Must We Hold Out For
Proponents of nuclear electricity and other atomic energy developments are quick to claim that "we understand radiation hazards better than any other environmental pollution hazard." Another favorite: "We have proceeded with more consideration of safety in atomic energy than in any other industry." One yardstick used by these atomic energy enthusiasts is the heavy expenditure of public money in studying radiation hazards. A great deal of money has certainly been spent—much of it unwisely and inappropriately. As for the methods used to establish safe radiation standards for atomic energy development, less sound public health principles would be hard to imagine.
Here is what we foresee in public health losses if atomic energy programs (including nuclear electricity) are allowed to proceed under our current allowable exposure standards—an average of 0.17 rad per year for Americans.
All of these staggering projections in health cost are already accepted by numerous leading scientists worldwide. Some project precise cancer or leukemia figures at half as high, others say they will be three times as high. But the precise number is not the issue. The horrible realization is that the truth does lie in the tens of thousands of deaths annually, not the one case, or none, the Atomic Energy Commission suggests to the public. And though the projected genetic deaths are uncertain—between the huge numbers of 100,000 and 1,000,000 per year—we are certain the genetic cost will be staggering.
Surely some major flaw in logic characterized the entire approach to setting radiation standards if, in the 25th year of the atomic era, we find that the "safe" or "allowable" doses are so lethal. Actually, total illogic is the basic characteristic of radiation standards development, both for workers in atomic plants and for the population-at-large. And elementary reasoning shows us that, if we proceed to handle environmental poisons in the future the way we have handled the radioactivity problem up to now, our environment and our species are surely doomed.
Perhaps the simplest way to understand the erroneous approaches of the past is to ask how we might act if the problem were a new one.
Suppose we have just developed a new "wondrous" technology with a by-product poison. For purposes of generalization, let us call this poison "Q". How much escaping "Q" would we be willing to tolerate in the environment where it might affect millions, or hundreds of millions, of humans? Of course, we must be concerned not only about whether people would drop dead immediately from exposure to "Q", but also about possible long-range effects upon individuals and upon the entire human species. Cancer and leukemia cases that might result in 5, 10, 15, 20 or 25 years must worry us. Genetic damage that might take generations to show up had certainly better worry us.
The promoters of the new technology would surely tell us (in two-page ads in all national magazines) that life on earth would be miserable unless the technology were immediately spread throughout the land. These same agents would probably wish to spend as little money as possible on protecting the people from exposure to "Q". Therefore, they would want minimal regulations against releasing "Q" into the environment.
How should society decide on the amount of "Q" that should be allowed to reach humans? Elementary logic would dictate that the promoters of the technology must prove safety of releasing any "Q" to the environment, that "Q" can do no harm to humans, before they release any "Q".
And how did we actually manage the question of radioactivity? The promoters of atomic energy and the bodies setting the standards said, in effect, the public must prove it is being harmed by radioactivity before we will stop radioactive pollution. Where environmental poisons are concerned, it has always been up to the public to show harm, rather than up to the polluter to prove safety.
Should society say, with excellent reasons, that no "Q" should be released to the environment until its safety is established, it is certain to be faced with two of atomic energy's favorite cliches:
"Do you want to stop technological progress?"
"Don't you realize the benefits outweigh the risks?" Society answers, "Of course we wish to receive all the benefits technological progress can give us, but we insist on knowing the hazards involved. After all, we are the potential victims. You must convince us that what we stand to gain is greater than what we stand to lose. And if there is a risk, prove to us that we cannot receive the same benefits through some less hazardous means."
If the proponents of "Q" technology follow the pattern of the atomic energy promoters they will answer, "We just know the benefits are marvelous. The benefits just must outweigh the hazards. And furthermore, we have seen no evidence that the amount of `Q' we plan to release will cause cancer, leukemia, and genetic damage to humans."
"But you are not saying that `Q' has been proved safe," the public responds. "Your statement of `no effects observed' simply reflects your ignorance concerning `Q'. If you have made inadequate observations with `Q', or none at all, how can you possibly know the answers?"
In answer, the "Q" promoters can be expected to appoint a body of expert scientists who will hold a long, serious conference and emerge from it with a magic number,—plucked out of thin air—a permissible standard for the safe release of "Q". And the public will be told it need have no fears, that the expert standard-setters will be watching the situation carefully. If too many corpses appear, they will confer once more, and set the safe standards for "Q" lower.
The public will certainly denounce the plan: "What utter nonsense it is to release the poison `Q' into the environment and wait to see what happens! Surely there must be a more rational approach."
