Radiobiology and gray science: flaws in landmark new radiation protections

The International Commission on Radiological Protection--whose regularly updated recommendations are routinely adopted as law throughout the globe--recently issued the first-ever ICRP protections for the environment. These draft 2005 proposals are significant both because they offer the commission's first radiation protections for any non-human parts of the planet and because they will influence both the quality of radiation risk assessment and environmental protection, as well as the global costs of nuclear-weapons cleanup, reactor decommissioning and radioactive waste management. This piece argues that the 2005 recommendations are scientifically and ethically flawed, or gray, in at least three respects: first, in largely ignoring scientific journals while employing mainly "gray literature;" second, in relying on non-transparent dose estimates and models, rather than on actual radiation measurements; and third, in ignoring classical ethical constraints on acceptable radiation risk.