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|INTRODUCTION The most serious occupational radiation episode in U.S. history was the exposure of uranium miners to radon daughters in the 1945-1968 time period. Although the maximum permissible dose at that time was 12 WLM (working level months) per year, average exposures were several times that figure, and ten times higher exposures were not uncommon. Starting in the early 1960s, mounting epidemiological evidence appeared for an excess incidence of lung cancer among these miners; up to 1974, there was an excess of 134 cases (159 observed vs 25 expected) among the 4000 in the group under study (NAS-1980). When this excess became apparent, the Federal Government took jurisdiction, greatly tightened enforcement, and in 1969 lowered the maximum permissible exposure to 4 WLM per year. These standards were met largely by a great improvement in ventilation. As a result of these measures, average miner exposures were reduced 5-fold from 1965 to 1968 and by another factor of 3 by 1970. In 1978, the 4 WLM/year maximum permissible exposure was exceeded by only 37 of 7500 underground miners, for only 16 wars it exceeded by more than 25%, and for only 8 was it exceeded by 502 (AIF-1980). The average exposures to the various groups are listed in Table 1. We see that the average exposure for all miners was 1.03 WLM, and for those who worked essentially full time underground it was 1.45 WLM. For purpose of later discussion, it will be convenient to choose a single value for average exposures. In view of the fact that employment situations and job categories are bound to vary over a lifetime of work, we take this to be 1.3 WLM/year. The purpose of this paper is not to dwell on history, but rather to address the question of whether or not this present situation is satisfactory. This question was considered recently by a study group under the auspices of National Institue of Occupational Safety and Health (NIOSH-1980) and it answered the question in the negative, concluding that the maximum permissible exposure should be substantially reduced. However, their arguments were incomplete and were lacking in perspective. The principal thrust of this paper is to provide some of the material overlooked. RISK TO URANIUM MINERS FROM RADON EXPOSURE In order to quantify the risk to uranium miners under present working conditions, it is first necessary to estimate the risk of lung cancer per WLM of exposure. The most straightforward way of doing this is to use the data on the group of uranium miners under study. These are listed in Table 2 for 8 exposure ranges and for the total group (NAS-1980). If all data are given equal weight, the risk is seen to be 3.5 x 10-6 per year per WLM. Much can be said in favor of using this value for the risk as dose independent; it is within one standard deviation (SD) of the observations in 5 of the 8 dose categories (as expected from the definition of SD), and within 2 SD for all 8, and for the three cases differing from the mean by more than one SD, two are above and one is below. However, the uranium miner exposures in the present situation will be far below those covered in Table 2, so it is worth considering the possibility that the risk differs from this at low doses. From the last column of Table 2 we see that the experience from all exposures below 600 WLM indicates a risk higher than the mean for the entire group by more than two standard deviations (the value 600 WLM in this comparison was deliberately chosen to maximize this deviation; for exposures below 360 WLM and 840 WLM, the excess is only 1.0 and 1.6 standard deviations respectively). In view of this tendency for the risk to be higher at lower dose, we will take the risk to be 5.0 x 10-6 per year per WLM in what we will refer to as model A. This risk estimate is based entirely on exposures much [higher] than those that will be experienced by|