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11 July 2000
Dr. Richard Jostes
National Research Council
Board on Radiation Effects Research
2101 Constitution Avenue
Washington, DC 20418
Subject: BEIR-VII Committee
Dear Dr. Jostes:
Enclosed for the BEIR-VII Committee are 19 copies of our comments to the Environmental
Protection Agency on its Proposed Rule on Radionuclides in Water. We challenge the
validity of the Linear No-Threshold (LNT) premise to establish radiation limits where
there are no harmful effects. We present examples of the extensive scientific evidence
that contradict the LNT premise for low doses; we note that this longstanding evidence has
not been refuted, including BEIR IV and BEIR V; and that EPA’s scientific
justification of the LNT premise misrepresents the existing data. We therefore requested
the EPA to refute the LNT premise, and to base its rule on valid science.
We have failed to get advisory and policy-making bodies to bring radiation protection
policies into line with the best scientific evidence, or even to provide sound scientific
bases for dismissing the large body of evidence that so clearly contradicts the LNT
premise of hazard at radiation doses far below the natural backgrounds of high-radiation
areas where people have lived healthily for generations. This evidence has been repeatedly
ignored or misrepresented.
Therefore, if EPA’s final rule is based on the LNT, we intend to take the matter
to court, where similar instances of EPA’s misuse of science in rule-making have
found against the EPA.
We have specifically identified examples of studies that claim to support the LNT, that
have manipulated or misrepresented data, or drawn unwarranted conclusions. Where this is
mere carelessness or scientific incompetence, this will be made public. Where it becomes
scientific misconduct under current definitions and precedent, we intend to make
appropriate allegations against individual scientists.
We expect that your Committee will find this scientific evidence helpful in its
deliberations. We will be pleased to provide any information and clarification on this
matter.
Sincerely,
Theodore Rockwell, Vice President
James
Muckerheide, President
3404 Woolsey, Chevy Chase, MD 20815 Box 843, Needham,
MA 02494
Encl: RSH ltr to EPA, w/ encl. (absent the "RSH Data Document" previously
provided)
Cc: w/ encl. Dr. Evan Douple, Executive Director, BRER
Independent
Individuals Knowledgeable in Radiation Science and Public Policy
Committed to Change
Radiation Science policy in the Public Interest |
