Part 1 of 5
Comments on ICRP-2005
C-1 Task Group Report
The report states in its
Executive Summary, page 9, lines 16-20:
The present document has been preceded by other, recent reports,
notably those of the UNSCEAR and the
Thus, this report, like
the NCRP reports it cites, does not examine, or even reference, the massive
body of work that has demonstrated the lack of harmful effects and the presence
of beneficial effects from low dose irradiation, for example the work of those
scientists listed in the example references.
These scientists are highly respected by their peers, work at creditable
institutions, and their reports are published in mainstream peer-reviewed
science journals. This evidence has not
been refuted. The Task Group, by
ignoring and discounting this scientific evidence, does not present a valid
basis for its conclusions.
In addition to ignoring
the most relevant evidence, the ICRP and similar advisory reports do not even
demonstrate that their self-restricted data pool and analyses support their
conclusions. They speculate that various
processes and phenomena have been “suggested” or “postulated” that “may induce”
or “would enhance” various effects and “thus facilitate the accumulation of the
requisite number of genetic events to produce a cancer.” Then they quickly add that “most types of
cancer have not been associated with specific DNA repair defects.” (page 115,
line 21). And in “Conclusions” (p.189,
lines 16-18) they assert:
There is no direct evidence, from either epidemiological or
experimental carcinogenesis studies, that radiation exposure at doses on the
order of 1 mGy of less is carcinogenic, nor would any be expected…
But, content with that
degree of support, they state (page 12, line 9) as “The conclusions of this
report” that “there seems to be no particular reason to factor the possibility
of a threshold into risk calculations for purposes of radiation
protection. The LNT hypothesis…remains a
prudent basis for radiation protection at low doses and low dose rates.”
To repeat: The Committee 1 Task Group report does not
even claim to have reasonably
established that low-dose radiation is harmful. In this, it is in full accord with previous
advisory reports on the subject. For
example, NCRP-121, states:
Few experimental studies, and essentially no human data, can be said to prove, or even provide direct support for the concept…It is conceptually possible, but with a
vanishingly small probability, that any of these effects could result from the passage of a
single charged particle…It is a result of this type of reasoning that a linear
non-threshold dose response relationship cannot
be excluded. (p. 45,
emphasis added)
The French Academy of Medicine states:
The hypothesis of the risks of cancer induced by low doses and
dose-rates is founded on…the linear no-threshold (LNT) assumption. This
hypothesis conflicts with itself and has many scientific objections and it is contradicted by experimental data
and epidemiology. ..[the Academy]
denounces utilization of the linear no-threshold (LNT) relation to estimate the
effect of low doses… (Dec
2001)
The relevant professional societies, the American Nuclear Society and the Health Physics Society, have also supported this stance in
carefully considered Position Statements:
It is the position of the American Nuclear Society
that there is insufficient scientific evidence to support the use of the Linear
No Threshold Hypothesis in the projection of the health effects of low-level
radiation. (PS-41, June 2001)
In
accordance with the current knowledge of radiation health risks, the Health
Physics Society recommends against quantitative estimation of health risks
below 5 rem in one year. (Public Statement on Radiation Risk in
Perspective, Jan 1996)
Both societies agree that:
“Below 10 rem…risks of health effects
are either too small to be observed or are non-existent.”
The fact that low-dose radiation is harmless and
often beneficial is not a new or minority opinion.
It
has been widely reported in the science media, and recently in the general
media, e.g., Fortune (Jun 03), Discover (Dec 02), American Spectator (Jul/Aug 02), Crisis (Jun 02), Wall St.
Journal (Dec 19, 03), and Boston
Globe (Dec 12, 03). The
proto-scientist Paracelsus said in
1540, “Nothing is poison but the dose makes it so.”
Within
months of Roentgen’s discovery of x-rays, reports began appearing in scientific
journals on the use of x-rays to cure infection. It was found even then that the radiation was
not strong enough to kill the bacteria directly, and that its effectiveness
results from stimulation of the immune system.
This
phenomenon—toxicity at high levels and stimulation of healing at low levels—is
a nearly-universal biological process, which has been called hormesis. Low dose radiation consistently shows that
it acts to reduce cancer incidence.
Calabrese
and Baldwin report (Nature 421, 691,
2003) “thousands of studies demonstrating hormesis…we see it across the whole
plant and animal kingdom… and at essentially every endpoint…the hormetic model is not an exception to
the rule—it is the rule.”
Jocelyn
Kaiser’s four-page News Focus on hormesis (Science
302, 376, 2003) contained a full-page sidebar documenting the phenomenon’s
occurrence with ionizing radiation.
There is voluminous data showing the beneficial
effects of low-dose radiation.
T.D.
Luckey, Chairman Emeritus, Biochemistry, U. Missouri-Columbia, wrote two books,
Hormesis with Ionizing Radiation
(1980) and Radiation Hormesis (1991)
with more than 2000 references validating hormesis in plants, animals and
humans.
James
Muckerheide, as Chair of the ANS Biology and Medicine Division Committee on Low
Level Radiation Health Effects, organized a series of sessions on Low-Level
Radiation Health Effects at ANS annual meetings, 1994-2003. (See http://www.radscihealth.org/rsh/realism/ANSsessions1994-1999a.doc)
Radiation,
Science, & Health, has amassed and evaluated several thousand documents on
the health effects of low-dose radiation (See http://www.radscihealth.org/rsh/docs ).
Edward
Calabrese and colleagues at the Northeast Regional Environmental Public Health
Center, U Mass School of Public Health,
publish a newsletter, Biological Effects
of Low-Level Exposures, and run an annual international conference on
Non-Linear Dose-Response Relationships (See http://belleonline.com ).
