Toward a New Paradigm for Risk-Based Radiation Policymaking

OBJECTIVE: To accomplish a systematic review of documents indexed by PubMed and the Nuclear Regulatory Commission public records database to explore the use and suitability of Risk Tradeoff Analysis as a means of informing U.S. radiation policymaking. METHODS: The aforementioned databases were searched using the inclusionary terms “risk trade”, “risk tradeoff”, and “risk tradeoffs” and exclusionary terms related to patient choices and preferences and animal predation. Unique documents that were printed in English and concerned with matters of public health were coded according to target risk, constructs of comparative risk assessment, and relevance. Relevance was rated high when constructs of risk tradeoff were discussed in conjunction with radiation risks and low when such constructs were presented in association with other risks. Results are tabulated and followed by a mostly narrative synthesis of findings. RESULTS: A total of 64 relevant documents were returned by the search, 60 from PubMed and four from Web-based ADAMS. Only eight documents were determined to be highly relevant (i.e., concerned with radiation risks), four from PubMed and four from Web-based ADAMS. Only one of the highly relevant documents reflects an analysis of 9 risk tradeoff, whereas the majority (75%) express a need for forward-thinking policymaking that considers countervailing risks. CONCLUSIONS: The paradigm for radiation protection policymaking should be remade in a manner that looks beyond the perceived immediate benefits of dose-limiting regulations, and Risk Tradeoff Analysis provides a logical framework that has benefited other public-health related decision making. Introduction Radiation exposure is a dreaded environmental hazard, with evidence of public fears tracing back to atomic bombings that occurred in Japan in 1945 and the media reports and Hollywood embellishments that followed (Walker 2000, Jones 2005). The reality of the evidence contemplating radiation’s effects on humans, however, is that the risks attributable to low, and in particular, very low, levels of ionizing radiation on humans are unknown (GAO 2000, Tubiana et al. 2009). Epidemiological studies do not have the statistical power needed to describe the dose–response relationship at low doses (Suzuki and Yamashita 2012). Moreover, the actual risk remains unknown in the presence of data from hundreds of thousands of diverse human subjects that have been collected over the better part of a century. That is, the fact that the exact risk remains unknown is not because scientists lack data, but because the preponderance of data suggest that the risk is so small at low doses that it cannot be discriminated. Due in part to the public’s perception of the seriousness of exposure to environmental radiation, policymaking is accomplished according to the paradigm that any amount of radiation is harmful and should be avoided (Cohen 2002, Calabrese 2013, Doss 2013). Because the U.S. framework for policymaking is highly fragmented, 10 multiple federal agencies demonstrate some responsibility for protecting the public from radiation (Levi 1946, U.S. Congress 1946, GAO 2000, GPO 2001). The result is a patchwork of detailed and rigid radiation protection policies that are largely unrelated to each other and do not seek unified health outcomes except to reduce dose to as low a level as reasonably achievable. An implicit concern of regulatory action is that well-intentioned efforts to reduce one risk may cause other adverse health outcomes (Viscusi 1994, Graham and Wiener 1995). These adverse outcomes are “costs” of the regulatory action. These costs are not exclusively financial; rather, they encompass any type of countervailing risk that arises (Hofstetter et al. 2002). Whenever the portfolio of risk is changed by an action that knowingly or inadvertently generates a countervailing risk (i.e., cost as previous described), a risk tradeoff is said to have occurred (Graham and Wiener 1995). Thus, policies aimed at reducing dose because any amount of radiation is presumed harmful may unknowingly lead to important risk tradeoffs, especially if the risks due to radiation are lower than predicted or nonexistent as suggested by contemporary critics (Tubiana et al. 2009, Suzuki and Yamashita 2012, Doss 2013). Until the benefits sought by dose-limiting regulations are compared against countervailing risks with a suitable comparative analysis method, we cannot be sure if such policymaking results in optimal