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Is Any Radiation "Safe"?

          When the industrial application of a technology has a poisonous environmental by-product, clearly a primary requirement is to understand the consequent public health hazard. Past experience shows that, at any point in medical history, we are unlikely to know enough to assess such hazards with accuracy. But the consequences of underestimating these hazards, especially genetic hazards, can be so grave that we must be extremely conservative in assessing them.

          An error on the side of conservatism in estimating a danger can be, at worst, a delaying nuisance for the promoters of the technology. An error on the side of optimism, leading to some underestimation of the true hazard, can be extremely costly to the human species. We can always later allow more exposure to a poison, such as radioactivity, if we learn that it can be tolerated. We cannot undo genetic and chromosomal damage from overdoses of poison already consumed.

          For nuclear electricity generation, the by-product poison is radioactivity (or radiation itself). Any of the hundreds of radioactive substances produced in the course of all phases of nuclear electricity generation can be harmful to man, from uranium mining through to disposal of astronomical quantities of radioactive wastes. It doesn't matter whether the radiation is external to the body or provided by one or more radioactive compounds that have gained access to the body through air, food, or water. What counts, for any particular organ, is the total absorption of radiation energy, which is measured in rads or millirads (1000 millirads = 1 rad).

          The only possible way to set a truly safe standard—a definite number of rads or millirads assigned to a particular tissue or organ—would be to know beyond any reasonable doubt that within that amount no biological effect will occur. We can state unequivocally, and without fear of contradiction, that no one has ever produced evidence that any specific amount of radiation will be without harm. Indeed, quite the opposite appears to be the case.

          All the evidence, both from experimental animals and from humans, leads us to expect that even the smallest quantities of ionizing radiation produce harm, both to this generation of humans and future generations. Furthermore, it appears that progressively greater harm accrues in direct proportion to the amount of radiation received by the various body tissues and organs.

          It came as a great shock to us, in the course of our study of radiation hazards to man, that nuclear electricity generation has been developed under the false illusion that there exists some safe amount of radiation. This unsupportable concept is surely one of the gravest condemnations of nuclear electricity generation. Obviously any engineering development proceeding under an illusion of a wide margin of safety is fraught with serious danger.

          What is more, the false illusion of a safe amount of radiation has pervaded all the highest circles concerned with the development and promotion of nuclear electric power. The Congress, the nuclear manufacturing industry, and the electric utility industry have all been led to believe that some safe amount of radiation does indeed exist. They were hoping to develop this industry with exposures below this limit—a limit we now know is anything but safe.

          Before describing the widely pervasive nature of this serious misunderstanding of the radiation hazard problem at such top levels in industry and government, it is important to establish carefully that we put the integrity, sincerity, and motives of no one into question. Undoubtedly, the scientists, the engineers, and the power executives involved, as well as the Congressmen, were simply misled in their belief that some safe amount of radiation truly exists. It was the result of some inadequate observations involving persons exposed to radium salts industrially. Numerous reputable scientists had long discounted these inadequate observations. All of the national and international standard-setting bodies had also refused to accept this inadequate evidence of a supposedly safe amount of radiation.

A Multi-Billion Dollar Industry on a Dangerous Premise

          How, under such circumstances, is it even conceivable that so many important industrial and governmental leaders were so totally and seriously misled, misled to the point of launching a multi-billion dollar industry based upon a dangerously false premise?

          One agency must bear the responsibility for this wrong impression—the United States Atomic Energy Commission. Probably there was no willful wrongdoing. But the Atomic Energy Commission, burdened by Congress with the impossible dual role of promoter of atomic energy and protector of the public from radiation, has historically suffered from false optimism.

          This is not only true, as we shall see, for radiation hazard issues, but also concerning the economics and the capabilities of the nuclear industry. The AEC, of all the agencies we know of, was the only one to back the idea that a safe "threshold" amount of radiation existed. Apparently it was able to convey this belief, not only to the Joint Committee on Atomic Energy, but to the nuclear and electric industries as well.

          This untenable concept, that there does exist some dose in rads, or millirads, innocuous to humans, is a grave danger to the public. Indeed, it would be difficult to conceive of a more serious situation in a burgeoning industry than to have such appalling misinformation rife among corporate executives and their leading technologists.

          It is our good fortune that the misunderstanding has been uncovered at last. It is now possible to halt unsafe growth of the nuclear electricity industry before the errors of the past are compounded.

          We believe the reader will be, and should be, interested in how we became aware of the widespread lack of understanding of the radiation hazards which characterizes the highest circles of atomic energy. Our realization arose from a direct encounter with the very top of the U.S. pyramid of atomic energy, namely, the Joint Committee on Atomic Energy of the U.S. Congress.

