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Submitted by Mr Trevor Moseley, Association of University Radiation Protection Officers
   Commenting on behalf of the organisation
Document Reference animals and plants
 
A member of our Scientific and Technical Committee (Dr Brian Heaton) was tasked with reviewing this document on behalf of AURPO. hHis comments are as follows. -

Our use of radioactive materials is relatively low level and all discharges to the environment are subject to control with humans having to be considered as they can be directly exposed or are at the head of a food chain.
We consider the draft to be well written and an excellent collation of the existing knowledge on the effects on non human species of ionising radiations.

1. We would support the principle that where discharges may result in the exposure of animals and plants but not humans then consideration must be given to them.
2. We would agree that establishing a set of reference animals and plants is a suitable way of assessing the potential impact of exposures to ionising radiation of non human species.
3. The detail in the document whilst very interesting and well written goes beyond the “concept and use” title and consideration should be given to publishing it in a separate report. The aim of this publication was to act as a high level guidance document not give the supporting information it does give.
4. Whilst we support the principle we feel more clear guidance should be given to the instances to which it would apply. Our worry would be that eventually this could be translated into a requirement for all users to carry out environmental assessments which would result in small users like ourselves being involved in large amounts of work for no good reason. It appears clear to us, from the data in the draft, than when one considers the doses and doserates required to produce any effects in the reference animals and plants any discharges where humans are exposed would, as has been assumed in the past, limit doses to non human species to an acceptable level.
5. The choice of animals and plants for reference although rational and at first sight quite reasonable was not always supported by the amount of data available on them. Other species would appear to have been more extensively worked on. It would seem reasonable to include this in the choice decision as much to reduce the amount of work that would have to be carried out on the species chosen and limit the expense and potential suffering.

Mr Trevor Moseley
Chairman of Scientific and Technical Committee of
Association of University Radiation Protection Officers