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Why Does FDA Tolerate More Radiation Than EPA?
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UPDATED 4/19 with long-awaited comment from FDA, at bottom.
Since the Environmental Protection Agency began detecting radiation in rainwater and milk at levels above its maximum contaminant level, government officials have been downplaying the importance of EPA’s maximum contaminant level.
They would much prefer us to speak in terms of the Food and Drug Administration’s “Derived Intervention Level.”
The two levels could hardly be more different:
- EPA does not allow drinking water to contain more than 3 picoCuries per liter of radioactive istotopes like iodine-131 and cesium-137.
- FDA allows up to 4,700 picoCuries of iodine-131 in a liter of milk and up to 33,000 picoCuries of cesium-137.
Officials from both agencies—as well as many state governments—explain the difference in terms of time: EPA assumes long-term exposure over 70 years. FDA assumes you’re encountering the radiation all at once.
But time isn’t the only difference between these two standards:
FDA tolerates a higher mortality rate.
In Hawaii, where milk from Hilo contained the highest levels seen so far, Environmental Health administrator Lynn Nakasone suggested the EPA’s standard is irrelevant to milk contamination.
“It’s like drinking two liters of water for 70 years to get (the EPA’s) limit,” Nakasone told the Honolulu Star-Advertiser. “So if you extrapolated to milk, you’d have to drink two liters of milk for 70 years to get that limit.”
Nakasone prefers the FDA’s standard. But here’s what Nakasone isn’t telling Hawaiians:
- The EPA’s level is calculated so that in a population of one million people, the radiation will result in no more than one additional cancer fatality.
- The FDA standard, on the other hand, accepts two extra cancer fatalities in a population of 10,000.
Why does the FDA tolerate more radiation, and more mortality, than the EPA? I posed a question Wednesday morning to FDA spokesman Siobhan Delancey, who said:
Let me check with my experts and get back to you, okay?”
Okay. When she does get back to me, I’ll add her answer to this post, so stay posted. Meanwhile, I’ll give you the answers we found in documents from both agencies.
First, I have some people to credit and thank. I owe this post to some of the other participants on this page who have become diligent researchers on this topic. Chargirl in particular dug up pertinent documents from the FDA. Mothra, and rickcromack have been dogged in their pursuit of facts. And daviddelosangeles has chipped in too.
As Chargirl pointed out in a comment yesterday, FDA’s Derived Intervention Limits are not radioactive exposure limits. In the FDA’s own words:
FDA has set Derived Intervention Levels for foods prepared for consumption. These levels do not define a safe or unsafe level of exposure, but instead a level at which protective measures would be recommended to ensure that no one receives a significant dose.
In other words, the FDA’s DIL is set at the point at which a single liter of milk is so radioactive, you should take protective action.
The number itself is conservatively estimated, with children and the elderly and our most vulnerable citizens in mind—but in practice, the DIL is more a commercial level than an exposure-safety level: DILs are recognized internationally as the level above which foods are unfit for sale or trade.
The EPA’s MCL Goal, by contrast, is “the level of a contaminant in drinking water below which there is no known or expected risk to health.”
And that’s not just over a 70-year period. EPA’s annual MCL for iodine-131 is equivalent to 700 picoCuries per liter, according to this EPA document.
That means FDA’s 4,700 picoCurie limit for one liter of milk is almost seven times higher than EPA’s exposure maximum for a year.
FDA’s limit for Cesium-137 in a single liter of milk is 47 times higher than EPA’s annual maximum for human exposure.
To arrive at that level of tolerance, FDA has to accept a higher mortality rate. But why would it?
I suspect it has something to do with the cost/benefit analysis that some regulatory agencies are required to conduct when they set standards.
EPA’s mandate is to protect public health while avoiding a “significant economic impact” to industry. If EPA finds high levels of radionuclides in a municipal drinking water system, the water can be cleaned relatively cheaply. Depending on the specific contaminant, the water can be treated with reverse osmosis, activated carbon, ion exchange, or better: all three.
If FDA finds high levels of radionuclides in milk, that milk can’t go to market. That cow can’t be implemented with a treatment system. And that dairy farmer faces a significant economic impact.
So the FDA observes a much more tolerant standard, and the impact is transferred to those theoretical two people in 10,ooo.
If FDA has another explanation, as I said earlier, I’ll add it to this post.
I should point out, once again, that the administrators of both agencies agree that the radiation contamination levels in the U.S. are far below levels of concern.
EPA Administrator Lisa P. Jackson, in testimony before a Senate committee yesterday:
EPA has not seen and does not expect to see radiation in our air or water reaching harmful levels in the United States. While radiation levels are slightly elevated in some places, they are significantly below harmful levels.
From FDA’s Radiation Safety FAQ:
At this time, there is no public health threat in the U.S. related to radiation exposure. FDA, together with other agencies, is carefully monitoring any possibility for distribution of radiation to the United States. At this time, theoretical models do not indicate that significant amounts of radiation will reach the U.S. coast or affect U.S. fishing waters.
The EPA’s MCL is due for review in 2015. There have already been allegations that EPA plans to relax radiation standards. In the wake of this conflict of agencies, expect someone to try to relax the MCL for radionuclides.
Comment from Siobhan DeLancey of FDA Office of Public Affairs, sent 4/19/2011:
The EPA MCLs are based on consumption of water every day for a period of 70 years under “normal” circumstances where little to no radioactivity is expected. The FDA DILs are conceived for emergency conditions only and provide a level of contamination where protective actions should be considered to avert further dose from accidental (or terrorist) contamination of food. This averted dose is referred to as the PAG or Protective Action Guide and for food is defined as 500 mrem (5 mSv) whole body (CEDE) or 5 rem (50 mSv) to a single organ (CDE). It is not intended, under the FDA paradigm, that an individual would continually consume contaminated food for a full year. However, for risk estimation purposes only, we have determined that, if someone were to consume contaminated food for a year, he/she would receive a dose estimated at 500 mrem (5 mSv) committed effective dose equivalent (CEDE), which corresponds to an excess risk of cancer mortality of approximately 1 in 4400 above the baseline of 1 in 5 for all people before any excess radiation exposure.
The terminology “mortality tolerance” is not used in practice and should not be used to imply that FDA is willing to allow consumption of radioactive food based on an “acceptable” level of mortality in the population. Risk coefficients (one in a million, two in ten thousand) are statistically based population estimates of risk. As such they cannot be used to predict individual risk and there is likely to be variation around those numbers. Thus we cannot say precisely that “one in a million people will die of cancer from drinking water at the EPA MCL” or that “two in ten thousand people will die of cancer from consuming food at the level of an FDA DIL.” These are estimates only and apply to populations as a whole. Our protective action guides and derived intervention levels are designed to avoid excessive dose and limit the risk to individuals from contaminated food. Further, our values have such a degree of conservatism that even if one were to consume food at the DIL, it is not conceivable that he/she would actually receive the PAG of 500 mrem/5 mSv. FDA would implement and recommend protective actions/interdiction long before anyone received a significant dose.
Related Stories:
New Radiation Highs in Milk From Little Rock and Hilo, Hawaii
Radiation in Drinking Water in 13 More Cities, Cesium-137 in Vermont Milk
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This is from Lawrence Livermore Labs. It’s an evaluation study from April 2010 regarding the FDA’s DIL and PAG calculations from ingestion of radionuclide contaminants (with noted exception for infants). It’s worth a read on point, if only for additional documents cited:
https://e-reports-ext.llnl.gov/pdf/393663.pdf
Thanks, mothra, I’ll be reading that shortly.
Jeff: The UC/Berkeley Radiological Air and Water Monitoring team has just posted a MAJOR CORRECTION to its previous, preliminary milk testing results, and it’s not good. Here’s the link:
http://www.nuc.berkeley.edu/node/2174
In response to another comment. See in context »Thank you rickromack. That converts to 53.8 pCi/l. An infant limit adjusted (I-131, Cs-134 & 7 combined) dose = 10 liters.
In response to another comment. See in context »You’re welcome… Though I’m not pleased to be the bearer of this news.
The veil needs to come off, folks, just as fast as possible. If what I’ve learned about cesium, and this early “trend analysis”, is in any way legitimate / accurate… Things are about to get a whole lot worse, and not just for milk and all ITS products, but for leafy greens, mushrooms, meat and maybe a whole lot more. Meanwhile, our Government is silent, aloof, and apparently, unconcerned.
In response to another comment. See in context »Nothing worries me more than a regulatory entity that insists there’s nothing to worry about.
In response to another comment. See in context »Regarding UCB sampling, and how radionuclides bear out environmentally – keep an eye on the collected rain sample data. Locally we had a rain out yesterday and EURAD had prior posted a cesium concentration over California and the West Coast that appears to be moving S/SW. I’d expect cesium deposits to eventually show and bear up in their data. Any half-life clocks only begin when emissions cease, but this how it builds and why I feel any “decrease in level” expectations and memes are unreasonable. Historically, Washington saw this after Chernobyl too (Seattle population has increased since 1990 by 6x mostly from ingress since): http://www.davistownmuseum.org/cbm/Rad7c.html#USA
In response to another comment. See in context »And lo as expected, a little rain, a liitle more I-131 and Cs-134 & 7 deposits from April 14…
In response to another comment. See in context »http://www.nuc.berkeley.edu/RainWaterSampling
Mothra – does this mean that if an inant drinks a little over a liter of milk a day it will reach the Maximum Contaminant Level (MDL) in about a week? (at 1 Liter per day that would be 10 days, at 1.44 Liters per day it would be a week).
For nursing mothers and pregnant women doesn’t that mean this exposure may be passed to fetuses and infants too if the mothers drink this amount of milk?
Where is the concern?
In response to another comment. See in context »Also, isn’t this amount of radionuclides detected (forget for the moment ones like Stronium 90 that no one seems to be testing for), then, nearly SIXTEEN TIMES the permissible EPA limits for anyone?
What infant limit are you referring to(what is it and who set that limit)?
If the EPA limit is 3 picocuries per liter for everyone then this is very troubling news indeed and as the plume has brought the Fukushima rain across the entire country at relatively similar doses when it rains, aren’t we ALL above the limit if we drink milk and eat produce that has been rained on with radioiodine and radiocesium when you combine the doses?
In response to another comment. See in context »Just a note about the UCB data – please put this in perspective with the biochemistry part of my post below. While the measurements have been revised upwards, it’s important to note that, so far, “though all I-131 activities have increased due to this revision, the levels are still very low — one would have to consume at least 1,900 liters of milk to receive the same radiation dose as a cross-country airplane trip.”
Which actually points to something we ignore: the constant, daily exposure we all have to other kinds of radiation. X-rays and other imaging technology such as MRI, cell phones, TSA whole-body scanners, and flying all expose us to radiation, and nobody talks about it. One of my personal missions is to educate people about this, and to find things we can do to support our bodies’ health without having to live in a bubble or a Faraday cage.
In response to another comment. See in context »My DIL/PAG limit concerns:
1.) Not set for infants. (Discounts children’s low dose phenomena risk).
2.) Not including multiple pathway exposures including tap water, rain outs and air- intervention is set in isolation to other exposures.
3.) Dose limit thresholds are too high in conflict with shrewd safety precautions and multiple other agencies both domestic and global.
4.) Lack of testing for known contaminates and their accumulation across pathways (ongoing). * You have to find it before you can act.
5.) Assume a one size fits all consumption rate.
6.) Based on outdated data and models from 30 plus years ago. Frankly, we know more now.
Therefore, I find FDA limits unacceptable. I go so personally far as to ask if this is some cruel joke? Sincerest appreciation to Jeff McMahon!
In response to another comment. See in context »Mothra, the DIL is expressed in becquerels per kilogram, so more conversion is necessary, but I believe FDA did set the DIL at the level for the most vulnerable age group—one-year olds, according to FDA. The data is in Table 6 here; see what you think:
http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/ChemicalContaminants/Radionuclides/UCM078341
In response to another comment. See in context »Mothra stated the following based on UC Berkeley’s revised milk findings:
“mothra
Thank you rickromack. That converts to 53.8 pCi/l. An infant limit adjusted (I-131, Cs-134 & 7 combined) dose = 10 liters.”
IF her calculations are accurate, then doesn’t that mean that it will take like eleven days to reach the EPA annual limit of 700 picocuries per liter if one drinks a liter of this contaminated milk per day (not to mention eating the spinach or leafy greens and other produce that is contaminated)?
Or am I misreading yor numbers? (Again, assuming that Mothra’s numbers are correct).
In response to another comment. See in context »“Other methods of extrapolation to the low-dose region could yield higher or lower numerical estimates of cancer deaths. Studies of human populations exposed at low doses are inadequate to demonstrate the actual magnitude of risk. There is scientific uncertainty about cancer risk in the low-dose region below the range of epidemiological observation, and the possibility of no risk cannot be excluded (CIRRPC 1992).”
“The five groups are: Strontium-90; Iodine-131; Cesium-134 + Cesium-137; Ruthenium-103 + Ruthenium-106; and Plutonium-238 + Plutonium-239 + Americium-241. An accident could involve more than one of the five groups. A single DIL for each radionuclide group was chosen based on the most limiting PAG and age group for the radionuclide group (i.e., the most limiting PAG and age group result in the lowest DIL). These five DILs are the ones incorporated into the new CPG.”
No citation for “information received:”
“FDA’s decision to reduce the assumption for dietary intake contamination from 100 percent to thirty percent is the main reason that the guidance levels established in the 1998 FDA document and adopted in the CPG are higher than the guidance levels contained in CPG 7119.14.’
Beyond FDA disclaimers above (among others), I should explain the following integrated
considerations I take into account for infants that others widely do not;
1.) Radionuclide activity: length in the body, environmental release date ongoing assumption, behavior tissue/bone/glandular/hormonal not stationary to exhibited system, accumulation/concentration, compounded or cascading immune response between all pathways and exposures including air & water.
2.) Density (cold or warm)
3.) Risk/benefit nutrition
4.) Low dose threshold phenomena
5.) Percentage of diet realistic – not 10% x 3
6.) Length of introduction – suddeness of exposure not priorly introduced
7.) Baseline background already in epidemic
8.) Lack of regional testing
9.) Exclusion of expected, known or reported radionuclides (re: MOX) in concert (now uncontained uranium, strontium, plutonium recently) – pending
9.) Mental development
10.) Long term reproductive
11.) Proir dietary deficiencies known
*I use the “my baby” standard, not the 1989 ICRP computed to age 70 years from people who’ve neither met us nor are incentivized by us.
