This I should underline several times. Regardless of what professional advice there may be, those responsible for the protection of man in our country will have to accept criteria and behave on them even in the present unsatisfactory state of understanding.

(b) The development of standard techniques of measurement has had full value even though this standardization also tends to stultify scientific advance. When the advantages are weighed against the chaos of dissimilar techniques of measurement, which preceded standard methods, the balance is undoubtedly on the side of a common language.

In the standardization of methods of water and milk analyses, it should not be forgotten that much scientific work, but not all, was at hand for this step. One of the significant provisions in the activity was for continuing revision by carefully established machinery—a frank recognition of a moving science and art. These successful revisions span half a century. The procedure has valuable lessons for the radiation field since voluntary professional societies in the United States dominated this contribution.

(c) Criteria to guide administrative practice have been used with caution in the public health field. Appraisal sheets, coupled with assessments of current practice, have had variable results even when issued by voluntary groups. The fear of freezing practice, paralleled by the desire to facilitate intelligent administration, have been the characteristics of such excursions. The appraisal sheets have provided aids to improved coverage in public health and have not proven too resistant to new knowledge. Again relative success with standardizing practice is due in great part to the concomitant provision of machinery for continuing revision of the bases for appraisal.

(d) How has the health worker balanced criteria against risk to life? The past record of public health accomplishment, of which one has reason to be eminently proud, is singularly devoid of such quantitative evaluations. I think you could search high and low to find a parallel to the efforts we have noted in the past few years where you are attempting to equate life with dollars.

The fact that the American public lives in one of the highest protected public health environments in the world is not contested. That this is the result of the composite of public health measures, standard of living, genetic influence, and other factors is likewise true.

But the saving of lives and the extension of life have been the result of public health practices to a significant degree. It must be recognized, however, that the guiding principle that public health is purchasable was a qualitative philosophical precept, rarely a quantitative equating of protective criteria against loss of man or dollars. Efforts at the latter equation have not been rare, but quite unimpressive in general impact either upon the people or their legislators. I can speak feelingly about this because in my appearances of some 40 years before various assemblies it is rare that I have been able to convert them to any public measure on the basis of a statistical table which is often not impressive but often unintelligible and is highly emotional. They are rarely interested, as I point out here, with the effort of measuring the economic value of the newborn babe, but the western acceptance of the general obligation of society to prevent disease and death

is the prevailing one. This differs a great deal with other parts of the world, but again not as much as we might suspect.

It is only with the search for criteria for radiation limits that one finds suggestions that it should be permissible to kill people to attain benefits to society. This has undoubtedly been in the minds of all criteria makers, but rarely has it reached the frank and stark pronouncements of recent years.

(e) Has there been a discernible factor of safety in public health criteria invariably in favor of the public? The answer is unquestionably "Yes," and the factor of safety has always been large.

This principle is well illustrated in drinking water quality standards to protect man against typhoid fever, the dysenteries, infectious hepatitis, cholera, et cetera. Obviously, the best criterion of the danger of a public water supply of inferior quality is the undertaker's certificate that the man is dead and that epidemiological evidence convicted the water he drank.

The health officer did not accept such a criterion, specific and quantitative as it was. It was not sufficiently prompt and did not provide a wide area of protective safety. He chose to widen this area immensely by moving to far less specific criteria with broad empiracal relationships to disease. The index preferred for half a century was the coliform group-nonspecific, even generaly nonpathogenic, and only a qualitative indication of a "climate" of unsafe quality. I stress this. It was a broad criterion and not a detailed, specific one. It has served its purpose beautifully as a striking example of intelligent empiricism preceding more refined measures of risk. Fortunately, no easy method of detection of the specific typhoid bacillus was available 30 years ago, because its adoption as the universal indicator would have narrowed measurably the area of safety for the consumer.

It is not an unmixed blessing that already the radiation industry is plagued in fixing criteria by a startling multiplicity of specific nuclides and their effects. I think the committee has already sensed that something might be done about this in its suggestion, which parallels my own, that another look at the value of gross criteria may be warranted, not because they may be more intelligent to the citizen but because they may be more easily entered into administrative practice. This multiplicity, of course, is a matter of concern to everyone of the radiation people who have done, as I said, a superb job of their evaluation, with all of the obstacles, scientific and otherwise that they had.

