This Document is a partial compilation of the large body
of valid scientific data on low level radiation health effects that contradict
international radiation protection policy. It represents contributions of many
independent, knowledgeable radiation scientists and public policy analysts, committed to
the public interest.
This data is not adequately considered by radiation protection policy bodies and
government agencies that presume that low level radiation causes adverse health effects
linearly to zero dose. These conclusions have been characterized within the knowledgeable
biology and radiation science community as "without scientific foundation",
"immoral", "the greatest scientific scandal of the century", and as
"a ‘good old boy’s network’ of insiders".
These policies cause direct public costs estimated to exceed US$ 2 trillion
(million-millions) world-wide, of which no more than a few percent contribute any public
health benefits. Many significant research programs and proposals to investigate and
confirm evidence contrary to the linear no-threshold hypothesis are not supported by
radiation protection policy institutions. Some of the most significant have been
terminated, and reporting of some research results substantially misrepresent the data.
Normally, as research and development is advanced, original assumptions are reduced and
criteria become less conservative. Radiation protection policy violates this rule. The
linear no-threshold hypothesis (LNTH) is based on presumptions, from early conservative
assumptions used for administrative purposes, that:
1. Health effects documented at high doses and high dose rates can be projected to
zero dose with no threshold, even though scientifically contradicted for decades.
2. Each radiation "hit" that damages DNA contributes to the probability
that the cell will develop cancer, even though DNA damage from low level radiation is
insignificant compared to normal oxidative DNA damage.
These presumptions further led to the policy of "as low as reasonably
achievable" (ALARA), which today essentially requires not only that all regulations
be met, but must then be exceeded as dictated by the ambiguous term,
"reasonable".
The biological plausibility of these presumptions are refuted by the large and growing
body of world-wide radiation health effects data accumulated for over 50 years, and
biology research showing stimulatory effects and beneficial health effects in plants,
animals, and humans from low to moderate dose radiation exposures, and data on positive
immune responses that have prevented and even cured cancer and other diseases.
The data sources are from low and moderately high exposures to:
1. Human populations, from epidemiological and clinical studies.
2. Animal and plant populations exposed in radiation research.
3. Radiobiology, genetic and cancer research, and molecular biology research
Radiation health effects research on low doses has been constrained by radiation
science policy, along with scientific knowledge about radiation and human health, and the
potential application of radiation in biology, agriculture, and human and non-human health
and nutrition.
Around the world, radiation medicine and other nuclear applications and benefits are
constrained and made uneconomic, and caused preventable adverse health effects, while
imposing enormous public costs for "radiation protection" that provide no health
benefits.
Data exist at the doses and populations to establish that no adverse effects exist.
Contrary to statements that requisite data and knowledge do not exist in the low-dose
regions, hundreds of scientifically valid studies are reported in the peer-reviewed
literature that fail to support, and directly contradict, the LNTH at low to moderate
doses. This evidence is often unstated, and even misrepresented, in published papers.
Such beneficial responses are not seen in research on cells and organisms that are not
supported by complete immune systems, and those kept in germ-free environments that do not
challenge immune functions. Such organisms or cells are laboratory artifacts that do not
reflect whole organism responses to radiation stimulation.
This Document summarizes the evidence, organized by "exposed populations" and
biological research. Data on the following human populations are summarized:
1. The Japanese atomic bomb survivors
This population has limited application to radiation protection, due to instantaneous
exposures, including neutrons, the effects of war-time conditions, significant known
errors in dose estimates, and the failure to consider fallout in .the low-dose group and
in controls.
Unlike most taxpayer-funded data, the Radiation Effects Research Foundation (RERF) data
is not available to researchers, including analysts for the BEIR report. Recent RERF
reports have claimed that the low-dose data support the LNT. Severe deficiencies have been
demonstrated in this analysis, although its claims to support the LNTH far exceed its own
results. Notwithstanding the limitations of the data on survivors, Dr. Sohei Kondo and
others report on analyses of the RERF data that, for low to moderate doses, health
benefits are identified.
