6
Recommendations for Revisions of the ACE Directive

While the ACE Directive is a commendable initial effort to establish guidelines to protect soldiers in the field from the adverse effects of radiation, the committee recommends that it be revised to assure completeness and clarity.

The Army requested that the committee complete its technical review of the ACE Directive as quickly as possible, concentrating on the broader issues of ethics and law, risk perception, training, recordkeeping, and communication in the second year of the study. The technical recommendations we now present do not yet include these extremely important considerations.

Not surprisingly, however, we found each technical point to be associated with numerous considerations that involve societal, organizational, and personal values. The committee will spend its next year of research and deliberation in providing the Office of the Army Surgeon General with cogent and practical guidance that includes and reflects this broader philosophical context. Because of this, the evaluation of the ACE Directive is a work in progress and will not be complete until the final report adds the broader perspective.

Underlying Philosophy

The committee recommends that the Army:

1.  

Provide soldiers the same level of radiation protection as civilians working in similar environments. The ACE Directive appears to manage all military missions involving radiation exposures as interventions. While this is clearly appropriate for many missions (e.g., emergencies, radiation accidents, and operations involving hostile action), other missions can more properly be



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--> 6 Recommendations for Revisions of the ACE Directive While the ACE Directive is a commendable initial effort to establish guidelines to protect soldiers in the field from the adverse effects of radiation, the committee recommends that it be revised to assure completeness and clarity. The Army requested that the committee complete its technical review of the ACE Directive as quickly as possible, concentrating on the broader issues of ethics and law, risk perception, training, recordkeeping, and communication in the second year of the study. The technical recommendations we now present do not yet include these extremely important considerations. Not surprisingly, however, we found each technical point to be associated with numerous considerations that involve societal, organizational, and personal values. The committee will spend its next year of research and deliberation in providing the Office of the Army Surgeon General with cogent and practical guidance that includes and reflects this broader philosophical context. Because of this, the evaluation of the ACE Directive is a work in progress and will not be complete until the final report adds the broader perspective. Underlying Philosophy The committee recommends that the Army: 1.   Provide soldiers the same level of radiation protection as civilians working in similar environments. The ACE Directive appears to manage all military missions involving radiation exposures as interventions. While this is clearly appropriate for many missions (e.g., emergencies, radiation accidents, and operations involving hostile action), other missions can more properly be

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-->        treated as routine practices, thereby affording more complete control of the radiation exposure. Missions amenable to control as practices might include security details, decontamination of vehicles, and other scenarios in which hostile action is not expected. 2.   Develop and state an explicit radiation protection philosophy that defines missions as falling under the framework of either a practice or an intervention. Practices would be subject to modified requirements of the Army's existing occupational radiation protection program as previously described. It is likely that the situation in Bosnia would fall into this category. Under the committee's recommendations, soldiers would be considered radiation workers if they are assigned military duties that have the potential for radiation exposures that could result in doses in excess of the International Commission on Radiological Protection limits for the public (ICRP, 1991a)—1 mSv per year. A revision of the existing exposure guidance in the ACE Directive would govern those situations that are of an emergency nature and would be managed as interventions. In both cases, keeping doses as low as reasonably achievable will continue to be of primary importance. 3.   Clearly state in the policy paragraph of the subsequent versions of the ACE Directive the definitions adopted for practices and interventions in the necessary military context. The procedures that follow the policy statement should address practice and intervention separately. It would seem reasonable for the commander to have the authority to determine which of these frameworks to follow based upon the military mission. Terminology in the ACE Directive The committee recommends that the Army: 4.   Not use the term low level to describe the radiation dose range of 50–700 milligray (mGy) (5–70 rad). Low level may be an appropriate descriptor when comparing these doses to those that may be experienced from the detonation of a nuclear weapon. In the broader context of radiation protection, however, low level clearly implies much lower doses. 5.   Use terms other than no risk and normal risk for the risk state categories labeled RES 0 and RES 1A in the table of exposure guidance in Annex A of the ACE Directive. To describe any nonzero dose as no risk is inconsistent with current international positions on the effects of radiation. Likewise, the term normal risk incorrectly implies no additional risk to that from natural background radiation exposures, even though such exposures are considered to contribute very small, possibly negligible, health risks. 6.   Avoid the term radiological hazard when describing the exposure of soldiers to radiation, unless the hazard refers to a specific detrimental effect. For most cases in the ACE Directive radiological hazard simply means radiation.