Evidence
that radiation may be essential to life is shown by experiments in which
organisms were shielded from background (e.g., H. Planel et al., Health Phys. 52, 571, 1987) and in which organisms were cultured in potassium with the K-40
depleted (T.D. Luckey, Radiat. Res. 108, 215, 1986).
Populations
that live at the lowest levels of natural background radiation have higher
cancer rates and shorter lifespans than populations that live in areas with
moderate and high background radiation levels.
The nuclear medicine pioneer, Rosalyn Yalow, Nobel Laureate in Physiology or Medicine, asserted:
No reproducible evidence exists of harmful effects from increases in background radiation three to
ten times the usual levels. There is no
increase in leukemia or other cancers among American participants in nuclear testing, no increase in
leukemia or thyroid cancer among medical
patients receiving I-131 for diagnosis or treatment of hyperthyroidism, and
no increase in lung cancer among non-smokers exposed to increased radon in the home.
The association of radiation with the atomic bomb and with
excessive regulatory and health physics ALARA practices [As Low As Reasonably
Achievable] has created a climate of fear about the dangers of radiation at any
level. However there is no evidence that radiation exposures at the
levels equivalent to medical usage are harmful.
The unjustified
excessive concern with radiation at any level, however, precludes beneficial uses of radiation
and radioactivity in medicine, science and industry. (Mayo
Clinic Proc 69:436-440, 1994)
Hugh F. Henry at
A
significant and growing amount of experimental information indicates that the
overall effects of chronic exposure (at low levels) are not harmful…The
preponderance of data better supports the hypothesis that low chronic exposures
result in an increased longevity… Increased vitality at low exposures to
materials that are markedly toxic at high exposures is a well-recognized
phenomenon. (JAMA 176, 27 May 1961)
The
“Wingspread Conference” August 1-3,
1997, concluded:
In a
surprise move, leading US and international scientific experts agreed in an
historic accord that an increase in cancer has not been observed at radiation
exposures below 10,000 millirem given to the whole body in a short time.
Prof. W.V. Mayneord,
former member of UNSCEAR and ICRP, wrote:
I have
always felt that the argument, because at higher values of dose an observed
effect is proportional to dose, at very low doses there is necessarily some
effect of dose, however small, is nonsense (Radiation
and Health, p.140, 1964).
These and many other
reports also establish that attributing damage where none exists can cause, and
has caused, serious harm in a number of ways.
Telling people who have
received trivial doses of radiation working with radioactive materials, or from
radon in their homes, or from mammograms and or medical procedures, has already
caused untold damage and initiated extensive legal proceedings and damage
compensation program based on false scientific premises.
Attributing a special
hazard to any hypothesized terrorist action that might involve radiation
converts a relatively harmless situation into a potentially life-threatening
panic and invites the very situation it claims to protect us from..
Robert Brent, in
“Commentary on JAMA article by Hujoel et al.” in the current Health Physics (2005 Vol. 18, No. 4, pp.
379-381) addresses the false
premises in the subject JAMA article (2004 Apr
28;291(16):1987-93) that
applies the ICRP claim that even trivial radiation doses can be harmful in
assessing the risk to the fetus of dental x-rays. Brent states, correctly, that “the extensive
animal and human literature refutes the claim of the authors…” Brent deplores the harm caused by such
premises.
It will promote anxiety in the dental patient population, provide the
news media with alarming information, and provide American trial lawyers with
another area of litigation.
Such false claims are
repeatedly made, demonstrating the high cost of presenting this false premise
of harm as scientific fact, where none has been shown to exist. It is disingenuous of ICRP to “see no
particular reason” to refrain from promulgating such false premises.
The Harmful Fallacy of Collective Dose
Once one assumes that any
small amount of radiation is harmful, then the concept of “Collective Dose”
arises. Small individual doses received
by a large population are added up, and hundreds or even thousands of
radiation-induced deaths are “predicted.”
So, radiation protection policy uses collective dose as a prime measure
of the severity of a casualty, or the efficacy of “good plant operation.” Such
use of collective dose has been repeatedly condemned as scientifically
indefensible. Yet current policy
presumes that, in the absence of more data, this is the prudent course.
NCRP-121
specifically warns that collective dose should not be used to predict death or
injury from low-dose radiation:
The summation of trivial average risks over very large populations or
time periods…has produced a distorted image of risk, completely out of
perspective with risks accepted every day, both voluntarily and involuntarily. (p.58)
And again:
…it is recommended that regulatory limits not be set in terms of
collective dose…When the uncertainty in the number of individuals …is large…
collective dose should not be used as a surrogate for risk, even at relatively
high levels of individual radiation dose. (p. 62)
And the Health Physics Society, in its March
1993 Position Statement, emphasized in bold-faced type:
We strongly recommend that dose limits be applied only (sic) to
individual members of the public, not (sic) to the collective dose to
population groups.
The French Academy of Medicine quoted and concurred with the above
statement from NCRP-136, and stated in a press release 4 Dec 01:
[the Academy] associates with
many international institutions to denounce improper utilization of the concept
of the collective dose to this end. These procedures are without any scientific
validity, even if they appear be convenient to administrative ends.
Zbigniew Jaworowski, MD, PhD, the noted member and former chair of UNSCEAR,
wrote in “Radiation Risk and Ethics” (Physics
Today, Sept 1999, 24-29) that use of collective dose:
…was introduced in the early 1960s…the concept is
still widely used, although both the concept and the concern [about harmful
hereditary effects] ought to have faded into oblivion by now…Individual doses
cannot be additive over generations, simply because humans are mortal and the
dose dies when an individual does. Similarly,
individual doses cannot be added for individuals of the same generation because
we do not contaminate one another with a dose that we have absorbed…
If harm to the individual is trivial, then the
total harm to members of his or her society over all past or future time must
also be trivial—regardless of how many people are or will have been exposed.
