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AAPM Tutorial Acceptable PaulH.

Risk

Murphy,

as a Basis

for

Regulatio&

PhD

In recent

years,

based

on

estimates

ments

regarding

guidelines for radiation of the risks associated acceptable

levels

protection have with radiation

of risk.

This

leads

increasingly

been

exposures

to a more

and

judg-

objective

ba-

are accurate. However, as enthusiasm for this approach expands, the large uncertainties in the risk estimates are often overlooked, and unreasonable, restrictive applications are possible. Several recent examples of radiation protection guidelines ifiustrate the riskbased emphasis underlying today’s radiation safety philosophy. sis for

regulations

if the

risk

estimates

INTRODUCTION The three fundamental tenets of a radiation protection program are that (a) the application of the radiation must be justfficd, meaning that there is an anticipated benefit; (b) dose limits should be set for workers and the public; and (C) there must be program to ensure that the radiation exposures are as low as reasonably achievable.

The purpose of this article dose limits are determined.

is to review

the philosophy

and process

of how these

includes a discussion of the history of radiation risk estimates, the current values, and the application of these values to arrive at dose limits in light of other occupational risks. Examples of regulations or guidelines from several governmental entities arc presented. The current approach to setting dose limits is based on the concept of acceptable risk. To discuss acceptable risk as a basis ofregulation, two aspects must be addressed. The first is, What is considered to be an acceptable level of risk? The second is, What

is the

magnitude

This

a

report

of the

risk

per

unit

radiation

dose

in the

dose

range

of in-

terest? Because radiation is only one of several occupational risks, others-such as fatal and nonfatal accidents, occupational illness, and travel on the job and to and from the workplace-should be considered when the radiation component is assessed. The fraction ofthe total occupational risk attributed to radiation should be considered in addition to its magnitude.

Abbreviations: national Commission

BEIR

Biological Radiological

on

tional

Council

on Radiation

Index

terms:

Radiations,

RadioGraphics 1

From

the

1991; Nudear

Department

30, 1991; 0PSNA,

revision

Protection

exposure

and

Measurements,

to patients

and

NRC

EPA = Environmental Aeronautics and = Nudear

Regulatory

#{149} Radiations,

personnel

Space

injurious

Protection Agency, Administration,

ICRP NCRP

= Inter. =

Na-

Commission effects

11:889-897

Medicine

of Radiology,

Effects of Ionizing Radiation, Protection, NASA National

Service, Baylor

requestedJune

3.261,

College 11 and

St Luke’s

Episcopal

ofMedicine,

Houston.

receivedjune

26;

Hospital, From

acceptedJuly

6720 the

1990

BertnerAve, RSNA

1. Address

scientific reprint

Houston, assembly. requests

TX 77030

and

Received to the

the

April

author.

1991

889

HISTORY OF RISK ESTIMATES

The

primary

assumption

risk

estimates

is that

the

underlying

forms

of this function,

Three

general

posed: models doses

the linear, linear-quadratic, of dose response that to predict the response

general

shapes

of the

of risk in the

the

magnitude

process

ofthe

risk

of developing is a known

regulations function

or the dose-response

based

ofradiation

curve,

have

on dose.

been

pro-

and threshold functions. These functions are use data from human populations exposed to high at lower doses. As ifiustrated in Figure 1, the three

dose-response

curve

result

in different

estimates

of the

magni-

region when data are extrapolated from the high-dose range. In human observations ofradiation-nelated carcinogenesis are statistically verified only at doses of hundreds of rem, but regulators are concerned with doses less than a few tens of rem for occupational and general public exposure limits. This is the low-dose range for which risk estimates are needed but are not tude

low-dose populations,

directly observable; thus, estimates must be made based on models dose data. The uncertainties in the resulting low-dose risk estimates The concept of acceptable risk as a basis for standard setting was National Council 1954 (1). Since ported

on Radiation then, several

their

conclusions

on

Radiological

mission

on the Effects Ionizing

and

ofAtomic

Radiation

Protection groups have

(BEIR)

and Measurements analyzed human

recommendations.

