Radiation, Science, and Health Documents
RSH Comments on NCRP 136
Article by
Dr. Theodore Rockwell on the US NRC failure, as the funding agency, to
require NCRP to consider the scientific data in NCRP-136:
"The quixotic quest for zero
radiation dose" 1999
[PDF 420 KB]
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NCRP Report 136 Misrepresents the Scientific Evidence:
Low-Dose Radiation is NOT Harmful; Shows Health Benefits Initial Comments, June 15, 2001, Radiation, Science, and Health.
(rad_sci_health@comcast.net)
or
[PDF file - 225 KB]
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. This will be challenged before the Federal
agencies that would be misled; before authorities that assess scientific misconduct, and
the Office of Scientific Integrity; and before the Congress, and the courts.
CRITICISM: of the NCRP Report
No. 136 on "Evaluation of the Linear-Nonthreshold Dose-Response Model for Ionizing
Radiation," September 2001, Zbigniew Jaworowski, Central
Laboratory for Radiological Protection, Warsaw, and Member and former
Chairman, UNSCEAR; and Michael Waligórski, Centre of
Oncology, Kraków, POLAND.
In December 1998, Central Laboratory for Radiological
Protection in Warsaw, a participant in the "Special Liaison Program of
NCRP," on the formal request of NCRP, prepared a critical review of the
draft of NCRP Report No. 136. We never received an answer to this criticism, and
in the final version of NCRP Report No. 136, almost all of these comments were ignored.
The title of the report is inappropriate. The Report is not an
objective evaluation of the validity of the linear-nonthreshold dose response hypothesis
(LNT); but rather is a propagation of LNT. It does not demonstrate that LNT is
scientifically valid, but rather that NCRP holds LNT dear. Because of the longstanding
involvement of NCRP in applying LNT as the basis of radiation protection and radiation
risk evaluation, with all of its far reaching economic, health and social consequences, NCRP
is probably not a proper body to conduct an objective estimate of the validity of the LNT,
because of the group vested interests that are the case here. In the face of a mounting
scientific evidence of invalidity of this hypothesis, and the increasing number of its
opponents, the Committee's Report can be seen as an attempt to defend the LNT, and
an attempt for an exculpation for its past use. The Committee did not fulfill the
provisions from its Legal Notice: "to provide accurate, complete and
useful information" for impartial and disinterested evaluation of LNT.
Instead, the Committee correctly states on p. 10: "an exhaustive or
comprehensive description of the literature was not the goal of this Report...The
Committee has presented an unbalanced presentation of the pros and
contras to the LNT. The Report demonstrates a biased selection of published
results, offering lengthy and often misleading pro-LNT interpretations and data, but
curtailing and deforming the information to the contrary, and most often ignoring it.
The Report concentrates almost exclusively on detrimental effects of radiation, and
ignores totally the beneficial effects... We
observe here not just incompetent and careless presentation of published data, but also
concealing important information that strongly refutes the LNT. This is a pattern that is
unfortunately typical for the Committee in producing the NCRP No. 136 Report."
See also an article by these authors:
"Problems of U.S. Policy on Radiation Protection,"
[PDF 105 kb] Executive Intelligence Review-Science
& Technology, May 16, 2003.
They
"discuss the deliberate misrepresentation, omissions and bias in a report by
the U.S. National Council on Radiation Protection and Measurements, at the
expense of the general welfare."
"the high scientific standards and impartiality of the
NCRP have melted into thin air, sacrificed to defend an obsolete and
untenable linearity paradigm...
"...we
shall limit ourselves to comments that demonstrate the unscientific nature
of this report.
"The subject of NCRP-136—namely, that there is a linear
relationship between radiation dose and biological effects—is a central
issue in the global radiological protection system. Adherence to this
assumption is why current radiation regulations are excessively complicated,
and its scientific and pragmatic principles in disarray. The consequences of
this assumption lead to what the former president and honorary member of the NCRP, Lauriston S. Taylor, defined as
"deeply immoral uses of our scientific
heritage" (Taylor 1980).
[Ed. note: Of course these
"problems" are not limited to the U.S. :-) ]
Critiques of
NCRP Report No. 136
September 2001, by Sohei Kondo, 6-2-13
Habikigaoka, Habikino City 583-0864 Japan. (skondo@taurus.bekkoame.ne.jp)
"Critiques...
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."
