October 24, 1999

Dr. Evan Douple

Board on Radiation Effects Research

National Research Council

National Academy of Sciences

Dear Dr. Douple:

We appreciate the opportunity to comment on your latest revisions to the BEIR VII committee.

BEIR VII was established to review the full range of evidence and viewpoints in the scientific community on the issue of risks from low-dose ionizing radiation. The scientific community is deeply divided on this issue. There are three basic positions taken, with variations within each:

VIEWPOINT 1. Some believe risk is strictly linear (risk is directly proportional to dose). This is called the Linear No-Threshold (LNT)model.

VIEWPOINT 2. Some believe it is supra-linear (risks at lower doses are higher per unit dose than if one extrapolated linearly from, for example, the higher doses experienced by the A-bomb survivor data).

VIEWPOINT 3. Some believe it is sub-linear [risks at lower doses are lower per unit dose than if one extrapolated linearly from the higher A-bomb survivor doses; e.g., the dose-response curve is a risk-reducing form of linear quadratic, or risk is reduced from the linear by a low dose and dose-rate effectiveness factor (DDREF)].

Within the third viewpoint is a range of views as to how much less the risk purportedly may be at low doses. Some accept a DDREF of 2; some believe it should be larger. A few, at the very far extreme, believe there is a threshold below which no risk whatsoever occurs. And the farthest reach of the debate believes that low doses are in fact good for you (hormesis).

Within the second viewpoint is also a range of views as to why a linear extrapolation from the atomic bomb survivor and atomic worker data may understate radiation risks. Among these are: the "healthy survivor" effect at Hiroshima and Nagasaki; the "healthy worker" effect in occupational studies; reduced cell killing at lower doses, allowing more damaged cells to survive and reproduce, causing cancers; and insufficient lag time having elapsed for all induced cancers to fully appear.

The BEIR VII panel was established to review the evidence on all sides of the LNT question. However, you have assembled a panel that has produced an outcry of criticism for being grossly one-sided. Of the three basic approaches to be examined (LNT, supra-linear, sub-linear) only scientists whose work is consistent with the last position were permitted on the panel (of those who have taken a stance on LNT regarding ionizing radiation). Indeed, the panel is heavily loaded with people from the more extreme wing of even the sub-linear viewpoint. Many, if not most, of the committee members who have taken a position, are of the view that even sub-linear risk estimates using the currently-used DDREF of 2 may significantly overstate risks at low doses.

In short, the panel, which is to look at all three major viewpoints described above, was restricted to members whose work supports only one of those three views, the least protective of public health and most favorable to nuclear agency and industry interests desiring relaxed regulation. And even within that one view, the panel is heavily dominated by whose work is often cited by those who advocate relaxation

of regulations. Furthermore, significant numbers of the panel members had and continue to have conflicts-of-interest, ties to agencies and industries that would benefit from relaxed risk estimates and the relaxed regulations that follow therefrom.

The criticisms of the panel composition and apparent violations of the Federal Advisory Committee Act (FACA) resulted in two rounds of changes to the panel. In the first round, you removed Dr. Mossman, a former President of an industry group pushing hard for relaxed radiation standards, and replaced him with Dr. Moeller, with similar ties to nuclear agencies and industries and holding similar viewpoints that current risk estimates overstate risks and cost industry and agencies too much. You also added four others that did nothing to rectify the overall imbalance on the panel, because none of them are experts in radiation who come from the perspectives of Viewpoints 1 or 2 identified above (strict LNT or supra-linearity).

The second round of changes to the panel involved dropping four more individuals -- Drs. Howe, Hoel, Whipple, and Moeller. However, you have still added no one who supports either Viewpoint 1 or 2 above. Not even one of the significant scientists whose view is that current risk estimates understate true hazards from low dose radiation has been added -- not even a single token representative of this view. We continue to call for even balance. The imbalance remains precisely as it had been before. Reducing a committee of 20 that has no one from the other side or the middle of the debate, to a committee of 16 that still has nobody from the other side or middle of the debate cures nothing in terms of the fundamental violation of balance requirements.

The sole new addition to the panel is Dr. Daniel Krewski. His is a puzzling addition, as he is a long-time regulator for Health Canada, the Canadian regulatory agency. To the extent he has dealt with ionizing radiation, his views appear squarely in line with those scientists already on the committee. His addition does nothing to remedy the extreme imbalance on the panel.

Dr. Krewski has asserted that LNT may overstate risks. He has taken the stance that the linear no-threshold model should not be used for estimating risks at low doses, consistent with the controversial position put forward by the Health Physics Society. He has proposed abandoning LNT even for regulatory purposes and replacing it with "benchmark doses" modified by uncertainty factors. He currently serves on the Board of BELLE, the primary hormesis organization, and has made a number of statements over the years sympathetic to hormesis positions, although his precise position isn't entirely clear from the literature available to us. He has opposed efforts to bring radiation standards (which are several orders of magnitude more lax than chemical standards) into conformance with the stricter limits set for all other carcinogens. He served on a previous National Research Council panel funded in part by industry that trivialized risks from pesticides in food, a conclusion trumpeted by the pesticide industry. A more detailed analysis of Dr. Krewski, with citations, is attached.

In summary, Dr. Krewski appears firmly in the set of views already heavily represented on the BEIR VII panel. His addition adds to the imbalance and does nothing to rectify it. None of the scientists whose position is that current risk estimates understate true risks from low dose radiation has been included on the panel. Just as it was at the beginning of this process so it is today: not a single radiation expert who supports the strict LNT model nor any who believe that the true shape of the curve is supra-linear have been permitted on the panel. The violations of the Federal Advisory Committee Act (FACA) remain unabated.

We remain troubled by the failure to release the panel members' curricula vitae and Conflict-of Interest forms. The imbalance in the committee remains absolutely uncorrected. Conflicts-of-interest remain.

We renew our request that the panel be disbanded and a new, balanced panel, free of conflicts-of-interest, be established that fully complies with the requirements of law and fundamental principles of neutral, disinterested scientific inquiry.

Sincerely,