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.:) UNITED STATES RADIUM CORP., Hon. CLINTON P. ANDERSON, Chairman, Joint Committee on Atomic Energy, DEAR SENATOR ÅNDERSON: 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 atómic 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, 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. RADIATION PROTECTION 589 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.) Now in the Division of Radiological Health, U.S. Public Health Service, Washington, D.C. By virtue of the authority vested in me as President of the United States, it is hereby ordered as follows: Section 1. (a) There is hereby established the Federal Radiation Council (hereinafter referred to as the "Council'). (b) The Council shall be composed of the Secretary of Defense, the Secretary of Commerce, the Secretaryof Health, Education, and Welfare, and the Chairman of the Atomic Energy Commission, (c) The Chairman of the Council shall be designated by the President, from time to time, from among the members of the Council. Section 2. The Council shall advise the President with respect to radiation matters directly or indirectly affecting health, including matters pertinent to the general guidance of executive agencies by the President with respect to the development by such agencies of criteria for the protection of humans against ionizing radiation applicable to the affairs of the respective agencies. The Council shall take steps designed to further the interagency coordination of measures for protecting humans against ionizing radiation. Section 3. The Special Assistant to the President for Science and Technology, or his representative, is authorized to attend meetings of, to participate in the deliberations of, and to advise with, the Council, Section 4. For the purpose of effectuating this order, each executive agency represented on the Council shall furnish necessary assistance to the Council, in consonance with section 214 of the Act of May 3, 1945, 59 Stat. 134 (31 U.S.C. 691). Such assistance may include detailing employees to the Council to perform such duties consistent with the purposes of this order as the Chairman of the Council may assign to them. Upon the request of the Chairman of the Council, the heads of executive agencies shall so far as practicable provide the Council information and reports relating to matters within the cognizance of the Council. Section 5. The Council may seek technical advice, in respect of its functions, from any sourcit deems appropriate. The White House DWIGHT D. EISENHOWER August 14, 1959 591 |