Low-Dose Radiation: Interagency Collaboration on Planning Research Could Improve Information on Health Effects
Published: 2017-09-26T00:00:00

Fast Facts:
Exposure to low doses of radiation may increase a person's risk of cancer. To help protect workers and the public against this risk, federal agencies set dose limits for power plants, issue guidance, and take other measures.
The Department of Energy and other agencies have also invested millions to better understand the health effects of low-dose radiation, but uncertainty remains. Given the reduction in funding for low-dose radiation research, agencies will need to work together to determine how to best use resources to address research priorities in the area.
We recommended that Energy lead efforts to enhance such interagency collaboration.

Highlights:
section_title: Why GAO Did This Study
paragraphs: According to EPA, exposure to low doses of radiation does not cause immediate health effects but may increase a person's cancer risk. Federal agencies fund research on cancer risk, but uncertainties remain about risk assessments that federal agencies use to develop radiation protection regulations and guidance.
GAO was asked to examine federal agencies' radiation protection requirements and guidance and related research. This report (1) describes how selected federal agencies have developed and applied radiation protection requirements and guidance and (2) examines the extent to which federal agencies have funded and collaborated on research on low-dose radiation's health effects for fiscal years 2012 to 2016.
GAO selected four federal agencies, based on their development of requirements or guidance for settings in which radiation exposure to workers and the public can occur. GAO reviewed agency documentation and interviewed agency officials on the development of the requirements and guidance. GAO also collected and examined federal-funding data for low-dose radiation research from seven agencies that fund this research.
section_title: What GAO Found
paragraphs: The Department of Energy (DOE), Nuclear Regulatory Commission (NRC), Environmental Protection Agency (EPA), and Food and Drug Administration generally used the advice of scientific advisory bodies to develop and apply radiation protection requirements and guidance for workers and the public in the radiation exposure settings that GAO reviewed. These settings were: (1) the operation and decommissioning of nuclear power plants; (2) the cleanup of sites with radiological contamination; (3) the use of medical equipment that produces radiation; and (4) accidental or terrorism-related exposure to radiation. Specifically, the agencies relied on the advice of three scientific advisory bodies that supported the use of a model that assumes the risk of cancer increases with every incremental radiation exposure. Accordingly, the agencies have set regulatory dose limits and issued guidance to confine exposure to levels that reduce the risk of cancer, while recognizing that scientific uncertainties occur in estimating cancer risks from low-dose radiation. For example, NRC requires nuclear power plants to consider measures for limiting workers' exposure below NRC's regulatory dose limit, such as by using robots for maintenance work in radiation areas.
GAO identified seven federal agencies that funded research on low-dose radiation's health effects. In fiscal years 2012 to 2016, DOE, NRC, EPA, and four other federal agencies obligated about $210 million for such research (see table). Although the agencies have collaborated on individual projects on radiation's health effects, they have not established a collaborative mechanism to set research priorities. GAO's previous work has shown that federal agencies can use such mechanisms to implement interagency collaboration to develop and coordinate sound science policies. In the past, DOE took a leading role in this area because DOE provided stable funding and advocated for greater coordination on research on low-dose radiation's health effects. However, since fiscal year 2012, DOE has phased out funding for one of its main research programs in this area. This has created a void in coordination efforts among federal agencies, and no other agency has stepped forward to fill this void. Because of DOE's prior experience as a leader in this area of research and its research responsibility under the Atomic Energy Act of 1954, it could play an important role in helping federal agencies establish a coordinating mechanism for low-dose radiation research.
Dollars are in millions and have not been adjusted for inflation
Source: GAO analysis of agency data. | GAO-17-546
section_title: What GAO Recommends
paragraphs: GAO recommends DOE lead development of a mechanism for interagency collaboration on research on low-dose radiation's health effects. DOE disagreed, stating that agencies set their own research priorities. GAO continues to believe that DOE is in the best position to lead such an effort, as discussed in the report.

section_title: Letter
paragraphs: Ionizing radiation—which comes from both natural sources as well  medical, commercial, and industrial activities—has a number of beneficial  uses, including treating cancer or sterilizing medical equipment, but can  also be harmful. Ionizing radiation is considerably more energetic than  non-ionizing radiation, such as radio- or microwaves and visible or  infrared light, and thus has a greater effect on human health. According  to the Environmental Protection Agency (EPA), the severity and type of  health effects depend in part on the amount and duration of exposure. A  very large amount of exposure, such as from a nuclear explosion, can  cause sickness or even death within days. According to EPA, low levels  of exposure are not known to cause acute health effects but may increase  a person’s risk of developing cancer or other health effects, such as  genetic mutations, during the individual’s lifetime.
To prevent cancer and other harmful effects associated with exposure to  radiation, EPA, the Nuclear Regulatory Commission (NRC), and other  federal agencies have established requirements and issued guidance that  apply to a wide range of settings in which such exposure can occur.  These requirements and guidance generally follow radiation protection  principles that call for radiation exposure to be justified by producing a net  benefit and by keeping within regulatory limits (i.e., limits on the dose or  limits on the increased risk to health) or, for emergency situations, limits  established by non-binding guidance on exposure levels designed to  protect those affected. These regulatory limits and guidance levels that  federal agencies have established include:  limits on occupational dose, such as for nuclear power-plant workers  and medical personnel whose work involves the use of radiation;  limits on dose or increased health risk for members of the public from  a facility, such as a nuclear power plant or industrial site with  radiological contamination; and guidance levels for protecting workers and members of the public  during an emergency response to an accidental or deliberate incident  that exposes them to radiation, such as an accident at a nuclear  power plant or a radiological dispersal device (also called a “dirty  bomb”).
The Department of Energy (DOE) and other federal agencies have  funded research to determine the health effects of exposure to low levels  of radiation; however, uncertainties remain in understanding the health  effects, including the risk of cancer. These uncertainties raise questions  about whether dose limits and guidance levels have been set  appropriately. For example, there are concerns that the dose limits and  guidance levels may be too low, increasing costs to reduce radiation  exposure unnecessarily. In contrast, there are also concerns that the  dose limits and guidance levels may be too high, causing greater harm  than assumed based on limited understanding of the risks.
Several organizations that provide guidance and recommendations to  federal agencies on radiation protection have identified research needs to  better understand the health risks from low levels of radiation exposure.  For example, in 2006, the National Academies of Sciences, Engineering,  and Medicine (National Academies) published the seventh in a series of  reports to advise the U.S. government on the relationship between  exposure to radiation and human health. The report identified research  needs in a number of areas, such as occupational radiation exposures  among nuclear industry workers, to help estimate the risk of cancer from  low-dose radiation, which occurs at levels where the biological effects  may not be detected and where current research does not definitively  establish the extent of cancer risk. In 2015, DOE directed its Biological  and Environmental Research Advisory Committee to provide advice on  defining a research program that could lead to conclusive results on  whether low-dose radiation causes cancer in humans. In 2016, the  committee issued a report stating that further research on the cancer risk  from low-dose radiation could decrease uncertainty in cancer risk  estimates. For example, according to the report, new tools for conducting  biological research could advance the understanding of connections  between radiation exposure, DNA damage, tissue responses, and cancer  development.
