Data and Documents
 

REALISM -
In Engineering and Analysis of the Sources and Consequences of Radioactivity in Using Nuclear Technologies

ICRP’S PROPOSED NEW RULES
Further Departure from Realism

Lauriston Taylor, one of the founders of the ICRP and the NCRP, wrote in 1980:

“No one has been identifiably injured by radiation while working within the first numerical standards set by the NCRP and the ICRP in 1934. The theories about people being injured have still not led to the demonstration of injury and, if considered as facts by some, must only be looked upon as figments of the imagination.“

At the eleventh quadrennial meeting of the International Radiation Protection Association in Madrid, May 27, 2004, the International Commission on Radiological Protection (ICRP) presented the first proposed revision of its position since ICRP-60 was issued in 1990. In apparent agreement with Dr. Taylor’s 1980 statement, the ICRP asserts that it “recognizes the need for stability in regulatory systems at a time when there is no major problem identified with the practical use of the present system of protection…” Despite this assertion, it then proceeds to tighten even further the ALARA-to-zero noose.

ICRP reaffirms its position that “there is presumed to be some probability of health effects even at small increments,” but proposes nevertheless that it is not necessary to address radiation protection for doses below 0.01 mSv (1 mrem).

ICRP reports are not to be taken lightly. When confronted with the harmful effects of their pronouncements in the real world, ICRP members generally protest that they report only on the science, and that regulatory authorities are free to follow their advice or not. But at Madrid, ICRP was less conciliatory: “These restrictions…should be considered as obligatory, and not maintaining these levels of protection should be regarded as a failure…where action to avert the dose is virtually certain to be justified.”

As instruments become more sensitive, as increasingly extreme practices become the norm, there is no end in sight. After setting extreme requirements, the Commission looks to local authorities to go further: “the Commission therefore recommends that further, more stringent, measures should be considered for each source…The Commission expects that the resulting national values of constraints will be lower than the maximum values recommended by the Commission, but probably not by as much as a factor of ten.”

The ICRP does recommend “optimization,” but it defines optimization as simply dose reduction: “the concept of optimization…is to engender a state of thinking in everyone responsible for control of radiation exposures such that they are continually asking themselves the question, ‘Have I done all that I reasonably can to reduce these doses?’” Since radiation dose is often caused by discretionary time spent inspecting and testing in radiation zones, this quixotic quest for zero dose creates an ill-advised incentive to reduce that time for no health benefit, at increased risk of missing a situation (such as corrosion or leakage) important to real safety.

ICRP also continues to use “collective dose” as a measure of health effects, despite widespread objection. Groups do not suffer health effects; only individuals do. ICRP also continues to distinguish between “natural” and “artificial” radiation sources, although there is no scientific basis for doing so.

Although it is not discussed explicitly in ICRP’s summary handout, ICRP Chair Roger Clarke and others stated that the Commission is not justifying its recommendations on the basis of risk, but simply on the basis of dose limits. They have nominal comparisons to background radiation, which is taken to be 1 mSv (100 mrem). This is the low range of background radiation, and excludes radon. Radon is not included because "it has been made subject to radiation protection control." This blurs the rationale for the limits. It obscures the lack of health benefits obtained for the enormous costs committed to radiation protection. This may explain the reason for the change

The ICRP states that the aim of its recommendations is “to make value judgments about the relative importance of different kinds of risk and about the balancing of risks and benefits. In this, they are no different from those working in other fields concerned with the control of hazards.” But it fact, these recommendations are of entirely different type and magnitude than encountered in other fields. Other potentially toxic agents are given a tolerance level, and regulation is thereby made clear and unambiguous. There is no public health and safety basis