Article: 974 of sgi.talk.ratical From: (dave "who can do? ratmandu!" ratcliffe) Subject: WWC: Critique of ICRP structure and membership by Dr. Rosalie Bertell Summary: govn'ts collaborate thru orgs like ICRP to standardize their "stories" Keywords: ICRP, UNSCEAR, BEIR, DOE, AEC->{ERDA,NRC}->{DOE,NRC}, MIT, UC Organization: Silicon Graphics, Inc. Date: Mon, 8 Feb 1993 15:53:24 GMT Lines: 709 The nuclear establishment is an international network where all industrial governments "who can play" are mutually involved in and connected with thru agencies like the International Commission on Radiological Protection (ICRP), the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), and the U.S. National Academy of Science committee on the Biological Effects of Ionizing Radiation (BEIR). These organizations are the ones that decide what is a "safe" level of exposure by humans (and hence, to ALL life on Mother Earth) to radioactive materials. Their purpose is to legitimize the practice and continuing development of nuclear technology. They do NOT exist to guarantee the health and well-being of all corporeal life here on Mother Earth. Simply put, national governments collaborate through organizations like ICRP, UNSCEAR and BEIR to standardize their "story" relative to the health trade offs (risks) of their nuclear activities (benefits). First below are excerpts from the complete Critique of ICRP structure and membership by Dr. Rosalie Bertell: This image of [the ICRP being] a balanced scientific team chosen from various relevant disciplines by a medical organization, free from government involvement and political pressures has proven to be a myth. . . . A complete list of the members responsible for the ICRP Document #2 [1959], Standard Setting for Internal Radiation Doses, indicates quite clearly that they were chosen with respect to their employment by their respective governments. They were all involved in the research and development of nuclear energy and/or national regulatory agencies. They do not represent a broad spectrum of scientific disciplines and they cannot be said to have maintained structural independence from governmental influence. Many members were also involved in their nation's nuclear weapon development and testing programs. . . In the three key regulatory documents the decision-makers were primarily physicists, involved in national atomic energy development, and medical administrators, working for their respective governments. Clearly when practically all members are in the pay of their respective governments, ICRP cannot claim to be free of all bias, conflict of interest or government pressure. ICRP has little or no claim to breadth of expertise on which it can call for balanced decision making, especially when dealing with the delicate questions of occupational and public health. In fact, persons from these disciplines have been excluded from membership since its conception in 1950. Membership in ICRP appears to be made on the basis of occupational affiliation with national nuclear research (military or commercial) and regulatory agencies. It clearly provides a forum for dialogue on nuclear policies and standards among nations with a clear governmental commitment to nuclear technology. Said more simply, national governments collaborate through ICRP to standardize their "story" relative to the health trade off (risks) of their nuclear activities (benefits). . . . Both ICRP and UNSCEAR undertake a review of already published peer reviewed scientific research, accepting or rejecting it on the basis of its regulatory usefulness. ICRP makes the definite choice of research acceptable for calculating risk/benefit trade-offs. As they have no members with training in public health, occupational health, epidemiology, or biometry, their judgement cannot be assumed to be based in objective science. . . . . . . Until publicly forced to do so, these agencies have taken little or no responsibility for the human consequences and suffering caused by these misguided human experiments. . . . The delegates to ICRP, UNSCEAR and BEIR chosen by their respective governments have both personal and national compelling reason for perpetuating their closed structure and secrecy. It is critical to understand the organizing