In June 2015 the US Nuclear Regulatory Commission (NRC) opened a 75 day comment period on whether dosage limits for ionizing radiation should be based on the current Linear No Threshold (LNT) model. The LNT model assumes that every bit of artificial radiation, from a baseline of zero, has an equal chance of producing harm to humans, generally in the form of cancer. The NRC action was the result of a public request for rule-making on the part of three medical doctors (Docket ID NRC-2015-0057). There have been studies showing that radiation, on the order of what might be found in some natural environments, may have positive effects and the petitioners feel that the population should not be denied an increment of radiation from artificial sources. The discussion of the petition from the NRC website includes these points in a summary of the petitioners’ request:


  • Public doses should be raised to worker doses. The petitioner notes that “these low doses may be hermetic. The petitioner goes on to ask, “why deprive the public of the benefits of low dose radiation?”
  • End differential doses to pregnant women, embryos and fetuses, and children under 18 years of age.


Broughel and Shamoun propose that a manufacturer’s alternative for a chemical banned or restricted as being hazardous will be a new, unlisted, chemical with as-yet-uncertain potential hazards. Hypothetically, the societal cost of excess regulation will be passed on to consumers with the result that they will be less able to purchase things that would also keep them safe, such as perhaps healthy food or smoke detectors. Fear of radiation induced by public knowledge of its possible effects or status as a regulated thing may lead to unreasonable fears which cause people to avoid even known beneficial therapeutic uses of radiation.


The discussion of hormesis does not examine the fact that any regulated, human-caused stress agent that is released or directed at the population will be experienced as an addition to natural background radiation, or to the amount of chemical pollution already present in the environment. Incremental stresses are not imposed on a blank state, or in a state of nature previous to any other synthetic release. For example, a small amount of benzene might be released in an area where there was already some amount of aromatic hydrocarbon pollution.