2. Nuclear reactor facility exposed populations
Nuclear weapons materials, and early research and development reactor workers were
significantly exposed to radiation compared to more recent nuclear workers, were also
exposed to other chemicals and adverse stress and physical conditions, and many were
exposed to contaminants prior to, during and after their AEC work. These workers generally
had weak to poor radiation dosimetry. Since chemical exposures are claimed to contribute
to human cancer, this group would be expected to have higher cancer rates than the general
population. Such is not the case. Dr. Luckey reports on nine nuclear worker studies
totalling 13 million person-years, with the exposed worker cancer mortality rate to be
about 66% of that of non-exposed workers at the same plants.
A 10-year, 1978-87, US$10 million study of US Navy shipyard workers compared nuclear
and non-nuclear workers. These workers, exposed to external radiation with with good
dosimetry and limited confounding effects, show significant reductions in total mortality
and in other specific adverse health effects. The US DOE funded this study, but it has not
been published. However, it was released under pressure as a contractor report in 1991.
The Chairman of the Technical Advisory Panel for this study was also chair of the BEIR V
Committee. However, this study was not included in BEIR V in 1990, though other
then-recent, unpublished work was included in the data and report.
This study was also not included in a recent study by the International Association for
Research on Cancer (IARC) of combined UK, US, and Canada nuclear worker studies funded by
DOE. It claimed to indicate adverse nuclear worker health effects, based solely on a
"test for linear trend" based on one data point of 6 deaths at greater than 40
rem (cSv). This study also misrepresents its own data.
3. Medically-exposed populations
Medical practitioners and patients in radiology and nuclear medicine have received
significant doses. Radiologists in practice before 1925 had very high doses, particularly
during WWI. Early radiologists were found to have excess cancers and leukemia in 1950s
studies. However, in a 1981 study of radiologists starting practice since 1921, with mean
doses estimated at about 500 cSv, no excess cancer or leukemia was found. Nobel Laureate
Dr. Rosalyn Yalow reports on 6500 WWII US Army radiologic technicians who received an
estimated 50 rem in training alone, and had no increased malignancies compared to Army
medical, laboratory, and pharmacy technicians 29 years later. A US National Cancer
Institute study of more than 100,000 U.S. female radiologic technicians certified since
1926, found no association for breast cancer due to their work, nor to personal
fluoroscopy or multifilm procedures.
Medical patients receive significant radiation doses, with poor to good dosimetry.
Studies show adverse health effects from high doses. Moderate doses are not found to cause
adverse health effects in dozens of studies, considering potential confounding factors
from health conditions. No excess thyroid cancer is found from diagnostic I-131 use (mean
thyroid doses estimated to be 50 cGy) for patients that were not suspected of having
thyroid cancer; and no excess leukemia was found from 10-15 cGy whole-body dose from I-131
to treat hyperthyroidism, compared to identical patients treated by surgery, contradicting
LNTH predictions.
4. Radium-burden population
Thousands of radium dial painters and others with internal radium have no excess bone
or nasal cancers with doses less than about 1000 cGy. The Center for Human Radiobiology at
Argonne National Laboratory, formed in 1970 at the retirement of Dr. Robley Evans at MIT
to be an "immortal organization" for the lifetime of the radium population that
had been exposed in the first half of the century, reported these data at an international
conference in 1981, and in the Health Physics Journal in 1983. The DOE initated program
termination in 1983, although more than a thousand subjects remained alive. Recent
follow-on analysis confirms these results. However, the study of this population has been
terminated; and the data is explicitly ignored by the radiation protection policy
interests.
Dr. Kondo reviews the radium-burden data and reports on the beneficial effects in
all-cause mortality in the early decades following exposure, and in non-cancer effects, in
US and UK populations. The absence of leukemia and lung cancer or other potential
radiogenic cancers and health effects from this substantial radioactive source to this
population, highly exposed to both external and internal radiation, with radon being
exhaled from the decay of radium, contradicts the LNTH. Potential increased longevity of
these early workers has been noted, but competent work has not been supported.
In 1991 the EPA stated in the Federal Register, rejecting recommendations by its own
Science Advisory Board, that to consider the health effects data on radium it would have
to abandon the linear model, which it would not do.
