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Briefing Notes: Ionizing Radiation Regulation

By Rosalie Bertell, Ph.D., GNSH
21 September 2000

Nature of the Hazard

Ionizing radiation includes penetrating rays such as gamma and X-ray, and also radioactive elements, which emit alpha or beta particles. It is called «ionizing» because it has sufficient force to knock an electron of a neutral atom out of its orbit, giving it an escape velocity. The resulting chemical (atom or molecule), without its electron, gains a positive charge and is called a positive ion. The electron has a negative charge and is called a negative ion. The radiation is called «ionizing».

Often it is the electron which «holds together» long molecules; dislodging an electron can break the molecule. Ionizing radiation can also directly break chemical bonds in the DNA or other molecules, since these bonds become vulnerable with 6 to 10 eV (electron volts) of force. The usual energy or force exerted by ionizing radiation encountered in medicine or the nuclear industries is in the keV to MeV range. Any complex molecule in living tissue, which is within the range of ionizing radiation, has no defence against its deposit of energy, and must rely at best on some repair of the damage. Internal contamination through inhalation or ingestion of radioactive material is always serious because internal cells are within the range of alpha and beta emissions.

The Cellular Repair System

There is ample evidence that living organisms can repair some cellular damage. It is unlikely that this system is activated by very low stimulants. However, once activated, it becomes increasingly efficient at repair until the hazard damage overcomes the ability to repair. This gives two likely interacting curves, where the resulting damage to the organism is the hazard damage minus the repair ability.

Regulatory History

Medical X-ray was discovered in 1895. The first observed health effects were skin burns, and, by 1912, cancers. Medical Radiologists organized to protect themselves in 1928, by starting an organization, and by setting worker exposure limits of 100 rad per year (in today's terms, this is 1 Sievert, 1000 mSv, per year). After various disasters, this was reduced to 30 rad (300 mSv) per year and then 15 rad (150 mSv) per year. After WW II, the physicists from the Manhattan Project from Canada, US and UK, met to determine standards which would be in effect during nuclear weapon testing, which began in the Pacific in the summer of 1946. The physicists went to the radiologist's organization, proposing the formation of the International Commission on Radiological Protection (ICRP), and jointly they recommended worker exposures be limited to 5 rem (50 mSv) per year for workers and 0.5 rem (5 mSv) per year for members of the public.

This group of thirteen men, which formed the Main Committee of ICRP, has persisted to the present day. They recommend Radiation Protection Standards based on what they consider to be an «acceptable risk-benefit trade off» for the beneficial uses of ionizing radiation (which traditionally meant the production and testing of nuclear weapons). This self-appointed group, is also self-perpetuating, with no outside organization (even the WHO) allowed to place a member on it. The composition of the Main Committee has been about half physicists, one-quarter medical administrators from nuclear nations, 10% radiologists and, 10% smattering of other disciplines, which use radioactive materials. They are the users of radiation. Occupational health specialists, oncologists, epidemiologists, public health specialists, paediatricians, etc. have never been included on the Main Committee (and are excluded by their by-laws).

Regulatory and Enforcement Agencies: ICRP

recommendations are internationally implemented through the International Atomic Energy Agency (IAEA), established by the United Nations in 1957, after the «successful» explosion of the hydrogen bomb. The IAEA mandate is to prevent horizontal proliferation of nuclear weapons and promote peaceful nuclear technologies.

The IAEA has MoU's with both the WHO and the ILO, giving it the lead in radiation health. For example, it is the IAEA, not WHO, which claimed that there were only minimal health effects due to the Chernobyl radiological disaster. WHO prepared a Chernobyl report in 1996 to try to counteract the IAEA report, but has not had sufficient funds to publish it.

Canada makes full use of the ICRP recommendations and echoes the IAEA assurances and promotional materials relative to nuclear industries.

Canadian Nuclear Industries

The Canadian regulatory guidelines for exposure to ionizing radiation are taken directly from the ICRP recommendations, with a ten to fifteen year lag time for implementation. However, in Canada, the «risk- benefit trade- off» nature of these regulations is not recognized, and standards are usually considered to be a safety limit below which there will be no damage to human or environmental health.

Workers have difficulty making a claim for compensation unless they have been «significantly over exposed». The public complaints about contamination of their food or drinking water are met with the answer that «the contamination is well within permissible levels». Risk-benefits trade off do not protect against health damage or fatalities, they merely regulate the «acceptance» of such damage as necessary for the benefits of the use of this hazardous material.

Complaints and compensation claims are deserving of consideration on their merit even when the pollution is «within permissible levels». If a construction worker obeys all safety regulations and then falls to his death, it would be considered scandalous to dismiss the death as not being eligible for compensation because no regulations were broken! The same should be true for radiation workers.

Another Gage for Radiation Standards

The radiation protection standards are based on preventing either of two fatal outcomes of exposure, namely, a direct fatality due to a lethal dose, on a fatal cancer attributable to a non-lethal dose. Even if this concept is accepted, current 1990 recommendations just implemented in Canada, would permit 50 fatal cancers per year per million people exposed at the regulatory limits. Traditionally a «Safe Industry» is one that causes no more than one fatality in the general public per year. The estimate of fifty, rather than one, is based on nuclear industry risk factors. My research indicates these to be too low by at least a factor of four, yielding 200 fatal cancers per year just for cancer deaths.

