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ICRP: Free the Annals!

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Submitted by Shehnaz Jackson, Jackson Consulting (UK) Limited
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
The proposed ICRP 2005 recommendations are interesting and very well written. But one issue we are not clear about is whether or not the lethality adjusted radiation risk factors have been lowered to take into account improved survival rates from early cancer detection and modern treatments (See Section 4.2.3 and Annex A). This approach could raise some ethical dilemmas, particularly about intergenerational equity. For example by lowering radiation risk factors to take into account better cancer treatability, new regulatory risk standards based on ICRP 2005 might potentially allow future generations of society to receive slightly higher doses of radiation than present standards would permit. Generally speaking of course, it is not usual regulatory practice to lower protection standards or risk factors in response to better clinical treatments becoming available. If possible please could the ICRP Secretariat explain how lethality risk adjustment takes into account cancer treatability? Thank You