I feel 20 Bq/kg is a conservative, fair expectation (as set for uranium) to promote acceptable prevention in absence of data or integrative approach in what I’d call a “sitting duck” scenario. I really wonder how the guideline debate ever moved so far in this upward direction. It forces me to cherry pick in a downward direction to combat it. *Not that I’d expect pureness sans all convention, but these are unreasonably high limits based on very little – outmoded to current lifestyles and environmental realities.
Thanks again! You do rock
.
In response to another comment. See in context »You can spank me later, no criticism is unwelcomed or offensive in pursuit of the cause. I’m learning and this is all how I learn:
1.99 Bq/kg = 53.78 pCi/L
1kg = 1.04 liters = 1
20 Bq = 540.54 pCi
(uranium and/or “my baby” limit)
540.5/53.8 = 10
California milk consumption? Tons:
http://future.aae.wisc.edu/tab/sales.html#39
Do radionuclides transfer via breast milk too? Yes:
http://rpd.oxfordjournals.org/content/105/1-4/251.abstract
How much do babies consume? Lots:
http://kidshealth.org/parent/pregnancy_newborn/formulafeed/formulafeed_often.html#
What does the FDA set? Yikes:
http://www.fda.gov/downloads/NewsEvents/PublicHealthFocus/UCM251056.pdf
Is anyone discussing, testing or limiting all known nuclear event radionuclides? Not that I can discern.
In response to another comment. See in context »Thank you for pursuing this Jeff, and everyone.
I fear that we could also lose the forest for the trees. The EPA has already clearly stated that the only “safe” level of radionuclides in drinking water is *zero*. http://water.epa.gov/drink/contaminants/basicinformation/radionuclides.cfm. That is its MCGL standard. Its MCL standard is not purely based on human health; it takes into account a “cost, benefits and the ability of public water systems to detect and remove contaminants using suitable treatment technologies,” while, however, attempting to get “as close to the health goals (the MCLG) as possible.” The “safe” level is zero. Zero times 70 years is still zero.
Jeff’s post is technically correct when it states that “The EPA’s MCL Goal, by contrast, is ‘the level of a contaminant in drinking water below which there is no known or expected risk to health.’ ” But I’m not sure it comes across that there are two standards, and that the MCL Goal is a different standard from the 3pCi/L or 700 pCi/year MCL. The difference is explained below, using language from the EPA document linked above.
The 1974 Safe Drinking Water Act requires EPA to determine 2 different standards for contaminants (including radiological substances). The first, called the MCGL (“maximum contaminant level goals”), is “the level of contaminants in drinking water at which no adverse health effects are likely to occur.” This health goal is “based solely on possible health risks and exposure over a lifetime with an adequate margin of safety.” It is non-enforceable.
Then, EPA sets an enforceable regulation, called a maximum contaminant level (MCL), “as close to the health goals (the MCLG) as possible, considering cost, benefits and the ability of public water systems to detect and remove contaminants using suitable treatment technologies.” That’s the MCL – in this case, the gross MCL for beta particles. The standard is 4 millirems/year (or 700 pCi). This would be 49,000 pCi in a lifetime. 1 1/2 Liters of contaminated milk under the FDA DIL would exceed the EPA’s lifetime limit.
The real question here is: why is EPA publicly issuing statements that flatly contradict its public health-based determination that the only safe level is zero? Why are they instead reassuring people based on an administrative standard from another federal agency (which does NOT have the same mandate EPA does) that would exceed even EPA’s lifetime MCL allowance, and kills 1 out of 4400 people? (This is actually a significant mortality rate.)
In response to another comment. See in context »That is THE question! It’s very big news. I also want to know in a timely way: what’s in it, how much and when. The blanket assurances are moot otherwise.
In response to another comment. See in context »“Low dose” mortality projections based on Census data found so far:
In response to another comment. See in context »NYAS Chernobyl model:
2,153,000 affected total fatalities N. America (not adjusted for Mox plutonium fuel, population growth US West Coast and other cities, mileage difference to Ukraine, undocumented residents)
CDC Hiroshima model:
107,303 from cancer US alone (between 2 years to decades – not adjusted for population growth, Mox plutonium fuel, non-fatal cancer, other ailments or undocumented residents)
5% 1Sv cumulative chronic low dose CEDE – TEDE model:
15,559,000 US (same adjustments as above).
Also, ECRR estimate:
220,000 fatalities within 100 km radius of Fukushima alone.
*Sniffle, somebody, anybody, please prove me a total nutter.
Thanks for the article, Mr. McMahon. It’s a chilling assessment of how this nation’s so-called “security” — and the individual safety of its residents — is inherently undermined, even completely nullified, by a variety of political, public relations, and commercial considerations and interests. It makes me wonder: If, God forbid, a radiological device were exploded near the stadium on Super Bowl weekend, would the federal Government underplay its , so as to ensure the financial efficacy of the NFL, team owners, local businesses, etc.? Would the continuing viability of that city as a tourism, convention, and retail / manufacturing concern be of far greater importance than the continuing safety of its citizens and workers? Would tweeting radiological monitors be dismissed as “not really all that much of a concern” for the sake of avoidng uncomfortable questions and heading off a public panic?
…Based on the actions, or lack thereof, of this Government during the first month-plus of this continuing nuclear event, I would have to say: That’s EXACTLY how I believe it would all play out.
Thank you,Mr. McMahon, for what seems like the only intelligent and insightful and honest reporting on these issues.
The revised UC Berkeley numbers for milk are scary, as it had seemed as if their results were trending downwards. Now it seems the bioaccumulation of the various cancer-causing radionuclides in cows grass, milk, farm produce, is increasing so that when you add all of these radionuclides together, as you have pointed out in your coments to previous articles, the overal dosing is substantial and above what the EPA or anyone else (except you and perhaps UC Berkeley and a few other sources) are telling us officially.
What REALLY bothers me, though, is that our government finds it ACCEPTABLE that levels of radiation in our food and water and air may kill a certain percentage of us.
It is well known and the standard scientific model (no threshold below which there is potential risk of harm from exposure to radionuclides) that ANY increase in carcinogenic and mutagenic radionuclide exposure, primarily internally, will result in additional cancers and illness and deaths.
So how in God’s name can they say that the levels are “no risk” or safe or not enough to be worried about or for us to take some reasonable precautions? This is a crime in my opinion. NO deaths are an acceptable risk so that Nuclear power plants can risk polluting the entire earth with cancer causing radionuclides for profit and greed.
Thank you for your hard work and thanks also to those who add info here and to the UC Berkeley BRAWM team for there test results. The EPA and FDA and NRC have failed us here.
After some thought: they can say it because the term of risk and effects exceed their length of position (2-60 years) and the costs are personal to individuals and families only with effectively no recourse in courts (6 month tort reform limitation). Essentially, there is no intervention and remediation.
In response to another comment. See in context »You mean, mothra, that since we can’t sue for any damages to ourselves and our family and because the nuclear industry, environmental administrators and government regulators cannot be held accountable that there is no recourse whatsoever when the government and industry uses a standard that says: well, its safe as long as only X amount of people are likely to die from this.
This sounds unConstitutional to me and a violation of our human rights. It is a taking of our life, liberty and pursuit of happiness with no due process. Sounds more like a crime against humanity.
If there is no civil recourse should we be looking at criminal prosecutions in the international court of justice?
In response to another comment. See in context »I can’t answer to motives except my own: being early, safe low-cost exposure prevention based on informed choices. The key to that, and all efforts toward that goal, is open information despite possible inconvenience or perceived impediments. I advocate strongly for public disclosure. These are decisions best left to the individuals they affect all across a wide spectrum.
In response to another comment. See in context »Jeff, mothra, chargirl and rickcromack, I’ve been following this conversation since the previous thread and want to express my appreciation to each of you for intelligent, thoughtful research and commentary.
Regarding the differences between EPA and FDA levels: they are apples and oranges because EPA is about PROTECTION and FDA is about ADMINISTRATION. Protection, functionally, seems to run in both directions, meaning that EPA seeks to protect the environment from human excesses, and humanity from certain kinds environmental threats. EPA focuses on the long term, too.
Administration, on the other hand, assumes there’s something to administer. FDA has such a strong focus on reviewing and approving novel drugs and treatments that I wonder whether they haven’t lost the forest for the trees – even without the business/political agenda that rickcromack mentions above.
Epidemiologically, is 1 additional cancer per 4400 people and 1 additional death per 2200 people a lot? Probably not, but I’d bet that those numbers are just whistling in the dark. As was mentioned by someone on the previous thread, I doubt there are solid cause-and-effect data from which we can forecast outcomes.
This is for several reasons. 1) There just haven’t been that many nuclear disasters (thank God). 2) To find an effect, you have to be looking for it. My grandfather died of liver cancer in the 1950’s after having been on the US military’s inspection team following the Nagasaki bombing. Is his death counted in the epidemiological followup?
3) Because of what has happened to the American food supply in the past 2-3 decades, the average American is actually much less healthy now than at the time of Three Mile Island or Chernobyl. So even if comprehensive data were available globally from those incidents, it seems likely they wouldn’t be directly predictive.
Here’s why:
As I understand the biochemistry, cancer – with thyroid cancer a possible exception – isn’t caused so much by the radiation itself as by toxicity that, through a biochemical cascade, creates a change in gene expression. Even when exposed to fairly high levels of radiation, if the body has the ability to corral and excrete the toxicity, then those otherwise quiescent cancer genes will not be turned on. (This is a highly simplified summary.)
Being under stress of any kind activates the fight-or-flight response and changes how the immune and excretory systems function. For example, energy that would otherwise be used for deep liver detox is diverted into having more white blood cells in the skin to protect the body from infection – think wounds from animal teeth and claws. This is fundamental survival biochemistry at work in our human animal bodies.
That’s why, in the last thread, I mentioned finding ways to de-stress. It feels good and really helps your body deal with ANY toxicity (which we all have lots of), not just radiation.
The other thing everyone can do is stop (as much as possible) eating refined sugar and especially high-fructose corn syrup. They are toxic to the liver and compromise the immune system. Removing that load will free up resources in the liver and other aspects of the immune system to deal with other toxins.
My personal perspective is: our government has multiple agendas, but I’ll bet its primary one is keeping us from panicking right now. They don’t know what’s going to happen any more than we do. But rather than educating us on the real implications, they choose to divert our attention in an attempt to keep us calm. So the DIL levels get cited instead of the MCL levels because that way the actual, measured numbers don’t seem so scary.
Again, I deeply appreciate this conversation. Thank you, Jeff, for providing this focal point, and to everyone else for contributing.
The problems discussed here take on a far greater level of concern when one considers that the radiation risk models being used do not account for the biological fate of internalized radioisotopes, as well as the phenomenon of “photoelectric enhancement” which indicates that radiolytic decay is not soley responsible for the genotoxic and cytotoxic properties of these toxicants. There is a radiological and CHEMICAL interaction on the cellular level, the latter of which may increase damage by several orders if magnitude higher than the radiation alone. This video covers the basics if thus topic http://www.youtube.com/watch?v=fJ4JvQvQ0E0&feature=youtube_gdata_player
Thank you for this article. As concern grows over the risks associated with both external radiation and internalized radioisotope exposures, it is of extreme importance that the public take the necessary precautions. The US National Library of Medicine and the National Institutes of Health contain a good body of rsearch on natural substances which are radioprotective (e.g. turmeric, propolis, vitamin E) and/or enhance radioisotope excretion (e.g. apple pectin used in 160,000 Chenobyl children). For the first hand peer-reviewed research http://www.greenmedinfo.com/pharmacological-action/radioprotective
In response to another comment. See in context »Thank you greenmed! I’m baking New Zealand tart apple pie now with chilled coconut oil crust – supremely flaky
. Had you seen this list of preventative supplements too? I see cross-overs:
In response to another comment. See in context »http://drmpatterson.vpweb.com/Newsletter-Archive.html
Thank you all for keeping on top of this important topic. It’s all about the money. Seriously, if the government told the public today that we are being exposed to large amounts of fallout through multiple channels, everything you eat, drink, and breathe, what would happen? Widespread panic, collapse of the economy, and worse. There’s nothing they can do about it and economics requires ignoring or downplaying the situation. The government’s plan for high levels of radiation = population reduction.
Jeff, sorry, I posted this first on another thread, then saw your request to “move the conversation here”. Apologies for the redundancy… But I think it’s important that SOMEONE say this:
I worry that EPA’s misunderstanding the nature of the situation, and relying overmuch on NRC / DoE’s assessment of the risk of continuing measurable RELEASES from Fukushima, and NOT the inherent nature of the radionuclides that are now ubiquitous to the northern hemisphere.
While it may well be true — and we should all be hoping and praying — that the “worst” of radionuclide emissions from Fukushima has now passed, being concurrent with those large explosions (and, perhaps, actual fires) we saw several weeks back… There can be no doubt that there is a CONTINUING release of iodine, cesium, and perhaps other known cell-damaging isotopes from Fukushima. Given the plant’s location, prevailing wind patterns, the nature of the jet stream and North America’s position “in the mouth of the shotgun barrel”, so to speak, it’s obvious that much of what has been, is being and will continue to be emitted from Fukushima will impact the U.S. and Canada “first and worst”. Although relative to those explosive releases, the continuing, sustained emissions of continuing nominal reactive processes at Fukushima may well be slight, they WILL remain for the foreseeable future, perhaps even decades or years.
Yet EPA insists that this is a “short-term” event.
Furthermore: Let’s assume, for a moment, that the authorities and operators at Fukushima HAVE hammered down day-to-day emissions of iodine, cesium, tellurium, etc., to near-zero. There’s still a whole lot of this stuff in the atmosphere, and it won’t simply dissolve into thin air, as the media seems to seriously believe (I’m not sure more than one in a hundred so-called “journalists” comprehends the MASSIVE difference between the definitions of “dispersion” and “dissipation”). It will do two things: SPREAD OUT and SETTLE, largely in that order. Where will it settle? Not the moon, folks; it’s going to come down to the ground, ALL of it, eventually (a process that may well take decades, even for the “minimal” amounts we’re seeing). When it hits the surface of the earth, it will aggregate / concentrate — no more so than in water and, ultimately, in everything that water touches, feeds or surrounds: Namely, EVERY SINGLE THING IN THE FOOD CHAIN. So, even long AFTER this so-called “short-duration” event ends, cesium, for example, will continue to be present, and in ever-INCREASING volumes, in plants, potable water sources, and, perhaps most concerningly and with the greatest longevity, in animals… specifically, meat products.
This is no “short-term” event, not by any stretch of the imagination. This is going to be a constant, persistent, increasing threat to the food chain and to us. So these estimations of “10% contamination” of the food chain are ludicrous, unless somehow a 300-million-population nation manages to import 90% of its food products from South America or sub-saharan Africa or Australia; and a “1-year” timeframe is equally spurious. And it’s about time someone said so, publicly.