You requested that we examine federal agencies’ radiation protection  requirements and guidance and related research. This report (1)  describes how selected federal agencies have developed and applied  radiation protection requirements and guidance for workers and the public  and (2) examines the extent to which federal agencies have funded and  collaborated on research on the health effects of low-dose radiation.
To describe how selected federal agencies have developed and applied  radiation requirements and guidance for workers and the public, we first  selected a sample of four settings in which radiation exposure can occur:  operation and decommissioning of nuclear power plants, cleanup of sites  with radiological contamination, use of medical equipment that produces  radiation, and accidental or terrorism-related exposure to radiation. We  selected these four settings because they can result in radiation exposure  for both workers and the public and because they involve a variety of  federal agencies and sites where exposure can occur. Next, through a  review of federal radiation-protection requirements and guidance, we  identified four federal agencies that have developed requirements or  guidance for these four settings—EPA, NRC, DOE, and the Food and  Drug Administration (FDA) within the Department of Health and Human  Services (HHS). Findings from our reviews of these four agencies in the  four settings we selected cannot be generalized to all agencies and  settings in which radiation exposure can occur but provided illustrative  examples.
For each of these four settings and selected federal agencies, we  reviewed agency documentation and interviewed agency officials on how  they developed radiation protection requirements and guidance and how  they apply them in practice. In addition, we interviewed stakeholders  involved in the four selected settings to obtain their views (1) on the  scientific assumptions federal agencies used in developing requirements  and guidance and (2) on the costs and benefits associated with applying  the requirements and guidance. We selected stakeholders who had  studied, issued policy statements on or raised concerns about federal  radiation-protection efforts in the four settings in our review and who  represented a range of private-sector, professional, state-government,  and environmental and public-health interests. Stakeholders we selected  included officials from state agencies responsible for radiation protection  and representatives of organizations active in the nuclear power industry  or radiology and of nonprofit organizations that study issues related to  radiation exposure.
To better understand how federal agencies have applied requirements  and guidance, we visited three sites—two DOE sites and one EPA site— with radiological contamination: DOE’s Savannah River Site in South  Carolina and Site 300 at Lawrence Livermore National Laboratory in  California, and the Nuclear Metals, Inc. site in Massachusetts, overseen  by EPA. We selected contaminated sites to include at least one large site  and one small site, and at least one site managed by DOE and one  overseen by EPA. We also visited a commercial nuclear-power plant to  observe measures used by the plant to limit radiation exposure, and we  interviewed plant personnel regarding their radiation protection program.
We selected a nuclear power plant that was close to one of the  contaminated sites we selected and that was able to provide access to  us. We interviewed DOE, EPA, and contractor officials at the  contaminated sites regarding the measures used for cleanup of  radiological contamination and how agencies apply radiation  requirements when making cleanup decisions.
For further information on how agencies have developed and applied  radiation requirements and guidance, we reviewed the reports of national  and international organizations that agency officials and documentation  cited as providing advice and recommendations to agencies involved in  radiation protection in the United States or other countries. These  organizations included the International Commission on Radiological  Protection (ICRP); the National Council on Radiation Protection and  Measurements (NCRP); and the National Academies. In addition, we  reviewed documentation from and interviewed officials at five other  agencies we identified that play a role in developing or applying radiation  protection guidance and requirements. These agencies were the  Occupational Safety and Health Administration (OSHA) within the  Department of Labor, the National Aeronautics and Space Administration  (NASA), the National Institute of Standards and Technology (NIST) within  the Department of Commerce, the Department of Defense (DOD), and  the Department of Homeland Security (DHS).
To examine the extent to which federal agencies have funded research  on the health effects of low-dose radiation, we interviewed officials at a  total of 11 agencies—at each of the nine agencies listed above, and also  at the National Institutes of Health (NIH) within HHS because it is a main  source of federal funding for medical research, and at HHS’s Centers for  Disease Control and Prevention (CDC) because it funds research to  advance the agency’s public health mission. In particular, we interviewed  agency officials to determine which agencies fund related research,  including either epidemiological research on populations of individuals  exposed to radiation or radiobiological research on cellular responses to  radiation exposure. For the purposes of this review, we also included  federal agencies’ funding of research on high-dose radiation (radiation  exceeding the level considered to be low dose) if agency officials  indicated that it had potential implications for low-dose research—for  example, by helping to address uncertainties in the risk of health  outcomes from low-dose radiation. We then requested the seven  agencies that had funded such research to provide data on obligations for  such funding for fiscal years 2012 through 2016 and information on the  type of research funded (epidemiological or radiobiological) and the  names of individual studies or projects. In addition, we interviewed  agency officials about the research these agencies funded. For one  program in particular, DOE’s Low Dose Radiation Research Program, we  requested funding data for every year since the program’s inception in  1998 because we found that it had been a primary source of dedicated  funding for radiobiological research on the health effects of such  radiation. We assessed the reliability of the data we obtained by checking  for obvious errors in accuracy and completeness and by comparing the  data with other sources of information, such as agency budget  documents. We resolved any data inconsistencies we found through e- mail and telephone communications with agency officials. We determined  that the data were sufficiently reliable for reporting on the amount of  federal funding for research on low-dose radiation and the type of  research funded.
To examine the extent to which federal agencies have collaborated on  research concerning the health effects of low-dose radiation, we included  questions about agencies’ research plans as part of our request for data  on obligations. In addition, to gain an understanding of the areas in which  federal agencies might benefit from collaboration, we interviewed agency  officials about their plans for future research, the potential to use results  of the research in agency efforts to develop and apply radiation  requirements and guidance, and their efforts to foster interagency  collaboration in funding and conducting research. We compared  agencies’ efforts with key considerations we have identified in our prior  work for implementing interagency collaborative mechanisms, such as  interagency task forces, and key practices for enhancing and sustaining  interagency collaboration, such as identifying and addressing needs by  leveraging resources. We also attended a conference on radiation and  health to learn about the results of research in the field and on potential  areas of future research. At the conference, we interviewed individual  researchers from universities who also attended. In particular, to gain  additional perspectives on agencies’ plans for future research and the  potential for agencies to collaborate, we asked researchers about their  areas of research, the support they had received from federal agencies,  and about their views on potential areas for future research and its  relevance to the development and application of radiation requirements  and guidance.
We conducted this performance audit from January 2016 to September  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: According to NRC’s website, radiation doses, such as those received by  survivors of the atomic bombs in Japan, can cause cancers such as  leukemia and colon cancer and, if levels are high enough, acute radiation  syndrome. The symptoms of this syndrome range from nausea, fatigue,  and vomiting to death within days or weeks. The higher the radiation  dose, the sooner the effects of radiation will appear, and the higher the  probability of death. For example, according to NRC’s website, 134 of the  plant workers and firefighters battling the fire at the 1986 Chernobyl  nuclear power plant accident received high doses of radiation and  suffered from acute radiation syndrome. Of these, 28 died within the first  3 months from their radiation injuries.
