responding international organization, the International Commission on Radiological Protection.

In view of the fact that the AEC has not only contributed to the effort of the NCRP but has depended heavily upon the NCRP for the advice upon which the basic policy of the AEC on radiation protection has rested, it is desirable to discuss in greater detail the relationships which have existed between the two. The recommendations of the NCRP are made by its main committee, now consisting of 45 persons of whom 8 are designated representatives of governmental agencies (including the Department of Defense), approximately 25 are designated representatives of professional or other nongovernmental organizations, 4 are members at large, and the remainder are members ex officio by virtue of their respective positions as chairmen of technical subcommittees. Although only 2 of the 45 members of the committee are designated by the Atomic Energy Commission, at least 17 have at one time or another been employed by the Atomic Energy Commission or by AEC contractors.

The detailed technical work of the NCRP is done by 18 subcommittees involving more than 100 aditional persons. Here, also, many of the chairmen and members have at one time or another been associated with the AEC or with one of its contractors.

The recommendations of the NCRP have included quantitative limits on the exposure to radiation of the whole body, or of specified portions of the body. The NCRP has also made general suggestions as to how exposures to radiation may be controlled or minimized. The recommended radiation dose limits are basic to the control of radiation hazard. The recommended methods for assuring that actual exposures will be kept within recommended limits are intended to be of assistance in the solution of accompanying administrative and economic problems.

The nature of radiation hazards as presently understood does, however, present some complicated problems in achieving the optimum administration of a radiation protection program. It is generally assumed that, at the levels of radiation exposure of interest in routine activities, the hazards are very small but are never zero. It is also assumed that the hazards increase with the total amount of exposure accumulated over a long period of years or over a lifetime. For these reasons, the NCRP, in addition to recommending limits on the exposure which may be received in specified periods of time, has recommended that exposures should be kept as low as practicable. It is always at least theoretically possible to achieve some further reduction in exposure by the expenditure of greater effort. Consequently such a recommendation implies that, in setting a level of exposure, a determination will be made that the level is one at which any further reduction in hazard would not be worth the cost of the effort which would be required to bring about the radiation. This approach, while quite appropriate for the purposes of the NCRP, leads to difficulties. for the Government agencies responsible for the formulation and administration of radiation standards.

On the one hand, the NCRP recommendation could be interpreted to permit larger exposures to the employees working around an experimental reactor than to those operating a standardized power reactor. On the other hand, if the recommendation should be coupled with the

policy that no one atomic energy worker should be exposed to a greater radiation hazard than another, one would be faced with a dilemma in the shape of a limit which would be either unattainable for some applications or unnecessarily high for others.

To understand how radiation standards are used by the Atomic Energy Commission, it is necessary to distinguish between two broad classes of activities: (1) The operation by the Commission of AEC facilities, and (2) the regulation by the Commission of the uses of nuclear materials and radioactive byproduct materials by others.

Since 1947 the Commission has been directly responsible for the operation of a complex of nuclear energy facilities which includes the production and processing of nuclear and radioactive materials, the experimental development of nuclear reactors and chemical processes, and research in most of the physical and biological sciences. In the operation of each of these facilities, it is necessary for the Commission to assure itself that there is due regard for the health and welfare of individual workers and of the general public.

Since 1954 the Commission has been authorized by the Atomic Energy Act to license the use of nuclear and radioactive byproduct materials by qualified applicants, pursuant to such safety standards as are established by rule of the Commission to protect health and to minimize danger to life or property. To meet those objectives, the Commission has established a well-defined regulatory program, governing the use of specified fissionable and radioactive materials, independent of the Commission's operational program at all administrative levels below the General Manager.

