|COMMENTS ON THE ICRP DRAFT “ASSESSING DOSE OF THE REPRESENTATIVE INDIVIDUAL FOR THE PURPOSE OF RADIATION PROTECTION OF THE PUBLIC”. April 5th, 2005 (version 18.1). (42/106/05)
· In both the Abstract and the Executive Summary and in Section 1 (Introduction) of the main text it would be appropriate to indicate what is really “new” in this document, with respect to what has existed to date.
· Evidently, the existing draft on the future new recommendations (ICRP, 2005a) is used as a basis, and there are numerous references to basic aspects of these recommendations, as they currently exist in that draft. Given that certain of these aspects might change in the final version of the recommendations, it is recommended that mentions of them be avoided, or at least that they be mentioned in a less “literal” sense.
· The draft makes massive use of the expression “must”. Each example of such use should be re-checked, either for ratification or for replacement of this term for “should”.
· In several places it is indicated, adequately, that compliance with the basic principles of the ICRP requires that the calculated dose is below the constraint and that it has been optimised. However, in other places it is indicated that it is sufficient for the calculated value to be below the constraint. These second phrases should be revised and either ratified or modified.
· The specific aspects of the “very long term”, as included in ICRP-81, are not sufficiently mentioned (for example, the need not to consider age groups and the impossibility of determining probabilities in the strictest sense). There is only a generic reference in paragraph 9 of the text.
· The idea of “realism” in the doses to be calculated is mentioned only in paragraph 46 of the text, and might possibly need to be reinforced in the document.
TITLE – Perhaps it would be better to use:
“ASSESSING DOSE TO THE REPRESENTATIVE…”
· First paragraph. Eighth line.
… cannot be measured directly (in some cases they cannot be measured at all). Therefore…..”
· Second paragraph. Third line.
Delete “simple”. Deterministic calculations are not always simple.
· Second paragraph. Last line.
Delete “(real)”, since at times the retrospective doses to be calculated are not necessarily real.
· Third paragraph. Third and fourth lines.
Modify for it to state: “… given the inherent uncertainties usually associated with…”
· Fifth paragraph. First line.
Delete “prospective”, because the sentence is equally applicable to the case of retrospective dose calculation.
· Paragraph 52. Sixth line.
Add text for clarification.
“… the Commission believes that by defining the representative individual in the form here described. There should be …”
· Paragraph 54. Fifth line.
· Paragraph 56. Fourth line.
Replace “is” for “could be”
· Paragraph 57. Eighth line.
Correct the last sentence in order to empower the regulatory authority to take decisions, instead of obliging it to do so.
“… The Commission believes that it is up to the regulatory authority to make the final …”
· Paragraph 58. Second line.
“… with the uncertainties usually associated with…”
· Paragraph 514.
This is excessively lengthy and complex.
· Paragraph 516. First and third lines.
Delete “prospective”, because retrospective dose calculations may also be carried out using probabilistic techniques.
· Paragraph 11. Complete.
This equally valid even though the doses not be “expected” but “real”, and when not “for the future” but arising in the past.
2. ASSESSMENT OF DOSE
· Paragraph 44. Fourth line.
Replace “is” with “could be”.
· Paragraph 51. Fifth line.
It would be more appropriate to say: “… The distribution of the calculated dose incorporates …”
3. THE REPRESENTATIVE INDIVIDUAL.
· Paragraph 57. Complete.
– The message that this paragraph wishes to transmit does not appear to be clear.
– In addition, it would be better if the first line were to say:
“… in prospective situations, it will be appropriate to recognise when institutional controls ….”
· Paragraph 61. Complete.
The content is ambiguous, perhaps intentionally, and is., therefore, of little use.
· Paragraph 84. First line.
“… compliance usually exists when …”
· Paragraph 85. First line.
“… defining the dose to the representative individual is …”
· Paragraph 87. First line.
· Paragraph 89. Complete.
This paragraph is very particular and also very complex, the basis ideas being better reflected in point 4.3.
Furthermore, the figure of the stakeholders might already be included explicitly in this paragraph.
4. OTHER CONSIDERATIONS RELEVANT TO THE REPRESENTATIVE INDIVIDUAL.
· Paragraph 97. Complete.
There are doubts as to the advisability of maintaining this in the document.
· Paragraph 100. Ninth line.
“… the operator and regulator are the decision makers (for the purpose of this document), and the stakeholders…)
FINAL NOTE: It has not been possible to analyse either the appendixes or the annexes.