rules governing membership in international nuclear "regulatory" organizations like ICRP and UNSCEAR include the absence of independent occupational health, public health and epidemoiology or toxicology professionals as well as the fact that the rules governing the selection and work of these commissions are defined to be self-perpetuating and extremely restrictive as far as inclusion of a wide range of scientists with varying backgrounds. In other words, if potential candidates aren't already associated in some way with official agencies in government, the military, or the nuclear industry, they are effectively excluded from participation in international official "guideline-setting" agencies like the ICRP. This has been a very effective way of censoring differing interpretations of research and studys conducted by independent scientists into the long-term effects of low-level ionizing radiation on celluar life. -- ratitor Document # 10 of Part II--The Ravages Of Preparation For War Have Been Hidden By Governments, Especially By The United States, Great Britain, The Soviet Union, France And China, And Most Victims Of This War-Making Pollution Have Been Allowed To Suffer And Die Without Either Assistance Or Compensation--of Dr. Rosalie Bertell's Testimony prepared for the World Women's Congress For A Healthy Planet held in Miami, Florida, November 8-12, 1991: _____________________________________________________________________________ RADIATION PROTECTION STANDARDS: ORIGIN OF THE STANDARDS The Atomic Energy Control Board (AECB) issues the regulations for worker and general public exposure to ionizing radiation from human activities (uranium related and/or nuclear fission related) in Canada. AECB also issues operating licenses for each industry setting maximum limits for releases of radioactivity into air or water. At all Federal or Provincial Hearings or Royal Commissions, AECB appeals to international groups such as the International Commission on Radiological Protection (ICRP), the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), and the U.S. National Academy of Science committee on the Biological Effects of Ionizing Radiation (BEIR) as a support for radiation protection standards in Canada. This brief examines the rationale and also the results of such dependence. RATIONALE FOR DEPENDENCE ON ICRP AND UNSCEAR: Canadian dependence on ICRP and UNSCEAR was clearly expressed by Chairperson Arthur Porter of the Royal Commission on Electric Power Planning in Ontario: "The Board (AECB) relies heavily on the recommendations of international agencies and committees. Two of the most important of which are the ICRP and UNSCEAR." This is rather typical of other Canadian Commissions and Hearings. This dependency was also clearly expressed in the 1983 document from AECB proposing to change Canadian radiation protection standards for workers in an attempt to implement in Canada the recommendations of ICRP Publication #26 (1977). This dependence remains the official Canadian position on Radiological Safety and was clearly expressed in both Ontario Hydro and Atomic Energy of Canada Ltd. briefs to the Ontario Nuclear Safety Review. The current pamphlet being distributed by Ontario Hydro: "Powerful Facts about Radiation" (undated, no author mentioned) states: "Three international scientific bodies (ICRP, UNSCEAR and BEIR) who periodically review all the relevant information on (low level radiation) have concluded that the linear theory is conservative - that half of a particular dose (of ionizing radiation) probably has less than half the risk." The public image of ICRP is again clearly stated by the Royal Commission report by Dr. Arthur Porter: "The ICRP consists of a group of twelve scientists -- biologists, physicists, geneticists, biophysicists, biochemists and radiologists -- who are selected by the International Congress of Radiology on the basis of their scientific reputation." This image of a balanced scientific team chosen from various relevant disciplines by a medical organization, free from government involvement and political pressures has proven to be a myth. MEMBERSHIP: Membership in ICRP is by recommendation of present members of ICRP or the International Congress of Radiology (ICR). Approval of the ICR executive committee was required in the early stages (1950 to 1977) of ICRP. Election of members is now by ICRP itself, subject to approval by the Executive Committee of ICR, which appears fairly automatic. In looking for verification of the balance in membership with respect to scientific specialty, IICPH has ascertained the following: 1. Between 1950 and 1985 there were 45 members of ICRP, serving between 4 and 24 year terms, for a total of 569 years of service. 