5. Nuclear weapons and facilities releases
Participants in atomic weapons tests have demonstrated no adverse health effects. In
1985, a US National Academy of Sciences (NAS) study of more than 46,000 participants in 5
major atomic bomb tests found no adverse effects. In 1996 an NAS study of 40,000 Navy
participants in the 1946 Crossroads test of two atomic bombs at Bikini Atoll, one of which
was detonated below the water that greatly increased radioactive contamination, found
that, although total mortality is slightly higher than controls in this population, cancer
death is not increased, nor is any other cause of death potentially associated with this
radiation. The average dose was estimated to be about 6 cSv. There is also no increase
found associated with higher dose groups.
Fallout from the 1954 Bravo test affected 23 Japanese fishermen, with ash that stuck to
the skin and caused significant burns. Doses were estimated to be 200 rad (cGy) to 670
rad. The fisherman with the highest dose died 206 days after the event. All others,
exposed to doses from about 200 to 575 rad and monitored for 24 years, showed no
associated adverse health effects. At 21 years, one died of ascites caused by cirrhosis.
No cancers had been observed.
Professor Jaworowski states: "Unexpected results were obtained in one of the best
studies in human genetics carried out in Hungary before and after the Chernobyl accident.
Several serious congenital anomalies occurred after the Chernobyl accident with lower
frequency than before the accident."
He also states: "Eleven years that passed since the Chernobyl catastrophe are more
than enough for realistic assessment of its early and late health effects." He
reports on the 28 early victims of radiation exposure, and the 3 deaths from thyroid
cancer from the more than 800 thyroid cases that have appeared since the accident, though
causes are not clearly related to dose estimates.
Dr. Shantyr et al state: "In the five-year age groups cancer morbidity of the
[Chernobyl] emergency workers makes no statistically significant differences with that of
the male populations of Russia and St-Petersburg. No evidence of an association between
radiation dose and cancer morbidity was observed."
6. Natural background radioactivity
Natural background radioactivity is by far the largest source of exposure to ionizing
radiation. Further, background radiation varies around the world by a factor of about 100,
and by differences of factors of more than 10 locally. Studies of large populations with
large dose differences consistently find either statistically significant lower cancer
rates in the more highly exposed groups, or no effects in populations that are poorly
differentiated. This directly contradicts the LNTH.
The US Atomic Energy Commission (AEC) contracted for a background radiation analysis in
response to a Federal court determination that AEC Environmental Impact Statements were
inadequate in the Calvert Cliffs decision. Dr. Norman Frigerio at Argonne National
Labatory assessed radiation dose and cancer data by state in the US, testing various
linear models with rigorous statistical analysis. The states with "high
background", with doses a factor of 3 higher than the low background states and twice
the national average, had consistently lower cancer rates, including analyses of likely
potential confounding factors. However, this contract was terminated, and the work
unpublished, by the AEC, and later by DOE. Subsequent summary analyses with later U.S.
average dose and cancer data have confirmed these results.
Lung cancer in areas of high radon exposures find a lower cancer rate in high radon
areas, or no effect in studies of poorly differentiated populations. The most
comprehensive and scientifically rigorous study of radon effects was produced by Dr.
Bernard Cohen at U. Pittsburg. This study, with more than 300,000 home radon data
measurements and cancer data from 1792 counties covering 90% of the US population,
demonstrates that the LNTH can not be valid. Dr. Pollycove, Dr. Kondo, and others confirm
the validity of Dr. Cohen’s analysis, including the effect of confounding factors.
Populations in radon spa areas do not have excess cancer, again contrary to the LNTH.
In substantial populations, lower cancer ratesoccur in the higher radon source area.
Smaller populations with greater dose differences include Kerala, India at about 4 times
average background, Guarapari, Brazil at about 6 times background, and Ramsar, Iran at
about 10 times average background. These populations all find no adverse effects from high
background radiation.
Note that the "releases" from high natural concentrations are much larger
than releases of man-made radioactivity subject to costly controls and decontamination.
