In the United States, there are no comprehensive, easy-to-interpret radiation protection guidelines available to the general public with practical usefulness in a time of emergency. What guidelines exist can be divided into five categories: early guidelines (antediluvian: before the flood of radioactive contamination of the biosphere); revised guidelines; post-Chernobyl "levels of concern;" official protection action guidelines for use by authorized persons for use during a domestic accident and the most recent federal publications discussed in the previous section.

The first protective action guidelines (PAG) issued by the Federal Radiation Council in 1960-61 are the early (antediluvian) guidelines. Present from before the birth of the commercial nuclear industry, these conservative guidelines described practical stages of safety precautions to be taken in the event of increasing radioactive contamination of the environment. In 1982, a second revised and much more liberal set of radiation protection action guidelines (PAG) were issued as a component of the development of radiological emergency response plans to be implemented on a state by state basis by the Federal Emergency Management Agency (FEMA) in the event of a domestic nuclear "incident." The focus of these guidelines is on emergency actions to be taken in times of major releases of nuclear contaminants to prevent the acute effects of radiation poisoning. Earlier guidelines were concerned with contamination of the environment beginning with a "level of concern" which was much lower than those now described as emergency actions in the more recent revised FDA/FEMA protective action guidelines (PAGs). A third set of guidelines specifically titled "levels of concern" was issued by the FDA just after Chernobyl in anticipation of the spread of radioactive contamination from this accident. The fourth set of guidelines is contained within the Radiological Emergency Response Plans sponsored by FEMA, the circulation of which is restricted to authorized persons. These four categories of protection action guidelines will be discussed as a component of the annotated citations below.

The fourth part of this section, following the summary of U.S. protection action guidelines, lists protection action guidelines in effect in Europe after the Chernobyl accident.
 

A. Early Guidelines (Antediluvian): 1961

The radiation protection guidelines issued by the Federal Radiation Council and contained in the following table are among the earliest recommendations in radiation protection literature. They represent the first category of protection action guidelines and the first PAGs issued in this country. Weapons-testing fallout pulses of ¹³¹I exceeded range III of these guidelines shortly after their publication (See RADNET Section 9: Dietary Intake, Baretta 1976); in the post-Chernobyl era, this guideline for radioiodine now seems quaint, a wistful remnant of a bygone era. Many important radionuclides are not listed in this guideline.
 

Table 1: Radiation Protection Guides (RPG) for transient rates of intake of (some) radionuclides(1)

Radionuclide	Target Organ	Dose Equivalent (RPG) for Upper Limit of Range II rem/year	Intake Rate (pCi/day)(a)
			Range I	Range II	Range III
Iodine-131	Thyroid	0.5	0 - 10	10 - 100	100 - 1,000
Strontium-90	Bone	0.5	0 - 20	20 - 200	200 - 2,000
Strontium-89	Bone	0.5	0 - 200	200 - 2,000	2,000 - 20,000
Cesium-137	Whole Body	0.17	0 - 1,450	1,450 - 14,500	14,500 - 145,000
Barium-140(b)	Bone	0.5	0 - 1.4x104	1.4x104 - 1.4x105	1.4x105 - 1.4x106
Tritium(b)	Whole Body	0.17	0 - 2x105	2x105 - 2x106	2x106 - 2x107
Ruthenium-106(b)	Lower, Large Ints.	0.5	0 - 725	725 - 7,250	7,250 - 72,500

(a) Range I requires only periodic surveillance; Range II, quantitative surveillance and routine control; Range III, evaluation and additional controls (FRC 61). (b) For specific radionuclides not considered by the FRC, the Ranges were derived using the radionuclide concentrations in water tabulated by the National Committee on Radiation Protection (NBS 63) for occupational exposure x 1/30 as applied to the general population.

(1) Transcribed from R.E. Sampson et al., Survey of Radionuclides in Food, 1961-77, p. 531. See Federal Radiation Protection Standards (1960-1961) Reports 1 and 2.

• This protection action guideline, which dates from 1961, represents the earliest and most conservative preventive action range of suggested evaluations and controls and pertains to the contamination of the environment beginning with low levels of anthropogenic radionuclides. In this guideline, a daily intake of 100 pCi/day of ¹³¹I represents a degree of contamination requiring actions which exceed quantitative surveillance and routine control (restrict pasture, avoid surface water supplies, wash or peel vegetables, store or reprocess milk) and encompass a level of contamination at which the "additional control" of isolating contaminated food would normally be taken.
• These protective action guidelines, often cited in FDA literature prior to 1980, have been superseded by the more liberal protective action guidelines issued by the FDA in 1982 and printed in the Federal Register. The EPA publication issued in 1992 and cited below reaffirms the 1982 FDA guidelines which were issued as a component of the radiological emergency response plans sponsored by FEMA. In these publications, no mention is made of the specific guidelines of the earlier FRC and their much more restrictive intake rate ranges.