Part 2 of 5
The
Committee 1 Task Group Report explicitly establishes common purpose with the
recent NCRP-136. NCRP-136
report uses the same methods to scientifically justify the LNT. Our comments on that report apply equally to
this report:.
NCRP Committee 1 has misrepresented the scientific
data to support its false premise that low-dose radiation (LDR)
might be harmful.
But the
data say otherwise.
The Committee:
1.
Produced voluminous irrelevant and
misleading data to support the linear no threshold (LNT) premise.
2.
Selectively misrepresented and obfuscated
data that do provide highly statistically significant and consistent
evidence of LDR benefits, and null dose-response effects, that contradict the
LNT.
3.
Failed to consider the
voluminous scientific literature, submitted to them by the
scientific community, including RSH, that consistently contradicts the
unsupported LNT premise.
The
NCRP’s position leads to extreme radiation protection policies requiring
enormous public expenditures for no
public health benefit.
The C-1 Task Group Report promulgates false and misleading
claims. For
example (p. 10 lines 2-6):
“There is some evidence
of increased cancer risk associated with exposures on the order of 10 mGy…
Also, the risk of mortality and morbidity from all solid cancers combined is
proportional to radiation dose down to about 100 mGy,”
Results
from few, unconfirmed, studies indicate harm in cases of very high,
instantaneous, dose rates, in the range of 100 mGy. This is primarily from the weak, unconfirmed,
epidemiological study of the atomic bomb survivors, and the claims of damage to
fetuses from moderate x-ray doses.
However,
hundreds of medical and biological research experiments consistently
demonstrate that whole-body x-ray and gamma ray doses in the range of 5 to 500
mGy, that are extended over a minute or more, consistently stimulate positive
biological responses. These responses
are shown to consistently cause medical and health benefits. Somewhat higher doses have been used to
consistently enhance immunological capability to successfully treat infections
and inflammatory diseases.
These
results have been demonstrated since the 1910s, although accurate doses at the
applicable low doses were then not well defined. However, such results have been confirmed
thousands of times over the last 80+ years, with hundreds of experiments in
recent decades, which apply current molecular biology, immunology, physiology
and epidemiology to demonstrate stimulatory, generally beneficial,
effects.
For
example, J.B. Murphy, in the Proceedings of the US National Academy of Sciences
(PNAS) in 1920, in one of many reports by Murphy and others in the 1910s and
‘20s, in studies of immunology in preventing cancer, moderate doses of
radiation were shown to suppress lymphocytes, which caused increases in
cancers. Increasing doses caused
increasing suppression of lymphocytes, and increasing cancers.
However,
at low doses, the lymphocytes were stimulated.
This caused DECREASES in cancers compared to unexposed controls – in one
case, 96.5% ‘takes’ in controls from inoculations with cancer cells vs. 50% in
the exposed groups, and another case, 75% in controls vs. 25% in exposed.
Such
results have also been consistently reported and confirmed in recent
decades. E.g., studies by K. Sakamoto
and colleagues demonstrated enhanced stimulation of mice and humans with doses
in the 5 to 30 cGy range. Hundreds of
experiments by S.Z. Liu and colleagues have consistently produced equivalent
results. [See examples in references below.]
The
“data” on epidemiology and biology presented in this report (Chapters 2-5)
reference many papers that are not relevant to the evaluation of the health
risks of low-dose radiation. Many
describe in vitro studies that report
results in cells that are not relevant to the dose response in immunologically
whole organisms.
Others
address high-dose and high-dose-rate conditions. But organisms respond totally differently
than they do to low-dose irradiation.
In
addition; the report suppressed the thousands of relevant results of research
that demonstrate and repeatedly confirm actual biological and epidemiology dose
responses in whole organisms, which are conducted at relevant doses and dose
rates. See, for example, a few of the
references to more extensive work by Ed Calabrese and colleagues. These papers document the importance, the
many studies, the consistent results, and the failure to adequately consider
the research that addresses the relevant doses and sample sizes, and the
appropriate animal models and human exposure data.
The TG Report also provides false premises. For example, it states, (p. 10 lines 12-15):
“The fundamental role of
radiation-induced DNA damage in the induction of mutations and chromosome
aberrations and the apparent critical involvement of aberrations and mutations
in the pathogenesis of cancer provides a framework for the analysis of risks at
low radiation doses and low dose rate exposures (Chapter 3).”
This premise has been repeatedly and consistently demonstrated to
be false in recent decades. [See examples in references below]
Direct and indirect radiation-induced DNA damage has been shown to
be irrelevant in assessing radiation risk because, in the biology of
immunologically whole organisms and animals, the amount of DNA damage from
background radiation up to about 100 times background radiation levels is
insignificant compared to the normal metabolic DNA damage rates, for both
single and double strand breaks.
This damaged DNA is continuously and consistently repaired, or in
very few cases is not repaired. However,
this is a function of the damage control system, not of low radiation
doses. The chance that a
radiation-damaged cell would progress to cancer remains an insignificant
fraction of the normal quantity of damaged cells.
Damage to the damage-control and repair systems are primarily due
to high stress events and conditions. This does apply to high-dose-rate
radiation among many other stressors. Or
it is due to reduced repair capacity caused by aging or other limitations in
the organism from disease or genetic conditions.
At high doses, the damage control and repair system are
affected. Specific genes and other
response factors are stimulated to undertake “emergency repairs” which are
error-prone. This is the same as the
toxic effect of essential nutrients at high doses. Recent data demonstrate that there are
different subsets of genes expressed than are stimulated by low radiation
doses.