          We were assigned to evaluate the hazards of atomic radiation by the U.S. Atomic Energy Commission in 1963. It was our job to assess the cost in human disease and death for all sorts of proposed and on-going nuclear energy programs, including nuclear electricity.

          In October, 1969, we were prepared to present our results on the expected cancer and leukemia deaths for human exposure to various amounts of radiation. We could have presented these results as the number of cancers or leukemias per year per rad or per millirad of exposure. The most useful basis appeared to us to express this risk for that amount of radiation, namely, 0.17 rads (or 170 millirads), which is the currently legal average dose that peaceful atomic energy programs are permitted to deliver to the U.S. Population.

          This dosage, 0.17 rads per year for average exposure, is a "guideline" of allowable dosage set by the Federal Radiation Council, an organization established in 1959 by President Eisenhower. This guideline in no way suggests that everyone should or does receive 0.17 rads per year. Rather, it states that no individual shall receive more than 0.5 rads per year nor shall the average dose exceed 0.17 rads.

          Thus, any combination of atomic energy programs could go forward legally, provided these criteria were met. It is conceivable that atomic energy programs might be irregularly distributed throughout the country, with the average exposure in some regions at 0.34 rads and in other regions at 0 rads. If these two regions were of equal size ( in population ) the overall national average would be 0.17 rads, which is perfectly legal under the guidelines. And let it be underscored that no one could be taken to task for allowing radiation exposure of the public up to the full limit of this allowable dose.

          Our calculations of cancer hazard were presented to an eminent scientific society, the Institute for Electrical and Electronic Engineers in San Francisco on October 29, 1969. The prediction follows:

"If the average exposure of the U.S. Population were to reach the allowable 0.17 rads per year average, there would, in time, be an excess of 32,000 cases of fatal cancer plus leukemia per year, and this would occur year after year."

When we presented this estimate, we anticipated no opposition whatsoever to our scientific findings.

          Our work showed that previous estimates (aside from early correct estimates by Professor Linus Pauling) were 10 to 20 times too low. The new evidence, on radiation-induced human cancer-plus-leukemia, from Japan, from Great Britain and from Nova Scotia, were now all telling us one story—radiation is a greater factor in cancer-leukemia than had been previously realized.

          New evidence was in; we were simply taking it into account. We expected the nuclear electricity industry and the U.S. Atomic Energy Commission to welcome our report on the cancer + leukemia risk—especially since the findings were being made available before a massive burgeoning of the nuclear electricity industry.

          At that time (October 1969), we had not given any special thought to the nuclear electricity industry per se. In fact, in our preoccupation with a careful analysis of the hazard per unit of radiation received by people, we had thought nuclear electricity one of the most innocuous of atomic energy programs, a view we have now had to alter radically. What surprised us beyond belief was that from all over the country our colleagues in various aspects of nuclear energy, particularly nuclear electricity, expressed their shock and disbelief that such a massive cancer-plus-leukemia risk could conceivably accompany exposure at the "allowable" Federal Radiation Guideline.

          Many of the people, in nuclear electricity work, simply expressed their disbelief that a Federal Agency would ever set a guideline that could be associated with such an enormous hazard. They all had been under the illusion that the hazard at the Guideline radiation level must be zero, or at least so very low as to be negligible. One after another, officials of the nuclear electricity industry expressed their opinion that surely something must be wrong with our estimates, although none of them could muster an iota of evidence as to what it could be.

          Only then were we alerted to the alarming state of affairs—a whole new industry, nuclear electricity, was growing up in the country with all of its experts totally unaware of the true hazards associated with it. We are not speaking about the kind of natural defensiveness a mother shows on hearing unkind remarks concerning her child. This type of defensive reaction on the part of some nuclear electricity spokesmen was quite understandable.

          But the sincere lack of realization by the nuclear electricity industry, that there is no proof of safety for any amount of radiation, was really disturbing. Our alarm reached its most serious proportions a few weeks later when we came to understand that even Congressman Chet Holifield, Chairman of the Joint Committee on Atomic Energy of the U.S. Congress was totally misinformed concerning radiation hazard. And the Joint Committee on Atomic Energy is the chief source of promotion of the nuclear electricity industry!

          Congressman Holifield called us in shortly after our presentation of the cancer hazard and expressed his dismay at our pessimistic projections. He told us he had been assured that the hazard level was truly 100 times higher than the level at which the Federal Radiation Council Guidelines had been set. He had assumed, therefore, that the "allowable" dosage couldn't possibly be associated with the production of any cancers or leukemias.

          How is it even conceivable that the top man in this country's nuclear energy development could be so totally and brutally misled and misinformed? There is only one answer—the U.S. Atomic Energy Commission had failed utterly to provide Chairman Holifield with the real information concerning radiation hazards.

