November 12, 2025
From: The below-signed organizations
To: The Commission, US Nuclear Regulatory Commission
Director Russel Vought, Office of Management and Budget
Rear Admiral Denise Hinton, Acting Surgeon General of the United States
Secretary Robert F Kennedy Jr, Health and Human Services, MAHA
Congressional Childhood Cancer Caucus, c/o TX Representative Michael McCaul
Jennifer Lockwood-Shabat, President, Women’s Congressional Policy Institute
Senator Edward Markey
Cc: list below organizational signers
Dear Executives,
The Trump White House has issued numerous executive orders (EO), including one directing the Nuclear Regulatory Commission (NRC) to revise its long-standing radiation rule, Standards for Protection Against Radiation, found in the Code of Federal Regulations, Chapter 10, Part 20 and related regulations. The title is apt—human and other living bodies do indeed require protection from radiation. Although Part 20 is already inadequate in many respects, it is still far better than the revisions now being proposed.
Advisory bodies representing industry and other government sectors that expose people to radiation daily are pushing to relax current standards. NRC has not made a revision yet, and has been hearing that the Part 20 exposure (external only) should be taken from the existing 100 mrem a year, per license, to 500 mrem a year, and in the view of some, even to 10 rems, which would be 100 times the current level. This means anywhere from five times less protection to one hundred times less protection. At 10 rems, four out of five adult males exposed over a 70-year lifetime would develop cancer — a sentence to diminished health and, in many cases, premature death.
The vested interests also attack the basis of NRC regulation, the Linear No Threshold (LNT) model. A 2015 Petition for Rulemaking to the NRC proposed a 10 rem per year exposure limit for the general public and triggered a review of the LNT model by the NRC. The Petition was soundly rejected by NRC in 2021, affirming the scientific basis and global consensus by expert radiation bodies and many regulatory bodies that the linear dose-risk graph extends to zero (no threshold) and is sound.
Now the EO calls for an additional weakening of protection by setting a threshold, or level below which radiation exposure would not “count” or be considered to have not occurred. Part 20 is based on the well-documented findings that even exposures so small that they cannot be measured may, sometimes, result in fatal cancer. The only way to reduce risk to zero requires zero radiation exposure.
Decades of published peer-reviewed research supports the Linear No-Threshold (LNT) model. Key studies demonstrate that increased radiation exposure levels lead to increased disease, and that there are catastrophic outcomes (fatal cancer for one) known as stochastic impacts that are not related solely to exposure level. Research demonstrating this includes study of the A-bomb survivors in the Lifespan Study (LSS) as reported by many, including the National Academy of Science report Biological Effects of Ionizing Radiation, VII Phase 2 (BEIR VII), and many studies of nuclear workers, including the INWORKS dataset that includes nuclear workers from European and US operations. Research teams continue to investigate radiation harm and have demonstrated support for the LNT model, supporting both BEIR VII findings and the Hiroshima and Nagasaki survivor LSS.
The threshold idea was tried by NRC back in 1986, and expanded in 1990, with the Below Regulatory Concern (BRC) designation for radioactive waste. BRC allowed radioactive waste, salvage items, contaminated materials, and some practices to be declared non-radioactive and released for indiscriminate disposal and recycling—including consumer products. The BRC concept was rejected by communities, waste management authorities, unions, counties, 14 states, and in 1992, Congress directed NRC to revoke its own BRC policy.
Part 20 bases its risk assessments on “Reference Man,” a model that represents a young adult male and fails to reflect the greater impacts to infants, children, and women—pregnant or not. Part 20 also focuses on external exposure while ignoring internal exposure from inhaled or ingested radioactive materials. Since the 1970s when Part 20 was established, newer research has shown that external radiation harms children more than adults and female bodies more than male bodies. Research on internal exposures, while showing that insoluble hot particles may result in much higher levels of exposure than previously thought, has not yet been sufficiently analyzed to discover broad age-based or male/female differences. This oversight needs correcting.
Existing standards should therefore be strengthened to account for these life-stage and gender disparities and for all pathways of exposure, not weakened. Radiation causes infertility, loss of pregnancy, birth complications and defects, solid tumor cancer, leukemia, non-cancer outcomes including cardiovascular disease, increased autoimmune disease, and ongoing new findings.