…There’s something else not being talked about, too. I have a friend who specializes in environmentally-friendly architecture, and he’s spent years designing and retrofitting buildings to be more efficient in terms of water consumption. Some of them utilize cisterns to collect rainwater, that is then filtered and repurposed into the building’s general supply. So it’s entirely possible — likely, even — that recent rainwater, which is one of the most heavily contaminated media out there at present in terms of iodine and cesium concentrations, is being “consumed” by a lot of people without them ever realizing it — coming out of faucets and hoses, existing in toilets (not a big risk there, admittedly) and dishwashers, and perhaps even making its way into drinking fountains.
…And, of course, let’s not forget: Most of our produce has at least SOME interaction with rainwater, even when that produce is grown in greenhouses — how many farmers do you know who DON’T have cisterns? Not to mention, ponds, water troughs, etc.
The U.S. Government is whistling past the graveyard, folks, by refusing to advertise or even acknowledge these issues and facts. I hope THEY’RE sleeping well at night… I’m sure not.
In response to another comment. See in context »So, I’ve looked all over the EPA’s website to verify your claim that their highest allowable level of iodine-131 is 3 picoCuries per liter, but I haven’t found anything. Would you mind posing your source?
Hi commenterguy. You can find a clear, recent expression of that maximum contaminant level here:
http://www.epa.gov/radiation/japan-faqs.html#rainwater
There are a couple of reasons why you may have had trouble finding the number. 3 pCi/L is the maximum contaminant level for all beta and gamma emitting radionuclides combined, so it’s often not expressed solely in association with iodine-131. And 3 pCi/L is a compliance standard EPA uses in pursuit of its true, hard limit for radiation exposure from those radionuclides, which is 4 millirem per year. So the same standard is sometimes expressed with different labels and different numbers.
In response to another comment. See in context »Mr. McMahon, there is an important error in your article. The EPA MCL is set so that if 1 million people were exposed to that dose, with the typical assumptions of the model, there would likely one additional cancer occurrance, NOT fatality. Additionally, you fail to differentiate between the MCL and the MCL Goal. While it is true that the MCL Goal is set at a level at which no adverse impact to human health would be expected, the MCL is set at a level that is both protective of human health (typically at or below the 1 in 1 million cancer risk level) and achievable with current treatment technologies. Finally, though it may be sobering, it is worth noting that the lifetime cancer risk is 1 in 2 for males (44%) and 1 in 3 for females (38%). I realize the purpose of the article is to imply a government conspiracy, but I do not see any evidence of it, if all the facts are taken into consideration.
First, it would be helpful if you would provide links for your assertions or citations so that readers can see what authority you are relying on. Mr. McMahon has done that.
Second, the current cancer pandemic is due in large part to the continuing contamination of our environment by radionuclides emissions and releases and “escapes” from commercial nuclear power plants, nuclear bomb tests, and other accidents and incidents according to many scientific bodies such as the Nobel Laureate Physicians for Social Responsibility, the Radiation and Public Health Project ( http://www.radiation.org ) and the European Committee on Radiation Risk, as wll as the NY Academy of Sciences recent publication on Chernobyl.
ADDING more radionuclide burden to our environment and to our bodies (especially children, infants, pregnant women and fetuses is insanity and criminal). For government and industry to downplay this risk and encourage exposures which harm us is likewise what I would consider a crime against humanity. Females are more susceptible to radiation harm as are fetuses and infants and children (as your stats make evident, I would assert).
Industry manipulates government to allow the contamination of our country and our planet for pure profit and greed. But when they KNOW it will kill a certain percentage of us and they cover that up or downplay it or obfuscate, it becomes a criminal “conspiracy” . Is that what we have here? Look at Tepko? Think they are concealing and obfuscating? Think they are downplaying the risks there in Japan? Why would industry be any different here in the US? Why would the industry NOT have an incentive to influence the EPA and NRC and FDA and Congress to hide the potential risks and harm already happening?
In response to another comment. See in context »Here are the references. I’m not sure how the rest of your comment relates to my effort to clarify some facts.
Page 70, starting at (A) 2. – (http://edocket.access.gpo.gov/cfr_2003/julqtr/pdf/40cfr300.430.pdf)
Click the “1″ on the chart or scroll 3/4 of the way down (http://water.epa.gov/drink/contaminants/index.cfm#1)
(http://www.cancer.org/Cancer/CancerBasics/lifetime-probability-of-developing-or-dying-from-cancer)
In response to another comment. See in context »Macamadamia, you are correct when you point out that Mr. McMahon’s article does not clearly distinguish between the MCL and MCLG. However, this actually increases the concerns raised by his article. The purely health-based MCLG acknowledges that the only safe dose of radionuclides is zero. http://water.epa.gov/drink/contaminants/basicinformation/radionuclides.cfm. The MCL of 4 millirems max per year (which EPA has stated would arise from exposure to 700 pCi per year) takes into account considerations like cost, and is less protective than the zero MCLG. If true that the MCL only allows 1 cancer (as opposed to one fatal cancer) per million, or less, then FDA’s DIL is even more grossly disproportionate. Leaving aside other health effects, a common rule of thumb is 1 nonfatal cancer for each fatal cancer. This means the FDA would permit at least 1 cancer for every 2200 people before intervening. That’s over 140,000 Americans.
You are wrong to compare the issue here to the “background” level of cancer, which as liberationangel points out below, is artificially raised by humans through such activities as thousands of bomb tests, nuclear power plant releases *and* accidents, x-rays, CT scans. medical radiation “therapy”, etc., etc. The problem we currently face is the number of deaths, cancers and other health effects that will be caused by fallout from THIS nuclear accident. Using a standard that allows for the death of 1 person in every 4400 to respond to this crisis is indefensible. (Note: I do assume here that you don’t think deaths from cancer are a good thing.)
Your implication that the “purpose’ of the article is to show a government conspiracy is totally unsubstantiated and a distraction from the real issue: is the fallout we’re being exposed to from our air, food, and water “safe”? What is the government doing and saying about it? Are their statements accurate? Might they, as human beings, make any mistakes?
In response to another comment. See in context »Deepest thanks and appreciation chargirl.
In response to another comment. See in context »I would say my pleasure, but of course this accident is anything but that.
I really appreciate your posts, new documents and detailed analysis of the documents and DILs. I wonder if you’ve managed to make any headway in coming up with a realistic estimate of true doses when radionuclides are ingested internally? I would value your work on that issue, if you’ve done it.
My understanding is that all of our governmental standards (including the EPA’s) are based on the ICRP’s model, which was not designed for nor based on data from internal emitters, but on external exposures (i.e., the Hiroshima and Nagasaki studies). I have not yet found time to start looking at other research that might provide a more realistic estimate. Have you seen this book, which contains a section on internal emitters? John W. Gofman, Radiation & Human Health: A comprehensive investigation of the evidence relating low-level radiation to cancer and other diseases (1981). John Gofman was a medical physicist and specialized in the health effects of ionizing radiation. Bio on the nytimes website and here: http://www.ratical.org/radiation/CNR/JWGobitLAT.html. He was part of the Manhattan Project while in grad school for chemistry at UC Berkeley, then went back to med school and made major discoveries in heart disease research before turning to study radiological health starting in the late 1950s/early 1960s. He headed LLNL’s first radiation biology lab.
In response to another comment. See in context »Beyond what I’ve posted from CDC, Lawrence Livermore Labs and my pending “answer from Oak Ridge Encironmental and Bioscience facilities, more on ingested radionuclides is generally sourced (PSR) in a recent article by CNET entitled “What does ’safe’ mean in a nuclear disaster,” and the NRC funded the NAS BIER VII mostly external low dose opinion here:
In response to another comment. See in context »http://www.dep.state.pa.us/brp/radon_division/BEIR%20VII%20Preliminary%20Report.pdf
*In a nutshell, this is an unprecedented ton load. It poses substantial risk, but they don’t know.
Based on a dated event study (Hiroshima et al under 200 ton load), the ICRP in 1991 issued the estimate that chronic low dose mortality is 5% per each 1 Sv of cumulative exposure. The NRBP 1996 published models that include ingested contaminates from food to that total. I’m combing volumes and have stacks to get through, but it isn’t insignificant impact, especially considering quality of life for non-fatal cases beyond 5%. Chronic low dose matters – a lot. Geez, I need a nap.
In response to another comment. See in context »Thank you very much for all this information mothra. I’m so grateful for your work. Will read those studies this weekend. It is a steep learning curve, isn’t it? It would be nice to be able to rely on the EPA at this time, but given their (in)action so far, I cannot. Did you know that during Chernobyl, EPA was holding press conferences every day? Maybe I mentioned that before.
I am tired also; I have decided to step away for the night. Take care.
In response to another comment. See in context »I think we’re asking what portion these internal CEDEs (committed equivalent dose estimates) mean integrally toward TEDE (total equivalent dose estimate) in a chronic, low-dose aggregate population exposure by multiple pathways. Some must know, since it appears Oak Ridge has this information and assessment capability and has for a long time, but I expect it’s not public, open information – yet:
In response to another comment. See in context »http://www.osti.gov/bridge/servlets/purl/6476084-ykcFlR/6476084.pdf
Mr. Macamadamia, thank you so much for your comment, for your challenge, and for your pursuit of important detail! All are welcome here.
You’re quite right that the EPA considers both mortality (fatal cancer) and morbidity (cancer whether fatal or not) when it calculates an MCL, and the MCL’s goal obviously is to reduce both. This makes the MCL an even safer standard in comparison to the FDA’s tolerance of two fatalities per 10,000 people.
(Also, the post is not exactly in error, because a non-fatal illness is still not more than one death. But perhaps I did oversimplify.)
Next, it’s good of you to create space here for discussion of the difference between the MCL and the MCL Goal. These matters are filled with nuance, as I think you know, and it’s always difficult to determine what to include and what to omit in what must necessarily be a brief blog post. The posts shouldn’t read like EPA regulations, after all. One beauty of comments is the ability to explore nuances further.
The MCL differs from the MCL Goal not only because of what is achievable with technologies, as you say, but also in response to cost-benefit analysis, as I mention above.
Regarding your final comment, I can’t imagine where you got the idea that the purpose of this post is to imply a government conspiracy. You didn’t get it from me, because I don’t believe there is a government conspiracy at work here. A discrepancy between FDA and EPA? Yes. A conspiracy? No. If you do see a government conspiracy in the backward masking of this post or anywhere else, I would be most appreciative if you would not attribute it to me.
Please do continue to contribute your detailed, informed, and challenging perspective to this forum.
In response to another comment. See in context »Jeff
Would you care to comment on the comparison of ingested radionuclide risks to things like flying cross country, which many authorities (and even US Berkeley BRAWM team) uses? I think it would make a worthy blog entry.
The difference between ingesting radioiodine or radio-cesium or strontium 90 (which bioaccumulate and are the toxic deadly “gifts” that keep on giving) and getting external exposure by flying or even an xray is huge.
First of all, excellent investigative work again, Mr. McMahon. You’re doing exceptional old-fashioned gumshoe journalism.
I’m personally tired of being a potential statistic that’s coldly tossed onto the cancer pile.
I’m also concerned with the potentiality of Fukushima occurring closer to home:
1. In 2010 alone, there have been 14 “near-miss problems” in nuclear power plants in the United States:
http://www.huffingtonpost.com/2011/03/17/us-nuclear-power-near-misses-2010_n_837176.html#s254851&title=HB_Robinson_
2. Three nuclear power plants rate a 3 out of 5 in safety (Fort Calhoun in Nebraska, H.R. Robinson in South Carolina, and Wolfe Creek in Kansas) and there are even cracks in the Crystal River nuclear power plant in Florida http://www.tampabay.com/news/business/energy/crack-at-crystal-river-nuclear-power-plant-explained/1119240
3. Outside of the U.S., there have been problems in nuclear power plants to the north of us in Canada:
http://www.globalpost.com/dispatch/canada/100628/nuclear-power
and to the south of us, in Mexico:
http://www.globalissues.org/news/2011/03/30/9088
and globally:
http://www.guardian.co.uk/news/datablog/2011/mar/14/nuclear-power-plant-accidents-list-rank#data
And therefore it makes this even more concerning:
According to this article, the United States health care system is unprepared for a nuclear incident and even stopped purchasing iodine for stockpiles 2 years ago.
http://www.propublica.org/article/us-health-care-system-unprepared-for-major-nuclear-emergency/single
This is completely unacceptable and unbelievable.
I hope, perhaps naively so, that our gov’t immediately prioritizes readiness and safety.
A *very* interesting and potentially important development broke yesterday and continues to unfold. It quite possibly relates to the ongoing contamination of milk with radioactivity.
Yesterdday Reuters and other sources reported that the EPA was suddenly relinquishing its authority over toxic milk spills by the nation’s dairy producers. http://www.reuters.com/article/2011/04/13/us-usa-epa-milk-idUSTRE73B7GR20110413 (“EPA exempts milk from spill-control rules”). It did so with approval from the White House.
EPA’s revised Spill Prevention Control and Countermeasure regulations would have required agricultural producers have an oil spill prevention plan in place and notify emergency responders. Now, “[t]he government will exempt dairy farmers … said the Environmental Protection Agency on Tuesday, a step applauded by dairy producers.”
“That exemption is now — today — finished with White House review and will be published today,” said Jackson. The rule would have required to have dairy farmers to have a plan on how to contact emergency responders in case of an on-farm oil spill (including milk, due to its animal oil content). For farms with aboveground storage capacity of more than 10,000 gallons of oil or oil products, the EPA would require that the SPCC plans be developed by a professional engineer.
Senator Chuck Schumer (D-NY), who had pushed for the change, noted that the rule was “intended for toxic substances” and milk is already regulated for quality. Yep, by the FDA – whose unprotective DILs we’ve been discussing. [note: Schumer's home state is 3rd in dairy production nationally.]
One of the reasons cited by dairy producers for exemption was that “Milk is not a contaminant or pollutant.” http://www.prnewswire.com/news-releases/statement-from-idfa-president-and-ceo-connie-tipton-on-epas-decision-to-exempt-milk-and-milk-product-containers-from-oil-spill-prevention-rule-119784434.html. Except that now, of course, we know it certainly could be: if it contains levels of radionuclides above the EPA standards. This is very likely in states like California, the largest dairy producer.
Of course, several of the milk test results we’ve seen nationally would be considered toxic under EPA rules – but, as we’ve been discussing, NOT under the FDA’s guidelines. And now the EPA has ceded control to the FDA.
Given that national milk tests have shown radioactive contamination in many states, this is peculiar timing, to say the least.
