The LNTH is based on presumptions, from early assumptions for administrative purposes, that:

1. Health effects documented at high-doses and high-dose-rates can be projected to zero with no threshold, even though contradicted by voluminous data and scientific evidence, by scientific principles, and biological data; and
2. Each radiation "hit" that damages DNA contributes directly to the possibility that the cell will develop cancer, even though low dose radiation DNA damage is insignificant compared to normal oxidative DNA damage, which is 10 million times greater than average background radiation, i.e., at about 3 mSv/year (300 mrem/year)²⁵.

These presumptions lead to the concept of collective dose. This results in adding units that are concentrations, which is scientifically invalid²⁸. Insignificant doses to individuals are therefore multiplied by large populations to predict health effects, equivalent to predicting: If 5 persons die in each group of 10 persons given 100 aspirins each, giving one aspirin each to 1000 persons will result in 5 deaths. The radiation protection policy that ignores dose rate effects data is equivalent to predicting that:

The study of this population has limited scientific and public policy application to setting radiation protection policies for chronic and low-dose radiation.

This population was exposed to near-instantaneous radiation of atomic bomb detonation, and has enormous confounding factors of personal conditions, and the effects and contaminations of war-time life, bomb effects, and follow-up conditions. Individual exposures are largely unknown, with radiation dose estimates that are known to be in substantial error, especially due to uncertainty in the neutron dose in Hiroshima. The "control" population was in the area following the bombing and so exposed to the fallout. The dose to these persons is claimed to be less than 0.5 cGy, but fallout doses have been estimated to be 20-50cGy. Therefore the Japanese survivor health effects are of minimal value to the knowledge of radiation dose-response for radiation protection purposes.

Unlike most government-funded studies, the Radiation Effects Research Foundation (RERF) data is not available to reviewers. This includes analysts for the taxpayer-funded BEIR reports. Recent US DOE attempts to establish control over the RERF provides further uncertainty in the results, following DOE defunding and closing of the Center for Human Radiobiology while more than 1000 of the study population was still alive; and its failure to publish the results of the 10-year (1978-87), $10 million, Nuclear Shipyard Worker Study that contradicts the LNTH, and to which $millions more were committed by DOE in 1994, still without publication.

However, notwithstanding these limitations, Dr. Sohei Kondo⁴⁸ and others report on the processed RERF data⁴⁸, plus independent analyses^50-52, that adverse health effects in this population are limited to persons exposed to high radiation doses. In the population of about 75,000 persons followed for 40 years, with about 21,000 total deaths through 1985, there were about 500 cancers more than expected vs. the "control population". However, there are approximately 600 excess cancers in the population near-instantly exposed to more than about 200 cGy, and approximately 100 fewer cancers for persons exposed to less than about 20 cGy⁴⁸. Kondo reports that those who were exposed to 1-9 cGy appear to have lower death rates from leukemia⁴⁸; and Dr. Sadao Hattori reports that about 8 cGy is the optimum dose for the suppression of leukemia in these survivors⁴⁹.

The BEIR V reports that the Life Span Study indicates no significant increases for leukemia below 0.4 cGy³, yet in typical fashion applies a linear result to presume effects down to zero dose. Dr. T.D. Luckey finds several discrepancies in the low-dose use of the LNTH as it applies to leukemia mortality²⁴, and shows that the data better fit the hormesis model. Dr. Myron Pollycove shows similar results for leukemia and non-cancer relative risk⁶. Mathematical analyses by Drs. Joseph Alvarez and Fritz Seiler also demonstrate discrepancies in the LNTH, and that non-linear models much better fit the data and show clear beneficial effects⁵⁰. The data find no increases, and statistically significant decreases, in non-cancer health effects below the estimated 200 cGy dose⁴⁸.

Only the shipyard workers on US Navy nuclear ships have moderately significant radiation doses in a moderately large population with high quality dosimetry and limited confounding effects from chemical exposures and other work conditions. The 10-year, US$ 10 million study of the shipyard workers undertaken in 1978, was completed in 1987. The nuclear workers were compared to a well-matched case-control shipyard non-nuclear worker group⁵⁶. These workers show significantly reduced total mortality. The US DOE funded this study. The study was not published in the scientific literature. It was only released by DOE under pressure as a contractor report, with a 2-page press release, in 1991. These results have still not been formally reported in the literature, although substantial funding and data analysis continues. Although Dr. Arthur Upton was Chairman of the Technical Advisory Panel (TAP) for this study, and he chaired the BEIR V Committee, this study was not included in BEIR V (though other unpublished work was included). Professor Emeritus Dr. John Cameron reported on this study and states: "The most significant and surprising finding of the NSWS research was that the nuclear workers with the greatest radiation exposure, a cumulative lifetime occupational dose-equivalent of 5 mSv or more, had a standardized mortality rate (SMR) of deaths from all causes of only 0.76 that for their age and sex in the general population, while the non-nuclear workers had an SMR of 1.0^12-13." Professor Emeritus Myron Pollycove states: " The nuclear worker groups had a lower death rate from all causes, leukemia, and LHC than the non-nuclear workers⁶."