The

Protection

(ICRP),

Radiation,

and

sponsored

fitted to highare large. discussed by the (NCRP) as early as

the

United

the Committees

by the

National

exposure

NCRP,

Nations

the

data

Scientific

reCom-

Committee

on the Biological Research

and

International

Effects

Council

have

of

all ad-

dressed 1 and

this topic. In 1971, the NCRP estimated the risk ofleukemia to be between 2 x 106 per person per year per roentgen and that the risk for all neoplasia was two to 10 times that value, with an average ofabout 5 x 106 (2). In 1972, the BEIR I Committee proposed that the data available in the high-dose range could be extrapolated linearly to the low-dose range (3). In 1977, the risk estimates from hu-

man data mechanism 1980,

were updated, for specifying

and the process ofusing the effective doses of equivalent risk was proposed

dose equivalent by the ICRP

as a (4).

In

the

BEIR III Committee proposed a linear-quadratic dose-response curve (5). Finally, the BEIR V Committee, which reanalyzed the dosimetry for survivors of atomic bombings and returned to the linear dose-response relationship, proposed risk estimates that are three to four times higher than those previously reported (6). Several large populations of humans who have received fairly high doses of radiation arc the basis for the risk estimates (7). The major populations are the survivors of the World War II atomic bombings in Japan and several groups that underwent radiation therapy for a variety of conditions. With the evolution of risk estimates, the standards for radiation workers have de-

creased

from 26 rem (0.26 Sv) per year in 1934 to the present level of Sv) per year. At this time, with continuing discussion of the conclusions BEIR V Committee (6), one can only speculate on the impact of its risk the standards

for radiation

workers

1. Three general shapes of the dose-response curves permit prediction of different mcidences of radiation effects in the low-dose range when the curves are fitted to data in the high-dose range.

and

the general

5

rem

(0.05

from the estimates on

public.

Figure

uJ C-)

z

w C-)

z

DOSE

890

U

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U

Murphy

Volume

11

Number

5

The

process

of associating

radiation

protection

levels

with

risk was probably

most

RISK-BASED

completely described in ICRP Report no. 26 in 1977 (4). In that publication, for all humans, a nominal risk of all cancers of 102 per sievert (1O per rem) was assumed, that is, a one in 10,000 chance ofdcveloping fatal cancer per rem dose equivalent. The authors supported the existing limit of 0.05 Sv (5 rem) per year for radiation workers, for which the average exposure is only one-tenth to one-twenti-

STANDARDS

average exposure results in a risk of approximately 0.5 to 1 x is comparable to the risk of a fatal accident in industries considered safe. Also, with a protection level of 5 mSv (500 mrem) per year for members of the general public, who are unlikely to receive an average exposure of more than 0.5 mSv per year, the resulting risk is less than 1 x 10’, which is comparable to other risks that all members of the population encounter frequently. The mechanism of specifying dose in terms of its risk equivalent was developed in ICRP Report no. 26 (4). This approach permits comparisons ofnonuniform radiation exposure to uniform whole-body exposure in terms of the risk associated with the exposures. Risk estimates for different tissues from this ICRP report sum to about 1.6 x 102 per sievert (1.6 x 1O per rem) (Table 1). Weighting factors were assigned to the different tissues to permit calculation of effective dose equivalent based on the relative risk per unit dose equivalent for the different tissues. Several sources of uncertainties in the risk estimates are particularly troublesome in the how-dose range. The primary source of information on radiation risk in humans is from the survivors of the atomic bombings. In such a catastrophic setting, dosimetry is complex, and the doses that are being assessed are in the high range and are delivered instantaneously. Also, the potential differences in cancer risk eth

io-4

of that limit. The per year, which

among

greatly

disparate

Japan and the ing those from

populations

with

United States, should the atomic bombing

very

different

be considered. survivors, age

together, although substantial differences in age and to exist for some cancers. In addition, the uncertainties from high-dose data make the low-dose risk estimates Most assessing since

risk estimates risk, looking the

Table

latency

are for death from at life shortening

period

lifestyles,

sex predilection introduced

as those

cancer

are believed imprecise.

cancers. is justified,

is typically

of

includaveraged

by extrapolating

uncomfortably

radiation-induced instead of death

for radiation-induced

such

For most risk estimates, and sex distributions are

However, particularly many

years.