Thank you Rick, for pointing us to a significantly upgraded levels found in California milk from the revised UC Berkeley’s milk contamination test results. What mistake had the UC Berkeley researchers made originally? (Sorry, I haven’t had a chance to review and analyze yet).
I am not sure what relation this might have to the issue of disposal of contaminated milk I’m raising in the above comment. But today, the USDA announced an 8-state pilot initiative to “assist” agricultural producers that have “aboveground storage capacity of more than 10,000 gallons of oil or oil products.” “The NRCS initiative offers a set payment for producers that use a certified Technical Service Provider to develop a SPCC conservation activity plan that meets” “revised Environmental Protection Agency (EPA) regulations for on-farm oil spills. The Natural Resources Conservation Service is accepting applications for the Spill, Prevention, Control and Countermeasure pilot initiative through May 20, 2011. http://www.agweekly.com/articles/2011/04/14/news/ag_news/news87.txt
In response to another comment. See in context »chargirl: You’re welcome. If I understand the BRAWM team’s explanation correctly — and I may not — in their initial presentation of data, they failed to account for the predictable degradation of certain short-lived isotopes (I-131, for example) over the “life” of the sample and were not using a consistent model to establish “original” radioactivity. I now believe they have accounted for this and are publishing results with regard to “bottling” or “processing” date, not purchase date, test / analysis date or “best by” date.
This brings up an interesting question: How long does it take for milk, once it leaves the animal, to end up in the bottle? One must assume that, if said milk were tested at the moment it was “created”, certain values would be higher still — perhaps considerably higher.
This is a perfect argument for why the Government and ALL its relevant agencies should be all over this, establishing common standards, enforcing rigorous testing protocols, disseminating information promptly and transparently, and offering up entire battalions of scientific, medical and technical assets prepared and instructed to fully inform and (if possible) reassure the public as to what is being done, what precautions are being taken, what considerations should be made, what behavioral advice is sensible (if any), etc. Instead there’s just a great, big, silent shrug, and, if you listen closely enough, a low, mocking laugh.
In response to another comment. See in context »Thanks much for the summary Rick.
Wow. That’s kind of a big & basic mistake. It’s one EPA had already made and corrected for its results by the time BRAWN posted its food samples, so I’m pretty shocked that BRAWN made this elementary error. No pun intended. Not that I’m any less grateful for their continuing monitoring efforts, but this shakes my confidence a bit. Have they corrected other samples for the same error?
While I would still give cautious credence to their sampling results, I could *not* say the same about their radiological health conclusions and statements. The team does not seem to distinguish between internal emitters versus external emitters in terms of expected doses, and at least once to my knowledge, members of the team have made grossly inaccurate statements regarding the basic biology and health consequences of radioisotopes: i.e., one BRAWN member stated in response to a posters concern about radioactive xenon levels that xenon is “not absorbed by the body” and therefore will not have negative health effects. In fact it is absorbed by the body through the lungs and deposited in adipose tissue, as has been known in the medical community for over 40 years. I will point out that when shown this evidence, he admitted he was wrong. I’m not trying to diss the team, just want to encourage people to take their health claims with a grain of salt. They are nuclear engineers, not medical physicists or radiobiologists.
In response to another comment. See in context »chargirl: You’re very welcome (such a strange sentiment when discussing such morbid things), but, again, please check out BRAWM’s own explanation of this correction [http://www.nuc.berkeley.edu/node/2174] — I may not have a full, or even accurate, grasp of what happened, there. To paraphrase Patrick O’Brian, no man could easily surpass me in ignorance of matters of science. I would hate to help degrade the UNCBE team’s reputation by virtue of my own big, stupid mouth.
That being said — they are working their tails off, and I’m certain are under an enormous amount of stress and pressure. As I have repeatedly told them, I would feel a heckuva lot better about our Government if I thought for a moment that any member of it, at ANY level, was toiling as faithfully, diligently, determinedly, and graciously as the good folks at UCB’s Nuclear Engineering Department. If only one of them would run for something… Or if the people who DID run for things had more qualities in common with BRAWM.
I do not believe they have needed to correct any other samples. I would be confident in their immediate disclosure of such a thing, if it were ever necessary.
Rather than shaking your confidence, let’s look at this through the other side of the glass: They’re not only savvy enough to go back and reconsider their methods and conclusions — even, review their already-”published” data — but they made no secret of their error, went out of their way to describe in painstaking detail their mistake, and promptly disclosed EVERYTHING in the most public fashion possible, regardless of the potential impact to their current sterling reputation. That’s integrity, folks, and something more: Accountability. I rather think this incident points out how very much trust and faith we ought to have in them. Let’s face it: Such an act would be UNHEARD of coming from just about any governmental body, corporation, oversight agency, industry group, or public figure you could possibly name.
In short: It’s the way we handle our screw-ups, that reveals our character. ESPECIALLY when you COULD “get away with it”, or bury it, or simply refuse to acknowledge it, with no one the wiser.
…I’m not comfortable with ANYONE’s estimation of the potential impact of this ongoing nuclear event, so, I hear ya there. We’re all canaries in the coal mine, now, if not outright guinea pigs. And, you know, whether they be nuclear engineers, radiobiologists or members of Dionne Warwick’s Psychic Friends Network, there are really NO “wise old men, not when it comes to this, not yet. There will be, though; you can count on it.
They are nuclear engineers, not medical physicists or radiobiologists.
In response to another comment. See in context »Has anyone found any standards for milk on how long the usual interval is from cow to bottle? I searched, but found only small ’boutique’ dairies delivering locally nationwide. Are there USDA standards that anyone can find?
My gut guess is that for a large dairy it may be several days, even a week, particularly since, once pasteurized, milk remains stable for quite a while after its “use by” date.
This time period really affects the I-131 load calculation.
In response to another comment. See in context »Additional background is provided by this article published yesterday in the New York press: http://www.empirestatenews.net/News/20110413-6.html
“The Clean Water Act was passed in 1972 in order to protect the nation’s waters from dangerous pollutants which can be harmful to public health. The law gave the EPA the authority to enact the Spill Prevention, Control and Countermeasures (SPCC) program, first promulgated in 1974, which aims to ensure that dangerous toxins are stored safely and that any large spill is cleaned up in a responsible manner. Essentially the provisions required entities that handle toxic oils to have a plan to clean them up in the event of a spill.
The SPCC rules were revised in 2002 but left considerable ambiguity about the regulations’ impact on milk, which can be considered a non-petroleum oil because of its butterfat content. In 2005, an EPA presentation made clear that the current SPCC policies could be applied to milk. Since then, milk producers have been working to ensure that EPA regulations don’t apply to milk producers. The Bush administration proposed a rule to officially exempt milk producers from any SPCC regulations, but the rule was held up as part of the Obama administration’s complete review of all EPA rules proposed under the previous administration.”
…
“Today’s final exemption applies to milk, milk product containers, and milk production equipment. In addition, because some of these facilities may still have oil storage subject to the spill prevention regulations, EPA is also amending the rule to exclude milk storage capacity from a facility’s total oil storage capacity calculation. The agency is also removing the compliance date requirements for the exempted containers.”
…
“The Environmental Protection Agency (EPA) has agreed to exempt dairy farmers from provisions of the Clean Water Act that, since 1970, have required them to develop and implement plans to handle a milk spill … Schumer has long fought for this EPA regulation to change, [on the argument that] the intention of Congress in these regulations was meant to apply to toxic substances … Schumer added, “The EPA’s exemption of dairy farmers is a huge victory, as it is a major step towards providing security to the milk producers that are so important to Upstate New York’s economy.” “Schumer has long worked to ensure that dairy farmers are not hit with added costs due to new, unnecessary regulations, so that Upstate New York producers will have the security they need to produce high quality milk and make a living for their families.”
Unfortunately, this security may come at the cost of millions of other families in New York state and around the country. What happens, for instance, if radioactive milk is dumped directly on the ground, to make its way into groundwater and rivers and streams? Or be taken up again by grass or other plants and animals? Right now, we have an opportunity to collect and remove radioactive particles from milk and from the food chain, and store it as safely as possible, and the EPA is throwing this opportunity away.
U.S. Sen. Charles Schumer said: “Everyone knows that when Congress enacted these laws it was targeting massive oil spills and toxic substances, not an accident involving milk.”
But now everyone knows that things have changed, and milk cannot be presumed free from radioactivity. Why would EPA choose NOW to give up its jurisdiction over this toxic waste?
In response to another comment. See in context »I think I should rephrase my question. According to what I have read so far, the rule exemption has been in the works for a very long time. It was a final-hour rule exemption issued by the outgoing Bush Administration; Obama’s Administration held it in abeyance while it reviewed the very large number of rules issued in the final days of the Bush team; Schumer and other NY legislators pressured EPA to approve the rule exemption, based on the argument that milk “wasn’t toxic”; EPA may have given the go-ahead on the Bush rule this February. Since then nothing has happened. For some reason, Obama approved it yesterday. Same question though: why would Obama choose NOW, when we have evidence that milk actually can be and has been proven to contain toxic substances, to issue an exemption which does not serve the public interest. What’s the big hurry when there are so many reasons to wait?
I realize that this new development raises a new problem beyond the question “what can I safely feed my family?” I don’t want to detract from that question. However, it does relate to the question of “what will my government do to protect me?”
In response to another comment. See in context »It’s unacceptable. At a time when radionuclides are detected and not decreasing? It’s only starting to be reported. It’s ongoing – currently increasing. That milk would be exempted in this way yesterday is jaw dropping for me. I don’t know why – it’s hostile. If I had to guess, I imagine it’s one way to erode regulation and promote a surface clean appearance, or reduce lifting the lid on it? You’re right, it’s not in the public interest – at all. Obama is committed to nuclear as clean energy by his SOTU speech and he reiterated the comittment in a lawn speech before he left for Brazil. Is this one way to keep nuclear “clean” – by not looking at the dirty?
In response to another comment. See in context »Yes, my guess is that this is EPA’s attempt to sweep the issue under the rug by handing the reins over to the FDA, whose “standards” would be laughably high, if they weren’t so lethal. Otherwise, EPA would be in charge of such spills, and I assume (though am not 100% sure) that their more protective standards would apply. It is expensive to dispose of radioactive waste, after all. So why not just send it right back into the food chain? I have called my Senators and Representative about this and about the EPA use of FDA’s standards (will talk to staffers on Monday), and will be calling Obama’s office and EPA on Monday. If I had had any idea this was in the pipeline I would have asked for their intervention beforehand. It’s a slap in the face that Obama has taken this action. And it’s amazing that the Reuters reporter didn’t think to ask a single question about this exemption, either.
The other horrible consequence of EPA and FDA not doing any testing is that future epidemiological studies of these exposures will be nearly impossible, or at the very least of compromised value. So the next time this happens, we’ll be in the same position of not being able to conduct an informed risk assessment. It’s infuriating.
In response to another comment. See in context »http://articles.lancasteronline.com/local/4/375988
Don’t apply the lower exceeded EPA safety standards to it or anything. Just exempt it and feed it to babies, or throw the radiation anywhere? Just unbelievable.
Thank you Jeff McMahon, chargirl and PEER perpetually for the heads up – so far in advance of public recognition.
In response to another comment. See in context »Some simple math that doesn’t add up
EPA annual MCL for iodine-131 is equivalent to 700 pCi/l
EPA MCL for iodine-131 is 3 pCi/l
2 Liters per day = 6 pCi * 365 = 1095 pCi per year.
Questions:
1) What am I missing here?
2) 700 pCi/l = 4 millirem dose… so you could only drink a total of ~1.91 pCi TOTAL of drinking water and milk combined to hit the dose.
3) What about combined dosages exposure to from multiple sources including water, milk, and food?
4) Water is used to produce other drinks as well, what about radiation in those sources?
Obviously radiation dosages will be received from milk, water contaminated by radiation and/or urine from cancer patients depending on whether or not you believe the official explanation of where radiation in drinking water is coming from and radiation doses from multiple sources of food which is currently being sold to unknowing consumers.
Radiation doses will also be recieved from iodine, c-134,c-137, and the array of other isotopes being tested and/or not being tested for (for example it appears the EPA is testing for i-131 in the drinking water as if the other isotopes don’t matter). And while we see UCB monitoring certain food stuffs, there will radiation in other sources of food. For example the cow that made the milk for will have a healthy dose of radiation. UCB shows cesium accumulating in grass by a factor of 5 compared to the surrounding topsoil.
So even we were talking about multiple doses from multiples sources under federal guidelines, those multiple sources give a combined dose of radiation which can quickly surpass federal limits.
And clearly we are already seeing contamination at multiples of certain federal guidelines and Japan is talking about spending the next 3 months just trying to keep the amount of radiation being released from increasing, no talk of any plans of taking any steps to stop it until then.
Alexander, Sorry about the delay. I just found your comment in the spam trap. Regarding your question about numbers not adding up, I think you already have the answer: that the numbers don’t add up.
The two MCLs we’ve seen 3 pCi/L for drinking water and 700 pCi/L for the annual dose, are agency approximations of the EPA’s true maximum for radiation exposure, which is 4 millirem per year.
3 pCi/L is the MCL EPA uses when regulating municipal drinking water systems. It assumes people are drinking two liters of water per day. It’s not clear whether 700 pCi/L assumes the same level of consumption on its way to that annual limit.
They are two efforts by EPA to keep people below 4 mrem per year, two unique expressions of an agency saying, “this much is too much.”
Both MCLs are decades old. The 3 pCi/L limit seems to derive from the National Book of Standards, published in 1959, which set occupational exposure limits. The 700 pCi/L limit is a calculation from a 1986 proposed rule published by EPA.
EPA plans to revisit and possibly revise the MCL for radionuclides in 2015. Stay tuned!
In response to another comment. See in context »http://www.idealist.ws/index.php
a good read on strontium, jeff.
i encourage you to read it
Government conspiracies to suppress information?
The Guardian is reporting today on how both the US White House and BP sought to control research on, and media exposure about, the scope and severity of the BP Gulf oil Spill.
Story Title: “Emails expose BP’s attempts to control research into impact of Gulf oil spill: Documents obtained under the Freedom of Information Act show BP officials discussing how to influence the work of scientists”
Here is the link to the memos that the Guardian is posted. They were obtained using the U.S. Freedom of Information Act http://www.guardian.co.uk/environment/interactive/2011/apr/15/bp-internal-meeting-notes
Here is the Guardian’s story http://www.guardian.co.uk/environment/2011/apr/15/bp-control-science-gulf-oil-spill?intcmp=239
Detail from story:
“Other documents obtained by Greenpeace suggest that the politics of oil spill science was not confined to BP. The White House clashed with officials from the National Oceanic and Atmospheric Administration (NOAA) and the Environmental Protection Agency (EPA) last summer when drafting the administration’s account of what has happened to the spilled oil. On 4 August, Jane Lubchenco, the NOAA administrator, demanded that the White House issue a correction after it claimed that the “vast majority” of BP oil was gone from the Gulf. A few days earlier, Lisa Jackson, the head of the EPA, and her deputy, Bob Perciasepe, had also objected to the White House estimates of the amount of oil dispersed in the gulf….”