U. S. Department of Health and Human Services. (1982). Accidental radioactive contamination of human food and animal feed; recommendations for state and local agencies. Docket No. 76N-0050. Federal Register. 47(205). pg. 47073-47084.

• This guideline applies only to contamination originating from a domestic nuclear accident and describes standards set forth by the Food and Drug Administration (FDA) as part of the development of guidelines for the Federal Emergency Management Agency (FEMA) to be used in the event of a domestic nuclear "incident." This notice is referred to in RADNET as the 1982 FDA/FEMA protective action guidelines (PAG).
• This guideline does not apply to exposure from multiple pathways e.g. external radiation, inhalation or absorption; it only concerns exposure from the ingestion pathway.
• This guideline consists of two components, "low impact protective actions (termed the Preventive PAG) at projected radiation doses of 0.5 rem whole body and 1.5 rem thyroid.... the Emergency PAG action is recommended at projected radiation doses of 5 rem whole body and 15 rem thyroid." (pg. 47074)
• RADNET has reproduced the low impact preventive PAG guideline in Section 12 of RADNET: Maine Yankee Atomic Power Company, in the annotation of FEMA's Maine Radiological Emergency Response Plan; extensive comments about the significance of these much less restrictive and more permissive contamination guidelines are contained under this citation.
• The most important component of the emergency protection action guidelines is that the projected radiation doses are assumed to take place in just a few days. It is assumed that exposure to the enormous amounts of radioactive contamination listed as the "response levels" in the emergency PAGs will not continue over a long period of time, despite the long radioactive half-life of ¹³⁷Cs, a primary constituent of accident deposition. The lesson of the Chernobyl accident in 1986 is that exposure to the longer-lived radionuclides in an accident plume pulse continue for far longer than the few days of exposure assumed in the FDA/FEMA guidelines.
• The following quotations are abstracted from the Federal Register:

"Assuming that initial contamination by ¹³¹I and cesium or strontium.... was at the preventive PAG level, radioactive decay and weathering would reduce the levels so that protective actions could be ceased after one or two months." (pg. 47076).

"Although it may be desirable to consider total health effects, not just lethal effects, there is a lack of data for total health effects to use in such comparisons." (pg. 47077).

"FDA believes that, to establish a PAG, the primary concern is to provide adequate protection (or safe level of risk [emphasis added]) for members of the public." (pg. 47077).

"Protective actions are appropriate when the health benefits associated with the reduction in exposure to be achieved are sufficient to offset the undesirable features of the protective actions."(pg. 47080).

• The FDA has established the following emergency protective action guidelines (See RADNET Section 12, Maine RERP annotation for the preventive PAG issued in this section of the Federal Register):

• The total accident intake listed at the bottom of column 1 assumes the impact of a nuclear accident will not exceed 30 days due to the implementation of controls which will mitigate the intake of radioactivity (relocation, use of canned or alternative food sources etc.).
• The fact that the emergency protection action guideline with respect to the daily intake of ¹³¹I for an infant is now 900,000 pCi/accident (30,000 pCi per day for 30 days) instead of 100 pCi/day as recommended in the old FRC PAGs (institute "additional controls", i.e. isolate contaminated food) illustrates both the schizophrenic content and the lack of credibility of the current federal radiation protection guidelines.
• The Chernobyl accident served to validate the probability of much higher levels of radioactive contamination of the environment but does not validate the radical change in the response levels for instituting the eminently practical preventative actions which should follow any type of nuclear accident.
• The bizarre nature of the 1982 FDA guidelines is further illustrated by the Federal Emergency Management Agency (FEMA) general protection action guidelines for authorized persons entering and leaving an emergency operations center (EOC), as illustrated in the Maine Radiological Emergency Response Plan (RERP) (See the RERP review in RADNET Section 12; also, see section C below.) The FEMA guidelines for authorized EOC personnel suggest specific remedial actions when total surface contamination on authorized persons exceeds 300 cpm above background (not nuclide specific). This compares with peak intake of radiocesium in milk for infants and pregnant mothers of up to 3,900,000 pCi/liter until a total accident intake of 110,000,000 pCi is reached. (1 pCi = 2.2 counts per minute {cpm}). Only at this level of intake do these protective action guidelines suggest destroying the milk rather than putting it in temporary storage until decay (of ¹³¹I , not radiocesium) occurs. (The FDA guidelines mention neither the long half life of ¹³⁷Cs nor the presence of a variety of other isotopes which would likely contaminate milk after a nuclear accident e.g. barium, lanthanum, etc.).
• The old FRC action guideline of 100 pCi/day intake of ¹³¹I (for adults!) is equal to a count rate of 222 cpm (of ¹³¹I in the daily diet); the action level for surface contamination on authorized persons of 300 cpm is compatible with these earlier guidelines but also serves to emphasize the lack of credibility of the FDA/FEMA emergency guidelines for both infants and adults.
• This 1982 FDA Federal Register notice contains a bibliography of 22 citations (pg. 47080) which are the basis for these protective action guidelines. There is no reference made to or mention of the 1961 Federal Radiation Council protective action guidelines still in use by the FDA after the Chernobyl accident as "levels of concern" in this notice.

