Two 2025 executive orders signed by President Trump could threaten the scientific evidence used to create radiation regulations for decades. Specifically, Executive Orders 14300 and 14303 are threatening to upend two foundational principles of Nuclear Regulatory Commission (NRC) radiation exposure guidelines: the linear no-threshold (LNT) model and the as low as reasonably achievable (ALARA) principle.
The NRC is an independent agency—founded by Congress in 1974—that regulates civilian (non-military) exposure to radioactive materials associated with nuclear power plants, nuclear fuel cycle facilities, and other non-military uses such as nuclear medicine. Nuclear medicine is a specialization of radiology that includes radioactive substances used for health research and the diagnosis and treatment of various conditions such as cancer.
Introduction to the LNT model and ALARA principle
The linear no-threshold (LNT) model assumes that the linear relationship between radiation dose and cancer risk observed at high doses can be extrapolated to low doses—where the data are more uncertain—with no threshold below which radiation is considered to have zero effect. Within this model, even the smallest dose of radiation poses a cancer risk. LNT is used to estimate the human health impacts of radiation exposure at low doses, which therefore influences all quantifications of risk and exposure that make up the scientific evidence base for US radiation regulations.
The National Academies of Science, Engineering, and Medicine (NASEM) 2006 Biological Effects of Ionizing Radiation Report (BEIR VII)—published in 2006—also supports the LNT model for low-dose ionizing radiation and cancers based on a comprehensive review of human health data. It is important to understand that at low doses of radiation, there are often not enough robust data to quantify exposure concentration and associated health outcome data.
More recently, in 2018, the National Council on Radiation Protection and Measurements further upheld that LNT was the best method currently available for assessing the dose response for cancer in a regulatory context.
The as low as reasonably achievable (ALARA) principle requires that radiation exposures to workers, the public, and the environment be minimized as much as is reasonably practical. This is done by balancing safety, technology, and economic feasibility, and taking all reasonable measures—even if the exposure levels are already below legal limits. The primary goal of ALARA is to optimize radiation dose calculations and limitations to the best of the federal and state regulatory agencies’ abilities and serves as an ethical framework guiding these agencies’ decisionmaking and duties.
“The fact that there is uncertainty in risks at low doses is not a justification for claiming that the risk there is zero.”
Dr. Jan Beyea, Consulting in Public Interest
Admittedly, there are some concerns with LNT and ALARA. For example, a simple LNT model is a measure of average population risk and doesn’t account for social vulnerability, radiosensitivity of vulnerable populations, or individual variability; most regulatory science calculations do not include these variables either. And because there is no legal definition of “reasonably achievable,” ALARA is often open to interpretation by the very institutions being regulated.
However, the LNT dose-response model and ALARA ethical construct are aimed at reducing radiation exposure doses and have been agreed upon by industry and government for decades as the best methods available for regulating radiation based on current science.
New executive orders and US radiation regulations
In 2025, two new executive orders (EO)—Executive Order 14300 (“Ordering the Reform of the Nuclear Regulatory Commission (NRC)”) and Executive Order 14303 (“Restoring Gold Standard Science”)—have directed a re-evaluation of long-standing radiation risk models and regulatory science frameworks used by federal agencies, particularly the NRC, based on the inaccurate claim that LNT and ALARA are flawed models.
While EO 14303 will affect numerous agencies, many of which make up the complicated web of radiation regulatory policy in the United States, this blog post focuses on the NRC specifically. The NRC sets the guidelines on annual limits of radiation exposure for workers and the general public related to nuclear fuel cycle facilities and medical use. Many other agencies have also adopted these guidelines, affecting nuclear weapons facilities and laboratories as well.
“There is no scientific basis for a change to the status quo, and President Trump’s attempt to force the NRC to abandon LNT is brazen political influence on science akin to the war on climate change mitigation, vaccines, and more.”
Ed Lyman, Union of Concerned Scientists
These two executive orders insist the NRC consider prematurely tossing LNT and ALARA before there is a better scientific alternative for dose-risk calculations. ALARA and LNT affect all regulatory science in the country no matter the exposure.
Furthermore, EO 14303 defines “scientific information” as “factual inputs, data, models, analyses, technical information, or scientific assessments related to such disciplines as the behavioral and social sciences, public health and medical sciences, life and earth sciences, engineering, physical sciences, or probability and statistics. This includes any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms.”
However, the term “factual” appears to be a subjective and ever-moving definition to pin down by the White House. So, it is understandable that scientists are worried the provided definition of science and insertion of politics into how scientific evidence is understood and used will result in scrapping validated research.
