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or distance or anything else, they accept this as being a yardstick with which the problem can be discussed between scientists.

Representative HOSMER. Do you feel that it is a proper thing to sacrifice accuracy and completeness in explaining to the layman in order to get over a general concept that has some significance within his own experience?

Dr. PETERSON. I would first of all qualify my answer by saying that we do not take liberties with accuracy in putting over a general concept, but merely attempt to redefine the concept in less technical language. If there is some controversy concerning detailed data involved in presenting the point, it is done so in such a way that the controversial data can be omitted and yet the point can be made.

Take for example the "threshold" question, which is vital but really a very technical problem. Obviously, a person without specialized training cannot understand the threshold concept in terms of the technical words and evaluate data which are often drawn from experience in mice and other experimental situations. But he can get the concept of the threshold without entering into these areas of controversy.

Representative HOSMER. You speak to a PTA or Rotary group, an evening church group, a few more: Is there a sufficient retention from what you have said that night to do any real good or is there merely an awakening of an interest or do they come away with an attitude, "Well, the people at least who are doing this know what they are doing."

Dr. PETERSON. Let me say that in general we are, ourselves, very disappointed about the fact that we cannot qualify the retention time that the audience enjoys after our evening of speaking. This is, as you can imagine, almost impossible to measure. We have one measure of response.

If we speak to a PTA, they will go to a church group and ask that a speaker from our committee go to the church group to talk. And the church group will say to the Rotary Club, "I heard an interesting subject discussed; I wish we could have it discussed here." We know there is an area of interest generated by this to the point that they will go out and seek further audiences. But in regard to the reaction of the person in the audience; that is, do people understand it? Can they control it? I would like to put before you that one of the commonest reactions we experience from these lay groups is that they hold the scientist culpable in this new age. They often couch the thing in this sense: "You scientists have released this thing and now it is up to you to control it." What we try to do at this point is to reassure that this is not a thing which has been released, but this is a very significant contribution to mankind and that what we now have to do is to learn how to handle it as safely as we possibly This is true of any contribution to mankind.

can.

Representative HOSMER. I am glad to know of something that they do not hold Congress responsible for.

There is one other question I want to ask you. I want to make sure of this. This group of yours does not have a political pitch or philosophy?

Dr. PETERSON. No political pitch whatever. I think we have a philosophy in that our statement of purposes specifically affirms

that the increasing use of nuclear energy requires that sound information on the nature of hazards of radiation be made available to the public. Only in this way can there be intelligent participation of citizens in the formation of public policy.

Representative HOSMER. It is merely trying to inform; is that

right?

Dr. PETERSON. Absolutely correct.

Representative HOSMER. Thank you very much.

Dr. PETERSON. We want to thank you.

(The following statement was received from United States Radium : Corp.:)

Hon. CLINTON P. ANDERSON,

UNITED STATES RADIUM CORP.,
Morristown, N.J., May 2, 1960.

Chairman, Joint Committee on Atomic Energy,
Congress of the United States, Washington, D.C.

DEAR SENATOR ANDERSON: It has been brought to our attention that hearings, beginning on May 24 and extending through June 3, will be held in Washington and that a portion of these hearings will be devoted to the subject of "Radiation Protection Criteria and Standards." We understand that comments from the public are invited and, as a concern which has been active in the field of radioactivity since 1914, we would like to submit some of the views which we have developed as a result of our long experience in this field. As a basis for our suggestions we wish, first of all, to submit a few comments on the current and proposed standards under which we have had an opportunity to conduct our activities for some time and which has thus enabled us to develop a few ideas regarding shortcomings of these regulations.

We believe

(1) That the current standards and regulations are much too general.

(a) They attempt to encompass a broad field with no recognition of the many variables introduced by different physical forms, chemical compositions, and end uses of the products or devices containing isotopes.

(b) They show a lack of practical experience in the field and too much reliance on a limited acquaintance with certain small segments of this highly specialized field.

(c) They are interpreted too literally by inspectors without giving proper consideration to applicable conditions or environment.

(2) They are considered as laws rather than guides in a field where insufficient experience exists to justify laws.

(3) They attempt, by legislation, to eliminate all element of risk by imposing ultraconservative limits.

(4) They assume that all knowledge of the subject is centered in the promulgators of the rules and make no allowance for the intelligence and commonsense and experience of the public.

(5) They incite "scare" psychology.

(6) They fail to recognize that protection of the employee and the public is more important, both financially and otherwise, to the processor or user of the product than to the enforcement agency.

(7) They impose useless, meaningless, and, in many cases, impossible requirements for reporting and recordkeeping which not only discourage use, but also greatly increase the cost of the end product.

(8) They fail to recognize hazards eliminated by the adaptation of isotopes to many normally hazardous industrial processes.