At low doses, the organism delays cell cycles and initiates other
factors to produce error-free repairs, and to eliminate damaged cells that
strengthen the organism immunologically and physiologically. This is equivalent
to essential nutrients, exercise, heat and other factors.
Of course, damage control fails to prevent damage in some
instances, but a healthy organism or animal prevents such cells from
affecting the organism by eliminating them (through apoptosis or necrosis) or
preventing cell cycle progression to division.
Although such cells do occasionally “escape” such controls, there are an
insignificant number of such damaged cells caused by radiation-induced damage
from low doses (i.e., less than about 1 Gy) than from normal causes.
The above quoted TG Report statement further begs the issue of the
known lack of the linkage between mutations and chromosome aberrations to cause
cancer in its use of “apparent” as a qualifier.
In fact, there is no causal linkage beyond the equivalent traditional
case that “galoshes cause colds.” This
is a misleading presentation to foster a perception to justify the LNT. People in high natural background areas and
occupationally exposed populations have shown increased mutations and
aberrations with NO increase in cancers.
This false premise substantially misleads persons concerned about
radiation protection to believe that a low dose of radiation can be hazardous
in a linear relationship from high dose experience. It fails to reflect the
fact that biology cannot have an adverse linear response to low doses of toxins
or physical stressors such as heat and ionizing radiation to which whole organisms
are normally exposed. Such a condition
would make life unsustainable.
In the case of radiation, it would indicate that life could not have
succeeded in prehistoric times, when background radiation was much greater, and
that high dose areas of the world would destroy or debilitate populations. But in fact, people living in these areas do
not have chronic illnesses or conditions. They are not deformed or short-lived.
Their health conditions are consistently better where background radiation is
higher.
This is
necessarily true when such stressors are essential to biological
functions. This is the case with
radiation since “radiation protection” from background radiation to levels at
and below low natural background levels, at roughly 1 mGy, has been shown by
e.g., H. Planel and colleagues in Comptes Rendus in the 1960s-1980s, summarized in 1987 (Health Phys, 52:571-8),
and many others to cause physiological debilitation
in such organisms.
However, even
with stressors that produce purely damaging insults, the biological response at
the lowest doses that would cause a response is to initiate an
“over-compensation” to the damage. This
results in a net increase in health and physiological conditions, not unlike
the damage caused by “low to moderate doses” of physical exercise.
The
fundamental response to radiation is not related to direct or indirect
radiation-induced DNA damage. The
fundamental response to radiation is the biological stimulation of enzymes,
genes, proteins, cytokines, and other biological control molecules and cells
that constantly attempt to maintain optimum biological conditions.
Any DNA
damage from low and moderate radiation doses is completely incidental to the
primary and highly significant biological response effects in immunologically
whole organisms directly caused by low- and high-dose radiation exposure.
Just as
Murphy showed in the PNAS in 1920 with the difference in low-dose and high-dose
response of lymphocytes, current molecular biology has repeatedly shown and
confirmed that there are completely different responses to high-dose and
low-dose radiation exposures. These
conditions alone establish that there can be no “linear” response that provides
a continuous response between these wholly different biological processes. This is, in fact, consistent with the current
biological knowledge that demonstrates that bi-phasic responses are the default
condition in biology, physiology and health.
Recent
studies have shown that there are substantially different sets of genes and
other molecules that are stimulated at high-doses vs. low-doses; in addition to
specific genes, enzymes and other factors that respond in completely opposite
directions (either stimulation or suppression) when doses at moderate
dose-rates are higher or lower than a dose in the range of 20-50 cGy. These differences are equivalent to the
stimulation vs. the suppression of lymphocytes shown by Murphy in the 1920 PNAS
report, and in hundreds of studies since.
This includes the successful treatment of infections, etc., before the
advent of antibiotics and other drugs that were favored by the commercial
medical establishment and government agencies.
This is
similar to (and anticipates) the current Codex effort to ignore evidence of the
health benefits of vitamins and minerals and nutritional supplements. These initiatives will similarly constrain
access to these supplements in favor of dispensing by medically-controlled
prescription at high cost, and to limit quantities to “minimum daily
requirements” which are generally considered to be less than adequate to
stimulate immunological and physiological conditions that are known to prevent
disease and recover health.
In
addition, the Task Group Report uses the results of many in vitro studies to claim that their response supports the
justification of a linear dose-response for cancer and other adverse health
effects.
Cells
in culture do not have the immunological functions and cellular repair
capacities of immunologically whole organisms.
Therefore, their response to radiation doses does not reflect the
response of living organisms.
There
are dozens, if not hundreds, of factual errors and misrepresentations that
could, and should, be addressed with specific applicable contradictory
scientific references that have not been included in the report. But this
cannot be achieved in this limited context.
It
is also useful to consider that there are hundreds of active scientists that
have published the current literature that contradict the results and
conclusions contained in this report.
Despite the hundreds of such papers in mainstream radiobiology and other
major biology and medicine journals, they have chosen NOT to comment on this
report.
It
is reasonable that they see this report as having no interest in addressing the
relevant science. It is seen instead, as
with the NCRP-136 Report, a biased exercise to rationalize and fabricate
support for the LNT; and that questioning this mandate may be hazardous to
their government-supported research and institutions. It may be seen as “trying to teach a pig to
sing.” It is not only a waste of time,
it annoys the pig.