Review of
NCRP Report No. 136 "Evalation of the Linear-Nonthreshold Dose-Response Model for
Ionizing Radiation" (NCRP, 2001-06-04, ISBN 0-929600-69-X),
Klaus Becker (prof.dr.klaus.becker@t-online.de)
"The highly developed art of 'politically correct' data selection is evident
in the report...
In general, epidemiological studies of populations in high
natural, NORM and TENORM situations are underrepresented in the report. This bias in
favour of LNT can also be observed in the selection of figures, etc... In summary,
the report is a valuable compilation for those supporting the LNT hypothesis, but
it is easy to imagine an equally profoundly documented report, written by an
equally reputable group of experts, which would come to quite different results. 'LNT or
not LNT, that is the question' remains open to further, hopefully serious and unbiased,
studies and analysis."
NCRP Report No. 136 – How to ignore data that contradict the LNT
hypothesis. John Cameron
"ICRP adopted the linear
nonthreshold model of radiation risk to simplify the administration of radiation
protection. At that time there were already several good epidemiological studies
that contradicted the assumption... Most radiation scientists understand the
bureaucratic reasons for the LNT assumption. Unfortunately some radiation
(political?) scientists have endeavored to convert the LNT assumption into a scientific
fact. NCRP Report No. 136 is the fourth attempt of a NCRP Scientific Committee to
accomplish this goal. It has failed... NCRP Report No. 136 was intended, as
stated in the first sentence of the Executive Summary, to determine our 'current understanding of the health effects of low doses of ionizing
radiation.' SC 1-6 violated this charge by discarding evidence from
important low dose rate epidemiological studies. On the other hand, it includes
fabricated epidemiological data that support the LNT view point."
Comments on
NCRP Report 136
Bernard L. Cohen, University
of Pittsburgh (blc+@pitt.edu)
"One very important criticism is that it did
not include as a "Research Need" in Sec. 9.5 a thorough study of health
impacts on residents of the Taiwan apartment buildings who were exposed for many years to
significant levels of radiation from Cobalt-60 in the structural steel." I
have many other reservations about the report, but comment on its dismissal of my study of
lung cancer rates vs average radon exposure in U.S. counties. "NCRP-136
references several papers that offer qualitative suggestions about how my study can give
erroneous results, but in each case I have published papers showing by quantitative
calculations that these suggestions are not productive, and my papers are not referenced.
That is surely a violation of standard scientific procedures." NCRP-136
claims that my study is subject to 1. the ecological fallacy, 2. inadequate control for
smoking, and 3. inadequate control for age distribution. These claims are not
substantiated and do not consider the contradictory data. "I can well appreciate that the Committee that prepared NCRP-136
did not have time to carefully examine and evaluate my work. However, it is very important
that it not be dismissed without such careful examination. I therefore offer to
personally finance an NCRP study to settle the matter with some finality. If you will give
me an estimate of the cost and time frame for such a study, I will provide the necessary
funds."
Comments on NCRP Report No.
136, " Evaluation of the Linear-Nonthreshold Model for Ionizing Radiation"
Jerry J. Cohen, 3417 Tice Creek Dr. #5 Walnut Creek, CA 94595,
(925) 933-8184 (jjcohen@prodigy.net)
"...it seems
apparent that the objective was to defend the status quo.
You have, no doubt,
received comments from other reviewers criticizing your summary dismissal of the plethora
of scientific publications that support the existence of a dose threshold and the validity
of hormesis. Although some of this evidence is cited and discussed in the report, no
cogent rationale was presented for rejecting its importance in reaching your
conclusions... I urge you to consider the total spectrum of ionizing radiation effects on
biological systems, primarily humans, in assessing the net overall health consequences... there
is a considerable body of evidence that low-dose ionizing radiation can have a
stimulatory affect upon the immune response system. This phenomenon could account for the
negative correlation between background radiation levels and various morbidity endpoints
observed in studies in the USA, China, and India... NCRP-136 included no immunologists.
There is a strong possibility that inclusion of this body of expertise might have
significantly influenced the conclusions of the report... Rather than
perpetuating an approach that focuses only those effects involving chromosome
aberration... it is likely that radiation could simultaneously produce a
multiplicity of effects on biological systems, some of which may be harmful,
while others may concurrently be beneficial in nature. Determination of the net
consequence to the dose receptor should require a quantitative consideration and
evaluation of all such effects. Depending upon the dose level, the net consequence might
be either detrimental or beneficial in nature. In any case, the simple inference
of low-dose effects from observation of certain high-dose consequences seems more an
exercise in faith than of science."
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