RADIATION PROTECTION CRITERIA AND TUESDAY, MAY 31, 1960 CONGRESS OF THE UNITED STATES, The subcommittee met, pursuant to recess, at 10 a.m., in room P-63, the Capitol, Hon. Chet Holifield (chairman of the subcommittee) presiding. Present: Representatives Holifield, Price, Hosmer, and Senator Dworshak. Also present: James T. Ramey, executive director; Carey Brewer and George F. Murphy, professional staff members; Richard T. Lunger, Hal Hollister, and James E. Turner, technical consultants, Joint Committee on Atomic Energy. Representative HOLIFIELD. The committee will be in order. This morning the Special Radiation Subcommittee of the Joint Committee on Atomic Energy will resume its consideration of the basis and use of radiation protection criteria and standards. Last week we were privileged to proceed with valuable testimony from witnesses on the nature of standards relationships among agencies and groups concerned with radiation standards and on the biological concepts underlying such standards. Today the hearings will concern the social and economic concepts underlying radiation protection standards, and during the remainder of the week we will consider concepts of practical application and some of the problems of organizational, administrative, and legislative relationships. We are pleased to have as our first witness this morning Dr. Russell Morgan, who is radiologist in chief of the Johns Hopkins University. Dr. Morgan, I understand that you do not have a prepared statement, but will speak from your statement contained in our preprint of selected materials. 257 STATEMENT OF DR. RUSSELL MORGAN,1 RADIOLOGIST IN CHIEF, JOHNS HOPKINS UNIVERSITY Dr. MORGAN. Thank you, Mr. Chairman. As you said, my statement is in the preprint and hence I shall only refer to one or two points this morning in order that there may be more time for questioning. First of all, I should like to reemphasize something which has been pointed out before in these hearings, namely, that radiation standards are fundamentally the same in concept as health standards generally. That is, they are based upon a body of scientific data in which the risks of radiation are first determined and then, to that body of scientific data philosophical judgments are applied in which risks on the one hand are balanced against benefit on the other. Although radiation standards in particular and health standards in general are based on a wealth of scientific data, there necessarily is a great deal connected with them which is of an arbitrary nature. For example, there is no question that where X-ray workers are exposed, in medicine, weekly doses of 1,000 roentgens are out of line with good practice. The same is also true of weekly doses of 100 roentgens. Indeed, a great deal can be said against weekly doses of 10 roentgens. But as soon as one starts going down to doses of 1 roentgen per week or doses of one-tenth of a roentgen or one one-hundredth, one immediately must become very arbitrary as to where the limits of good operating practice should be set. As indicated in the preprint, the maximum permissible dose for radiation workers in the X-ray field originally was set at approximately 1 roentgen per week, whereas now it has been reduced to one-tenth of a roentgen per week, primarily because the lowest dose possible was recognized as the objective to be reached, and by practice it was found that a dose of one-tenth of a roentgen per week was possible under normal operating practices. As far as the socioeconomic factors of radiation standards are concerned, I think it is extremely important that, in their application, those to whom the standards apply and those who use the standards understand them just as fully as possible. In other words, these standards should be in such a form that they may be applied without ambiguity. This has not always been the case in the past. Let us take for a moment the case of one of the first standards that was set up by the parent organization of the National Committee on Radiation Protection, namely, the maximum permissible dose. This standard is important because it is the key to many of the other standards which have been developed since that time; also it has wide application to the population generally. Through the years, a good deal of misunderstanding has arisen over the meaning of the term "maximum permissible dose." There are those who have considered the maximum permissible dose to be the dose above which one should be gravely concerned regarding radiation safety. Actually, however, those who conceived the term intended that this dose merely indicate that level of radiation below which one need not be too concerned regarding the exposure which is received and above which some action is necessary to insure personal safety. In other words, this term which has been called the maximum permissible dose in reality is a minimum action dose; that is, it is a dose below which one need only be concerned with the application of minimal protective measures in the control of radiation, and above which one should apply increasingly strict controls of regulation. I am delighted to see that the Federal Radiation Council in its new guides for radiation standards has moved away from the use of such terms as maximum permissible dose, and is instead replacing such terms with nomenclature which more nearly meets the scientific facts, namely, that radiation as a potential hazard to the health and wellbeing of our Nation presents a problem which is roughly proportional to the doses involved. Their guides, calling for different actions to be taken at various radiation levels by health and other authorities concerned with the regulation of radiation is certainly a step in the right direction. There has been some concern regarding the place of the Federal Radiation Council in the field of radiation standards. However, I think that a prominent place by the Council is essential. Certainly, there is need, with the wide increase in the use of radiation for the Federal Government to take a place in the formulation of radiation standards, and the Federal Radiation Council seems a logical place where this development take place in view of the fact that it represents the major agencies of Government which are concerned with the control of radiation. The Council quite properly has used the National Committee on Radiation Protection quite widely since its work has begun, and here again this is highly desirable because here is a body of scientific people who are widely informed on radiation matters, people who can give expert advice to the Council. The Council quite rightfully is also calling on other people to guide it. As I indicated earlier, radiation standards not only depend upon scientific information but on prudent judgment and such judgment does not come only from scientific sources. Such areas as industry, labor, and so on can also provide the sort of guidance with which the