Part 3 of 5
Comments
on ICRP’s
Proposed New Radiation Regulation Guidelines
The ICRP report will be
considered by many people to be the ultimate authoritative judgment of the
international scientific community on the matters it discusses. It is important to recognize that this is
simply not true. ICRP reports express
the opinions of a self-selected group of radiation protection specialists whose
scientific judgment differs markedly from mainstream biologists and medical
researchers. It is neither appropriate
nor necessary to speculate as to the biases or agendas of the ICRP committee
members. But it is vitally necessary to
view the conclusions of the ICRP reports in light of relevant research findings
and conclusions of the broader scientific community. Our comments are presented in that
context.
It is also pertinent to
note that ICRP has no competence or responsibility to consider the practical or
economic impact of its recommendations.
When it concludes that “The LNT hypothesis…remains a prudent basis for radiation
protection” we should note that this sentence is preceded, not by a statement
that this conclusion is derived from the scientific evidence, but by the casual
rationale that “there seems to be no particular reason to factor the
possibility of a threshold into risk calculations for purposes of radiation
protection.” That is an opinion that
calls for input from outside the expertise of the ICRP.
Moreover, the question of
whether or where to apply a threshold is less important than the need to
repudiate the false idea, now being promulgated as official scientific truth
that even the tiniest amount of radiation poses a threat that must be reduced
if at all possible. ICRP tells us its
mission is to create a mindset that makes us ask of every radiation exposure,
“Have I done all that I reasonably can to reduce these doses?” That question puts radiation reduction,
which it misleadingly calls “optimization,” ahead of public health and
safety. We should not concur in that
mission.
ICRP-2005
is Harmful and Unnecessary Step Backwards
The proposed ICRP 2005
document is ill-advised and harmful, both in concept and detail. It makes no mention of the vast amount of
literature that shows, to quote NCRP-136, “it is important to note that the
rates of cancer in most populations exposed to low-level radiation have not
been found to be detectably increased, and that in most cases the rates have
appeared to be decreased.” Supporting
data for this statement have been published in the professional literature and
presented repeatedly to various regulatory bodies. See, for example, http://www.radscihealth.org/RSH/docs
Perhaps mindful of this
fact, ICRP drops all previous effort to justify its requirements on the basis
of risk. In fact, it offers little
justification at all for extending its regulatory arm down to a fraction of a
percent of natural background.
It concedes that “there is
no major problem identified with the practical use of the present system of
protection in normal situations.”
Despite this fact, the report virtually scraps all previous guidance and
proposes a new system, based on new principles, with new terminology and more
complex and more burdensome requirements.
No justification is given for these changes
It disguises the concept
of ALARA by calling it “optimization,”
stating that ICRP’s mission is to create a state of mind that looks at
every radiation exposure situation with the question: “Have I done all that I
reasonably can to reduce these doses?”
Since radiation dose generally results from people attending to
operations and equipment in a radiation zone, a regulatory incentive to
minimize such critically important safety functions actually works against
safety without producing any health benefit. We have many examples of this.
ICRP’s phobic attitude
toward radiation is shown by its continued insistence on treating even natural
radiation as a hazard, requiring that natural radiation be regulated when it is
considered “controllable” (e.g. radon and mill tailings) while ignoring even higher
doses (e.g. airplane passengers; dwellers in, or visitors to, high natural
radiation areas; medical therapy) that, for the present, it calls
“uncontrollable.”
The report warns against
misuse of collective dose, but then sets up requirements that will inevitably
increase its use in falsely “predicting” thousands of deaths were none would
realistically be expected. This is
particularly harmful in dealing with emergencies, where a minor event can be
made into a life-threatening panic, and rescue workers prevented by unwarranted
fear of radiation from doing their duty.
As a final insult to
science and common sense, the report suggests that regulatory authorities set
even lower values “but probably not by as much as a factor of ten.” This is after suggesting that where there may
be multiple dominant sources, still further restraints are advised.
The report also recommends
that a vast new research program be set up to determine the effects of low-dose
radiation on all non-human species, which would lead to waste of public
resources and even further constraints on our use of technologies involving
radiation.
We strongly recommend that
this entire report be rejected out of hand.
It is a scientific embarrassment and a harmful and unnecessary assault
on all beneficial uses of radiological technologies.
Recommendations
All that is really needed is to clarify current
regulations by adding a statement
such as “Doses below 50 or 100 mSv/year are not harmful and may be
beneficial. ALARA below those levels serves
no useful purpose and can be detrimental.”
Merely setting a threshold radiation dose is not
enough. It is important to repudiate
the false dogma that a single gamma ray can kill. Nearly every responsible organization writing
on radiation protection—the UK NRPB, the US NCRP, the Health Physics Society,
the American Nuclear Society, the French Academies of Medicine and of
Science—all have stated that in the presence of a large and widely varying
natural radiation background, it is clearly absurd to argue that even the
tiniest increase in radiation dose will cause a numerically predictable
increase in cancer and death, and must be avoided. Yet this repudiated argument is what we are
asked to accept in ICRP-2005. That
argument is at the root of the radiophobia that blocks rational discussion of
radiation protection. It must be
squarely faced and publicly be put to rest.
In addition, the concept of collective dose itself must
be repudiated. Amending current regulations
to add a phrase such as: “Collective dose should not be used as a measure of
excellence in radiation protection, nor should it be used to predict
detrimental effects such as illness or death.
The only meaningful doses are those to individuals.” The Chairman of the ICRP, Roger Clarke, has often
asserted unambiguously (e.g., 1 Oct 98 at http://hps.org/documents/controllable.pdf)
:
If the risk of harm to the health of the most exposed individual is
trivial, then the total risk is trivial—irrespective of how many people are
exposed.
It is essential that this
important principle be made crystal clear in all relevant regulations,
standards and practices.
