1A CRITICAL ASSESSMENT OF THE ICRP SYSTEMFROM A SCIENTIFIC PERSPECTIVE
From a set of social and economic commandments
to a system representing human rights and science
Katsuma Yagasaki
Professor Emeritus, University of the Ryukyus

The International Commission on Radiological Protection (ICRP) has arbitrarily introduced many concepts
that go against scientific principles. It is not a system founded upon science. A scientific and democratic
viewpoint is necessary in order to objectively criticize the ICRP.

§1 The Commandments, Utilitarian Philosophy and Hidden Nuclear Warfare of the
ICRP System(1) Lack of scientific foundations: disregard of definitions and deviation from causality
The ICRP is not a scientific system, but a set of “social and economic” commandments. These labels,
borrowed from the international nuclear lobby, are used to mean “not hindering nuclear propulsion” and “notplacing a heavy burden on the state and its industry.” The meaning of “commandments” here is a set of rules
governing nuclear weapons and nuclear power production that have developed into a regulatory system.
Characteristics of the ICRP Commandments① Physical quantities not used according to the proper definition② Constructed with arbitrary physical quantities, in defiance of the principles of science and causality
This is not a system based on science.

Brief Explanation① Not using physical qualities and quantities according to the proper definition is the same as removing the
backbone of science.
To expand,
1.

Units of measurement of absorbed dose are limited to “per internal organ/tissue”

2.

Exposure dose is used instead of absorbed dose1

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② Arbitrary amounts are set in a high-handed manner and in violation of the principle of causality, which isthe very pillar of scientific concepts.

The ICRP uses factors such as biological equivalent dose, radiation weighting factor, tissue weighting factor,
effective dose and so on to create notions that go against the fundamental principles of science. If one kind ofradiation has larger output (damage) compared with the others, ICRP multiplies the actual radiation energy(input) by the radiation weighting factor, and assumes that value to be the energy of that kind of radiation.
This multiplied absorbed dose is referred to as equivalent dose.
A causal relationship can be explained thus: An action or stimulus (input) is imposed on a subject. A responseto that stimulus arises inside the affected subject. Some phenomenon (output) is observed as a result of this
response. ICRP does not apply the logic of “the response arises as a result of the stimulus to the activatedsubject.” The excited internal reaction is not considered on scientific basis and is closed in a black box.
Closing this response relationship in a black box means they are using metaphysical formal logic, saying thatthe damage (output) is large because the radiation energy input is large.
Using this approach, the output of damage to health can be restricted to only the diseases accepted by ICRP:
cancer and a few types of tissue damage. It is a way for the commandments of those in power to make thehealth effects of radiation appear to be less than they are, and these commandments are unfortunately incontrol of the world.
The ICRP has denounced the description of a causal relationship and made a complete departure from science.
The following are some of the physical quantities created high-handedly and in defiance of the principle ofcausality:
1.

Radiation quality weighting factor, biological equivalent dose2.

Tissue weighting factor, effective dose (units: Sievert)

These factors are used without clarifying the action of radiation, and the effects on living organisms are closed
inside a black box. This black box has made it possible to confine radiation damage to a very narrow range of
diseases.

(2) Utilitarian philosophy, which contradicts human rights and democracy

The ICRP’s 3 principles of radiological protection (justification, optimization and dose limits) are utilitarianand contradict democracy and human rights. We can think of these principles in terms of comparing risk tolife (personal rights) to the business activities of industry.
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The principles state the following:① The principle of justification: If the common good is served, then the processes that cause health damage
by radiation are justified.

② The principle of optimization of protection: Protective activities should be based on social and economic
factors and carried out in moderation.

③ Dose limits: Dosage limits must not be so strict as to hinder industrial activity.

These principles have been accepted by many countries of the world. The first principle, that of justification,
can almost be seen as a threat to democracy by the nuclear industry.
Politically, it is a practical policy of nuclear dominance based on the Treaty on the Non-Proliferation of
Nuclear Weapons. In reality, the treaty enforces the continued promotion of nuclear power plants and thenuclear arms monopoly which they complement, and which is based on nuclear deterrent force.

