Imbalance and Conflict-of-Interest

in BEIR VII Phase 2 Committee Membership


Our review of possible conflict-of-interest and imbalance problems in the membership of the BEIR VII Phase 2 committee has been hampered by a number of factors:

The refusal to release conflict of interest "disclosure" information or even curricula vitae creates a clear impression that NAS is trying to hide something about the composition of the panel. A review of the publications of the panel members makes clear what that something is: virtually all of the panel members are from the side of the scientific community urging reduction in radiation risk estimates, and all scientists on the other side of that debate have been excluded from the panel. Indeed, to the best of our knowledge, every scientific member of the panel has publicly opposed the strict Linear No-Threshold (LNT) model of radiation risk that is the core subject to be assessed by BEIR VII, all arguing that risks are less than linear. Not a single scientist whose work has indicated a linear dose-risk relationship appears to have been included, let alone any of the significant scientists whose work suggests risks are greater than one would presume from linear interpolation (i.e., supra-linear). For an important National Academy of Sciences study re-evaluating the Linear No-Threshold approach, it is remarkable that not a single defender of the strict LNT model has been permitted on the committee, and that all LNT critics that have been appointed are those whose would lessen rather than increase risk estimates. Most panel members are individuals whose past positions and sympathies are clearly with relaxing regulations, providing cost savings to nuclear agencies and industry while increasing exposures to the public. Scientists whose leanings are towards increased protection of the public have been scrupulously excluded.

The association between financial sponsorship of research and the conclusions of that work has long been noted. By saying that, one is not asserting that a particular scientist has skewed her or his research to meet the economic interests of the funding source, although certainly there are regrettable cases where that occurs. Rather, funding sources with a large economic interest in a particular outcome of investigation will tend to provide financial support to those investigators whose viewpoints and past conclusions suggest that their work will, more likely than not, be helpful to those interests. It is no accident, for example, that researchers with strong ties to the Department of Energy (DOE) have tended to perform studies suggesting minimal harm to workers at DOE nuclear facilities whereas the work performed by scientists more independent of DOE have been more likely to find significant excess cancers associated with radiation exposure. (A discussion of the troubled history of radiation epidemiology due to this conflict is enclosed separately.)

With this history and context, it is therefore troubling to examine the known institutional associations of the people chosen to serve on the panel. The associations with DOE and similar institutions in other countries (EURATOM, Canadian Atomic Energy Control Board) are numerous, whereas associations with the other side in the nuclear debate are non-existent. Several panel members have financial ties to the Electric Power Research Institute (EPRI), an institution representing the nuclear utility industry; no panel members associated with the critics of the nuclear industry are included. The committee includes a representative of an organization composed of people responsible for compliance with radioactive waste and protection regulations at industries and other institutions that handle radioactive materials, an organization that has been lobbying hard for relaxation of those regulations so as to save money for their institutions and others like it. Another committee member is a Vice President of a major nuclear contractor with an obvious interest in saving money by relaxed radiation standards. However, no one associated with groups representing the public or nuclear workers who have an interest in strengthening protections so as to save lives has been permitted on the panel. At least four members of the panel have worked as consultants (presumably paid) to industry in litigation, defending the companies against lawsuits brought by alleged radiation victims; to our knowledge, no panel member has served as a plaintiff’s witness, defending radiation victims against industry or agencies in such litigation.

The chances are vanishingly small that such bias -- data points all falling on one side of the line separating viewpoints and associations on this highly controversial issue -- could be random. The human hand -- and the pressure of institutions -- appears at work. Indeed, when one examines the viewpoints of the NAS staff responsible, the same viewpoints and associations appear. When one examines the origins of the BEIR VII committee itself --pressure from industry groups such as the Health Physics Society and from nuclear agencies such as DOE and NRC for an attack on LNT in an effort to roll back regulations and save money -- the skewed nature of the appointments appears completely non-random.

Additionally, even with the refusal to release conflict-of-interest information, from information that is publicly available it is clear that at least several members of the panel have such conflicts. The Academy’s appointment of these individuals despite their conflicts, and its failure to disclose the conflicts, violates the Federal Advisory Committee Act (FACA). The failure to assure balance in the appointments further violates FACA.