2. With respect to years of professional service as a member of ICRP, the contributing expertise divides as follows: BIOLOGIST: 1 radiobiologist 2.5% of the time (14 years) PHYSICISTS: 16, 45.5% of the time (259 years totally: average 16 years each) GENETICISTS: 3, 6.0% of the time (34 years totally: averaging 11 years each) BIOPHYSICIST: 1, 1.4% of the time (8 years) BIOCHEMISTS: None RADIOLOGISTS: 12, 14.9% of the time (85 years totally: averaging 7 years each) MEDICAL SPECIALIST: 1, 3.9% of the time (22 years) MEDICAL ADMINISTRATORS: 11, 25.8% of the time (147 years totally: averaging 13 years each) The dominant expertise among ICRP membership between 1950 and 1985 was physicists, with one biophysicist (46.9% of the person years). The second highest input was from physician administrators, including the single specialist, (29.7% of the person years). These two categories account for 77% of the membership years. The category physician administrator was not mentioned in the Porter Commission report. 3. Some very relevant areas of scientific expertise failed to gain any representation on ICRP, namely: radiation epidemiology (or any epidemiology), public health, occupational health, biometry, biochemistry and pediatrics. ICRP has never even listed most of these specialties as desirable. Since there was apparently no effort to balance membership of ICRP on the basis of scientific or medical expertise, an examination on the basis of national affiliation and an examination on the basis of employment was undertaken, with a special focus on the years in which important regulatory documents: ICRP #2, #9 and #26 were issued. 4. It is also noteworthy that the 12 member committees plus Chairpersons who have made up the 37 year history of ICRP have never contained a woman. MEMBERSHIP IN ICRP 1956 - 1959 -- ICRP DOCUMENT #2 (1959): The committee which drafted the Document recommending limits for internal radionuclide levels (via inhalation, ingestion or absorbtion) consisted of: 3 Americans, 2 British, 2 West Germans, and one each from Sweden, France, Denmark and Canada. There were 8 physicists, one Medical Doctor from France's Scientific Counsel for Atomic Energy, one Medical Doctor from the University of Toronto who also served on the U.S. Atomic Bomb Testing Project between 1952 and 1960. A complete list of the members responsible for the ICRP Document #2, Standard Setting for Internal Radiation Doses, indicates quite clearly that they were chosen with respect to their employment by their respective governments. They were all involved in the research and development of nuclear energy and/or national regulatory agencies. They do not represent a broad spectrum of scientific disciplines and they cannot be said to have maintained structural independence from governmental influence. Many members were also involved in their nation's nuclear weapon development and testing programs. RESPONSIBLE FOR ICRP DOCUMENT #2 (1959) ON STANDARD FOR INTERNAL DOSES OF IONIZING RADIATION: L. BUGNARD: 1956: Member, Conseil Scientifique du Commissariat a la Energy Atomique, France 1956 - 1965; Vice-President, Comite de Biologie Commissariat a l'Energie Atomique. 1956 - 1965: Member Scientific and Technical Committee EURATOM. L.S. TAYLOR: 1948 - 1961: Organized and headed the Biophysics Section in the Division of Biology and Medicine of the U.S. Atomic Energy Commission during above ground nuclear bomb testing (1946 - 1963). He was trained as a physicist. W. BINKS: 1953 - 1963: Secretary of the U.K. Medical Research Council Committee on Protection against Ionizing Radiations. He was trained as a physicist. J.C. JACOBSEN: 1956 - 1958: Research Director, Atomic Energy Research Station, Risoe, Denmark. 