Cataracts: NRC Robbing Americans Blind – Comment Deadline 22 June 2015, 1159 pm NY-DC (ET)

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blindness, cataract surgery, cataracts, dilution, eyesight, health science, ICRP, ionizing radiation, lens, NRC, nuclear energy, nuclear power, radiation, radiation dangers, radiation safety, safety standards, standards, surgery

Vision without cataracts

Vision with cataracts

Images by Marcela, CC-BY-SA-3.0

US NRC Comment Deadline June 22: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0098 (On cataracts and more.)

In “Mayo Clinic. ‘Cataract surgeries on the rise as boomers age, raising access, cost issues.” ScienceDaily, 9 October 2013, we learn that cataracts affect at least 22 million people in the US and cost almost $7 billion to correct each year. Elsewhere you can read that people in their 40s and 50s are now having cataract surgery. In case you don’t know, they don’t just clean-up your eyes, they remove the entire lens and put an artificial one. An artificial one is not yet as good as a real one, may never be, and you will almost certainly need glasses, even if you didn’t before. For those over 65 (and the very poor) the US taxpayer will pick up the tab; for those under 65, the individual or the insurance. Probably the rich can have new lens tissue cloned.

The US NRC has been robbing Americans blind, both literally and figuratively for a long time. After people have been told for decades to wear sunglasses and sun screen to protect against natural and less dangerous UV rays, the international radiation standards body, the ICRP, has just suddenly decided that they have been allowing occupational exposure to ionizing radiation, which is seven and a half times greater than they should – dropping maximum exposure recommendations from 150 mSv per year to 20mSv per year, averaged over 5 years, with no greater than 50 mSv, in any one year.

Even now the ICRP is making assumptions, which may prove false, due to “practical purposes, irrespective of the rate of dose delivery, and future studies may elucidate this judgement further.” In a few years they probably will lower it again. Since detectable lens changes may be at 200 mSv to 500 mSv exposure (ICRP 118, p. 117), if they learn that it is gradual over 40 years, then the number will drop to 5 mSv. They should assume 40 to 100 years, and drop it on down to 2 mSv or less. But, that wouldn’t be “practical” for the medical and nuclear industry. Blind people or cataract surgery is a win-win for both groups at public suffering and expense.

X-rays and Gamma rays are more damaging than UV (Ultraviolet) rays. Alpha are even more damaging.

This change is because the US NRC and the ICRP have strangely just discovered that “The lens of the eye is one of the most radiosensitive tissues in the body (Brown, 1997; Ainsbury et al., 2009)” (cited in ICRP, 118, 2012). How could they only just now figure that out? How dim-witted can they be?

The ICRP is refusing to reduce the amount for the general public on the grounds that it is unlikely that the eyes would get more radiation than the rest of the body. But, obviously, in 1990 (ICRP 60), they had the public eye exposure at 15 mSv and skin at 50 mSv for some reason. Steam from cooling towers or radioactive rain? Nuclear war?

This isn’t the first such reduction in recommended exposure either. In 1977 300 mSv of radiation to the eyes was allowed. In 1991 they dropped it to 150 mSv and now “whoops” they were wrong and it is 20 mSv per year. In other words 15 x more radiation to the eyes was recommended in 1977 compared to 2012.

The fact that they both are continuing to drop “safe” levels of exposure should raise eyebrows and shows that they are not concerned with public health and safety. It shows that either they don’t know what the hell they are doing or don’t want to know.

