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Can ICRP Be Trusted To Set Radiation Exposure Standards?
by Rosalie Bertell, Ph.D., GNSH
Osaka Symposium August 13, 1995
AUGUST 1945:

I was sixteen years old in the summer of 1945. In June, I had completed grade ten, and would enter grade eleven in September. I remember well the invasion of Normandy and the end of the European War. A young girl who lived two doors from my home had married her childhood sweetheart, a young neighborhood boy in April 1945, and he was sent overseas almost immediately with the US army. His first battle was the invasion of Normandy, and he died on the beach head. His young pregnant wife was devastated by the news. The pain of invasion could be felt in the whole neighborhood, as we saw the build up toward an invasion of Japan. Remember, we had heard horrible stories of the fighting in the Pacific Islands, most recently at Iwo Jima and Okinawa.

Then on 6 August 1945, the President announced that the US had dropped a new and awesome bomb on Hiroshima, and this might make it unnecessary to invade Japan. On August 9, a second bomb was dropped on Nagasaki. We were told that Japan's military ship building was the target. Then Japan surrendered, and there would be no second bloody invasion to end the Pacific War. Everyone went crazy with celebration. My brother went to our Church and he, together with another boy, rang the Church bells for twenty minutes straight, until they were both exhausted. All of the Church bells in the city were ringing, and the people were out in the streets singing and laughing with joy. The boys were coming home. The war was over!

During the war there were many patriotic demands made on us, like rationing of food in short supply or needed by the troupes. We also wrote letters to the boys in service. I took on a slightly different type of letter writing. I wrote to boys who were conscientious objectors, who refused to kill. This was a very patriotic war and conscientious objectors were treated like dirt in the military. They had to put in their time in the service, but were given the most disagreeable jobs the military could find. I undertook to support them and try to keep up their morale. Killing, and what I understood as Abully power@ merely biased the post-war negotiating process where the real decisions which carved out future relationships were made. The strongest, not the most just, got to Al ay down the law@. This merely set the stage for the next war, as the loser tried to build up the power to confront his oppressor.

On August 15, 1945, as all the neighborhood was celebrating, my Mother was strangely quiet. As she prepared the supper, I watched her stir the soup and keep repeating:
AThey should not have done it. They should not have done it.@ These words still haunt me. They were correct, but I do not know how my Mother knew, because the propaganda was so strong at the time.

GOD'S LAKE URANIUM MINE:

My Father served on the Financial Advisory Board of our Church. During the late 1940's, when there was a boom in the uranium mining industry, the Church wanted to invest in God's Lake Uranium Mining Co. in Canada. My Father strongly objected to this, and I heard him talking about it at home. Eventually, the Church withdrew its proposal and did not invest in this industry. There were no nuclear power plants at that time, so, as I know now, the only use for that uranium was bombs. Again, I do not know how my Father knew this or why he so vehemently opposed this industry. He was a businessman himself, the President of the Standard Mirror Company, which produced most of the automobile mirrors of the Detroit car industry.

THE PEACEFUL ATOM PROGRAM:

Atomic bombs had proved to be limited in size. In order to induce sustained nuclear fission, the chain reaction which produces all of the energy, the uranium 234 atoms need to be brought very close together so that the neutrons released in the splitting of the atom can reach other atoms and continue the splitting. In an explosion this fissionable material is blown apart and the reaction stops. The first large hydrogen bomb explosion occurred in March of 1954 at the Bikini Atoll in the Marshall Islands. We, in North America, did not know what had happened to the Rongelap People and the other Marshallese. Nor did we really understand that this new hydrogen bomb provided the military with a bomb, which had no upper limit in detonation power. The bomb was based on fusion rather than fission. In fusion, atoms are forced together rather than blown apart, and in the process they release an almost unlimited number of neutrons. The energy for the fusion was produced by a fission detonation. The neutrons produ ced by the fusion were then absorbed into a blanket of fissionable atoms producing detonations in the megaton rather than the kiloton range. There was no theoretical upper limit to size. These hydrogen bombs were able to cause damage one thousand times the damage done at Hiroshima.

In the wake of the Bikini test, called Bravo, the military decided to change the whole arsenal to thermonuclear devices - atomic bombs. For this, it required extensive uranium mining, a series of large production facilities to enrich the uranium, bomb production factories, and public tolerance of the waste from all parts of the cycle. They also needed the cooperation of society with the transportation of radioactive material, radioactive effluences from nuclear facilities and uranium support industries. The military needed University cooperation in preparing nuclear engineers and nuclear physicists to staff its technical needs. All of this would be impossible during peacetime when the only purpose was producing weapons of mass destruction. They were already experiencing the rumbles of anger over the Nevada Nuclear Testing Site, established in 1951 as an atomic bomb proving ground.