In contrast, the effects of low-dose radiation are more difficult to detect. In  particular, below about 100 millisieverts (mSv) (10 rem)—the level below  which the National Academies’ 2006 report on radiation and human  health considered radiation to be low dose—data do not definitively  establish the dose-response relationship between cancer and radiation  exposure. It is often not possible to determine the extent to which a  health outcome such as cancer is caused by low dose radiation because  of the potential confounding effects of other chemical and physical  hazards and lifestyle factors, such as smoking and diet. In addition, much  of the data on health effects of radiation exposure come from non-U.S.  populations, such as Japanese atomic bomb survivors, who received a  large exposure to radiation over a short period of time (an acute  exposure), and there is uncertainty about the extent to which the health  effects for these populations can be extrapolated to a U.S. population that  is regularly (chronically) exposed to low-dose radiation.
The roles of federal agencies in developing and applying radiation  protection requirements and guidance vary depending on the setting in  which radiation exposure occurs. For the four settings in our review— operation and decommissioning of nuclear power plants, cleanup of sites  with radiological contamination, use of medical equipment that produces  radiation, and accidental or terrorism-related exposure to radiation—the  key agencies for establishing dose limits and guidance levels are EPA,  NRC, DOE, and FDA.
EPA advises federal agencies about radiation matters that affect  public health and provides technical information for conducting  radiation risk assessments; federal and state agencies use such  assessments to develop and implement radiation protection  regulations and standards. EPA also develops requirements and  guidance for particular settings in which radiation exposure can occur.  For example, EPA has developed regulations to limit discharges of  radioactive material affecting members of the public from operations  associated with use of nuclear energy to produce electrical power for  public use, such as nuclear power plants. In addition, EPA has  developed guidance on establishing protective cleanup levels for  radioactive contamination at sites cleaned up under the  Comprehensive Environmental Response, Compensation, and  Liability Act (CERCLA). It has also developed guidance on levels of  radiation exposure that would trigger public safety measures, such as  evacuation, to minimize or prevent radiation exposure during an  emergency.
NRC is responsible for protecting people and the environment from  unnecessary exposure to radiation as a result of civilian uses of  nuclear materials. Among other things, NRC has established dose  limits for workers and the public exposed to radiation from the  operation and decommissioning of nuclear power plants, as well as  minimum requirements for emergency plans for protecting members  of the public from exposure in the event of a radiological emergency.  NRC also has the primary responsibility for licensing, inspecting, and  regulating medical uses of nuclear material.
DOE is responsible for ensuring that its facilities are managed to  protect workers and the public. As part of this responsibility, DOE has  established radiation dose limits for workers at its facilities and public  dose limits for DOE radiological activities, including cleanup of  radioactive contamination at DOE sites. In addition, under the  Atomic Energy Act of 1954, DOE is the federal agency that currently  has primary responsibility for research related to nuclear energy. This  responsibility includes the protection of health during activities that  can result in exposure to radiation. DOE addresses this requirement  through research to determine if DOE workers and people living in  communities near DOE sites are adversely affected by exposures to  hazardous materials from site operations. DOE’s National Nuclear  Security Administration (NNSA) assists in emergency response to  accidental or terrorism-related exposure to radiation by characterizing  radiation levels in the area of an accident or terrorist event and  providing information to emergency-response decision makers.
FDA has issued radiation safety regulations for medical equipment,  such as diagnostic X-ray systems. According to FDA officials, FDA’s  regulations generally do not limit the dose to the patient but instead  prescribe mandatory performance standards for most radiology  medical devices, such as standards for the display of cumulative time  that an X-ray system is activated. FDA has also developed guidance  for state and local agencies to aid in emergency response planning for  accidental or terrorism-related radioactive contamination of human  food and animal feeds.
Other federal agencies also have roles in radiation protection. For  example, ionizing radiation is addressed in specific OSHA standards for  general industry, shipyard employment, and construction. According to  DOD officials, DOD operates facilities and engages in activities where  radiation exposure can occur and implements occupational and public  dose limits established by NRC and states in which these facilities and  activities are located. NASA sets radiation exposure limits for space flight  and supports research on the health effects of cosmic radiation to better  manage health risks to astronauts. DHS’s Federal Emergency  Management Agency provides guidance on responding to incidents  involving release of radioactive material and has established procedures  for review and approval of state and local emergency plans for the offsite  effects of a radiological emergency that may occur at a commercial  nuclear power facility.
Two U.S. scientific advisory bodies—the National Academies’ Nuclear  and Radiation Studies Board and the National Council on Radiation  Protection and Measurements (NCRP)—and one international body—the  International Commission on Radiological Protection (ICRP)—are  involved in analyzing scientific developments regarding the health effects  of radiation exposure and advising federal agencies.
The National Academies’ Nuclear and Radiation Studies Board  conducts studies on safety and other issues associated with nuclear  and radiation-based technologies. The board has published a series  of seven reports to advise the U.S. government on the relationship  between exposure to radiation and human health, with the most  recent report published in 2006.
NCRP, a congressionally-chartered, nonprofit educational and  scientific body, seeks to formulate and disseminate information,  guidance, and recommendations on radiation protection and  measurements that represent the consensus of leading scientific  thinking. NCRP issues reports on specific issues of concern to federal  agencies, such as on the use of medical equipment that produces  radiation.
ICRP, an independent, international organization with members  consisting of scientists and policymakers in the field of radiological  protection, offers recommendations to regulatory and advisory  agencies on protection against radiation. In addition to addressing  particular areas within radiological protection, its publications describe  an overall system of radiological protection.
Several other organizations are involved in scientific research and  standards setting for protection against radiation. For example, the United  Nations Scientific Committee on the Effects of Atomic Radiation  (UNSCEAR), which includes 27 United Nations states as members of its  scientific committee, has a mandate to assess and report on levels and  effects of exposure to radiation. Its summaries of basic scientific studies,  along with scientific developments reported by the National Academies  and other national organizations, serve as a primary source of information  for NCRP and ICRP. The International Atomic Energy Agency, in  collaboration with other organizations, has issued basic safety standards  for protecting people and the environment from harmful effects of  radiation. It has also issued safety requirements for preparedness and  response for a nuclear or radiological emergency. The World Health  Organization, one of the organizations that has collaborated with the  International Atomic Energy Agency, also supports research on the health  effects of radiation.