Why is ICRP now up to document number 118 or greater? This also appears to indicate that they don’t know what they are doing. Additionally, the ICRP mixes medical radiology, including x-rays, with the nuclear industry and they should not be mixed. Medical radiology has worked very hard to minimize dose and develop very short-lived radionuclides. The nuclear industry has not. The nuclear industry legally leaks long-lived radionuclides into the air and water, constantly. [1]

For over half a century, what ICRP 118 calls a “landmark statement“, which “appeared in the 1950 Recommendations“, has been largely ignored: “in view of the unsatisfactory nature of much of the evidence on which our judgments must be based, coupled with the knowledge that certain radiation effects are irreversible and cumulative, it is strongly recommended that every effort be made to reduce exposures to all types of ionizing radiations to the lowest possible level.” (cited in ICRP 118, p. 5)

The NRC and the ICRP have allowed outrageous amounts of exposure to the eyes and skin by ionizing radiation, both for nuclear workers and for the general public. They have allowed 15x (15 mSv) the amount to the eyes and 50x (50 mSv) to the skin, than was previously recommended for the body (1mSv), for the general public. And, they continue to do so.

In 2007, the ICRP said that if there is a prolonged component of exposure from long-lived radionuclides, the yearly exposure for the general public should be 0.1 mSv per year. This is apparently per facility so that it adds up to a maximum of 1 mSv. Insanely they allow 0.3 mSv exposure for nuclear waste. The US NRC wants people to think that it is ten times greater: 1 mSv. This 1 mSv is substantially greater than the US EPA’s current 0.25 mSv (25 mrem). Thus, the NRC appears to be abusing the ICRP to further endanger the public.

The 1 mSv per year leads to approximately one in hundred additional cases of cancers or leukemia over a lifetime. That is if the radiation did not accumulate in the environment. However, it does accumulate, meaning that the risk is higher. (Under Bill Clinton, the NRC appears to have allowed 25 mrem (0.25 mSv) compared to the 100 mrem (1 mSv) allowed today. And, the EPA 10 mrem (0.10 mSv).

The biggest con of all, however, is that the NRC actively encourages the nuclear industry to dilute radionuclides in air and water, by only measuring concentration, i.e. dilution. And even then these concentrations are often in violation of the clean water act.

“When the radiosensitivity of various eye tissues is compared, detectable lens changes are noted at doses between 0.2 and 0.5 Gy,… In recent years, a number of new studies have suggested an elevated risk for cataract development in populations exposed to low doses of ionising radiation below” [formerly] “assumed thresholds.” (ICRP 118, p. 117) 0.2 Gy is 200 mGy; 0.5 Gy is 500 mGy. This is almost certainly gamma or x-ray (low LET radiation) so 0.5 Gy is 0.5 Sv = 500 mSv.

On p. 11, ICRP 118, they clearly state “For occupational exposure in planned exposure situations, the Commission now recommends an equivalent dose limit for the lens of the eye of 20 mSv/ year, averaged over defined periods of 5 years, with no single year exceeding 50 mSv.”

The Gy would have to be less for alpha and neutron irradiation, or the mSv would sky-rocket due to a weighting factor of an estimated 20 x more damage from alpha and gamma per gray. “For X-rays and gamma rays the gray is numerically the same value when expressed as the sievert (Sv), but for alpha particles one gray is equivalent to twenty sieverts because of the radiation weighting factor that is applied.” http://en.wikipedia.org/wiki/Gray_(unit)

Earlier they say that “threshold dose for radiation-induced eye cataracts is now considered to be approximately 0.5 Gy for both acute and fractionated exposures, in line with various recent epidemiological studies” (p. 23). Probably this is from the above info, so that it should be 0.2 to 0.5 Gy, i.e. 200 mSv-500 mSv. Fractionated over 10 years this is their 20 mSv. However, if “fractionated” is over 40 years, then it drops to 5 mSv per year. See ICRP, 118, p. 118 too.

