Disproportionate impact of radiation and radiation regulation

Reference Man is used for generic evaluation of ionizing radiation impacts, regulation, and nuclear licensing decisions made by the U.S. Nuclear Regulatory Commission (US NRC). The United States Code of Federal Regulations, 2018 edition, Chapter 10: Part 20 ‘Standards for Protection Against Radiation’ contains eight references to ‘reference man’ as the basis for regulation and calculation of radiation exposure. The document was accessed January 9, 2019 (https://www.govinfo.gov/content/pkg/CFR-2018-title10-vol1/pdf/CFR-2018-title10-vol1-part20.pdf). Findings from 60 years of A-bomb survivor data show that Reference Man does not represent the human life cycle with respect to harm from radiation exposure. Findings reported here show females are more harmed by radiation, particularly when exposed as young girls, than is predicted by use of Reference Man; the difference is a much as 7-fold. Since females have been ignored in regulatory analysis, this has resulted in systematic under-reporting of harm from ionizing radiation exposure in the global population. A critique is also offered on the US Environmental Protection Agency’s attempt to include females in its regulation. Recommendations for interim regulation to provide better protection, and questions for further study are offered.