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APPENDIX V
WHEN EXPERTS DISAGREE
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.
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.
Environmental Protection Agency:
Attention: The Honorable William D. Ruckelshaus, Administrator Proposed: A Public Radiation Debate 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:
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 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.
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