Comment (5) of Michael M. Graham and Jay A. Harolds on FR Doc # E9-15950

The Society of Nuclear Medicine and the American College of Nuclear Medicine are generally opposed to the proposal because there is no clear scientific basis for a reduction in permissible worker radiation absorbed doses. The available radiobiology literature varies in the interpretation of the effects of low dose radiation and new investigations are challenging traditional theories. Under the current 50 mSv (5 rem) plus ALARA system, doses to radiation workers in medicine are being well controlled and on average are only a small fraction of the regulatory dose limit. While it appears that a change from a 50 mSv (5 rem) to a 20 mSv (2 rem) dose limitation system would affect only a relatively small portion of the medical radiation worker population, there is nevertheless a real possibility that this change will cause increased costs to patients and third party payers and, potentially, a decrease in the quality and availability of medical care. We find no basis for the implied claim that such increases in costs would result in any clear benefit to workers. For these reasons, we oppose a change in the current 50 mSv (5 rem) plus ALARA radiation dose limit to radiation workers. There is a very strong current societal emphasis on controlling medical costs. Reducing dose limits in a way that may increase costs and possibly decrease medical quality, without any demonstrable benefit to workers, is not reasonable at this time.