A discussion of the imbalance and conflicts-of-interest follows. In so doing, we wish to reiterate that we are not questioning the integrity of any person named to the panel, nor their right to hold the views they do. What we are concerned with is the lack of balance, the failure to represent the range of opinions in the scientific community on the very questions that BEIR VII is to examine.


The BEIR VII Phase 2 Committee


CHRIS WHIPPLE. Dr. Whipple is Vice President of ICF Kaiser, the huge nuclear contractor that, among other projects, runs the heavily contaminated Rocky Flats nuclear weapons facility for the Department of Energy. ICF Kaiser is a major nuclear contractor elsewhere and has a major economic stake in relaxed radiation standards. Prior to joining ICF Kaiser, Whipple was employed at the Electric Power Research Institute (EPRI), an a nuclear industry advocacy organization. He has spent his professional career working for the nuclear industry.

Whipple’s appointment is a perplexing one, as, in addition to the conflict of being a Vice President of a major nuclear company, Whipple has no background in radiation epidemiology or radiation biology. His area of specialty has been nuclear waste disposal. He is listed in the BEIR roster in the area of risk assessment, but surely the Academy could have found someone other than an executive of a nuclear company--who would have a major interest in asserting risks from its industry are minimal--to contribute in this area, if it were needed at all. And if one were to place on the panel someone from industry who argues the risks it generates are minimal, surely he should have been balanced by a risk specialist from an independent organization more critical of the nuclear industry.

It is inappropriate for someone associated with an entity that has a financial interest in the outcome of the study at hand to be involved in the study itself. The Academy would, one would hope, think twice about having someone from the Tobacco Institute or a tobacco company on an NAS study panel examining whether risks from smoking had been over- or under-estimated. However, if Dr. Whipple is permitted on the panel, he should be balanced by someone representing the other interests in this debate: the public potentially exposed to radiation from companies such as Dr. Whipple’s ICF Kaiser. Yet no representatives of or scientists associated with communities residing near contaminated facilities like Rocky Flats have been permitted on the panel. (Indeed, no scientist who has found significant excess cancers at DOE sites such as Rocky Flats, e.g., Gregg Wilkinson’s brain cancer finding there, has been permitted on.) An industry advocate is appointed, whose industry stands to gain financially if risk estimates are relaxed; but no public interest advocate, and no scientists believing current risk estimates are leading to regulations that are causing undue numbers of excess cancers.

Dr. Whipple has a disqualifying conflict-of-interest. Furthermore, his presence is unbalanced by anyone with contrary views.


KEN MOSSMAN: Dr. Mossman is in charge of compliance with radiation regulations at Arizona State University. As such, part of his job is to press for relaxed radiation requirements so as to reduce compliance costs for ASU. He has been very vigorous in this effort, acting as a major advocate of changed regulations so as to permit ASU and other institutions with radiation activities to dramatically increase the amount of exposures to the public permitted. As discussed below, he has advocated that his and other institutions be permitted to markedly increase such exposures, expressly saying to do so would save them a great deal of money.

Perhaps the clearest and most troubling expression of Dr. Mossman’s advocacy in this regard is an editorial he wrote and which was published 14 May 1998 in The Arizona Republic newspaper. It is entitled, "EPA Guidelines Waste Funds, Based on Faulty Science: Small Doses Just Aren’t Harmful." In it, Mossman attacked EPA radiation protection standards as overly restrictive and costing billions of dollars in supposedly unnecessary compliance expenses, and lobbied on behalf of a Congressional bill to restrict EPA’s rulemaking powers:

Billions of dollars of public funds may be expended needlessly to comply with overly restrictive regulations for environmental clean-up and waste disposal unless the EPA’s proposed Federal Guidance on "Health Risks from Low-Level Environmental Exposure to Radionuclides" is revised to reflect current scientific understanding. A new Bill in Congress may force the EPA to do just that.

