- 36 Comments:

The author flatly states the parenthetical expression as if it
were fact,

There is complete disregard for any and all mechanisms

of cancer induction other than that postulated by the author,

Page 15,line 28 to Page 16, line 3 - "Although these levels are

only about 10 percent of the 24Upo organ burdens of heavy smokers,

the effects may be correspondingly greater because the total population
is exposed, and the inhalation exposures begin at birth."
Comments:
The author here states chat the "effects (due to fallout) may
be correspondingly greater)

(than those due to cigarette smoke).

The sentence implies as fact that health effects resulting from smoking
are due to 2105, organ burdens; this unverified assumption is the
author's.
Page 16, lines 4-12 - "If the health risks attributable to fallout

plutonium exceed 10 percent of the risks of heavy smoking, then
inhalation exposure at
20 times fallout (the surface soil concentration

of plutonium which corresponds to the interim soil standard adopted by
the Colorado Board of Health in 1973) would give rise to organ burdens
more than twice that of heavy smokers. Exposing children to such levels
would be tantamount to their smoking four packs of cigarettes per day,
beginning at birth,

This estimate assumes, as I believe to be the

case, that the inhaled, insoluble radioactive smoke particles give
rise to the serious health effects of smoking."
Comments:

Such numbers relationships have little meaning when the basic
assumptions are so poorly founded (see earlier comments).

The author

is building assumption upon assumption, which he acknowledged in
lines 10-12.
Page 16, lines 13-21 - "For the estimate of organ burdens which

may result from the inhalation of soil contaminants, it is common
practice to attempt to determine the average surface soil concentrations,
the applicable resuspension factors, inhalation exposure patterns,
particle size distributions, lung retention, clearance and translocation
patterns and rates, etc.
The large cumulative errors and uncertainties
in the prediction of theultimate organ burdens from long-term exposure
to contaminated surface soils and urban dusts by such a long sequence

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