section_title: Selected Agencies Generally Used Advice from Scientific Advisory Bodies to Develop and Apply Radiation-Protection Requirements and Guidance
paragraphs: EPA, NRC, DOE, and FDA have generally used the advice of scientific  advisory bodies to develop and apply radiation protection requirements  and guidance for workers and the public for the four radiation settings in  our review. Three scientific advisory bodies—ICRP, NCRP, and the  National Academies’ Nuclear and Radiation Studies Board—have  supported the use of the linear no-threshold model for such requirements  and guidance; this model assumes that the risk of cancer increases with  every incremental increase in radiation exposure. The requirements and  guidance the four agencies have developed and applied vary depending  on the settings, in part because the scientific advisory bodies on which  the agencies relied have also developed recommendations specific to the  settings we reviewed.
subsections: section_title: Support of Scientific Advisory Bodies for Use of the Linear No-Threshold Model
paragraphs: In developing and applying radiation protection requirements and  guidance for workers and the public—specifically, developing limits on  dose or increased health risk and guidance levels on exposure—EPA,  NRC, DOE, and FDA have generally taken the advice of scientific  advisory bodies. This advice includes the use of the “linear no-threshold  model,” which assumes that the risk of cancer increases with every  incremental increase in radiation exposure. The model is used to estimate  the risk of cancer when the overall level of exposure is in the range  considered to be low dose. At this level of exposure, data from  epidemiological studies of individuals exposed to radiation provide  evidence of increased risk to cancer, but with uncertainties about the  extent of this risk.
Under this model, federal regulations set dose limits for radiation  exposure that are below the level in the National Academies’ 2006 report  on radiation and human health for defining low-dose radiation. For  example, NRC’s annual dose limit for members of the public (excluding  natural, or background, sources of radiation) is 1 mSv (0.1 rem), or a  hundredth of the level the National Academies considers low dose.
Three key scientific advisory bodies—ICRP, NCRP, and the National  Academies’ Nuclear and Radiation Studies Board—have supported use  of this model for development of radiation protection requirements and  guidance. For example:  ICRP, in its 2007 update to its recommendations on radiological  protection, stated that at low doses of radiation, it considers the linear  no-threshold model to be the best practical approach to managing risk  from radiation exposure. In addition, ICRP stated that this model is  consistent with the principle that actions should be taken to avoid or  diminish harm to human life or health that is scientifically plausible but  uncertain, as is the case at low doses of radiation. ICRP’s update also  explained that it periodically re-evaluates its recommended dose limits  based on its evaluation of new scientific data and information.
NCRP, in a 2001 study on the linear no-threshold model that it  continues to reference today, noted that the existing epidemiological  data on the effects of low-dose radiation are inconclusive and, in  some cases, contradictory, prompting some observers to dispute the  validity of the linear no-threshold model. Nevertheless, NCRP  concluded that while there is uncertainty about the health effects of  low-dose radiation, the linear no-threshold model is more plausible  than other models, such as the hormesis model, which assumes that  low-dose radiation protects against rather than increases the risk of  cancer. Further, according to NCRP’s president, recent  epidemiological studies indicate that the preponderance of evidence  continues to support the linear no-threshold model for use in radiation  protection.
The National Academies, in its 2006 report on low-dose radiation,  supported the use of the linear no-threshold model, stating that the  balance of evidence from epidemiologic, animal, and mechanistic  studies tends to favor a simple proportionate relationship at low doses  between radiation dose and cancer risk. According to the National  Academies, the availability of new and more extensive data since the  publication of its previous report in 1990 strengthened confidence in  the 2006 report’s estimates of cancer risk. For example, the 2006  report incorporated data from an additional 15 years of follow-up of  Japanese atomic bomb survivors and from studies of nuclear workers  exposed to low-dose radiation.
Nevertheless, these advisory bodies have recognized challenges in  accurately estimating cancer risks from very low doses of radiation  exposure when using the linear no-threshold model. For example, the  epidemiological data used to estimate the dose-risk relationship for  American workers over a 1-year period are largely from studies of  Japanese atomic bomb survivors’ exposure to radiation from the atomic  bomb. As a result, to account for different doses and dose rates of  radiation exposure, advisory bodies have recommended that estimates of  the risk of low doses using these data be adjusted accordingly. For  example, in radiation protection guidance issued in 2007, ICRP  recommended that cancer risk estimates for low doses of radiation be  adjusted downward by a factor of one-half.
Figure 1 depicts examples of the dose limits and guidance levels  established by EPA, NRC, and DOE. (See app. I for further examples.)  As shown in the figure, the public dose limit for nuclear power plants is  one-third the U.S. average natural background radiation level.
Some stakeholders have questioned whether radiation dose limits based  on the linear no-threshold model are too strict, or whether they are strict  enough, and have advocated for revising dose limits and guidance levels.  For example, in 2015, NRC received three petitions from different  individuals proposing that NRC raise its occupational and public dose  limits. One petitioner commented that some studies suggest low levels of  radiation have protective effects and that the costs of complying with  linear no-threshold-based regulations were high. Similarly, a joint study  by the French National Academies of Science and of Medicine in 2005  concluded that epidemiological studies have been unable to find a  significant increase of cancer at low levels of radiation exposure.  Conversely, representatives we interviewed from two nonprofit groups,  Physicians for Social Responsibility and Beyond Nuclear, told us that  dose limits based on the linear no-threshold model were not strict enough  to protect vulnerable groups, such as children and pregnant women and  their fetuses.
NRC officials told us that in the absence of convincing evidence that there  is a dose threshold below which low levels of radiation are beneficial or  not harmful, NRC will continue to follow the recommendations of scientific  advisory bodies to use the linear no-threshold model. Similarly, officials  from EPA told us that they would consider changing the use of the linear  no-threshold model as the basis of their requirements and guidance only  if there were a strong recommendation from scientific advisory bodies on  radiation protection as well as an endorsement of the change by the  National Academies. In addition, EPA published a paper in 2009 that  stated that it believed that the evidence on health effects of radiation  exposure does not preclude the possibility of a threshold below which  there is no increased risk of cancer, but that the evidence at present does  not support the existence of a threshold.
section_title: Agencies’ Radiation Protection Requirements and Guidance Vary Depending on the Four Settings Reviewed in Which Exposure Can Occur
paragraphs: The limits and guidance the four agencies have developed and applied  vary depending on the settings in which exposure can occur, as  described below. This result is in part because the scientific advisory  bodies on which the agencies relied have developed recommendations  specific to the four settings we reviewed: (1) operation and  decommissioning of nuclear plants; (2) cleanup of sites with radiological  contamination; (3) use of medical imaging equipment that produces  radiation; and (4) accidental or terrorism-related exposure to radiation.
subsections: section_title: Operation and Decommissioning of Nuclear Power Plants
paragraphs: According to NRC’s notice of its final rule for standards for protection  against radiation, NRC used ICRP’s recommendations issued in 1977 as  the basis for NRC’s regulations. ICRP stated that it developed its 1977  recommendations on occupational dose limits in part through a  comparison between the cancer risk from occupational exposure to  radiation and the rates of occupational fatalities in industries recognized  as having high standards of safety. Thus, nuclear power plant workers  would not face a greater risk of cancer than the fatality risks, whether due  to accidents or disease, that workers face in other industries. For the  general public, ICRP suggested that the cancer risk—and therefore the  dose limit—should be less than that for workers and should be  comparable to the public’s risk from everyday activities, such as taking  public transportation. ICRP further stated that when setting public dose  limits, an agency must consider members of the public belonging to  critical groups, such as children and pregnant women, who may be more  susceptible to the effects of radiation than the population as a whole.
According to one of ICRP’s key recommendations for radiation protection,  radiation exposure should be limited to keep the likelihood and magnitude  of exposure as low as reasonably achievable, taking into account  economic and societal factors. In keeping with this recommendation, NRC  requires nuclear power plants to have a radiation protection program that  includes measures to keep doses as low as reasonably achievable  (ALARA). NRC defines ALARA to mean making every reasonable effort  to maintain exposures to radiation as far below dose limits as is practical  consistent with, among other things, the economics of improvements in  relation to benefits to the public health and safety. Under the ALARA  principle, NRC encourages nuclear plants to demonstrate their use of the  principle through cost-benefit analyses or other quantifiable methods.
According to NRC officials, nuclear power plants typically set their own  occupational dose limits at 40 percent of NRC’s regulatory limit of 50 mSv  (5 rem) per year, and cost is generally a key criterion that plants use to  determine what actions to take to reduce radiation exposures under their  ALARA programs. At the nuclear power plant we visited, representatives  told us that under their ALARA plan, the plant set its own dose limits for  workers at 40 percent of the regulatory limit. Officials at the plant told us  that they have been able to keep exposures below the plant’s own limit by  continuously seeking opportunities to reduce unnecessary worker  exposure to radiation, such as using robots to perform maintenance work  in radiation areas. According to NRC’s 2014 annual report on  occupational radiation exposure, none of the 124,831 nuclear power plant  workers who were monitored in 2014 received a dose above NRC’s  regulatory limit, and over 99 percent of these workers received a dose  below the 40-percent level used by many plants as their own limit.
section_title: Cleanup of Sites with Radiological Contamination
paragraphs: DOE and EPA both used the recommendations of scientific advisory  bodies, including the use of the linear no-threshold model, to develop  limits on dose or increased health risk for members of the public from  sites with radiological contamination, even though the agencies used  different approaches in implementing the recommendations. For example,  in an order on radiation protection of the public and environment, DOE set  a public dose limit of 1.0 mSv (0.1 rem) per year, which was the dose limit  recommended by ICRP in 1990. In developing its recommendations,  ICRP used the assumptions of the linear no-threshold model to identify a  dose that would not cause more than a small increase in the age-specific  mortality rate from cancer. In contrast, according to a 2014 EPA  memorandum on cleanup of sites with radiological contamination, EPA  uses a risk-based approach to prescribe cleanup levels for carcinogens,  including radiation, in a range that will not result in more than 1 in 10,000  to 1 in 1 million additional cancers in a population during their lifetimes.  Under this approach, EPA uses the assumption of the linear no-threshold  model to set site-specific levels of cleanup that account for various  factors, such as the site’s expected future land use and the presence of  other contaminants, such as chemicals that may also increase the risk of  cancer. Under its 2014 memorandum, EPA determined that when using a  federal or state standard for radiation protection at sites with radiological  contamination, this standard is generally not sufficiently protective if it is  greater than 0.12 mSv (0.012 rem) per year.
section_title: Use of Medical-Imaging Equipment That Produces Radiation
paragraphs: According to FDA officials, FDA does not have the authority to regulate  the total amount of radiation exposure a patient receives from medical  imaging equipment. They also commented that decisions such as the  frequency of taking medical images are based on patient need and that  those decisions determine the total amount of radiation exposure to the  patient. Similarly, ICRP’s 2007 guidance on radiation protection states  that, while all use of radiation in medicine should be justified and the  radiation dose from each examination should be as low as reasonably  achievable, radiation dose limits do not apply to medical exposures of  patients.
FDA officials stated that, instead of setting limits on total amount of  radiation exposure to patients, the agency regulates the maximum limits  radiation output of medical equipment. In particular, they stated that the  agency based its equipment standards on NCRP guidance from 1968 on  medical X-ray and gamma ray protection. They also commented that this  NCRP guidance provided a dose rate limit for the equipment and stated  that the exposure rate should be as low as reasonably achievable. In a  2005 Federal Register notice on FDA’s change to its performance  standards for medical-imaging equipment, FDA stated that it used the  assumptions of the linear no-threshold model to determine that the health  benefits to medical staff and patients (in monetary terms) exceeded the  costs incurred by equipment manufacturers and FDA to implement the  change.
In keeping with the principle that radiation exposure should be kept as low  as reasonably achievable, FDA encourages voluntary measures by health  care providers to address radiation exposure to patients from the use of  medical-imaging equipment. Under an initiative launched in 2010, FDA  identified a number of factors that contribute to levels of exposure that  exceed the levels for meeting patients’ clinical need, and FDA identified  steps to mitigate these factors. For example, its initiative recommended  that healthcare professional organizations continue to develop nationally  recognized benchmark levels for medical-imaging procedures that use  radiation, and FDA stated that it has increased its participation in these  efforts both on its own and through collaborative efforts with industry and  healthcare professional organizations. Benchmark levels are not  mandatory but allow medical facilities to investigate when a medical  examination exceeds the benchmark and determine whether it is possible  to reduce exposure without adversely affecting image quality.
section_title: Accidental or Terrorism- Related Exposure to Radiation
paragraphs: To develop guidance for state and local governments’ emergency  response to deliberate or accidental radiological incidents, EPA and  FDA used the recommendations of scientific advisory bodies, including  the assumptions of the linear no-threshold model to recommend radiation  doses at which protective actions would provide a net benefit when  compared with other factors, such as cost of the actions taken. For  example, according to its 2016 guidance on emergency response to  radiological incidents, EPA compared the cost of evacuation under  several scenarios with the number of cancer deaths avoided to  recommend a radiation dose to the public at which evacuation should be  considered. Using ICRP guidance, EPA assumed a linear relationship  between radiation exposure and cancer risk—a principle of the linear no- threshold model—to calculate the number of potential cancer deaths.  According to EPA’s guidance, the radiation dose the agency identified fell  within the risk level it considered acceptable, while also meeting EPA’s  criteria that the cost of the protective action be justified by the reduction of  risk to public health.
According to EPA’s guidance, decisions on the radiation doses at which  to take protective actions need to consider health risks other than  radiation. For example, weather hazards may impede evacuation and  favor sheltering-in-place instead. Similarly, EPA’s guidance explains that  decisions on relocation need to account for a variety of health problems  that relocation itself can cause. In its response to frequently asked  questions about radiation in Fukushima, Japan, the World Health  Organization noted that these problems were evident in the aftermath of  the March 11, 2011, earthquake and subsequent tsunami that caused  significant damage to the Fukushima Daiichi Nuclear Power Station,  releasing radioactive material into the environment. There were no known  acute deaths or illnesses from radiation exposure, but the relocation of  thousands of people caused an increase in disaster-related deaths, as  well as mental health and access to health care issues, according to the  World Health Organization.
