Because the NAS study, "Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 (2005)," was not issued until June 29, members of the public now have until Nov. 28 to submit comments to help the agency determine what action, if any, should be taken to update the standard, 29 CFR 1910.1096.
In its most recent regulatory agenda, OSHA has explained its decision to consider revising the 31-year old rule by observing that, "radiation is now used for a broader variety of purposes, including health care, food safety, mail processing and baggage screening." Exposure to high doses of radiation can cause cancer, heart disease, stroke and mental retardation in the children of pregnant women.
The new NAS study concludes, "there is a linear, no-threshold dose-response relationship between exposure to ionizing radiation and the development of cancer in humans." In other words, low doses of exposure to radiation are neither more, nor less, harmful to humans than estimated by a linear model based on the risks posed by higher exposures.
As of Aug. 15, there were 95 documents on a docket OSHA has established for public comments on whether to revise the radiation rule.
Many of the comments from industry groups point out that other federal and state agencies, particularly the Nuclear Regulatory Commission, already regulate ionizing radiation. For example, the Council on Radionuclides and Radiopharmaceuticals Inc. (CORAR), opposes OSHA rulemaking on ionizing radiation because it "would duplicate or potentially conflict with NRC." CORAR members include manufacturers and shippers of diagnostic and therapeutic radiopharmaceuticals.
The group states it has submitted data concerning trends toward a marked reduction in collective and average occupational exposures.
New Jersey's Department of Environmental Protection (DEP), however, writes it is "dismayed" that OSHA mentions throughout its summary on ionizing radiation that not changing its "outdated" regulations is a possibility. "The current OSHA rules on radiation exposure as applied, could allow 50 times more radiation exposure to a worker than is currently allowed under NRC regulations and most state regulations."
The DEP comment argues that although OSHA rules are applicable only to radiation workers, they are often applied to workers exposed to radiation but untrained in radiation safety, such as water treatment workers, construction workers and paper and pulp mill workers.