APPENDIX V
WHEN EXPERTS DISAGREE
WHICH ONES SHALL WE BELIEVE?
It surely falls within human ability to find a way
by which the scientific community, in full public view,
can calmly examine together the evidence, the
assumptions, and the conclusions which form the basis
for assessments of radiation risks.
When the public is asked to accept an officially
approved "acceptable" dose of radiation, the public is
also entitled to know what risks may go with it or with
any fraction of it. This approved dose is now used in
determining emission standards for nuclear power plants,
color television sets, and numerous other facilities and
activities. Further it is used in deciding what the
hazards may be from medical x-rays. If there is
disagreement as to the acceptability of the dose, the
public is entitled to know why.
In the hope of clarifying and perhaps resolving some
disagreement regarding radiation risk-levels, I offer
the following proposal. While details remain to be
worked out, I see advantages to seeking public comment
at this time. I welcome all suggestions.
Mike Gravel, March 1, 1971
U.S. Senate, Washington, D.C. 20510
Editor's note to the reader:
An idea like this does not "get off the ground"
unless people support it. If you do, let your Senators,
Representatives, and the Environmental Protection Agency
hear from you.
Senate address: House of Representatives:
Washington, D.C.
20510 Washington, D.C. 20515
Environmental Protection Agency:
1129 Twentieth St., N.W.
Washington, D.C. 20460
Attention:
The Honorable William D. Ruckelshaus, Administrator
Proposed: A Public Radiation Debate
I. The Proposal.
II. The Need.
I. THE PROPOSAL
The word "debate" must not be interpreted literally.
Proposed is an inquiry on the question:
WHAT MAY BE THE BIOLOGICAL RISK-LEVELS PER MILLION
PEOPLE RECEIVING A WHOLE-BODY DOSE OF NUCLEAR RADIATION
AT THE RATE OF 170 millirems PER YEAR?
In other words, what may be the health consequences
of the presently permissible dose of radiation? Both
somatic and genetic consequences would be considered, as
would be the question of age during the exposure-period
(in utero, childhood, adulthood).
The format would be approximately this:
As a precondition to the entire procedure, the
scientists who are the principal participants or
advocates in the radiation dispute would have to agree
unanimously upon five scientists to be the jury. We
believe this can be done.
Included in the scientific jury, it is hoped, would
be at least one biologist, geneticist, statistician,
public health specialist. Excluded from the scientific
jury would be anyone who has publicly declared a
position in this dispute, anyone who has received
financial support from the Atomic Energy Commission,
anyone who has been a member of professional societies
related to radiation, such as the National Committee on
Radiation Protection (NCRP), American Nuclear Society
(ANS), American College of Radiologists, Health Physics
Society, etc.
During the inquiry, all advocates and all jurors
would be present, and the proceedings would be open to
the public, and fully recorded by a stenographer for
prompt transcription.
Three sessions would be held, each approximately a
month apart.
The first session: The advocates and the jurors
would discuss which information, data, experiments, and
papers they agree to evaluate -- which animal data,
which human data. The jurors would hear and participate
in the arguments, and if there were disagreement, the
jurors would make the final decision.
The second session: The same procedure would be used
to decide what assumptions would be applied to the data
-- assumptions concerning public health protection,
extrapolation, linearity, thresholds,
dose-fractionation, dose-accumulation, cancer latency,
age sensitivity, etc. Perhaps more than one
constellation of assumptions would be decided upon.
Again, the decision of the jurors would prevail in case
of disagreement.
The third session: Each advocate would present his
risk-estimates (with levels-of-confidence specified)
based on applying the agreed assumptions to the agreed
data.
In each session, questions and cross-examination
mutually between the advocates and the jurors would
proceed freely with minimal formality.
The motto would be Linus Pauling's:
"Science is the search for truth -- it is not a
game in which one tries to beat his opponent, to do
harm to others."[1]
After the discussions, the jurors would openly
deliberate and publicly announce their estimates of the
BIOLOGICAL RISK-LEVELS FROM THE PRESENTLY PERMISSIBLE
RADIATION DOSE (170 millirems per year whole-body
exposure). Degrees of uncertainty and areas of ignorance
would be described, and dissent (if any) among the
jurors would be summarized.
* * * *
II. THE NEED
In January of 1970, Dr. John W. Gofman made the
following statement to the Chairman of the Joint
Committee on Atomic Energy:
"We urge you to nominate a jury of eminent persons,
physicists, chemists, biologists, physicians, Nobel
Prize winners or National Academy of Sciences members,
or American Association for the Advancement of Science
members, who have no atomic energy ax to grind. We urge
you to serve as chairman of a debate. Dr. Tamplin and I
will debate each and every facet of the evidence
concerning the serious hazard of Federal Radiation
Council guidelines against the entire Atomic Energy
Commission staff plus anyone they can get from their
19-odd laboratories, singly, serially, or in any
combination."[2]
A month later, Drs. Gofman and Tamplin wrote to
Senator Edmund S. Muskie:
"Dr. Tamplin and I hereby challenge Lauriston Taylor
and the entire National Committee on Radiation
Protection to a complete debate, including every minute
facet of the evidence, before a jury of eminent peers
who have no atomic energy ax to grind, preferably in
public view."[3]
Yet, unfortunately, more than a year has passed
without such a debate.
