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Submitted by Maurice Phillips, United Kingdom Ministry of Defence
   Commenting on behalf of the organisation
Document Foundation docs Optimisation; Dose to Individual
The United Kingdom Ministry of Defence (MOD) has reviewed the ICRP proposal in the ICRP foundation document on assessing dose to the representative individual and has the following comments to make:

General Comments

The document provides greater guidance on the Representative Individual for assessing doses than was available previously for Critical Groups. With this in mind the report is welcomed and will hopefully lead to better habit data than is currently available.

We suggest that it would be useful to introduce the concept of source-pathway-receptor into the document and an explanation that by breaking this link an assessment would be unnecessary. This would then align human exposure with the approach used for non-human species.

Specific Comments

Page x paragraph S18. The suggestion that the operator and the regulator must make a decision as to “....whether changes in habits of the individual exposed might be proposed and supported....” in circumstances where the dose to specific individuals exceeds the dose constraint is considered somewhat extreme. Although it may be possible to fence off areas of a site to prevent public access it is unlikely that the operator and regulator would be able to enforce the prohibition of the eating of certain foodstuffs on the basis of exceeding a dose constraint. This approach may be unacceptable on the grounds that it could infringe civil liberties.

Page 5 section 1.3. It is unclear why the ICRP Committee has moved from the critical group to the representative individual. A statement explaining the reasoning for this should be included in section 1.3, fundamental principles and concepts. It would then provide the link between past historical recommendations involving critical group and the representative individual representing the future direction.

Page 5 Paragraph 19. The wording of the second sentence requires reviewing. The dose constraint could involve exposure received from medical or occupational sources as liquid or atmospheric discharges from a medical, nuclear or other such facility could contribute to the public dose.

Page 15 Section 3.4 While the simplification of using 3 age specific dose coefficients as opposed to 6 is accepted we are concerned that in some instances a more cautious approach should be made, for example in potential radioiodine exposures to different sub group ages of children.

Page 19 Table 3 - In the UK the regulator provides guidance to operators but does not prescribe the method for calculating doses to the representative individual. This can be viewed as being prescriptive and not in accordance with the current philosophy of regulation within the UK . Whilst recognising that cultures in other countries are different to the UK we would ask that the wording of this Table and elsewhere in the document provides the flexibility to enable the UK arrangements to continue. It is suggested that this may be achieved by using the wording “and where appropriate the regulator”. There may also be a need to make changes to the body of the text.