In his editorial, Mossman goes on to asserts that low dose are safe and attacks LNT, saying:

...this approach is overly conservative, leading to excessive regulatory compliance costs. Low level radiation may be less dangerous than commonly believed. In one study of the costs and benefits of federal social regulation -- regulations aimed at reducing occupational safety and health risks -- imposed compliance costs of about $9 billion annually for negligible risk-reduction risks. Less restrictive standards would save the public billions of dollars without compromising the public health or safety.

(emphasis added)

After saying "the linear, no-threshold philosophy is unacceptable," Mossman then argues for setting standards for the public at about 200 millirem annually above background -- or an order of magnitude over current EPA regulations. (Elsewhere he has argued for relaxing public limits to up to 300 millirem).

Finally, he concludes by saying that the key to this billion-dollar savings is the outcome of the new National Academy of Sciences (BEIR VII) review. It seems incomprehensible that someone who has been lobbying for relaxed standards, part of a campaign attacking LNT in order to reduce compliance costs for his own and associated institutions, and who expressly says one must pin one’s hopes on BEIR VII, is appointed to it.

In another article, Mossman identifies regulatory compliance costs as one of the "major drivers in the LNT debate." He goes on to say:

Another important driver has to do with public relations. Support of the LNT theory and the idea that any radiation dose is potentially harmful has resulted in a public relations nightmare for the nuclear industries....Public "outrage" from dangerous radiation has led to over-regulation of nuclear industries resulting in billions of dollars in compliance costs. Abandoning the LNT philosophy and relaxing regulations would have enormous economic implications.

(emphasis added)

After arguing for a ten-fold relaxation of radiation standards, up to 300 millirem annually for members of the public, Mossman concludes that "Discarding the dominant ideology that any radiation dose may be harmful for a less conservative standard-setting approach is not an easy task. . . . Although much is yet to be learned about health effects of low-level radiation, sufficient information is available now to apply less conservative approaches to standard setting ...." (emphasis added)

In a related article ("The Linear No-Threshold Debate: Where Do We Go From Here?), Mossman vigorously attacks the LNT model. Among the reasons again: "regulatory compliance costs too much .... [S]upport for the LNT theory and the idea that any radiation dose is potentially harmful has resulted in a public relations nightmare for the nuclear industries." He says, Science will never be able to resolve completely the question of a threshold," but then goes on to argue that "Selecting a predictive model for the purposes of setting regulatory policy must be based on economic, social and political considerations as well." (emphasis added) He again argues for relaxing public exposure limits ten-fold, or more, concluding, "A less conservative approach to standard setting now seems appropriate and will have substantial economic benefits without compromising the public health." (emphasis added)

Dr. Mossman is also the past President of the Health Physics Society (HPS), the nuclear advocacy group leading the charge for relaxed radiation standards. HPS is an association of health physicists, i.e., those, like Mossman, charged with assuring compliance with radiation protection regulations at their institutions (nuclear power plants, DOE nuclear weapons labs, nuclear waste disposal facilities, and other entities that use or handle radioactive materials.) HPS has been aggressively representing its members’ interests in reducing financial burdens on their institutions by pushing for easing radiation regulations.

In that regard, Dr. Mossman is the lead author of the highly controversial HPS position paper calling for agencies to ignore all doses below 5 Rem annually and 10 Rem lifetime. The position paper attacks the linear, no-threshold model, asserting it "results in an overestimation of health risks in the low dose range." The position paper touts cellular repair of radiation injury and concludes that below 10 rem, "zero health effects is the most likely outcome" (i.e., 10 rem is a threshold below which harm doesn’t occur at all). These are, of course, precisely the extreme claims that the BEIR panel is to examine; it seems hard to envision circumstances in which Dr. Mossman can dispassionately evaluate assertions from HPS, of which he has been a key officer and prime author of the controversial position statement to be evaluated. Furthermore, because the HPS position statement is intended in part as a component of a lobbying effort to relax radiation requirements that cost money to the institutions for which HPS members work, having the past president and key author of the HPS position on the panel seems particularly in appropriate.