in Also,

1

Weighting

Factors

and

Risk

Factors

for Tissues

at Risk

for Stochastic

Effects

Weighting Tissue

Risk

(Sv

‘)

Comments

Factor

Gonads

4.0 x i03

Genetic risk to first two generations

0.25

Breast

2.5 x i0

Averageforallagesand

0.15

both Red bone Lung

marrow

sexes

2.0

X

10

Leukemia

2.0

X

iO

Cancer

Thyroid

5.0

x i04

Bone surface Remainder

5.0 x 10 5.0 x i0-

Total

1.65

Source-Data

September

from

1991

reference

x 102

Fatal

0.12

0.12 cancer

0.03

Osteosarcoma Cancer, assuming that no single tissue contributes more than ‘/, of this total .

.

.

0.03 0.30

...

8.

Murphy

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RadioGraphics

U

891

the ratio of the incidence of disease to the mortality rate is approximately 2: 1 on the average for all cancers but ranges from 10:1 for thyroid cancer to 1:1 for lung cancer. The aim of radiation protection is to make the radiation industry as safe as the industry, with an accidental (9) (ie, less than 1 X iO-

safest

years

among

different

industries

are

year

per

industries

and

trade,

manufacturing,

the

the radiation

industry

10,000

per

death year

rate ofone for individual

occupations, and

is compared.

The

The

annual

workers.

or fewer per 10,000 workerworkers). Fatality rates vary as shown in Table 2 (10). The safest

total

service

industries,

U.S. average risk

and

is about

to a radiation

one

it is to these

fatal

worker

that

accident

per

is estimated

to

be approximately 2 x iO-4 based on an average radiation exposure of 2.3 mSv (230 mrem) per year (1 1). The radiation risk is summed with the risk of a fatal accident and the rather high risk of travel to and from the workplace to arrive at this total occupational

risk. This risk level is comparable to that for other occupations The radiation component is about 25% ofthe total. most recent risk estimates were published by the BEIR V Committee

recog-

as safe.

nized

The reviewed

human

survivors. conclusions

The that

concluded

exposure

data,

particularly

committee updated the the neutron component

that

for the 76,000

estimates of the was less than

atomic

(6),

who

bombing

doses on the basis previously assumed.

of recent It also

function was the most appropriate and arThe risks for all cancers were estimated to be three to four times higher than previous estimates. The average lifetime excess risk ofdeath from cancer is 0.8% per 0.1 Sv (10 rem). With a 30% cancer frequency and 20% mortality, this accounts for about 4% of the baseline risk of death from cancen. The BEIR V Committee qualified these higher risk estimates by indicating that they should be used as that only, that is, as a risk estimate, and not for purposes of at new

rived

prediction

a linear

those

estimates

dose-response

ofradiation

or calculation

did not specify

risks.

ofthe

number

ofcancer

deaths.

rate reduction factor, which that the risks from doses in the low-dose and that the probability exists that there range of a few hundred millirem. In fact,

indicated

observed the dose

a dose

However,

the

committee

many believe is at least two (6). It range are too small to be directly may be no risks from exposures in some believe that exposure to low

levels ofradiation mayyield beneficial effects, a process known as hormesis (12). Hormesis is a stimulatory effect brought about by low-level exposure to a substance that is toxic at high levels. The potential mechanisms that have been proposed for radiation hormesis are increased free radical scavengers, enhanced DNA repair, and enhanced

factor

immune

cell

in any activity

Table

production.

of regulatory

Hormesis

agencies

is a controversial

Fatality

from

Rates

Accidents

in Different

No.

of

Annual

Fatal

Accident

Rate

24,000

0.5

Manufacturing

19,900

0.6

Service Government Transportation

28,900 15,900

0.7 0.9

5,500

2.7

5,700

3,400

3.9 4.6

1,000

6.0

and

util-

Construction Agriculture Mining, quarrying

All U.S. industries Source-Data

U

a

(per 10,000 workers)

Trade

ities

RadioGraphics

is not

Occupations

Workers (X 10)

Occupation

U

and

2

Annual

892

topic

to date.

Murphy

from

104,300

reference

1.1

10.