Both the operational program and the regulatory program of the Commission have used the basic recommendations of the NCRP as guides to the control of radiation hazards. A detailed discussion of the application of NCRP recommendations to Commission activities is given on pages 505-517 of the Joint Committee's print of "Selected Materials on Radiation Protection Criteria and Standards," May 1960; and their application to the regulatory program is discussed on pages 518-532 of the committee print. While both programs have been based upon the recommendations of the NCRP, a principal difference between the application of these recommendations to the two programs should be pointed out:

Because the AEC has direct and continuing contractual control of its own operations, it is possible to place upon the technical staff of the contractor a considerable amount of responsibility for the selection of means by which specified objections of the radiation protection program are to be met. Those means are subject to continuous modification in the light of experience. On the other hand, the controls applicable to licensed operations are

(a) The Commission's regulations contained in the Code of Federal Regulations, which must be equally applicable to a great diversity of conditions, and

(b) Special provisions which may be incorporated in the terms of particular licenses.

Thus, the Commission applies radiation protection standards to its licensees in a manner which results in requirements on the licensees which tend to be more detailed and less flexible than are those applied to the Commission's own facilities. The Commission's requirements

on licensees do not, however, require them to provide a higher degree of radiation protection than is achieved in the Commission's contrac tor-operated facilities. The point is that certain rigidities are necessarily involved in the regulation of licensed atomic energy applica tions which are not involved in the Commission's direct operations.

In August of last year the President equipped himself to provide general guidance for executive agencies with respect to criteria for radiation protection by establishing the Federal Radiation Council, a body to which the Congress, a short time later, gave statutory status. There was thus provided for the first time an official mechanism for providing basic guidance for use by the Atomic Energy Commission and for other Federal agencies in the formulation of radiation protection standards. The first report of the Federal Radiation Council to the President containing recommended criteria for the limitation of exposures to radiation was approved by the President on May 13, 1960. The criteria contained in that report do not differ substantially from the current recommendations of the National Committee on Radiation Protection. Work on derived criteria for limitation of exposure to radioactive materials in air and water is underway.

The Commission has cooperated fully with the Federal Radiation Council in its work. The Chairman, or another Commissioner acting as his alternate, has attended all meetings of the Council to date. A representative of the Office of Health and Safety has regularly represented the Commission on the Working Group of the Council.

Representative HOLIFIELD. At that point, you say "the Chairman, or another Commissioner acting as his alternate, has attended all meetings of the Council to date." How many meetings has the Chairman attended?

Mr. FINAN. I would have to supply that for the record, Mr. Holifield. I have only had reason to attend one or two of the meetings myself. So I cannot speak from my own knowledge.

We will be glad to furnish that information.

(The information referred to follows:)

Representative HOLIFIELD. But at least the Chairman or another Commissioner has attended all the meetings?

Mr. FINAN. Yes, sir. Briefly, Dr. Williams, I believe, went to one or two meetings. Subsequently, Mr. Floberg has attended those meetings that the Chairman was unable to attend.

Shall I proceed, Mr. Chairman?

Representative HOLIFIELD. Yes.

Mr. FINAN. The recent report of the Council to the President was based upon 312 months of full-time work, expected to extend through a period of several months-the AEC is contributing two professional men experienced in radiation protection problems. In addition, the

AEC has made available to the Council and its staff approximately 25 days of consultation from 23 experts from its own organization, its prime contractors, or its consultants.

Some further insight into the role of the Atomic Energy Commission in the field of radiation protection is afforded by consideration of the related responsibilities of other governmental agencies.

The Atomic Energy Commission and the Department of Health, Education, and Welfare have intersecting responsibilities in several areas. One such area, for example, involves control of the release into interstate waterways of materials licensed by the Atomic Energy Commission. In another area the Atomic Energy Commission has the responsibility for measures to prevent excessive quantities of radioactivity becoming incorporated in food products, but if excessive quantities were to appear in such food products it would be the responsibility of the Department of Health, Education, and Welfare to take appropriate action with respect to the food.

In addition, the Department of Health, Education, and Welfare has been given primary responsibility within the executive branch of the Federal Government for the interpretation of data on environmental radiation levels.

Interagency cooperation between the AEC and several other civil Government agencies is necessary for radiation protection in a number of situations.

The Department of Labor defines hazardous occupations from which children under specified ages are prohibited. The Department of Agriculture inspects meat for wholesomeness. The Office of Civil and Defense Mobilization has an extensive interest in problems of radiation protection in connection with civil defense.

