This blog post explains that any reconsideration of the U.S. radiation protection framework must keep in mind the goals of reestablishing the United States as the global leader in nuclear energy and maintaining the United States’ reputation as a leader in nuclear safety. Any changes the U.S. makes in its radiation protection framework should be based on the best available scientific information and done through a process that maintains public trust.
Background
In May of 2025, the Trump Administration issued Executive Order 14300, “Ordering the Reform of the Nuclear Regulatory Commission (NRC).” The EO establishes several overarching goals and requires numerous specific actions to reform NRC’s culture, structure, and regulations.
One of the EO’s specific requirements is for NRC to revisit the U.S. radiation protection framework. In revisiting this framework, two overarching goals of the EO are especially salient: “Reestablish the United States as the global leader in nuclear energy” and “Maintain the United States' leading reputation for nuclear safety.”
What is the U.S. Radiation Protection Framework?
As it does with respect to many types of pollution, the U.S. government currently assumes that any amount of radiation poses some risk (i.e., there is no threshold), that more radiation is more harmful than less radiation, and that the risk increases proportionately (linearly) with the amount. This is known as the Linear No Threshold (LNT) model. As with many environmental carcinogens, it is very difficult to distinguish the risk of very low levels of radiation from the typical cancer risk each person faces from all other factors. LNT is a conservative model in the face of these uncertainties.
To manage this risk and its uncertainty, the U.S. radiation protection framework combines non-zero radiation dose limits with the application of the “As Low as Reasonably Achievable” (ALARA) principle below those limits. Although the statutes and acronyms vary by pollutant and by country, most regulators agree that it is essential to take into account health effects as well as what is reasonably achievable in managing these types of risks. For example, under the hazardous air pollutant provisions of the Clean Air Act, the Environmental Protection Agency (EPA) sets Maximally Achievable Control Technology standards (based on what makes sense for technical feasibility, economic, environmental, and public health reasons) and some additional risk-based standards.
Revisiting the U.S. Radiation Protection Framework
The main justification given in EO 14300 for revisiting the U.S radiation protection framework is that the LNT model is flawed. NIA’s view is that, flawed or not, it’s widely used and no compelling alternative model has emerged to replace it. While the LNT model drives the “as low as” in ALARA, reasonableness is supposed to drive what is “reasonably achievable”. So ALARA is supposed to embody a balancing test. Importantly, U.S. and international dose limits are not set at zero, but rather are based on judgements about what level of risk is acceptable. The U.S. radiation protection framework is based on the work of domestic and international organizations like the National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiation Protection (ICRP), as well as the requirements of multiple domestic health and safety statutes.
While there is a substantial body of research on the effects of high doses of radiation, there is a research gap on low-dose effects. Improving the scientific and technical basis for the radiation protection framework would be helpful, but challenging. Some have proposed a substantial investment over decades to collect additional data, but it is unclear whether this would provide additional clarity. It is important to identify a cost-effective approach to obtaining decision-relevant information. One option would be for NCRP to complete the ongoing epidemiological assessment of low-dose radiation called The Million Person Study in the next 3-5 years with an incremental investment of $10-12 million.
Currently, the U.S. public dose limit is set based on the pragmatic notion that the radiation received from a nuclear power plant should be less than the variation in natural background radiation levels. The U.S. worker dose limit is set to keep occupational risks in the nuclear industry comparable to that in other safe industries. This is a common-sense approach in the face of uncertainty about whether an actual effects threshold exists.
Other specific limits below these dose limits apply under multiple domestic environmental and safety statutes. Thus U.S. agencies and programs such as the U.S. Department of Energy (DOE), NRC, and EPA, have different subsidiary limits. Some agencies have entered into memoranda of understanding (MOU) that allow one agency to lead for specific subsidiary limits.
Revisiting the Dose Limits
NIA sees no compelling need or basis for changing the existing dose limits. In particular, changing the radiation framework without adequate justification or transparency would undermine the public trust essential to a bright future for new nuclear energy.
While the current dose limits may be conservative, conservatism has its benefits. NIA advocates for doubling or tripling the use of nuclear power, and often notes that even with such a big expansion, cumulative doses to the population will remain very low.
There is no need to raise dose limits to enable nuclear innovation. The same sorts of features that enable increased safety margins in new designs (compared to currently operating plants, which are already remarkably safe) also enable them to easily meet worker and public dose limits. New nuclear reactors are already being licensed successfully under the existing radiation protection framework. The existing plants are operating well below the current dose limits and so can the next-generation plants.