          The AEC surely realized that all the responsible national and international radiation protection bodies were on record rejecting the idea of any safe amount of radiation (for cancer production.) Can it be that the dual role of promoter and protector made it difficult for AEC to inform Congressman Holifield properly? As the Chairman of the Joint Committee he is the one American in government who needed to know the truth concerning radiation hazards.

          We can ill afford, on such desperately important issues, to have key governmental officials so totally and hopelessly confused. No wonder this ignorance and confusion spread to the leaders of the nuclear electricity industry. These executives and engineers assumed, quite reasonably, that the Chairman of the Joint Committee on Atomic Energy must know the facts.

          We readily discovered how Chairman Holifield had been misled, and we so informed him in the following letter of December 1, 1969.

Livermore, Calif., December 1, 1969.

Chairman, Joint Committee on Atomic Energy,
U.S. Capitol, Washington, D.C.


      Both of us were deeply honored by the opportunity of some two hours of frank and substantive discussion with you and your colleagues last week. Especially is this so because both of us are intense admirers of the devoted and untiring efforts of the Joint Committee on Atomic Energy to bring to light all the true facts concerning radiation hazards. The various Hearings you have held are unequalled as a monumental contribution to the public welfare and health.
      In our discussion you asked us a very specific question, "How can you tell us there is a potential hazard at certain dosages when we have been assured that the hazard level is approximately 100-fold higher?"
      We answered, "Congressman Holifield, we believe you have been misinformed."
      We know that you needed more answer than that. Based upon the evidence and calculations, we knew that what we were saying had to be true, but we did not know how it had come about that deep mis-information had come to the Joint Committee. We resolved, therefore, to go right home and find out how this had, indeed, come about. After careful study of many of the Hearings of the Joint Committee on Atomic Energy, we believe we have complete understanding of the specific nature of the misinformation.
      It is the purpose of this letter and the attachments to explain all of this to you. And we are prepared to defend our analysis of this situation in any format the Joint Committee would find helpful. We believe, however, our analysis will speak for itself.
      Specifically, we refer to the Radium Dial Painter studies reported to you by Dr. Robert Hasterlik at the Hearings (87th Congress, Part 1, p. 325) and by Dr. Robley Evans at the Hearings (90th Congress, Part 1, p. 265 ) .
      Dr. Hasterlik interpreted his findings correctly when questioned by Congressman Price. Dr. Evans, in our opinion, grossly misinterpreted his own data, but undoubtedly with total sincerity of purpose.
      Our analysis attached shows both sets of data consistent with each other. In striking contrast with Dr. Evans' claim that the data indicate a threshold of radiation below which cancer doesn't occur, our analysis indicates nothing of the sort.
      1. Neither the Hasterlik data nor the Evans data can even remotely be construed to suggest any safe "threshold" below which cancer doesn't occur.
      2. The data from both researchers are perfectly consistent with cancer production right down to very low doses, and this could very well be a linear relationship over much of the entire dose range from low doses upward.
      We are both dismayed that the Editorial Board of the "British Journal of Radiology" and the Editorial Board of "Health Physics" did not catch the indefensible claim of Dr. Evans that a threshold exists.
      Worse yet, we are dismayed, indeed, by Dr. Evans statement that his "proof" of a threshold is the cornerstone of all radiation protection standards. If this be true, then, there is little wonder that the cornerstone of radiation protection standards is made of quicksilver.
      We believe, after careful study of this particular fiasco, you may be more understanding of our total lack of confidence in the underlying basis for existing radiation standards. However, we are certain everyone concerned in informing you was well-intentioned.
      Since we know this information will be of great interest to the AEC, we feel you will approve of our sending copies of this letter and the enclosures to Chairman Seaborg and Dr. John Totter.
      Assuring you of our deepest commitment to constructive assistance to you in your gravely important responsibilities, we are

       Sincerely yours,

Faith Is Not Justified

          There are, in addition, further mechanisms which operated to confuse the Congress, the electric utility industry, and, eventually, the public of the United States. It is commonplace to find that people in industry, the Congress and the public-at-large, have an almost mystical faith in governmental regulatory agencies. That faith led them to believe that no governmental agency would ever dream of setting a "permissible" dose of radiation that could add one new cancer case for every 10 already occurring—as the Federal Radiation Council apparently had. By examining this situation closely, we come to understand that the erroneous faith comes from "failing to appreciate what was written in fine print."

          The story begins with the emotional and vehement controversies over the hazard of radioactive fallout from nuclear weapons testing of the l950's.