Excellent points Majia!
Thanks for that.
The use of the term CT for “conspiracy theory” as a disparaging term or even a meme has its roots in disinformation and propaganda to ridicule even the possibility that corporate or military or government entities want to “spin” the truth or even distort it when they do improper, bad or even evil things.
Spinning is a fine art, but if you allude to it when the data is outright false or dangerous you get labelled a “conspiracy theorist” and so in one quick retort ALL of what you may say is ridiculed or denigrated.
If there is ANY doubt that TEPCO and international agencies set up to support nuclear power (where they make all their profits and need to cut their losses here on global nuclear power business ventures) are spinning the info, THAT would be hard to fathom.
Corporate influence at the EPA and FDA is HUGE, even in this administration, and those corporate entities profitting immensely from nuclear energy policies and regulations have been at this for years to maximize their profits at the expense of the human race.
GREAT point you make here. Call it “conspiracy theory” if you want to demean those who speak truth to power, but only a fool would think that it is not greed and profit and power that determine how we are fed the information like stupid sheep so that those who profit from our ignorance and peril can keep their power and profits.
In response to another comment. See in context »The term “conspiracy” can be as simple as two or more people agreeing to mislead others. I don’t feel asking questions, sharing information or seeking data on matters of public health and concern apply. In fact it’s the opposite.
In response to another comment. See in context »Does anyone know why UC Berkeley Radiological Air and Water Monitoring Team has not given us any new readings on Tap Water since March 31??
Two things:
They have not had a lot of rain out there and they expect their readings to be below measureable amounts. They have sort of explained that on their forums but if you post there – there is a thread in which they say they MIGHT do more if the public wants them to – so post there and encoruage them to.
They have instead been focusing more recently on milk, produce, and those things where the radiation is or may be accumulating – so you can see pretty recent results for milk, spinach, topsoil, mushrooms and a few other things.
Apparently due to little rain (they hadn’t posted rainwater results as of last night in over week) they are not expecting to see measureable amounts BUT the last results they posted for milk did show some troubling increases – meaning the radiation that rained down is spreading into the food chain.
Finally, when I asked about the rain results they said new ones were coming soon, and that the delay was because the levels are so low it takes longer for the tests to detect them (which I take as a relatively good sign) BUT the results will tell.
But a good question and I envourage people to support their efforts, post there, encourage them and ask them to keep doing it. Given the failure of the private sector (industry) and the government (EPA, etc) to give recent comprehensive updates, the UC Berkeley BRAWM team is exceptionally helpful and will continue to be EXTREMELY important in the epidemiological studies and assessments of risk and harm to come from these socalled low dose events (which are still above that which seems to be likley to kill a certain percentage of US citizens with cancer and other illnesses such as metabolic disorders, hypothyroidism, heart ailments, birth defects, infant mortality, etc etc etc.
In response to another comment. See in context »Link to UC Berkeley Physics Forum. The folks there do respond to some wuestions and comments and they are testing rainwater, milk, produce, topsoil, air, etc.
EXCEPTIONAL work keeping the public posted and responsive personnel(with a few pro and anti-nuke posters skirmishing, but mostly just honest discussion of the halth risks, what the samples results mean etc plus lots of worthwhile info in FAQ’s etc).
http://www.nuc.berkeley.edu/forum/218
In response to another comment. See in context »I am so grateful to the UCB BRAWN team for testing under pressure, and in the near absence of it elsewhere from agencies we fund. You have to find it, or verifiably eliminate the presence of it before you can act or issue opinions and assurances. The possibility of finding unwelcomed results shouldn’t be an impediment to looking for or reporting on an ongoing situation that affects us all.
In response to another comment. See in context »Regarding dianalees comment, I haven’t seen much mention of the proposed hormetic benefits of low-dose exposure to radiation in any of these discussions.
There is extensive evidence that low-dose exposure to radiation can stimulate immune function and actually reduce the risk of developing cancer. Here is one reference: http://www.ncbi.nlm.nih.gov/pubmed/18648595. A simple search on Pubmed.org will turn up hundreds more.
Someone please correct me if I’m wrong, but the EPA’s MCL is 3 pCi of I-131 and c-137 in a liter of milk – but that’s assuming continuous consumption of 70 years. The FDA’s DIL is 4,700 pCi per liter of milk consumed (at a single occurrence).
The farmer I get my milk from in Northern CA had it tested by UC Berkeley and it came back at 79 pCi. This far exceeds the EPA MCL (based on 70 years) but is less than 2% of the FDA DIL.
I understand that consuming this milk for 70 years would exceed the safe limit, but in light of the potential hormetic benefits of low-dose radiation exposure and in light of the fact that this amount of milk is less than 2% of the FDA DIL, it seems like a stretch to assume that drinking milk with these levels for a couple of weeks could produce any harm – even to a pregnant woman.
My wife is 6 months pregnant, so I am serious about getting as clear on this as possible. Thanks for your help.
Oh, how I wish! You have no idea the depths of my adoration for cheese. However, You should know, the hormesis hypothesis is unproven and really “out there” in a fairly recent wee minority and doesn’t address CEDE from ingested alpha and beta contaminates in any verifiable way:
In response to another comment. See in context »“However, As the BEIR-VII report points out, “the presence of a true dose threshold demands totally error-free DNA damage response and repair.” The specific damage they worry about is double strand breaks and they continue, “error-prone nonhomologous end joining (NHEJ) repair in postirradiation cellular response, argues strongly against a DNA repair-mediated low-dose threshold for cancer initiation”.[12]“
I agree that the hormetic effects of low-dose radiation are controversial, but I’d hardly call it an “out there” theory of a “wee minority”. There are literally hundreds of studies supporting it in peer-reviewed journals. Here are a few:
“The possibility of the use of low dose radiation in cancer treatment to improve the outcome of conventional radiotherapy was raised by citing previous reports on experimental studies, which showed increased efficacy in tumor control with significant reduction of total dose of radiation when low dose radiation was used in the combined treatment protocol.”
http://www.ncbi.nlm.nih.gov/pubmed/20332172
“However, this authoritative body recognized also the existence of radiation hormesis, termed as ‘adaptive response.’ The political and vested interests behind exclusion of hormesis from the current risk assessment methodology are discussed.”
http://www.ncbi.nlm.nih.gov/pubmed/20332170
“The LNT model has sufficient evidence at high doses but has been extrapolated in a linear fashion to low dose regions with much less scientific evidence. Much experimentation has suggested discrepancies of this extrapolation at low doses. The hypothesis of radiation hormesis suggests low dose radiation is beneficial to the irradiated cell and organism. There is definite standing ground for the hormesis hypothesis both evolutionarily and biophysically, but experimental evidence is yet to change official policies on this matter.”
http://www.ncbi.nlm.nih.gov/pubmed/20169836
“Thus, the combination of a failed understanding of the hormetic hypothesis and its linkage with a strong chemical hormesis database, flawed analyses by prestigious scientists at the critical stage of scientific research development, reinforced by a Cold War mentality led to marginalization of an hypothesis (i.e., radiation hormesis) that had substantial scientific foundations and generalizability.”
http://www.ncbi.nlm.nih.gov/pubmed/10745295
“Evidence is presented which supports the conclusion that the hormetic dose-response model is the most common and fundamental in the biological and biomedical sciences, being highly generalizable across biological model, endpoint measured and chemical class and physical agent. The paper provides a broad spectrum of applications of the hormesis concept for clinical medicine including anxiety, seizure, memory, stroke, cancer chemotherapy, dermatological processes such as hair growth, osteoporosis, ocular diseases, including retinal detachment, statin effects on cardiovascular function and tumour development, benign prostate enlargement, male sexual behaviours/dysfunctions, and prion diseases.”
http://www.ncbi.nlm.nih.gov/pubmed/18662293
“Current recommendations for limiting exposure to ionizing radiation are based on the linear-no-threshold (LNT) model for radiation carcinogenesis under which every dose, no matter how low, carries with it some cancer risk. In this review, epidemiological evidences are discussed that the LNT hypothesis is incorrect at low doses. A large set of data was accumulated that showed that cancer risk after ordinarily encountered radiation exposure (natural background radiation, medical X-rays, etc.) is much lower than projections based on the LNT model. The discovery of the low-level radiation hormesis (stimulating effect) implies a non-linear dose-response curve in the low-dose region. The further studies in this field will provide new insights about the mechanisms of radiation carcinogenesis.”
http://www.ncbi.nlm.nih.gov/pubmed/21434396
“A statistically significant decrease in cancer risk with increased exposure was found for values ≤ 157 Bq m(-3) normalized to the reference exposure of 4.4 Bq m(-3), the lowest radon concentration measured(adjusted odds ratio (AOR) [95% CI] = 0.42 [0.180, 1.00], p = 0.049). This result is consistent with those reported elsewhere that considered radon exposure with cubic spline terms (Thompson, RE et al. 2008).”
http://www.ncbi.nlm.nih.gov/pubmed/21431078
“Current guidelines for limiting exposure of humans to ionizing radiation are based on the linear-no-threshold (LNT) hypothesis for radiation carcinogenesis under which cancer risk increases linearly as the radiation dose increases. With the LNT model even a very small dose could cause cancer and the model is used in establishing guidelines for limiting radiation exposure of humans. A slope change at low doses and dose rates is implemented using an empirical dose and dose rate effectiveness factor (DDREF). This imposes usually unacknowledged nonlinearity but not a threshold in the dose-response curve for cancer induction. In contrast, with the hormetic model, low doses of radiation reduce the cancer incidence while it is elevated after high doses. Based on a review of epidemiological and other data for exposure to low radiation doses and dose rates, it was found that the LNT model fails badly. Cancer risk after ordinarily encountered radiation exposure (medical X-rays, natural background radiation, etc.) is much lower than projections based on the LNT model and is often less than the risk for spontaneous cancer (a hormetic response). Understanding the mechanistic basis for hormetic responses will provide new insights about both risks and benefits from low-dose radiation exposure.”
http://www.ncbi.nlm.nih.gov/pubmed/20585444
“A large set of data was accumulated that showed that cancer risk after ordinarily encountered radiation exposure (natural background radiation, medical X-rays, etc.) is much lower than projections based on the LNT model. The discovery of the low-level radiation hormesis (stimulating effect) implies a non-linear dose-response curve in the low-dose region. The further studies in this field will provide new insights about the mechanisms of radiation carcinogenesis.”
http://www.ncbi.nlm.nih.gov/pubmed/21434396
“Radiation hormesis is explained, pointing out that beneficial effects are expected following a low dose or dose rate because protective responses against stresses are stimulated. The notions that no amount of radiation is small enough to be harmless and that a nuclear accident could kill hundreds of thousands are challenged in light of experience: more than a century with radiation and six decades with reactors. If nuclear energy is to play a significant role in meeting future needs, regulatory authorities must examine the scientific evidence and communicate the real health effects of nuclear radiation. Negative images and implications of health risks derived by unscientific extrapolations of harmful effects of high doses must be dispelled.”
http://www.ncbi.nlm.nih.gov/pubmed/19343116
“Yet the current system of radiation protection needs revision because radiation-induced natural protection (hormesis) has been neglected. A novel, nonlinear, hormetic relative risk model for radiation-induced cancers is discussed in the context of establishing new radiation exposure limits for nuclear workers and the public.”
http://www.ncbi.nlm.nih.gov/pubmed/19088900
“In this paper, low, essentially harmless doses of gamma rays spread over an extended period are shown via use of a biological-based, hormetic relative risk (HRR) model to be highly efficient in preventing lung cancer induction by alpha radiation from inhaled plutonium.”
http://www.ncbi.nlm.nih.gov/pubmed/18846259
Current guidelines for cancer risk assessment emphasize a toxicant’s “mode of action”, rather than its empirically derived dose-response relationship, for determining whether linear low-dose extrapolation is appropriate. Thus, for reasons of policy, demonstration of hormesis is generally insufficient to justify a non-linear approach, although it may provide important insights into the actions of toxicants. We evaluated dose-response characteristics of four carcinogens reported to have hormetic dose-response curves: cadmium chloride; ionizing radiation; PAHs; and, 2,3,7,8-TCDD. For each, the study that documented hormesis in one organ also provided evidence of non-hormetic dose-responses in other organs or non-hormetic responses for seemingly similar carcinogens in the same species and organs. Such inconsistency suggests toxicologic reasons that the finding of hormesis alone is not sufficient to justify use of non-linear low-dose extrapolations. Moreover, available data in those examples are not sufficient to know whether hormesis is a property of the toxicants, the target organ, or the exposed species. From the perspectives of cancer risk assessment, the greatest informational value of hormesis may be that it provokes mechanistic studies intended to explain why hormesis occurs.
http://www.ncbi.nlm.nih.gov/pubmed/18648620
“Large-scale tests and experience with nuclear accidents demonstrate that even severe accidents expose the public to only low doses of radiation, and a century of research has demonstrated that such exposures are beneficial to health. A scientific basis for this phenomenon now exists. PRAs are valuable tools for improving plant designs, but if nuclear power is to play a significant role in meeting future energy needs, we must communicate its many real benefits and dispel the negative images formed by unscientific extrapolations of harmful effects at high doses.”
http://www.ncbi.nlm.nih.gov/pubmed/18648610
“Metabolic and energetic efficiency, and hence fitness of organisms to survive, should be maximal in their habitats. This tenet of evolutionary biology invalidates the linear-no threshold (LNT) model for the risk consequences of environmental agents. Hormesis in response to selection for maximum metabolic and energetic efficiency, or minimum metabolic imbalance, to adapt to a stressed world dominated by oxidative stress should therefore be universal. Radiation hormetic zones extending substantially beyond common background levels, can be explained by metabolic interactions among multiple abiotic stresses. Demographic and experimental data are mainly in accord with this expectation. Therefore, non-linearity becomes the primary model for assessing risks from low-dose ionizing radiation. This is the evolutionary imperative upon which risk assessment for radiation should be based.”
http://www.ncbi.nlm.nih.gov/pubmed/18648598
“Three aspects of hormesis with low doses of ionizing radiation are presented: the good, the bad, and the ugly. The good is acceptance by France, Japan, and China of the thousands of studies showing stimulation and/or benefit, with no harm, from low dose irradiation. This includes thousands of people who live in good health with high back- ground radiationThis includes thousands of people who live in good health with high background radiation. The bad is the nonacceptance of radiation hormesis by the U. S. and most other governments; their linear no threshold (LNT) concept promulgates fear of all radiation and produces laws which have no basis in mammalian physiology. The LNT concept leads to poor health, unreasonable medicine and oppressed industries. The ugly is decades of deception by medical and radiation committees which refuse to consider valid evidence of radiation hormesis in cancer, other diseases, and health. Specific examples are provided for the good, the bad, and the ugly in radiation hormesis.”
