RSH > Documents > RSH Comments on NCRP 136 > Dr. Sohei Kondo

Comments on NCRP 136

Dr. Kondo is

 

 

Critiques of NCRP Report No. 136 re: 1) non-threshold model for action of ionizing radiation in the very low dose range, 2) the assumption that radiation-induced DNA double strand breaks (dsbs) are different from spontaneous dsbs and peculiarly difficult substrates for the cell to cope with, 3) biased presentations of data on atomic bomb survivors and 4) omission from the Report of relevant reports for threshold effects in radiation tumorigenesis after irradiation at extremely low dose-rates.

Sohei Kondo, 6-2-13 Habikigaoka, Habikino City 583-0864 Japan; E-mail: skondo@taurus.bekkoame.ne.jp

 

1) Non-threshold model for action of ionizing radiation in the very low dose range

The Report states that even at the smallest doses, some of the target cells receive relatively large amounts of radiation energy when they are struck by a single particle. This is a biased statement because live cells are actually exposed to various chemicals in nature and endogenous toxin. Therefore, the question is whether the dose of about 1 mGy given to a cell struck by a single particle is larger than the chemical dose given to that cell by spontaneous toxin. This question is equivalent to the question whether DNA damage induced in a cell by 1 mGy of low LET radiation is more severe than DNA damage induced spontaneously. This is the subject of discussion in the following paragraph.

2) The assumption that radiation-induced DNA double strand breaks (dsbs) are different from spontaneous ones and peculiarly difficult substrates for the cell to cope with.

This is the basic assumption adopted in NCRP Report No. 136. It is mentioned in the Report that DNA damage other than dsbs is produced in cells by spontaneous factors more abundantly than by radiation but the damage is almost completely repaired. The Report emphasizes that dsbs occurring in unirradiated cells are sealed enzymatically as part of normal processes but dsbs induced by ionizing radiation have unusual end groups and hence peculiarly difficult substrates for the cell to cope with and thought by most radiobiologists to be the lesions that endow ionizing radiation with its uniquely toxic effects (Ward, 1995).

Recently, studies of Nijmegen Breakage Syndrome (NBS), a very rare autosomal recessive genetic disorder, have revealed that NBS results from a gene mutation on chromosome 8q21, cells from NBS patients are two-fold sensitive to killing by X rays than wild-type cells due defect in the repair of dsbs, in 40% of the NBS patients, lymphoma, leukemia and other tumors were noted before age of 21 years and congenital malformations were noted in about 50% of the patients (The international Nijmegen breakage syndrome study group, Arch Dis Child, 82, 400-406, 2000). Therefore, the defect in repair of DNA dsbs in the NBS patients is responsible for high incidence of malignancy and malformations. In other words, spontaneous DNA dsbs are highly toxic if they are not normally repaired. These results are not compatible with the NCRP Report ‘s basic assumption that radiation-induced DNA dsbs are uniquely toxic damage.

The number of dsbs produced spontaneously in human cells in a growing phase is estimated to be about 10 per cell per day. Since 1 mGy of gamma rays induces 0.04 dsb per cell, the risk of 1 mGy gamma rays per day is only 0.4% of the spontaneous DNA dsb damage. Of course, radiation-induced dsbs may not be perfectly identical with spontaneous dsbs in regard to the detailed molecular structure. Even if this is the case, we may assume that exposure to ionizing radiation at the level of 1 mGy per day is no more hazardous than spontaneous risk without radiation. Supporting evidence for this conjecture from an epidemiologic study will be discussed in paragraph 4.

 

3) Biased presentations of the data of atomic bomb survivors in the Report

In regard to radiation-induced mutations, epidemiologic data are available only for children of atomic survivors. In the Report, these important data are only briefly mentioned that there were no significant differences between children of atomic bomb survivors and control children in regard to altered electrophoretic mobility or activity of a series of 30 proteins. Following results should also be mentioned; the original papers reporting these results are given in the paper by Neel et al. (1988) quoted in the Report. Sex chromosomal aneuploidy was 0.23% for children of atomic bomb radiation-exposed parents at 600 mSv and 0.30 for those of nonexposed parents. The frequency of balanced structural chromosome rearrangements was 0.22% for children of atomic bomb radiation-exposed parents at 600 mSv and 0.31% for those of unexposed parents. Furthermore, no statistically significant effect of parental exposure to the ionizing radiation of the bombs on the frequency of congenital malformations, still births, survival, physical growth and development, and malignant tumors with onset prior to age 20 was found. That is to say, at about 500 mSv parental exposure, ionizing radiation gave no statistically significant genetic effects on humans.

If human germ cells are as sensitive as spermatogonia of mice to radiation for mutagenesis (see the murine data quoted on p. 40 of the Report), we expect exposure to 500 mSv will double the frequency of spontaneous germ-line mutations in humans. The fact that there was no genetic effects of 500 mSv radiation on humans may indicate that human germ cells are more resistant to radiation than murine germ cells.

The dose estimated by Dosimetry System 1986 (DS86) is used by all the data published from Radiation Effects Research Foundation. However, the measured gamma-ray kermas from the Hiroshima atomic bomb by a thermoluminescence method using tile specimens on rooftops of buildings indicate that ratio of the measured gamma- ray kermas to DS86 values is 1.2 at ground distance 1.3 km form the hypocenter and the discrepancy increases to the ratio of 2.1 for ground distance 2.05 km where the DS86 value is 58 mGy (T. Nagatomo et al. Health Phys. 69, 556-559, 1995). Therefore, cancer risks estimated at the dose range below 300 mSv are not reliable in regard to the dose response relationship.

 

 
4) Omission from the Report of relevant reports for threshold effects in radiation tumorigenesis after irradiation at low dose rates

J.P. Morlier et al.(Radiat Prot Dosim 56, 93-97, 1994) subjected rats to chronic inhalation of radon gas at two different concentrations under conditions such that both groups of rats were given the same total dose of 25 WLM (about 0.19 Gy). Radon gas was carcinogenic at dose-rate 100 WL (about 4 mGy/h) but not carcinogenic at the extremely low dose-rate 2 WL (about 0.1 mGy/h). O. Yamamoto et al. (Int J Radiat Biol 73, 535-541, 1998) carried out the following experiments. Mice were supplied with drinking water containing known concentrations of tritium until they all died. The incidence of thymic lymphoma was more than 20% for internal b-ray induced dose rates above 20 Gy/y, and came down to 0 % for dose rates of 70 to 300 mGy/y. Magnitude of carcinogenic risk associated with chronic exposure to low doses of radiation during radiological practice was estimated by P.G. Smith and R. Doll (Br J Radiol 54, 187-194, 1981) in the following way. Radiologists who entered the profession before 1921 suffered a death rate from cancer 75% higher than that of medical practitioners. For radiologists who entered the profession after 1920, there were 72 deaths from cancer whereas 68.7 deaths were expected, based on rates among medical practitioners; the ratio of observed to expected deaths is statistically not significant. The authors estimate that radiologists who entered between 1920 and 1945 could have received an accumulated whole-body dose of the order of 1-5 Gy, i.e., 40 - 200 mGy/y. In 1934, ICRP recommended the level of 0.2 roentgen per day as a maximal permissible dose. These results may suggest that the order of 1 mGy per day is a threshold below which there is no risk of cancer after exposure to radiation.

 

 

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07/13/05