Draft document: Recommendations
Submitted by Keiji ODA, Japan Health Physics Society (JHPS)
Commenting on behalf of the organisation

Comments on ICRP Draft Recommendation Japan Health Physics Society 1. Background and Overall View New recommendation should summarize the current of several yearsf discussions, triggered by the former Chairman Dr. R. Clarke. After 1990 recommendation, a lot of Annals of the ICRP have been published and the previous draft has been open for consultation last year together with five foundation documents. Some responses by ICRP can be found in this new draft; for example, an explicit statement of gJustificationh in paragraph 30, which is one of critical comments that many groups including JHPS working group have insisted on keeping in the new recommendation. From these situations, we consider it may be time to conclude the divergent arguments. Such adjustments to critical comments from many countries and institutions would result in deletion of challenging proposals and ideas and to return back to Publ.60. Some of us pointed out little significance of this revision of the recommendation. However, we understand the necessity of both arrangement of past documents published after 1990 Recommendation and revision of scientific fundamentals according to new findings. These should be substantial purposes of new recommendations. 2. Consistency with Past Publications Since one of main missions of new recommendation is arrangement of the past publications, the draft should state clearly which publications are still alive or already revised. 3. Clarification of the Framework of Radiological Protection - Proposal of Revision of Structure - This draft recommendation and the latest draft report entitled gThe Scope of Radiological Protection Regulationsh will try to classify all the exposure situations as generally as possible. We can understand ICRPfs intention to some extent, but it is not reflected in the structure of eleven chapters in the present draft. So, we recommend to reconstruct the contents, for example, as follows; 1. Introduction 2. Premises 3. Radiological Protection for Controllable Situations 4. Particular Situations 5. Implementation In this example, the recommendation consists of five chapters. The main part of radiological protection is collected in new Chap.3, and its content should also be organized properly to describe the generic system. The biological consideration and the dosimetric quantities are considered to be a kind of premises for the system of radiological protection. The other situations, which are not assigned to controllable, are stated in another chapter 4. We believe proposed constitution is more comprehensive than the present one. 4. Classification of Exposure Situations The draft says in Chap.5 all the possible exposure cases are classified into three types of situations and three categories of exposures. One of nine combinations is apparently unrealistic as is easily understood, and two cases are questionable. We would like to make another proposal of explanation by using a 3x3 matrix. Then, the number of chapter and section should be in appropriate order, as was pointed out. 5. Remark to Inappropriate Applications In Chaps.3 and 4, ICRP criticizes inappropriate use and applications of LNT hypothesis, epidemiological application, collective dose, effective dose, and so on. We agree completely to these descriptions, but they appear in different sections. So, the recommendation should state all the notices in one dependent section in order to exaggerate them. On the contrast, we found a lack of explanation about scientific fundamentals, for example, the reason why the equivalent dose should be used as the protection quantity for tissue reactions. 6. Expression in English We understand the ICRP publications intend to be read in all countries, where the documents are translated into respective languages. So, the main recommendation should be written carefully in simple expression in order not to cause misinterpretations and confusions.