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Submitted by Dave Bench, Director of Science, Health and Safety Executive, UK
   Commenting on behalf of the organisation
Document Radiological Protection against Radon Exposure
 


The Health and Safety Executive is an independent regulator for work-related health, safety and illness in the UK. It submits the following comments on the draft ICRP report "Radiological Protection against Radon Exposure" in relation to radon exposure in the workplace.,


 


1.  The draft report makes a number of recommendations in relation to controlling exposure in workplaces which do not reflect current thinking in the area and in particular those being adopted in the IAEA and current draft Euratom Basic Safety Standards  (BSS) for radiation protection. 


 


2.  Of particular concern is that ICRP considers 'exposure in workplaces may be adventitious (cannot reasonably be regarded as being the responsibility of the operating management) and not occupational’. ' In the UK we have considered in our Health and Safety legislation since 1985 that radon in workplaces is the responsibility of the operating management (the employer) and that these are the best people to control the exposure of their workers. Where levels exist above the reference level, it is considered as a planned exposure situation and in such cases employers usually manage to install mitigation systems to reduce levels to below the reference level. Where this cannot be achieved, optimisation is usually tackled through limitation of exposure times. If doses remain sufficiently high, areas may have to be designated as Controlled, workers as Category A (Euratom BSS), and the dose limit applied. This system applies to all workplaces, including shops, offices, schools, factories, mines and NORM workplaces. In practice there are very few Controlled areas or Category A workers (<100) in the UK and the system is relatively simple and works effectively.


 


3.  We are not convinced that there is a need for an additional reference level for buildings with public access. Given the protection afforded to workers and the lower occupancy times of the public in most of these buildings we think that the public are adequately protected by the workplace reference level. The additional category adds further complexity and potential for confusion as well as making it more difficult to regulate.  


 


4.  We are aware that in certain buildings there are prolonged domestic type exposures to non-workers and workers which do need to be considered. Non-worker examples are residential schools, prisons, and nursing/care homes. Worker examples are hospitals and other workplaces where workers are provided with accommodation within the workplace. In these circumstances exposure is essentially domestic and the domestic reference level should be used.


 


5.  We also comment that it seems premature to try and ascribe a system of protection, particularly for workplaces, when ICRP have still to publish the dose coefficients for radon exposures in these situations. Our understanding is that whilst the average dose per unit exposure for radon in likely to increase by a factor of two, the increase for the vast majority of workplaces may be by a factor of at least four. If correct, this calls into question the whole system for workplaces described in this report, including the proposed activity concentrations and 10 mSv dose reference levels. We therefore feel unable to comment further on the report without being able to envisage how it may be implemented in practice.