Professor Emeritus Dr. T.D. Luckey reports on information from nine studies with nuclear workers and bomb test observers totalling 13 million person-years⁵⁶. The results show the exposed worker cancer mortality rate to be 65.6% of that of carefully selected control populations. Studies of the "high-dose" groups in the US and in the UK, including the cleanup workers following the 1957 Windscale fire, demonstrate that no excess cancers exist in these most significant populations1^7,57.

In a study by the US National Cancer Institute of the more than 100,000 U.S. female radiologic technicians certified since 1926, more than 500 eligible breast cancer cases had a mean of follow-up of 29 years; however, no association was found for breast cancer to experience in radiotherapy, radioisotopes, or fluoroscopy, nor to personal fluoroscopy or multifilm procedures⁶³.

Medical patients receive significant radiation doses, with poor to good dosimetry. Early patients have demonstrated adverse long-term health effects from high doses. However, there are millions of procedures with moderate exposures every year subject to prospective studies. Some historical records enable credible followup. Radiation protection interests fail to undertake credible research on these most significant populations.

Hyperthyroid patients treated with I-131 received an estimated 10 cSv whole-body/bone dose. Of 22,000 patients treated by I-131 vs 12,000 treated by other means, primarily surgery, there is no leukemia increase^59,64. This is contrary to BEIR V LNTH predictions that leukemia would more than double³. 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 cancer⁵⁹. In fact, these patients have a significant reduction in thyroid cancer.

Studies of significant x-ray exposures and leukemia incidence are also negative⁶⁵. Yalow reports on one such study based on competent records of exposures up to 300 cSv from normal x-ray practices over many years^59,66. Yalow reported also on the extent of the evidence that doses at the level of moderate medical exposures, which are very much higher than radiation protection limits, are not implicated in adverse health effects⁵⁹.

In the case of high doses from multiple fluoroscopies to female tuberculosis patients, data at doses below 30 cSv indicate highly significant reductions in breast cancer, although the report projects a straight line from higher dose data, simply dividing all excess cancers by total dose to claim an excess of breast cancer, ignoring and contradicting its own data^5,6,67. A more recent report obfuscates this relationship^40,68.

Stimulation of the immune system by ionizing radiation, based on animal studies^30,31 using 10-15 fractions of 10-15 cGy each over 3 weeks, is successfully treating and suppressing the reappearance of cancer and non-Hodgkins lymphoma in the hospital of Tohoku University³².

Recent follow-up data and analyses by Dr. Constantine Maletskos, working with Evans, reports an estimated threshold of 1100 cGy⁷²; by Dr. Otto Raabe who reports a threshold of about 1000 cGy⁷³; and by Dr. Robert Thomas, who reports that a log-normal projection of just the homogeneous group of female dial painter cases, ignoring the fact of thousands of cases with no cancers, projects to a minimum threshold of about 400 cGy^14,15. Recent work indicates that the doses to these populations were underestimated with corrections that confirm the threshold, but work to scientifically study this data is not supported¹⁶. Direct exposures to external gamma radiation from daily work with luminous compounds on studio bench tops, while sitting for many hours per day, is a highly significant but unquantifiable contributor to radiation exposure to the upper torso and head in considering the potential risks from low level radiation⁷⁴.

An NAS report on 40,000 military participants in the July, 1946 Operation Crossroads, including one detonated below the water that greatly increased radioactive contamination, found. total mortality slightly higher than controls. However, cancer death is not increased, nor is any other cause of death potentially associated with radiation. The average dose was estimated to be 6 rem (cSv). There is also no increase found associated with groups with the higher doses⁷⁶.

Fallout from the 1954 Bravo nuclear weapons test affected the Marshall Islanders, and fishermen on the "Lucky Dragon" fishing vessel. Ash stuck to the skin and caused significant burns. In the high-dose group in the Marshall Islanders there was an excess of thyroid nodules⁴⁸. The 23 "Lucky Dragon" fishermen were exposed to roughly 200 rad (cGy) to 670 rad (cGy). The person exposed to an estimated 670 rad (cGy) died 206 days after the event. All others, monitored for 24 years, showed no associated adverse health effects. At 21 years, one died of ascites caused by cirrhosis. No cancers were observed^48,77.

No excess cancers are found in the public in Utah exposed to above-ground atomic bomb test fallout³. In a study of British bomb tests, although the participants had significantly more leukemias and multiple myelomas, there was no association with the type or degree of radiation exposure⁷⁸.

