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Submitted by Lisa Pedrazzi, Suva
   Commenting on behalf of the organisation
Document Radiological Protection against Radon Exposure
 

 


Suva (Swiss Accident Insurance Fund) is the supervisory authority in those entreprises where there is a need, above all, for protection of employees, in particular industrial and commercial entreprises.

We read with interest your publication project on "Radiological Protection Against Radon Exposure" currently in consultation. Here are our comments:

Lines 384-390: The new philosophy to recommend, for the sake of simplicity, the same value for existing dwellings, mixed-use buildings and workplaces is inadequate, because the time of residence is an important criteria to define the exposure of building users. The worker, whose residence time at work is approximately 2000 hours, would be better protected than the inhabitant of a dwelling (about 7000 hours indoors).

Lines 390-391: The RL dosimetry (10 mSv/y) taking into account the actual conditions of exposure at work is not applicable, without having the exact conversion factor between Bq/m3 and mSv/a (future publication ICRP 64). According to the working environments, the equilibrium factor may be significantly different from 0.4 and the respiration rate may change. As this important information is missing, we prefer a reference level in Bq/m3 that is measurable.

These comments have been written in collaboration with Martha Gruson (Swiss Federal Office of Public Health).

Best reguards

Lisa Pedrazzi

Suva
Occupational Safety and Health Department
PO Box 4358
6002 Lucerne