7. Animal and plant biology
Hundreds of scientifically valid studies of animal and plant populations have shown
that low level radiation produces beneficial health effects, or no health effects. No
substantial or reproducible studies have demonstrated adverse health effects according to
the LNTH. Dr. Luckey has documented more than 2000 studies that demonstrate beneficial
effects from "whole-body" doses, not including beneficial effects from organ
doses.
Dr. Luckey reports on studies by Egon Lorenz of the National Cancer Institute and
others, which reported beneficial effects that include lower cancers, increased mean life
span, increased growth rates, increased size and weight, increased fertility and
reproduction, and reduced mutations, along with many enhanced physiological and biological
functions. The physiological responses in animals and plants are shown to be equivalent to
the effect of many natural elements and compounds that are essential nutrients at low
levels and toxic at high levels. Studies directed by radiation protection interests have
selectively ignored research to document such beneficial effects, andother studies have
been defunded.
Dr. H. Planel and others have shown positive effects at small increases in natural
background radiation, and a continuum to detrimental effects at doses below natural
background in lower order animals. Such health and medical research results have lead to
establishing the basis for vitamin and mineral and other supplements for nutrition and
health. However, support for such radiation research is constrained.
In plants, Drs. Sheppard and Regitnig in Canada, Dr. Alexander Kuzin in Russia and
others (even high school science projects) have shown the stimulation of growth and
reproduction by irradiation of seeds and seedlings. Dr. Kuzin and others have called for
planning to implement programs to enhance food supplies.
8. Cellular and molecular biology, genetics, and cancer research
Radiobiologist Dr. Gunnar Walinder of Sweden and others in biology state that
carcinogenesis is a complex, iterative progression that precludes the biological
plausibility of the LNTH as a postulated stochastic "hit" to DNA that can
progress to a cancer. Biological evidence has established that ‘whole’ cell
colonies and organisms have adaptive responses to radiation, for cells in which complex
intracellular communications and responses are enabled, and for organisms in which immune
responses are functional. Some of the limited research that is claimed to
"support" the linear model comes from organisms and cell colonies with deficient
biological response capability.
Dr. Kondo and others establish the biological evidence that ‘altruistic cell
suicide’, apoptosis, which is absorbed without the necrosis and potential damage of
cell killing, stimulates proliferation of healthy cells to replace a damaged cell,
eliminating injury. Apoptosis and other biopositive responses are shown to stimulated by
low-dose radiation. The role of radiation at low doses may be a beneficial, if not
essential, contributor to cell function and repair.
Drs. Pollycove and Paperiello state: "The biological effect of radiation is not
determined by the number of DNA mutations it creates, but by its effect on the body’s
protective processes. At high levels, radiation supresses them; at low levels, it
stimulates the DNA damage-control biosystem." [emphasis theirs] They demonstrate that
the DNA damage rate from oxidative metabolism is a million times greater than the damage
rate from natural background radiation. Many multiples of background radiation can no
significantly increase DNA damage, but does stimulate repair of oxidative DNA damage.
While this does not necessarily prove beneficial effects, such research establishes
that the LNTH is not biologically feasible, and that beneficial effects are biologically
plausible and likely. Combined with the extensive evidence of stimulation of biological
processes and physiological functions, and the extensive evidence of biopositive effects
on organisms, and the epidemiological evidence in significant populations, the need for
changes in radiation science policy is established. The potential for human and
environmental benefits is enormous.
9. Biological models
Current data from cellular and molecular biology is being reflected in models of
biological processes and responses, and tumorigenesis. Simplified 2-stage models
(representing the 3- to 6-stage cancer development process) by Drs. Kenneth Bogen at LLNL
and Tom Downs at U. Texas, building on the work of Dr. Surhesh Moolgavkar and others,
reflect the linear damage from radiation dose, with terms to reflect repair processes,
including cell death by apoptosis and necrosis, along with wound healing and tumorigenesis
that produce a non-linear dose-response.
These and other models reflect the significant work being developed that scientifically
establish the biological validity of the evidence for biopositive dose responses.