The Interstate Commerce Commission, the U.S. Coast Guard, the Federal Aviation Agency, and the Post Office Department regulate the transportation of hazardous materials over land, by ship, by air, and through the mails, respectively.

Currently, problems of the regulation of transportation of radioactive materials are coordinated by an interdepartmental committee chaired by a representative of the Atomic Energy Commission and including representatives of the agencies mentioned above. In addition the Bureau of Explosives of the American Association of Railroads is represented on this committee. Representatives of this committee are working with representatives of other countries under the sponsorship of the International Atomic Energy Agency to achieve a coordinated international approach.

I should like at this point to introduce into the record a brief statement on the regulation of transportation of radioactive materials by Federal agencies.

(The statement referred to follows:)

REGULATION OF TRANSPORTATION OF RADIOACTIVE MATERIALS BY FEDERAL AGENCIES OTHER THAN THE AEC

Existing regulations for the transportation of radioactive materials deal with questions of packaging, labeling, and handling of radioactive materials to minimize exposure of transportation workers and members of the general public to radiation either under routine conditions of transportation or in case of accident. Although these regulations do not contain specific statements as to the radiation dose which might be received by individuals as a result of such handling or ac

cident, current standards of radiation protection constituted an important consideration in their formulation. In some cases, a more restrictive consideration is the desirability of protecting photographic film from excessive exposure and of avoiding radioactive contamination of other materials.

Although a number of Federal agencies have responsibility for regulating transportation of hazardous materials, under certain modes of transportation the basic regulations in current use are those promulgated by the Interstate Commerce Commission and published as parts 71 to 78 CFR 49. These regu lations apply to surface transportation by land and, under some circumstances, by water. Regulations governing the transportation of radioactive materials in aircraft are published by the Federal Aviation Agency in part 49 CFR 14, and transportation of radioactive materials subject to the regulations of the U.S. Coast Guard are published as part 146 CFR 46. Because the transportation of any particular shipment of material is likely to use two or more modes of transportation, some degree of correlation between the regulations applying to one mode and those applying to another is necessary. In practice, the packaging and labeling specified by the ICC are adopted by the Federal Aviation Agency and the U.S. Coast Guard.

The Post Office Department does not accept packages of radioactive materials which, under ICC regulations, require special packaging and labeling but permits the shipments of small quantities of radioactive material with specified labeling.

Mr. FINAN. I should also like to invite attention to the statements prepared by most of the agencies mentioned above which appear in the Joint Committee's print of "Selected Materials."

An amendment to the Atomic Energy Act enacted last September, Public Law 86-373, provided a mechanism by which the Atomic Energy Commission might relinquish to the States some of the responsibili ties for the regulation of licensed materials given to the Atomic Energy Commission in 1954.

It is contemplated by the statute that AEC will enter into an agree ment with a State for the discontinuance of jurisdiction if the Governnor of that State certifies that the State has a program for the control of radiation hazards adequate to protect the public health and safety with respect to the materials within the State covered by the proposed agreement, and that the State desires to assume regulatory responsi bility for such materials; and the AEC finds that the State program is compatible with the Commission's program for the regulation of such materials, and that the State program is adequate to protect the public health and safety with respect to the materials covered by the proposed agreement.

It is assumed by the Atomic Energy Commission that in order for a State program to be compatible with that of the Commission, the State program will be based upon the radiation protection standards used by the Federal Government.

The Commission has prepared a statement of criteria to be used in negotiating agreements with the individual States and these have beer. circulated to the various States. Although these have been discussed in some detail at various meetings with representatives of individual States or groups of States, formal replies had been received as of May 20, 1960, from only two States.

The material supplied to the Joint Committee for incorpartion in its print of "Selected Materials on Radiation Protection Criteria and Standards: Their Basis and Use" includes, on pages 518-530 of the committee print, a discussion of the AEC licensing and regulation program with particular emphasis on part 20 of the Commission's regulation, "Standards for Protection Against Radiation." In elabo