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Submitted by David Smith, UK Ministry of Defence
   Commenting on behalf of the organisation
Document Emergencies
a) This document is very philosophical and approaches the subject from a largely academic and idealistic viewpoint; as a result, it is hard to understand. In reality, emergency planning and response needs to be very straightforward, practical and pragmatic in order to be fit for purpose. As such, the approach used in this CD may benefit from rationalisation of the information into two parts: (i) practical recommendations in a concise form supported by (ii) more detailed theoretical analysis which the user can refer to if required. This would also have the benefit for the user of making at least the practical recommendations in the document more readable and easier to follow.
b) Has the overall approach been tried out in practice by anyone? Is there any evidence that it can it work? (especially the concepts in par. 32 et seq).
c) It would also aid clarity if the content of the document was more closely aligned with the two distinct phases of implementation: emergency planning & emergency response. As currently structured, this is not achieved – the content switches from phase to phase in an inconsistent way. Similarly the terminology is used inconsistently in places.
d) Current emergency planning and response arrangements tend to be structured into three groups: operator (inward-looking at the accident site), local (interface with local population & local emergency services), and national/regional (wider population, resources, food, & other government issues). It would be helpful if this was reflected in the structure of the advice in this publication.
e) How does this publication interface with extant ICRP docs? - e.g. ICRP63, ICRP96. There are some references in the CD implying that recommendations made in earlier publications still stands (e.g. par. 117). It is far from clear what the status of the majority of the extant recommendations is to be; it would aid clarity and remove doubt if the new publication replaced earlier publications in their entirety. If this is not possible, then explicit statements should be made in this new publication as to the nature of the interface with ICRP63 and ICRP96.
f) Whilst the scope of the advice is made clear (“all radiation emergency situations”), is this realistic? Whilst effort should be focussed on reasonably foreseeable events, how far past this point are the Commission recommending that planning should take place? It would be useful to have a statement in the publication which indicated a probability level cut-off (independent of consequence).
g) Whilst ICRP recommendations fundamentally address the management of radiation hazard and risk, nevertheless it would be useful to flag the importance of consideration of conventional H&S risk as a component of the optimisation process.
h) Par 9 - the supposition that “criminal investigation will take priority over radiological considerations” is questionable. It is difficult to see how this situation would arise; it would almost certainly be in conflict with national statute.
i) Par 19 – whilst in agreement that considerations of RBE are appropriate at the planning phase, it may be worth stating that this would not necessarily be appropriate to delay dose assessments during the early stages of emergency response where reliance would instead be placed on electronic personal dosemeters etc which are inevitably calibrated in terms of effective dose and occupational DDREF.
j) par 32 et seq – ..”justification & optimisation to be considered across all exposure pathways”. In terms of emergency response phase, it is difficult to envisage how this could be achieved in practice in what will inevitably be a complex decision-making process with many stakeholders with widely differing interests – protecting emergency responders through to members of the public. Additionally, there may be overlap or interactions between elements of the emergency response which can only be fully characterised during the response phase. Duties and responsibilities will fall into separate areas. How is this simultaneous over-arching assessment across all relevant protective options to be managed and achieved in practice in the early stages of implementing a response? How is the balance between dose to an individual or group of emergency workers to be balanced against dose saving to the wider population? Whilst theoretically possible to calculate, will there be sufficient information available during the early phase of the response to carry out this calculation? – highly unlikely.
k) Whilst there is reference in par. 117 to specific considerations for pregnant/nursing women, there is no guidance about the use of females (other than pregnant/nursing) in emergency response roles. There is a strong need for such guidance.
l) Fig 4 is difficult to read and interpret. The labels Sm_rel & Lg_rel should be meaningful or at least explained in the main body of text. It would be more helpful to express the contributions in absolute rather than relative terms (using typical source terms).