The cloud hanging over the BEIR process caused by Dr. Mossman’s appointment to it has been exacerbated by the appearance that the BEIR Committee is in some fashion tied to HPS in other ways. For example, the first meeting of the BEIR committee has been scheduled purposely to be held in conjunction with the HPS Annual Meeting in Philadelphia.

Dr. Mossman is at the extreme end of the scientific debate on radiation. He has declared that "radiation is a weak environmental carcinogen" and harmless at low doses. He is a political advocate on behalf of saving institutions such as his own substantial money by radically relaxing public protections. He has every right to be an advocate of those positions which, if adopted, could save his employer money in terms of waste disposal and radiation protection costs. He might even be interesting for the BEIR committee to have come before it to present his advocacy as a speaker, IF balanced by someone of opposing viewpoints.

However, placing Mossman on the panel suggests a political review, tainted by economic interests, rather than a neutral scientific review. This is particularly true when no one representing the opposing views (radiation standards too weak) and interests (protecting the public from unnecessary radiation exposures) has been appointed. Dr. Mossman has conflicts-of-interests, which appear to conflict with FACA requirements. (We wish to make clear that we are not saying that any scientist associated with any university that spends money on radiation protection has a significant conflict-of-interest. Here, Mossman is not just an unrelated faculty member, but in charge of the radiation safety office, whose duties include reducing regulatory compliance costs for his institution, a matter about which he has been very energetic, and which will be directly affected by BEIR, as he has himself editorialized.) Furthermore, the extreme nature of Dr. Mossman’s views, and the lack of a counter to them on the panel in the form of scientists who view current standards are too weak, creates an unacceptable imbalance.

DAVID HOEL. Dr. Hoel is a strenuous opponent of the Linear No-Threshold model. (See, e.g., Hoel and Li, "Threshold Models in Radiation Carcinogesis," Health Physics, September 1998, Vol. 75, No. 3, 241-250). He advocates the concept of a threshold, below which no harm from radiation occurs. He argues that, even were there no threshold, low doses must be considerably less harmful than would be predicted by the linear model. He points to fractionation effects, adaptive responses, and other arguments to support his view that low dose risks being less than predicted by LNT. Scientists who hold opposite perspectives are excluded.

Dr. Hoel began his career working for the Westinghouse Corporation (a major nuclear reactor vendor) and DOE’s Oak Ridge nuclear laboratory. In recent years he has testified on behalf of General Public Utilities (GPU), operators of the Three Mile Island reactor, defending it in court in a lawsuit brought by nearby residents of the reactor that suffered a meltdown. On behalf of the TMI operators, he attacked the study by Steve Wing and colleagues about possible health effects from the accident.

Dr. Hoel has also recently been a consultant to the Rocketdyne Corporation, operators of the heavily contaminated DOE Santa Susana Field Laboratory (site of a 1959 partial core meltdown and other accidents), attacking on the company’s behalf a study by a team of epidemiologists from the UCLA School of Public Health (Morgenstern, Ritz, and Froines) which found significantly elevated cancer risks among workers associated with radiation exposures well within regulatory limits. The Morgenstern study, like several other recent studies, found cancers being induced at about an order of magnitude greater rate than would be predicted from current risk estimates for "low dose" radiation.

It is difficult to see how Dr. Hoel, who has been presumably paid by these nuclear companies to attack studies by Drs. Wing and Morgenstern, will be in a position to neutrally analyze those and similar studies in the BEIR process. Furthermore, the authors of the studies Dr. Hoel has been paid by industry to attack have not been permitted on the panel. Again, only advocates of reducing official risk estimates for radiation have been allowed on the committee; and scientists whose studies produced contrary findings have been excluded. (Indeed, we note that none of the studies finding cancer risks greater than predicted by current official risk estimates -- e.g., Wing and others at Oak Ridge, Stewart and Kneale regarding Hanford, Morgenstern and others at Rocketdyne -- are even included in the BEIR VII Phase I report, coauthored by Hoel, as studies to be even examined by the Phase 2 committee.) No one with views to the contrary of Dr. Hoel -- i.e., none who believes that current risk estimates may be too low -- has been permitted on the panel to balance his views and those of the rest of the committee.

