|The following are my recommendations regarding International Radiation Recommendations (ICRP 2006):
Delete all discussion and recommendations for exemptions and exemption levels. Delete Section 2.4 and any tables supporting exemptions.
The ICRP had no scientific justification for its proposal to release certain radioactive materials into the environment, including the market place, regular garbage dumps and incinerators. Therefore, the concept of excmptions should be deleted from ICRP 2006. Nuclear waste and radioactive materials should go only to licensed radioactive waste sites in order to protect public health and safety. No radioactive materials should be exempted or excluded from nuclear regulation.
The ICRP should adopt and incorporate the Precautionary Principle in its overall framework. The ICRP should ask how it can prevent radiation exposure to animals, plants, and ecosystems. It should not set legal radiation levels for these non-human species in order to allow those responsible for contamination to escape liability.
In addition, the ICRP should not allow low level doses of radiation when it has no scientific basis for those levels, especially on large populations. New information indicates greater health effects at lower doses. Averaging radiation damage to humans leaves the most vulnerable people unprotected. There should be no levels of radiation exposure that are exempt or excluded from regulatory control. Industries should be responsible for and protect the public from all doses not just those above an ICRP-selected level.