UNITED STATES ENVIRONMENTAL PROTECTION AG:

                            WASHINGTON. O C 20i6Q
April 26, 1985
                                                                     or t ic t Or
Honorable Lee M- Thomas                                           _ME AOV1,N1,,Th.ATC.«
Adninlstrator
U- S, Environmental Protection Agency
401 M. Street S. W.
Washington, D.C, 20460

Dear Mr* Thomas:

     The Radiation Advisory Committee of the Science Advisory Board was
recently established to review the technical basis of EPA's radiation
ruleoakings and to provide advice on the Agency's radiation research
program. The Committee Is concerned over long-term trends in funding
for radiation activities.  At its first meeting of February 4,  1985, the
Committee learned that the Office of Radiation Programs' resources had
been repeatedly reduced.  At its second meeting, the Committee  learned
that EPA's Health Effect Research Laboratory's nonlonizlng radiation
research program will be eliminated in Ff '86.

     We would like to convey to you our strong concern that this  unique
research capability will be lost if this action is carried out.   The
decision to cease research in this area goes counter to the ad-vice given
by the SAB earlier and counter to the Agency's need to maintain an
analytical and research capability if it is to make informed regulatory
decisions.  In addition, advances in the field of nonionizing research
are changing our understanding of the biological nsechanisras at  "work.

     EPA should continue and strengthen its program of extramural research
and also its in-house research on the health effects of radiofrequency
radiation*  This is necessary not only to keep abreast of the field  but
also because the research itself is invaluable to the nation, as  attested
by the fact that a considerable part of the scientific results  reported
in its recent (1984) review of the field derives from work done at EPA's
own laboratories.

     Among possible topics for future research, the Committee enutierates
the following,

     a. Effects of modulation imposed on radiofrequency carriers,
particularly modulation at very low frequencies, on biological  specii?Kns
exposed to vsry low power densities,
     b. Effects of chronic vs. acute  exposures! 3n|3  °*  partial~body vs.
whole— body exposures.

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     c.  Effects of exposure to pulsed sources of very high peak power vs.
sources that are adequately characterized by average power.

     d.  Synergistic effects of radiofrequency energy with other physical and
chemical agents.

     e. Testing the validity of recent results with regard to mutagenic and
similar effects observed at low power densities.

     f. Evaluation of the thermoregulatory capability and concomitant
physiological processes of various populations exposed under extreme
environmental conditions.

     Inasmuch as results of recent investigations in this  field have served
to confirm the  importance of these topics for the decision-making that
support the establishment of nonionizing radiation protection guidance,  ^
the Radiation Advisory Committee reiterates  the importance of the Agency s
own research in this  field, especially in-house research.  We understand
that the guidance now being developed does not address low-level and
modulation effects because the  information to make  judgments on how to
address them is not yet available.   It is reasonable to  use currently
available information to protect public  health while continuing to explore
unknowns.  It  is quite another  thing to  acknowledge  that information is
needed  and simultaneously eliminate  the  principal  resource for  collecting
that information—EPA's own laboratories.

     The Committee understands  the pressure  exerted  on  the Agency  to
eliminate this item in  FY'86, but  points out that  this  research  is
clearly in  the national  interest  and is  consistent  with EPA's mission.

     Accordingly,  the Committee strongly urges  you to review the  Agency's
decision and  to reinstate  at  least the in-house portion of the  Agency's
research effort.

                                Sincerely,
                                William J« Scm Ll, Chairman
                                Radiation Ad\£:3ry Committee
                                Norton Nelson, Chairman
                                Executive Committee
                                Science Advisory Board
 cc:  Radiation Advisory Committee

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