Volume

11

Number

5

A few recent examples of risk-related regulatory activities or risk-related standards being set for radiation exposure are (a) the NCRP recommendations to the National Aeronautics and Space Administration (NASA) on the astronauts’ exposure limits while in space (1 1); (b) the Environmental Protection Agency’s (EPA) proposal on limits

of radionuchide

10 of the Code Standards uhatory islature’s

proposal

on

(13);

against to low-level

goals

for

hustrates a regulatory agency’s risk estimates and a judgment At the request of NASA, the by astronauts

during

space

STANDARDS

to section 20 of title Commission’s (NRC) policy on “below reg(8); and (e) the U.S. leg(15). Each of these il-

(C)

Regulations,

for Protection concern,” relating

OF

the proposed revision the Nuclear Regulatory Radiation (14); (d) the NRC’s

emissions

of Federal

EXAMPLES RISK-BASED

radioactive

indoor

radon

materials concentrations

attempt to set limits on radiation exposure based on ofwhat constitutes an acceptable magnitude of risk. NCRP proposed standards for radiation dose received

activities

(1 1).

Radiation

limits

for

space

flight

were

re-

viewed from the standpoint of (a) stochastic effects (including primarily fatal cancer), with a nominal risk factor of 2 x 102 per sievert; (b) the genetic effects over the subsequent two generations, with an estimated risk of 1 x 102 per sievert; and (C) nonstochastic effects, including radiation-induced cataracts and adverse effects on fertility. In proposing limits for space activities, the NCRP looked at the extremes in risks for terrestrial radiation workers. For example, with a maximum permissible dose of 0.05 Sv (5 rem) pen year and a 50-year career, a radiation worker could conceivably receive a lifetime dose equivalent of 2.5 Sv (250 rem). This results in a lifetime risk ofdeveloping fatal cancer ofapproximately 5%. On the other hand, the average radiation worker receives an annual exposure ofabout 2 mSv (200 mrem), which results in a lifetime total dose equivalent of 0. 1 Sv (10 rem) and an excess cancer risk of less than 1%, which is comparable to risks of fatal accidents in safer industries. It did not seem reasonable to limit the exposure of astronauts to the average exposure of the terrestrial worker, given the other much more risky activities associated with space travel. It seemed more reasonable to limit the exposure to that of the more highly exposed terrestrial worker, that is, a dose of 0.05 Sv pen year for a potential 2.5 Sv pen lifetime. However, on the basis ofcurrent experience, it is unlikely that an astronaut’s total exposure will exceed about 0.7 Sv. Thus, the NCRP’s proposed limit for space workers is a career dose equivalent of 1.5 Sv (150 rem) or a risk ofless than 3% for fatal cancer. This 3% represents about one-sixth of the natural risk of fatal cancer and, in light of the other risks of space travel, was deemed to be acceptable. The age and sex differences for risk estimates were recognized by the NCRP, and the career whole-body for male and female

Table

dose-equivalent subjects as shown

limits were specified in Table 3 (1 1). These

3

NCRP Recommendations Astronauts’ Career

for Whole-Body

Dose-Equivalent

Limits

Age (y)

Female

Male

25 35 45 55

1.0 1.75 2.5 3.0

1.5 2.5 3.2 4.0

Limit

Source-Data

from

Note-Dose on a lifetime cancerof3

September

for several age groups values are the dose

reference

equivalent excess risk x

1991

(Sv)

1 1.

limits are based of death from

102.

Murphy

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U

893

equivalents Notice that

in sieverts the doses

that range

would from

risk of cancer mortality of 3%. rem) to a high of 4 Sv (400 rem).

produce a career a low of 1 Sv (100

The NCRP also recommended limits on dose equivalents for short-term exposures. For example, in Table 4 (1 1), the annual limit for irradiation of blood-forming organs

tion

is 0.5 Sv (50 workers.