1958 - 1969: Consultant to Danish Atomic Energy Agency. He was trained as a physicist. E.A. WATKINSON: 1959: Principal Medical Officer, University of Toronto; also Department of Environmental Health and Special Projects, Health and Welfare, Canada. He was a physician. R.G. JAEGER: 1950 - 1962: Chairperson Committee III Protection against Xrays and electrons up to energies 3 MeV and beta and gamma from sealed sources; 1960: International Atomic Energy Agency. He was a West German physicist. W.V. MAYNEORD: 1947 - 1962: U.K. Medical Research Council committee on Medical and Biological Applications ____ ___ ________ _____ ___ _ ________ ___ __________ G. FAILLA: 1946 - 1960: Consultant to U.S. National Council on Radiation Protection and Measurements. Physicist, Director of the radiological research laboratory at Columbia University (died 1961). R.M. SIEVERT: 1941: Professor of Radiophysics, Karolinska Institute, Stockholm; Co-founder of International Xray and Radium Protection Committee (1928) and of ICRP (1950); Swedish delegate to UNSCEAR 1960. He was trained as a physicist. H. HOLTHUSEN: 1937 - 1960: Physicist, Member of International Commission on Radiation Units; 1960: Member of West German Atomic Energy Commission. K.Z. MORGAN: 1934 - 1943: Member of the Research Staff, Atomic Bomb Project, University of Chicago; 1953 - 1959: Chairperson of committee II (Internal Doses) of ICRP - Responsible for ICRP Document #2; 1943 - 1972: Director of Health Physics Division, Oak Ridge National Nuclear Laboratory, U.S. Atomic Energy Agency. He was a physicist. R.S. STONE: 1952 - 1960: Project Director for Health, U.S. Atomic Bomb testing; Member of the Executive Committee of the U.S. National Commission on Radiological Protection. He was trained as a radiologist. MEMBERSHIP IN ICRP 1962 - 1966: ICRP DOCUMENT #9: Membership consisted of: 4 Americans, 2 British, 2 Swedish, 2 French, 1 Canadian and 1 from West Germany. With respect to scientific expertise, there were: 6 physicists, 3 medical doctors (from the French Atomic Energy Agency; AECL's Chalk River Research Laboratory and the National Radiological Protection Board in Britain), 1 radiologist from the U.S. Atomic Bomb Project, 1 geneticist and 1 radiobiologist. Document #9, was adopted by ICRP in 1965 and published in 1966. It was intended as a review and revision of previous publications, aimed at reducing the need to refer to those documents. It recommended a system of maximum permissible doses for occupational exposure and dose limits for the general public. These exposures are over and above all natural background and medical exposures (which are unlimited). It derived dose limits for various body organs: gonads, red bone marrow, skin, thyroid, head, forearms, feet and ankles, as well as the traditional whole body limits of 5 rem per year for workers and 0.5 rem per year for the general public. Membership in ICRP 1962 - 65 was still apparently based on employment position in one's country. MEMBERS OF THE ICRP 1962 - 1965: RESPONSIBLE FOR ICRP DOCUMENT #9, DOSES TO BODY ORGANS: Many of the members responsible for the ICRP #9 were also on the ICRP #2 committee, so their affiliations will not be repeated. These members were: L. Bugnard; L. S. Taylor; W. Binks; R. M. Sievert; K.Z. Morgan and R.S. Stone. New members were: O. HUG: 1958 - 1959: Senior Officer and West German delegate to the International Atomic Energy Agency; 1959 on, Director, Institute of Radiobiology, Munich University; 1959 - 1973: Member of ICRP. H.P. JAMMET: French physicist, member of the Commission Nationale de Protection Radiologique; 1950 - 1960: Chef du Service d'Hygiene Atomique et de Radiopathologie and Chef du Service des Radio - Isotopes a l'Hopital Curie. B.G. LINDELL: Physicist, Director National Institute of Radiation Protection, Stockholm; 1957 - 1958: Secretary of UNSCEAR; Swedish delegate to UNSCEAR 1969 - 1985. Sir E. POCHIN: 1957 - 1974: Chairperson of the U.K. Medical Research Council Committee on Protection against Ionizing Radiation; Member of the U.K. Atomic Energy Agency coordinating committee for radiobiological research; U.K. representative to UNSCEAR. J.F. LOVTIT: 1947 - 1975: Director of the U.K. Medical Research Council Radiobiological Research Unit, Atomic Energy Research Establishment, Harwell. (after 1953 this was under the