In response to another comment. See in context »http://www.ncbi.nlm.nih.gov/pubmed/18648595
These are all hormetic opinions on targeted, controlled “gamma” sources – not alpha and beta ingestion as per milk or the food chain. The few that are not (cigarettes, radon inhalation) are disclaimed as unknown risk by the authors themselves. In the case of radon and cigarette inhalation that disclaimer is proper. If you further source the opinions and the author bios – you see a lack of verified, or sourcable study opinions on beta and alpha ingestion and even fewer named sources in human health disciplines on the resume. It just means a few people outside of radiological health and bio-physics peppered the NIH journal with opinions in opposition to wide and sourceable medical consensus. Per my prior comment, you are and always have been free to make your own informed decisions on radiation pathway exposures – everyone is. I believe the key is “informed.” I’d like testing and access to all data. It’s what I advocate. What other people do with it, once we have that isn’t in my perview, we have to obtain it first. If you are asking me to tell you it’s “safe, low or no risk,” I won’t, because I’d be lying. Further, I have nothing to sell you and no personal, promotional or profit motive to do so. So, what’s your point exactly? I’m unclear on that. Respectfully, I’d like to stay on point: ingested alpha and beta radionuclide limits on aggregate population mortality risk, otherwise, I could just go watch TV and eat gobs of ice cream for all that hormesis foray provided me on safety. Thank you very much for your input though, it’s appreciated
.
In response to another comment. See in context »“What doesn’t kill you makes you stronger”?
In response to another comment. See in context »Of course, it’s your family’s decision, but in plain English I’m saying:
In response to another comment. See in context »I wouldn’t bet my 1.6 pound rapidly developing fetus on an untested idea.
Also worth noting is the UCB finding of radioactive cesium in Bay Area milk. Cesium has a 30 year half-life, meaning it dissipates by half every 30 years. It would take 150+ years to dissipate fully, well beyond 70 year EPA MCL model you mention.
In response to another comment. See in context »Also worth noting that UCB is NOT testing for strontium 90 which has been found in villages surrounding Fukushima and apparently blew out when the explosions occurred (meaning it could be here as well in the milk).
The EPA has eggregiously failed to do any testing for strontium radioisotopes (except 2 towns very early on) and there seems to be NO one reporting or testing or sampling for this here (Japan’s tests show short half-life strontium 89 as well as long half life Sr-90 in multiple villages tend of kilometers from the plant).
I hope, mothra and Jeff, that some more in depth investigation of the strontium 90 risks and exposures can be done by you folks.
as far as the Cesium and radioiodine and socalled hormesis (a very tenuous theory which is less well documented than supralinear risks , or the Petkau effect – lower doses over long periods do more cellular harm than higher doses over short periods of time; I recommend the wiki analyses on Petkau and hormesis and suprlinear for an overview of that data) – the risks are in my opinion far too high with a fetus to riks any exposure at all if you can help it.
NO dose, especially internally, is safe according to prevailing scientific norms — and exposure of an infant to ionizing radiation intenrally via the mother’s diet may cause spontaneous abortion (miscarriage) or severe birth defects and increased infant mortality risks.
It just isn’t worth that risk if you are pregnant or nursing when simply avoiding as much as possible contaminated milk and foods is easy and possible.
In response to another comment. See in context »Yes, but the C-137 levels in Bay Area milk (11 pCi) are very far below the suggested limit, correct? My understanding was that the I-131 levels from the Bay Area milk were of concern, but the c-137 levels were not.
In response to another comment. See in context »You’re not getting it – these internally ingested radionuclides all have very different systemic behaviors that are not mutually exclusive to each other. The only safe dose is no dose. They can’t be compared to targeted, controlled medical or background gamma sources, and these are in addition to those.
In response to another comment. See in context »Further, this guy induced low dose chronic ingested beta carcinogenesis in mice, so yeah… like we’ve said, there’s risk and concern:
In response to another comment. See in context »http://informahealthcare.com/doi/abs/10.1080/09553000110034612
Please, there’s no need to be rude. I’m trying to get a clear understanding of an issue that has a lot of high-spirited arguments on both sides.
What I’m most confused about are the differences in conversions. The EPA document you referenced claims that 700 pCi (26 Bq) is equal to 4 millirems of exposure to I-131.
Since the milk in CA contains 78 pCi (2.9 Bq) of I-131 per liter, it would only take about 9 liters of milk to equal 4 millirems.
However, on the BRAWM site they say that one would have to consume 403 kilograms of spinach (which has about the same pCi of I-131 as milk) to equal one round-trip flight (5 millirems). http://www.nuc.berkeley.edu/node/2525. Here’s how they calculate TEDE: http://www.nuc.berkeley.edu/node/1897
What am I misunderstanding? (That is not a rhetorical question). Obviously 403 kilograms of spinach is a vastly larger amount than 9 liters of milk, so how would it be that they produce roughy the same TEDE?
In response to another comment. See in context »Mr Switters -
If your wife is 6 months pregnant and you have milk which you claim UCB tested at almost 27 times above the EPA recommended maximum contamination by radioactive iodine, why would you even consider risking your baby’s development, health, life, physical integrity, and wellness in utero by exposing her or him by drinking contaminated milk?
The fact is that minute quantities of radiation fed to a pregnant mother can cause mutations, birth defects, increased risk of infant mortality, and spontaneous abortion (miscarriage or stillbirth). The prevailing scientific risk model says there is NO dose so low that there is not a risk of harm and a fetus or developing child in utero is MOST at risk.
You can quibble about what governments and industry promote as an “acceptable” risk (based on profit for the nuclear industry), but in reality consuming milk and produce contaminated with mutagenic and carcinogenic if you are pregnant (or not) INCREASES the risk of mutation of cells, damage to dna and ultimately death of the fetus or person (or animal) exposed to the radionculide contaminant.
Because the radionuclides are bioaccumulative, they will be absorbed by the developing fetus and organs and bones and internal organs and remain in the body multiplying the damaging, mutating and carcinogenic impact as long as they are in the thyroid or blood or organs (which may be months or years) producing more radioactive decay which means the radionuclides continue to damage surrounding dna and cells as they break down and emit their radiation.
MAYBE they won’t kill or mutate your baby or your wife, and maybe they will.
Either way you won’t know for sure until it happens (and that could be a stroke during delivery or a cancer in 30 years).
Are you really that cool with having your baby in utero being used as a guineau pig by the nuclear industry and by pro-nuclar government entities.
Ever heard of Dr. Mengele? It is an apt comparison.
In response to another comment. See in context »mrswitters,
I cannot emphasize enough the importance of the FDA’s own statement that its DILs are NOT a safety standard.
The EPA has determined that the “safe” exposure to ANY and ALL radionuclide (including Cs-137) is zero particles. See http://water.epa.gov/drink/contaminants/basicinformation/radionuclides.cfm. This is the MCLG (“maximum contaminant level goal): ‘the level of a contaminant in drinking water below which there is no known or expected risk to health.’ It represents, in the EPA’s best scientific analysis, “the level of contaminants in drinking water at which no adverse health effects are likely to occur.” This health goal is “based solely on possible health risks and exposure over a lifetime with an adequate margin of safety.” They law makes this standard non-enforceable. 70 years times a zero annual dose is zero lifetime exposure. This is a very powerful statement of how unsafe the EPA considers radionuclides: the amount of particles you can ingest at which no adverse health effects are likely to occur is ZERO.
The EPA’s MCL standard of 4 millirems max radioactive dose per year (which you see cited as the 3 pCi/L standard or 700 pCi per year) is not purely based on human health; it takes into account a “cost, benefits and the ability of public water systems to detect and remove contaminants using suitable treatment technologies,” while, however, attempting to get “as close to the health goals (the MCLG) as possible.”
The MCL is less protective than the pure health standard of the MCLG. If your wife were to make her decisions based on the EPA’s MCL standard, she would add an additional 1 in 1,000,000 risk of getting cancer to her existing risk.
No matter what EPA is saying in press releases, no federal agency has ever adopted the DILs as a health standard – again, that includes the FDA.
If your wife were to make her food consumption decisions based on the FDA’s DIL, she will be taking AT LEAST a 1 in 4400 risk that she will die of cancer. Women are twice as sensitive to radiation as men, so her risk may be as high as 1 in 2200 of dying of cancer. The risk of getting a nonlethal cancer is even higher. There are other health risks from radiation, but we are just talking about cancer now.
Since she’s pregnant, she also will be deciding to risk the fetus’ health. According to the reading I have done, she will increase the fetus’ risk by much, much more than her own. Decades ago, studies showed that just ONE prenatal x-ray doubles the baby’s risk of childhood leukemia.
By far the most vulnerable age group is a developing fetus. For just one discussion of prenatal radiation, see this blog http://www.georgewashington2.blogspot.com/2011/04/nuclear-power-killing-unborn.html (he’s mostly citing experts). “In all stages, they are vulnerable to emitting isotopes ingested by the mother. For example, if a pregnant mother inhales or ingests radioiodine, it can be carried through the placenta to the fetus, where it can lodge in the fetal thyroid and where its gamma and beta emissions can cause serious damage to the developing organ. Once the fetal thyroid is damaged, changes in the hormonal balance of the body may result in serious–possibly fatal–consequences for the development of the child through pregnancy, early childhood, and beyond. Such effects include underweight and premature birth, poorly developed lungs causing an inability to breathe upon delivery, mental retardation, and general ill-health.”
“Other emitters can lodge in other fetal organs. For example, yttrium-90, a decay product of strontium 90, can gravitate toward the pituitary gland. Overall, fetal irradiation during the second and third trimester has been linked to microcephaly (small head size), stunted growth and mental retardation, central nervous system defects, and behavioral changes. Exposure of the fetus to radiation during all stages of pregnancy increases the chances of developing leukemia and childhood cancers.”
The EPA MCL standard is 4 millirems/year (or 700 pCi). This would be 49,000 pCi in a lifetime. 1 1/2 Liters of contaminated milk under the FDA DIL would exceed the EPA’s lifetime limit.
You and your wife are the safeguarders of your child’s health. The FDA is not going to protect you. Let me repeat their own words: the DIL is not a health standard.
Mothra has done more reading into the health effects of internal radiation than anyone I’m aware of at the moment. Please feel free to do your own review of the research and resolve these questions for yourself. After looking into the research, I would not dream of relying on the FDA standards, or of knowingly ingesting radiation while pregnant. We can’t control this fallout, but we can do what we are able to minimize our consumption of it. I wish you both the best of luck in keeping your son or daughter healthy.
In response to another comment. See in context »Regarding UC Berkeley dosage calculations. My guess is that the UC Berkeley nuclear scientists are relying on a model that does not distinguish between internal and external emitters. Can you confirm? This model has a further weakness of being based on a man (women are twice as sensitive, fetuses even more so)
As I noted above, while I would mostly rely on their sampling results, I could *not* say the same about UC Berkeley’s radiological health conclusions and statements. They are nuclear engineers, not medical physicists or radiobiologists. As I said above, “The team does not seem to distinguish between internal emitters versus external emitters in terms of expected doses, and at least once to my knowledge, members of the team have made grossly inaccurate statements regarding the basic biology and health consequences of radioisotopes: [e.g.], one BRAWN member stated in response to a posters concern about radioactive xenon levels that xenon is “not absorbed by the body” and therefore will not have negative health effects. In fact it is absorbed by the body through the lungs and deposited in adipose tissue, as has been known in the medical community for over 40 years.”
In response to another comment. See in context »I just received this reply from a friend of mine who is is a nuclear physicist at Harvard. Anyone care to comment:
“Well, a Becquerel is a really small amount of radiation – 1 decay per second. 3 Becquerel is a very low level.
The trick here is that what matters for health is the total radiation load (rad, rem, Sieverts are units). To convert that you need to know how long the exposure lasts and how long the radioactive iodine atoms are in the thyroid.
One thing to keep in mind is that the half-life of iodine 131 is 8 days. So wherever it is, half of it disappears every 8 days.
Also remember that the iodine is generated only when fission is actively occurring. The Japanese reactors have been shut down since the earthquake, with minimal uncontrolled fission. This means the amount of iodine 131 at the reactors is being cut in half every 8 days. As long as they don’t have some uncontrolled fission event, the iodine danger is going to be steadily diminishing. So whatever the iodine level in California food is right now, you can expect it to be steadily diminishing in the weeks to come. So the risk is diminishing with every week that passes. Because of the 8-day half-life, if your farmer gets his milk tested again in 8 days, the level will be about 1.5 Becquerel/liter; 0.75 Becquerel/liter in 16 days; and so forth.
Now let’s look at how much your wife may be getting. Suppose she drinks a liter of milk per day. After 9 days at 3 Becquerel per day, the iodine-131 in milk she drank 9 days earlier will have decayed or been excreted, so her exposure will exactly equal the EPA’s MCL rate. But the MCL rate is calculated so that there is minimal danger with continuous exposure for a year or more. Your wife has only gotten a week’s exposure, so she’ll be at least 1/50 the lowest dangerous dose according to the EPA MCL.
Since iodine-131 radiation getting into California milk is halving every 8 days, her total expected exposure over the course of her pregnancy would be double that, or 1/25 the lowest dangerous dose by EPA standards.
However, this too is an over-estimate. Iodine-131 is only dangerous if the decay occurs in her thyroid. If she gets natural iodine from any source, there will be competition and only a fraction of the radioactive iodine will be able to reach her thyroid.
I believe the iodine content of milk is around 150 mcg/liter. So if she gets 1 mg iodine per day from non-radioactive sources, the I-131 in the milk will be diluted 8-fold. Thyroid uptake is somewhere below 100 mcg/day, so her thyroid gland dose would be diluted 10-fold, or to about 1/250 the EPA MCL level. If she takes 10 mg iodine her thyroid would be at 1/2500 the EPA MCL.
You can also let milk or other products sit in the refrigerator for 8 days before drinking. This will cut iodine radioactivity in half.
The difference between the EPA MCL and FDA DIL is based on time of exposure. The EPA MCL is concerned about total dose with a year of exposure. The FDA presumably is concerned with total dose over some shorter exposure period, thus the higher allowed dose.
Similarly, the MCGL is calculated assuming an exposure period of 70 years. The appropriate exposure time for the Japanese I-131 is something under a month.
