FDA's "Derived Intervention Levels"

There has obviously been a lot of concern about the isotope levels
in our foods. And a lot of interpretation/mis-interpretation of what
the government agency limits are. So, here's a link to the FDA's
supporting info for their "Derived Intervention Levels" (DIL's) for
the most common isotopes. It's covering the justification for going
from their "Levels of Concern" (LOC) model (established in 1982) to
the DIL model (established in 1998) currently in use. And applies to
food for import as well as domestic.

I'll say up front that I'm not interested in conspiracy theories or
comments about government incompetence. I'm just posting this so
those interested can read the reasoning stated by the FDA.

http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/Chemical...

A high level summary (as best I can understand it) and my observations.
Please read it for yourself and draw your own conclusions:

1. The DIL's were established as a response to possible nuclear incidents.
Not long term acceptable levels.

2. They *state* that the 1982 Levels of Concern were determined based on
early 1960's understanding of radiation. And the new levels are based on
a better understanding.

3. The DIL's are setting limits and associated risk assesments for 1
year of exposure. If food is going to be contaminated beyond that time,
they state that other actions will have to be taken.

The DIL's are ***NOT*** a "lethal single dose" as has been posted in
this forum.

4. The DIL's take age into consideration. There are charts in the link.

5. The DIL's assume 30% of the food is contaminated as opposed to the
100% level assumed in the replaced 1982 guidelines.

6. The DIL's were established to set a 1 in 4400 risk of getting cancer.

They also point out that approx. 20% of us are going to die from non-
radiation related cancer anyway. Which is lower than the 40+% that I've
read elsewhere. And that exposure at the DIL for a year would add 2 cases
to the projected 1990 per 10,000.

If my math is correct, that's a 0.023% risk. So, if every person in
Calif. was exposed at the DIL for one year and lived long enough for
the radiation induced cancer to catch up with them (***which is NOT the case on either front***), it would result in 8400 additional cancers
deaths if you included the entire current Calif. population of 37 million.
No data has shown we are anywhere near the DIL's and a large percentage
of the population will surely die due to some other cause.

7. The I-131 DIL for adults is 4700 pCi/kg (L) or approx. 170 Bq/L

Many have rightfully been alarmed by the milk measurements seen in the
BRAWM data. As high as 1.16 Bq/L (31.32 pCi/L) for the 04/21/2011 best
by date sample. That's approx. 150 times lower than the FDA DIL for milk.
Does this mean it presents a 1 in 660,000 risk (4400 * 150)? And the
latest BRAWM result showed .49 Bq/L (13.23 pCi/L). Or 355 times lower
than the DIL. 1 in 1.56 million risk? Can someone help me out on the
risk assessment here?

8. The Cs-134/Cs-137 DIL for adults is 33,000 pCi/L or 1200 Bq/kg (L)

The highest BRAWM team measurement for Cs-137 was 0.49 Bq/L in milk with
a best by date of 05/02/2011. That's approx. 2450 times lower than the
FDA DIL.