          President Eisenhower, duly disturbed over these controversies, and hopeful of ameliorating this situation in the atomic energy field, established a new agency, the Federal Radiation Council. This agency was to review the evidence concerning radiation hazards, and to provide guidance for the nation concerning what exposure might be regarded as permissible in association with further developments in the atomic energy field. It is this same Federal Radiation Council which finally set 0.17 rads as a legally-permissible, average, annual radiation exposure for the U.S. population, associated with "peaceful" uses of the atom, such as nuclear electricity generation.

          And here is where the fine print must be carefully examined! In setting this permissible limit of 0.17 rads per year, the Federal Radiation Council did not say that this radiation dose was expected to be safe. Far from it! What they said, in effect, was that they hoped the benefits to be received from peaceful uses of the atom would outweigh the risks associated with their permissible doses to the population.

          A reasonable person, having studied this "fine print" qualification might want to know how the Federal Radiation Council had performed the benefit evaluation and the risk evaluation, both so essential in reaching the hopeful conclusion that the benefits outweigh the risk? But, alas, nowhere is there any evidence that this critical part of the task was even attempted by the Federal Radiation Council.

          The public and industry, not realizing the fine print qualification, assumed that "permissible" meant "safe." Little did they, the public and industry, know that "permissible" doses could ultimately translate into disaster.

          The Federal Radiation Council can deny all culpability—for all they were suggesting was the hope that the benefits would outweigh such risks. The Atomic Energy Commission cannot escape justifiable criticism and condemnation, for they have endeavored, and still endeavor, to create the impression that "permissible" radiation exposure means "safe" radiation exposure.

          As a result, utility company officials make countless public statements, and written pronouncements to the effect that 0.17 rads would be without harm to the individuals receiving this amount of radiation. Witness a typical statement by Mr. Frederick Draeger of the Pacific Gas and Electric Company:[1]

          "There is no evidence that 170 millirads is harmful and any new plant will actually emit only an infinitesimal fraction of that amount."

          Apparently, Mr. Draeger hasn't the slightest comprehension of what his statement "no evidence" really means. "No evidence" here means no one has even looked!

          Considering their sophistication and the high degree of responsibility they exercise, the brainwashing of the corporate executives and engineers of the largest single industry in the U.S., the power industry, is hard to believe. Certainly it deserves the No. 1 position among the modern marvels of public relations efforts.

          Faced with the fact that a multi-billion dollar industry has been led down a path of potential economic and public disaster, the Atomic Energy Commission could, of course, also retreat from responsibility by saying, "We too hoped the benefits would outweigh the risks." After all, the AEC hadn't specifically and officially claimed absolute safety. But AEC officials have repeatedly obscured the knowledge of potential hazards! The unfortunate result, even if unintended, is a widespread, false impression of safety in the standards set for nuclear electricity generation and other atomic energy programs.

          In their shabbiest efforts at self-exoneration, both the Federal Radiation and AEC officials have stated that they were not advising the irradiation of all members of the population up to the "permissible" limit. Amen! If we must all be grateful for small favors, this certainly must be one.

          Recently HEW Assistant Secretary Roger Egeberg stated in Congressional hearings (August 5, 1970):

"The FRC position at the present time can briefly be summarized as follows:

    1. We continue to advocate the basic premise that the FRC guides must not be construed as an `allowed' dose which could result in every person in the United States eventually being exposed up to the allowed level."

          This remarkable statement of the FRC position would be ludicrous if it didn't deal with such a deadly serious threat to the future health of the entire U.S. population. If the FRC doesn't want the U.S. population exposed to it, what ever led them to set such a guideline as the allowable exposure? A reasonable question suggests itself: "If you want the exposure to be kept at some low level, why not set the allowable dose there?"

          The Federal Radiation Council antics do, in many respects, compete with those of the Atomic Energy Commission, possibly because the AEC is represented on the Federal Radiation Council. For example, the Federal Radiation Council has stated it is "inadvisable" to accept any amount of radiation without good reason. But where did the FRC ever present any "good reasons" for allowing 0.17 rads as the average U.S. population exposure?

          Considering the magnitude of the cancer, leukemia, and genetic fatalities to be expected from such "guideline" allowable exposure, an incensed public should very well demand, from the Federal Radiation Council, explicit good reasons for allowing 0.17 rads per year.