Part 4 of 5 – References 1
Comprehensive
assessments of the scientific literature and current biology refute the biased
misrepresentation of selected “facts” and the suppression of valid data
provided in the Task Group report. For example:
Calabrese, E.J. (2005). “Hormetic Dose-Response Relationships in
Immunology: Occurrence, Quantitative Features of the Dose Response, Mechanistic
Foundations, and Clinical Implications,” Critical Reviews in Toxicology,
35:89–295. [207 pages]
Immune-system-related biphasic
dose-responses occur extensively, with over 90 different immune
response-related endpoints, induced by over 70 endogenous agonists, over 100
drugs, and over 40 environmental contaminants, including radiation,
reported in over 30 animal models, over a dozen mammalian and human cell lines.
Immune-system-related hormetic-like
biphasic dose-response relationships are common and highly generalizable. These
findings were generally recognized and explicitly discussed by the original
authors, often with consideration given to possible mechanistic foundations
as well as numerous clinical implications. Despite this recognition, the
overall widespread nature of
immune-related hormetic responses has been only little appreciated, with a
general lack of insight into the highly generalizable nature of this phenomenon
as well as the complex regulatory networks affecting biological switching
mechanisms that result in the hormetic responses.
Calabrese, E. J. and R. Blain (2005). "The occurrence of hormetic dose
responses in the toxicological literature, the hormesis database: an
overview." Toxicol Appl Pharmacol 202(3): 289-301.
This database of studies includes ~5600
dose-responses satisfying criteria for hormesis of over 900 agents, of which
radionuclides/radiation constitute 29% of the results. Hormetic dose-response occurs in animal
models in all age groups, across species, with a broad range of toxic
susceptibilities, in plants, viruses, bacteria, fungi, insects, fish, birds,
rodents, and primates, including humans. Endpoints include growth, longevity,
metabolic parameters, disease incidences (including cancer), performance
endpoints such as cognitive functions, immune responses, and others.
Quantitative strength of the evidence supporting hormesis is based on study
design, magnitude of the response, statistical significance, and
reproducibility. Comprehensive
biology/toxicology evidence shows hormesis to be the biological default
condition.
Calabrese, E. J. (2004). "Hormesis: from marginalization to mainstream: a case for hormesis
as the default dose-response model in risk assessment." Toxicol
Appl Pharmacol 197(2): 125-36.
Calabrese, E. J. (2004). "Hormesis: a revolution in toxicology, risk assessment and
medicine." EMBO Rep 5
Spec No: S37-40.
Calabrese, E. J. (2004). "Hormesis--basic, generalizable, central to toxicology and a
method to improve the risk-assessment process." Int J Occup Environ
Health 10(4): 466-7.
Calabrese, E. J. and L. A. Baldwin (2003). "The hormetic dose-response model is more
common than the threshold model in toxicology." Toxicol Sci 71(2): 246-50.
Calabrese, E. J. and L. A. Baldwin (2003). "Toxicology rethinks its central
belief." Nature 421(6924):
691-2.
Calabrese, E. J. and L. A. Baldwin (2003). "HORMESIS: The Dose-Response
Revolution." Annu Rev Pharmacol Toxicol 43: 175-97.
Calabrese, E. J. and L. A. Baldwin (2002). "Applications of hormesis in
toxicology, risk assessment and chemotherapeutics." Trends
Pharmacol Sci 23(7): 331-7.
“…in properly
designed studies the U-shaped hormetic response predominates and is more
fundamental.”
Calabrese, E. J. and L. A. Baldwin (2002). "Radiation Hormesis and Cancer." Human
and Ecological Risk Assessment 8(2):
327-353.
Data on radiation hormesis and cancer exist
consistent with and/or supportive of radiation hormesis. Biomedical
research provides mechanistic insight: low dose exposures activate immune
functions to prevent tumor development and metastasis; low doses of radiation
reduce mutagenic responses and induce endogenous antioxidant responses. This is consistent with epidemiological
data showing inverse relationships between background radiation and cancer
incidence, and with occupational epidemiological investigations in which
low-dose exposure groups display markedly lower standardized mortality rates
(in excess of the “healthy worker effect”) than controls.
Calabrese, E. J. and L. A. Baldwin (2001). "Hormesis: U-shaped dose responses and
their centrality in toxicology." Trends Pharmacol Sci 22(6): 285-91.
The fundamental nature of the dose-response
is neither linear or threshold, but rather U-shaped. When studies are
properly designed to evaluate biological activity below the traditional
toxicological threshold, low-dose stimulatory responses are observed with high frequency
and display specific quantitative features. …mechanistic evidence indicates that hormetic effects represent overcompensation in
response to disruptions in homeostasis that are mediated by agonist
concentration gradients with different affinities for stimulatory and inhibitory
regulatory pathways.
Calabrese, E. J. and L. A. Baldwin (2001). "Hormesis: A generalizable and
unifying hypothesis." Critical Reviews in Toxicology 31(4-5): 353-424.
Calabrese, E. J. and L. A. Baldwin (1999). "The marginalization of
hormesis." Toxicologic Pathology 27(2): 187-194.
Calabrese, E. J., L. A. Baldwin, et al. (1999). "Hormesis: a highly generalizable and
reproducible phenomenon with important implications for risk assessment."
Risk Anal 19(2): 261-81.
Calabrese, E. J. and L. A. Baldwin (1998). "Hormesis as a biological
hypothesis." Environmental Health Perspectives 106(Suppl 1): 357-62.
Calabrese, E. J. (1999). "Evidence that hormesis represents an "overcompensation"
response to a disruption in homeostasis." Ecotoxicology and
Environmental Safety 42(2):
135-137.
Liu, S. Z. (2003). "On radiation hormesis expressed in the immune system." Crit
Rev Toxicol 33(3-4): 431-41.