The question raised by Drs. Gofman and Tamplin is
simple, and it is of supreme importance to current
decisions affecting our health and survival in the
future:
HOW BIG A RISK (in cancer and genetically-related
diseases) MAY BE ASSOCIATED WITH THE PRESENTLY
PERMISSIBLE RADIATION DOSE (or "guidelines")?
The public has not received risk-estimates from the
institutions officially responsible for protecting the
public from radiation hazards: the Federal Radiation
Council (now under the Environmental Protection Agency),
the Atomic Energy Commission (AEC), the National
Committee on Radiation Protection (NCRP), and the
National Academy of Sciences (NAS) Advisory
Committee.[4]
At the NCRP press conference on January 26, 1971,
AEC spokesman, Dr. Victor Bond (who is also a member of
the NCRP) declined to express casualty figures. He
instead stated: "All I can say is that we have
considered exactly the same data as Drs. Gofman and
Tamplin, and we come to different conclusions."
Why do equally qualified experts reach different
conclusions from the same data? When experts disagree,
which ones shall we believe?
These questions arise not only with radiation
effects, but with cigarette smoking, drugs, pesticides,
organic farming, the supersonic airplane, the Alaskan
pipeline, the damming of rivers, the anti-ballistic
missile, the storage of radioactive wastes, the
engineering of nuclear power plants, and many other
questions on which public policies have to be made and
whose economic stakes are enormous. Much is at stake in
addition to public health and business interests; the
lofty ideals of science and democracy are also involved.
There are at least two reasons why Congressional
hearings fail to cope successfully with such
controversies: the hearing format does not require the
experts to confront each other or to clarify the reasons
for their disagreement, and members of Congress do not
have the scientific training to ask all the important
questions.
Expert committees are also often handicapped by
deficiencies. They operate behind closed doors which
exclude the public as well as the rest of the scientific
community. Where conflicts of interest may be present,
their findings lose credibility.[5]
Such hearings and reviews resolve little; the
radiation controversy will simply rage on, unless
findings can be validated in an open inquiry with all
sides participating. Without such a forum, the experts
will continue to roam the country independently making
solo addresses, accusations, and testimonies which are
not subject to critical scrutiny or even to comparison.
When scientific experts reach contradictory
conclusions, there are reasons for the disagreement.
These reasons need to be identified, and that usually
requires:
a. Identification of the prime data which each is
considering and not considering.
b. Identification of the statistical and experimental
methods used by each.
c. Identification of the unspoken scientific premises,
public health principles, and personal values
underlying each expert's position.
A jury of qualified scientists could determine this
information as it relates to the radiation controversy
by questioning the scientists who disagree, and by
listening as the disagreeing scientists question each
other.
There is no reason why this examination process
should be private or secret. The scientists are not the
least shy about advocating their positions publicly;
they can hardly claim shyness about submitting their
positions publicly to the critical scrutiny of
scientific peers. There is no reason, either, for the
deliberations of the scientific jurors to be secret; the
decency of all participants is taken for granted.
FOOTNOTES
1. No More War, by Linus Pauling, New York, Dodd, Mead
& Co, 1958; page 209.
2. "Environmental Effects of Producing Electric
Power," hearings before the Joint Committee on
Atomic Energy, January and February, 1970 Part 2
(Volume 1), page 1390. (See also: Chapter 7)
3. Published in "Underground Uses of Nuclear Energy,"
hearings before the Senate Public Works
Subcommittee on Air and Water Pollution, Nov.
18-20, 1969, Part 1, page 290.
4. When the presently permissible dose was set in 1957
at 170 millirems per year, the following risks were
apparently considered acceptable:
Cancer: According to Dr. William Mills (presently
director of the Division of Biological Effects,
HEW's Bureau of Radiological Health), the NCRP then
estimated that 5 percent-10 percent of all cancers
are caused by natural background radiation (100
millirems per year). This is an estimate also
quoted by Dr. Gofman in a Nevada speech, 1965. The
NRCP has set the permissible dose of man-made
background radiation (which does not count medical
radiation) at 170 millirems average for the
population.
Present U.S. cancer mortality is about 320,000
deaths per year.
Genetic: the NAS Committee on the Biological
Effects of Atomic Radiation (the BEAR Committee)
endorsed the permissible dose, while acknowledging
that the price might be a quarter of a million
extra "defective children" if the parents of one
generation were exposed to it every year (see
Report #3 of the Federal Radiation Council, May
1962. Appendix B). Now, some say that estimate was
much too high, while others say it was a great
underestimate.
5. In January, 1970, HEW Secretary Robert Finch
directed a thorough review to be made of the
permissible radiation dose. Two studies were
undertaken -- one by the NCRP and one by the NAS.
NCRP membership: Total 64.
* About 10 are radiologists.
* About 14 were also members of the BEAR
Committee.
* About 30 receive employment or research grants
from the AEC, the Dept of Defense,
Westinghouse, or General Electric (major
manufacturers of nuclear reactors).
Naturally, there is some overlap in the three
categories.
NAS Radiation Committee membership: Total 20.
Twelve of the twenty are notable as follows:
* 7 are either employed by the AEC or have been
receiving research money from the AEC.
* 8 are concurrently members of the NCRP.
* 10 were also members of the BEAR Committee.