The reconciliation of apparently contradictory data on the inverse dose-rate effect for fission neutron-induced neoplastic transformation in vitro has proven to be a daunting task . A number of explanations have already been published (Barendsen 1985, Burch and Chesters 1986, Rossi and Kellerer 1986, Elkind and Hill 1986a,b, Ward et al . 1987, Sykes and Watts 1989, Brenner and Hall 1990, but to the extent that these have received little subsequent attention and new explanations continue to appear, one must conclude that the older explanations are considered to be inadequate . With an ever-increasing data base available for analysis, Elkind (1991) has developed a new explanation which attempts to encompass numerous features of the available data in a comprehensive, detailed manner . However, the points enumerated below demonstrate that a similar volume of evidence arguing against this latest explanation has been omitted from the analysis, so that the conclusions are not supportable .1 . The letter of Elkind (1991) focused on possible discrepancies of the experiments showing no inverse dose-rate effect, but within the framework of the proposed model fails to consider the major quantitative discrepancy of quoted experiments showing positive results . Specifically, the first reported enhancement of transformation in C3H/l0T} cells had a maximal value of about 20 at 0 . 1 Gy fission neutron dose (Hill et al . 1982), whereas in subsequent work, where the inverse dose-rate effect was observed for fission-spectrum or other energy neutrons in a similar neutron dose range, enhancement was estimated to be around 2 or less than 2 (Miller et al . 1988, Jones et al . 1989, Hill 1989) . These newer results also failed to reproduce the biphasic dose-response curves in the initial reports by Hill et al . (1982Hill et al . ( , 1984aHill et al . ( , 1985 . Further, it is not certain that some of these small enhancements could be proven statistically significant, mostly because this series covered a narrow range of doses (Miller et al . 1988, BalcerKubiczek and Harrison 1989, Jones et al . 1989) .2 . A substantial body of data indicating no inverse dose-rate effect for neutrons was not included in the proposed explanation . To date we have accumulated a solid data base for fission neutrons indicating no dose-rate effect for survival, neoplastic trnsformation and mutation induction down to 0 . 05 Gy Harrison 1991) . Using an in vivo-in vitro mammary cell system, Ullrich (1986) found that low-dose-rate neutron exposures enhance progression to malignancy but not the number of cells initiated by neutrons . TerzaghiHowe (1989) found no difference in transformation frequency of epithelial cells between high-and low-dose-rate neutrons . Similarly, Saran et al. (1990Saran et al. ( , 1991 observed no effect of dose fractionation in C3H/10T cells following irradiation with fission neutrons, 1-MeV monoenergetic neutrons or 6-MeV monoenergetic neutrons . al. 1988, 1989), but omitted our results with density-inhibited cultures reported in the...