For mouse and human T lymphocyte functions
in the dose range of 0.01 to 10 Gy a J or inverted J-shaped curve is usually
observed. The cellular and molecular mechanisms of the enhancement of
immunity induced by low-dose radiation are analyzed on the basis of literature
published in the last decade of the past century. Intercellular reactions among
the APCs and lymphocytes via distinct changes in expression of relevant surface
molecules and secretion of regulatory cytokines in response to different doses
of radiation were described. The major signal transduction pathways activated
in response to these intercellular reactions were illustrated. The suppressive
effect of low-dose radiation on cancer induction, growth, and metastasis and
its immunologic mechanisms were analyzed. The
present status of research in this field gives strong support to radiation
hormesis in immunity with low-dose radiation as one of the mechanisms of cancer
surveillance.
Tubiana, M. (2000). "Radiation risks in perspective: radiation-induced cancer among
cancer risks." Radiat Environ Biophys 39(1): 3-16.
…the use of the linear no threshold (LNT)
hypothesis… gives credence to the concept that even the smallest doses are
harmful. There are a number of scientific and epidemiological data currently under debate that are not
consistent with the LNT hypothesis. For example, no difference in the
incidence of cancers or of birth defects has been observed between regions with
low or high natural irradiation.
Jaworowski, Z. (1995) “Stimulating effects of ionizing radiation:
New issues for regulatory policy, Regulatory Toxicology and Pharmacology,”
22:2.
UNSCEAR 1994 concentrates on the elucidation
of mechanism by which radiation hormesis acts at the level of cell control
systems such as protein synthesis, gene activation, DNA repair, stress-response
protein production, radical detoxification, activation of membrane receptors,
proliferation of splenocytes, and stimulation of the immune system.
Townsend, J.F. and Luckey, T.D. (1960) “Hormologosis in pharmacology,” J. Am.
Med. Assoc., 173: pp44-48.
While studying
fermentation in milk, Richert (1906) noted that heavy metals were stimulatory at concentrations lower than those which
gave the harmful "oligodynamic action." Schulz (1888) and Branham
(1929) have shown that most of the
classic bactericidal agents exhibit hormesis in yeast. Antibiotics frequently cause a zone of accelerated growth in
bacteriological assay work. Garrod's evidence (1951) indicates that this may
have a direct effect on the cells. The antibiotic
growth stimulation of laboratory and farm animals has recently been reviewed in
full (Luckey 1959a).
Since
pharmacology is the department of medicine which deals most directly with such
chemical effects on cells and tissues, a survey of hormetics is appropriate in
this field. From the generalized viewpoint of hormology, a study of the action
of a variety of drugs in animal systems may add further evidence to the
validity of the thesis and illustrate a common denominator in drug action.
Goodman and Gilman (1955) recognize the phenomenon of hormesis as being of a
general nature as is shown by the following statement: 'Quinine affects such a large variety of biological systems that it has
been called a general protoplasmic poison; with some reservations this
appraisal is probably correct. Like many other poisons of this sort, it may
stimulate in low concentrations but depress in higher concentrations.'
A possible
mechanism of action at the cellular level has been suggested (Luckey 1959b) as
follows: The stimulation reflects
limitations in the ability of the organism to equate or modulate its response
to a given stimulus at the lowest threshold of perception. If we assume that
the response involves a chemical reaction, then the response of the organism is
a unit (discontinuous) response, in which the lowest possible reaction would
require one or more molecules to be changed. The release of an enzyme,
proenzyme, hormone, or ribonucleic acid information molecule could quickly
change the internal character of cells. The minimum response is an apparent
overcompensation at the sensing threshold of the organism.
The complexities
of higher organisms lead to interactions between different cells and tissues.
This allows a more complex reaction mechanism to be visualized. In spite of
this, the over-all patterns of response are similar to those seen with
micro-organisms. Irrespective of mechanism, common denominators evidently exist
in the response of organisms to drugs at the threshold of perception and
response levels.
The fact that so many apparently unrelated
stimuli produce the same general response (for example, stimulation followed by
depression) at least suggests that there are a few fundamental processes by
which the cell responds to all such stimuli rather than myriad processes by
which it responds to a wide variety of compounds. The complete pattern of
drug response patterns should be known. Demonstration of the uniformity of
response in the face of diversity of stimulation ...should point the way to a
better understanding of drug action and allow some generalization in basic
cellular physiology.
Part 5 of 5 - References 2
These
references are a few examples of studies that consistently find and confirm
that low dose radiation stimulates immune functions, and reduces cancer
incidence.
Liu, S.Z. (1997), “Cellular and molecular basis of the
stimulators effect of low dose radiation on immunity,” In: Wei, L.,
Sugahara, T. and Tao, Z., High Levels of Natural Radiation 1996: Radiation Dose
and Health Effects,
It has
been observed in human populations and animal studies that low dose radiation
(LDR) could stimulate the immunological responses. The up-regulation of immunity following
LDR involves a series of cellular and molecular reactions as well as their systemic
regulation. The studies in our
laboratory and elsewhere in recent years have convinced us that whole-body irradiation (WBI) with X- and gamma-rays
in the dose range within 0.2 Gy has definite positive effect on the immune
system which can be considered as beneficial to the organism.
Liu, S.Z., Liu, W.H. and Sun,
J.B. (1987) “Radiation hormesis: its
expression in the immune system,” Health Phys 52:pp579-583.