10. Nutrition and health
Drs. Luckey, Planel and others have produced research data that find that background
radiation deficiency adversely effects microbes, plants and invertebrates as a dose
deficiency of essential vitamins and minerals. Such data is consistent with dose-response
for such nutrients that affects all orders of biota, including humans. Confirmatory
research on the role of radiation in health and nutrition, and on mammals, has not been
supported by the radiation science establishment, even though:
1. substantial results would be produced at the appropriate doses for radiation
protection;
2. such preliminary research would require much less than 1% of the funding of
current "radiation research", much of which is without merit except to
promulgate public fear; and
3. the potential benefits to human health are very great, along with the potential
for eliminating large and unwarranted public costs for unnecessary radiation protection,
and reduce the unfounded public fear of radiation.
Dr. Luckey states: "If ionizing radiation is an essential agent, most populations
live in a partial radiation deficiency. Radiation hormesis would then be the alleviation
of a partial radiation deficiency. This would make the dose-response curve for ionizing
radiation comparable with that of several essential nutrients. Examples include vitamin A,
thiamin, vitamin B6, calcium, iron and selenium. Individuals and populations who receive
insufficient amounts of these essential nutrients are routinely supplemented with those
nutrients. Supplementation with an essential agent present in insufficient amounts would
explain the dramatic results following small increments in whole body exposures to
chronic, low dose irradiation."
Dr. Luckey further states: "The cumulative knowledge indicates exposures to the
general population should be raised to a "minimum yearly recommended allowance"
(MYRA) of about 10 cGy/y (Luckey 1991). A public health evaluation should be undertaken to
establish the bases and methods of providing radiation supplementation as a public health
service."
Drs. Sadao Hattori and Kiyohiko Sakamoto report that radiation hormesis is being used
clinically to successfully treat and to suppress the reappearance of cancer in the
hospital of Tohoku University. This clinical program was founded on research that confirms
the stimulation of the immune system and the reduction and successful treatment of tumors
in animals. Successful clinical practice has been implemented using x-ray of about 15
fractions of 10 cGy each, delivered 3 times per week for 5 weeks, with standard high-dose
radiation treatments.
11. Costs
Radiation protection establishment policy is directed to support radiation protection
objectives committed to control radiation to negligible levels. This policy produces huge
government bureaucracies and high public costs for negligible public health benefits.
Estimates have been made for radioactivity "cleanup" and decommissioning that
could exceed US$ 2 trillion (million-millions) worldwide to meet standards that are far
below levels of naturally-occurring radioactivity. In addition to the costs for identified
"cleanup", public costs for regulatory control to negligible dose levels, and
for future "decommissioning" of facilities, are similarly enormous.
Professor Emeritus radiobiologist Dr. Marvin Goldman, UC-Davis, then President of the
Health Physics Society, stated: "Are we really serious about investing about a
trillion dollars to cleaning up our atomic backyard when in all likelihood very little
credible health risk may be involved...?"
Professor Dr. Klaus Becker asks: "How much of our rapidly decreasing funds can we
afford to devote to the further reduction of potential risks which, if they exist at all,
are so small that they could not be detected in decades of painstaking and expensive
research efforts?"
Professor Dr. Zbigniew Jaworowski states: "Each life hypothetically saved by
implementing the U.S. Nuclear Regulatory Commission’s regulations costs about $2.5
billion (Cohen 1992). Such spending is morally questionable. Studies of radiation hormesis
suggest that such expenditures may be futile and actually have an adverse effect on the
health of the population."
Professor Emeritus radiobiologist Dr. Gunnar Walinder, in distributing his book,
"Has Radiation Protection Become a Health Hazard?", states: "I do not
hesitate to say that this is the greatest scientific scandal of the 20th Century."
Radiation protection policies cause further unwarranted public costs by constraining
nuclear technologies through artificially high costs, and by promoting a public fear of
radiation that provide incentives for government and private interests to apply
alternative technologies that have higher actual public cost, provide lower public health
and safety, are less effective, and have greater environmental costs. In medicine, energy,
and industry, these policies have caused high public health and safety costs in addition
to economic costs; with rapidly growing prospects for international conflicts over
resources and environmental damage in the growing economies and populations of the 21st
century.