Importantly, nuclear reactors are long-lived assets that need stable and long-lived rules. In order for rules to be durable, they must have broad stakeholder, public and bipartisan support. Executive orders – from any administration – are inherently unstable because the next administration could easily change them. Regulations can always be undone by new regulations in the future. EO and regulatory whipsawing can hinder new nuclear investment and development by creating uncertainty. Spending time repeatedly revising regulations is a distraction from licensing early mover reactors, which can continue to be licensed under existing regulations, as long as the rules are implemented efficiently and flexibly.
Unilaterally changing the U.S. radiation protection framework could do more harm than good for U.S. nuclear innovation and competitiveness. The U.S. radiation protection framework is now aligned with international norms and standards. U.S. technologies that do not align with these norms and standards will be difficult to export. Savvy technology exporters will meet international standards to be competitive, negating any benefit from changing domestic standards. To quote EO 14300 once again, it is essential to both “Reestablish the United States as the global leader in nuclear energy” and “Maintain the United States' leading reputation for nuclear safety.”
NIA’s view is that the current worker and public dose limits should remain where they are, given their commonsense basis and international acceptance. It is worth considering harmonization of the various agency-and program-specific limits consistent with each agency’s respective authorities and responsibilities. Expanding the current use of MOUs could be helpful.
Revisiting ALARA
NIA agrees with most regulators that it is essential to take into account health effects as well as what is reasonably achievable in managing radiation risk. In our view the problem is not the ALARA principle itself, but rather how it is being implemented. Even though the word “reasonably” is right there in the ALARA acronym, there are numerous instances of it being implemented inconsistently and sometimes unreasonably.
It is unclear whether on balance eliminating ALARA would reduce costs. On the one hand, minimizing doses can reduce operating costs because it can entail working more efficiently to minimize time of exposure in high radiation environments. On the other hand, minimizing very low dose can increase costs and non-radiation occupational risk. For example, requiring the use of respirators makes sense to avoid high radiation doses, but its benefits in low-radiation environments may not be worth the added costs and risks of heat stress and reduced visibility.
One option for revisiting ALARA is to “mend it, not end it.” For example, NRC could develop new, more reasonable guidance for ALARA implementation based on comparative risk assessment. Such guidance would establish best practices for ensuring that actions taken to reduce radiation exposure below established limits do not expose workers to larger non-radiation risks. As another example, the United Kingdom recently issued new guidance for implementing its “as low as reasonably practicable (ALARP)” principle more proportionately and efficiently.
The industry-led Institute of Nuclear Power Operations (INPO) sets a high bar for radiation protection best practices with which its members comply and to which insurance companies pay attention. Thus, eliminating federal ALARA rules might not change much in the power industry. However, other sectors like radiography, where some of the highest occupational doses occur, do not have an equivalent institution to INPO to establish best practices in the absence of federal guidance.
NIA’s view is that it’s important to address the problem of inconsistent and sometimes unreasonable implementation of ALARA by mending it, not ending it.
The Path Forward
To meet the EO 14300 requirement to revisit the U.S. radiation protection framework, NIA recommends the following:
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Keep the U.S. public and worker dose limits where they are, given their commonsense basis and international acceptance.
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Any changes the U.S. makes in its radiation protection framework should be based on the best available scientific information and done through a process that maintains public trust.
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Any regulatory changes must be durable, meaning they must have broad stakeholder, public, and bipartisan support.
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All the agencies that regulate radiation, including the U.S. Department of Energy (DOE), NRC, the Environmental Protection Agency (EPA), and others, should ensure a common understanding of the best available scientific and technical information across the federal government, coordinate based on each agency's respective authorities and responsibilities, and where feasible implement a common set of limits.
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Implement ALARA more reasonably, transparently and consistently through improvements in guidance and/or regulation. This would benefit industry, workers and the general public.
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In determining whether to take further action on ALARA, the federal government needs to consider the costs and benefits of alternative approaches, provide a clear rationale, and vet any proposed approach with experts and stakeholders.
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For the long term, improve the scientific and technical basis for the radiation protection framework across the federal government through well designed and executed research. For example, the NCRP could complete The Million Person Study of low-dose radiation in the next 3-5 years with an incremental investment of $10-12 million.