The "Q" technologists propose next that they be permitted to release "Q" in some amount. Presumably some accidental exposures will occur to sizeable groups of humans. The experts plan careful studies of how many cancers, leukemias and genetic mutations are occurring in the exposed humans. "Then we will know precisely how bad a poison `Q' is. If the numbers should turn out too high, we'll reduce the `permissible' levels of `Q'." (This is precisely what happened with atomic energy. The standard-setters waited for the corpses to appear in Hiroshima survivors before they would believe increased cancer occurs in humans exposed to radiation.) Meanwhile, of course, all 200-million people in the country might have been irreversibly injured by the "Q" already released.
Obviously, disaster is the fate of a people willing to accept a poison in their environment, hoping that an accident will show them how dangerous the poison is. Worse yet, they will come to realize that technology spawns many "Q" poisons, not one, and all of them together might mean the end of life for the human species.
This entire scenario about the new poison, "Q," may sound far-fetched. But it is a precise description of how the radiation hazards question has been handled in the course of developing atomic energy. Far worse, both the nuclear electricity promoters and the standard-setting bodies still insist vehemently that they must be allowed to proceed with this same idiocy in the future.
Atomic technology was pushed hard by two governmental agencies, AEC and the Joint Committee on Atomic Energy. Accredited biological experts were assembled, in one committee or another, to consider radiation and radioactivity and decide how much people could be exposed to. Obviously, the pressure was on. These expert bodies must burden the atomic technology with the fewest possible restrictions.
Did these experts tell the technologists, "The burden of proof of safety is upon you?" Did they say, "We refuse to allow you to expose anyone to man-made radiation because we don't know how much physical damage it will cause?" They did not.
Instead, they pulled some numbers out of a hat and declared that the numbers represent "acceptable" standards for human radiation tolerances. And the atomic technology proceeded under the blanket of respectability of these "allowable" doses.
By now it is obvious, since these "acceptable" doses have had to be lowered 100-fold in the past two decades, that something certainly was wrong with the original standards. Perhaps the experts did know that people wouldn't drop dead immediately from the "acceptable" doses they set at first. But for such late effects as leukemia, cancer and genetic diseases, the "experts" could hardly have been further off-base than they were.
If there had been no information available to the "experts" about the potential danger of cancer and genetic injury in humans, it might be argued that the men who set the standards had no way of knowing such radiation effects were possible. But the knowledge was available! These scientists knew that radiation causes cancer and genetic damage. And still, they set totally unacceptable standards! It is impossible to believe anything but that the agencies responded to pressure from the atomic technology promoters for "standards we can live with." The technologists were presented with a set of numbers for human exposure that presumably wouldn't make the promoters too unhappy, while those who set them probably prayed the disaster to the human species wouldn't be too severe.
The essence of this prayer comes through in the very forthright statement of ignorance made by the International Commission on Radiological Protection:
(83) Because of the need for guidance in this regard, the Commission in its 1958 Recommendations suggested a provisional limit of 5 rems per generation for the genetic dose to the whole population, from all sources additional to natural background radiation and to medical exposures. The Commission believes that this level provides reasonable latitude for the expansion of atomic energy programs in the foreseeable future. It should be emphasized that the limit may not in fact represent a proper balance between possible harm and probable benefit, because of the uncertainty in assessing the risks and the benefits that would justify the exposure.
It is very important to note that the International Commission says "this level provides reasonable latitude for the expansion of atomic energy programs in the foreseeable future." Is the concern for health, or for the technology? The Commission goes on to admit uncertainty both with respect to risks and benefits. It is almost unbelievable that an official standard recommending body would suggest allowing such exposure in the face of an overt admission of its own ignorance concerning hazards. But this is the record of such bodies, over and over again. The public must realize the implications.
If the errors in the earliest days of atomic technology are to be excused on the basis of ignorance or on the basis of a simple lack of awareness concerning sound public health principles, how shall we excuse the fact that rationality has not entered the picture to this date.
In our discussion of "Q," we expressed dismay that anyone might even suggest waiting for some catastrophic consequence of accidental human exposures to evaluate late effect hazards of the poison. Yet, this is precisely what the various standard-setting bodies for radiation exposure are doing and have been doing for many years.
A number of groups of humans actually have been exposed to ionizing radiation in high doses (Hiroshima-Nagasaki Atom Bomb Survivors, 14,000 British subjects with arthritis of the spine treated with x-rays). The experts have seized upon these groups with enthusiasm. They have pronounced that as the cancer and leukemia corpses appear in these human groups, they will be counted.
Only when a sufficient number of corpses have appeared, say, from lung cancer, will the experts accept that lung cancer is produced by radiation. If these men determine that too many cancers and leukemias are occurring, the allowable radiation dose to the public will then be lowered. Incredible as it may seem, this barbarian approach to public health practice is truly occurring!