The factor of safety was even more enlarged by the essential application of administrative judgment. Water quality appraisal was a composite of understanding of heredity or origin of source, environmental adjustment or treatment, and of final product. The equilibration of these three factors was a sine qua non of assessment and depended upon professional proficiency. There were always those, of course, who looked to a single quantitative unit for appraisal. These in fact did damage to administrative justice by attempting to oversimplify the complexity of interpretation of many criteria. We are between this upper and lower millstone in the radiation field where we want simplification but we cannot ignore that this is still an area of judgment and nothing else. It would be hazardous and, I think,

almost calamitous to try to have a handbook formula which everyone on the street could use. It is not in that condition yet.

(f) The march of scientific understanding pressed toward evermore dramatic hopes in public health. Shifts in objective toward even lower death rates were the symbols of practice as the means for accomplishment became more evident or were created. For example, in the 1920's a residual typhoid fever death rate of 10 per 100,000 was assumed to be inevitable. Less than this was "impracticable' to attain. Yet public health measures were persisted in so that the typhoid death rate last year in the United States was one-hundredth of this figure. Was this desire to save lives foolish? It is to be doubted.

We have one of the lowest typhoid death rates in the world. We simply ignored the lower level which could not be depressed lower. It turned out to be untrue, which is something that might be borne in mind.

(g) Were the results of continually higher standards for health protection unduly costly in dollars? It is rare to have encountered public or private agencies in the past which did not plead poverty and excessive costs of corrective. History shows that the public health demand for pasteurized milk was consistently opposed because capital and maintenance costs would price milk off the market. It is a credit to industry that it meets such challenges while at the same time fighting them.

Improved water quality has moved forward rapidly at remarkably low cost, because the technologist has been able to design, construct, and operate plants meeting ever-increasing and more rigid criteria. Fear has been expressed that the establishment of too rigid criteria for the radiation activity may stifle progress because of excessive costs of attainment. One may view this fear with some cynicism in the light of the whole history of health and safety endeavor. This fear has always been expressed, but the historical reality consistently belies it. Criteria must rest upon public health protection and not

cost.

No one, of course, should advocate excessive and unnecessary restraints. Those restraints most logically suggested, however, within the framework of current scientific understanding should not be resisted soley because resulting costs may threaten to throttle application. This should be scrutinized with a great deal of care before it is accepted as your baseline of decision.

Now I come to the very brief implications in the field of radiation. The lessons of the past in general health and safety practices are easy to read. They are characterized by moving empirical decisions, by eternally persistent reappraisals, by consistently giving the public the benefit of doubt, by an ever-narrowing gap between knowledge and application, by qualitative rather than quantitative slide-rule assessments of hazard, and by objectives of reducing disease and fatality to a vanishing degree and not to a preconceived notion as to how many people we have a right to kill. The reasoning has never been proposed or accepted that the goal for reduction of coronaries should be the number of violent deaths we insanely accept on the highway. I might interpolate here that, from my point of view, the highway deaths annually are not a goal; they are à disgrace. They

are a true indication of the failure of public health practitioners to either assess, diagnose, or put into position corrective measures. This should not be held out now as the basis by which we should measure other hazards to people. Such subtleties of philosophical irony, if invoked, would cost many a health officer his job, and should. These are not the kind of criteria that public health practitioners have ever used, and I hope never will.

The radiation field is today confronted with similar problems and decisions, greatly complicated by the very nature of the biological effects to be considered. The somatic and genetic resultants are unclear and not fully predictable with assurance, perhaps for some years. Yet one cannot bide one's time in placing restraints upon the public and private producer. These latter do not have an unblemished record of self-policing. Hence society must look to scientific groups and public officials for providing criteria and guides, at times admittedly uncertain, at others admittedly tentative. As knowledge increases, reappraisals ensue, either for relaxation or for tightening of criteria. These supposedly fumbling steps have much historical validity and precedent in public health practice. They are unpalatable to the precisionist and to many others seeking to find formula in place of evolving judgment and declining ignorance.

