# Filyushkin (1991) — the Soviet "350-mSv concept" and the categorical rejection of "acceptable risk"

*I. V. Filyushkin (Institute of Biophysics, Moscow, USSR), "Concept of a 'Lifetime Dose' of 350 mSv,"
**Health Physics** 61(3):401–404 (Sept 1991) — a *Forum* (perspective) piece. Operator Taildrop 2026-06-13;
READ IN FULL. Local: `papers/lateral/healthphysics1991_filyushkin_350mSv_soviet.pdf` (+`.txt`). Register **H38**.*
**Grade: [CONFIRMED-primary]** for the author's argument; his characterizations of "Soviet hygiene" policy are
his own (an insider's) framing.

## What it is — the radiation "acceptable risk" device seen from the *other* side of the Cold War
After Chernobyl, the **USSR's NCRP recommended a lifetime dose limit (LDL) of 350 mSv** as a late-phase
intervention level for contaminated rural populations (the "350-mSv concept"). This *Forum* piece defends it —
and, in doing so, exposes the deepest fault line under the whole "acceptable risk" lineage: the Soviet system
**officially refused the concept.**

## Verbatim (with `.txt` line locators; OCR lightly cleaned)
- **The ideological rejection — the headline:** the ICRP/IAEA principles "are at present **very difficult to
  apply in the USSR because the concepts of risk and acceptable risk are rejected categorically**." (abstract,
  ll. 22–23)
- The Soviet tradition was **threshold-based "hygiene"**: "The principles underlying hygiene in the USSR have
  [tra]ditional recognition of a **threshold** for inducing all types [of effect]" (ll. 76+); the framework
  rejected "notions about '**socially acceptable risk**'" as alien to "'socialist' hygiene enshrined in law"
  (ll. 82, 102, 114).
- **But the science breaks the threshold:** radiation carcinogenesis "**[has] no threshold**" (ll. 50, 89:
  "Nonstochastic effects have a threshold," but stochastic/cancer effects do not) — so a threshold-only hygiene
  is untenable, and Filyushkin urges adopting ICRP **justification and optimization** (the acceptable-risk
  machinery).
- **The number:** "a lifetime dose of **350 mSv** would impose on an individual an **average annual risk of the
  order of 10⁻⁴ y⁻¹, which is lower than the annual individual risk due to nonradiation causes** prevailing in
  many areas in the USSR." (ll. 18–20; exponent recovered by 400-dpi OCR) — he defends the dose by **comparison
  to background mortality**, i.e. the very acceptable-risk logic the system rejects.
- **The inversion:** "the lifetime dose limit of 350 mSv, as an intervention level, **actually may be far too
  low**, in contrast to the notion that has gained credence among the public that it is **far too high and
  therefore 'inhumane.'**" (ll. 209–211)

## Why it matters — the counter-pole the series needs
- **An ideological mirror of "acceptable risk."** Everything this dossier traces — NCRP/ICRP/FDA building a
  *number* for tolerable nonzero risk (10⁻⁶ food, 10⁻⁴ soldier, 10⁻⁷/yr radiation public) — the Soviet system
  **refused on principle**, insisting (rhetorically) on thresholds and "maximum permissible" limits. That
  rhetorical absolutism is closer to **Delaney's** "no safe dose" pole than to the **calculated-threshold** pole.
- **But the punchline cuts against easy moralizing:** rejecting "acceptable risk" did **not** yield a stricter
  standard. The Soviet intervention level — **350 mSv ≈ 1.7 × 10⁻² lifetime cancer risk (~10⁻⁴/yr)** — is **far
  more permissive** than any Western *public* number: ~1000× the NCRP negligible level (10⁻⁷/yr, H34) and ~10⁴×
  the FDA food-additive 10⁻⁶/lifetime (H25). **Absolutism in rhetoric ≠ stringency in practice.** Without an
  explicit risk framework, the USSR reached for a cruder, looser intervention number — and then justified it by
  the back-door risk-comparison it claimed to reject.
- **For the Delaney/Dingell framing:** Filyushkin is the third data point. Delaney = absolute statute (no safe
  dose, in law). The calculated threshold (Frawley's de minimis, the 10⁻⁶, the HC5) = the round-number device.
  The **Soviet "socialist hygiene"** = absolute *rhetoric* that, under Chernobyl, produced a worse number than
  either — a caution that the honest move may be the explicit, arguable round number, not its denial.