          A more farcical antic is displayed in some recent testimony of Dr. Paul Tompkins, Executive Director of the Federal Radiation Council—testimony published in the record of the Hearings of the Joint Committee on Atomic Energy:

          Quote of exchange between Dr. Paul Tompkins (of FRC) and Senator Pastore (JCAE):

Dr. Tompkins: "No, sir. It is an exceedingly difficult problem because when dealing with radiation hazards and accepting the no thresholds, the classic approach of setting "a safe level" is denied to us.
      Consequently we have to look at the magnitude of the risk on the one side, and the operational requirements, the desirability of the activities, and so forth on the other, which means there has to be a consensus among many conflicting viewpoints and getting such a consensus is often very difficult."
Chairman Pastore: "May I ask you a question on that point? Reverting back to your statement on page 2. Does the Federal Radiation Council concern itself with the economic aspects of this problem? Does that make a difference to you as to the health measures that are to be recommended?"
Dr. Tompkins: "It depends upon how you define economics."

and, additionally

Senator Pastore: ". . .I agree with that statement, of course, but I was wondering within the province and the purview and the functions of the Federal Radiation Council what are the guidelines that you take into account in reaching a decision?"
Dr. Tompkins: "Primarily the health consideration is, of course, the overriding factor."
Chairman Pastore: "There again you are leaving room for something else. Why shouldn't it be the only factor, from your point of view?"
Dr. Tompkins: "Well, if one can provide a statement as to how much individual risk might be acceptable for certain activities, then I think that would be the only consideration needed."

And separately from a statement of Dr. Tompkins in those same Hearings (p 34):

      "The primary objective of the FRC is to make recommendations which represent a reasonable balance between biological risk and the impact on uranium mining."[2]

          What "operational" requirement of any aspect of the nuclear energy program is more important than the health and safety of the people of the United States? Precisely who decides upon "operational requirements" for nuclear electric power production that might sacrifice thousands or tens of thousands of additional human lives to disease annually.

          The FRC always has expressed its grave concern about "operational" requirements, meaning convenience of governmental or industrial atomic polluters. The FRC always has expressed its grave concern about the cost in dollars of protecting humans from senseless radiation. We have yet to see the FRC express grave concern about extra degenerative and genetic diseases from its own "guideline" radiation doses.

          One further group of totally irresponsible statements emanating from nuclear power proponents deserves careful study here. These statements are not only misleading, but they can be construed in one of only two ways. Either those who make the statements don't understand what they are saying, or they deliberately intend to deceive the public.

          Recently Dr. Theos Thompson, one of five U.S. Atomic Energy Commissioners, said:

". . . Obviously this is a very small amount of radiation compared with the levels which mankind has been receiving through all of the ages. To date, in spite of many careful studies, no one has been able to detect any effect from these low levels of radiation and it is unlikely that studies of literally millions of cases would show any such effects."[3]

          First, we challenge the AEC to produce a single careful study on this issue.

          Furthermore, at first reading the unsuspecting public will again understand this statement to mean that low doses of radiation will produce no effect upon humans. Did Dr. Thompson really want to say that? Why did he make the statement at all?

"No Effect Observed"

          First, the AEC can retreat, upon challenge, to a position that all that was meant was "no effect observed." AEC is not claiming "no effect occurs." The public would have every right to be outraged by this shallow defense of an indefensible statement. But the "no effect observed" statement is not unique to any one spokesman of the AEC. Governmental and industrial atomic energy hucksters seem to adore this statement.

          Suppose there were 1,000 persons in an auditorium and suddenly the lights were extinguished. During the period of ensuing darkness in the auditorium, suppose a man is stabbed to death. When the lights go on again, it is perfectly appropriate (in Dr. Thompson's framework ) to state that no murder was observed ("no event observed"). Yet there is a result for certain—in the form of a murdered man!

          What does this analogy teach us? Simply if we do not look, or if it is too dark to see, then no event can be observed—no matter what disastrous result has occurred. We have every right to be shocked that such devious, non-reasoning pronouncements are typical of nuclear electricity promoters. Indeed, such pronouncements are so characteristic of them that the sheer repetition of such nonsense probably leads even them to believe what they say makes sense.

          What one really must ask the soothsayers of nuclear energy, who appear to have no understanding of public health principles, is, "Have you ever looked properly?" Or, "Were the lights on when you looked?" Their answers we fear, will be meaningless or non-existent.

          They may point out to us, for example, that people have received ionizing radiation from medical x-rays or at their work and "no effect has been observed." What these so-called atomic authorities mean is that after exposure to 5 rads, for example, people don't seem to die immediately.

          This has absolutely nothing to do with whether deadly effects are occurring. For what worries us, and should worry every American concerning the ill-conceived, burgeoning nuclear electricity industry is totally different. We don't expect all exposed persons will die immediately or next week. It is cancer or leukemia five or ten years later, and genetic diseases in many future generations of humans that concern us. Major human tragedy can be occurring and yet, with closed eyes, "no effect is observed."

          Over and over again the public is treated to "no effect observed" pronouncements by AEC officials, such as Commissioner Thompson and Commissioner Larson, when it is quite clear that no meaningful study was ever made. No such studies exist.

          On the other hand, Dr. Alice Stewart (Lancet, June 6, 1970) has produced solid evidence that 250-350 millirads delivered to embryos (1 x-ray film) during gestation produces about a 25% increase in the subsequent occurrence of childhood cancers and leukemias. Faced with such evidence we wonder very seriously whether AEC Commissioners would really continue to make the deceptive, irresponsible statements concerning "no effect observed."