FDA also relied on ICRP guidance and the linear no-threshold model to  recommend radiation doses at which protective actions would provide a  net benefit when compared with other factors. In particular, according to a  1998 Federal Register notice about recommendations for accidental  radioactive contamination of human food and animal feed, the agency  developed protective action guides for state and local agencies  responding to these types of accidents. These guides provide a  recommended radiation dose range in which countermeasures should be  taken for the contaminated food and feed after an accident. This range is  based on values set by ICRP on the basis of the linear no-threshold  model.
section_title: Seven Agencies Have Funded Research on the Health Effects of Low-Dose Radiation but Have Not Collaborated on Overall Research Priorities
paragraphs: For fiscal years 2012 through 2016, seven federal agencies—CDC, DOD,  DOE, EPA, NASA, NIH, and NRC—obligated about $210 million for  research on the health effects of low-dose radiation, but annual funding  decreased by 48 percent. During the period we reviewed, the seven  federal agencies that funded this research collaborated on particular  projects, but they did not use a collaborative mechanism to address  overall research priorities, such as research needs that advisory bodies  identified regarding health effects of low-dose radiation.
subsections: section_title: Seven Federal Agencies Obligated about $210 Million for Fiscal Years 2012 to 2016 for Research on Low-Dose Radiation’s Health Effects, but Annual Funding Decreased
paragraphs: From fiscal year 2012 through fiscal year 2016, seven federal agencies  obligated $209.6 million for research on the health effects of low-dose  radiation. As shown in figure 2, DOE and NIH accounted for most of this  funding, with DOE obligating $116.3 million and NIH obligating $88.6  million, or about 56 percent and 42 percent of the total, respectively. The  five other agencies—NRC, NASA, DOD, EPA, and CDC—obligated the  remaining $4.7 million.
The research that the seven federal agencies funded included both  epidemiological and radiobiological studies. Agency officials told us that  both types of research are important to better understand the health  effects of low-dose radiation and could inform future efforts to update  dose limits and guidance levels for radiation exposure.
Two of the largest epidemiological studies funded by federal agencies  were the Epidemiologic Study of One Million U.S. Radiation Workers and  Veterans (Million Person Study)—an ongoing study headed by NCRP— and the International Nuclear Workers Study, a multi-year study that  includes over 300,000 workers from France and the United Kingdom as  well as from the United States. The Million Person Study began in 2009  and includes plans to examine mortality statistics on multiple cohorts  (populations) of over 1-million U.S. radiation workers, veterans, and other  individuals. The purpose is to provide information about low-dose  radiation health risks when the exposures are received gradually over  time and not instantaneously, as was the case for the 1945 atomic-bomb  exposures in Japan. Officials from two agencies that fund or use the  results of research on the health effects of low-dose radiation—DOE and  NRC—told us that NCRP’s Million Person Study can help address these  research gaps. For example, according to NRC, the study is important  research in order for the agency to examine the radiation risks to workers  exposed to doses and dose rates in actual exposure settings.
DOE, EPA, NASA, and NRC have provided funding for the Million Person  Study. DOE’s Office of Science provided the initial funding of $500,000  for the pilot study in fiscal year 2009, as well as $869,000 for a  subsequent larger study, as part of its Low-Dose Radiation Research  Program, but DOE stopped funding the study in fiscal year 2010 to fund  other research priorities. Since DOE’s initial $500,000 funding for the pilot  study, NCRP has received a total of $4.2 million in additional funding from  DOE, EPA, NASA, and NRC, according to DOE officials. In addition, an  explanatory statement accompanying the fiscal year 2017 Consolidated  Appropriations Act directed DOE to provide not less than $500,000 from  funds for DOE’s Office of Environment, Health, Safety and Security for  this study. With the funding it has received, NCRP completed various  feasibility studies and follow-up work on several of the different cohorts of  individuals included in the overall study. For example, NCRP began work  on a mortality study of nuclear power plant workers. NCRP has estimated  that it would need $20 million to analyze and report on of all of the cohorts  included in the overall study. In addition, NCRP’s president told us that  continuous funding could help to retain the study’s original investigators,  who might otherwise move onto other work.
DOE also provided about $2.1 million for the International Nuclear  Workers Study for fiscal years 2012 through 2016, and CDC provided  $66,000. According to CDC officials, the workers in the study experienced  a similar form of radiation, thereby simplifying the study’s analysis, and  the results of the study have shown associations between radiation  exposure and leukemia and solid cancers.
Additional information on the types of low-dose radiation research funded  by federal agencies and the results of this research is described below:
DOE has two offices that have funded research on the health effects  of low-dose radiation—the Office of Science and the Office of  Environment, Health, Safety and Security—according to funding  information DOE provided. The Office of Science established the Low  Dose Radiation Research Program in 1998 and funded it through  fiscal year 2016. A primary focus of this program was to fund  radiobiological research, and over the course of the program, it  provided an average of about $14 million per year for such research,  which included funding for the Million Person Study. According to  DOE’s website for the program, the program provided data and  information about the low-dose range of exposure, producing 737  peer-reviewed publications as of March 2012. According to a 2016  report from DOE’s Biological and Environmental Research Advisory  Committee, among the important discoveries under the program was  a phenomenon known as the bystander effect, where cells may  sustain radiation damage even though no radiation passes through  them. Other areas of discovery included the role of DNA repair and  the immune system, as well as the potential beneficial effects at the  cellular level caused by low-dose radiation. The Office of  Environment, Health, Safety and Security provided annual funding  from fiscal year 2012 through fiscal year 2016 for epidemiological  studies in two areas: (1) the Radiation Effects Research Foundation,  which conducts studies involving Japanese atomic bomb survivors in  Hiroshima and Nagasaki and is a source of data used by national and  international standard-setting organizations and scientific advisory  bodies to set regulations and (2) assessments of worker and public  health risks from radiation exposure resulting from nuclear weapons  production activities in the former Soviet Union, which provided DOE  researchers with data from Russian workers who experienced chronic  exposure to radiation.
NIH has funded and conducted both epidemiological and  radiobiological studies on low-dose radiation, according to NIH  officials. The officials stated that the studies are conducted through  the National Cancer Institute’s internal research program for radiation  epidemiology, as well as through NIH’s research programs for  external funding of investigator-initiated research. The aim of the  internal research program for radiation epidemiology is to identify,  understand, and quantify the risk of cancer in populations exposed to  various types of radiation, and to advance understanding of cancer  caused by radiation. Other institutes of NIH, including the National  Institute of Environmental Health Sciences, also fund research related  to the health effects of radiation exposure as part of NIH’s overall  mission to fund medical research. Examples of research supported by  NIH have included (1) a study conducted in partnership with the U.S.  Department of Veterans Affairs on cancer mortality among military  participants in U.S. nuclear weapons tests and (2) a tissue bank with  samples from Chernobyl survivors. These samples are being used to  understand the effects of radioactive exposure from nuclear power  plant accidents. NIH has also funded radiobiological research on high- dose radiation, and some of this research also applies to low-dose  radiation.