From the military point of view, it was acceptable to cause a few deaths down wind of the Nevada Test Site and from their military operations, because they were (they thought) preventing a nuclear war. The thought of a bomb dropping on New York or Los Angeles in revenge for Hiroshima and Nagasaki, or in defiance of the new-found power of the United States, justified any thing in their minds. These were never democratic decisions in the US. They were made in the Joint Atomic Energy Committee of the US Congress, presided over by Senator Pastore between 1945 and 1972, when it was finally abolished. This joint committee had members from both the House of Representatives and the Senate. They took their decisions in secret committee meetings and then introduced the same bills into both the House and Senate. There was little debate as most members of Congress assumed the Committee understood the needs and was only seeking congressional approval. Because House and Senate bills were always the same there was no need to reconcile (therefore debate) the bills. The general public accepted the secrecy of the nuclear decisions because it was said that information on this awesome weapon should not fall into the ”wrong hands”. It was better for the average person to know nothing. In fact the Atomic Energy Act of Congress made any information related to the atomic bomb, even the health effects of radiation, secret for National Security, even if one discovered it in one's own laboratory or through one's own research.

Shortly after the hydrogen bomb explosion in March of 1954, President Eisenhower made his Peaceful Atom speech in the United Nations, and people were told that this awesome energy was now tamed and could produce unlimited amounts of electrical energy. It would produce electricity too cheap to meter. It would instantly bring the developing world into modern, high standard of living, industrialized economies. There would be no more war, because the whole world would have as much of all the good things in life as they could ever desire. For a world just beginning to understand Hiroshima and Nagasaki, and the potential atomic megadeath, this promise of something wonderful for humanity arising out of the ashes was intoxicating. Academics, who abhorred the bomb, began to study nuclear science. It became popular in the schools. People became willing to mine uranium and to tolerate the effluence and waste. Nuclear engineers and physicists became like gods, and they were admired for their intelligence and thei r ability to attract government grants. They were like super-humans, privy to the secrets of the gods, which were totally beyond the understanding of most people. The peaceful atom myth was very successful in gaining the public support, without which the build-up of nuclear weaponry would have been impossible. Most of the civilian enablers of this military addiction where completely unaware of their roles. Many were pacifists and anti-war activists.

The United Nations' response to Eisenhower's Peaceful Atom speech was to establish the International Atomic Energy Agency (IAEA). This new agency was given two mandates: to prevent the horizontal proliferation of nuclear weapons, and to promote peaceful uses of nuclear energy. It has no basic mandate to abolish nuclear weapons or to promote health or safety relative to nuclear technology. (The IAEA is still busy trying to find medical, agricultural and commercial uses for nuclear energy. More recently, it has been promoting the image of nuclear power as a ”safe clean technology” for energy production by down-playing the radiological consequences of the Chernobyl accident. This doubly victimizes the people who lived near this failed reactor: first they were the innocent victims of the disaster and now their illnesses and sufferings are being denied. I think that the Japanese can understand this injustice.)

By the late 1950's, with great ceremony, the first civilian nuclear reactor was christened in Shippingport, Pennsylvania and the era of nuclear power began. In reality, this nuclear reactor was taken from one of Rickover's nuclear submarines and placed on land. It was modeled after the 1943 reactor built in Hanford, Washington, to produce plutonium for the Manhattan Project Nagasaki bomb. There was nothing new about it. It was an extremely dangerous way to boil water for an ordinary steam-to-electricity plant.

THE INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION:

According to the available information, the US military had six nuclear bombs at the end of World War II. Two were dropped in Japan, leaving four to be used in ”tests”, which they decided to conduct in the Pacific Islands. I think that the Atolls, with their beautiful necklace-like chain of Islands looked like a bull's eye target to the military. Testing at Bikini began in the summer of 1946, even before the United Nations had given the Territory of Micronesia into the ”protection” of the United States as a Strategic Trust Territory. The Trust was not established until 1947, and it was only the UN Ambassador from Australia who objected. The whole world knew that the US was already using the Atolls as a nuclear weapon testing range. The Australian Ambassador resigned, was replaced, and the vote taken in favor of US possession. The world looked the other way as the 32,000 People of the Marshalls were subjected to some 68 nuclear tests.

One of the physicians who served at the Bikini Atoll gave up the practice of medicine after he saw what the radiation effects were on the sailors sent into ground zero after the tests. All of the health damage was classified as secret, even from the men themselves.

Originally, the military thought that the radioactive fallout would ”only” spread over about half of the Northern Hemisphere. They found that the lethal cloud circled the earth about two and a half times. The three Nations which had produced these bombs - the United States, Britain and Canada - had different radiation protection standards at the time, and they were afraid of some neutral Nation bringing a law suite against them for the fallout. The nuclear physicists from the three countries met between 1945 and 1950 to hammer out an agreement on ”radiation protection” standards, which could then be promoted globally. This committee of physicists was called the Tolerance Dose Panel, indicating a belief that people would be able to ”tolerate” and adapt to increased radiation pollution in the nuclear age. The Medical communities in both Britain and the United States were alarmed, and they organized two other investigative committees on radiation protection standards. In Britain, i t was the National Radiation Protection Board (NRPB), funded by the government, and in the United States a committee called BEAR, Biological Effects of Atomic Radiation, funded by the Rockefeller Foundation. The physicists decided that 15 rem (150 mSv) per year for nuclear workers and 1.5 rem (15 mSv) per year for the general public was a reasonable trade-off between cancers likely to be caused by the exposure and the benefits of the activities which caused the exposure. At the time, the ”benefits” were atomic bombs. The NRPB and BEAR decided that 5 rem (50 mSv) per year for workers and 0.5 rem (5 mSv) per year for the general public was a more health protective alternative than that proposed by the physicists.