(3) Hidden Nuclear Warfare

The above-mentioned characteristics of the ICRP system are derived from its purpose of undervaluing nuclear
damage, both scientifically and philosophically. This is why Katsuma Yagasaki uses the term “Hidden
Nuclear Warfare.” This refers to the tactics they use to make exposure seem lower, by disregarding
measurements and investigation and by the lack of integrity of their measured values. Another method used istheir extremely narrow definition of health effects caused by radiation.
This is illustrated by the following representative examples:① Although the legal radiation dose limit is set based on the full amount of environmental exposure, theJapanese government follows the ICRP by reducing it to exposure during daily activities, thereby forcing
radiation exposure on its citizens.
Japanese laws have been made based on the “Ministerial Ordinance for Commercial Nuclear Power Reactors
Concerning the Installation, Operation, etc.” This ordinance defines the inhabited “peripheral monitoring zone”
as the area in the vicinity of a controlled access location, and any place beyond the exterior of this area where
the radiation dose may not exceed a dose limit set by the Minister of Economy, Trade and Industry (Article 2,paragraph 6). This dose limit (effective dose) was set as 1mSv per year (Ordinance paragraph 3).
What is important to note here is that the limit is set on the environmental radiation of the affected area. In
addition, the Environmental Radiation Monitoring Guidelines state that “fundamental data on thecontaminated environment”, which is information provided to many areas, must use the air absorbed dose rateof gamma rays (in Greys per hour or Gy/h).
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The calculation method proposed by The Japanese Government for absorbed dose rate, which corresponds to
1 mSv per year, is in clear violation of this guideline. Treating environmental dose as environmental
contamination, if one were to simply convert from 1 year to 1 hour, the figure would be a physical amount of
0.114 μSv/h. However, the government does not present the environmental dose, but instead calculates a dosefor daily activities, based on the assumption that people spend 16 hours a day indoors and 8 hours outside, andthat the strength of irradiation indoors is 40% of that experienced outdoors. This amount is equivalent to
0.19μSv/h, 60% of the environmental dose, which increases to 0.23μSv/h when background radiation rate isincorporated. This value, which does not obey the law, is said to correspond with 1mSv per year.

② Monitoring posts: The systems in place show only half of the dose values measured by Yagasaki and co.
③ While investigation is supposed to be the responsibility of the state, this so-called civilized nation neither
conducts investigation nor collects data, thereby abandoning its people. Specifically, “no data” is taken tomean “no data showing damage from radiation,” which translates to “there is no damage from radiation.”
Prime Minister Shinzo Abe’s statement at time of the Olympic bid that “There have been no health problems
and nor will there be” is a shrewd application of this political strategy.

A detailed explanation of the above points is necessary in order to objectively criticize the ICRP. However,this assessment will focus only on the scientific side of the issues.

§2 Physical quantities not used according to definition

Definition of absorbed dose
To begin with, the definition of absorbed dose is as follows:
D = dE / dm
Where D is the absorbed dose and E is the amount of energy transferred by radiation to mass m. The formulacalculates the ratio of infinitesimal energy to the infinitesimal mass to which the radiation is transferred.
Absorbed dose is defined as the absorbed energy transferred to an infinitesimal mass (ICRP recommendation,1990).

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5① Using “per type of internal organ/tissue” as a unit of measurement: selling internal exposure short
It was announced at the same time in the same recommendation that “per type of internal organ/tissue” would
be used as a unit of measurement.
For external irradiation, for which ionizing action is distributed over a wide range, as well as Potassium-40
irradiation, the exposure expands to affect the whole body. In these cases, per-organ measurements can beused to approximate the level of exposure.

As for internal irradiation, especially that brought about by particle radiation, the ionization is concentrated
and the range of alpha and beta rays is short, which means that radiation exposure is focused on certain areas
and the majority of cells are not ionized. First of all, it can be shown that derivation is not carried out as
defined, based on the spread of ionization in internal radiation.
Measuring per organ results in a very large calculation denominator for non-irradiated cells (those that do notundergo ionization) as well as an extreme underestimation of the high-dose radiation in the areas surrounding
the ionized microparticles. The ICRP states that cancer originates from the division of individual cells with
DNA anomalies. This self-produced definition functions as a red herring to obstruct the real conditions ofcancer outbreak and divert attention from the dangers of internal irradiation. Furthermore, by saying thatexternal and internal irradiation are the same thing, they are trampling on their own definition.

Also regarding internal radiation, water-soluble radiation (in which decomposition to single atoms occurs)
permeates throughout the body, circulating via blood and lymph, in keeping with biological half-life. There isalso chemical/physiological affinity, which is not in accordance with biological half-life. Insoluble radiation,
where particles accumulate in one area of the body, is different to soluble radiation in that it isdisproportionately higher in the organs. In the case of soluble radiation, organs with large blood flow arecontinuously exposed to high-level radiation, but even this effect is covered up.

