Draft document: Recommendations
Submitted by Wayne Tiefenbach, Radiaiton Safety Unit, Saskatchewan Labour
Commenting as an individual

Have and updating regulations depend on a number of variability's: • Having well accepted standards • Having the means to enforce the standards • Having the political mandate to implement change • Having the political will to change The later three are difficult to assess and predict. But are facilitated by having good scientifically based internationally accepted standards/recommendations. Regulations need well accepted standards The most critical point in having good regulations is to have well accepted standards. The International Commission on Radiological Protection (ICRP) continues to play an important role in developing radiation standards. However, the ICRP must recognize in addition to the need for specifics, there is need for flexibility so that the standards can be applied to a particular jurisdiction. Draft ICRP Recommendations Many aspects of the draft ICRP recommendations are welcome. Since 1990 there have been several new publications and new thoughts that can benefit by being brought together into one document. Also updated tissue weighting factors and expansion of the section on medical exposure of patients are needed. In jurisdictions with few staff, we are often looking at one to three person operations for radiation protection. It is much easier to have one document. For this reason I would support the need to the new recommendation, sooner better than later. With regards to these latest draft recommendations, it was pleasing to see how much attention the ICRP paid to the comments received on the 2005 draft recommendations and the improvements that resulted. Hopefully the same consideration will be given to this set of comments. Comments on Section 6 I have concerns with regards to the term dose constraint and how it is to be used, more clarification and perhaps some examples are needed. We do not need to introduce another set of limits. At this time I will make some specific comments on Section 6, medical radiation exposure. Data from Canada’s National Dose Registry indicate that over the last ten years the dose to occupational workers has been declining. However, the same cannot be said for patient doses. With the increasing complexity of interventional procedures and the increased use of CT - patient doses have increased. Accordingly it is appropriate to see that the ICRP have given significantly more attention to medical exposure to patients in these draft recommendations. Because of the nature of medical exposures, dose limits cannot be applied. However, as the draft emphasizes in Section 6, justification and optimization are very critical to reducing exposure. 6.1 Justification Paragraph 247 and 248 - clarification is needed - who can perform the justification and reviews. These must be performed by qualified persons/groups. Paragraph 250 - appropriately defines and clearly identifies the qualified persons (i.e. radiological practitioner and the referring physician) 6.3 Exposure of pregnant patients First sentence in paragraph 262 should be moved up to be the first sentence in paragraph 260. In all cases “It is important to ascertain whether a female patient is pregnant prior to any radiological procedure”. The principle of optimization supports that it is important to determine if a female patient is pregnant while recognizing that for most diagnostic examinations the procedure may still be justified. 6.4.2 Medico-legal exposures Paragraph 269 - not medically prescribed exposures opens the door to questionable practices and perhaps needs further clarification. Who is qualified to justify an exposure when the primary benefit is not to the patient? More clarification is needed on this potentially difficult area. 6.5 Release of patients after therapy with unsealed radioactive nuclides This section seems to lack a flow and is generally difficult to follow. It requires more clarity on the whole. Paragraph 274 - Is it possible for the Commission to provide explicit guidance on this interpretation? Conclusions Regulations need well accepted standards and it is best if these are on an international level. Over the years the ICRP have become recognized as this standard setting body for radiation. This is an important role of the ICRP and in general the ICRP does a reasonable job. The draft ICRP recommendations are going in the right direction. Additional clarification is needed in some areas. Sooner rather than later is preferred. As the public often views international standards/recommendations as regulations, care must be exercised so that burdens are not unrealistically placed on the resources of a country/province that could get more value used in other sectors. This is a difficult task to be specific but flexible.