A critical evaluation of the NCRP COMMENTARY 27 endorsement of the linear no-threshold model of radiation effects

Regulatory policy to protect the public and the environment from radiation is universally based on the linear, no threshold model (LNT) of radiation effects. This model has been controversial since its inception over nine decades ago, and remains so to this day, but it has proved remarkably resistant to challenge from the scientific community. The LNT model has been repeatedly endorsed by expert advisory bodies, and regulatory agencies in turn adopt policies that reflect this advice. Unfortunately, these endorsements rest on a foundation of institutional inertia and numerous logical fallacies. These include most significantly setting the LNT as the null hypothesis, and shifting the burden of proof onto LNT skeptics. Other examples include arbitrary exclusion of alternative hypotheses, ignoring criticisms of the LNT, cherry-picking evidence, and making policy judgements without foundation. This paper presents an evaluation of the National Council on Radiation Protection and Measurements' (NCRP) Commentary 27, which concluded that recent epidemiological studies are compatible with the continued use of the LNT model for radiation protection. While this report will likely provide political cover for regulators' continued reliance on the LNT, it is a missed opportunity to advance the scientific discussion of the effects of low dose, low dose-rate radiation exposure. Due to its Congressionally chartered mission, no organization is better positioned than the NCRP to move this debate forward, and recommendations for doing so in future reviews are provided.