U.K. Atomic Energy Authority); was on the circulation committee for classified documents from the British Atomic Bomb Testing Program in Australia. He was trained in genetics. C.G. STEWART: 1955 - present: Medical doctor, director of the Medical Division, Chalk River Nuclear laboratories, Atomic Energy of Canada Ltd. H.J. MULLER: 1946 - 1964: Member of U.S. National Commission on Radiological Protection; 1953 - 1964: Professor of Genetics, Indiana University. MEMBERSHIP IN ICRP 1973 - 1977: ICRP DOCUMENT #26 (1977): Membership in the ICRP Committee responsible for Document # 26 consisted of: 1 American, 4 British, 1 Swedish, 1 French, 2 Canadian, 1 Soviet, 1 Argentinean, 1 Japanese and 1 Polish representative. There were only 3 physicists on this Committee and 6 M.D. administrators who worked in government nuclear research or regulatory establishments. There were 3 radiologists and one geneticist from Chalk River. Document #26 was designed to replace ICRP Document #9. It included a new system of dose limitations replacing the "critical organ concept" and attempting to set "equal risks" whether a whole body or partial body exposure was received. These new recommendations had the effect of allowing increases in radiation doses to several body organs including thyroid gland and bone marrow. The ICRP membership 1973 - 77 shows a slight shift of membership selection by employment in that 3 members, 23%, received government positions after rather than before membership. Little information is available on these members, therefore this may be a false perception. Since ICRP is self-perpetuating the possibility of newer members being students of older members needs to be researched. This was beyond the scope of this brief. MEMBERSHIP OF ICRP - RESPONSIBLE FOR DOCUMENT #26 ON EFFECTIVE DOSE EQUIVALENCE: Members of ICRP 1973 - 1977: included some members from the 1962 - 1965 Committee responsible for Document #9. These were: H.P. Jammet, B.G. Lindell, Sir E. Pochin and C.G. Stewart. New commission members were: I. TASKAHASHI: Radiologist from Japan's Aichi Cancer Center; 1977: Member of the Japanese Government's Science and Technical Agency. Y.I. MOSKALEV: Radiologist at the Institute of Biophysics, Moscow; 1977: Vice-Chairman of the Soviet National Commission of Radiological protection. J. LINIECKI: 1973 - 1985: member of ICRP; 1977 Chief, Division of Nuclear Medicine and Radiobiology, Medical Research Center, Lodz, Poland; 1977 - 1982 Consultant to UNSCEAR. A.C. UPTON: 1967 - 1977: Attending Pathologist, Medical Department, Brookhaven National Nuclear Laboratory, U.S. Atomic Energy Commission; 1954-1969 Pathologist, Biology Division, Oak Ridge National Nuclear Laboratory, U.S. Atomic Energy Commission. H.B. NEWCOMBE: 1947 - 1983: Head of Biology and Physics Division, Atomic Energy of Canada Ltd., Chalk River Nuclear Laboratories. He was trained as a geneticist. J. VENNART: 1956 - 1971: Physicist; Radiological Protection Service U.K. Medical Research Council and U.K. Atomic Energy Authority; 1971 - 1983: Director, Radiobiology Unit, Harwell. D.J. BENINSON: 1969 - present: Medical doctor with the Argentinean National Commission of Atomic Energy; 1974 - Director Radiological Protection, Argentine Atomic Energy Commission; 1969 - 1984: Argentine delegate to UNSCEAR. SIR B. WINDEYER: 1970 - 1978: Member U.K. National Radiological Protection Board (Chairperson 1977); Radiologist, Director of Radiotherapy Mt. Vernon Hospital (1940 - 1946) and Middlesex Hospital (1942 - 1969). 1967-1972: Vice-Chancellor, Univ. of London. In the three key regulatory documents the decision-makers were primarily physicists, involved in national atomic energy development, and medical administrators, working for their respective governments. Clearly when practically all members are in the pay of their respective governments, ICRP cannot claim to be free of all bias, conflict of interest or government pressure. ICRP has little or no claim to breadth of expertise on which it can call for balanced decision making, especially when dealing with the delicate questions of occupational and public health. In fact, persons from these disciplines have been excluded from membership since its conception in 1950. Membership in ICRP appears to be made on the basis