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Submitted by G. Underdown, Director General Nuclear Safety (DGNS)
   Commenting on behalf of the organisation
Document Recommendations
The Director General Nuclear Safety (DGNS) is the ionizing radiation safety authority in the Canadian Forces and the Department of National Defence. DGNS was established to regulate the military, industrial, and defence research uses of ionizing radiation. With respect to military operations and the use of military equipment, the Canadian Forces and Department of National Defence are excluded from the application of the national legislation subject to a condition that the requirements for health, safety, security and protection of the environment are consistent, to the extent practicable, with the requirements of the national legislation taking into account operational requirements

It is suggested that an addition to section 2.3 - Scope of Recommendations be included to reflect the nature of military operations and combat.

In practice the Commission's system of radiological protection are not applicable to any activities of armed forces during an armed conflict, as those terms are understood under international humanitarian law.

However, it is recommended that these Recommendations should be considered during any military operation undertaken by military forces of a State in the exercise of their official duties, inasmuch as they are governed by other rules of international and national laws.

“Military forces of a State” means the armed forces of a State which are organized, trained and equipped under its internal law for the primary purpose of national defence or security and persons acting in support of those armed forces who are under their formal command, control and responsibility.

“Military operation” includes any training, exercise, trial, manoeuvre, deployment and related activities carried out by the forces of a state, and any activity of these forces that directly or indirectly supports any such operations.