694 



'Afhatever the limitations of models and the degree of controversy 

 surrounding their ecological assumptions, there is a '.'.ay underlying 

 assu.-?.ption within the whole de minimus approach, -an assumption 

 which is not in itself rational or scientific, but social and 

 political. This is the assumption of an 'acceptable' dose. This 

 assumption structures all the research efforts and is the context 

 for all the lAEA/NEA efforts. The base-line is held to be the 

 ICR? recommended dose-limit of 500 mrem/annum for members of 

 the public exposed to radiation from man-made sources, and a 

 further recommendation that all doses are as low as reasonably 

 achievable (ALARA principle), having regard to economic and social 

 factors. 



Thus the IAEA's whole revised definition rests upon the 

 assumption that an internationally acceptable level of exposure 

 exists for wastes dumped in international waters and which may 

 give rise to radiation damage in populations other than those 

 who produced ■ the waste. This assumption is clearly questionable, 

 especially when the waste arises from civil nuclear power programmes, 

 as opposed to pure research or medical uses which might be held 

 to be of universal benefit. 



A closer look at the ICRP reveals that it is a heavily criticis- 

 ed body, in terms of its international role. A former ICRP chairm.an, 

 and leading US authority on radiation protection, Prof.K.Z. Morgan, 

 has charged it with conservatism in the face of recent research 

 suggesting a revision of basic risk-factors, and the present 

 chairman of the prestigious US National Academy of Sciences, 3EIR 

 Committee (Biological Effects of Ionising Radiation) has remarked 

 that it a self-selected, self-perpetuating body, (elected wi~hin 

 a core of professional radiologists) , which is answerable to 

 nobody, and has. mixed scientific judgement (on risks) with economic 

 factors relating to industrial practice, to produce recommended 

 dose limits, (its aim being to equalise nuclear industry exposure 

 risks to those of other industrial risks). 



There are several assvimptions in the ICRP approach, but 

 the key one is that the nuclear industry can be classified along 

 with other industries or activities (and risks) accepted by society. 

 This may have been true in the 1950' s when the limits were recommend- 

 ed, (and when the IAEA first recommended the application of the 

 ICRP limits for ocean disposal practices), but it is clearly 

 not tenable when large sections of the public, and indeed, whole 

 states, (e.g. Austria) have decided that the nuclear industry 

 does not provide a net benefit. 



In conclusion, t'r.erefore, the ICRP dose limits, upon which 

 the de minimus concept is based, cannot be viewed as 'oniversally 

 acceptable. States which receive no direct benefit from other 

 states' nuclear power programmes, or which regard the nuclear 

 enterprise as uniquely dangerous to the earth's environment (through 

 ei"her accident risk, or weapons proliferation) , have no reason 

 to accept ICRP limits, and indeed, any radiation -ixacsure from 

 another state's nuclear orogramme. 