EPA helps fund research through an ongoing interagency agreement  with DOE’s Oak Ridge National Laboratory, according to EPA  officials. The funding supports the development of models that provide  information about doses to particular organs from ingestion or  inhalation of a specific quantity of a radioactive element, such as  cesium or plutonium. According to EPA instructions for calculating  radiation dose and risk, EPA uses this information to estimate cancer  risks of exposure to over 800 radioactive elements. These estimates,  according to EPA, can be used by federal and state agencies to  develop and implement radiation protection regulations and  standards. EPA also provided funding for the Million Person Study.  According to EPA officials, the agency contributed to the study to be  able to discuss and review the research in its early stages.
NRC officials we interviewed said that NRC does not generally fund  research on radiation’s health effects but agreed to provide funding to  the Million Person Study with the understanding that NRC would be a  minority funding partner in the program. However, after DOE stopped  funding the study, NRC became the largest contributor, providing a  total of $2.1 million in fiscal years 2012 to 2016. NRC also funded an  epidemiological study analyzing cancer risks in populations living near  U.S. nuclear facilities, but it did not continue the study because of the  study’s limited usefulness for drawing conclusions about risk and its  long duration and high cost, according to NRC officials.
NASA officials told us that the agency mostly conducts research on  space-based radiation, which differs from ground-based radiation in  terms of its physical characteristics and its effects on health. In the  past 5 years, NASA has funded over $100 million for research on  space-based radiation, including research on its health effects, such  as on the risk of acute central nervous system effects. The agency  also provided funding for low-dose radiation research at DOE, as well  as for the Million Person Study.
CDC has provided some funding for epidemiological studies such as  those evaluating the long-term effects of occupational radiation  exposures or analyzing mortality among nuclear workers, according to  funding information provided by CDC. For example, according to this  information, CDC partially funded the International Nuclear Workers  Study. CDC officials told us that the program has published more than  two dozen studies related to occupational exposures and cancer risks  among workers across the DOE complex. CDC’s National Institute for  Occupational Safety and Health also provided funding for institute  researchers to conduct studies on flight attendants exposed to cosmic  radiation and on uranium miners exposed to radon.
DOD has contributed a small amount of funding for radiation health  effects research activities through the Armed Forces Radiobiology  Research Institute, according to funding information provided by DOD.  Most of the work conducted through the institute is research on  radiation countermeasures—treatments that could be used in the  aftermath of an attack involving the release of radioactive material. In  addition, according to DOD’s funding information, the institute  provides some funding to researchers in order to better understand,  for example, cancer risks due to low-dose radiation exposure.
As shown in figure 3, in fiscal years 2012 through 2016, the seven  agencies collectively decreased their annual funding obligations for  research on health effects of low-dose radiation by 48 percent, from $57.9  million in fiscal year 2012 to $30.4 million in fiscal year 2016, and NIH and  DOE decreased their annual funding obligations by 48 and 45 percent,  respectively.
DOE accounted for a large portion of this overall decrease in annual  funding. Specifically, over this 5-year period, DOE reduced its annual  funding obligations for this area of research by 45 percent—from $32.6  million in fiscal year 2012 to $18.0 million in fiscal year 2016. According to  DOE, the decrease was primarily due to DOE’s reduction in funding for its  Low Dose Radiation Research Program. DOE’s Office of Science  established this program in 1998 to fund research on the effects of  radiation on genomes, cells, and living organisms, with the aim of  providing a scientific basis for developing radiation protection standards in  line with the research results that demonstrate the response of complex  biological systems to low doses of radiation. According to DOE officials,  decreases in funding for the program reflected a shift toward bioenergy  and environmental research within the department’s Office of Science.  These officials said that the agency provided the final funding for the  program in fiscal year 2016. In contrast, funding remained stable for  research supported by DOE’s Office of Environment, Health, Safety and  Security on epidemiological studies in Japan and Russia.
Similarly, over the 5-year period, NIH’s funding for low-dose radiation  research decreased by 48 percent—from $23.1 million in fiscal year 2012  to $12.0 million in fiscal year 2016. NIH officials commented that  sequestration occurred during the time period in which radiation research  funding decreased. In addition, NIH officials explained that funding  levels for a particular disease or research area can fluctuate depending  on several factors, including the number and quality of research  proposals submitted and the outcome of NIH’s peer reviews of the  proposals, as well as the overall research budget. Table 1 shows  agencies’ annual obligations for research on health effects of low-dose  radiation.
section_title: Agencies Collaborated on Individual Projects on Radiation’s Health Effects but Not on Overall Research Priorities
paragraphs: The seven agencies that funded research on health effects of low-dose  radiation for fiscal years 2012 through 2016 collaborated on particular  research projects through the use of several mechanisms, including the  following:
Joint funding of individual research projects: For example, as  previously mentioned, DOE’s Office of Science, EPA, NASA, and  NRC jointly funded the Million Person Study, and CDC and DOE’s  Office of Environment, Health, Safety and Security helped fund the  International Nuclear Workers Study.
Participation in interagency committees: For example, DOD, DOE,  EPA, HHS and NRC are members of the Interagency Steering  Committee on Radiation Standards, which has a goal of promoting  consistency in federal radiation protection programs. Collaborating on  research on low-dose radiation is not a committee focus, but the  committee provides a forum for sharing information on research  developments. Similarly, the head of DOE’s Office of Environment,  Health, Safety and Security co-chairs a bilateral U.S.-Russian  Federation committee for coordinating research on the health effects  of exposure to radiation in the Russian Federation from the production  of nuclear weapons. CDC, DOD, EPA, NASA, and NRC are also U.S.  members of the committee.
Participation in meetings and conferences: For example, in June  2017, DOE’s Oak Ridge National Laboratory hosted a workshop on  radiation-protection research needs. The workshop agenda included  presentations by DOE, EPA, NRC, FDA, and NIH’s National Cancer  Institute. In addition, DOE officials told us they share research results  informally with other agencies through their participation in  conferences held by NCRP and other groups, and NIH officials also  said that members of the radiation epidemiology scientific community  have the opportunity to connect at specialized meetings.
However, the seven agencies that fund research on health effects of low- dose radiation did not use a collaborative mechanism to address overall  research priorities, such as research needs that scientific advisory bodies  have identified. The 2006 National Academies report to advise the U.S.  government on the relationship between exposure to radiation and human  health—which was funded in part by DOD, DOE, EPA and NRC— identified 12 areas of research needs. Many of these areas were related  to uncertainties from the linear no-threshold model and, by extension, in  the agencies’ dose limits and guidance levels that are based in part on  that model. In addition, as previously noted, the 2016 report of DOE’s  Biological and Environmental Research Advisory Committee also  provided information about research needs in low-dose radiation and  found that further research could decrease uncertainty in predicting  cancer risk from low-dose radiation. The report recommended that,  should DOE decide to continue research in this area, workshops be  convened to formulate a specific research program. In addition, the report  stated that other agencies—including NRC, NIH, EPA, DOD, and  NASA—could benefit from the reduction in uncertainty that could be  obtained by this research.