In the Federal Register call for comment, the NRC says: “The ICRP Publication 118 (2012) formalized the new ICRP recommendations for the lens of the eye that are based on the prevention of radiogenic cataracts. For planned occupational exposure situations, the ICRP recommended reducing the limit on equivalent dose for the lens of the eye to 20 mSv (2 rem) per year, averaged over 5 consecutive years (i.e., 100 mSv (10 rem) in 5 years), with no single year exceeding 50 mSv (5 rem), which is significantly lower than ICRP’s previous recommendation of 150 mSv (15 rem) per year in ICRP Publication 60 (1991).” http://www.gpo.gov/fdsys/pkg/FR-2014-07-25/pdf/2014-17252.pdf

The NRC appears to be ignoring new concerns by the ICRP showing the same increased risk to the circulatory system. The ICRP 118, p. 11, dangerously gives 0.5 Gy rather than the 0.5 Sv which they give for the eyes. It is dangerous because if this were High LET neutrons or alpha, it could be deadly.

Then, in their publicly available statement, the ICRP dangerously screws up and writes 0.5 Gy for both eyes and circulatory system: “ICRP Statement on Tissue Reactions / Early and Late Effects of Radiation in Normal Tissues and Organs – Threshold Doses for Tissue Reactions in a Radiation Protection Context ICRP Publication 118, Ann. ICRP 41(1/2), 2012 F.A. Stewart, A.V. Akleyev, M. Hauer-Jensen, J.H. Hendry, N.J. Kleiman, T.J. MacVittie, B.M. Aleman, A.B. Edgar, K. Mabuchi, C.R. Muirhead, R.E. Shore, W.H. Wallace

Abstract – This report provides a review of early and late effects of radiation in normal tissues and organs with respect to radiation protection. It was instigated following a recommendation in Publication 103, and it provides updated estimates of ‘practical’ threshold doses for tissue injury defined at the level of 1% incidence. Estimates are given for morbidity and mortality endpoints in all organ systems following acute, fractionated, or chronic exposure. The organ systems comprise the haematopoietic, immune, reproductive, circulatory, respiratory, musculoskeletal, endocrine, and nervous systems; the digestive and urinary tracts; the skin; and the eye.

Particular attention is paid to circulatory disease and cataracts because of recent evidence of higher incidences of injury than expected after lower doses; hence, threshold doses appear to be lower than previously considered. This is largely because of the increasing incidences with increasing times after exposure. In the context of protection, it is the threshold doses for very long follow-up times that are the most relevant for workers and the public; for example, the atomic bomb survivors with 40–50 years of follow-up. Radiotherapy data generally apply for shorter follow-up times because of competing causes of death in cancer patients, and hence the risks of radiation-induced circulatory disease at those earlier times are lower.

A variety of biological response modifiers have been used to help reduce late reactions in many tissues. These include antioxidants, radical scavengers, inhibitors of apoptosis, anti-inflammatory drugs, angiotensin-converting enzyme inhibitors, growth factors, and cytokines. In many cases, these give dose modification factors of 1.1–1.2, and in a few cases 1.5–2, indicating the potential for increasing threshold doses in known exposure cases. In contrast, there are agents that enhance radiation responses, notably other cytotoxic agents such as antimetabolites, alkylating agents, anti-angiogenic drugs, and antibiotics, as well as genetic and comorbidity factors. Most tissues show a sparing effect of dose fractionation, so that total doses for a given endpoint are higher if the dose is fractionated rather than when given as a single dose. However, for reactions manifesting very late after low total doses, particularly for cataracts and circulatory disease, it appears that the rate of dose delivery does not modify the low incidence. This implies that the injury in these cases and at these low dose levels is caused by single-hit irreparable-type events. For these two tissues, a threshold dose of 0.5 Gy is proposed herein for practical purposes, irrespective of the rate of dose delivery, and future studies may elucidate this judgement further.

