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Response to Hayes: LNT Contradicts Biology, but ALARA Gets Lethal.

Dear Editors: WE ARE pleased to respond to the letter by Hayes (2018) as it provides an opportunity to address the very important issues raised in his alternative perspective. The U.S. National Academy of Sciences (NAS) Biological Effects of Atomic Radiation (BEAR) I Committee Genetics Panel started the pervasive fear of radiogenic mutations by issuing a recommendation in 1956 to use the linear no-threshold (LNT) dose-response model for assessing the risk of radiation-induced mutations instead of the standard threshold model (NAS 1956). It misled the world community about cancer risk assessment, and all governments adopted the LNT model (Calabrese 2013, 2016). Calabrese has even presented significant newly uncovered evidence of Genetics Panel scientific misconduct—its “deliberate misrepresentation of the research record in order to enhance an ideological agenda.” Based onmore than 50 y of human experience, renowned Massachusetts Institute of Technology (MIT) scientist and health physicist Robley D. Evans (1949) calculated the radiation-induced mutation rate in humans and concluded: “From the appropriate mathematical theory, and the experimental data now available, it seems safe enough to conclude that no detectable increase in hereditary abnormalities is likely to result, even after many generations, if a small fraction of the population receives daily radiation doses up to 0.1 roentgens (R) per day.” (Evans’manuscript was reviewed by geneticist Donald R. Charles of the University of Rochester and by physicist and radiobiologist Louis Harold Gray of the Hammersmith Hospital in London.) Since 1 R is about 10 mGy, this “tolerance dose” rate amounts to a limit of about 300 mGy y. Indeed, data on low dose-rate induction of late effects such as cancer unequivocally contradict the statement by Hayes (2018) “. . . all such doses are cumulative.” This and the plea by Hayes not to abandon the concept of as low as reasonably achievable (ALARA) lead us to contemplate the following. About 21 y ago, nuclear pioneer Theodore Rockwell (1997) stated that the cost of trying to reduce harmless radiation exposures is exorbitant, and “predicting” casualties from such exposures generates groundless fear and distorts public policy. It is time to bring radiation protection policy into line with the data. When pressed for a statement, many regulators will admit there is really no science to support the notion that any amount of radiation, no matter how small, can be harmful to the body. They say: “We’re not really saying it is harmful; just that it might be.” But then they ask: “What's wrong with being cautious? We tell people it might hurt them, and perhaps it won’t. Can that do any harm?” The answer is plenty of harm—five different kinds of harm: billions of dollars wasted, unwarranted regulations imposed that degrade the credibility of science and government, destructive fear generated, detrimental health effects created, and environmental degradation accelerated. Current regulations define as “radioactively contaminated” material that gives off less radiation than the natural background where people have had happy and healthy lives for many generations. Storing even low-level radioactive waste requires multimillion-dollar studies with unreal scenarios of atoms migrating through miles of desert soil to “contaminate” a possible water source in the distant future—water whose natural radioactivity would already be far above that of the mythical contaminant. There is accumulating evidence (>120 y) that low doses or low levels of ionizing radiation are not harmful, contrary to the induction of harm at high doses. A recent analysis of a study on long-term gamma-ray exposure of dogs, which model humans, provides evidence of a doserate threshold for the onset of exposure-induced life shortening. Fig. 1 illustrates that the threshold ranges from about 700 mGy y to about 1,000 mGy y (Cuttler et al. 2017). Since 1956, all of the regulatory authorities continue to accept the NAS recommendations, failing to address the mounting scientific evidence that contradicts the LNT model. There is no biological data that supports the LNT model. Urgent change is needed to radiation protection policy (Cuttler 2016). In view of the abundance of radiobiological data on low-dose effects, we recommended a consensus conference to establish dose and dose-rate limits for radiation protection, belowwhich risk cannot be comprehended (Feinendegen and Cuttler 2018). Continuation of the ALARA concept is detrimental because it sustains unwarranted fear of any exposure to radiation and thus brings on decisions with lethal consequences. The Chernobyl and Fukushima accidents resulted in the enormous suffering of many hundreds of thousands of people who received harmless exposures. Thousands died prematurely due to psychological stress; many abortions were performed. 0017-9078/18/0 Copyright © 2018 Health Physics Society