of occupational affiliation with national nuclear research (military or commercial) and regulatory agencies. It clearly provides a forum for dialogue on nuclear policies and standards among nations with a clear governmental commitment to nuclear technology. Said more simply, national governments collaborate through ICRP to standardize their "story" relative to the health trade off (risks) of their nuclear activities (benefits). CURRENT ICRP MEMBERSHIP: 1985 - 1989: D. BENISON (Argentina) - Chairman ICRP; Chairperson for Radiation Protection, Argentine Atomic Energy Commission. H. JAMMET (France) - Vice Chairman ICRP; Director and Chief, Radiological Protection Department, Commissariat a l'Energie Atomique, France. R.J. BERRY (U.K.) 1974 - 1976: Medical Research Council Radiobiological Unit, Harwell; 1982: U.K. National Radiobiological Protection Board. H.J. DUNSTER (U.K.) - U.K. Atomic Energy Authority; National Radiation Protection Board, Harwell. W. JACOBI (F.R.G) - Head, West German National Institute for Radiation Protection and Research. D.P. LI (P.R.C.) - Director, Institute of Radiation Protection MNI, Taiyuan, Shanxi, People's Republic of China. J. LINIECKI (Poland) - Chief, Division of Nuclear Medicine and Radiobiology, Medical Research Center, Lodz, Poland. C.B. MEINHOLD (U.S.) - Head and Senior Health Physicist, Brookhaven National Nuclear Lab. U.S. Atomic Energy Agency, now U.S. Department of Energy. A.K. POZNANSKI (U.S.) - Member of U.S. National Commission on Radiological Protection; Pediatric Radiology, Children's Memorial Hospital, Chicago. R.B. RAMZAEV (U.S.S.R.) - Department of Pathological Anatomy and Laboratory of Electron Microscopy; Central Research Laboratory; I.P. Pavlov First Leningrad Medical Institute, Leningrad, U.S.S.R. G. SILINI (ITALY) - Laboratory of Radiation Pathology, Centro di Sudi Nucleari Della Casccia, Comitato Nazionale per l'Energia Nucleare, Rome; Secretary of UNSCEAR. W.K. SINCLAIR (U.S.) President U.N. National Commission on Radiological Protection; Argonne National Nuclear Laboratory, U.S. Department of Energy. E. TAJIMA (Japan) - Member of Security of Atomic Power, Kagaku Gijitsu cho, Science and Technology Agency, Prime Minister's Office, Tokyo, Japan. CONNECTIONS BETWEEN ICRP AND UNSCEAR: UNSCEAR, as all United Nations Agencies, is an organization of delegates sent by member governments. It does not make recommendations on radiological health and safety practices but serves primarily as an information gathering agency. ICRP depends on outside information gathering such as is done by UNSCEAR. Dual membership in ICRP and UNSCEAR was held by 11 members of ICRP (25% of the total ICRP membership). Both ICRP and UNSCEAR undertake a review of already published peer reviewed scientific research, accepting or rejecting it on the basis of its regulatory usefulness. ICRP makes the definite choice of research acceptable for calculating risk/benefit trade-offs. As they have no members with training in public health, occupational health, epidemiology, or biometry, their judgement cannot be assumed to be based in objective science. THE U.S. NATIONAL ACADEMY OF SCIENCE BEIR COMMITTEE: The third source on which Canadian Radiological Protection rests is the BEIR committee reports of 1972, 1979 and 1980. A fourth report is expected soon, devoted to the radon gas problem. BEIR V is expected to consider the risk estimate changes due to new dose assignments for the Hiroshima data. These new dose estimates will not be released to the public until presentation to ICRP in September 1987. The BEIR Committees are heavily staffed with personnel from U.S. Government nuclear research laboratories such as Oak Ridge and Brookhaven, and with researchers from the atomic bomb research centers at Hiroshima and Nagasaki. There is a greater breadth of expertise on the BEIR Committees than on ICRP and much more internal dissent. However, the Committee assumes an adversarial rather than scientific role. For example, BEIR III includes critiques of scientists who have challenged its risk factors without providing for a response by these scientists to their critique. The atomic bomb research has dominated the BEIR reports, and the health effects of exposure to ionizing radiation are seen as a