in radiation protection standards and guidance are proposed based on new information, agencies can estimate the economic impacts of the changes and perform benefit-cost and cost-effectiveness analyses of alternative measures. These analyses can also be informed by econometric studies of the social impacts of low-dose radiation exposures on health or other endpoints (e.g., education)
From page 95...
... population from the use of radiation while making the most effective use of resources. Uncertainties in low-dose radiation risks raise questions about whether dose limits and guidance levels are set appropriately or whether they are set too high and therefore do not sufficiently protect workers and members of the public or too low and therefore result in unnecessary costs to reduce radiation exposure.
From page 96...
... Costs for complying with radiation protection standards and guidelines, administering radiation compensation programs, or for using technologies that utilize radiation in medical and other applications are balanced with the health, societal, and other benefits based on current scientific understanding of low-dose radiation exposures. These costs are substantial but to the committee's knowledge, comprehensive estimates of overall costs to federal agencies and society to comply with current radiation protection standards and guidelines are unavailable.


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