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Submitted by CASTANIER Corinne, director, CRIIRAD (commission for independant information and research on radioactivity
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Short presentation of the French NGO CRIIRAD
Commission for Independant Information and Research on radioactivity

CRIIRAD was created in 1986, just after the Chernobyl catastrophe. It’s a non governmental and non profit organisation which purpose is :
- to inform population on all topics relating to natural and artificial radioactivity, its civil and military applications, the risks it involves for environment and public health.
- to improve protection against ionising radiation. In this context, CRIIRAD is used to control the respect of radiological protection regulations, to denounce the infringements and to put pressure on authorities to guarantee a better protection for exposed workers and for the public.
Thanks to its laboratory (*), CRIIRAD realises since 19 years independent studies on the radiological state of environment in France and abroad, informs the population about the results and, if necessary, alerts the authorities and brings proceedings against the plants responsible for radiological contamination.

CRIIRAD's statement on 2005 ICRP recommendation

CRIIRAD considers that « 2005 recommendations» will induce a dangerous decline in protection against the dangers arising from ionising radiation.

CRIIRAD considers that future ICRP's recommendations are going to legalise radioactive foodstuff and to authorise a widespread contamination of the environment.

CRIIRAD carried on a detailed analyse of the ICRP's project and specially of the decision to set up exclusion levels. This study has demonstrated the superficiality and lack of scientific argument of the text. As soon as the English translation will be achieved, this document will be sent to ICRP. It points out false statements, gross mistakes and errors of judgement. For instance, while pretending to conform the statement to the decision of the Codex alimentarius Commission, the ICRP’s text take no account of the import/production factors the Codex Commission used for its calculations. So, in fact, there are huge and hiden differences between both evaluations. The limits that ICRP recommends correspond to a risk level which is all but trivial.

In the name of its 4 000 members and of the 33 562 citizens who has already signed its petition(***), CRIIRAD demands the withdrawal of the project and a minimum of three years moratorium to organise public debates on how to really improve our radiological protection.

Seeing the seriousness of the stakes, this debate must involve all the real stakeholders (customers, farmers, animal breeders, citizens involved in environmental and public health struggles, and so on). The decision must not be confiscated by a non representative minority. Indeed, when duly informed, the great majority of citizens disagrees with the establishment of so high exclusion levels.

(*) The CRIIRAD laboratory is equipped with gamma spectrometry chains, scintillation liquid detector, radiameters, dosimeters, sampling material Its regularly participates in French and international programs of intercomparison and is approved and certified by the French Department of Health. It is specialised in radiological environment study (evaluation of the level of Chernobyl fallout in France, .detailed mapping of residual caesium-137 ground contamination in France and part of Europe involving 3 000 onsite measurements in 1999-2000, numerous studies on French uranium mines, on radiological impact of routine releases of nuclear plants and so on

(**) This comment is only dealing with the part of the draft « 2005 recommendation » relative to humane protection, not to environment one.

(***) Three months ago, CRIIRAD has launched an international petition against ICRP exclusion levels which has collected, to date, 33 562 signatories. It is only the beginning since the petition has not yet been sent to European citizens and NGOs.