          We have pointed out the treacherous nature of the statement "no effect observed" used by atomic energy proponents to justify allowing population exposure to radiation. Were this an isolated example, now past, we could realize this and forget it. But what about tomorrow?

          We must ask ourselves, "Would it be possible for a major public health calamity to occur, due to a by-product poison, and go unappreciated until it is too late?" The answer is, it could readily occur if officials continue their application of "no effect observed." The reason is that few of these officials appreciate what a major public health calamity is!

          Many persons think of poisons in a "one-to-one" sense. They expect a very high proportion—one out of two or one out of ten people—to show a serious effect. And beyond this, the expectation is that the effect will occur soon (hours, days, or weeks) after the exposure to the poison. If we apply such expectations to potential environmental injury, the human species would surely be doomed. Disastrous effects can occur and be far more subtle than this.

          How disastrous? The combined toll of misery and death due to all forms of cancer plus leukemia would certainly be regarded by every American as a major human tragedy. We know this is true, for Americans consider a reduction in the burden of suffering from these diseases as a major priority goal of generously-supported cancer research. Moreover, research is generously supported for the much more limited, and modest, goal of an added 6 months to a few years of life for the victims of cancer or leukemia.

          In the United States some 320,000 people die annually from all forms of cancer plus leukemia combined. The number appears large. But with 200-million persons in the U.S.A., the fatal toll of cancer is one person annually out of every 600 people. It may come as a surprise that a major human disease, cancer, strikes "only" one out of 600 each year. Intuitively one expects "a major killer" to strike many more persons per year.

          This same type of thinking makes it easy to overlook the introduction of a major killing disease of cancer's magnitude by a cavalier approach to environmental questions.

          Such a disaster can be introduced easily and unobtrusively because of two fundamental errors in public health thinking:

  1. We tend to look for "immediate" effects of poisons.
  2. We forget what careful studies are required to show that 1 out of 600 die per year of a disease.

          And this is the kind of erroneous public-health thinking that encourages the specious statements of technology promoters that "no effect has been observed."

          The kind of serious poisoning produced by radiation has already been described. We know that cancer and leukemia begin to occur 5 or more years after the radiation has been received. Thus, if radiation were the environmental insult under study, one could examine a group of exposed persons after one, two, three, or four years, and reach the massively erroneous conclusion that the radiation had done no harm. This is what happens if scientists look for immediate effects when the real hazard is delayed. A self-evident truth? We must remember that one of the greatest public health errors of judgment was made in precisely this way in the field of radiation protection—and made by highly competent scientists!

          Leukemia appears in radiation-exposed persons approximately five years after exposure, whereas most other cancers take 10 or more years to occur. Therefore, a group of humans exposed to ionizing radiation would show only leukemia five years later, simply because all of the other cancers had not yet occurred. The expert bodies of scientists studying radiation hazard for humans fell into this specific trap and as a result, they seriously underestimated the cancer hazard.

          What is even worse, the error has been even further compounded. Knowing that some forms of cancer may take even 15 to 20 years to appear after radiation, these expert bodies still were refusing to consider additional cancers even though they realized it might still be too early, 15 years after radiation, to perceive the full effect.

          For most of the serious environmental poisons, cancer at 5 to 25 years after the poisoning is precisely the kind of effect we must worry about. Genetic effects, occurring in subsequent generations, can be many times more serious than cancer! The folly of looking for "immediate" effects, and thereby exonerating a poison, must be strongly condemned if disaster is to be prevented.

The Careful Studies Required to Observe Effects

          We have pointed out that one person out of 600 dying annually from cancer represents a "major killer" entity—equivalent to the entire cancer problem in the United States. Could officials miss such an effect for an environmental poison through inadequate studies? The answer is "Yes." In fact, one repeatedly encounters supposedly scientific studies that have led to erroneous results and enormous public-health blunders, simply because an inadequate number of exposed persons were studied.

          How many people exposed to an environmental poison, radioactivity or other, would be required? At the outset we realize that, whatever the number, the observations won't begin to be meaningful for at least 10 years, because that is when the cancers are beginning to occur in appreciable numbers.

          Suppose we ask ourselves about a study involving 1200 people exposed to an environmental poison, a poison that might kill, after a 10 year latency period, one out of 600 people per year. Obviously the first requirement would be a "control" population, not exposed to the same poison, to compare with the exposed group of 1200 persons. So we would now be studying 2400 persons, 1200 who had been exposed to the poison, 1200 who had not been exposed.