In Russia, Prof. Dr. Zbigniew Jaworoski reports that 10,000 people were evacuated from a 1957 thermal explosion of nuclear materials in the Urals. In the 7,852 people studied for 30 years, tumors in the 496 mSv group were found to be 28% lower, in the 120 mSv group 39% lower, and in the 40 mSv group 27% lower in the exposed population than in the nonirradiated control population from the same region⁷⁹.

Dr. Alan Brodsky reports: "The Chernobyl accident has been estimated in an appendix of the 1988 UNSCEAR report to produce a collective dose equivalent of 0.6 million personSv (60 million person-rem), mostly in the former Soviet States and Europe. Thirty percent of this collective dose has been delivered in the first year following this 1986 accident, and the remainder will be delivered in the tens of years after the accident. This collective dose (in the first year) is about 2 percent of the annual natural background collective dose to the world population⁸⁰.

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."⁷⁹ Professor Jaworowski also states: "Eleven years that passed since the Chernobyl catastrophe are more than enough for realistic assessment of its early and late health effects. The fatalities of the Chernobyl accident caused by ionizing radiation, are 28 victims who succumbed to accute radiation sickness. Three more persons died during the first few weeks due to non-radiation factors of the catastrophe. Thus, the total of the early victims amounts to 31 persons. Over the next ten years 3 children died due to thyroid cancers⁸¹."

A preliminary AEC analysis of external radiation dose and national cancer data by states in the U.S., with rigorous statistical analysis to test various linear models, found that the "high background states", with 3 times higher doses than the low background states, and twice the national average, have consistently and significantly lower cancer rates, with analysis of readily identifiable confounding factors⁸⁵. This study at state-average data levels was preliminary to plans for more comprehensive studies of cancer and radiation at county or other population group levels. However this AEC contract to support environmental assessment was then terminated, and the work unpublished, by AEC and later by DOE. Subsequent analyses with later U.S. average dose and cancer data has confirmed these results^24,87,88.

Studies of lung cancer and other cancer rates as a function 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 and the LNTH has been developed for over 10 years produced by Professor Emeritus Bernard Cohen at U. Pittsburgh, incorporating more than 350,000 home radon data measurements and cancer data from 1792 counties, using 1601 counties to avaoid ‘retirement’ states, including about 90% of the U.S. population^89-98. This study and responses to all criticisms, demonstrates that the LNTH can not be valid^97,99-100. Analysis by leading epidemiologist Dr. Graham Colditz at Harvard University establishes the validity of the biostatistics in the population analysis⁹⁶. Drs. Fritz Seiler and Joseph Alvarez also document the case that the data on the whole population define the valid dose-response relationship, superceeding the question of a ‘model’ and what ever confounding factors may exist¹⁰¹.

Populations in radon spa areas, for example, in the area of Misasa Japan, find lower cancer rates in the higher radon source area^49,102. Smaller populations with larger dose differences include Kerala India at about 4 times average background, Guarapari Brazil, about 6 times, and Ramsar Iran, about 10 times background⁸³. These populations all find no adverse effects from background radiation^24,103-105 To the contrary, "The people of Kerala have a higher fertility rate with the fewest neonatal deaths than any other state of India²⁴" Dr. Kondo states: "The negative correlations of home radon levels with lung cancer rates ... are based on ecological studies on groups of people; they can be taken as strong evidence against the validity of non-threshold hypothesis that is adopted for the assessment of radiation risk by the EPA and corresponding agencies in many other countries of the world.⁴⁹."

The work during and following the Manhattan Project, by Egon Lorenz of the National Cancer Institute, and many others at AEC-supported national laboratories and universities, report on beneficial effects: lower cancer rates, increased mean life span, increased growth rates, increased size and weight, and increased fertility and reproduction, and reduced mutations, along with many enhanced physiological and biological functions^58,108,109. Studies that fail to demonstrate beneficial effects are largely the result of using hybrid animals with deficient immune systems, keeping animals germ-free, and even studies that discard controls with early mortality²⁴. 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.

Dr. Luckey reports that: "The beneficial effect of low dose irradiation was discovered 100 years ago at the University of Missouri. Professor W. Shrader (1896) inoculated Guinea pigs with diphtheria bacillus. Unexposed controls died within 24 hours. When animals were exposed to X rays before inoculation, they survived²³," and "The statistically significant results of Lorenz have been confirmed in several studies. The well-designed and executed experiments of Donaldson (1964), Bonham (1990), and Hershberger (1978) leave little doubt that chronic exposure of young animals to low doses of ionizing radiation increases the growth rate. Exposure to acute doses is less pertinent; however, such data add evidence to the concept of radiation hormesis. A chronologic perspective of radiation hormesis in growth suggests this is a general phenomenon.²⁴." Dr. Harold Boxenbaum reports that: "Further support that radiation produces longevity hormesis is supplied... (I)n this case, the data deal with chipmunks living in the wild. The animals were live-trapped, irradiated with either a single-dose of 200 or 400 Roentgens gamma-radiation, except for controls, and then returned to the wild. It is readily apparent that gamma-radiation exposure, within the dose-range utilized, enhanced longevity¹⁰⁸."