Executive Order 14300 would do the opposite. It would undermine public trust by falsely claiming that NRC’s radiation risk models lack scientific basis, despite decades of peer-reviewed evidence and international consensus supporting the LNT model. The order explicitly instructs the NRC to “reorganize to promote the expeditious processing of license applications and the adoption of innovative technology.” Executive orders do not have the power to require federal agencies to take actions that violate their governing statutes, nor to grant them new powers outside those statutes. The NRC needs to stand up to the Executive Order’s marching orders to “promote” nuclear power — a mission outside its legal regulatory mandate under the Energy Reorganization Act of 1974 and the concurrent amendments to the Atomic Energy Act. NRC should not favor industry propaganda asserting that some radiation is safe over science-based protection of the public. This is a deliberate subversion of science and public health in favor of corporate interests.
The undersigned organizations advocate for stronger, science-based radiation protections that:
• Center standards on the life stages most impacted by radiation — gestation and early childhood — thereby improving protection for everyone.
• Base exposure limits on female physiology, which is more affected by radiation.
• Include internal exposure from contaminated air, food, and water in overall exposure limits.
• Use empirical data to reform inadequate internal-dose models.
• Guarantee public access to real-time radiation monitoring of radioactive emissions and waste at all licensed sites.
• Develop updated risk models acknowledging that no radiation dose is harmless and focusing protection on those most at risk, including communities targeted because of socio-economic factors including race and language barriers.
As radioactive emissions accumulate in the environment, radiation exposure is intensifying and affecting all living things. The NRC’s own cancer-risk estimates, based on 1970s data, underestimate harm by nearly a factor of three for adult males. Contemporary research shows that radiation’s impact is far greater on females, children, and fetuses — with the most at-risk postnatal group being girls from birth to age five. A truly protective framework would replace Reference Man with a lifecycle model.
Accepting weaker radiation protections amounts to accepting an ever-increasing level of avoidable human disease and suffering. It is not too late for the NRC to uphold genuine family values — those that prioritize the health of children and future generations — by resisting efforts to trade human safety for nuclear industry expansion.
With shared concern for our future,
Beyond Nuclear, Takoma Park, Maryland
Nuclear Information and Resource Service, Mt. Rainier, Maryland
Physicians for Social Responsibility, Washington, DC
Sierra Club, National
Generational Radiation Impact Project, Asheville, North Carolina*
Southwest Research and Information Center, Albuquerque, New Mexico
Nuclear Energy Information Service, Chicago, Illinois
Nuclear Watch South, Atlanta, Georgia
ECAN — Erwin Citizens Awareness Network, Inc., Jonesborough, Tennessee
The Clinch Coalition, Wise, Virginia
Appalachian Peace Education Center, Abingdon, Virginia
Nuclear Free Northwest, Seattle, Washington
Montana Environmental Information Center, Helena, Montana
Snake River Alliance, Boise, Idaho
Healthy Environment Alliance of Utah (HEAL Utah), Salt Lake City, Utah
Ohio Nuclear Free Network, Statewide Ohio
Rocky Mountain Peace and Justice Center, Boulder, Colorado
Greenaction for Health and Environmental Justice, San Francisco, California
San Clemente Green, San Clemente, California
San Luis Obispo Mothers for Peace, California
Ecological Options Network, Bolinas, California
Redwood Alliance, Arcata, California
Alliance for Nuclear Responsibility, San Luis Obispo, California
Citizens Awareness Network, Shelburne Falls, Massachusetts
Citizens’ Resistance at Fermi Two (CRAFT), Redford, Michigan
Western North Carolina Physicians for Social Responsibility, Asheville, North Carolina
Reject Raytheon AVL, Asheville, North Carolina
Stop the Algonquin Pipeline Expansion (NY, CT, RI, MA)
Physicians for Social Responsibility – New York
Alliance for Nuclear-Free NY, Albany, New York
Manhattan Project for a Nuclear-Free World, New York
Indian Point Safe Energy Project, New York
LEAF of Hudson Valley, Nanuet, New York
Hudson Valley Climate Science and Solutions, Cottekill, New York
Safe Energy Rights Group, Peekskill, New York
Rockland Coalition to End the New Jim Crow — Environmental Committee
Council on Intelligent Energy & Conservation Policy (CIECP), New York
Northwest Environmental Advocates, Portland, Oregon
Oregon Conservancy Foundation, Boring, Oregon
Columbia Riverkeeper, Hood River, Oregon
Alliance for Democracy, Portland, Oregon
Cc:
American Medical Association
National Association of Medical Professionals
American Academy of Pediatrics
Society for Pediatric Research
National Academy of Sciences
Volker Türk, UN High Commissioner for Human Rights
Union of Concerned Scientists
Public Citizen
Correspondence may be sent to Generational Radiation Impact Project, 30 Westgate Parkway #362, Asheville, North Carolina 28806