Prior to 1950, radiation protection standards were based on protection against skin burns. It had been know since about 1912, however, that radiation also caused cancer. This became even more painfully apparent with the deaths of the radium dial painters. In about 1943, Hermann Muller received a Nobel Prize for showing that radiation was effective for causing genetic damage in the fruit fly. During the 1945-1950 period, several different biological endpoints were considered on which to base radiation protection standards: skin damage or other injuries, fatal tumors, general effects on blood, cataracts, obesity, impaired fertility, shortened life-span, or genetic effects (from G.J.Neary, ”The Evaluation of Tolerance Levels” in Biological Hazards of Atomic Energy, edited by A. Haddow, and published by Oxford Clarendon Press in 1952).

The committee decided to base the standards on fatal cancers, and since then the arguments have centered around just how many fatal cancers would be caused by exposure of the Standard Man to one rem (or equivalently, 10 mSv) of whole body ionizing radiation exposure. The carefully worded statement is: ”What people should be concerned about after radiation exposure is fatal cancer.” The many other possible damages have faded into the background.

In 1928, radiologists had formed an international organization to compare their experiences with exposure to medical X-ray sources and to set standards to protect themselves and their co-workers from its harmful effects. In 1952, the Manhattan Project physicists who had been trying to decide on common radiation protection standards approached this group of radiologists and suggested that they combine into one group. The physicists agreed to not ever limit medical use of radiation on patients, but only to set standards for worker exposure and exposure to the public from nuclear industries. They proposed their 15 rem (150 mSv) per year radiation limit for workers, but were eventually prevailed upon by the NRPB and BEAR committees to reduce this to 5 rem (50 mSv) per year. The merger of these two groups was called the International Commission on Radiological Protection, ICRP. ICRP now claims that it began in 1928, when the radiologists first organized, but this was a very different organization.

ICRP is a self-constituted organization. Since 1952 it has maintained a membership of about 50% physicists and 50% medical doctors. The doctors have been about 25% medical administrators (often from nuclear weapon countries) who set radiation protection practices in their National Ministries of Health or Labour and about 15% medical radiologists. The other 10% has consisted of one pathologist, two geneticists and some biophysicists. By their rules, the Main Committee, responsible for all decision making, will not ever include an epidemiologist, occupational health specialist, public health specialist, oncologist or pediatrician. One can say that it consists only of users of radiation and administrative regulators. Since 1952, the ICRP has perpetuated itself, with current members nominating new members. These were approved by the Executive Committee of the International Radiologists Association at first, and then by the ICRP's own Executive Committee. Membership term is for an unlimited time. They have n ot mandated themselves to be protectors of worker or public health, but rather to recommend ”sensible” trade-offs of health for the benefits of their activities.

By 1957 the ICRP got out its second publication, recommending that the internal radiation dose to workers and the public be limited to 5 rem (50 mSv) per year of any ingested or inhaled radio nuclides. The committee originally intended that this be a combined external plus internal dose limit of 5 rem (personal communication, Dr. Karl Z. Morgan, Chairperson of the Internal Dose Committee of ICRP). Actually, it was often interpreted to mean the worker could get both internal and external doses per year. There was another abuse related to internal contamination, i.e. when radionuclides were ingested or inhaled and became incorporated into bone. These nuclear experts counted only the 4 or 5% of total dose delivered the first year and then forget about subsequent years. A slowly delivered dose due to bone incorporation could continue for 50 to 60 years.

ICRP Publication 2, 1959 states:

”The permissible dose for an individual is that dose, accumulated over a long period of time or resulting from a single exposure, which, in the light of present knowledge carries a negligible probability of severe somatic or genetic injuries, furthermore, it is such a dose that any effects that ensue more frequently are limited to those of a minor nature that would not be considered unacceptable by the exposed individual or competent medical authorities.”(Section 30. Emphasis added).

It is important to note several things: first, dose rate is not considered to be important; second, only severe effects are prevented, and third, the probability of more frequently experienced effects is admitted but dismissed as not unacceptable. The recommendations are resting on several value judgements and not on objective norms protecting health. Effects of a minor nature include non-fatal cancers, embryonic and fetal loss, still birth, and congenital malformations or diseases, which are not inheritable.

GENETIC DAMAGE:

On 6 February 1947, Professor D.G.Catchside, member of the Faculty of Botany at Cambridge University, prepared a memo on: ”the genetic effects of irradiation with reference to man”, and sent it to the British Medical Research Council subcommittee on radiation protection standards. He testified that even the smallest dose of ionizing radiation caused genetic effects. His own experiments included doses down to 0.1 rem (1 mSv) per day on mice. All genetic effects from X-ray or gamma rays was cumulative, either additive or proportional to total dose. Even when the dose rate was lowered, genetic effects were additive. He was concerned about doses to human ova and sperm.

Dr. D.E.Lea answered Catchside in a memo to the Medical Research Council dated 28 April 1947:

”In writing this memorandum I assume members of the panel to be familiar with and accept the survey of Genetic Effects of Radiation prepared by D.G.Catchside.” He suggests accepting the observations but not trying to prevent the problem since: ”It will not be possible to prove whether any particular instance was caused by radiation, so no question of liability for compensation can occur.” Lea stated this twice, first with respect to deleterious effects caused by recessive gene mutations and second, with respect to semi-sterility. Lea concludes: ”so long as less than 1% of the population is exposed to radiation there is not likely to be a noticeable increase in the incidence of hereditary abnormalities.”