Another

rem)

example

or 10 times

of risk-based

Standards for Hazardous 1979, when radionuclides

the

limit

presently

regulatory

Air Pollutants were listed

applied

activity

(13). under

to earth-bound

radia-

is the EPA’s National

Emission

The history ofthis activity goes the Clean Air Act as a hazardous

back to air pol-

lutant. In 1985, the EPA proposed final rules for several categories of radioactive material users, including licensees of the NRC. The EPA was forced by the federal court to propose standards for radionuclide exposure, following the precedent set for vinyl chloride, and the final proposal was published in 1989. The standards followed the two-part guidelines defined in the vinyl chloride case: (a) to limit risks for individuals most highly exposed to one in 10,000 and (b) to reduce the risk for as many people as possible to one in 1,000,000. On the basis ofcurrent risk estimates, this

results

mSv)

in a maximum

per

year,

ofwhich

to radioactive posed

iodine.

continuously

allowable

dose

no more

This to the

than

dose

to a member

3 mrem

estimate

maximum

of the

(0.03

assumed

mSv)

that

concentration

public

of

year

can

per

an individual

for 70 years.

10 mrem

would The

(0.1

be attributed

be ex-

EPA approach

to estimating the risks from radionuclide emissions is to either measure or estimate the emissions, predict concentrations as a function of distance from the source with use of a dispersion model, and calculate the exposures of the populations. The estimates of risk per unit dose equivalent are then used to set limits on emissions to

Table 4 NCRP

Career

Recommendations for Astronauts’ Short-term Limits for Protection against Nonstochastic

Dose-Equivalent Effects

Limit

Time Period

Blood-forming Organs

30d Annual

.

from

Source-Data

2. comparison Figure

reference

.

and

(Sv)

Lens of the Eye

Skin

1.0 2.0 4.0

1.5 3.0 6.0

0.25 0.5

Career

Limits

.

11.

The NRC’s of below-regu-

hatory-concern doses to doses ral background cal exposures.

(BRC)

from and

I

natumedi-

I 40

p [T#{244} I

6

Fi 0

All Medical Exams

50

Natural Radioactive Materials in the Body

BRC

Practice

Chest

X-ii

BRC

50

Affecling

Urnited

Numbe r of People

I

Practice Affecting Large Number of Pei 100

150

200

250

300

Radiation Dose (mrem)

894

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Volume

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5

keep the risks less than those the emissions are below these problem, the EPA has provided phiance. The program, named relative

leveh

With

use

of emissions of cost

previously limits can

mentioned. be extremely

a computer

program

Comply,

has

to assist

a tiered

options,

safety

from

the

EPA

for

for

is 500

times

radionuchide the

ganizations

greater

emissions.

of implementing

that

implementing

com-

depends

on the

standard

associated

for

with

than

the

Because these

number

of the

the

saved

with

perceived

medical

and

licensed

activities

various

acceptable

dollar spent to reduce the risk of of magnitude, if the money were nadionuclide emissions (16). For spent per year for automobile

analysis

restraints

limit

that this

of radionuchides.

estimates

one

by a licensee To address

in documenting

structure

concluded that for every death, the yield would be much higher, by orders spent on safety programs rather than on reducing example, the number of lives saved per $ 1 million risk

Verification complicated.

the

large

academic

EPA’s

proposed

cost-to-benefit

licensees,

ratio

professional

aggressively

oppose

or-

the

regula-

tion.

Another risk-based regulatory action is the proposed revision to section 20 of title 10 of the Code of Federal Regulations: the NRC Standards for Protection against Radiation (14). This regulatory action has been in development for several years and would essentially implement the effective dose-equivalent approach as proposed by the

ICRP

in

general risk

1977.

public

It would

that

are

establish

based

radiation

on risk

exposure

estimates

and

levels

for

a decision

workers

and

regarding

the

acceptable

levels.

A more recent NRC initiative based on risk estimates is the NRC’s Below Regulatory Concern Policy Statement for exempting low-level radioactive materials from regulations (8). The NRC believes that this statement will establish a consistent risk framework for regulatory decisions. It establishes dose criteria of 1 mrem (0.01 mSv)

and

and

10 mrem

from

sievert)

(0. 1 mSv)

all sources per

year

for

the

fact that variations vide some perspective the

on

the

hypothesis

is linearly

(0. 1-mSv)

which

individuals

regions

and

that and do

country

for

individual

respectively,

population.

exposures

and

It recognizes

1,000 and

from

single

person-rem

uses

sources

(10

as a basis

for

personjustification

from natural sources of radiation proof risk. The policy is explicitly based

the

fatal

risk

to the

medical

of the

year

in individual exposures on the acceptableness

proportional

mrem ground

per

ofradiation,

of developing dose

at 5 X iO

1-mrem

(O.01-mSv)

exposures

(Fig

not

associate

or living

levels

2) and an

also

unacceptable

in a brick

versus

cancer

per

rem.

from The

exposure NRC

by comparing

to doses risk,

a wood

to radiation

justified

the

them

to natural

from

other

activities

such

as living

home

(Fig

3.