§3 Absorbed dose replaced with exposure dose
Units of exposure dose are modified to match absorption dose56
By estimating effective dose from phantom measurements, everything is replaced with irradiation (surface
exposure). While creating their own definition of absorbed dose, the ICRP system replaces every instance ofabsorbed dose with surface exposure.
Humans, mice and cultured cells vary in thickness, so even with the same amount of surface exposure theirabsorption doses will vary greatly. Smaller organisms show lower absorption doses and higher leakage doses.
This results in gross overestimation of absorbed dose in cell culture and animal experiments, and factors suchas the threshold amount of remaining unrepaired DNA are elevated by several orders of magnitude.
Consequently, the effects of low-dose radiation are ignored. Organizations like the ICRP and UNSCEAR are
neglecting important scientific facts.
As illustrated in Figure 1, absorption dose is the amount subtracted from radiation exposure to give transit
dose (the amount that passes through the other end). When measuring absorption dose in an experiment, themeasuring instrument is placed in front of and behind the blue object, and the difference between thosemeasurements is the absorbed dose. However, in today’s experiments, the instrument is placed at a location
corresponding to the depth from the surface of the phantom model to the organ, starting with 1cm ofequivalent dose. The dose measured is recorded as the effective dose of the organ. Although it would be more
appropriate to call this measurement the exposure (surface dose) received by the organ, in these experiments
effective (absorbed) dose is equated with surface dose. Factors such as the thickness of the organ are not being
taken into account, and all exposure is added into the absorbed dose. In this explanation, the phantom model isan anatomical model of the human body used to estimate the effects of radiation on humans.

Figure 1 Exposure, absorption dose, transit dose. The blue object represents the body of the organism being observed. Transit dose(the amount that passes through and out the other end) does not have any ionizing effect on living organisms. Absorption doseshould be measured by taking measurements at the front and behind the blue object and calculating the difference between them.

The actual absorbed dose is just a percentage of the radiation dose. The same can be seen with the dose
evaluation of the victims of the atomic bombings. All the initial radiation at the site of the nuclear chain
reaction was calculated using distance from the blast, and this attained dose (the dose that reaches the body)was taken as the absorbed dose. While they did take into account the fact that people who were in the shadowsof buildings were shielded from the blast, all external exposure was used as absorbed dose.
The differences between the effects of external irradiation (gamma rays and neutron radiation) and internal
irradiation (alpha, beta and gamma rays) were completely ignored, and internal exposure was calculated on
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the same scale as external radiation. The radioactive fallout, which caused internal exposure, was measured(disregarding what was washed away by heavy floods) and reported to be a small enough dose as to pose no
threat to health. The results of animal and cultural cell experiments are also discussed only in terms ofradiation exposure.

A perfect example of confusing exposure and absorbed dose can be found in the research of Shun’ichi
Yamashita’s group: Effects of Low-Dose Radiation on the Induction and Exclusion of DNA Damage(Masatoshi Suzuki et al, Nagasaki University School of Medical Sciences Journal 87, 239 (2012)). The
research is described as being performed by cultivating cells on sterilized cover glass and exposing them to Xrays with a dose rate of 200mGy/min.
In the discussion, they say:“In examining the effect of radiation exposure on DNA damage, even as low a dose as 100mGy was clearlyfound to cause DNA damage.”“At a level of 100mGy, before 6 hours had passed the majority of DNA damage was gone. Further, within 24
hours it was observed that the cells had returned to their original condition from before the exposure. Of
course, as there were foci present from before the exposure, it is difficult to determine whether or not all theradiation-induced DNA damage had been removed. However, from the fact that the ratio of focus-positive
cells and the number of foci near the cell nuclei had returned to their original states, we have shown, with theresults of not just simple numerical analyses but also qualitative analyses, that it is correct to say thatradiation-induced DNA damage was completely repaired and removed.
From the above-mentioned results, we conclude that DNA damage caused by 100mGy low-level radiation is
at a level that cells can handle. So, what level of radiation is too much for cells to deal with? In the results ofthis experiment we confirmed that above 250mGy of radiation exposure there was residual DNA damage thatwas not repaired after 24 hours. Observing the movement of DNA repair, it was seen that even after 24 hours
there was a slight decrease in the amount of DNA damage. Even taking that into account, it was clear thatDNA damage caused by 250mGy exposure cannot be fully repaired. Therefore, the lower limit of radiation
exposure where cells can handle DNA damage is higher than 100mGy but lower than 250mGy.”