Apparently this dialogue was passed on to the Tolerance Dose Panel of nuclear physicists, because they held a meeting on genetic effects in April of 1948. No minutes are available from this closed meeting. Some members of the Tolerance Dose Panel went on to found the ICRP, and were members of its Main Committee when the question of genetic effects surfaced again in 1957.

Professor Catchside delivered a paper, ”Genetic Effects of Radiation” at the Conference on the Biological Hazards of Ionizing Radiation at Cambridge in 1950. He stated clearly: ”There is no threshold, no time factor (latency period) and no recovery”.

”The genetic defects would consist in part of obvious and gross ones and in part of the minor ones which tend to reduce the fitness of many apparently normal individuals. The latter effects may well be rather considerable and the more important from the point of view of the species as a whole. The total effect may well be very serious or even disastrous.”
(Catchside in Biological Hazards of Atomic Energy, edited by A. Haddow, and published by Oxford Clarendon Press in 1952, Pages 47-55).

The same caution was echoed by Hermann Muller, who was by that time a member of the ICRP Main Committee. This position is detailed in: ”Radiation and Heredity”, American Journal of Public Health, Vol. 54 No.1, pp 42-50, 1964, in an article which Muller published.

While both Catchside and Muller based their concerns on animal and plant studies, I had reached the same conclusions after studying the effects on medical diagnostic x-ray exposure. In the childhood leukemia data, leukemia was a late-death phenomenon. What I mean by this is that large numbers of embryonic and fetal deaths, neonatal or infant deaths also occurred in the irradiated group. The number of such deaths was significantly higher than the losses in the unexposed group. The final deaths in the birth cohort occurred after one year of age and were leukemia (or other cancer) deaths up to age 15 years. I reported this in ”Radiation Exposure and Human Species Survival”, Environmental Health Review, Vol.25 No.2 (1981). My reasoning was that if medical x-ray during pregnancy was so lethal, it was very likely that many more babies who survived were damaged in some way. After exposure to a trauma capable of killing, it is unlikely that survivors had no residual problems. These were of course, ha rd to detect since there was no way of knowing the potential health of the offspring had they not been irradiated.

It was Professor K. Mather, Department of Genetics, University of Birmingham, U.K., who answered the objection that there would be a ”slow loss of fitness in the population” with chronic exposure to radiation. Mather takes courage in the ”fact” that no more than 1% of the population would be exposed to radiation, but this was before the spread of nuclear technology and the fallout from nuclear weapon testing programs globally. He noted that:

”In particular, in human society, the fate of an individual is not independent of the activity of his fellows ... If his fellows take steps to alleviate his lot, his selective disadvantage will, at least in some cases, be reduced and his contribution to the next generation increased ... The point to be made clear is that, in the case of man, discussion of the effect on the community of raising the mutation rate cannot be divorced from consideration of changes of selective forces, in the way that is possible with other species.”
In Biological Hazards of Atomic Energy, edited by A. Haddow, and published by Oxford Clarendon Press in 1952, Page 64).

This is the old discredited argument of eugenics. In its more modern form, it advocates amniocentesis during pregnancy and abortion of genetically inferior offspring. This does not change the reality of damage to the human gene pool. It only kills the victims who are most easily identifiable. There will be many more who are not identified for years after their birth. The genetic load of the species will increase, and as Einstein said in 1945: ”we will have fewer geniuses”. Your own eminent and internationally recognized scientist, Dr. Ichikawa has often spoken out on the sensitivity of genetic material to even very low levels of radiation. He has also demonstrated the power of these rays to mutate flowers planted in the vicinity of nuclear plants.

The Atomic Bomb data has been recognized for many years as being inappropriate for the study of the genetic effects of radiation. The United States National Academy of Science Committee on the Biological Effects of Ionizing Radiation (the BEIR Reports) normally uses mouse studies for their risk estimates, although their cancer estimates are based on the Japanese data. BEIR III (1980) contains a section called ”Advances in Knowledge Since 1972" (pages 74-79). In this section, the committee says, with respect to genetic damage:

”We cannot ignore such mild mutations ... taken over the whole period and in conjunction with other mutants, their effect may be far from negligible. Despite a concern for this effect, we shall not attempt estimating it quantitatively...

”In contrast to somatic effects, where the concern is concentrated mainly on malignant disease, the genetic effects are on all kinds of conditions, for the spectrum of radiation-caused genetic disease is almost as wide as the spectrum of all other causes.”

Recently the BEIR Reports have used atomic bomb data to support their theory that humans have undetectable genetic damage from the atomic bombs. As early at 1957, the World Health Organization called together a Committee to study the genetic effects of radiation and to recommend protection of the human gene pool. In the publication by this committee, Kerala, India, was identified as the best place to study the genetic effects of chronic radiation exposure over several generations. To date, the nuclear establishment has not undertaken a serious study of this population, indicating their lack of concern for genetic damage. In one study, undertaken for another purpose, the authors noted that the exposed population of Kerala had an abnormally high rate of Down
=s Syndrome. Researchers also found significantly high levels of broken chromosomes in the exposed group. In 1988, with the help of Indian researchers, I agreed to act as sci entific advisor to a study of the people of Kerala. Researchers found that they were the first group to interview and examine the population, although the nuclear industry often uses Kerala as its example to ”prove” that low level radiation is harmless.