The effects of
low-dose single and continuous whole-body irradiation on immune functions were
studied in C57BL/6 mice. Plaque-forming
cell reaction of the spleen was found to be stimulated by single doses of x
rays in the range of 0.025 to 0.075 Gy and by continuous exposure to gamma rays
with a cumulative dose of 0.065 Gy. The reactivity of thymocytes to interleukin
1 showed a dose-dependent depression in the dose range of 0.025 to 0.25 Gy, but
there was an increase in cell number in the thymus between doses of 0.025 and
0.10 Gy, resulting in enhancement of reaction of the whole organ. Unscheduled
DNA synthesis of spleen cells was stimulated by single irradiation with 0.05 Gy
and continuous irradiation with a cumulative dose of 0.13 Gy. The
implications of these immunologic changes under low-dose radiation are
discussed."
Kojima, S., K. Nakayama, et al.
(2004). "Low dose gamma-rays
activate immune functions via induction of glutathione and delay tumor
growth." J Radiat Res (
…immune functions were enhanced through the
induction of cellular glutathione after low-dose irradiation …in Ehrlich solid
tumor-bearing mice. Tumor growth after inoculation was significantly delayed by
the radiation.
Kojima, S., H. Ishida, et al. (2002). "Elevation of glutathione induced by low-dose gamma rays and its
involvement in increased natural killer activity." Radiat Res 157(3): 275-80.
Kojima,
S.,
The
glutathione level in mouse splenocytes increased 2 h after whole-body gamma-ray
irradiation at 50 cGy… is at least partially responsible for the enhancement of
immune function, and may throw light on the mechanisms of carcinostatic
effects induced by low dose ionizing radiation.
Takahashi,
M., S. Kojima, et al. (2000). "Prevention
of Type I Diabetes by Low-Dose Gamma Irradiation in NOD Mice." Radiation
Research 154: 680-685.
Kojima, S.,
Mitchel, R. E., J. S. Jackson, et al. (2003). "Low doses of radiation increase the
latency of spontaneous lymphomas and spinal osteosarcomas in cancer-prone,
radiation-sensitive Trp53 heterozygous mice." Radiat Res 159(3): 320-7.
Safwat, A.,
Safwat,
A. (2000). "The role of low-dose
total body irradiation in treatment of non-Hodgkin's lymphoma: a new look at an
old method,." Radiother. Oncol. 56(1): 1-8.
Smirnova,
O. A. and M. Yonezawa (2003). "Radioprotection
effect of low level preirradiation on mammals: modeling and experimental
investigations." Health Phys 85(2): 150-8.
Yamaoka, K.,
A single post whole-body low-dose
irradiation (50 cGy of gamma-ray) on mice with …induced transient
hepatopathy…accelerated the rate of recovery… This may be because of the
enhancement of antioxidant agents such as total glutathione (GSH + GSSG),
glutathione peroxidase (GPX), glutathione reductase (GR) and
gamma-glutamylcysteine synthetase (gamma-GCS) by low-dose irradiation. These
findings suggest that low-dose irradiation relieved functional disorders at
least in the livers of mice with active oxygen species related diseases.
Yamaoka, K. and Y. Komoto (1996). "Experimental study of alleviation of hypertension, diabetes and
pain by radon inhalation." Physiol Chem Phys Med NMR 28(1): 1-5.
Ohnishi, T. (1997). “The
induction of a tumor suppressor gene (p53) expression by low-dose radiation and
its biological meaning,”. Low Doses of Ionizing Radiation: Biological
Effects and Regulatory Control: 406-409.
Shen, R. N., L. Lu, et al. (1997). "Murine AIDS cured by low dosage total body irradiation."
Adv Exp Med Biol 407: 451-8.
Shen, R. N., L. Lu, et al. (1996). "Curative effect of split low dosage total-body irradiation on
murine AIDS induced by Friend virus: the results and the possible
mechanism." In Vivo 10(2):
191-9.
Shen, R. N., L. Lu, et al. (1991). "Effect of split low dose total body irradiation on SFFV mRNA,
genomic DNA and protein expression in mice infected with the Friend virus
complex." Leukemia 5(3):
225-9.
DBA/2 mice infected with lethal dosages of
Friend virus complex (FVC) can be 100% cured by split-dose total body
irradiation (TBI) at 150 cGy, an effect associated with the restoration of
the cellular immunity which is compromised by the virus.
Shen, R. N., L. Lu, et al. (1991). "Cure with low-dose total-body irradiation of the hematological
disorder induced in mice with the Friend virus: possible mechanism involving
interferon-gamma and interleukin-2." Lymphokine Cytokine Res 10(1-2): 105-9.
Shen, R. N., N. B. Hornback, et al. (1988). "Curative effect of split low dosage
total-body irradiation on mice infected with the polycythemia-inducing strain
of the Friend virus complex." Cancer Res 48(9): 2399-403.
All FVC-P injected mice were dead within 40
days; however, infected mice receiving TBI on days 5 and 12 exhibited long-
term survival. FVC-P-injected mice receiving TBI treatment on days 5 and 12
had normal leukocyte counts, normal spleen weights, and no detectable spleen
focus-forming virus. Although the FVC-P-infected mice had decreased proportions
of L3T4+ cells and increased proportions of Lyt-2+ cells, these were returned
to normal following TBI treatment. …The inability of in vitro
irradiation doses of up to 1000 cGy to inactivate FVC-P which was subsequently
injected into murine hosts suggests that the
effectiveness of the TBI treatment in vivo is not due to a direct
radiation effect on the virus.
Miyamoto,
M. and K. Sakamoto (1987). "Anti-tumor
effect of total body irradiation of low doses on WHT/Ht Mice." Jap.
J. Cancer Clin. 33(10):
1211-1220.
Sakamoto, K. and M. Miyamoto (1987). "Tumor control effect by total body irradiation,." Oncologia,
20(2): 86.