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Submitted by David Webbe-Wood, Emergency Planning, Radiation and Incidents Division, Food Standards Agency, UK
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
 
Emergency Planning, Radiation and Incidents Division of the UK Food Standards Agency Response to International Commission on Radiological Protection 2005 Draft Recommendations



The Emergency Planning, Radiation and Incidents Division of the Food Standards Agency welcomes the opportunity to comment on the draft ICRP 2005 Recommendations. We have a number of comments on the draft Recommendations. These are summarised below:

General
1. As currently drafted the Recommendations lack clarity as to what parts of previous recommendations are still applicable. It would be helpful if the 2005 Recommendations restated the principles of the Commission, gave a clear summary of the status of previous guidance, and were written as a standalone document.

Specific

2. Section 6.3.1
We welcome the Commissions retention of the critical group concept. We understand that that the report on the Representative Individual for the Purpose of Radiation Protection of the Public is intended to give more detailed guidance on the application of the concept but is not yet available. We look forward to the opportunity to comment on a draft of this report in due course.

3. Section 6.3.1
We suggest that guidance on whether the homogeneity criteria for a critical group should be applied to the habits of the group or to the doses received by members of the group would be a helpful addition. Experience has shown that it is possible for members of the public with different habits to receive comparable exposure from the same source.

4. Section 6.1
Radioactivity is only one of the substances in food that can cause a detriment to consumers. The comparison of the risks that different substances in food represent, if they are present at the relevant limit, is facilitated if the limits are derived based on risk. Derivation of the limits and constraints for the exposure to radiation by comparison with background levels makes this comparison between substances more difficult. Comparisons between different substances will be less transparent to members of the public who have little knowledge of risks from exposure to background radiation.

5. Section 6.2
It would be helpful to clarify whether the dose for exposure of members of the public, which is compared to the constraint for a source, includes exposure caused by past practices connected to the source.

6. Paragraph 54
As currently drafted the restrictions on the use of effective dose i.e. that it should not be used for retrospective assessment of stochastic risks is, in our view, too prescriptive. In practice, interpretation of the results of surveillance programmes to demonstrate compliance with dose constraints requires the use of effective dose.

7. Chapter 8
It would be helpful to clarify in the Recommendations that national and international authorities could set exemption levels that are higher than the proposed exclusion levels. It would also be helpful if the distinction between the concepts of exclusion and exemption was explained in the Recommendations.

8. Chapter 8
In some cases the proposed exclusion levels are higher than the levels proposed by Codex Alimentarius for limiting radionuclide concentrations in foods in international trade. Similarly in some cases the proposed exclusion levels are higher than the exemption levels specified by the IAEA in Safety Guide RS-G-1.7. The interrelationship of these levels needs to be resolved and the methods used to derive the recommended levels should be described.