We now have measurements of the background radiation at grid points all through the contaminated area, detailed information on about 32,000 exposed households and matched control households not living on contaminated sand, and information on 92,000 pregnancies. Our preliminary findings are that the rate of Down
=s Syndrome is 3 to 4 times higher in families living on the radioactive sand than for control families. Other problems which were more than doubled for the radiation exposed group were congenital blindness and deafness, epilepsy, malformation of long bones, childlessness (couples who wanted to have children but could not), and various kinds and degrees of mental retardation. In the communities living on the contaminated soil every one of the so-called sentinel mutations, rare genetic damage was found. This was not true for the matched controls. We are still trying to raise money to complete the detailed analysis of this important data.

In my opinion, all future radiation protection standards should be based on damage caused to future generations. This will significantly lower the limits of exposure, which are now officially considered ”safe”. It has serious implications for further plans to expand the nuclear industry and for the management of nuclear waste.

HOW MANY DEATHS ARE ”ACCEPTABLE”:

In basing radiation protection recommendations on fatal cancers, the ICRP makes a decision on how many cancer deaths per year are ”acceptable” for the activity (building nuclear bombs, generating nuclear power or caring for a patient with a radium implant). The fatal cancer risk is an estimate of how many cancer deaths are expected for an exposure to 10 thousand Person Rem, or, equivalently, the exposure to 100 Person Sieverts. Prior to 1990, the official fatal cancer estimates for this exposure were 1.25 (ICRP) or 1.00 (UNSCEAR- United Nations Scientific Committee on Atomic Radiation). I think that UNSCEAR merely rounded the numbers to the nearest digit.

There are also international guidelines for ”safe industries”, for example a chemical plant, which state that in a safe industry there will be no more than one death per 10,000 workers per year. A safe industry in a city, is one that causes no more than one death per million people per year.

If one examines the ICRP recommendations for whole body exposure, which governed the nuclear industry between 1952 and 1990, one finds that the maximum permissible dose to workers was 5 rem per year. If 10,000 workers actually received that dose, the industry would cause 50,000 Person Rem exposure or five fatal cancers (using their risk numbers). Yet, they have never acknowledged this to be a hazardous industry. Instead, they claimed that the workers only received an average of 1 rem a year, not 5 rem, (10 mSv, not 50 mSv) and therefore only one cancer death per 10,000 workers per year would be caused.

In 1990, the ICRP, after re-assignment of doses to atomic bomb survivors, and pressured by scientists and medical professionals globally, moved their risk estimate to 5 fatal cancers per 10,000 Person Rem, or, equivalently, 100 Person Seiverts. This again makes the nuclear industry ”hazardous” even at 1 rem (10 mSv) per year average exposure. It means that 5 fatal cancers are caused. The ICRP lowered its maximum permissible dose in 1990 to 2 rem or 20 mSv per year, averaged over five years. Using their figures, this means a commitment to 10 fatal cancers for nuclear workers per year is considered by ICRP to be ”acceptable”. Since 1984, the ICRP has admitted that its recommended exposure limits were: the upper limit above which everyone agrees that it is hazardous. Prior to that, the limit was considered a threshold below which exposures were considered safe.

The recommended maximum exposure for members of the public at risk from nuclear industries was 0.5 rem (5 mSv) per year in 1952. If one million people actually received this dose, it would be 500,000 Person Rem (or 5,000 Person Sievert) exposure. Using the ICRP risk estimate, this means 50 to 62.5 fatal cancers. This is a very unsafe standard even using ICRP calculations. The ICRP claimed that the maximum dose to the public was only 1% of that recommendation, hence the industry was ”safe”, but they would never lower this permissible dose. The 1% always referred to the reactor phase of the cycle (and was never demonstrated to be true when all radionuclides and all pathways to human were taken into consideration). It was never claimed for uranium mining/milling or for nuclear waste.

In 1984, ICRP recommended that exposure to the public not average more than 0.1 rem (1 mSv) per year. They did not specify the length of time over which this average was to extend. Many governments, including Canada, averaged over the lifetime of the person (70 years) and thereby allowed higher per year levels around nuclear reactors only expected to operate for 35 to 40 years.

In 1990 the ICRP risk estimate was change to 5 fatal cancers, and the maximum dose to the public averaged over five years was recommended to not exceed 0.1 rem or 1 mSv. This is a commitment to 100,000 Person Rem (or 1000 Person Sieverts per year), or equivalently, to 50 fatal cancers per year. This is a very hazardous industry even under the assumptions which ICRP deem ”acceptable”.