          Let us consider, say, the fifteenth year of the study. Would we easily observe the massive effect that could be occurring? If the spontaneous, or natural, cancer occurrence rate is one per 600 per year, we would expect two cases in one year of observation among the control group. We would expect four cases in one year of observation for the exposed group (two spontaneously plus two for the poison effect).

          BUT there is a random statistical fluctuation in such occurrence rates from year to year, such that the control group might in a particular year show zero, one, two, three, four, or even more cancers occurring. The exposed group, even with four cases expected, may, in a particular year, show anywhere from 0 to 10 cases, with a reasonable likelihood. Thus, what appears to be a large study, 2400 persons under careful observation, turns out to be inadequate even to discover an effect so large as to be representative of the entire size of the U.S. cancer plus leukemia problem.

          Even if we had 3,000 people in the poison-exposed group and 3,000 in the control group, with the expectancy of 10 and five cancer cases in one year respectively, we would still be uncertain of the meaning of the results, simply because of statistical fluctuations. At least 6,000 exposed persons and 6,000 controls would be necessary for a reliable reading of even a massive effect—one in 600 per year!

          Yet technology promoters seem oblivious to the requirements in terms of how many people must be observed for meaningful answers. They consider a totally inadequate number of cases and conclude "no effect observed." While this may delude the public into accepting poisonous by-products of the technology, it is not consistent with survival of humans on earth.

          We have been discussing here a massive effect that can only be considered a bludgeoning of the human species. And even so, it is apparent that an inadequate study can lead, easily, to the ridiculous assertion, "no effect observed."

          Atomic energy development must, unfortunately, be regarded as one of the worst examples of irresponsibility of this sort.

          The important purpose of demonstrating the rash unsoundness of "expert" pronouncements in the past is to alert the public to such errors so that they will insist on a vastly improved performance in public matters in the future, for radioactivity and other serious pollutants.

          In recent testimony before the Congress (Joint Committee on Atomic Energy Hearings) Dr. Paul Tompkins, Executive Director of the Federal Radiation Council, described, with apparent pride, the history of so-called "Radiation Protection Standards." (A more apt description might be the history of "Radiation Disaster Standards.") Dr. Tompkins related that in 1954 the National Committee on Radiation Protection, a leading U.S. group of "experts" had issued the following statement,

"We have a lower limit of continuous exposure to radiation that is (unavoidably) tolerated by man. There is, on the other hand, a much higher level of exposure that is definitely known to be harmful. Between these two extremes there is a level of exposure, in the neighborhood of 0.1R per day, that experience to date shows to be safe for the individual concerned."[4]

          Not a shred of scientific evidence was produced to support this statement, an astounding statement of supposed reassurance. Now, let us consider, in the light of our medical knowledge of radiation injury 16 short years later, what the cost would have been for public exposure to radiation at such supposedly "safe" levels.

          The NCRP was reassuring about 0.1 rad per day. For estimations of cancer risk we customarily estimate the dose for persons of about 30 years of age. At 0.1 rad per day, a person would accumulate 1095 rads by 30 years of age (since 36.5 rads would be accumulated in one year at this rate, it would be 36.5 x 30, or 1095 rads in 30 years). Now, from extensive studies concerning the cancer-producing and leukemia-producing ability of ionizing radiation in humans, it appears that approximately 50 rads of accumulated exposure will add as many cancers plus leukemias as occur spontaneously due to "natural" or "spontaneous" causes. And such added cancers and leukemias will occur each year for many years once the latency period is over.

          By simple arithmetic, 1095 divided by 50 equals 21, so we can expect twenty-one times the natural incidence of cancer plus leukemia. TWENTY-ONE TIMES the natural, spontaneous fatality rate from cancer plus leukemia would have been the result of a dose pronounced by a body of experts as being without physical effects upon the person exposed.

          No disaster in man's health history could match this one had people truly been exposed to this radiation dose, stated to be safe by a standard-setting body, the National Committee on Radiation Protection. It is something of a stretch of public credulousness and confidence to call for lasting faith in such "standard-setters."

          Earlier, we spoke of the horrors of increasing cancer plus leukemia to double the spontaneous occurrence. The NCRP "safe" dose could have provoked a catastrophe 21 times larger than that!

          And this is only the beginning of the incredible fiasco of "standard-setting" for technology. Up to now, we have considered only the cancer plus leukemia part of the hazard. Everyone concerned about radiation hazards to man knows that the genetic consequences in future generations give every expectation of being far more severe than the cancer plus leukemia risk in the current generation of humans.