In many places chemical industries are held to a stricter standard namely, they should not cause more than one cancer (whether fatal or not fatal) with the exposure over a seventy year lifetime for a million people. Radiation standards using nuclear industry estimates would allow about 5000 such cancers over a lifetime of exposure in the legally exposed population. Citizens who object to such a risk would not be heard or recognized as reasonable by the legitimate Canadian authorities.

The Department of Health of the State of Minnesota decided to treat radiation pollution in an even-handed way, comparable to their treatment of chemical pollution. With respect to exposure of the public from radioactive waste, the permissible exposure was, by federal law, 500 mrem (5 mSv) per year, the same as in Canada prior to year 2000. Minnesota required that radiation waste site expose the public to no mare than 0.05 mrem (0.0005 mSv) per year. In Canada the current guideline is 1 mSv (100 mrem) per year. This would need to be reduced by a factor of 2000 to match the regulations in Minnesota. That is a very large error, and I would say (introducing the factor of four errors) it is really an error of 8000 times.


Radiation Protection Standards, and any other standards for hazardous exposures, which are set on a «risk- benefit trade -off» should require clear notification to workers, the public and the courts, that damage to health may occur with exposures below the recommended guidelines. In other words, such regulations need to be clearly distinguished from safety standards below which no harm is expected to occur.

The public needs some decision-making power with respect to companies that emit ionizing radiation into residential areas. A compulsory buffer zone around the facility should be mandated, with special protection of the air and watersheds. Children, our most precious and vulnerable population, are «at home» and «at risk» for 24 hours a day. This protection is necessary even when the facility is complying with all regulations.

Canada should seriously consider setting more stringent radiation protection standards than are recommended internationally, especially given the current admission in the US of the many worker health problems which were denied and covered up by the government in view of the cold war nuclear arms race.

In the next few weeks the U.S. Congress will decide on compensation for the nuclear weapon workers sacrificed during the Cold War. The program is estimated to cost $3.9 billion over ten years. The same radiation regulations govern the weapons and commercial nuclear industry, and they are also used for hospital and X-ray unit workers. The victims of these over-permissive exposure laws are now in the billions.

Who are the Real Victims of this Polluting Industry?

The acute radiation victims, especially of Hiroshima and Nagasaki stand out in history as those most victimised. Next come the millions who have suffered radiation induced fatal cancers:

Casualties of the Nuclear Age

in Million

Source Fatal
 while in 
Nuclear Weapon Testing 240.00 117.00 223.00 558.00 1138.0
Nuclear Weapon Production






Military Nuclear Accidents 243.00 120.00 227.00 566.00 1156.0
Subtotal Military 484.00 237.00 451.00 1125.00 2297.0
Nuclear Power Production






Medical Production and Use 0.84 0.42 0.78 1.96 4.0
Civilian accidents 3.16 1.55 2.94 7.35 15.0
Subtotal Civilian 8.40 4.17 7.82 19.61 40.0
Grand Total 492.00 241.00 459.00 1145.00 2336.0

There are another 241 million non-fatal cancers, 459 million genetically damaged live born children, and 1145 million live born children seriously damaged in utero. This makes the total estimates of nuclear victims about 2.33 BILLION.

Radiation protection risk estimates are ordinarily limited to those for fatal cancers, and even these risk estimates are too low by about four times. I added in the non-fatal cancers, except for non-melanoma skin cancers that are normally treatable. I am not counting the other chronic diseases caused by damage to DNA and the body's immune competence, such as the autoimmune diseases. I also added the damage to embryo's and foetuses exposed in utero. This damage, although well known, is not normally admitted by the nuclear estimates since the unborn are not yet under civil protection (they are the concern of the Mother, not society). In utero damage can result in a mentally retarded child, one with epilepsy, blindness or deafness, damage to long bones or other less severe problems. This is not considered genetic damage since it is not passed on to offspring of the damaged child.

My estimate of victims is very conservative. I did not include the factor of four increase in cancers, which I consider appropriate. I also did not include those embryos or fetuses, which are so damaged that they are spontaneously miscarried or still born. If these tragedies, together with all secondary damage, for example the well know property of radiation to promote cancers induced by other factors, such as smoking, the number of victims would far exceed the 2.33 Billion estimates.

It is time that physicists and engineers are restricted to measuring the radiation and estimating the impact in living tissue. They should however, be restricted from going beyond their competence and attempting to estimate damage to human and environmental health. This needs to become, as it should have been from the beginning, the prerogative of health professionals. It will require time to make this change in policy since the physicists are well entrenched in this (and only this) area of health. This is a global problem, in which Canada could play a significant leading role since it is the only one of the original nuclear nations not to commit to developing, building and testing nuclear weapons.


Victim estimates are based on ICRP risk factors, except where noted, and UNSCEAR data of exposure.

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