Problems created by regulating the ALARA principle

Regulating ALARA has fundamental problems: Optimisation of protection is not a hazard or harm; rather it is a principle of good practice for which education rather than mandated control is more appropriate and effective. The continuous cycle of ALARA drives regulation into very low risk areas where no harmful effect can ever be observed. Whatever the biological model, the risk from low doses of radiation is low. Because the ALARA principle applies in all situations, regulatory attention is directed widely rather than to where the main risks lie. Regulators focus on achieving the principle as an end in itself, rather than on achieving good outcomes. Regulating tiny doses underpins the view that no level of radiation is safe. This is compounded by professional reluctance to call a millisievert 'safe'. This has perverse outcomes in community understanding and reinforces the dread of radiation. As a first step, regulators should exclude from regulation doses below an agreed threshold. There are ways of controlling doses (of any size) that are more effective than mandating optimisation. If it cannot be effectively enforced (and it can't) then better tools should be used. Change can be achieved within the framework of international recommendations, and without restricting good radiation practice. Because the risks at commonly encountered doses are low whatever the model of biological effects (LNT, threshold or hormesis), the assumed model does not affect the argument.