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Journal js7a's Journal: Please Help Fight Birth Defects from Uranium Exposure 2

Please distribute widely:

The Federal Register published my rulemaking petition for recognition of the developmental and reproductive toxicity of heavy metals today (70 FR 34699.)

Please send a comment before August 29th to SECY@nrc.gov with a subject line such as: comments on PRM-20-26 toxicity petition

I recommend that you use your own words, but please include the following points:

  • Current regulations ignore the developmental and reproductive toxicity of heavy metal radionuclides, and are at present designed only to prevent kidney failure.
  • The reproductive toxicology profile for uranium combustion product inhalation in humans is currently unknown with any accuracy beyond 14 years (i.e., since the February 1991 exposures) and has shown an increasing and accelerating tendency, consistent with the fact that uranium accumulates in testes damaging sperm production cells and increasing chromosome damage over time.
  • It is completely unethical and immoral to allow any release of a known reproductive toxin without a fully established toxicology profile. Doing so is reckless and negligent; to willfully allow such releases is potentially a crime.
  • Regulators should attempt to extrapolate the existing known toxicology profile of heavy metal radionuclides and assume the worst case within the projections' 95% confidence intervals, and in an abundance of caution allow at least a two order-of-magnitude margin of error for limiting the increase in congenital malformations in children of the exposed to 5% after 30 years.

Thank you for the time and effort to help protect against birth defects.

Sincerely,
James Salsman (my other blog is hosted by a national laboratory)

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Please Help Fight Birth Defects from Uranium Exposure

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