GEOFFREY HOWE. Dr. Howe is another advocate of the premise that low doses of radiation are substantially less harmful than officially presumed. He bases his position in part on the premise of "fractionization," i.e., that if one divides a single high dose into several low doses the effect of the latter is markedly less, perhaps even zero, compared to the former. See, e.g., Howe, "Lung Cancer Mortality between 1950 and 1987 after Exposure to Fractionated Moderate-Dose-Rate Ionizing Radiation in the Canadian Fluoroscopy Cohort Study and a Comparison with Lung Cancer Mortality in the Atomic Bomb Survivors Study," Radiation Research 142, 295-304 (1995). His work has been financially supported by the Canadian Atomic Energy Control Board. In that study, for example, he argued for a "substantial fractionation/dose-rate effect" and asserted that current risks from exposure at low to moderate dose rates may be "overestimated" by extrapolation from the A-bomb victims data.

Dr. Howe has also asserted that it is "most unlikely" that there is any relationship between radiation exposure and increased risk of cancer around British nuclear installations. (See, e.g., "Leukemia and Other Cancers Around UK Nuclear Installations," The Science of the Total Environment, 127 (1992) 43-45.) However, no author of any study that has shown such an apparent link has been permitted on the panel.

We have been told that Dr. Howe has worked for the nuclear giant BNFL in its defense in litigation over the Sellafield nuclear facility, for the defense in Hanford litigation, and for the DOE contractor at Rocky Flats. (Without access to the conflict-of-interest disclosure forms, we cannot confirm this.) No scientist who has worked for radiation victims rather than nuclear companies in such litigation, to our knowledge, is on the panel; and the panel includes no scientist whose viewpoint is that fractionization increases rather than decreases overall risk because at higher doses, there is a higher probability the cell will be killed completely, whereas at lower doses the cell has a greater chance of surviving but damaged, so it can reproduce to produce a cancer.

ALBRECHT KELLERER. Dr. Kellerer is a long-standing opponent of the linear no-threshold model. (See, for example, Rossi and Kellerer, "Radiation Carcinogenesis at Low Doses," Science, 14 January 1972, 200-202; "linear extrapolation to lower doses is unjustified." Rossi was the most outspoken member of the BEIR III minority in his assertion of minimal risk of low dose radiation.) Kellerer has in recent months reaffirmed these views by arguing that current risk estimates are "unreasonably over-conservative" and should be radically decreased, and that in fact there may be no risk at all from low doses. See Kellerer, "The Effects of Neutrons in Hiroshima. Implications for the Risk Estimates," C.R. Acad. Sci. Paris, Sciences de la vie / Life Sciences, 1999. 322, 229-237. In that paper, Kellerer argues that a policy focus on radiation risks is largely misplaced, and that "[t]he cost of such distortion is high," asserting that great expense is directed needlessly towards reducing the supposedly minimal risks from radiation. He describes exposures of the population due to nuclear technology as "minute." Kellerer has chosen to focus his attack on the LNT model --which he refers to as a "dogmatic reduction" -- because "it is this reduction that often determines regulatory decisions."

Kellerer argues in the above-mentioned article that radiation risk estimates should be dramatically reduced. He argues that by changing some of the assumptions for Hiroshima studies (not using a constant Relative Biological Effectiveness factor for neutrons, and altering assignment of doses to some of the population), "the risk estimates from the Hiroshima data could be less than current values." By assuming, further, that risks among A-bomb survivors decreases significantly with time, they can by this presumption alone "decrease the risk estimates to about half their assumed values." Additionally, Kellerer is an advocate of altering the dosimetry assumptions so as to assign all or virtually all of the cancer induction at low doses to neutrons and none or virtually none to other forms of radiation. He indicates that if that new dosimetry assumption were accepted, "Hiroshima could cease to be proof of a fine risk coefficient for photons." He says this would be major support for a threshold. If these assumptions of his were accepted, "it will imply that all effects at low doses might well have been due to neutrons. The A-bomb data would then cease to support finite risk estimates for sparsely ionizing radiation [the kind being examined by BEIR VII and to which the public is most commonly exposed.]" Kellerer concludes that risk estimates should be significantly decreased. No one from the opposing point of view is on the panel.

