Post comments here:
https://www.regulations.gov/document/NRC-2025-1237-0001
(Here's what Sharon and I just submitted, NRC Comment Tracking Number:
mtq-m7u1-38b4)
September 6, 2026
We oppose implementation of the changes in NRC-2025-1237-0001 which impact radiation standards for medical use of radioactive materials. We specifically ask the NRC to consider the comments and questions raised by the American College of Occupational and Environmental Medicine (ACOEM). (The ACOEM describes its members as "... the physicians who conduct medical surveillance of radiation workers, evaluate individuals after suspected overexposures, counsel patients and their families about radiation risk, and perform the causation analyses on which occupational illness compensation depends.")
The ACOEM states that: " ... the proposed rules as a whole reduces protection for workers, for caregivers, and for members of the public on a scientific record that the NRC itself describes as supporting the opposite conclusion." If this statement was the only concern raised about this proposed change to regulations, it should be sufficient to prevent the new rules from being implemented until the ACOEM's concerns are addressed.
The ACOEM raises important concerns about radiation exposure standards for caregivers such as a parent or spouse (quotes from the ACOEM's comment).
- "Caregivers receive no radiation worker training, no individual monitoring, no medical surveillance, and no periodic dose accounting." Yet, the proposed standards would make it possible for caregivers to receive even more radiation than professionals whose dose limits are restricted by occupational safety standards.
- There is no clarity about the total radiation a caregiver might receive. For example, a caregiver might be exposed to radiation while visiting the patient in a medical facility, and then be exposed to additional radiation while caring for the patient at home.
- Special radiation limits exist for pregnant workers, but not for caregivers who may be pregnant.
- The proposed regulations for caregiver exposure do not apply to minors, because minors cannot be designated as caregivers.
The reality is that minors and pregnant women may act as caregivers and they will almost surely be exposed to radiation if a patient is discharged for home care. It is better to acknowledge that people in these categories are particularly vulnerable to radiation and provide them with training, monitoring, and as much protection as possible.
Instead, in addition to not considering these special vulnerabilities for caregivers, the new regulation would reduce reporting requirements for radiation exposure to fetuses. The rational is that a patient might be unaware of her pregnancy when the radiation is administered. This is certainly a valid scenario, but it should not mean that the exposure to the fetus should not be reported. Instead, any child who was exposed to radiation in utero should have that fact as part of their medical record.
Finally, the ACOEM raises important points concerning state radiation protection standards, pointing out that under the proposed regulation: " ... a State could not retain an ALARA requirement, could not retain a ceiling on authorized public dose, and could not retain a lower caregiver dose allowance, even if its own legislature or radiation control program concluded that doing so was warranted for its population."
Throughout the nuclear era there have been efforts to relax the regulations for exposure to radiation. Leslie Groves claimed to have heard that severe radiation poisoning "is a pleasant way to die". In the latest attempts to reduce radiation protection, federal employees and others have promoted the blatantly false assertion that "Hormesis" is a thing — without a shred of evidence, and despite study after study indicating just the opposite: that LNT is a good approximation of radiation risk from exposure, down to the lowest possible measurable amount. BEIR VII confirmed it and literally thousands of individual research projects have contraindicated Hormesis. The physics of how the damage occurs was unknown when man-made radiation was introduced into society , but the fact that damage occurs was well-known before the Manhattan Project.
All ionizing radiation presents risks and should have a corresponding benefit to society. Both authors of this comment have benefited from the high doses of radiation given to diagnose and treat cancer patients (both are cancer survivors) and appreciate the work of organizations such as the ACOEM.
Even small radiation doses to vast numbers of people will cause cancers that need not have happened. Radiation exposure should ALWAYS be kept As Low As Reasonably Achievable (ALARA). These proposed rules will weaken protections for millions of people and will make it difficult for families and their medical providers to assess risks. For these reasons they should be abandoned.
We incorporate by reference and adopt as our own the comments submitted by the ACOEM (
https://www.regulations.gov/comment/NRC-2025-1237-0006 tracking #:
mtd-chbq-9vvg).
Sharon and Ace Hoffman
Carlsbad California USA
Contact information for the author of this newsletter:
Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download:
acehoffman.org
Blog:
acehoffman.blogspot.com
YouTube:
youtube.com/user/AceHoffman
Email: ace [at]
acehoffman.org
Founder & Owner,
The Animated Software Company
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