I had the immense pleasure of asking Dr. Jan Beyea about LNT and ALARA. He is a nuclear physicist, well-published in environmental epidemiology, and has participated in the debate over human health risks from low-level radiation exposure for more than 40 years. Dr. Beyea submitted written responses to the NRC’s call for public comments on the executive orders. Additionally, my colleague Dr. Ed Lyman, UCS director of nuclear power safety, provided oral comments on the orders at a July 2025 NRC hearing.
Dr. Chanese Forté: How did you get involved in this topic recently and what are your initial thoughts on how annual and accident-related radiation exposure limits are set?
Dr. Jan Beyea: I was notified of a July 2025 release of a report by Idaho National Laboratory (INL) that lays out a blueprint for the administration to change dose limits and philosophy throughout the government, including at DOE and EPA.
The Department of Energy is apparently considering dropping ALARA, which might affect how clean contaminated facilities, such as the Hanford tank farms, must get. It is suggested by the authors that agency heads could speed things up by ordering changes in how ALARA is enforced before rulemaking is complete. There was no discussion of the legality of such a move. Worker standards for DOE employees could also be affected.
The authors claim that it’s fine for workers to get 5,000 mrem per year, citing contrarian scientists for their justification that there would be no harm in that. What about allowing such a dose every year for the duration of a worker’s career? They hedge their bets a bit on this.
They propose monitoring be set up to define such a limit, ignoring the fact that recent data already answers the key question. We now have huge amounts of nuclear worker data
that indicate with confidence that getting 5,000 mrem per year for even two years will increase worker mortality, albeit by a small amount.
Additionally, data on residents of Techa River in Russia confirm the fact that many years of such doses would likely increase the rate of atomic worker deaths.
Dr. Forté: How are LNT and ALARA used, and could this alter their use?
Dr. Beyea: The predictions of the linear model are a reasonable approximation to the actual cancer risks from ionizing radiation measured to date in human and animal populations. As recommended by committees of mainstream experts established by groups—like the National Academies of Sciences, the National and International Committees on Radiation Protection, and others—the linear model is used with some modest adjustments to extrapolate cancer health effects to the low-dose regime where measurements so far are not yet reliable.
The fact that there is uncertainty in risks at low doses is not a justification for claiming that the risk there is zero.
ALARA, when used in cost-benefit analysis with the linear model, is a way to balance cost and safety in a traceable way that reduces subjectivity. If the administration wants to tolerate more risk for policy reasons, they should say so and not try to hide behind claims that contrarian science is true.
Dr. Forté: What are possible adverse outcomes of a swift change from LNT and ALARA in US regulatory science?
Dr. Beyea: I oppose forced adoption of contrarian science that claims there is threshold behavior in response to ionizing radiation. Specifically, I oppose forced adoption of 1) a dose threshold for radiation-induced cancer, 2) a dose-rate threshold for radiation-induced cancer, and 3) a contrarian idea that a little bit of radiation is good for you (hormesis).
“My guess is that the biggest financial effect would come from reducing requirements for nuclear waste cleanup and the disposal of nuclear waste.”
Dr. Jan Beyea, Consulting in Public Interest
Also, [if these changes are made] there will be greater doses and increased cancers possibly after accidents and terrorist attacks, although the public would likely demand a rollback to stricter standards after any such events—as happened after Fukushima. I expect that there would be more nuclear waste [disposed of] from power plants to save money on repair. Over time, doses would increase across society, including in medical facilities. Our society might decide to accept such consequences, but eyes should be open before proceeding.
In Summary
Everyone should be aware that all radiation regulatory policy from the NRC is lined up to be a fundamentally different proposed rule by February 2026 and a final rule around November 2026. EO 14300 directly encourages an alteration to the scientific basis of all NRC radiation policies. The impact on radiation regulations from EO 14303 will be more widespread, affecting multiple agencies including the DOE and EPA, and will likely also affect NRC policymaking.
As written and on the surface, the Trump administration is calling for more transparent, reproducible, and peer-reviewed science informing policy. These executive orders are trying to change the agreed-upon scientific model (LNT) and approach to decisionmaking (ALARA).
Furthermore, these executive orders appear to introduce a new way for the executive branch to create favoritism for the nuclear industry’s bottom line over scientific evidence. The process for finding new standardized models and decisionmaking frameworks often require decades of debate and discussion among human health, regulatory science, and policy experts.
These executive orders represent a continued attack on science by the Trump administration that has been well documented and opposed by UCS. ALARA and LNT have been the cornerstone of regulatory science in the United States for many decades. The effects of these orders are still developing, and yet to be fully observed. It is important for the public, people residing near nuclear facilities, and nuclear materials workers alike to be aware of these changes and their possible effects on radiation regulatory decisionmaking in the near and distant future.