The day of handbook rule for measuring the hazard of radiation is a long way off. In the meantime one acts upon limited knowledge. In such action the guilding principle must be the maximum protection of people, not because of sentiment but because society demands it. An agreed acceptance of a number of consequent disabilities is not an appealing basis for the development, say, of nuclear power. Industry will do better than rest upon such an affront to man. I know they will, and have.

Whether the costs of protection will prove to be exorbitant, it is too early to predict. All radiation effort is in evolution and consequent costs are still high. It is not unreasonable to anticipate that all such costs will decline. With this decline, costs of built-in health and safety measures will also fall. The past record amply justifies such a prophecy.

In the interval during technological advance one might profitably follow the wise conclusion Lauriston Taylor so well states in the congressional print (Preprint) page 238:

* * * we have a deep moral responsibility to make certain that the problem does not become a critical one for those that follow us. We are thus inescapably compelled to consider, and consider carefully, the question of the long-range uses of all radiation sources whatever, to be certain, first, that any level we set is not seriously exceeded, and, second, to be certain that no one source causes us to use up our exposure allowance at the expense of other uses, which may in fact be more essential to our overall health and well-being.

Representative HOLIFIELD. Thank you, Dr. Wolman. Certainly that was one of the most interesting statements that the committee has ever heard. I know there are some points about which they will want to question you.

Mr. Price.

Representative PRICE. Mr. Chairman, I was just reading where the doctor says that experience has disclosed that where such criteria have been frozen into law, revision becomes a heroic effort. Administrative rule is by far more flexible.

I was trying to place that thought with the end of your statement which I thought was exceptionally good-your statement was all good. You mean that you would not advocate or propose that we deal with this area through legislation at this stage, or soon?

Dr. WOLMAN. Let me say this. I do not feel that it should be translated, at least the criteria should not be translated into law or legislative action. My reason for this is, as I have pointed out, that this is moving, even with some rapidity, in adjustment to the criteria and much more important in the flow of new experimental and observational knowledge. We have here the rather general agreement of most of the material in the testimony, that it is only by such extended research that the criteria become not only more refined, but more intelligible and even more appropriate. I would prefer-and this rests on all of our previous public health experience that where you freeze criteria into law, you freeze the present known knowlege which in almost every instance is inadequate. Then it becomes very difficult to unfreeze it. It may be either too rigid or it may not be rigid enough. Representative PRICE. I recognize that as a problem. I think the committee does also, because we have been studying this matter for several years now. But there is also the other side of it, that if it is allowed to go too far or too long, the economic pressure that might build up industrially, and so forth, might make it more difficult to eventually enact adequate legislation.

Dr. WOLMAN. You may never have to.

Representative PRICE. I am only thinking out loud. I have been thinking of the previous experience in this field.

Dr. WOLMAN. You may never have to set it up or translate it into legislation. I am speaking of the criteria. You have established in our society administrative units in order to exercise this flexibility, this continuing adaptability to new knowledge. That is why you establish them. You did not say to them when you established them or at a subsequent time that the criteria under which you will have to function in the radiation field, or in the toxic industrial poisons field, that you will have to work within these limits of application of criteria, because if you did, you are doing something that you are not prepared to do, first, in the light of scientific knowledge, and, second, you should not do it even if the present knowledge gave you some guarantee, which it does not. In our whole history of criteria, such as the toxic leads or the mercuries, we have learned more about them and their effects on man as time went on. It would have been a mistake to have frozen them into a legislative act. It takes 10 to 15 years to change a legislative act. You can change the Federal Register, we hope, as often as the new knowledge warrants the change.

I add a second point. I emphasized it in the paper and I think many of the other speakers have. Voluntary scientific groups are eternally reviewing criteria in any field. They are on the alert and always have been in determining when a criterion ought to be changed. They do not have the power of law, but I think they have an even greater power of scientific influence on the administrative agencies. Where the administrative agency does not establish the criterion, because many of these in public health fields are established by voluntary associations of a professional nature, they don't find their way either into law or into current Federal or State or local administrative decisions.