FATAL CANCER RISKS BASED ON SCIENTIFIC LITERATURE:

The ICRP risk estimate is based on a double reduction of the observed fatal cancer risk at Hiroshima and Nagasaki. Under the same standard conditions, 10,000 Person Rem or 100 Person Sievert, Dr. Preston, Research Director of the RERF at Hiroshima estimated that 17 fatal cancers would be caused (Technical Report RERF TR 9-87, p.35) using direct linear extrapolation from high dose. According to Dr. Preston, UNSCEAR 1988 report reduced this estimate because of a low-dose-factor to 7 to 11 fatal cancers. ICRP took the estimates from BEIR 1990 (8 to 14) and UNSCEAR 1988 (7 to 11), which averaged about 10, and divided them by 2 using a slow-dose-factor. Hence, the ICRP estimate of 5 is really quite low even based on atomic bomb data. The reduction of the estimate for low dose and slow dose rate has never really been shown to be a valid process. In fact, the most recent studies of nuclear workers, who actually receive low doses at slow dose rates, would indicate that these factors are incorrect. Professor Rudy Nussbaum has written an excellent analysis of the atomic bomb fatal cancer estimates and finds the correct estimate to be about 20. Studies on US nuclear workers found risk estimates to be 19 (Hanford Workers) and 27 (Oak Ridge Workers). British nuclear workers had a risk of 10 (range 0 -26). Under these circumstances, it is unwise for ICRP to reduce the risk factor to 5 on theoretical grounds. Prudence, at this point in time, would dictate using a risk of at least 20.

In my Handbook for Calculating the Health Effects of Exposure to Ionizing Radiation (1984), I found a risk factor of about 10 for fatal cancers. Both BEIR and UNSCEAR now accept that number. However with the new studies on nuclear workers now available, I believe that this estimate was too conservative and should be increased to 20. (The Handbook is available in Japanese from The English Agency Japan Ltd., Sakuragi Bldg. 4F, 6-7-3 Minami Aoyama, Minato-ku, Tokyo 107).

With a risk of 20 fatalities due to radiation exposure of 10,000 Person Rem or 100 Person Sievert, the ”acceptable” number of deaths per year at 2 rem (20 mSv) average exposure for workers and 0.1 rem (1 mSv) average exposure for members of the public, would be:

WORKERS: 10,000 workers x 2 rem/year x 20/10,000 Person Rem =
20,000 Person Rem/year x 20/10,000 Person Rem = 40 cancer deaths / year

GENERAL PUBLIC: 1 million People x 0.1 rem/year x 20/10,000 Person Rem =
100,000 Person Rem/year x 20/10,000 Person Rem = 200 cancer deaths per year.

This is, of course, quite different from the claims of the industry, and from the ”evidence” of the poorly designed studies which the industry claims back its estimates. It should also be remembered that these numbers are radiation initiated fatal cancers which may take years to develop and to be diagnosed. By the time all of the cancers are ”seen” the nuclear facility will be moth-balled and the operators gone.

ANNUAL LIMITS OF INTAKE:

The nuclear industry routinely emits radioactive chemicals into the air or water in the vicinity of a plant. It is difficult to regulate a mixture which is ever changing, so these radioactive chemicals are regulated one at a time as if the total permissible dose for the year was obtained from one radioactive chemical and via one pathway (air or water). Assuming that the Standard Man (a twenty-year-old Caucasian male in good health) has a standard breathing rate and inhalation volume and drinks a fixed amount of water each day, these estimates are converted into maximum permissible concentrations of the radioactive chemical in air or water. The concentration permitted would give the Standard Man the maximum permissible dose in one year. These numbers can be modified for Asians, for women or children, for various combinations of radioactive chemicals etc. There are derived limits for the cumulative releases from nuclear reactors. These are subject to the same problems as the whole body dose previously discussed. However, inhaled or ingested radioactive chemicals also pose special problems. They often are dispersed differently in the body. For example radioactive iodine concentrates in the thyroid gland and cesium in muscle.

Recently the ICRP has invented the Cumulative Effective Whole Body Dose, which accumulates the dose expected from the radioactive chemical over the next fifty years of the person's life, the organs affected, and the whole body dose which would cause the same number of fatal cancers. This methodology seriously neglects non-fatal cancers. For example only 5% of thyroid cancers are considered fatal and less then 1% of skin cancers. These non-fatal cancers are allowed under the radiation protection schema.

For every 20 fatal cancers caused by radiation, about 10 non-fatal non-skin cancers and 20 skin cancers will be caused. It is certainly not clear that these non-fatal cancers should be ignored when ”protecting” people from radiation! This puts the nuclear industry in an even higher risk category when its permissible exposure levels are attained. It is assumed that 100 cancers will be caused per 10,000 workers per year, 40 of which cancers are expected to be fatal. For the general public, it means 500 cancers per million people per year, 200 of which are expected to be fatal.

As was pointed out earlier, this does not include the other more frequent effects of exposure which have been judged by the nuclear experts to be not of concern to people. These include autoimmune diseases and depressed cellular immune system. The latter leaves the person vulnerable to the more serious viral and bacterial infections and less able to cope with cancers caused by other factors. (See ”Internal Bone Seeking Radionuclides and Monocyte Counts”, by Rosalie Bertell. International Perspectives in Public Health, Vol.9, pp 21-26, 1993).