In this discussion there is no distinction between exposure and absorbed dose, as the only expression used is“low radiation exposure level of 100mGy.” This expression is a reflection of the true nature of ICRP’s dose
evaluation.
Assuming that the half-value layer was 100ml and the thickness of the culture fluid was 1mm, we can estimate
the dose absorbed by the culture fluid. The result is that the absorption dose at which DNA damage was7

8almost entirely repaired was not 100mGy but 0.69mGy, and the dose at which all DNA damage could
not be repaired was not 250mGy but 1.73mGy. Incidentally, the half-value layer is the distance at which
the strength of the introduced radiation is halved.
The following equation calculates the strength of radiation when moving a distance 1 through a single
material:

Ｎ(l)＝Ｎ０e-(log2/L)lwhere
N (1) is the radiation strength after passing through a distance l, andN0 is the radiation strength at the point of insertion in the substance.
If we assume the length of target substance is l, the absorbed radiation Nabsorb is as follows:
Nabsorb =Ｎ０ -Ｎ(l).
We need to evaluate the value of Nabsorb for absorbed dose.
Narrowing down the focus to absorbed dose, the conclusion should not be “at 100mGy all DNA damage isrecovered” but “at 0.69mGy all DNA damage is recovered,” and not “at 250mGy DNA damage is not fully
recovered” but “at 1.73 mGy DNA damage is not fully recovered.”
The problem lies with taking the whole dose that the cells cultured on top of the cover glass were exposed toand making it the same thing as the absorbed dose. The majority of the rays would go right through theextremely thin cell layer and out the other side. The amount of energy applied to the cells by ionizing the cellorganization (energy counted into absorbed dose) is exceedingly small, but this team is using the erroneous
ICRP idea that the energy of the radiation coming out the other end is also “absorbed.”
They consolidated their experiment’s results thus: that 24 hours after exposure to 100mGy of radiation all of
the DNA damage was repaired, and that at 250mGy of radiation exposure the damage repair was not perfectand damaged cells still remained. However, their values of 100mGy and 250mGy as effective dose are a grossoverestimation. Taking total exposure as effective dose is an outrageous error, but one that is part of ICRP’s“resolutions” and is inevitable to occur as compelled by the ICRP system.
A more accurate calculation instead yields values of 0.69mGy and 1.73mGy, respectively. When they say that“below 100mGy all damage was repaired” it should actually be “at an absorbed dose of 0.69mGy all damage
was repaired.” Likewise, instead of “at 250mGy DNA damage was not all repaired,” they should say that “atan absorbed dose of 1.73mGy there was remaining DNA damage.”
A Swiss study performed on over 2 million children below the age of 16 examined the link between
background radiation and childhood cancers. In the study they report the cancer hazard ratio as 1.04 per 1mSv

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9of cumulative dose (Spycher BD et al., Environ. Health Perspectives, 123, 622-628 (2015)). The
aforementioned research of Suzuki et.al. endorses the results of this study.
The results of correct scientific processing are proof that even at a level of 1.7mGy, unrepaired genetic
anomalies persist and can be linked to carcinogenesis. In this way, the physical application of their selfdefined “absorbed dose” is consistently and systematically flawed. As in the above example, where although
DNA damage persists at an absorbed dose of less than 2mGy, they instead come to the false conclusion that
100mGy is safe because there is no remaining DNA damage.
Likewise, saying “Below 100mSv is safe” has no scientific basis and is an outrageous claim. Not only
Yamashita Group, but almost all animal and cell culture experiments use this technique. Threshold levels andthe radiation dose at which the causes of “harmful tissue response” and “stochastic effect” start to appear are
deduced excessively. In the above experiment, threshold dose and so on are estimated at 150 times higher thanthey should be, and the result is that there are now campaigns featuring the claim that low-dose radiation issafe and harmless.
Because of this manipulation, an immeasurable amount of “harmful tissue response” and “stochastic effect”
owing to damage brought about by low-level radiation has been ignored or underestimated, and countless
victims have been discounted.
For more information, please read the article below (Japanese only).
https://www.sting-wl.com/yagasakikatsuma19.html§4 Destruction of the principle of causality, removing the backbone of science① Radiation weighting factor (1990 and onwards), biological equivalent dose