Why is all this appalling? Suppose the accidental exposure at Hiroshima and in Britain had not occurred. There would have been no new information. Presumably, nothing at all would have been done about the allowable exposure levels which turned out to be so disastrous.
Now we know it takes 5 to 20 years before the various forms of leukemia and cancer show themselves after radiation exposure. If we sat by, waiting for each type of cancer to show up in the accidentally-exposed human groups, decades might go by, with hundreds of millions of people overexposed to radiation, and not a finger lifted to stop it. Exactly what is going on to this day!
Leukemia is the earliest cancer to occur following radiation exposure, surfacing after some five years. Obviously, before five years passed for the exposed human groups, it seemed that no cancers or leukemias had occurred among them. The standard-setters felt relieved. Then the five-year mark was passed, and leukemias did appear as an effect of radiation in the Japanese and British subjects. The standard-setters generously took due notice of the fact. Leukemia, they said, had indeed been produced in humans by radiation. Now the manuals were rewritten and leukemia was listed at last as a late hazard of radiation exposure.
What about the other forms of cancer that were known to follow radiation in experimental animals? The experts steadfastly refused to consider any of these. Not having seen any human corpses, they refused to admit they might exist, and would not lower the population exposure standards accordingly.
A little later, the incidence of thyroid cancer became so common in irradiated humans that it had to be acknowledged. The experts revised their reports of radiation hazards to include the thyroid cancer risk. They were now considering leukemia and thyroid cancer as radiation caused—but no other cancers.
So it continues up to the moment of writing this book. Even though cancer of the lung, the breast, the thyroid, the pharynx, the stomach, the lymph glands and bone have been unequivocally proved to occur in human subjects as a result of radiation, the standard-setting bodies are just beginning to consider some of these cancers in their calculations.
Having embarked upon a course of action that can charitably be called public health-in-reverse, those charged with setting radiation standards persist in their errors and continue seriously to underestimate the true hazard of exposing people to radiation. And so nuclear electricity development and atomic technology in general both proceed under a set of standards permitting radiation exposure of the population that can lead to a massive public health calamity! All the while the public is reassured by announcements that eminent scientists are constantly reviewing the standards.
When we, the authors of this book, finally awakened to the unbelievable galaxy of errors represented in this standard-setting, we exposed it publicly. We were accused of making a direct, frontal attack on all radiation standards. Indeed, we are making a direct, frontal attack. And proudly. This account will, we hope, convince the public how long overdue such a massive, direct attack is!
Unfortunately, any criticism of erroneous public health practices is likely to be misinterpreted as an attack upon the motives of the men involved. We intend no such implications, nor even consider it in questioning their standard-setting procedures. These men are, after all, human. All of us learn through our errors, and few indeed have escaped serious errors of judgment in one or another aspect of their lives. But is it not tragic and inexcusable to persist in the errors of the past? The defensiveness of those scientists involved is leading directly to this tragedy. It appears certain that it will take public pressure to introduce a rational note into the radiation-nuclear energy scene.
We cannot refrain from addressing the issue of conflict-of-interest. And we do this not to impugn motives. Public officials are routinely required to divest themselves of holdings that might represent, or be considered to represent, a conflict with execution of their public duties. Yet, most of the scientists who serve on the various radiation standard-setting committees are directly or indirectly in the employ of the nuclear industry or the atomic energy government bureaucracy. Some are recipients of major university research grants from these same agencies.
The conflict of interest may be subconscious, but it is inescapable. Men can hardly be expected to consider civic responsibility exclusively, when they cannot be unaware that certain of their actions may well result in drying up sources of support for their research or for their salaries. This is a hopeless situation from which to extract objective performance. It is the very reason for our rather strict codes in such potential conflict-of-interest situations for public servants.
Recently one of us was lecturing in a university classroom concerning the leukemia and cancer hazard from ionizing radiation. A fellow professor attending the lecture asked, "If the Atomic Energy Commission pays to support your research, why do you criticize radiation as a hazard?" The deep implications of this question, undoubtedly asked in great innocence, must not be lost upon the public. If the source of research funds is expected to buy silence concerning hazards of major public concern, we are assuredly in very deep trouble as a society.
Many scientists would not ask this question so directly. They would simply remain silent about public-health hazards of technology if they sensed that speaking out might cost them their jobs or their research funds. Nor is it particularly hard to understand why. The heavy hand of reprisal by vested interests, governmental or private, is very widely appreciated.