A NEW APPROACH TO RADIATION RESEARCH:

When the radiation exposure level is low, i.e. within an order of magnitude of natural background radiation, I believe that it is best understood as contributing to the effects of that background radiation. Over time the human body ”ages”. Ordinary diseases come more frequently and last longer. The ability to overcome fatigue and illness is lessened. Cancers and autoimmune disease incidence rate increases. Not all of the characteristics of old age are connected with background radiation, but certainly some are. Chronological age is a good measure of cumulative background exposure to ionizing radiation.

I would like to undertake an analysis of the atomic bomb survivors using their radiation enhanced age: i.e. their chronological age plus their bone marrow dose from the atomic bomb divided by about 0.8 mSv (80 mrem), the radiation dose to bone marrow received each year from background radiation excluding the dose from radon gas. I think that then we would understand both their physical problems and also begin to identify the portion of aging attributable to background radiation. I will leave with you a professional paper which I delivered at the One Hundredth Anniversary of Roentgen meeting of the International Radiation Protection Association in Berlin in May of this year.( ”Low Level Radiation Exposure Effects in the Tri-State Leukemia Survey”, by Rosalie Bertell. Proceedings of the Meeting of the International Radiation Protection Association, Berlin, May 1995).

The acceleration of some of the components of aging can explain a part of the problems experienced by those exposed to radiation, for example, the earlier occurrence of breast cancer in young women under age ten at the atomic bombings, and the adult illnesses observed in Chernobyl children. It can open new ways to understand the subtle chronic exposures, which accumulate over a lifetime and finally lead to death because of our inability to cope with our environment. This natural process can apparently be accelerated by increasing the natural radiation exposure levels.(See ”X-ray Exposure and Premature Aging”, by Rosalie Bertell, Journal of Surgical Oncology, Vol.9, Issue 4, pp 379-391, 1977).

Some phenomenon are not repeatable, and the radiation exposure becomes redundant, or useless for producing that effect. An illness like adult onset diabetes for example, is an old age disease which one cannot acquire more than once. Therefore one can expect a lessening of the effect of radiation on aging as the cumulative dose increases. However, at higher doses, direct damage to vital organs and direct induction of cancer can be expected to increase. I believe that there are complicated and competing effects of radiation, the aging effect being predominant at the low doses.

CAN THE ICRP BE TRUSTED TO SET RADIATION PROTECTION STANDARDS?

This was my original question, and I think it is obvious that my answer would be no. I think that it is time to disassociate ourselves from this self-appointed recommending body. Firstly, it does not have as its goal protection of worker and public health. Rather its goal is to recommend the ”acceptable” trade-off of that health for the benefits of the nuclear industries (medical, commercial and military) which it represents. In the fifty years since the formation of the ICRP it has never taken a stand on behalf of worker or public health, even against such obvious violations of human rights as non-ventilation of underground uranium mines and nuclear atmospheric testing.

It is also possible to fault the ICRP on its non-democratic structure. It is a self-appointed and self-perpetuating non-governmental organization. Its behaviour does not follow that of usual scientific bodies which have elected members from professional societies. I believe that it would be appropriate for us to protest the false credibility given to this organization by the World Health Organization and the United Nations.

The ICRP, moreover, avoids all responsibility for its recommendations. It claims that it merely makes recommendations, which then become the responsibility of individual nations to either implement or modify as they see fit. However, it is evident that most nations of the world lack the financial and scientific capacity to counter the unlimited resources and international prestige of the ICRP. Political bureaucrats, with low scientific literacy, take the easy way out and adopt these international recommendations. They claim not to have the resources to set standards for themselves.

ICRP attempts to deflect criticism for its permissive recommendations of standards by requesting that the nuclear industry always operate ALARA: As Low As Reasonably Achievable.

Perhaps the most important outcome of this symposium would be a recommendation for Japanese scientists to join and support the International Radiation Protection Association formed by German medical physicists and radiologists to provide an alternative international voice to counter the ICRP. Membership can be gained through contact with: Professor Doctor Inge Schmitz-Feuerhake, Universitat Bremen, FB 1, AG Medizinische Physik, Postfach 330 440, D-28334 Bremen, Germany.
(Tel: 49-421-218-2414, 49-421-218-2422; Fax: 49-421-218-3601)

Perhaps with the current international focus on reform and reorganization of the United Nations, it will be possible to publicly discredit this non-governmental organization before the world, and to replace it with an organization which truly has as its goal the protection of the human right to life and health, at risk from ionizing radiation used to serve military and industrial violence and greed.

ACTION ON BEHALF OF CHERNOBYL VICTIMS:

In the January 1995 issue of the IAEA Bulletin, a meeting to once and for all declare a consensus of the results of the Chernobyl disaster, especially its radiological consequences, was announced. This meeting would counteract the myths and fears which have caused widely divergent opinion about low level radiation. The meeting will be held in April of 1996, and will be followed by an IAEA meeting.

From colleagues in Europe, I have heard that the IAEA story is trivializing Chernobyl by saying that thyroid cancer rates in children, although 30 times over the expected rate, is not fatal. They also believe that it could have been prevented had potassium iodide been distributed to the people. Other effects of the accident have been attributed to poor nutrition, fear and sensational press stories. The official death toll at Chernobyl is set at 29, while the governments involved place the number of deaths at more than 10,000.