When an object is subjected to a stimulus, a reaction occurs in that object in response to the stimulus, and as aconsequence of that reaction (a result of receiving the stimulus), some phenomenon is observed. The stimulus
described here is an action that forms the cause of the phenomenon (result). In data processing terms wewould call this the “input.” As such, the phenomenon that results from the stimulus (i.e. the result brought
about by the action to which the object is subjected) would be called the “output.”
The scientific approach is to discuss the relationship between the response and the result, and to represent the
principle of causality. The ICRP system fails to apply this most fundamental logic.
To explain biological equivalent dose: supposing damage from alpha rays was 20 times that of beta andgamma rays, then the radiation energy of the alpha rays would also be 20 times larger. So, if the actual
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radiation dose of alpha rays was 1mGy, then multiplying by 20 gives 20mSv, which is biological equivalentdose. A radiation weighting factor of 20 means a “biological equivalent dose” of 20 times the radiation energy,
based on the fact that alpha rays cause extensive health effects. “Biological equivalent dose” is an imaginary
physical quantity.

This ignores the principle of causality. While this expression may be useful in the medical field and so forth,
the radiation weighting factor ignores the mechanisms and responses inside the object (organism), and uses asingle value to express the fact that energy was large, which is entirely unscientific.
Saying that a large output occurs simply because of a large input is the same as enclosing the organism’s
response process inside a black box. By doing so, limiting the output to cancer greatly underestimates theadverse health effects of radiation and provides the system with a scientific smoke screen, going against the
principle of causality. This scientific smoke screen continues with quantities such at the tissue weighting
factor. This is part of the ICRP’s imperial domination.

② Tissue Weighting Factor (1990 and onwards)
Essentially, tissue weighting factor is set according to the incidence of cancer and was created with thereasoning that effective dose could be divided between the tissues.
The idea of dividing absorbed dose amongst organs by way of tissue weighting factor shows another of
ICRP’s arbitrarily composed, mysterious physical quantities. It is the same kind of error as if we were to add
the population densities of each prefecture and claim the result as the population density of the whole country.
It is not a scientifically rational physical quantity.
Absorbed dose is a quantity defined (and derived) thus: energy from irradiation is divided by the mass which
absorbed that energy and then normalized. If you take the absorbed energy and mass of each tissue and add it
up you get the absorbed energy and mass of the whole body (extensive variable). However, absorbed dosecannot be calculated in the same way (intensive variable). This is the same as the population density example
above.
Further, calculating effective dose by multiplying the actual absorbed dose by tissue weighting factor brings
about a considerable underestimation. This is the second of ICRP’s cheap tricks.
Calculating “effective dose” by this outrageously arbitrary composite restricts the effects of irradiation tocancer only, and serves as the culmination of ICRP’s imperial deception, designed to play down the scope ofdamage. An “imperial deception” idea means that the ICRP possesses an imperial-like controlling power,
which it uses to force its illogical ideas on the public.
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11③ The unit called “Sievert:” Terminology that runs counter to science’s fundamental spirit ofrationality
The unit called “Sievert” is used for fictional physical quantities that arbitrarily modify absorbed dose on
several levels. The first of these is biological equivalent dose, which is radiation quality weighting factor
added to the strength of radiation energy.
The second is effective dose, which is obtained by dividing absorbed dose among the internal organs
according to tissue weighting factor. The ICRP systematizes the underestimation of damage by limiting theassessment adverse health effects to cancer only, making it a system that is not up to the standards of science.

§5 In Supplement(1) The ICRP’s 3 principles of radiological protection serve as a system whose anti-democratic doctrines defy
human rights and justify the existence of the nuclear industry.
For example, the first principle, “justification,” certainly claims that loss of life due to radiation can beforgiven if it works in favor of the public good. To put it frankly, this is a societal justification for murder via
radiation from nuclear power stations, and part of the nuclear industry’s defensive “so-what” attitude.

(2) By standardizing the units of absorbed dose and exposure, many of their concepts can be applied invarious areas, as is convenient for the country and nuclear power companies. The first and foremost of theseapplications is the use of “effective dose” to claim that the low numbers shown on glass badges are valid.
Radioactive contamination and the doses shown on monitoring posts are defined in legal terms as “amounts
expressing the contamination of the region” and “atmospheric absorbed dose.” Regardless, the calculation of
exposure from daily activities (16 hours spent inside and 8 hours outside, and so forth) was introduced, which
greatly undervalues the amount of irradiation. Further, the monitoring posts set up both within and outside
Fukushima prefecture only reflect half the absorbed dose to which the citizens are being exposed. Considering
these facts, we can say that the ICRP system does not exist to protect citizens (against radiation) but rather toprovide a full-scale smoke screen to hide the damage caused by radiation.

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