The risk from cesium is really inconsequential in California. It has real implications for farmland in Japan, but cesium is not very dangerous compared to iodine and isn’t a risk in California.
Probably the EPA limits are very cautious – they don’t account for the body’s ability to do DNA repair effectively at small damage levels. There’s even a belief that hormesis occurs and small radiation damage causes repair not only of the radioactive damage, but also of other damage from carcinogens and so on. So reaching the EPA MCL limits for a month or so probably isn’t dangerous at all.
So my conclusion would be that Elanne and the baby are totally safe as long as she is supplementing with 1 mg/day iodine (putting her probably at at most 1/100 the EPA MCL level), and probably very safe even if she isn’t, though with all other food sources she might start approaching the EPA MCL level of intake, but probably not for long enough to produce any significant radiation load, and probably not anything beyond her body’s natural ability to repair.
Your other questions:
1) The radiation from an airplane flight is vastly higher than the radiation she’ll be getting from I-131, but it isn’t from iodine and isn’t concentrated in the thyroid. So it’s not really comparable. Still, it’s probably true that the cancer risk from an airplane flight is probably much larger than the thyroid cancer risk from I-131 tainted food, water, and milk.
2) Remember that Curies and Becquerels are units of decay events per second. Rad is energy received per gram of tissue; rem or Sievert is rad adjusted for tissue absorption efficiency. To convert Becquerel to rad/rem/Sievert, you have to multiply by how much energy is transmitted in each decay, divide by the amount of receiving tissue, and multiply by the length of time of the exposure. So, you can get very different results with different assumptions, e.g. (a) what if the time of exposure to I-131-tainted milk is one month, but the time of a cross-country flight is 6 hours; or (b) what if the tissue exposed to flight in radiation is the whole body, but you assume that I-131 is concentrated entirely in the thyroid, which is much lighter. You can easily see how these assumptions can make big differences in the calculation.
I don’t see any real cause for concern. But you can take simple precautions:
1) Supplement with at least 1 mg/day iodine for a 90% exposure reduction, or 10 mg/day for a 99% exposure reduction.
2) Wash vegetables, since most of the I-131 will be in fallout in the form of dust on the surface. This might reduce the vegetable radiation 80% or more.
3) Keep foods in the refrigerator for a few days before eating them. This might reduce exposure 50% with an 8-day delay or 12% with a 2-day delay.
If she hasn’t been supplementing iodine, I would advise starting with low doses. Messing up thyroid function would probably be more dangerous than the I-131, so don’t double the dose in less than 2-3 weeks.”
In response to another comment. See in context »Also, I believe the BRAWM team does distinguish between external and internal emitters. They have a page explaining their TEDE calculation using air and water. http://www.nuc.berkeley.edu/node/1897
They also state that the “reference man” used in the model receives an average of 50 millirem per year of radiation from all sources of air and water, and that a single round-trip flight from SF to DC is equivalent to 5 millirem.
If it’s true that “no dose of radiation is safe”, then why aren’t you warning people (especially not pregnant women) never to fly, breathe, drink water or do anything that would obviously expose them to several millrems of radiation? We would also have to remove basically all fresh food grown in the ground from the list, because spinach, strawberries, mushrooms, kale, etc. are all testing between 0.2 and 3 Bq/kg.
In response to another comment. See in context »Well – I do think it is a good thing that the Harvard Physicist says that reasonable precautions will reduce the potential harm.
Obviously these discussions will raise the awreness of some people to the risks of externela and internal exposures so that they can make informed decisions.
The real distinction between flying and other natural exposures and radionuclides is, of course, the former is something we have to live with – we have no choice but to eat and drink and breathe and we can choose whether or not to fly or get an xray or ct scan. But radionuclides are now everywhere due to the nuclear industry and we cannot and did not CHOOSE to be poisoned – these decisions were made to permit deadly exposures by courts, legislatures, military authorities and industry, with little or no consideration of the real risks (but rather primarily the benefit of industry and investors and military).
Of course reducing risk, as the Harvard physicist suggests, is the smartest thing to do once we are exposed to the radionuclides. But I believe that eliminating the CAUSE of the risk in the first plkace is the WISEST choice for humanity.
German Chancellor Merkel is taking nuclear power off the table, shutting them all down, in favor of renewables. We can do that too here in the US and it is the wisest and most economical investment in our future and will create tens of millions of jobs in all sectors.
Defending nuclear and downplaying the risks is defense of the indefensible.
In response to another comment. See in context »Exposure to ionizing radiation causes damage to living tissue leading to mutation, illness, cancer and death. Ionizing radiation comes in alpha particles, beta particles, electromagmetic and gamma rays. When I go out I wear sunscreen (gamma/nucleus/cosmic). When I broke a bone the radiologist covered my girl bits (electromagnetic/electron/Xray). When 3 types of radioactive plutonium were found uncontained at Fukushima people were deeply concerned (alpha). When I-131 and Cs-134 & 7 were found in France 8-10 times lower than the US West Coast CRIIRAD issued an advisory to wash leafy greens and reduce fresh dairy consumption (beta). Why? Chronic or long term low level exposure to ingested ionized beta radiation poses signifigant risk. It only takes a little. Fukushima will emit some portion of 1,900 tons for some duration and in varying spike degree. Further, other radioactive beta particles were found uncontained from Fukushima: strontium and uranium. Data and testing is pending. Milk is an indicator of contamination across the food chain. Not all foods are equally susceptible to beta radionuclides. Each of these beta particles has a unique system they target in a human body. Everyone’s risk is not equal, since subsets of aggregate populations are more susceptible (women, children, immuno-supressed et al). Exposure to one radionuclide doesn’t preclude or eliminate exposure to the others or additional ionizing radiation (already in epidemic). Half-life particle dissipation ranges: Iodine-131 80 days to Cesium, Strontium and Uranium 150+ years to Plutonium (72 to 288,000 years). The half-life clock starts and deposits end when emissions cease – pending estimates are months to a decade before decommission. Current distribution pathways are inclusive: atmospheric/air, land and oceanic. Current limits and protective action thresholds are set too high for long term low dose exposure safety. I-131 is personally the least of my growing concerns. This is an unprecedented nuclear event.
In response to another comment. See in context »By unprecedented nuclear event, I mean: a slow emitting long duration emission deposits of 1,900 (disclosed) tons. Former guidelines and limits were set for beasts of 200 tons and under for shorter duration of dispersion and different distribution. A lot of things have changed globally since, from exposure studies to food trade policies to deregulation and economics to lifestyles and environment practices. Not that prior models weren’t bad enough or we weren’t still dealing with those legacies either. This wasn’t planned for – it was the unthinkable scenario before.
In response to another comment. See in context »Yes, but when it comes to mortality and survival rates there are countless variables to consider. You say you put sunblock on when you go outside to reduce exposure to radiation. But that will decrease your vitamin D levels, unless you are supplementing, and low vitamin D has been associated with increased morbidity and mortality. Likewise, folate and B12 are absolutely essential nutrients during pregnancy (both are involved with DNA synthesis and repair), and most women don’t get enough of each. If women are advised to stop eating leafy green vegetables and meat because of the I-131 contamination, that may increase the risk of birth defects from folate or B12 deficiency without adequate supplementation.
I’m a health care practitioner so this is how I think. Leaving politics aside (I am completely in your camp), the issue is not eliminating risk. That’s impossible. If there’s one thing we’re certain of it’s that we’re all going to die. We’re talking about taking prudent steps to limit the potential increased risk of cancer WITHOUT simultaneously increasing the risk of another potentially fatal disease.
“Disease substitution” is not an acceptable outcome. But it happens all too often in medical research. Look at the studies on HRT where they decreased the risk of CVD in women but dramatically increased their risk of breast cancer.
At this point, from what I can gather from multiple sources, the following seems prudent:
In response to another comment. See in context »- Avoid or reduce consumption of fresh milk. Cheese or butter made prior to the meltdown is not an issue.
- Wash leafy green vegetables very well before consuming them, and limit intake until radiation levels fall in test samples
- Pregnant women without autoimmune thyroid issues should supplement with 1 mg of iodine and 600 – 800 mcg of folate daily
- Make sure to get enough of the fat soluble vitamins (A, D, K, K2) plus vitamin C and selenium, all of which play an important role in immune health. Cod liver oil is a good choice for the fat soluble vitamins, selenium is plentiful in fish, and vitamin C can be supplemented with.
- Take steps to manage stress. As dianalees pointed out earlier, stress diverts energy to “fight or flight” mechanisms and away from immune and repair processes.
An open letter to esteemed Nuclear Physicists:
In response to another comment. See in context »“Conclusion? Simply this: that the biological effects of radiation (in terms of increased occurrences of cancer, leukemia, and genetic damage) are linearly related to the accumulated dose of radiation received, regardless of whether it’s a big dose administered all at once or a small dose administered over a long period of time.”
http://www.ccnr.org/open_letter.html
What advice are you referring to? I’ve not given what you ascribe to me. I’ve never advocated disease substitution – only caution and simple, low cost preventative action. I’ve requested consumers be slow and cautious regarding the plethora of ranging advice based on very little out there. Check my comment record. I don’t feel our goals are dissimilar.
Regarding yours:
On sunny Vitamin D – it only takes a few minutes, we get plenty from that source and it’s limited anyway. So, yes I wear sunscreen:
http://www.emaxhealth.com/83/7214.html
Folate and Vitamin B concern? Take a multivitamin, I do and wash your contaminated leafys and cruciferous, switch to frozen or “pre-event,” use an aged cheese, cesium is reduced from meats via brining marinades, powdered and canned dairy are options as are fortified grains, or make a substitute – there are many choices and radionuclide-laced fresh milk varieties aren’t the only source:
In response to another comment. See in context »http://www.hsph.harvard.edu/nutritionsource/what-should-you-eat/vitamin-b/
“Vitamin B12 is found in foods that come from animals, including fish and shellfish, meat (especially liver), poultry, eggs, milk, and milk products. Eggs are often mentioned as a good B12 source, but they also contain a factor that blocks absorption. Certain insects such as termites contain B12 produced by their gut bacteria, in a way analogous to ruminant animals. An NIH Fact Sheet lists a variety of food sources of vitamin B12. While lacto-ovo vegetarians usually get enough B12 through consuming dairy products, vegans will lack B12 unless they consume B12-containing dietary supplements or B12-fortified foods. Examples of fortified foods include fortified breakfast cereals, fortified soy products, fortified energy bars, and fortified nutritional yeast. According to the UK Vegan Society, the present consensus is that any B12 present in plant foods is likely to be unavailable to humans because B12 analogues can compete with B12 and inhibit metabolism.”
The assumption of continuous consumption for 70 years holds for water NOT for milk.
I’ve spent hours trying to find the milk models but they are not available online at any of the EPA connected sites or alternative sites I searched.
The FDA’s DIL is very high for milk.
I spent a lot of time searching research on radiation exposure using Science Direct, an academic science index (i’m an academic), and the effects of radiation on embryos and fetuses are scary.
There is a lot of research on this subject and the “hormetic” benefits of radiation on embryos seem to be that low levels cause defects or cancer while slightly higher levels cause death, thereby masking the damaging effects of those doses on expectant mothers who end up having spontaneous abortions
There is a reason pregnant women don’t get x-rayed….
In response to another comment. See in context »Aye, and thank you!
And I’ll add “low dose phenomena” is real, well known and signifigant:
“Regardless of the explanation, the phenomena of supra-linearity at low dose irradiation are well demonstrated and present counter-evidence to the DDRF assumption.”
It’s not just fatal cancer:
“The Adult Health Study (AHS) has greatly increased in importance in recent years as a result of the accumulation of an enormous body of data from serial medical examinations, with and without superimposed radiation aspects. Particularly noteworthy is the accumulating evidence of the radiation dose related increase in non-cancer disease morbidity, such as cardiovascular disease, hyperparathyroidism, thyroid diseases, uterine myoma, chronic liver disease, and cataract … Another unexpected finding is the retrospective evidence that radiation is associated with premature menopause, and this in turn, may result in earlier onset of other conditions, such as an increase in cholesterol levels and cardiovascular disease. In addition, most recent findings suggest that diabetes mellitus increases with radiation dose among young survivors of Hiroshima.”
Therefore:
“Consequently both ICRP’s choice of a biological endpoint as fatal cancer, and its current exclusiveness, are now in question, as well as the effective dose estimates for internal radiation emitters. In such a situation the Precautionary Principle should prevail. The choice of fatal cancer as the exclusive biological endpoint after ionizing radiation exposure is not scientifically acceptable. Equally unacceptable are estimates of equivalent effectiveness made without adequate backing by scientific research.”
These are general excerpts on internal and external ionizing radiation used in this article to address only tritium risks, but the points are applicable to our situation:
In response to another comment. See in context »http://iicph.org/health-effects-of-tritium-appendix-2
They aren’t testing and the “refer to other agency” dance has begun for the ocean. BC, Canada found radionuclides in seaweed weeks ago from rain outs and land run-off, so the Pacific contaminate-free claim is just entirely false. Tuna and salmon migrate. Radioactive debris and oceanic currents are expected within the year. This is just in the agency Twilight Zone now.
http://www.adn.com/2011/04/16/1813982/fda-claims-no-need-to-test-pacific.html
In response to another comment. See in context »Source article – Pacific EPA, FDA and NOAA.
This is an unbelievably educational discussion thread, and once again, my gratitude and respect to all of you for such thorough and diligent tracking down of facts. Trying to keep track of all the details, my head, is, frankly, spinning.
With that said, I still want to weigh in again.
I worked in life science research for 23 years, and had occasion to work directly with a number of radioactive isotopes, including tritium, Phosphorous-32, Iodine-125, and even once in a while strontium-90 and technetium-whatever. Disclaimer: I am not a radiation biologist. However, from looking directly at the biological data from countless experiments, I know a few things. Sorry, no articles or websites to link to. This is in my head.
1. Regardless of what the officially approved levels are, radiation is potentially dangerous at any dose.
2. Rapidly-forming tissues – such as fetal tissues – are very vulnerable to direct damage because DNA repair may not be fast enough and damaged stretches may be replicated, turning on disease genes or causing other unplanned effects. There’s a reason why we use radiation to treat cancer. Cancer reproduces faster than other adult human tissues and is therefore more susceptible.
3. Another very vulnerable population is the elderly, for a different reason. Their systems are slowly deteriorating and their ability to detoxify and rejuvenate the body is impaired. So toxicity builds up, disease genes are turned on, and then the fun begins.
4. Even so, the human body has an extraordinary ability to heal itself, so odd bits of DNA damage don’t necessarily lead to long-term disease.