I propose to hold a Tribunal in Vienna in parallel with the IAEA Conference. The Tribunal would judge both the scientific presentations of the Ukrainian, Byelorussian and Russian scientists, and the human rights violations after the disaster. There would also be concurrent presentations of solar energy, art exhibits and cultural events for participants. I hope to have the cooperation of the international human rights lawyers in the Permanent Peoples' Tribunal. We are in the planning stage now, and I welcome your support and participation. We need strong public expressions of outrage!

PROGNOSIS FOR A RADIOACTIVE EARTH:

Human life evolved on this planet after the primordial plutonium from the ”big bang” decayed to predominantly the uranium and thorium series of radionuclides. We are reversing the process by again building up an inventory of plutonium by splitting the atom, creating radioactive forms of most of the ordinary chemicals needed for life. We are also enhancing the natural radioactivity by uranium mining and milling, careless dispersal of the waste and tailings, and by such things as trans-continental air flights. We will pay a price for this, but not as great a price as will fall on our children and grandchildren. You have had a very brave and honest scientist in your midst, Professor Yasuo Nakagawa, who at great personal cost has spoken out clearly about the danger of nuclear technology. His voice is silent now, but we must not let his message be silenced. The nuclear industry is poised to further expand into smaller nuclear reactors and food irradiation in the near future.

There is no other source of life except the precious seed - the human ova and sperm - and the seeds of all-living plants and animals. To destroy the seed is to cripple the future. It is to cut off the number of future generations which will be viable on this planet and then cut short the life of the human species. I can think of no ”benefit” worth such a cost! The future belongs to those who can offer new ways and bring new hopes and dreams to a weary world.

My mother was right 50 years ago: They should not have done it. My father was right when he said to leave uranium in the ground! I think that I am now right to call for an end to the lying and destructiveness of this industry which would steal from us the future life and health of our planet!


TABLE 1

RADIATION EXPOSURE MEASUREMENTS


Rad: unit of absorbed dose of radiation equal to 0.01 Joule per kilogram, or 100 ergs per gram.

100 rads = 1 Gray

Rem: unit of dose equivalent equal to the absorbed dose (in rads) times a quality factor compensating for the type of radiation (X-ray, gamma rays, neutrons, alpha or beta rays), times dose distribution facto, times any other necessary modifying factors. The base dose is one rad of 250 kVp X-rays and equivalence is for some specified biological damage, usually cancer deaths.

100 rem = 1 Sievert

mrem: one thousandth of a rem

100 mrem = 0.1 rem = 1 mSv (milliSievert)




TABLE 2

OCCUPATIONAL HEALTH AND SAFETY STANDARDS

GENERALL ACCEPTED NORM FOR A SAFE WORKPLACE:

NO MORE THAN ONE DEATH PER 10,000 WORKERS PER YEAR

NUCLEAR INDUSTRY STANDARDS: PRIOR TO 1990:

AT THE MAXIMUM PERMISSIBLE DOSE:

5 DEATHS PER 10,000 WORKERS PER YEAR (UNSCEAR)

6.25 DEATHS PER 10,000 WORKERS PER YEAR (ICRP)

50 DEATHS PER 10,000 WORKERS PER YEAR (Bertell)

AT 20% OF THE MAXIMUM PERMISSIBLE DOSE

1 DEATH PER 10,000 WORKERS PER YEAR (UNSCEAR)

1.25 DEATHS PER 10,000 WORKERS PER YEAR (ICRP)

10 DEATHS PER 10,000 WORKERS PER YEAR (Bertell)

NUCLEAR INDUSTRY STANDARDS: AFTER 1990
AT THE MAXIMUM PERMISSIBLE DOSE

10 DEATHS PER 10,000 WORKERS PER YEAR (ICRP)

20 DEATHS PER 10,000 WORKERS PER YEAR (BEIR, UNSCEAR)

40 DEATHS PER 10,000 WORKERS PER YEAR (Bertell)




TABLE 3

PUBLIC HEALTH AND SAFETY STANDARDS


GENERALLY ACCEPTED CRITERIA FOR A SAFE INDUSTRY:

IT WOULD CAUSE THE DEATH OF NO MORE THAN ONE MEMBER OF THE PUBLIC PER MILLION PEOPLE PER YEAR.

NUCLEAR INDUSTRY STANDARDS GOVERNING RADIONUCLIDE EMISSIONS: BEFORE 1990

AT THE MAXIMUM PERMISSIBLE DOSE TO THE PUBLIC

50 DEATHS PER MILLION PER YEAR (UNSCEAR)

62.5 DEATHS PER MILLION PER YEAR (ICRP)

500 DEATHS PER MILLION PER YEAR (Bertell)

AT 1% OF THE MAXIMUM PERMISSIBLE DOSE (REACTOR ONLY)

LESS THAN 1 DEATH PER MILLION PER YEAR (UNSCEAR, ICRP)

5 DEATHS PER MILLION PER YEAR (Bertell)

NUCLEAR INDUSTRY STANDARDS GOVERNING RADIONUCLIDE EMISSIONS: AFTER 1990

AT THE MAXIMUM PERMISSIBLE DOSE:

50 DEATHS PER MILLION PER YEAR (ICRP)

100 DEATHS PER MILLION PER YEAR (BEIR, UNSCEAR)

200 DEATHS PER MILLION PER YEAR (Bertell)


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