Radiation Standards: How They Should Have Been Handled
We have noted that everything—the philosophy and execution for promulgating human radiation exposure standards—has been wrong. But this is the set of standards under which the nuclear electricity industry is proliferating. The conservative public health practice of caution on the side of health of the public, has been neglected—totally.
What would have been a reasonable approach? First and foremost, it is unthinkable to require human corpses before a standard-setting body will act to protect the public health. A procedure for effective action should have been developed, based on a cardinal set of public health principles, that does not require human experiments:
Why should the standard-setting bodies demand human disaster as a guide for setting safe standards? Experimental animal studies, available for decades, prove conclusively what needed to be known. Virtually every form of cancer and leukemia had already been produced in several animal species provided radiation was absorbed in the appropriate organ. Furthermore, these studies indicated a five percent (or greater) increase in cancer occurrence rate for a variety of cancers, per rad of exposure.
A responsible society, applying sound public health principles, would have assumed that all forms of human cancer and leukemia would be induced at least as easily by radiation as they were in the most sensitive experimental animal. Conservatism would suggest assuming the human to be even more sensitive. Proceeding in this manner, it would have been estimated that all forms of cancer and leukemia would increase by five percent for each rad of human exposure accumulated.
Now we can estimate how we would have evaluated the implications of a particular exposure level for the population. Suppose we estimate the consequences of developing nuclear electricity and other atomic programs working with the "permissible" dose of 0.17 rad average for the population, the value chosen ten years ago by the Federal Radiation Council. Now let us ask ourselves if this value, 0.17 rad, would really have become codified, or if the calculation would have led to far more stringent guidelines for radiation exposure.
It would have been reasonable to choose 30 years of age as a representative age for an "average" person who might be affected. By age 30, a person receiving 0.17 rad per year would have accumulated 30 x 0.17, or approximately 5 rads of total body exposure. At earlier ages, the accumulated exposure would, of course, have been lower. But evidence has long existed to indicate that the sensitivity to cancer induction by radiation is materially higher at early ages. (Now, we realize the sensitivity in utero is extremely high. ) Furthermore, the lower accumulated dose at early ages would be counterbalanced by more than 5 rads accumulated at ages beyond 30 years.
By simple arithmetic, if 5 rads is the average accumulated dose, and if (as experimental animal data shows) there is a 5 per cent increase in cancer plus leukemia per rad, then, multiplying the two, we should have expected a 25 percent increase in the death rate if our population were exposed to 0.17 rad per year. This estimate would undoubtedly have shocked even the most hardened individuals. In the United States there are some 320,000 cancer-plus-leukemia deaths each year. A 25 percent increase would mean an additional 80,000 deaths from cancer and leukemia annually!
If this simple arithmetic had been done by the standard-setting committees fifteen years ago, (the experimental animal data were available then) it is extremely doubtful that 0.17 rad per year would have been chosen as an allowable exposure. It is extremely doubtful that national programs like nuclear electricity generation would have been allowed to develop under such a guideline. The conclusion would have been self-evident; this is far too high a population exposure to contemplate.
The standard-setting committees did not go through this simple arithmetic. While their sincerity and devotion is not to be questioned; their judgment and comprehension of public health most certainly must be. The committees neglected the animal data which would have waved a red flag of alarm, and demanded human evidence before reducing the allowable radiation exposure for the public.
Now let us see whether this approach, using the experimental animal evidence, would have misled us or would have provided very sound guidance.
By now, to our sorrow, human evidence is available for all the major forms of cancer and leukemia induced by ionizing radiation. Whatever the results are for the few remaining minor forms of cancer, they cannot alter the picture significantly. Further, extensive human evidence shows a 2 percent increase in cancer per rad of exposure in young adults.
Again, using our 30-year old person as representative, with 5 rads accumulated at the allowable annual exposure, we have 5 x 2, or a 10 percent increase in cancer plus leukemia expected. And 10 percent of 320,000 is 32,000 extra deaths from cancer plus leukemia annually are to be expected if the population receives the allowable 0.17 rad per year.
Independently, Professor Linus Pauling estimates 96,000 extra cancer plus leukemia deaths annually. Comparing these estimates, 32,000 to 96,000 extra deaths annually, with the 80,000 that would have been arrived at from the experimental animal data, we realize immediately that the animal data would have provided sound guidance indeed! Moreover, the animal data would not have been at all super-conservative, for the human evidence now available shows there was no margin for safety!
The issue is not whether the estimate of 80,000 extra cancer-plus-leukemia deaths annually for exposure of the entire population at 0.17 rad would have been exactly correct. The real point is that the expected numbers would have been in the tens of thousands, not near zero.