K. SANKARANARAYANAN. Dr. Sankaranarayanan, whose work has been financially supported by EURATOM, is another advocate of the view that low doses are less dangerous than currently thought, largely based on his belief in the controversial premise of an "adaptive response" to low-level radiation. See e.g., Sankaranarayanan et al., "Adaptive Response of Human Lymphocytes to Low-Level Radiation from Radioisotopes or X-rays," Mutation Research, 211 (1989) 7-12. Sankaranarayanan argues that the body in essence "adapts" when given low doses so as to "learn" how to respond and become less sensitive to subsequent doses. He also has argued that current radiation risk estimates for genetic diseases overstate the true risks. (See "Ionizing radiation, genetic risk estimation and molecular biology: impact and inferences," TIG March 1993, Vol. 9, No. 3.) Scientists with opposing views on these matters have been excluded from the panel.

Dr. Sankaranarayanan also appears to come from the same viewpoint as virtually all of the rest of the panel with regards to the value of regulation of environmental pollutants generally. He is co-author of a controversial commentary article, "Choosing the Limits to Life," (Nature, Vol 357, 21 May 1992), which appears to argue that deployment of resources to control environmental carcinogens is in general justified in neither the developed nor the developing world. He argues that additional expenditures for controlling exposures to carcinogens in the developed world is not justified in that average lifespan already approaches what he views as the natural maximum, so controls on carcinogens cannot, he says, significantly increase a developed nation’s average life expectancy. As for the developing world, he argues that other factors are more important in the lower life expectancy there, and so, again, environmental controls (with the exception of avoiding major environmental degradation or dramatic local increases in chemically induced cancers) are generally not worthwhile.

While Dr. Sankaranarayanan is certainly entitled to his opinions, it is of concern that the panel seems composed generally of people all from the point of view questioning the value of environmental controls on carcinogens like radiation.


ETHEL GILBERT. In the 1970s, Dr. Thomas Mancuso, Dr. Alice Stewart, and George Kneale reported that workers at DOE’s Hanford facility were dying from excess cancers associated with their radiation exposure. In a famous incident, DOE canceled Dr. Mancuso’s contract (trying also to separate him from his data) and gave the Mancuso contract to Dr. Gilbert, working for DOE contractor Pacific Northwest Labs, who proceeded to issue a series of reports for DOE attacking the Mancuso et al. work. The Mancuso/Gilbert affair was one of the major contributors to the decision by Admiral Watkins, while DOE Secretary, to try to end the practice of DOE contractors performing epidemiological studies of DOE’s nuclear facilities because of the obvious conflicts of interest and troubled history. Dr. Gilbert’s long work on behalf of DOE has frequently asserted no findings of excess cancers or age effects when analyses of the same worker populations by experts such as Dr. Alice Stewart have demonstrated precisely such excesses and age effects. Dr. Gilbert is on the panel but Dr. Stewart, one of the greatest figures in radiation epidemiology, is not, one of the clearest signals of imbalance on the committee.


ELISABETH CARDIS. Dr. Cardis is the lead author of one of the studies most frequently cited by the nuclear industry as supposed support for its claim that low-dose radiation risks are overstated. The pooled study has been widely criticized for combining non-comparable data sets and a number of other methodological problems, including diluting positive findings for particular cancers from one facility with data from facilities with different cancers due to different radiation exposure pathways. However, none of the critics of the Cardis et al. study have been permitted on the panel, while two of her co-authors (Gilbert and Howe) are on it. The IARC study combined data from 7 nuclear facilities in three countries despite the paper by Kneale and Stewart which showed that even Hanford and Oak Ridge data are not compatible. (Kneale & Stewart, "Factors affecting recognition of cancer risks of nuclear workers", Occup & Environ Med 1995,52, 515-523.) Cardis and two co-authors of the study are on the panel, but Kneale and Stewart are not. Furthermore, no scientists who studies have reached contrary conclusions have permitted on the panel. It is hard to see how a panel can be considered balanced when three authors of a single study widely pointed to by the nuclear industry will be judging the implications and validity of their own work as well as that of scientists who have reached contrary conclusions, while the critics of the Cardis et al. study and the experts whose research found strong radiation effects are excluded.