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--> Prospective Risk Assessments The committee recommends that the Army: 7.   Develop requirements for measuring, interpreting, and responding to airborne and surface contamination (particularly that containing alpha and beta emitters). Guidance should define levels of alpha and beta contamination that would trigger use of protective equipment and actions. The ACE Directive gives only cursory consideration to this topic and the terminology used to describe the instrumentation necessary for the detection and measurement of radioactive contamination is not clear. 8.   Reconsider its absolute requirement that soldiers wear protective equipment within an exclusion zone as defined in the ACE Directive. The decision to use protective equipment should be based on the potential for personal contamination with radioactive materials, externally or internally. To require respiratory protection regardless of the existence of an airborne hazard may be counterproductive to completing the mission in a timely and effective manner. 9.   Make a clear distinction between military intelligence threat estimates and radiation risk estimates. It is unclear, in the Intelligence procedures section (NATO, 1996, §1-3.a.), whether risk (high or low) refers to (a) intelligence assessments of the likelihood of radiation contamination or (b) the magnitude of measurable levels of radiation contamination. 10.   Develop explicit requirements to define when individual radiation monitoring is required in the field. The guidance on whether a soldier could enter a low-level contaminated area without individual dose monitoring is vague. It would be reasonable to require individual dosimetry for all incursions into an exclusion zone where radioactive contamination is likely. Dosimetry Requirements The committee recommends that the Army: 11.   Review its dosimetry capabilities and determine if they are adequate to support the use of the Operational Exposure Guidance in the ACE Directive. In order to manage soldier exposures according to the ACE Directive, all soldiers would have to have dosimeters that can measure doses as low as 0.5 mGy (0.05 rad). 12.   Increase specificity of the dosimetry program guidelines in subsequent versions of the Directive (e.g., provide specific guidance on the capabilities of monitoring devices and equipment). The committee considers radiological monitoring and dose estimation for individuals, outside the occupational environment, as areas that require significant attention by the Army. 13.   Not assume, as the ACE Directive does, that internal doses will be zero because respiratory protection will be used. Soldiers may receive an

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-->       internal dose from inhaling or ingesting radionuclides. This may occur if they are unaware of airborne contamination and are not wearing protective equipment or if the equipment fails or is used improperly. 14.   Review its capability to measure airborne radioactive contamination. The ability to measure airborne radioactivity and respond accordingly is essential to an adequate radiation protection program. The lack of exposure information for airborne hazards has proven a problem, as noted previously for the Atomic Veterans. More recently, potential chemical exposures during the Persian Gulf War at Kamisiyah, Iraq (DoD, 1996; Schaeffer, 1996) have demonstrated how a lack of airborne exposure data creates problems with health assessment activities. 15.   Expand Operational Exposure Guidance to include radiation doses from both internal and external sources of radiation. These should be expressed in terms of effective dose and be consistent with the requirements of the U.S. Nuclear Regulatory Commission. The lack of consideration of internal dose is a major shortcoming in the ACE Directive. 16.   Adopt the millisievert (mSv) as the standard unit of effective dose and milligray (mGy) as the unit of absorbed dose. There are three reasons for this recommendation. First, the units currently used in the ACE Directive—centigrays (cGy) and centisieverts (cSv)—are not internationally accepted scientific units. Second, by using millisieverts, all doses to individuals can be compared to one year's nominal U.S. background dose from external sources (1 mSv). This should make it easier for soldiers to understand their exposures.15 Third, at low radiation levels, the use of the unit millisievert will reduce, albeit only slightly, the problems of recording doses that are much less than one and are expressed to several decimal places (e.g., 0.00002). 17.   Clearly define the time over which doses are to be accumulated for assignment of radiation exposure status (RES) levels in the Operational Exposure Guidance in Annex A of the Directive. Presumably, doses are cumulative over a career and are not reset to zero after each operation. 18.   Review and revise doctrine and procedures on dosimetry to ensure individual doses are monitored and recorded for all soldiers exposed to radiation, whether from routine occupational exposure or as a consequence of uniquely military missions. While the ACE Directive requires that records of individual dose be maintained, existing guidance (HQDA, 1994) requires tracking only of unit doses (e.g., average doses for a platoon). 15    One millisievert is the average accumulated background radiation dose to an individual for 1 year, exclusive of radon, in the United States.

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--> Operational Exposure Guidance Below 700 mGy The committee recommends that the Army: 19.   Include radiation doses from internal sources (e.g., from inhaled airborne radioactivity) in applying reference levels in Operational Exposure Guidance. The reference levels shown in the Operational Exposure Guidance table (Annex A) appear at least as stringent as those found in current civilian radiation protection recommendations of expert national and international advisory bodies. However, the ACE Directive misapplies the levels by assuming there will be no internal doses. 20.   Clearly specify what actions are recommended at each reference level in the Operational Exposure Guidance. Although the reference levels in the Directive are generally appropriate, the actions recommended at each level lack specificity. Future versions of the Directive or its implementing instructions should specify the details of each action (e.g., when to initiate a monitoring program and what its specific requirements are). 21.   Restructure the table of Operational Exposure Guidance to account for the uncertainty of dose estimates in interventions. Because of this uncertainty, the two lowest dose categories in the existing guidance are too narrow to be scientifically justified (in the environment of an intervention) and should be combined. 22.   Develop separate Operational Exposure Guidance for managing practices (routine tasks involving radiation exposure) in the context of a military operation. If the Army adopts the philosophy that soldiers should receive the same level of protection as civilian radiation workers in similar environments and circumstances, the guidance in Annex A should be expanded to include dose limits and reference levels appropriate for a practice as well as an intervention.