Council can balance risk against benefit in making its decisions. Now, not only is it necessary that radiation standards be clearly understood by the population at large but it is equally important for the development of atomic energy in this country that radiation standards be clearly understood at the legal level, at the industrial level, and at the labor level, because without clearly understood standards, one is likely to encounter a good deal of confusion as atomic energy is developed in the future. This, Mr. Holifield, is all I would like to say now so that there may be time for questions. Representative HOLIFIELD. I notice you approve the setting up of the Radiation Council. Do you believe it is representative of all the elements that should be represented in our society? In view of the fact that no so-called public members, as provided for in the act, have been appointed? Dr. MORGAN. Mr. Chairman, I think one has to be a little careful in the appointment of so-called public members. The Council, as now constituted, represents certainly the principal areas in the Government field where radiation is of concern. It is making use of the National Committee on Radiation Protection and other scientists as well in getting the best scientific judgment which it can get. I think one has to be careful, as I said, in selecting public members. Representative HOLIFIELD. Is that because they are lay members? Dr. MORGAN. No. This is because by omission, if one is not careful, one may leave out people who have equal competence. Representative HOLIFIELD. This is always true in the selection of every group. You always leave out someone. Dr. MORGAN. Yes. Representative HOLIFIELD. The point involved is that Congress provided not only these members of the President's Cabinet to be appointed, but also there are people from wider areas, such as agriculture, labor, and possibly State and local governmental bodies and organizations representing the States, and so forth. Dr. MORGAN. Yes. I think since such representation now exists in large part, I think that additional help for the Council can probably best be obtained by the mechanism of consultants rather than working members of the Council. Representative HOLIFIELD. You are speaking of the working groups? Dr. MORGAN. Yes. Representative HOLIFIELD. The formulation of working groups on different problems, you mean? Dr. MORGAN. Yes. Representative HOLIFIELD. And then their recommendations should come to the Federal Radiation Council? Dr. MORGAN. That is right. Mr. RAMEY. You mentioned in your testimony the need for bringing in other interests than strictly scientific on this, and in your prepared statement at page 65 you mention that in addition to backgrounds in physics, chemistry, and biology, knowledge is required in industrial techniques, public health, military affairs, political science, economics, law, and many other disciplines if these standards are to represent the best judgment of the Nation. Just going through the list of consultants that the Federal Radiation Council gave in Mr. Flemming's testimony last week, you don't see many, or any, political scientists. It is hard to pick out an economist. You don't see many industrial experts. How does that fit in? Dr. MORGAN. I think there are two ways of taking care of this situation. No. 1, the economist, political scientists, generally do not represent localized areas of society, but are concerned with social problems in general. I think that such people might well be added to strengthen the Federal Radiation Council. In speaking of the industrial and labor fields, I think that here the mechanism of consultation may perhaps provide the best mechanism of giving the Council the sort of background of information which is necessary to make the judgments which it will be called upon to make. I think the Radiation Council in this first year has made remarkable progress. It is feeling its way along. I don't know what its plans are specifically in adding people, but I am sure that it is well aware of these issues. Mr. RAMEY. You have the situation, however, of the Federal Radiation Council now having adopted this basic radiation standard which again is substantially, as we understand, the same as the NCRP standard. In each case these have been developed by scientists with none of the other social disciplines being consulted or involved. So by the time they get around to taking on these people they will have already adopted the basic standards. Do you think that makes sense? Mr. MORGAN. I am not too concerned about the adoption of basic standards, although it is true that standards once adopted are perhaps difficult to change. However, I think we can look forward to many changes in the guides of the FRC over the years, not only as additional scientific information comes to hand, but as more extensive philosophical judgments are brought to bear in the balancing of risks against benefit. For example, I am not at all sure that in the field of industry several operating levels at which one may be permitted to work may be required. This does not cause any particular problem, I think, just so long as in each instance the standards are sufficiently well drawn that they are clearly understood and that adequate mechanisms are set up to compensate workers in the case of accident. Representative HOLIFIELD. How does the philosophy of benefit and risk change when one considers applying existing standards as opposed to setting standards? Dr. MORGAN. May I hear that again? Representative HOLIFIELD. My question is, how does the philosophy of benefit-risk change when one considers applying already existing standards as opposed to setting standards? Dr. MORGAN. I think that regardless of whether one is setting standards or whether one is altering existing standards, there is always a balance to be reached between benefit and risk. This business of balancing benefit and risk is rarely a purely scientific matter. The reasons for this are that one is often balancing unlike quantities. It is like balancing apples and pears. It is difficult to do in any but a philosophical way. Representative HOLIFIELD. Do you believe that the economic costs of radiation protection should be a major or primary factor in the setting of standards? Dr. MORGAN. I think it should be one factor, of course. Representative HOLIFIELD. Who should pass judgment on that, the industrialists or labor men or some scientist who does not have an economic problem involved? Dr. MORGAN. I think a well-balanced Federal Radiation Council is probably the best one. Representative HOLIFIELD. But the Radiation Council is not well balanced because it does not have industry or labor members on it, and they are the ones affected by cost. Dr. MORGAN. I am not so concerned about the absence of industry and labor members as I am perhaps concerned about additional people in the political science and economic areas whose viewpoints and |