SCOTT DAVIS. Dr. Davis is the lead author of a controversial study of thyroid cancers among downwinders from the DOE Hanford nuclear facility. On 18 February 1999, a number of public interest organizations wrote to the Director of the National Center for Environmental Health at CDC expressing their "profound dismay and objections" to the manner in which Dr. Davis and others had characterized the conclusions of the Hanford Thyroid Disease Study, which they felt went far beyond the actual data. Dr. Davis, despite the limitations of the study and the clear findings of other studies of radioiodine causing thyroid cancer, caused significant consternation when he made statements that appeared to suggest that his study had proven that the massive releases of radioiodine from Hanford had caused no harm. Like the Cardis et al. study, the controversial Davis work has been cited by those attempting to relax radiation standards. Once again, no scientist whose work suggests the opposite conclusion has been permitted on the committee.

RICHARD MONSON. Dr. Monson is another advocate of the premise of dose fractionization causing low dose rates to be considerably less harmful than would be assumed using the LNT model, at least for cancers other than that of breast. He has argued that multiple exposures to "low dose" radiation "is not likely to be greater than currently assumed ... and may well be less for many sites, most notably the lung." See Davis, Boice, Hrubec, and Monson, "Cancer Mortality in a Radiation-exposed Cohort of Massachusetts Tuberculosis Patients," Cancer Research 49, 6130-6136, 1989. No researcher who has found risks greater than currently assumed has been permitted on the panel, and virtually no advocate even of current risk estimates. We have been informed that Dr. Monson has, like others on this panel, served as an expert witness for the defendant side of litigation in at least one case involving radiation exposure; no witnesses on behalf of exposed individuals, to our knowledge, have been permitted on the committee.

Dr. Monson has also been an advocate of using external comparisons of radiation worker mortality to the general public (Standardized Mortality Ratios, or SMRs) to screen for radiation effects in worker populations, despite the well-known problem of the healthy worker effect. Wilkinson and Morgenstern have argued that such an approach could miss radiation effects, showing that cancer effects at Rocky Flats, for example, would have been missed by Monson’s approach. See Wilkinson and Morgenstern, "Should External Comparisons Be Used to Screen Data in Occupational Studies?", Am. J Epi 1994, 139(Supp): S17. Dr. Monson is on the panel, indeed chairs it; Dr. Wilkinson, who has performed seminal studies showing low doses of radiation producing excess cancers at rates substantially above those predicted by official estimates, is not on, nor are others such as Steve Wing, Alice Stewart, or John Gofman.

ROGER COX. Dr. Cox is one more panel member who does not believe radiation risks have in any way been understated by official estimates. He has, for example, attacked the work of Eric Wright, who showed radiation damages DNA in a new and unexpected way. Cox disputes that genomic instability, as demonstrated by Wright, suggests current risk estimates may be too low. Cox is on the committee; Wright, of course, not. The committee’s review of genomic instability issues will be hampered by this imbalance.

ROBERT ULLRICH. Dr. Ullrich was for many years at DOE’s Oak Ridge nuclear laboratory, in charge of its radiation carcinogenesis unit. He is a critic of the linear model, arguing that it overstates risks. He has advocated a particular linear-quadratic model, resulting in lower risks predicted at low doses than would be the case using LNT. See Ullrich and others, "Radiation Carcinogenesis: Time-Dose Relationships", Radiation Research 111, 179-184 (1987). The applicability of Ullrich’s animal research to humans was questioned in BEIR V (see p. 262). If Ullrich is on the BEIR VII committee examining his own work, will the new BEIR committee reach the same conclusion? Advocates of supralinear models indicating low doses are more dangerous than predicted by simple linear extrapolation from high doses, for example, Dr. John Gofman, have been excluded from the panel.