          The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) has indicated that it takes about 10 to 100 rads to double the spontaneous rate of genetic mutations. Professor Lederberg, the eminent geneticist, has recently estimated approximately 50 rads to double the mutation rate. His estimate is almost precisely in the center of the range estimated by UNSCEAR, so we may explore the consequences of this estimate. At the average reproductive age of 30 years, a person receiving NCRP's "safe" 0.1 rad per day would have accumulated 1095 rads, we saw above. So, if the genetic mutation rate is doubled by 50 rads, it is increased 21 times by 1095 rads. So the NCRP "safe" dose of 0.1 rads per day would have meant a 2100 percent increase in mutation rate. Contrast this with Professor Lederberg's recent admonition that society would be well advised not to add one percent to the mutation rate. Contrast 2100 percent with one percent!!!

          It is only by a quirk of fate and timing that society escaped acceptance of the National Committee on Radiation Protection's recommendation, and its results. The nuclear electric industry and other atomic energy programs just weren't ready, technologically, for widespread expansion in 1954.

          In the years shortly after 1954, scientists began to wake up a little and realize the enormity of the error represented by the pronouncement of the NCRP. It was obvious that a massive reduction, in doses to be allowed for humans, must be made immediately. Biologists in the 1956-58 period, realizing the enormity of their past error, had an opportunity to implement a sound policy with respect to allowable radiation dosage. But they did not do so.

          A sound policy of public health protection gave way to the powerful imperative of "convenience" for the promoters of technology. The scientists asked themselves. instead. how low they could push the allowable radiation dose to the public, without interfering with the "orderly development of atomic energy." So they issued suggested standards along the following lines:

  • 5.0 rads per year for workers in atomic energy
  • 0.5 rads per year for individuals in the population-at-large
  • 0.17 rads per year average for the population-at-large.

What a come-down these numbers represent from 36 rads per year being "safe" or "without physical effect"!

          Incredible as it seems, scientists, in a few short years, had to change a recommendation, downward, between seven and 200 times. And what evidence did these standard-setting scientists provide that the "new" standards of allowable radiation would be safe? None whatever. Absolutely none.

          Obscurantism gobbledygook has characterized all efforts to set so-called "safe" or "allowable" standards for industrial poisons, radioactive or other. In truth, standard-setters know full well there is no evidence for any safe amount of a poison such as radiation or radioactivity.

          We are perfectly happy to consider errors of the past as part of the learning process. But the "standard-setters" are not satisfied to learn by errors; they defend their errors of the past and try to justify their unbelievable errors of the present.

          For example, the catastrophic statements of NCRP in 1954 are explained this way: "We were not recommending that people be exposed widely to 0.1 rad per day." Thank heaven for this! But, of what earthly use is a pronouncement by a standard-setting body, that 0.1 rad per day is without physical effect upon the exposed person, other than as guidance for technologists so they can plan their designs, including safety features?

          When the nuclear electricity promoters are asked about hazards due to irradiation at the "allowable" doses of radiation, they go into speeches about the "expert scientists" who set these "allowable" (inferring safe) doses after careful deliberation. Indeed, the electric-utility industry buys two-page advertisements in national magazines to present precisely this justification for safety of the "allowable" doses.

          When the evidence is presented to the "standard-setters" that large numbers of cancers, leukemias, and genetic disorders would accrue from population exposure at the "allowable" dose, they answer, "We didn't mean for people to ever reach those allowable doses."

          Recently, the charade has assumed even more ridiculous proportions as the nuclear electricity salesmen have attempted to defend their obviously indefensible standards for human radiation exposure. An attempt at justification, bizarre in the extreme, is now presented for the 0.17 rads allowable for the population-at-large. It is known that natural sources of radiation plus those from medical uses of x-rays add up to approximately 0.17 rads per year. "Aha," say the proponents of nuclear electricity and other nuclear energy programs, "We shall allow the 'peaceful atom' to give an amount additional that will just equal what people are already getting from other sources." But why would anyone think of doubling the harm already being produced by the 0.17 rads from natural plus medical radiation? From all that has already been discussed, we know that natural and medical radiation produce cancer and genetic harm, in direct proportion to the dose received, down to the lowest doses.

          No amount of ionizing radiation is safe!

Radiation Hazard

  1. Quoted in "Nuclear Hazard In Santa Cruz" by Harold Gilliam, San Francisco Chronicle, Sunday, June 28, 1970.

  2. Reference: "Radiation Exposure of Uranium Miners." Hearings of the Joint Committee on Atomic Energy, 90th Congress 1st Session. May-August, 1967. Part 1.

  3. Reference: Power Technology and The Future by Commissioner These Thompson (USAEC). Presented at "Briefing Conference for State and Local Government officials on Nuclear Development," Columbia, South Carolina, May 21, 1970.

  4. Reference: Dr. Paul Tompkins, quoting directly from 1954 NCRP Statement. In "Environmental Effects of Producing Electric Power." Hearings before the Joint Committee on Atomic Energy," 91st Congress, 1st Session, October-November, 1969. Part 1.

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