Until recently, DOE’s Low Dose Radiation Research Program provided a  stable source of funding for such research and according to DOE’s  website, DOE took a leading role in advocating for greater communication  and coordination between the fields of radiation biology and  epidemiology. As previously mentioned, DOE is the federal agency that  currently has primary responsibility under the Atomic Energy Act of 1954  for research related to the protection of health during activities that can  result in exposure to radiation. DOE’s decisions to reduce funding the  program in fiscal year 2012 and stop funding the program in fiscal year  2016 also reduced the role that DOE previously held as a leading source  of federal funding for low-dose radiation research. DOE’s reduced role  has created a void in federal efforts to maintain a collaborative  mechanism for low-dose radiation research, and no other agency has  stepped forward to fill this void.
Our previous work has shown that collaborative mechanisms can serve  multiple purposes, such as leading interagency efforts to develop and  coordinate sound science and technology policies across the federal  government. Although collaborative mechanisms differ in complexity  and scope, they all benefit from certain key features, such as leadership,  which raise issues to consider when implementing these mechanisms.  Such issues include: whether a lead agency or individual has been identified;  if leadership is shared, whether the agencies have clearly defined  roles and responsibilities; and how leadership will be sustained over the long-term.
For example, the Interagency Steering Committee on Radiation  Standards includes a process for rotating the leadership role among  member agencies.
DOE is well positioned to lead an effort to ensure that federal agencies  have a mechanism for interagency collaboration to address overall  research priorities related to low-dose radiation health effects because of  the agency’s past experience as a leader in this area of research. Such a  role is also consistent with DOE’s research responsibility under the  Atomic Energy Act of 1954. Such an effort could help DOE and the  collaborating agencies determine roles and responsibilities, including  leadership, when addressing shared research priorities.
section_title: Conclusions
paragraphs: DOE and other federal agencies have invested millions of dollars in low- dose radiation research, and this research has led to a better  understanding of the health effects of radiation exposure, thereby helping  federal agencies develop and implement radiation protection  requirements and guidance for workers and the public. DOE has provided  more than half of all federal funding for this research over the past several  years. Given the reduction in funding for low-dose radiation research,  federal agencies can benefit from greater collaboration on addressing  their research priorities in this area. Our previous work has shown that  collaborative mechanisms can be used for coordinating federal science  efforts and that agencies can enhance their collaborative efforts through  key practices, such as agreeing on leadership roles and responsibilities.  In the past, DOE took a leading role in both funding and evaluating low- dose radiation research, and the agency continues to fund a substantial  portion of the research. However, more recently DOE’s funding has  significantly decreased, resulting in a lack of leadership in this area. DOE,  consistent with its past experience as a leader in this area of research  and its research responsibility under the Atomic Energy Act of 1954,  could assist agencies in developing an interagency collaborative  mechanism for the future.
section_title: Recommendation for Executive Action
paragraphs: We recommend that the Secretary of Energy lead the development of a  mechanism for interagency collaboration to determine roles and  responsibilities for addressing priorities related to research on the health  effects of low-dose radiation.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Commerce; DHS;  DOD; DOE; Department of Labor; EPA; HHS’s CDC, FDA, and NIH;  NASA; and NRC for review and comment. DOE, the Department of  Labor, EPA, HHS, and NRC provided technical comments, which we  incorporated as appropriate. DOE also provided written comments, which  are reproduced in appendix II. The other agencies did not provide any  comments.
DOE commented that in general, the draft report reflects how federal  agencies, including DOE, developed and applied radiation protection  requirements and guidance for workers and the public. DOE did not  concur with our recommendation that it lead the development of a  mechanism for interagency collaboration on research on the health  effects of low-dose radiation. In particular, DOE stated that EPA and NRC  also have legal mandates to research low-dose radiation exposure and  that these agencies establish their research priorities in accordance with  their respective budget authorities and recommendations from  independent advisory bodies. DOE stated that as a result, it would not be  appropriate for DOE to lead the development of a mechanism for  interagency collaboration. Instead, according to DOE, from its experience,  the leadership of an organization with government-wide responsibilities  would result in the most effective interagency collaboration.
We believe that DOE’s concerns stem from a misinterpretation of our  recommendation, and we made several changes to our report and our  recommendation to clarify DOE’s role. In particular, we did not  recommend that a mechanism for interagency collaboration serve as a  replacement for agencies’ legal mandates, budget authorities, and  recommendations from independent advisory bodies. Instead, this  mechanism would help agencies address shared research priorities, such  as research needs that the National Academies, in advising the U.S.  government, identified regarding health effects of low-dose radiation.  According to officials we spoke with from DOE’s Office of Environment,  Health, Safety and Security, more collaboration among agencies on low- dose radiation research would be very helpful.
In making our recommendation, we did not specify the coordinating  mechanism that agencies should use and instead left it to DOE to lead  the development of an appropriate mechanism. If the leadership of an  organization with government-wide responsibilities would result in more  effective interagency collaboration, as DOE suggested in its written  comments, then DOE could implement our recommendation by working  with such an organization to obtain its involvement in a coordination  mechanism. We continue to believe that an interagency coordination  mechanism for low-dose research is needed and that DOE is in the best  position to lead agencies in developing the most appropriate mechanism.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Commerce, the Secretary of  Defense, the Secretary of Energy, the Secretary of Health and Human  Services, the Secretary of Homeland Security, the Secretary of Labor, the  Administrator of EPA, the Administrator of NASA, the Chairman of NRC,  and other interested parties. In addition, the report will be available at no  charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact John Neumann at (202) 512-3841 or neumannj@gao.gov.  Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this report. GAO staff who made  key contributions to this report are listed in appendix III.
section_title: Appendix I: Federal Agencies’ Radiation Protection Measures for Workers and the Public
paragraphs: To prevent cancer and other harmful effects associated with exposure to  radiation, federal agencies have established radiation protection  measures that apply to a wide range of settings in which exposure can  occur. These measures call for radiation exposure, for workers and for  the public, to be kept within regulatory limits (either on dose or increased  health risk) or, for emergency situations, non-binding guidance on  exposure levels established for protecting individuals. Table 2 shows  examples of federal agencies’ dose limits, guidance levels, and other  radiation protection measures.
section_title: Appendix II: Comments from the Department of Energy
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: John Neumann, (202) 512-3841 or neumannj@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the individual above, Joseph Cook (Assistant Director),  Allen Chan, Kendall Childers, Richard Frankel, Richard Johnson, David  Messman, Cynthia Norris, Josie Ostrander, Todd Paulsen, Amber  Sinclair, Sara Sullivan, and Jack Wang made key contributions to this  report.