PATRICIA BUFFLER. Dr. Buffler is a perplexing choice for service on a Biological Effects of Ionizing Radiation committee, as she has to our knowledge done little or no work on ionizing radiation. In the area of electromagnetic fields (EMF), however, she has generally taken a position supporting industry and dismissing evidence of potential health effects. She has, we are informed, served as a defense witness in at least one case regarding EMF, defending industry. From 1987 through at least 1994, Dr. Buffler has chaired a committee for the Electric Power Research Institute commissioning EPRI-sponsored studies on whether the electric utilities’ EMF has caused harm. She has been part of some of those studies, and has been a consistent defender of the industry position. Once again, the BEIR committee appointee is on one side of these general radiation and health issues, the industry side. There is no one on the panel who has generally taken the position of affected communities, regarding EMF or ionizing radiation, in these disputes with the industries that are exposing the public.



We have virtually no information about Drs. Dewey, Cleaver, and Rowan. We note, however, that Dr. Rowan’s area of specialty is supposedly "risk communication," a field viewed with great suspicion by the public, as it has more often than not been an effort by government and industry to convince the public that perceived environmental risks are not real hazards. Dr. Rowan has done work in this risk communication area for the Nuclear Regulatory Commission.

One additional note: The NAS staffperson responsible for the BEIR VII process, Evan Douple, has publicly taken the same positions that low-dose radiation is less dangerous than generally thought and at some doses essentially not dangerous at all. He is cited in TIME Magazine (23 June 1997) as saying that radiation is not as harmful as was supposed. "‘Radiation in general is a very ineffective carcinogen,’ he says. Below certain very low levels, it may cause no harm at all." In a 6 January 1998 letter to Dr. Oscar Rosen to Atomic Veterans Radiation News, Douple affirmed these views, saying radiation is "a very ineffective carcinogen," that its effects are less harmful than predicted, and below some low level, no harm would be expected. Given the bias of the NAS staff responsible for the formation of the BEIR committee, the bias in its composition is perhaps to be expected. That makes it no more defensible, however.

We wish to make absolutely clear that we are in no way questioning the integrity or competence of the scientists named to the BEIR panel, nor their right to take the positions they hold. It is not their fault that they were appointed to a panel that does not contain a full spectrum of the positions in the scientific community on these issues. The key point is that the selection process has been skewed, created an unbalanced panel. Authors of studies suggesting risks may be overstated have been named to the panel. Authors of studies suggesting current risk estimates may be understated have been excluded (e.g., Wing and Richardson on Oak Ridge, Stewart and Kneale on Hanford, to name just two such studies). The entire scientific method is designed to assure the ascertainment of truth via the avoidance of bias in investigation. That fundamental principle of science has been breached here, not by the people named to the panel, but by those who named them.

The current committee members, by and large, have pre-judged the issues they are to examine. They have a history of positions on one side of the debate. Indeed, many of the panel members frequently cite the work of each other in their own work for support of their positions. (See, for example, Hoel, "Threshold Models in Radiation Carcinogenesis," citing Kellerer, Mossman, Howe, Cardis, and Gilbert in support of his position that low doses are less dangerous than currently thought.) The remarkable aspect of the BEIR VII committee is that a panel supposedly established to assess issues of significant scientific controversy has been packed with partisans of one side of that debate, to the exclusion of the opposing viewpoint.

We must strongly state that the gross imbalance on the 16-person panel cannot be cured by the appointment of one or two additional members. Even were those to be the strongest representatives of the viewpoint that current risk estimates are too low, the panel would remain dramatically skewed. This would be even more true were the additions to be people that were neutral on the key issues, or in the center of the debate. Given the dramatic bias in the current committee composition towards advocates of relaxing rather than strengthening risk estimates, cosmetic changes would be grossly insufficient to remedy the problem. The Academy should start over again and establish a balanced committee, free of conflict-of-interest, and compliant with law.