5. The ionizing radiation from radionuclides is dangerous, but as liberationangel (and I think someone else) mentioned above, there are abundant other sources of hazardous radiation, and most people just live with them and assume it’s OK.
6. Diseases express in people who are unable to detox, chelate, and – ALL IMPORTANT – de-stress. Waiting for the other shoe to drop is stressful. So is worrying about the potential dangers. Stress is arguably more dangerous than Cs and Te in the food supply. You can chelate Cs and Te, and your body can and does automatically repair damaged DNA. But if your body is in adrenal exhaustion, and flooded with cortisol, those disease genes will turn on regardless of whether toxins are present.
Regardless of what is being said by government agencies, we have a responsibility to ourselves and our fellow humans. It’s clear that radiation is here it seems inevitable that it will continue to arrive. So our most intelligent approach is to treat our food supply and our bodies with that in mind.
Jeff, would you consider posting – or finding a guest blogger who can – on ways to deal with radiation in the food supply, rainwater, and air? Not out of fear, but out of commonsense. If it’s here, we may as well deal with it.
I know my stress would decrease if agencies would start to test, shoe some action and refrain from blanket assurances and motives not supported by science, public health or anemic open data. Maybe we should get a little understandably freaky or assertive about this? The eerie “calm” and opacity is what induces my stress the most – along with banana and suntan comparisons. The public largely doesn’t know. It’s sad really.
In response to another comment. See in context »And lo, here come the atypical pneumonias and increased P&I, ILI activity from Boise, Mexico, UK… especially with high risk groups from March through April.
In response to another comment. See in context »According to the most recent report the levels of radioactive isotopes in rain water are decreasing across the board.
In response to another comment. See in context »Does anyone know how long it takes for I-131 or other radionuclides landing on the grass to eventually show up in cow’s milk?
I was just looking at the UCB data, and realized that their rainwater data http://www.nuc.berkeley.edu/RainWaterSampling show much higher levels of all isotopes through 3/30, but much lower since then (even though there are also fewer data points.
But the milk data http://www.nuc.berkeley.edu/node/2174 show Cs-137 and I-131 increasing for the past couple of weeks. Makes me wonder about exactly how that part of the food chain works. Did someone already address this?
The grass-cow-milk pathway depends on the isotope deposited, breed and grazing habits, plus geography and ambient weather or season. Just like brown egg chickens eat more feed certain times of the year and certain climates are warmer or wetter. Cesium is long term once deposited.
In response to another comment. See in context »“Mean values of weathering half lives on plants are 9.1 +/- 0.6 d for iodine and 11.1 +/- 0.8 d for cesium, in good agreement with means established from experiments performed before 1986. Mean values of equilibrium feed-to-milk transfer coelbcients are 3.4 +/- 0.4 10-3 d L-1 for 131I and 5.4 +/- 0.5 10-3 d L-1 for 137Cs.”
http://www.ncbi.nlm.nih.gov/pubmed/8181940
http://mobile.journals.lww.com/health-physics/_layouts/oaks.journals.mobile/abstractviewer.aspx?year=1994&issue=06000&article=00005
Jeff, Thanks for showing how well we are not protected by the safety regulators. What the Feds and media ignore is the cumulative damage from radiation. It’s the same as a boxer and brain damage; each hit takes us closer to a lethal buildup.
The biggest scam related to the FDA contaminant level is tobacco. When they determined cigarettes caused cancer, they ignored radiation and chemical contamination. Most US commercial tobacco is grown near nuclear processing sites. The cancer is actually caused by a small, FDA legal, amount of radiation going directly to the lungs. In addition you have weed killer and insecticide going directly to the lungs. The FDA never tested organic, low/no radiation tobacco. Native Americans should have been wiped out by cancer long before Europe invaded.
Aye, Jeff McMahon rocks! Who knew about this? I really didn’t before. Thank you everyone for the discussion that didn’t exist elsewhere in this way. It’s important. I learned things. Info is a hammer.
In response to another comment. See in context »The thanks rightfully should go to you Mothra, and to all of you on this thread for your diligence and dedication and research.
Please note that Siobhan Delancey of FDA has gotten back to me this afternoon with comment for this post, and I’ve added it at the bottom of the post. I don’t think the statement tells us anything we didn’t already know or expect to hear, but I know you’ll all want to read it.
In response to another comment. See in context »Gosh, I’d really prefer FDA Siobhan Delancey’s “Precautionary Principle” stance on anti-biotics in animal products in regard to ingested beta radionuclide contamination:
“Using too many antibiotics is resulting in more antibiotic-resistant bacteria in animals, says a 2008 review in The Annual Review of Public Health. “Antibiotic-resistant pathogens in food-producing animals can be transferred to people who handle or eat contaminated meat or milk,” says Siobhan DeLancey of the FDA. This means if someone is infected by an antibiotic-resistant pathogen, drug treatment will be less effective. Antibiotics can also get into soil and water, increasing our exposure and compromising their effectiveness.”
Or, perhaps Four Loko:
“FDA spokeswoman Siobhan Delancey would not confirm any upcoming rule, according to National Public Radio, but she did tell the news organization that the agency recognizes that the debate over the drinks is a “very important public health issue.”
Or, cloned animal consumption:
“It is theoretically possible” offspring from clones are in the food supply, said Siobhan DeLancey, an FDA spokeswoman.”
Or, tainted animal feed:
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm172768.htm
Or, even hair straightener:
“However manufacturers do bear responsibility for making sure their products are safe to use,” says Siobhan DeLancey, a spokesperson at the FDA Office of Public Relations.
In the meantime, my heart goes out to the US and I suppose I’ll have what Ms. Delancey is having Harry Met Sally deli style? Her first, then within 2 to 20 years. We’re talking about ingested beta radionuclide contamination in the food chain and not Four Loko and silky tresses after all. Thank you.
In response to another comment. See in context »EPA and FDA aren’t being quite candid when trying to walk away from the MCL. The MCL’s are not a 70-year exposure. Under the Safe Drinking Water Act and EPA’s associated regulations, water is not permitted to exceed the MCL averaged over any single year. One is not permitted to average over 70 years. Using instead as a standard FDA’s emergency limits, which are based on 1 cancer (incidence) resulting per 2000 people exposed, is very inappropriate when looking at exposures that could extend over much of the U.S. population. That “acceptable” risk level would result in 150,000 cancers, using their own figures.
@mothra. I received you email. Gary Null is not a credible source. His “PhD” is in Interdisiplinary Studies in the humanities. He is not a scientist and speaks about things he does not understand. He lacks the necessary education in nuclear science to have an informed opinion. On the other hand I actually am a formally trained health physicist. The EPA “scientists” are likewise ignorant on this issue. If you look at the FDA regs closely you’ll see they are based on dosimetry (radiation dose calculation) techniques of the ICRP, which is the international standard setting organization for radiation protection in all fields (medicine, nuclear industry, academic, etc.). The people in the ICRP (unlike the EPA) are real scientists who have spent the last 80 years developing and refining radiation dose estimation and measurement techniques. I am sorry you are not comforted, but my main goal was to educate, not comfort. I am scientist. I can give you facts, nothing more. I really don’t have an agenda here on this. You can believe me or not. Here’s a good link for you: http://www.doseinfo-radar.com/RADAR-INT-Occ.html. It has links to several spreadsheets (esp. Table II-VI) that will give you the whole body doses for injestion of radionuclides broken down by isotope and age group. You will need to mutiply the number by the total activity (in Bq) injested. I don’t know your math skills or whether you’ve had any scientific training whatsoever so this might be a mistake, but it’s just to show you I’m not hiding anything. The dose-radar site is good in general for having lots of relatively user-friendly info that’s much the same as used by professionals in this field (overlapping info with ICRP publications which I cannot direct you to as they are not free and not cheap to purchase).
Sorry, I thought you stated prior that you were a “nuclear physicist,” so you can understand my confusion that you’re now a “health physicist?” do you mean nuclear health physicist? I rarely encounter oxymorons in physics.
I say then, let’s hear it for the Humanities and all their quoted low dose ingested beta and alpha radionuclide studies! I think you just tried to feed me an ALARA Pipe Dream Milkshake and called it a Safe Sunday with a condescending cherry on top? You’re still not correct, but it sounds delicious – you first, then we’ll compare notes and co-pays after the latency period. No worries:
http://iicph.org/health-effects-of-tritium-appendix-2
http://www.ratical.org/radiation/CNR/RIC/index.html
http://www.ead.anl.gov/pub/doc/ANL_ContaminantFactSheets_All_070418.pdf
http://www.cnn.com/2011/OPINION/03/25/caldicott.nuclear.health/index.html
http://www.epa.gov/radiation/docs/402-f-06-061.pdf
http://www.ncbi.nlm.nih.gov/pubmed/1188384
http://www.ncbi.nlm.nih.gov/pubmed/8927711
http://www.cardnm.org/healtheffects_a.html
http://www.psr.org/resources/radiation-and-public-health.pdf
http://www.jstor.org/pss/3580326
* I have more when you’re ready.
In response to another comment. See in context »For reference, I likey the maths and sciences. I’m comfy coverting Bq to pCi etc. I just don’t like ingesting them. I’m not certain how many health hours you’ve logged in training, but Grandpa Math has a letter for you about it. I’m less eloquent and trend “sailor mouth” when considering infant health in the face of hubris, which wouldn’t be polite or fit for public commentary:
http://www.ccnr.org/open_letter.html
Do you really want to be “that guy” who downplayed known, signifigant risks from morbidly high fatal cancer thresholds set for economy and energy policy in the face of health science consensus?
In response to another comment. See in context »I put on your shoes for a spell and I boiled it down to this:
If I advocate testing, disclosure, diet, rest, exercise, hydration, hygiene, reduction of exposure to ingested alpha and beta radionuclides detected in my city air, rain, tap water, soil and food chain during the largest global nuclear event in history – who gets hurt?
1.) My carpal connective tissue from a touchpad?
2.) Your industry gets retrained in sustainable low-impact energy and health modalities, or outsourced to India where it encounters their “misunderstanding” masses, but with the lovely hint of saffron in the air?
3.) I-131 and Cs-134 & 7 laced infant spinach puff market takes a temporary loss? Talk about your nuclear “green energy.” Oy.
If I advocate your position – who gets hurt?
1.) Potentially 5% aggregate population per 1Sv cumulative lifetime exposure, or 350,000,000 per each Sv worldwide cancer fatality (not including myriad quality of life reducing ailments, the undocumented or population growth from 2-60 years)?
Wow. So, I like my ethical position odds better, and I don’t feel “new” nuclear is a sustainable answer or green. Thorium. Waste products. Phht. Stop it.
In response to another comment. See in context »@mothra. I was trained as a nuclear physicist and now work in the health physics field. You obviously are impervious to reason and I have little patience for the willfullly ignorant so go live off in La-la land and do what you will and I’ll keep plugging away in the real world. But before I sign off, as far as the radiation in the food goes…if you want to avoid it completely you’ll have to stop eating and drinking entirely! There are naturally occuring radioisotopes in every single thing you eat and drink and they’ve been there since the beginning of time. 40-K, uranium, etc. You just can’t escape it. Sorry to burst your bubble. You seem to live in a alternate reality. Giving me Dr. Null as a nuclear expect…ROFL. The guy is a AIDS denying quack nutrionist and you trust HIS word on radiation more than a real scientist. Sorry I don’t think there’s any help for you, but hopefully some rational person on this board heard a thing or two I said. But I’m not wasting any more time with the tin foil hat crowd. Adios.
Okay, but from inconvenient reality La La land, I ask you to be cautious of your radionuclide ingestion via leafy cruciferous and fresh milk like CRIIRAD and ECRR advise, because even if I don’t agree with you via mountainous studies you won’t read – I do care. Call it tin foil hat, or golden heart or platinum ethics or “level of concern” or whatever:
In response to another comment. See in context »Chris Busby ECRR:
“I attach my “don’t panic” paper. However, since then I have re-thought this advice as the thing is still fissioning and releasing 10 to the fourteen becquerels a day. This will mean that Sr-90 [strontium 90] and Uranium and particulates will be building up in the USA and Europe. I will assess this later but for now I think it prudent to stop drinking milk. I also attach the particulates note.”
http://www.scribd.com/doc/53738157/Busby-Dont-Panic
please do!
asap as now is when we seem to be getting dosed most!
thx for all you are doing to raise awareness and provide solid info!
I am a nuclear physicist who studies radiation safety issues. The FDA certainly doesn’t have the best track record in the world with relation to pharmaceuticals, but I can assure you the limits they have set with respect to radioactive contamination are orders of magnitude on the safe side. The EPA limits are ridiculous. 131-I has a relatively short half life and any contamination of the food or water supply after a release would be mostly gone in 60 days (down to 1% initial level). Drinking 2 liters of water a day for 60 days which was contaminated with 3 pCi of 131-I would give you the same radiation dose as standing outside for 30 minutes! Drinking the same water at the FDA limit of roughly 170 Bq/kg gives you a dose of about 1 month natural background. Aka. That water’s no more likely to give you cancer than simply being alive for a single month. The EPA Cesium limits at the max allowance 1200 Bq/kg (134-Cs + 137-Cs) would give you a annual dose of 14 mSv (roughly 2 chest-CT scans worth). Now, it’s important to remember these contaminants would not be naturally occurring, but only if there was a nuclear accident. The limits are safe. There is no reason to worry.
Dear esteemed brenthankYhank you for your response. I was waiting for it, wanting to know and be informed – even if mortality and quality of life issues aren’t pleasant to address, I felt it was important to transcend my natural aversion to a morbid discussion in the public interest by keeping focus. I drafted about 5 point for point replies to your comment in my own words, but decided to tell you personally your well intended reply is misguided and actually less comforting in the low dose ingested radionuclide arena. I’ll let a more eloquent publication demonstrate how and why:
http://www.laka.org/docu/boeken/pdf/6-01-4-80-46.pdf
Best wishes to you and yours,
Me and mine
*I hope we can each use our gifts to global advantage in future – rather than the converse as set currently in ideology and hubris.
My concern is not a “single” dose of radiation. Rather, my concern is children (my children) and pregnant woman being exposed to these individual “safe” limits from multiple sources over an extended period of time and the effect it will have on their general health. Not just cancer risk, as we know that radiation exposure causes more health issues than just cancer. As a lawyer, I view all the evidence and however unfounded the scientific community thinks the public’s fears, I believe they are justified. Additionally, we know that the governments and the nuclear company have been less than candid in this case. We may never learn the true extent of radiation exposure here, but the effects will be seen in future generations. I will believe there is no reason to worry when the radiation stops being emitted and our air, precipitation, food, and water supply is free of radiation attributable to this disaster.