In mammals, some population studies replicate the beneficial effects of low level radiation doses, while none show detrimental effects consistent with the LNTH. However, many studies did not include the dose range of interest due to the radiation protection establishment requirements to assess higher doses for purposes of radiation protection standards. Since there was general knowledge of beneficial effects at lower doses, it was easy to avoid both the dose ranges of interest and to perform studies with animals that would not have full immune competence to enable a general beneficial response.

Studies have demonstrated beneficial effects of low level radiation in response to infection, as early as 1896, and to wound healing, and other adverse health conditions²⁴. However, no generalized research was supported on such beneficial effects in order to establish the role of radiation in physiology, health and medicine. Beneficial effects in dissolving selected cancers and in non-Hodgkins lymphoma have been documented, but research on such potentially beneficial applications has again not been supported in the interest of radiation protection programs and costs.

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^{33,45,49,109,122-124}. Dr. Kondo (1988) 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, which eliminates injury¹²⁸. Apoptosis is shown to be stimulated by radiation, and that the role of radiation at low doses that do not exceed the body’s capability to function within the cell life-cycle, may be beneficial, if not essential in the process of cell repair.

Dr. James Trosko and others show that radiation damage effects can only initiate at levels that exceed normal levels of oxidative damage; and that responses are triggered by intracellular signal transduction mechanisms that are epigenetic, not genotoxic, in nature¹²⁰. As such, radiation doses sufficiently high to contribute to cancer are not the result of a toxic insult, but triggered by a non-stochastic epigenetic process. When damage frequencies are within the background rate of metabolic processes, which are thousands to millions of times the natural radiation background rate, proliferation and adaptive functions in multi-cellular organisms regulate damaged cells through sharing reductants for repair and by triggering apoptosis. Biologically, cancer can not be caused by radiation at low doses.

Drs. Myron Pollycove, Ludwig Feinendegen, and others report on work by Drs. Daniel Billen, John Ward and others that cellular and DNA repair mechanisms are complex functions of the effect of radiation on the stimulation of multiple repair mechanisms^25,129,130. Research has demonstrated that radiation enhances known specific repair processes that control the repair effectiveness of both DNA and cellular damage events¹³¹. The work on the cell by Dr. Bruce Alberts, President of the National Academy of Sciences, and others, find that the normal metabolic and oxidative DNA damage events rate is extremely high¹³¹. The DNA damage rate of radiation due to natural background radiation is an insignificant fraction of the normal DNA damage rate. At many multiples of natural background radiation, these events remain insignificant contributors to DNA damage and mutation rates. However, at such levels, recent research led by Dr. Sadao Hattori in Japan^49,133, and Dr. Shu-Zheng Liu in China^33,122, and Drs. Sheldon Wolff¹²¹ and Takashi Makinodan¹³⁴, and others, have confirmed that both DNA and cellular repair mechanisms are enhanced.

Dr. Takeo Ohnishi states, "The induction of p53 by low dose radiation may contribute to the prevention of cancer event, because there are thresholds in several kinds of radiation-induced cancer¹³⁵." Drs. Yoshio Hosoi and Kiyohiko Sakamoto state, "TBI [total body irradiation] on mice with 15-20 cGy suppressed spontaneous lung metastasis significantly, and 15 cGy was the most effective dose¹³⁶." 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. [emphasis theirs] At high levels, radiation supresses them; at low levels, it stimulates the DNA damage-control biosystem¹³⁷."

Dr. T.D. Luckey states (1996): "Ionizing Radiation as an Essential Agent: 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 irradiation⁷⁸."

In addition to identified "cleanup" costs, public costs for regulatory control to negligible levels, and for future facility "decommissioning", are similarly enormous. 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? Tens of billions of dollars are spent every year worldwide in decommissioning, redemption, or nuclear waste programs, which could obviously be used much more beneficially in other areas of public and individual health, in rich and even more so in poor countries¹⁴⁷."

Professor 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 population⁷⁹."

The author has stated, "Recently, however, these radiation protection excesses have resulted in large incremental public costs, with even more proposed, with no accompanying public health benefit. Currently, these policies especially effect radioactive waste management and site decommissioning costs, to the benefit only of government bureaucracies and contractors. The immense costs incurred are reducing the viability and public benefits of many radiation and nuclear technology applications, and humanity is losing major advances and contributions to human health and well- being, without benefit to public health⁵."