ICRP, 2012 ICRP Statement on Tissue Reactions / Early and Late Effects of Radiation in Normal Tissues and Organs – Threshold Doses for Tissue Reactions in a Radiation Protection Context. ICRP Publication 118. Ann. ICRP 41(1/2).” ICRP: CC-BY-SA-3.0 http://www.icrp. org/publication.asp?id=ICRP%20Publication%20118
0.5 gray = 500 milligray = 500 mSv for Low LET xray or gamma radiation. High LET alpha and neutrons are much more damaging per Gray. The weighting factor for alpha and neutrons is 20, so that this would be a 10,000 mSv for alpha or gamma, which would be dangerously high. See original 118 here: http://pbadupws.nrc. gov/docs/ML1326/ML13269A319.pdf

Questions given in the Federal Register for the eyes follow some of the same errors as the ICRP and add more. Their 0.50 Gy should be written 0.5 Gy, because it risks accidentally becoming 50 Gy. Furthermore it needs to be in sieverts, unless it is clearly stated that this is only for Low LET x-rays and gamma. Additionally, the standard is now supposed to be 20 mSv per year average over five years, with no more than 50 mSv in any one year. So, it is NOT in line with the ICRP to say that the new limit is 50 mSv.

Oh, here’s the NRC kicker question for the eyes: “How should the impact of a radiation-induced cataract be viewed in comparison with other potential radiation effects?” What the F(ukushima Daiichi) does that mean? Is it better to be blind or have cancer?

No concern by the NRC about the cost to individuals, family, insurance companies, taxpayer – nope!

A wicked, nasty lot, the NRC. Damage to the brain is another concern mentioned in ICRP 118 which the NRC workers —forgot? Or they became psychopaths – sociopaths from too much radiation to the brain?

“Q2-1: Is closer alignment with or adoption of the ICRP Publication 118 (2012) recommendations regarding the dose limits to the lens of the eye appropriate given the scientific information now available?
Q2-2: How should the impact of a radiation-induced cataract be viewed in comparison with other potential radiation effects? Q2-3: What mechanisms could be applied to keep the cumulative exposure to the lens of the eye below the threshold of 0.50 Gy (50 rad)?
Q2-4: What methods should be allowed for measurement or assessment of the dose to the lens of the eye?
Q2-5: What methods should be allowed for recording dose to the lens of the eye when the eyes are protected?
Q2-6: What are the potential operational impacts of lowering the annual occupational dose to the lens of the eye from the current NRC regulatory standard of 150 mSv (15 rem) to 50 mSv (5 rem)? Would a reduction in the occupational dose limit for the lens of the eye require changes in programs, procedures, practices (e.g., increased use of protective eyewear), or in-room shielding? If so, please describe these changes, including any potential implementation and operational costs.
Q2-7: What are the potential impacts on State regulatory programs of a reduction in the occupational dose limit to the lens of the eye from the current NRC regulatory standard of 150 mSv (15 rem) to 50 mSv (5 rem)?” http://www.gpo.gov/fdsys/pkg/FR-2014-07-25/pdf/2014-17252.pdf

They have other horrid questions like how much they will allow embryos and fetuses to be irradiated. And, if they should consider gender and age in their concentration ratios. This is a ridiculous question, because they are simply diluting in air and water and letting the same amount out! And, if it doesn’t impact those nearby, it will get women and children downriver!

Related posts: https://miningawareness.wordpress.com/2013/12/18/radiation-and-cataracts-in-birds-at-chernobyl/ https://miningawareness.wordpress.com/2013/12/19/radiation-induced-cataracts/

[1] We do not believe that radionuclides are needed in medicine. X-rays have use for broken bones. Nonetheless, medical radiology has held itself to a higher standard and should not be lumped in with the nuclear industry. One does usually have a choice to opt out of x-rays and radio-isotopes, though the better options are not always allowed. There is the problem of people being sent home with short-lived radioisotopes and leaving radiation in their wake and in water systems. But, the nuclear industry and its long-lived waste is forced upon us all for perpetuity.

The links were intentionally broken. Either do a search for the NRC document ( ML13269A319) or repair the broken link. We also broke the ICRP link, because we don’t want direct link throughs or they may remove the ICRP 118 document. Get your copy quickly: ML13269A319