national security subject in the U.S., both because they describe the effects of atomic bombs and because they affect the public's willingness to produce, test, store and accept the waste from the military program. The purpose of BEIR I was to answer criticism of U.S. above ground nuclear testing in Nevada. Enclosed with this testimony is a letter dated 24 October 1986, to the Honorable John S. Harrington, Secretary of the Department of Energy, from U.S. Representative Edward J. Markey, Chairperson of the U.S. House of Representatives Subcommittee on Energy Conservation and Power of the Committee on Energy and Commerce (Enclosure 1). The letter addresses the subject matter of some 31 experiments conducted under the U.S. Atomic Energy Commission (or its successor agencies: Energy, Research and Development Administration and Department of Energy) deliberately exposing some 695 Americans to plutonium, uranium, Xray, strontium 90, cobalt 60 or other internal and external sources of ionizing radiation without their knowledge or consent. This is a civilian counterpart to the deliberate exposure of more than 200,000 military men, including Canadians, to the atomic bombs. Until publicly forced to do so, these agencies have taken little or no responsibility for the human consequences and suffering caused by these misguided human experiments. These human experiments were carried out at or through the Oak Ridge Associated Universities, the Argonne National Nuclear Laboratory together with the University of Chicago, the Washington and Oregon State Prisons, Columbia University and the Montefiore Hospital in New York, the Massachusetts Institute of Technology and Massachusetts General Hospital in Boston. In addition to this, there were area experiments with radioactive iodine deliberately released to the environment from the U.S. Hanford Reservation and the U.S. National Reactor Testing Station at Idaho Falls. Some of the radiation related findings are still classified as secret in the U.S. The delegates to ICRP, UNSCEAR and BEIR chosen by their respective governments have both personal and national compelling reason for perpetuating their closed structure and secrecy. Canada has cooperated in the secrecy of these experiments for a share in the illegitimate knowledge gained. Just as Canada cooperated with U.S. experimentation with mind altering drugs in the 1960's, so too experimentation with humans was apparently accepted as a fact of life in the nuclear age. Reliance on such vested interest sources and silent cooperation with Nazi-like experimentation is a totally unacceptable basis for Canadian radiation protection. Seeking entrance into such an "old boy network" and describing their pronouncements as the consensus among the best scientists in the world is repugnant. IICPH denounces experimentation on humans and deception of the public for supposed national or economic gains. RECOMMENDATION: The IICPH agrees with the recommendation of the Select Committee on Ontario Hydro Affairs (June 1980) that Ontario establish its own Radiation Protection Agency with open meetings, expertise from all relevant disciplines, scientific representation from within and outside of the uranium or nuclear industries, and an institutional forum for worker and public participation. RECOMMENDATION: The IICPH recommends further that needed research to identify and resolve disputed questions on Radiological Protection be sponsored in such a way as to restore credibility, scientific validity and public health priority to Standard Setting in Canada. This section was prepared by Dr. Rosalie Bertell, with assistance of P.A. Green, M.Sc., researching membership in ICRP [Dr. Rosalie Bertell] -- Humanity has been held to a limited and distorted view of itself, from its interpretation of the most intimate emotions to its grandest visions of human possibilities, by virtue of its subordination of women. Until recently, "mankind's" understandings have been the only understandings generally available to us. As other perceptions arise-- precisely those perceptions that men, because of their dominant position could not perceive--the total vision of human possibilities enlarges and is transformed. -- Jean Baker Miller, "Toward a New Psychology of Women" (1976)