The above is not to be construed as an objection on our part to regulations. We are most anxious to see workable controls and regulations imposed and believe that such regulations are extremely necessary and would do much to promote the atomic energy industry. We are also cognizant of the fact that there presently exists only limited data from human experience on which to base rules and that long-range effects of radiation are, at this time, not predictable. With reference to the lack of data from human experience, we are aware of a number of so-called radiation exposure cases which resulted in a fatality, but honest evaluation of cases which can definitely be attributed to this effect 58454 0-60-38

indicates that the exposure factor was greater, by a fantastic figure, than the radiation levels which are now in use or proposed. On the subject of long-range effects, it is quite true that this is an unpredictable area, but one must also consider that the long-range effects of antibiotics, drugs, alcohol, smog, and many other items are also unknown, but no attempt has been made to legislate these out of existence. The hazard has been weighed in terms of the good which can be accomplished and a more reasonable approach has been taken. One must also remember that if an attempt were made to legislate away all hazards there would now be in existence no matches, automobiles, elevators, cigarette lighters, etc. The point we would like to make is that the regulations must be considered from a practical standpoint if there is ever to be any hope for the future of the radioactive program. There is doubtless a happy medium which could recognize past experience in the field of natural isotopes and would not constitute too great a liberalization of the regulations.

It is quite possible that more responsibility could be placed in the hands of the isotope user rather than having all the responsibility concentrated in a comparatively small group which frequently lacks practical experience.

In these considerations one must also look at the economic effect. Many regulations are prepared by groups whose experience has been limited to either research institutions utilizing infinitesimal quantities of radioactives or Gov. ernment laboratories which have unlimited access to funds necessary to provide elaborate protective features. Continued reduction in radiation levels permitted by the regulations does not seriously affect the operations of these groups, but the story is much different in the commercial field. As a typical example of the effect, we may point to our own experience in operating under the regulations permitting an exposure of 300 mr per week as contrasted with working at a level of 100 mr per week. At the level of 300 mr per week the operating efficiency of our laboratory was approximately 60 to 70 percent. Under the new levels of 100 mr per week we find that the efficiency is approximately 30 percent and the rise in the overall cost of operation, exclusive of increased equipment costs and other incidentals, is slightly in excess of 100 percent. If the regulations were essential in order to definitely assure the safety of personnel, financial considerations would not enter in and one would simply have to face facts and make the best of the situation. We believe, however, that these levels are not realistic and, as a result, increased operating costs are gradually pricing these products out of the commercial field.

Other examples could be cited and the entire subject could be expanded upon, however, we hope the above brief discussion will represent a few thoughts which are worthy of consideration and that some of the points raised can perhaps be expanded upon at the forthcoming hearings. Respectfully submitted.

C. W. WALLHAUSEN,

Vice President.

Representative HOSMER. That concludes our list of scheduled witnesses. Is there anybody here who has a speech to make?

In that event, this will conclude the Special Radiation Subcommittee hearings on the basis and use of radiation protection criteria and standards. On behalf of the subcommittee I wish to thank the many witnesses who have contributed to these hearings. I believe we have established a valuable public record which should go far to clarify some of the confusion and misunderstanding which has existed in this field.

The Special Radiation Subcommittee will continue its study in this field, as we have since 1957, when the initial fallout hearings were conducted.

These hearings, as well as the 1959 hearings on fallout and on waste disposal, Federal-State relationships and workmen's compensation, provided much of the background for the current hearings.

A summary analysis of these hearings will be prepared by the committee for issuance to the public, together with the printed verbatim record. This may or may not include recommendations as to the problems considered.

It is possible that the Joint Committee will want to consider a followup hearing next year on ways in which Federal organization should be changed to permit a more effective process for the development and application of radiation protection standards for use by Federal agencies and agency contractors.

For the record I want to note that before the hearings started the committee asked three highly respected persons in fields related to radiation protection to act as rapporteurs. This meant being present every day, taking notes, and spending their own time summarizing the high points of the hearings.

The committee wishes to express its sincere thanks to

Dr. Charles Dunham, Director of AEC's Division of Biology and Medicine;

Dr. Francis Weber, Chief of the Division of Radiological Health of the Public Health Service;

Mr. H. M. Parker, manager of the Hanford Laboratories Operations, General Electric Co.

In addition, the committee wishes to thank the following persons, who were asked to be present throughout the hearings:

Mr. Jack Healy, General Electric Co., Hanford;

Dr. Paul C. Tompkins,' Naval Radiological Defense Laboratory; Dr. K. Z. Morgan, Oak Ridge National Laboratory, and his associate, Dr. W. S. Snyder;

Dr. Charles Williams, Liberty Mutual Insurance Co.; and

Mr. Duncan A. Holaday, Bureau of State Service, U.S. Public Health Service.

I want to express our thanks also for the valuable assistance rendered by Mr. Hal Hollister and Dr. James Turner, of the Atomic Energy Commission, who have served as technical consultants to the Joint Committee for these hearings.

We appreciate very much their excellent contribution to these hearings.

The record of the hearings will remain open for 10 days for the receipt of supplementary materials.

This concludes the meeting.

(Whereupon, at 3:50 p.m., the hearing was concluded, subject to the call of the Chair.)

1 Now in the Division of Radiological Health, U.S. Public Health Service, Washington, D.C.

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