• This thick manual is a somewhat disorganized collection of action guides, supplementary reports, appendices, figures and tables and includes the FDA Federal Register notice, Accidental Radioactive Contamination of Human Foods and Animal Feed: Recommendations for State and Local Agencies. This publication constitutes the most up-to-date EPA summary of protection action guidelines to be followed during a nuclear accident. The FDA federal register notice reviewed in the previous annotation is reprinted as chapter 3 of this EPA manual.
• The following summary of exposure pathways, accident phases, and the actions which would follow provide a general guide to governmental evaluation of and response to a nuclear accident, now no longer specified as only domestic in origin:

• It is important to note that both the preventive and emergency protection action guidelines issued by the FDA and used by FEMA only consider the ingestion pathway, #6 above, as the basis for protective actions to be taken during and after a nuclear accident.
• "It is necessary to distinguish between evacuation and relocation with regard to incident phases. Evacuation is the urgent removal of people from an area to avoid or reduce high-level, short-term exposure, usually from the plume or deposited activity. Relocation, on the other hand, is the removal or continued exclusion of people (households) from contaminated areas to avoid chronic radiation exposure." (pg. 1-5).
• This report defines "early phase" as "the period beginning at the projected (or actual) initiation of a release and extending to a few days later, when deposition of air-borne materials has ceased, and enough information has become available to permit reliable decisions about the need for longer term protection. During the early phase of an incident, doses may accrue both from air-borne and from deposited radioactive materials... for the purpose of planning, it will usually be convenient to assume that the early phase will last for four days -- that is, that the duration of the primary release is less than four days, and that exposure to deposited materials after four days can be addressed through other protective actions, such as relocation..." (pg. 2-3).
• The protection action guideline for the early phase of a nuclear incident is evacuation or sheltering for a projected dose of 1-5 rem, and the administration of stable iodine at 25 rem. See Table 2-1, pg. 2-6.
• The focus of this manual, as well as the FEMA guidelines used in the Maine Radiological Emergency Response Plan, is on the acute health effects associated with large doses of radiation rather than on any consideration of the health effects or social impact of lower levels of radioactive contamination that would also be a component of any type of nuclear incident which resulted in the high levels of contamination which these action guidelines address. "Acute radiation health effects are those clinically observable health effects which are manifested within 2-3 months of exposure... acute effects do not occur unless the dose is relatively large, and there is generally a level of dose i.e. threshold, below which an effect is not expected to occur." Appendices in this manual provide extensive discussion of what these acute effects are and the related dose level estimates.
• "Even in heavily irradiated populations, the number of cancers and genetic defects resulting from radiation is known only with limited accuracy. In addition, all members of existing exposed populations have not been followed for their full lifetimes, so data on the ultimate numbers of effects is not yet available." (pg. B-19).
• Appendix E includes a brief description of various categories of nuclear power plant accidents (See Table E-1, pg. E-2), as well as the source term for the most serious type of nuclear accident (See Table E-2, Release Quantities for Postulated Nuclear Reactor Accidents, pg. E-3), reproduced below.

• This manual also includes a "consideration of the appropriate range of costs for avoiding a statistical death... Estimated incremental societal costs per day per person relocated are:"

• These specious per diem "societal costs" estimates symbolize the overall lack of credibility of all aspects of the EPA/FDA 1982 guidelines and the Maine RERP and other radiological emergency response plan PAGs derived from these publications.