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Submitted by Michael Boyd, Interagency Steering Committee on Radiation Standards
   Commenting on behalf of the organisation
Document Foundation docs Optimisation; Dose to Individual
Comments on the ICRP Task Group Report: Assessing Dose of the Representative Individual for the Purpose of Radiation Protection of the Public

Prepared by the Federal Guidance Subcommittee of the US Interagency Steering Committee on Radiation Standards (ISCORS)

The following comments represent a consensus of views from participating members of the subcommittee representing the Nuclear Regulatory Commission (NRC), the Environmental Protection Agency (EPA), the Department of Energy (DOE) and the Agency for Toxic Substances and Disease Registry (ATSDR) of the Department of Health and Human Services.

We are pleased to participate in the open process of consultation offered by the International Commission on Radiological Protection (ICRP).

The report has some inconsistencies, particularly in the way the representative individual is defined throughout the document. When the 95th percentile is referred to, it needs to be more obvious whether this is referring to the general population or the critical group.

The report should acknowledge that for some chronic exposure situations, the use of a single age- and gender-averaged representative individual may be sufficient. In general, we support the use of fewer age groups or one age/gender averaged representative for prospective dose evaluations.

The statement on page viii, paragraph S10 – “If the value of dose to the representative individual meets the dose constraint established by the Commission, then the Commission’s goal is achieved.” – could lead to some confusion with the report on optimization. It should be made clear that optimization below a constraint is still expected.

It is not clear that all relevant attributes of uncertainty are covered in the document. For example, sample measurement uncertainty can be an important consideration in an overall uncertainty assessment.

We encourage the ICRP to work towards improving and completing the Foundation Documents before taking up the revisions to RP 05. The timetable for this process should not be rushed.

Thank you for the opportunity to offer these comments.