Figure

comparison

other

for

in different

3).

The NRC’s of below-regu-

latory-concern doses to doses

lected

10back-

(BRC)

from

se-

radiation

sources.

30 40 Radiation Dose (mrem)

September

1991

Murphy

U

RadioGrapbics

U

895

The

response

to this policy

of acceptable vigorously

risk opposed

is not the

statement

has demonstrated

necessarily the same policy by associating

lem of disposal

oflow-level

radioactive

have

suggestions

that

ing

also

been

in contaminated

consumer

some time. A final example

waste

some

of risk-based

waste

power

is that

groups to the

companies.

will the

activity

perception

Several solution

materials

Undoubtedly,

regulatory

the public’s

regulators’. a careless

by nuclear

of the

products.

that

as the it with

have prob-

There

be recycled,

debate

will

relating

result-

continue

to indoor

for

radon

concentrations. The U.S. Public Health Service has declared that indoor radon gas is a national health problem and that radon causes thousands of deaths pen year. This has led the U.S. Congress to pass legislation that establishes as a national goal the reduction of indoor radon concentrations to the level of outside concentrations (15). Indoor radon is currently perceived to be the most important problem involving

radiation

exposure

the concentration would correspond This

of the

public.

recommendation

is quite

different

whose approach is somewhat the Food and Drug Act. This cinogenic,

the

cinogen CONCLUSIONS

(ie,

Most tude

people of the

basis

assumption

any

of these

for

to automated

limit

automatically

benefit purposes,

risk

estimates

that Also,

dose

estimate,

Most

people

conservatism

when

quotes

today

(17).

“For

practical

been

used

consistently

sents

a conservative

problems the

assessment

RadioGrapbic.s

U

as then,

is how

uncertainties

U

from

Murphy

although

these

the

because upper

uncertainties of the

dose

of a car-

of risk for

proceedings

linear,

estimates

regulatory

assessment

process but

rather

other

as pretypes

the

risk

estimates

doses,

with

their

regulations

when

of frequency

of cancer

of interest.

as relevant

to the

risks

dose

of

of the

the association

usually

addressed

non-threshold

such

with

setting

ranges are

the

the interpretation

predictions

in the dose

to

protection

reasons,

risks

at low

for

proceedings

of risk

other

estimates

as a

tends

the dose

for

Because

as a basis

risk doses

on deemphasize

established for

magniis the

acceptable at low

to ignore

monitoring.

an effective

assessment

regulatory

legislature,

is adjusted,

of radiation importance on

of its plausible

limit

in the risk

use

NCRP

purposes

to develop

in making

the

Once

estimates

tends

is inappropriate

1980

U.S.

Amendment to found to be car-

whole-body irradiation, difficult to interpret.

may be zero

the

range.

approach

appropriate

but

the

as a safe

a risk estimate

personnel

that

is still

issue

ation

agree

is justified

this

to uniform risk is very

in fact this frequency

following

896

would

uncertainty,

when

is proportional to the The major disagreement

As it becomes

comparison increased

from

are based on dose-equivalent between badge reading and

by

thing

of risk

approach

to apply

for example,

exposure range.

is, once

this

or

action

the Delaney food additive

such

low-dose

ratio.

is a tendency

of frequency of cancer Also, this approach places

proposed

is no

application

of the benefit-risk

there

there

in the

regulations; adjusts.

that

remedial

in the United States, which of approximately 4 x 10.

logic behind banned any

risk of radiation in the high-dose

diction risks.

significant

recommends

is unacceptable).

is established,

portion

from

that

cancer

risk

regulation

lead

NCRP

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excess

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The

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from

The

radiation

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response

model

has

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.

.

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the

.

.

The

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is not the to use

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Number

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9.

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Acceptable risk as a basis for regulation.

In recent years, guidelines for radiation protection have increasingly been based on estimates of the risks associated with radiation exposures and ju...
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