Had this been appreciated, and announced fifteen years ago, nuclear electricity generation could have been more rationally evaluated in the light of realistic appraisal of the potential future hazard. The electric utility industry would not have been mistakenly lured into nuclear power by false and meaningless assurances of safety to humans in "allowable" doses of radiation.
It is truly pathetic to see how the misapplication of public health principles has deceived a major industry, including its executives, physicists, and engineers. The deep and widespread misinformation has led these physicists and engineers to design and install nuclear reactor systems under a delusion as to their true margin of safety. A real appreciation of the cancer-leukemia hazard of radiation would, doubtless, have altered the outlook of the nuclear electricity industry. Whenever design and engineering are carried through with a false idea of margin of safety, and in this instance false by 100 to 1,000-fold, real danger lies ahead.
We are not concerned with mistaken notions of the past, but of the present! Dr. Walter Jordan is a physicist, and Assistant Director of the Oak Ridge National Laboratory, a leading nuclear science and engineering laboratory.
Recently (May, 1970) in an article on nuclear electric power for the journal, Physics Today, Dr. Jordan expressed his impatience with those who are concerned about the hazards of nuclear electricity generation. Dr. Jordan agreed there may be a hazard, but it surely is worth the risk. We would honor Dr. Jordan's privilege to express this opinion in any event. But we are horrified, upon reading his article, to learn that he has no concept at all concerning the cancer-leukemia risk! For Dr. Jordan states in his article that exposure to 30 times the allowable annual dose of 0.17 rad will lead to no physical effects upon the exposed individuals. Of course, Dr. Jordan cites no evidence to back his reassuring statement.
Let us explain to Dr. Jordan what a population exposure of 30 times the allowable dose would amount to in extra cancer-plus-leukemia deaths annually in the USA. Our estimate would be 960,000 extra deaths per year. Professor Pauling's estimate would be three times higher, or 2,880,000 extra deaths per year. Even a lower recent estimate, ascribed to R. H. Mole of the British Atomic Energy Authority, would lead to 210,000 extra deaths annually. Would Dr. Jordan consider that 210,000 to 2,880,000 extra deaths annually represent "no physical effect?"
Far more frightening is Dr. Jordan's recent appointment to the Atomic Energy Commission's "Atomic Safety and Licensing Board Panel." In this position, he will help review applications for the licensing of construction and operation of new nuclear-electricity generating plants. Here we have a man, obviously competent in his own field of physics and engineering, totally oblivious of the real hazards of radiation for humans. This man will be passing upon radiation safety and related matters for nuclear electricity installations. He will also sit on Public Hearing Boards to listen to any public protests and concern about the hazard of such plants.
Many nuclear reactor industry spokesmen and AEC officials have decried the "alarmism" associated with the estimates of leukemia and cancer risk from radiation, although there is not a shred of evidence they can offer in refutation of the estimates. It is not the estimates of the cancer and leukemia hazard from radiation that should alarm the public. But the public should be extremely alarmed that members of the Atomic Safety and Licensing Board are totally oblivious to the real magnitude of the radiation hazard. As late as 1969, the Chairman of the Joint Committee on Atomic Energy expressed his opinion that there existed a margin of safety of 100 times in the allowable radiation dose for the public.
If the sound public health principles we have described had been applied, we could have averted today's sad state of affairs. Physicists, engineers, and utility executives could have been made aware of the true hazard of ionizing radiation. The rash proliferation of the nuclear electricity industry would surely not have occurred in the manner that it has.
The electric utility industry is a highly responsible one. It is a matter of great concern that it was so badly misled.
Considering the magnitude of the stakes involved, for the public, for industry, and the nation's future, it is imperative that sound public health practices be introduced into the nuclear electricity industry, especially since the hour is late for constructive action.
It is perfectly appropriate for a group of scientists, with expertise in a particular field, to provide estimates of the risk of serious disease as the result of potential exposure to environmental pollutants. In so doing, it is essential that the sound public health principles described above be applied in making the estimate of hazard. At all times a conservative approach, erring, where uncertainty exists, in favor of the public health is essential. Here the responsibility of the scientist, as a scientist, should end. The only appropriate standard for pollution is zero, until negotiated away from zero for very good reason. Expert scientists, operating behind closed doors, are in no way an appropriate body to make such negotiation, or to set any "standards."
The negotiation away from zero as the appropriate pollution level must necessarily involve a broad segment of society. For, in deciding to allow a negotiated pollution, society at large is accepting a hazard to health in current and future generations. Society as a whole must make the determination of whether the hazards are truly offset by projected benefits. The sole control over the health of humans and the quality of the environment can no longer be left in the hands of "experts." Such control must be carefully guarded and exercised by an informed public.