The Federal Register published my rulemaking petition for recognition of the developmental and reproductive toxicity of heavy metals (70 FR 34699.)
Please send a comment before August 29th to SECY@nrc.gov with a subject line such as:
I recommend that you use your own words, but please include the following points: (continued)
- Current regulations ignore the developmental and reproductive
toxicity of heavy metal radionuclides, and are at present designed
only to prevent kidney failure.
- The reproductive toxicology profile for uranium combustion
product inhalation in humans is currently unknown with any accuracy
beyond 14 years (i.e., since the February 1991 exposures) and has
shown an increasing and accelerating tendency, consistent with the
fact that uranium accumulates in testes damaging sperm production
cells and increasing chromosome damage over time.
- It is completely unethical and immoral to allow any release of
a known reproductive toxin without a fully established toxicology
profile. Doing so is reckless and negligent; to willfully allow
such releases is potentially a crime.
- Regulators should attempt to extrapolate the existing known toxicology profile of heavy metal radionuclides and assume the worst case within the projections' 95% confidence intervals, and in an abundance of caution allow at least a two order-of-magnitude margin of error for limiting the increase in congenital malformations in children of the exposed to 5% after 30 years.
Thank you for the time and effort to help protect against birth defects. Excerpts from peer-reviewed medical literature in support of this petition follow.
From the peer-reviewed medical literature:
"Overall, the risk of any malformation among pregnancies reported
by men was 50% higher in Gulf War Veterans (GWV) compared with
-- Doyle et al. Int. J. Epidemiol..2004; 33: 74-86.
"Infants conceived postwar to male GWVs had significantly higher
prevalence of tricuspid valve insufficicieny (relative risk [RR],
2.7; 95% confidence interval [CI], 1.1-6.6; p = 0.039) and aortic
valve stenosis (RR, 6.0; 95% CI, 1.2-31.0; p = 0.026) compared to
infants conceived postwar to nondeployed veteran males. Among infants
of male GWVs, aortic valve stenosis (RR, 163; 95% CI, 0.09-294; p
= 0.011) and renal agenesis or hypoplasia (RR, 16.3; 95% CI, 0.09-294;
p = 0.011) were significantly higher among infants conceived postwar
-- Birth Defects Res A Clin Mol Teratol. 2003 Apr;67(4):246-60.
Here are some quotes with their full citations from "A review of
the effects of uranium and depleted uranium exposure on reproduction
and fetal development," in Toxicology and Industrial Health, vol.
17, pp. 180-191 (2001), which is temporarily at:
"In rats, there is strong evidence of DU accumulation in tissues including testes, bone, kidneys, and brain." Pellmar, T.C., Fuciarelli, A.F., Ejnik, J.W., Hamilton, M., Hogan, J., Strocko, S., Edmond, C., Mottaz, H.M. and Landauer, M.R. "Distribution of uranium in rats implanted with depleted uranium pellets," Toxicol Sci, vol. 49, pp. 29-39 (1999.)
"Degenerative changes in the testes resulting in aspermia in the testes and epididymis ... apparently a result of uranyl nitrate" Maynard, E.A., Downs, W.L. and Hodge, H.C., "Oral toxicity of uranium compounds," in Voegtlin, C. and Hodge, H.C., editors, Pharmacology and Toxicology of Uranium, Volume 3 (New York: McGraw-Hill, 1953), pp. 1221-1369.
"uranium exposure causes morphologic changes in the rat testes possibly as the result of a uranium-induced autoimmune response.... Average testes weight was significantly (P0.05) decreased in rats exposed to uranyl nitrate.... Titers of testicular autoantibodies were described as fairly high for rats with chronic exposure to uranium and the authors relate this finding to the possibility that the observed testicular changes are an autoimmune response to protein confirmation changes as a result of uranium-protein interactions. Four other references are cited ... as evidence of an interaction between uranium and the testes or thyroid but are not reviewed here." Malenchenko, A.F., Barkun, N.A. and Guseva, G.F., "Effect of uranium on the induction and course of experimental autoimmune orchitis and thyroiditis," J Hyg Epidemiol Microbiol Immunol, vol. 22, pp. 268-277 (1978.)
"The number of female mice impregnated successfully was significantly reduced at all levels of uranium exposure as compared with negative controls." Hu, Q. and Zhu, S., "Induction of chromosomal aberrations in male mouse germ cells by uranyl fluoride containing enriched uranium," Mutat Res, vol. 244, pp. 209-214 (1990.)
Testicular injection with ... uranyl fluoride ... resulted in a dose-dependent increase in chromosomal aberrations (i.e., DNA breakage, SCEs) in spermatogonia, primary spermatocytes, and mature sperm of adult mice." Zhu, S.P., Hu, Q.Y. and Lun, M.Y., "Studies on reproductive toxicity induced by enriched uranium," Zhonghua Yu Fang Yi Xue Za Zhi, vol. 28, pp. 219-222 (1994.)
"existing data indicate that implanted DU translocates to the rodent
testes and ovary, the placenta, and fetus.... DU has been shown to
be genotoxic...." Benson, K.A., Evaluation of the health risks of
embedded depleted uranium (DU) shrapnel on pregnancy and offspring
development, Annual Report No. 19981118065 (October 1998.) That
quote also cites Pellmar, et al., as above, and A. Miller et al.,
from the U.S. Armed Forces Radiobiology Research Institute, whose
work can be found on MEDLINE and here:
For more information please see: