Register for Updates | Search | Contacts | Site Map | Member Login

ICRP: Free the Annals!

View Comment

Submitted by Brian Ahier, OECD Nuclear Energy Agency - CRPPH/EGIR
   Commenting on behalf of the organisation
Document Emergencies
 
Note: Comments noted in the rest of the text should be reflected in a revised executive summary.

Introduction
Paragraph 1: General comments on two statements:
• [“These new recommendations are intended to complement, rather than replace, the Commission’s previous advice. However, the advice contained in these new recommendations has important implications for emergency preparedness and response”.] : ICRP has stated in Publication 103 that the new recommendations do not introduce major change. This statement implies otherwise. Does this mean emergency arrangements need to be changed? If so, it should be explicitly stated
• [“This document discusses the application of the new advice, and explains how the previous advice fits into the revised overall system of protection”.] : This objective needs to be addressed consistently throughout document for each new element introduced. It is felt that in many cases the explanations are missing.

Scope of this advice
Paragraph 2:
• Text discussing workers has been deleted as in does not bring useful clarification
(2) This advice relates to preparedness for, and response to, all radiation emergency situations. The Commission defines radiation emergency exposure situations as: ‘situations that may occur during the operation of a planned situation, or from a malicious act, or from any other unexpected situation and require urgent action in order to avoid or reduce undesirable consequences’. The scope of this advice is the process of preparedness for, and response to, emergency exposure situations. It covers the protection of all those at risk of exposure, whether they are directly involved in mitigating actions (here termed emergency ‘workers’, regardless of whether or not they are routinely exposed to radiation as a result of their normal employment), or are simply in need of protection (here termed ‘the public’).

Paragraph 3:
• Text has been added to highlight the main difference between emergency and existing situations.
(3) An emergency exposure situation has some common features with, but is distinct from, an existing exposure situation, primarily in the need to take urgent protective action. The Commission defines an existing exposure situation as 'exposure situations that already exist when a decision on control has to be taken, including prolonged exposure situations after emergencies'. Therefore an emergency exposure situation that includes the release of significant quantities of longer-lived radionuclides, may evolve, in time, into an existing exposure situation. This evolution is discussed in more detail in Sections 1.3.1 and 4. The management of emergency exposure situations and of existing exposure situations have distinct characteristics. Therefore the Commission's detailed advice for these situations is published in two complementary documents.

Objectives of protection in emergency exposure situations
Paragraph 4:
• Use consistent terminology throughout: in this case, emergency exposure situation
• Reducing dose is tangible. Reducing health consequences is less certain. Change “health consequences resulting from exposures to radiation” to “radiation dose”
• IAEA, 2002: The document should quote an ICRP document as a fundamental source, rather than IAEA. If kept, than the bullets should be shown as quotes.
• The use of “prevent” in bullet 5 is problematic. Can reduce – but not prevent - stochastic effects. Since this is a reference from IAEA, need to consider how to incorporate this change. Perhaps delete the bullet altogether.
(4) In the event of an emergency exposure situation, the first concern is the prevention or reduction of radiation dose. However, …
# 5. to reduce, to the extent practicable, the occurrence of stochastic health effects in the population; …

Paragraph 6:
• The listed lessons are unbalanced, and focus only on social aspects. Other important lessons exist, including the need for a timely response, international coordination, etc. Further, it is not clear what the point of this section is. How does it fit in? Suggest to delete paragraph (6). If not, then add in the other important lessons.
• DS-44 is a draft, and should not be referenced.
• Delete reference to decision-makers as non-experts. Decision-makers are experts.
• Text has been written with NPP emergencies in mind – text should be generic in terms of applicable scenarios
• Bullet point 3 modified to make it more neutral/factual.
(6) The results of an analysis of the lessons from response to the Chernobyl, Goiânia and other emergencies over the past years [IAEA TECDOC-1432, GS-G-2.1] conclude that while the nature and extent of past emergencies are dissimilar, the lessons concerning emergency response are very similar, e.g.:
• Non-experts (the public) and other decision-makers in different fields implement protective and other actions.
• The public and decision makers want to know that they and their loved ones are safe, so a rationale based only on cost benefit and averted dose is not helpful in addressing this concern.
• Criteria consistent with established radiation protection principles cannot be effectively developed solely during or after an emergency because communication of those principles can become more difficult.
• Non-radiological (e.g. economic, social and psychological) consequences may become worse than the radiological consequences due to a lack of pre-established guidance that is understandable to the public and officials.

Paragraph 7:
• Text has been modified to stress importance of timeliness of all actions and to cover the range of necessary actions appropriate to the situation being considered, without making unnecessary distinction between urgent/less urgent actions
(7) One of the most important lessons therefore is the need to have prepared an agreed framework within which decisions on the optimum response will be made. Since protective actions must be taken in a timely manner, it is necessary to determine in advance a set of internally consistent criteria for taking such protective measures, and, based on these criteria, to derive appropriate triggers for initiating the actions appropriate to the emergency situation. For these, the procedure by which such criteria will be established during the emergency should be agreed in advance, in order to facilitate their acceptance by the public during the emergency. Scientifically based recommendations for implementing protective and other measures need to be accompanied by an explanation that enables the decision maker to understand and reasonably consider them, and also to be able to explain them to the public…

Emergency exposure situations and existing exposure situations
Paragraph 8:
• ICRP should revisit whether “stable and acceptable” is what is meant by “normality”.
• The concept of phases as discussed here and in 1.3.2, particularly as being distinct, needs to be rethought as this is likely not the case. The text has been modified to better reflect this approach
• The text should refer to rates of actual exposure, not potential exposure
(8) Emergency exposure situations are characterised by the need to manage a changing situation back to one of ‘normality’, or at least one which is both stable and acceptable, even if still considered as an “existing exposure situation”. Emergency exposure situations may be characterised by one or more of the following features: significant uncertainty concerning current and future exposures, rapidly changing rates of actual exposure, potentially very high exposures (i.e. those with the potential to cause severe deterministic health effects), loss of control of the source of the exposure or release. Any or all of these features may continue to dominate how the response is managed for an extended period of time (i.e. months or even years), although, for some types of accidents, the emergency exposure situation may be very short (days or even hours).

Paragraph 9:
• Emergency situations always end. However, the authorities may decide to continue to manage an ongoing situation as an existing situation as defined in Pub 103. The proposed changes better reflect this evolving timeline, and options for management.
• Deleted text (“ especially if the initiating event or radionuclides released are short-lived, or any environmental contamination is limited in extent”) is unnecessary detail
• EGIR disagreed with the last statement, as practical experience shows that both consequence management and criminal investigation need to be carried out in an appropriate manner, and arrangements should reflect this need.
(9) At some point in time, the emergency situation will end. Thus an emergency exposure situation will, in time, cease to be managed as an emergency, but the situation may be further managed according to the Commission's advice on existing exposure situations. However, not all emergency exposure situations will evolve into an existing exposure situation. Similarly, not all existing exposure situations will be preceded by an emergency exposure situation. However, for a major accident at a nuclear site or a serious malicious contamination incident, it would be expected that management of the response would move from that required for an emergency exposure situation to that required for an existing exposure situation at some appropriate time following the event. For malicious events, emergency arrangements should be such that both consequence management and criminal investigations can be carried out in an appropriate manner.

Paragraph 10:
• Practical experience shows that both aspects need to be carried out in an appropriate manner, and arrangements should reflect this need.
• Text has been modified to better reflect the characteristics of an existing situation
• Deleted text provides unnecessary detail [“Radionuclides of importance during this later management regime will be long-lived e.g.: iodine-129, caesium-137, strontium-90 and transuranic radionuclides [ICRP 82]”]
• Deleted text is confusing [“However, the later part of the emergency exposure situation will be more similar to the early part of the existing exposure situation”]
• Other information from paragraphs 8-10 can be usefully included in the diagram
(10) Existing exposure situations are characterised by the need for a population to continue living in an area with known or assessable levels of exposure. Additionally, detailed monitoring data is available, exposures can be more accurately assessed, rates of exposure are not changing rapidly with time, exposures are well below the thresholds for deterministic health effects, and the initiating source of exposure or release is under control (i.e. there is no further risk of an additional contribution to the levels of exposure). Whilst there will not be a sharp transition between these two situations, the characteristics at early times in an emergency exposure situation will be distinct from those later on in an existing exposure situation. This is illustrated in Figure 1 below. It is therefore a management decision that determines when the transition from one type of response to the other should take place. Management of the long term rehabilitation of contaminated areas is discussed in the complementary ICRP publication [ref TG report on rehabilitation].
(Fig 1: Evolution of an emergency exposure situation with time and the transition to the existing exposure situation)

Phases of an emergency, for the purposes of these recommendations
Paragraph 11:
• Need a clearer and more consistent description in these paragraphs. Planning is not a phase, as it will happen as part of preparedness and in response.
• For some states, phases may also be tied to legal issues, not just technical
• Last sentence: The dynamic nature of the situation should be noted – i.e, different areas may be in different phases. Paras 70-76 should be brought here.
• See comment in paragraph 8.
(11) In the context of emergency preparedness and response for emergency exposure situations, the Commission defines the following phases of an emergency. The first phase, and in many ways, the most important phase, is the pre-emergency phase. This is the phase during which the planning of an appropriate response is undertaken. An effective response always requires appropriate planning. Therefore, the greater part (i.e. Section 2) of this document deals with the application of the Commission’s advice for the planning process. It should be noted, however, that for some emergency exposure situations affecting large areas, management of the response may need to deal simultaneously with different phases over different geographical areas.

Paragraph 12:
• Discussion of early phase applies to NPPs, not necessarily to malicious acts, for which there may be no early phase. Also, different scenarios may have phases of different lengths.
• The may be exposure without a “release” (eg, an orphan source)
• Triggers: This terminology needs to be better defined.
• Text changes proposed to make the text clearer
• General comment on format: this and the next 4 paragraphs should put the phase at the beginning of the paragraph ion bold to improve presentation
(12) The early phase of an emergency exposure situation starts once it becomes apparent that an exposure or release is happening or is very likely to happen. Depending upon the emergency, it may be possible to distinguish within the early phase a warning period and an exposure period. The warning period is when no exposure or release has actually started, but the strong likelihood of one occurring has been recognised. The exposure period is when exposures are actually occurring, and the initiating source of the release/exposure is no longer under control. It is during this phase that many actions need to be taken promptly and so emergency plans need to contain straightforward ‘triggers’ for robust responses, requiring the minimum of discussion or delay. The early phase will normally last a few days to a few weeks, depending on the nature of the event.

Paragraph 13:
• The circumstances leading to the exposure, but not necessarily the exposure, are under control. Text has been changed to reflect this.
• It is noted that predefined criteria may still be useful in this phase
• Implications of decisions on future options should be considered
(13) The intermediate phase begins when the circumstances leading to the exposure have been brought under control, but there are still decisions to be taken on relatively short term protective measures, for which predefined criteria may be useful. During this phase decisions will be required on the termination of early phase protective measures. Such decisions should consider implications on future options. The implications and need for longer term protective measures will need to be assessed, planned in detail and initiated if required. The intermediate phase may last from days to months, depending on the circumstances of the emergency exposure situation.

Paragraph 14:
• For consistency with the preceding paragraphs, the term “late phase” should be at front of paragraph
• “Timescales” can have different connotations eg, as used in waste management. Alternate terminology suggested.
• It is not clear what “invasive” means. This has been deleted.
(14) For large-scale emergencies involving long-lived radionuclides, the level of contamination may require protective measures to be implemented for a number of years, for example, long term food restrictions, decontamination measures and relocation. If the purpose of these measures is to continue to reduce potential exposure rates to a level more acceptable for normal living, the management of the response continues to be that appropriate to an emergency exposure situation. This period of management is termed the late phase. The boundary between the intermediate and late phases is unlikely to be defined in terms of changes in the exposure pathways or decision timescales. Rather, the late phase will be recognised by the need to continue to manage the emergency exposure situation for a longer period of time.

Paragraph 15:
• This issue of simultaneous management of response in different phases should be dealt with earlier under a modified discussion on phases, therefore propose to delete this sentence here.
(15) The transition from managing the situation an as emergency exposure situation to an existing exposure situation, if it is required, may take place at some point during the intermediate or late phases. It is not expected that this transition would occur during the early phase, although it might follow it immediately, without any intermediate phase, for small events. The appropriate time for making this transition is a decision that should be taken by the responsible authorities, taking account of the characteristics of the actual situation, as discussed in Section 1.3.1. Thus, a change to management as an existing exposure situation might not occur for all locations at the same time. In planning for emergency response, it is therefore important to consider issues relevant to each of the phases, since it will not be known in advance exactly when this transition might occur. The application of the Commission’s advice to an emergency exposure situation is discussed in Sections 2 and 3 of this document. Aspects of the transition to an existing exposure situation are discussed in Section 4.

Types of emergency exposure situations
Paragraph 16:
• Consistent terminology should be used throughout the document, ie emergency (not accident or incident). The generic term should be emergency, unless the context of the paragraph implies otherwise (eg, accident, malicious event)
• Text addressing emergencies from non-regulated activities should be a separate paragraph
(16) Emergency exposure situations can cover many different types of initiating events and initial locations. Emergencies can occur, for example, at nuclear sites, at hospitals using radioactive materials, at industrial sites that use or make radioactive sources or process materials containing naturally occurring radioactive isotopes (NORM industries), or during the transport of radioactive materials, whether for commercial, energy generation or weapons’ use. For these situations, because the use of the radioactive material is regulated, and therefore planned or known about in advance, it is possible to develop emergency response plans tailored for the specific characteristics of the potential accidents. The level of detail required for such plans will be decided by the relevant national authorities, with response planning for the more likely accidents developed in more detail than those judged more unlikely.
(16+) Exposures could also be caused maliciously, e.g. through the dispersal of radioactive material in a public place. For these, it is not possible to plan in detail, because the exact mechanism and location of exposure cannot be known in advance. However, this does not preclude the preparation of generic response plans: the inclusion of flexibility and resilience is of paramount importance to enable these generic plans to be adapted to the actual situation that arises. Further guidance on response planning for such events can be found in Publication 96 [ICRP 2005a]. Emergencies may also occur at non-regulated sites, such as appearance of orphan sources at scrap metal facilities. Finally, there are accidents that occur beyond the jurisdiction of the affected regulatory authorities, for example, accidents in other countries, satellite crashes. For these, again, it is not be possible to plan in detail, but outline response plans should still be developed.

Paragraph 17: Propose to delete paragraph as in its current wording, it does add value, nor make a link to the following sections.

Dose quantities
Paragraph 20:
• [“In general, where effective doses less than 100 mSv are calculated,…”]: The integration time should be included: several days, one year?
• [“Where effective doses in excess of 100 mSv are calculated, consideration should be given to whether there is a need to evaluate equivalent doses or absorbed doses in addition to the effective dose, as the Commission advises that assumption of linearity, fundamental in the derivation of effective dose, becomes progressively less reasonable, as doses exceed 100 mSv.”] : This sentence is confusing. It should be edited to make the concept clearer.

Paragraph 21:
• [“When calculating effective dose it should be remembered that its value is not related to an individual but to a reference person, averaged over both sexes and all ages.”]: ICRP should add a caveat that states that effective dose applies to a reference individual, and if specific protection is to be developed for specific age / sex groups (ie, children, pregnant women), then effective dose may not be the appropriate quantity.

Paragraph 22:
• Remove reference to DS-44 as it is a draft.
• It should be noted that triggers relating to dose should be first estimated before exposure occurs if possible, using models, then using measured parameters once the release has occurred
• For Figure 2: If this figure is from DS-44, perhaps it should be removed. If retained, then provide some guidance on when equivalent dose vs RBE weighted dose is used (bottom of diagram). No guidance on which calculation path should be used.

Dose concepts
Section 1.3.5
• Consider reducing this section and including a diagram showing the relationship between the dose concepts. Consider using the text from Publication 103, which provides a clearer explanation.

Paragraph 23:
• Text changes are proposed to improve presentation
(23) In addition to the use of these dosimetric quantities, it is necessary to define a set of conceptual doses, for use in the justification and optimisation of emergency plans and decisions. These doses include:
• ‘residual dose’: doses that are expected to be received following implementation of planned protective measures;
• ‘projected dose’: doses that are expected to be received in the absence of planned protective measures;
• ‘averted dose’: doses that all or part of the planned response are expected to avert.
These doses and their respective roles in emergency planning are discussed below.

Residual dose
Paragraph 24:
• Text added to improve clarity and explanation of concepts
(24) The total residual dose received through all exposure pathways is the total effective dose from the emergency exposure situation that is expected to remain after the implementation of the full strategy of protective measures. It can refer to an estimated dose during planning, or an actual received dose. The total residual dose should be calculated as realistically as possible. Strictly, since emergency plans are developed to protect population groups, not specific individuals, the residual dose is derived as the dose to each of a set of ‘representative person. Guidance on characterising the ‘representative person is provided in Publication 101 [ICRP 2006]. In principle, those populations potentially exposed during the emergency should be divided into groups which are relatively homogeneous with respect to exposure and risk from that exposure, and representative persons characterised for each group. This is discussed further in Section 2.1.4.

Paragraph 25:
• The distinction between planning and response is important. Text changes are proposed to highlight this.
(25) During planning, the calculation of total residual dose is important for emergency planning, because it is necessary to explore whether or not this dose is both radiologically and socially acceptable, given the circumstances. In particular, it is fundamental to the Commission’s approach to emergency planning, and supports the achievement of goals 3, 5, 6, 7 and 8, as listed in Section 1.2. The total residual dose may be calculated over the period of time that a protective measure is active (in order to determine the dose averted by the action for comparison with appropriate intervention levels, see Section 2.1.5), or it may be calculated, taking account of the effectiveness of planned protective measures, for a year (or the duration of exposures, whichever is shorter) for comparison with the appropriate reference level (see next paragraph). During the actual response, where the implementation of additional protective measures is being considered during the actual response, the residual dose calculated for comparison with the reference level should include doses already received and committed, as well as those expected to be received in the future (see Section 3).

Paragraph 26:
• This section deals with dose concepts. Therefore, the discussion in paragraphs 26 and 27 on constrained optimisation and reference levels should appear later in the section dealing with optimisation (1.4.2). A more logical order of concepts needs to be followed for this and subsequent paragraphs.
• The issue of harmonisation of values in different countries should also be addressed
• Before giving the ICRP recommended range of reference levels, it should be noted that the choice of a reference levels depends on the scenario, etc
• Different values of references appear in a mixed order. First high values, then lower.
• [Such exceptions include circumstances of extreme benefit (e.g. life saving)…]: This is a different situation. The concept of a reference level for life saving actions is not appropriate, as it is more an issue of dose limitation for individual actions.
(26) The Commission has recommended that a process of constrained optimisation be used to determine what total residual dose(s) will be acceptable in particular circumstances. The level of dose that acts as a constraint on the optimisation process is termed a ‘reference level’. The choice of reference levels depends on the scenario being considered, the level of effort that can be reasonably expected to reduce doses, etc. In the context of developing response plans for emergency exposure situations, the Commission recommends that national authorities set reference levels between, typically, 20 mSv and 100 mSv effective dose (acute or annual). Reference levels that exceed 100 mSv will only rarely be acceptable… (etc)

Paragraph 27:
• Paragraphs 26 and 27 need to be edited collectively to improve clarity
• This is a section on dose concepts. This issue of stakeholders needs to be addressed appropriately elsewhere in the document. However, to note: Stakeholders include more than just the public. See also 2.4.3
• [“It is therefore important, in the development of emergency plans, to engage the potentially affected stakeholders and, to the extent possible, explore with them what overall outcome, including residual dose, would be acceptable.”]: It is noted that this endpoint may not be feasible – could lead to an endless process. Delete.
(27) The process of constrained optimisation should result in a level of the total residual dose, below the appropriate reference level, that is both radiologically and socially acceptable. This is because the process of optimisation involves wider issues than simply the radiation health risk associated with the dose. The process of optimisation must take account of the perceptions and aspirations of those who will continue living and working in the area, and of those who may visit or purchase goods from it. Doses that are acceptable in the longer term will be influenced by the doses actually received. Therefore it is generally the full one year residual dose (dose received summed with prospective dose for the remainder of the year) that should be optimised. The optimised outcome may also be influenced by other, non-radiological, measures taken to support those affected, for example, compensation schemes, health monitoring, infrastructure and economic support. It is therefore important, in the development of emergency plans, to engage the potentially affected stakeholders, including public, private sector, etc. . This process of constrained optimisation within emergency planning is discussed in more detail in Sections 1.4.2 and 2.

Projected dose
Paragraph 28: It appears that there is inconsistency between individual dose and dose to a representative person.

Averted Dose
Paragraph 29 and 30: The value of averted dose is questioned. Consider shortening and putting this under projected dose (it is observed that the averted dose is not discussed in section 1.4.2 on optimisation).

Applying the Commission’s System to emergency exposure situations
Paragraph 31:
• ICRP should provide clarification on the requirement to protect against severe deterministic effects for all situations that could result in deterministic effects, as it does not consider risk-management. There needs to be a reasonable approach to scenarios considered and resources expended. ICRP should state that planning needs to be risked-based (see also paragraph 34).
• For consistency, ICRP should state why the principle of limitation does not apply

Justification
Paragraph 32:
• Optimisation during planning should be explicitly mentioned. Text has been added.
• [“The Commission now considers that a more complete protection is offered by simultaneously considering all exposure pathways and all relevant protective measures…”]: It is not clear what does this mean in practice? Is it feasible? ICRP should reword this to express the intent to take a collective / overall view of actions to be taken, rather than deal with each countermeasure in isolation.
(32) Protection strategies are made up of a series of specific protective measures designed to address, as appropriate, all pathways to which affected populations may be exposed. This concept represents an evolution from the previous ICRP recommendations which suggested that the individual and independent justification and optimisation of protective measures was sufficient. The Commission now considers that a more complete protection is offered by simultaneously considering all exposure pathways and all relevant protective measures when deciding, during planning, on the optimum course of action to be taken. In more concrete terms, this means that the overall “benefit” and “harm” of a suite of protective measures must be assessed when judging the justification of their application – it will be justified to implement a protective strategy when it results in more benefit than harm. In many cases, the summation of benefit and harm from a series of justified individual protective measures will also result in a net benefit. However, in some cases, particularly for large-scale accidents, the addition of many protective measures, each with a positive net-benefit but each resulting in significant social disruption, could result in the collective benefit of the protection strategy being negative. Thus, while each individual protective measure must itself be justified, in addition, the full protective strategy must be justified, resulting in more good than harm.

Paragraph 33:
• The beginning of the paragraph is confusing. Does it mean: the more obvious the justification, the less resources needed to quantify this? ICRP should simplify this.
(33) The level of resources allocated to the quantification of the factors relevant to the justification process will depend on how readily it can be demonstrated that the benefits outweigh or do not outweigh the harm. The detail of the process of justification will vary depending on a number of factors. Two of the most important factors are the nature of the likely health effects, should an emergency exposure situation occur, and the extent to which the harms can be deferred until the occurrence of the exposure situation (i.e. whether the planned response can largely rely on ‘paper’ planning and training, or whether specialised equipment, for example alarm systems, must be purchased and/or installed in advance). The Commission also recognises that the practicability of implementing a protective measure is relevant to determining whether that action should be included in the overall protection strategy.

Paragraph 34: This paragraph should be deleted because it is viewed as problematic, as it does not consider risk-management. There needs to be a reasonable approach to scenarios considered and resources expended.

Optimisation and the role of reference levels
Section 1.4.2
• Paragraphs 26, 27 should be moved here. Also, it has been previously stated that averted dose is important, yet the concept is not mentioned here. Consider reducing importance of averted dose in the previous section on dose concepts.

Paragraph 35:
• Some simplifications proposed, but editing of this paragraph is still required
• [“Again, this is because the combination of effects of many individual protective measures each involving large social disruptions may be too socially disruptive overall.”]: This is a cumbersome sentence and should be edited.
• Some additional text changes have been proposed.
(35) When optimising protection strategies, it is necessary to consider all aspects and protection measures to reduce residual dose, questioning whether “…the best has been done in the prevailing circumstances, and if all that is reasonable has been done to reduce doses.” [ICRP 2007, paragraph 217]. While this new approach does represent a relative increase in operational complexity, it also provides a significant amount of increased flexibility in designing the “best” protection to address an emergency exposure situation. This is partly because it enables the influence of one protective measure upon another to be taken into account, and partly because it provides for resources to be focussed towards those measures that are expected to achieve the most net benefit overall, rather than implying the need to focus equal attention on each single protective measure. The sum of the benefits and harms from all individual, optimised protective measures may not, itself, be positive. Again, this is because the combination of effects of many individual protective measures each involving large social disruptions may be too socially disruptive overall. An overall optimised strategy may include within it protective measures which, if considered in isolation would not appear optimised.

Paragraph 36:
• The concept of constrained optimisation is not presented clearly. Should be rephrased to make it clearer. Some changes proposed to improve clarity.
• [“The exceptions are extreme malicious incidents and some high consequence, low probability emergencies (cf. 2.3.4).”]: ICRP needs to clarify how these exceptions fit into the overall approach to using reference levels and optimization. Also need better guidance on how to set the reference level
• Last sentence: “release” changed to ‘exposure”, as it is the exposure that is relevant, and to apply more generically to a broader range of scenarios.
(36) The Commission has introduced the concept of constrained optimisation below reference levels in order to ensure that the response, as well as being optimised, also avoids unacceptable doses in the resulting dose distribution. The reference levels define a level of dose above which it is generally unacceptable to plan to allow exposures to occur. The exceptions are extreme malicious incidents and some high consequence, low probability emergencies (cf. 2.3.4). The level of dose applies to that estimated for representative persons of identified population groups. Since the circumstances relating to different types of emergency exposure situations and to different population groups (e.g. on-site, off-site, different age groups and vulnerabilities) may be very different, national authorities may wish to define sets of reference levels appropriate to these different circumstances. In developing emergency plans, the potential exposures of different population groups should be considered, and an appropriate set of representative persons identified. Note that the protection of those involved in implementing urgent protective actions (here termed ‘workers’, see Section 1.1) is also subject to optimisation below an appropriate reference level, with the exception of life saving actions and measures undertaken to bring the source of the exposure under control. Further guidance on the protection of workers is provided in Section 2.4.4.

Paragraph 37: Consider moving figure 3a closer to this reference

Paragraph 38: Delete “emergency” in the first sentence [“In planning, it is necessary to optimise protection both with respect to specific population groups and with respect to the overall response.”]

Paragraph 39:
• Text added to highlight that the relevant reference level is that which is appropriate to the scenario (ie, there is not just one single reference level applicable to all situations)
(39) Whilst the general intent of the Commission’s advice is that no residual doses should be planned to exceed the reference level appropriate to the emergency scenario, there may be circumstances in which this is either not practicable or not possible. In particular, where an emergency results from a malicious act, or where an accident occurs that results in very high exposures being received during or shortly after the initiating event, it is not practicable to plan to prevent all doses above the reference level. However, it is important that any exclusion of particular situations or population groups from the general requirement to plan to keep doses below the reference level is explicitly justified and agreed by the appropriate national authorities.

Paragraph 40:
• Added text to provide additional detail on re: exposure pathways and decisions
• Last sentence: change “ individual” to “single” to avoid confusion with actions aimed at individuals
(40) In order to optimise an overall planned response strategy, it is necessary to identify the dominant exposure pathways, the timescales over which components of the dose will be received, and the potential effectiveness of individual protective measures. Knowledge of the dominant exposure pathways will guide decisions on the types of protective measures to consider and the allocation of resources: resources allocated to protective measures should be commensurate with the expected benefits, of which averted dose is an important component. Knowledge of the timescales over which exposures will be received informs decisions about the lead times available to organise protective options once an emergency exposure situation has been recognised. Where urgent action is required to reduce exposures, it may be necessary to commit resources in advance of the emergency, and to use easily identifiable ‘triggers’ as the basis for decisions to implement the options, in order to ensure they are completed within the necessary timescales. The effectiveness of single protective measures can be complex to evaluate, since it includes, not only dose-effectiveness, but also wider social and economic consequences.

Paragraph 41:
• The first sentence should be edited: too many “optimisations” mentioned.
• Text added to highlight distinction between planning and response
• Last sentence has been modified: “equitability” has been removed as this concept is unclear.
• Text has also been added stating that in the first instance, the resulting dose should be compared against the expected residual dose, not just the reference level.
(41) The optimisation of the effectiveness of the overall strategy during planning is an iterative process, involving stakeholders, in which the proposed component protective measures are individually optimised and then their contribution to the overall strategy optimised. For planning, this optimisation needs to be robust for a range of circumstances, as the detailed circumstances of the emergency cannot be known in advance. However, when an emergency has been recognised, the appropriate strategy should be implemented. Once the early phase measures have been implemented, a more detailed iterative optimisation can be implemented, taking into account the exact circumstances and the actual stakeholders. Thus the process of constrained optimisation is iterative with respect to individual measures and the overall strategy, with respect to time, and with respect to stakeholders. At each stage, comparison of the total residual dose expected from the overall strategy should be compared with the planned residual dose to gauge the effectiveness of the implementation strategy, as well as the appropriate reference level(s) to ensure the outcome is optimised.

Paragraph 42:
• Text describing the post-emergency evaluation phase should be included in the document
• Last sentence has been modified. There will always be a distribution of doses: some of these may be above the reference level
(42) Figure 3b illustrates the application of the reference level once an emergency situation has occurred. Regular review of the expected residual doses as both the emergency situation and the response develop, and a consequent re-optimisation of the response, may well result in a progressive lowering of the expected residual doses over time. Review of the expected residual doses may also demonstrate that the doses to some population groups will exceed the reference level. In this case, any re-optimisation of the response strategy should first focus on these population groups, in order to explore whether it is optimum to reduce their doses. It should be noted, however, that a fully optimised response will still result in a distribution of doses, where some may be above the reference level, as indicated by the second bar in Figure 3b.

Figure 3b: Actual dose distribution after implementing the planned protection strategy (left) and ongoing optimization (right)

Planning for emergency exposure situations
Section 2:
• Alternate title proposed: Arrangements for emergency exposure situations
• The focus should be on arrangements, since plans are only one aspect of emergency preparedness. This should be reflected here and throughout the document.

Situations for which to prepare response plans
Section 2.1
• The discussion should refer arrangements rather than plans throughout this section, as plans are only one element of emergency preparedness

Paragraph 43:
• For presentation, the second sentence should be converted to a list, and add in some of the missing elements such as risk assessment as basis for plans, international communications, coordinated plans, etc. This will provide the overview of items to be considered as part of overall preparedness, then the document can focus on developing protective strategies (ie Publication 103 concepts) as part of planning.

Paragraph 44:
• Cannot prepare for all emergencies. Planning should be based on a risk assessment and associated risk management. Text has been modified to account for this.
• Add orphan sources
• Change agencies to parties, since more than government is involved
• Some additional important preparedness elements have been added
• Last sentence: strategies should be based on the scenarios identified (not just one strategy). Detailed text on triggers deleted, as can have triggers for more than just prompt actions.
(44) The Commission recommends that plans are prepared for the types of emergency exposure situations identified in the risk assessment: nuclear accidents (occurring within the country and abroad), transport accidents, accidents involving sources from industry and in hospitals, malicious uses of radioactive materials, and other events, such as a potential satellite crash or orphan sources. The level of detail within the plans will depend on the level of threat posed, and the degree to which the circumstances of the emergency can be determined in advance. However, even outline generic plans should indicate the responsibilities of different parties involved, methods for communication, coordination, cooperation and organisation between them and internationally during the response, and a framework for guiding decision making. More detailed plans should contain a description of the protection strategies for the identified scenarios, and provide triggers to facilitate prompt decision making.

Paragraph 45:
• Not clear what “holistic” means here. Text change has been proposed.
• The following sentence [“For this reason, the Commission's reference level for emergency exposure situations refers to the total residual dose received/committed over one year.”]: This is the definition of the reference level. It should be mentioned once in the earlier discussion of reference levels.
• Re: discussion of intermediate and late phases - Suggest rewording this to remove the rigidity of distinct phases, and different approaches are taken by different authorities (again, see earlier note re: dynamic nature of phases). Also, it may be too difficult to include the late phase in an emergency plan, and in fact may be better treated as an existing situation. However, it should provide for the transition to this, as many useful things can be done as part of emergency planning. Some text in this direction has been added.
(45) Detailed response plans are likely to place most emphasis on the initial response as this is when there is least time for developing the response in real time and when uncertainties concerning the overall situation, current exposures and the likely evolution of exposures will be greatest. However, any actions (or inactions) taken during the early phase will impact on what can be, or needs to be, done later on. In addition, the particular characteristics of these later phases, for example, with regard to the need for widespread monitoring, may mean that unless the response strategy is adequately addressed during planning, it may not be possible to respond effectively in the event. Finally, as outlined in Section 1.2, the optimum protection strategy for emergency exposure situations must address a broad range of issues, addressing a wide range of issues over a range of timescales. For this reason, the Commission's reference level for emergency exposure situations refers to the total residual dose received/committed over one year. Optimising the planned strategy to aim for the maximum residual doses to be below this level requires consideration of the response across all phases (or at least the early and intermediate phases for large events). An emergency response plan should therefore address the response during all phases. For the early phase, the planned response would be set out in detail with triggers to help guide decisions on implementation. For the intermediate and late phases, it is likely that, rather than a specific response being planned, an outline strategy would be indicated, together with a framework for developing the specific response at the time of the accident, taking account of the actual circumstances. Whilst the form of the planning for the later phases would be different, and in some cases may be done as part of planning for existing exposure situations, it is important that this planning is undertaken in such a way as to provide confidence that total residual doses over a whole year will not exceed the reference level.

Paragraph 46:
• The concept of adjusting and terminating actions should be mentioned
• Last sentence: Text has been proposed to state that the level of detail should be appropriate to the scenario for which the plan is made (rather than stating that it reduces with time).
(46) Even after an emergency exposure situation has occurred, there will be a need to plan subsequent actions, particularly as time advances and the urgent need to act dissipates and finally disappears. As such, there will continually be a need to reflect relevant experience in selecting, implementing, adjusting and terminating protective measures. The emergency plan will have identified a set of protective measures, and planned their implementation to an appropriate level.

Protective measures to avoid severe deterministic injury
Paragraph 47: Not clear what the message of this paragraph is. Delete the full paragraph.

Paragraph 48:
• New sentence added to highlight importance of avoiding deterministic effects
• Terminology: severe deterministic injury – this appears to be a new term that should be defined here and in the glossary
(48) The first concern in the event of a radiological emergency is to keep the exposure to individuals from all pathways below the thresholds for severe deterministic health effects (ICRP 60, 63). In the event of an emergency it is possible that some individuals may be exposed to radiation doses that are so high that, without prompt medical treatment, they will cause severe, irreversible injury to their health. The Commission calls these severe deterministic injuries, to distinguish them from deterministic tissue reactions which either may be reversible or may have only a minor impact on the individual’s health. The Commission continues to advise that practicable protection measures should always be planned to protect those individuals who would be at risk of suffering severe deterministic injury in the event of an emergency exposure situations. The following paragraphs provide additional advice on a framework for achieving this.

Paragraph 49:
• ICRP needs to address the clarity of this and other related paragraphs. Concern that it does not make sense, as it makes a distinction between situations of exposure, rather than planning situations. There is no fixed line between what can be planned for to some degree, and what cannot. Can also have the situation of planned exposure situations under another jurisdiction, over which another impacted jurisdiction may have no control (trans-boundary event). Can also have “accidents” for situations that are not considered planned situations, eg, orphan source.
• Re: planning for malicious acts: Planning can be done for some of these, such as those that might target a NPP, hospitals, etc
• Global change from accident to emergency (as appropriate to context)
(49) In developing this framework, the Commission recognises that there is a qualitative difference between planning protection for emergencies and planning protection for unintentional events (eg, orphan sources) and malicious acts. Accidents occur when unplanned events disrupt planned exposure situations. It is therefore possible to design additional safety precautions into a planned activity, that would mitigate the doses received in the event of an accident. This is clearly not possible in the case of malicious acts, as such acts are planned deliberately to circumvent any protective measures that might be in place. The Commission therefore recommends that the framework for protection in the case of accidents comprises two steps, one prior to any accident and one in the event of an accident. The recommended framework for protection in the case of malicious acts may contain a ‘prior’ step, for specific locations or activities judged to be at particular risk, but will generally focus on the response phase only.

Paragraph 50:
re: last bullet points addressing justification:
• [“disruption of normal activities to an unreasonable extent”]: This is not useful guidance. What is considered unreasonable, particularly in the context of dealing with deterministic effects?
• [“that another protective option exists which provides the same or better protection.”]: This is an issue of optimisation of an action, not justification of an action. Because one action provides the same protection does not mean that another is unjustified. Suggest to delete this.

Paragraph 51:
• The second sentence is written from an NPP perspective. There could be situations where this is not the case, eg, triage, improvised nuclear device. There is concern that this sets expectations that might not be achievable in all situations (ie in cases where aid/assistance will not help severely injured individuals)

Engagement with stakeholders (who to involve)
Section 2.1.3: Consider combining this section, or ensuring better linkages, with section 2.4.3, “stakeholder involvement in planning”

Paragraph 53:
• First sentence: ICRP should rewrite this to reflect what is possible and practicable, particularly in context of paragraph 54, which includes international stakeholders.
• Last sentence: ICRP should add text noting that there will be a need to engage with the authorities who will be handling these longer-term issues if they are not same as the emergency response authorities
(53) During planning, it is essential that the plan is discussed, to the extent practicable, with all relevant stakeholders, including other authorities, responders, public, etc. Otherwise it will not be possible to implement them effectively during the response. The overall strategy and its constituent individual protective measures should have been worked through and agreed with all those potentially exposed or affected, so that time and resources do not need to be expended during the emergency exposure situation itself in persuading people that this is the optimum response. Where evaluation of the later phases indicates that there may be significant societal and economic adjustments required in order for populations to live in areas that were contaminated, it is important that those populations are engaged in exploring the implications of, and reasons for, this in advance of any accident occurring. Such engagement will assist the emergency plans in being focussed, not only on the protection of those most at risk in the early and intermediate phases, but also on the progression to populations resuming ‘normal’ lifestyles (where ‘normal’ may be rather different from the ‘normality’ that existed before the emergency). Additionally, there will be a need to engage and coordinate with the authorities who will be handling these longer-term issues if they are not same as the emergency response authorities.

Paragraph 54:
• The concept addressed in this paragraph is in the wrong place. International cooperation, etc with other countries, is a coordination issue, not a Stakeholder Involvement issue. It should be mentioned elsewhere in the document.

Paragraph 55:
• First sentence: Text change proposed as this is not contaminated waste, but waste containing radioactive material. Need consistent terminology (global change)
(55) A further need for stakeholder engagement centres around the issue of waste containing radioactive material. In any emergency exposure situation involving anything more than the most limited contamination of the environment, it is likely that very large volumes of contaminated waste will be generated, e.g. Goiania [IAEA 1988]. Managing and disposing of this waste will pose significant problems both socially and practically, and may even require changes to legislation. Where agriculture is affected the problem of large volumes is compounded with the waste rapidly becoming a health hazard and the production of some food wastes (e.g. milk) not being easily terminated. Engagement with representatives of local communities, producers and regulators in advance of an emergency can provide an opportunity for solutions to be developed in outline, and any legislative changes required to be identified in advance.

Representative persons (who to protect)
Paragraph 56: Changes have been proposed to improve clarity
(56) In the event of an emergency exposure situation, it is likely that actual exposure rates will vary in space and time, and that the doses received by individuals will vary, both as a result of the variations in exposure rates and as a result of differences in their physiological characteristics and their behaviours. In order to ensure that the optimum response strategy is developed, it is important to consider the range of doses and other consequences for individuals that may occur, both in the absence of protective measures (projected doses), and following implementation of the protection strategy (residual doses).

Paragraph 57:
• [“It would be expected that, where children are likely to be present in an affected area, the consequences and protective strategy for this age group would be explicitly considered …”]: ICRP is requested to explore the implications of this on possible protective strategies – eg, specific actions to protect sensitive groups vs population-wide actions based on the sensitive group, and provide appropriate clarification.
(57) The Commission advises that this is achieved by identifying a set of different population groups who, by their locations, characteristics and behaviours, appropriately represent the full distribution of doses and risks. These population groups should be characterised by representative persons, as described in the Commission's advice on representative persons [ICRP 2006]. It would be expected that, where children are likely to be present in an affected area, the consequences and protective strategy for this age group would be explicitly considered as deemed appropriate in the planning arrangements. In accordance with the Commission's advice on the representative person, it is important that the dose estimates made reflect the those likely to be received by the groups most at risk, eg pregnant women and children, but that they are not grossly pessimistic.

Setting reference levels
Section 2.1.5
• There are basic concepts on setting reference levels throughout paragraphs 58-62 that should be put first in paragraph 58, before the discussion of ICRP recommendations. The values should flow from the rationale presented.

Paragraph 58:
• ICRP may want to provide guidance on how to explain to the public the choice of different reference levels for different emergency situations.
• The first two sentences of paragraph 59 should be put at the beginning of this paragraph as it provides the basic approach to setting a reference level.

Paragraph 59:
• First/second sentences: Should be moved to the beginning of the section, before the discussion of ICRP values, as it is a basic statement addressing the purpose of this section
• Second sentence: text proposed to make it more generic in terms of applicable scenarios. Also, does this guidance mean that all of these particular groups require their own optimised protective strategy? Greater complexity does not necessarily deliver greater protection. Protective strategies need to be practical and effectively implemented. The optimisation process needs to have feasibility included
• [“The optimisation process may thus need to take into account exposures of different phases simultaneously in assessing whether the optimum protection is being afforded to individuals under various emergency circumstances.”]: ICRP is requested to clarify this statement, as it appears impractical. If it is simply to reflect the fact that the situation has temporal and spatial variability, then this should be clearly stated. A diagram would help to illustrate this concept
• [“The total residual doses to be compared with the pre-selected reference level is that assessed and/or estimated…”]: This implies that there only one reference level. What is the situation if there is a critical organ, eg, thyroid
(59) The selection of a reference level should fit the type of emergency exposure situation and the protection strategy to which it will be applied. For example, in a large-scale release of radioactive material the protection strategy will be an evolving set of protective measures aimed at addressing the particular circumstances of populations affected in different ways and to different levels, at different times and in different places. Because of the lasting nature of the situation and the exposure circumstances, the pre-selected reference level against which to assess the optimisation of protection should be expressed as mSv in a year. The optimisation process may thus need to take into account exposures of different phases simultaneously in assessing whether the optimum protection is being afforded to individuals under various emergency circumstances. The total residual doses to be compared with the pre-selected reference level is that assessed and/or estimated for the exposed populations for the year following the accident. However, in an accident involving no long term environmental contamination (eg, criticality accident), the pre-selected reference level against which to assess the effectiveness of the protection strategy is the dose received as a result of the accident.

Paragraph 60: delete and combine with previous paragraph

Paragraph 61:
• This is a basic concept that should be put at the front of this section, before discussion of ICRP values.
• Planning should be risked-based. ICRP is requested to clarify terminology: credible, reasonably foreseeable, etc. Needs to be practical. Proposed text has been added.
• This paragraph should also go earlier in discussion of planning basis. The risk assessment is performed to determine which scenarios will be planned for. Reference levels will then be selected for the planned scenarios.
(61) The type of reference level that is selected should thus be tailored to meet the type of accident scenario under consideration. Regulatory authorities and operators will assess reasonably foreseeable risks, and authorities will be able to pre-select appropriate reference levels for the various accident scenarios that they judge to be relevant.

Paragraph 62: The first sentence is viewed as a basic concept, and should be put at the front of the section as well; The last sentence is not clear, and should be clarified in the context of the preceding text

Role of intervention levels
Section 2.1.6:
• Recognising the major change from ICRP 63 to 103, and the change in focus from single intervention levels to optimisation of strategies, the value of intervention levels is questioned. This section puts too much emphasis on intervention levels and should be condensed as there are only a few countermeasures for which intervention levels have been defined. It is noted that intervention levels are not discussed in the section on optimisation, 1.4.2. (see previous related comments on averted dose).

Paragraph 65: Consider combine this paragraph with paragraph 63

Paragraph 66: Delete the last sentence as it is redundant [“The Commission therefore continues to recommend use of intervention levels in planning, provided they are applied flexibly, as an aid to developing an optimised overall protection strategy.”]

Components of an emergency response plan
Paragraph 67:
• This paragraph appears out of place. This paragraph should be moved earlier, consider combining with [43].
• Last sentence: If this means that the focus is not on how to develop arrangements, but on implementing those aspects of ICRP 103, then this should be clearly stated.
(67) An emergency response plan will contain a wide range of information and guidance, including much information, such as contact details, duties and responsibilities of the different organisations involved, reference to legislation, amounts of equipment/resource required etc, that is beyond the scope of this document. A discussion of these practical and technical issues can be found in publications from other bodies, such as the NEA and IAEA [NEA 2000, IAEA 2002, IAEA 2003,]. In these documents only those aspects of emergency response planning relevant to the application of the Commission's advice are discussed.

Strategies and individual protective measures
Paragraph 68:
• Second sentence modified to improve clarity
• [“The most commonly considered urgent protective measures in a nuclear or radiological emergency are evacuation, decontamination of individuals, sheltering, respiratory protection, iodine prophylaxis…”]: Put this as a bulleted list to improve presentation
(68) There are different protective measures which could be applied in a radiation emergency for the protection of people. These protective measures could be applied promptly (urgent protective measures) or be prolonged over weeks, months or years (longer term protective measures). Urgent protective measures are those that must be taken promptly (normally within hours) in order to be effective, and for which the effectiveness will be markedly reduced if there is a delay. The most commonly considered urgent protective measures in a nuclear or radiological emergency are evacuation, decontamination of individuals, sheltering, respiratory protection, iodine prophylaxis, and restriction of the consumption of foodstuffs that have the potential to give significant exposures to people (eg green vegetables grown in the open and milk from animals grazing outdoors). Longer term protective measures (and food restrictions to protect against longer term exposures) include measures such as relocation, agricultural protective measures and some decontamination measures. The Commission has previously published detailed guidance on most of these protective measures [ICRP 1993]; further discussion of individual protective measures in this document is therefore restricted to new aspects of the Commission's advice.

Paragraph 69:
• First sentence: Text proposed highlighting that a broad range of measures may be considered, not just those addressing exposure.
• Some text could be added to the paragraph that care needs to be taken in implementing some long-term follow-up in order to not give a sense of victimization to the followed populations
(69) During an emergency there are also other measures that are likely to considered. These include public warning, information, advice and basic counselling, dealing with their own national citizens in another affected country, comprehensive psychological counselling, medical management and long-term follow up. More details on some of protective measures are provided in Annex B.

Temporal and geographical issues
Paragraph 70:
• Last sentence: While recognizing that the response will be a continuum, it is noted nonetheless that in many cases there needs to be sharp boundaries for reasons of practicality in implementing protective measures. ICRP should modify this text to account for this fact.
(70) The characteristics of potential exposures and therefore the requirements for protective response will vary both spatially and in time. In order to be manageable, emergency plans will sub-divide the area at risk into appropriate sub-areas, based on a number of factors such as: distance from the initiating source; demographic, economic and land use factors, response phase (early, intermediate, late). This approach enables the broad issues for each sub-area to be treated appropriately within the plan. However, in reality, there will be few, if any, sharp boundaries to delineate the implementation of protective measures.

Paragraph71: This paragraph should be deleted as it does not add value.

Influence of actions in one phase on actions in another phase
Paragraph 72: This paragraph should be deleted as it does not add value.

Paragraph 73:
• The following text has been deleted as it is viewed as unhelpful [“However, such an approach is likely to be very confusing to the public, and may even imply that the authorities had wrongly believed the hazard had gone, only to discover later that it had not..”]. Conversely, ICRP should add some text that discusses the need to get across the message in a non-confusing manner (discussed later in 2.4.3)
• The example has been modified to make it more generic
(73) The termination of protective measures is one area where the potential interaction of early phase protective measures and intermediate phase protective measures is particularly obvious. Withdrawing all early protective measures and then, some time later, initiating intermediate protective measures such as decontamination, might, purely from consideration of future doses and dose rates, seem the optimum course of action.. It may also not be optimum from a practical and ‘cost’ viewpoint. For example, extending evacuation whilst decontamination is carried out may actually not increase the monetary costs of the combined protective measures substantially, as the decontamination may be carried out more efficiently in the absence of people living in the area.

Paragraph 75: Alternate text has been proposed for “between phases”
(75) The Commission therefore advises that effective emergency planning should consider the interactions between protective measures, not only during each phase, but also along the entire timeline of the response. It may be that one way of ensuring that these interactions are adequately addressed is for the planned response to identify the need for a team to be set up in the early phase whose responsibility is primarily to consider what might be required in later phases and how early phase decisions might impact on this.

Co-existent response phases
Section 2.2.2.2
• An alternate title is suggested, which is viewed as being more correct: Dynamic nature of response
• This is an important paragraph that could be used earlier during previous discussion of phases
• A diagram may help illustrate this concept.

Developing an emergency response plan
Section 2.3
• An alternate title is suggested “Developing protective strategies” as the focus should be on ICRP 103 concepts, not on a developing a plan.

Evaluation of emergency exposure situations
Section 2.3.1: Paragraphs 77-81 should be shortened. There are too many examples - consider putting these details in an Annex

Paragraph 77: The sentence [“This is likely to be followed by a phase lasting days or weeks when iodine-131 dominates the exposures”] refers to only one type of emergency. The text should be more generic.

Paragraph 79: If the diagrams are kept, it would be more useful to show time variability

Paragraph 81: The paragraph needs to be simplified.

Justification of protective measures
Section 2.3.2
• This section should be combined with the previous text on justification, in one single place in the document

Optimisation based on reference levels
Section 2.3.3
• For consistency with Publication 103, the correct title should be “Constrained Optimisation”

Paragraph 84:
• It is the protective strategies that are optimised, not the plan. The text has been modified accordingly.
(84) Development of protective strategies requires optimisation of the expected residual dose, to all relevant population groups, below the appropriate reference level. It is not sufficient simply to plan to achieve doses just below the reference level; it is necessary to demonstrate that the planned protection has been optimised below that level

Paragraph 86: The meaning of this paragraph is not clear, and should be clarified.

Detailed optimisation
Paragraph 88:
• The approach mentioned in the first part of the paragraph is not necessarily “holistic”, as described earlier in the document. This needs to be made consistent. This also needs to be edited and simplified.
(88) In principle, the process of applying constrained optimisation to the planning of strategies of protective measures is the same as that for individual protective measures, that is, all the consequences, harmful and beneficial, expected to result from the imposition of different strategies are evaluated and balanced, and the one with the greatest net benefit, which also results in a residual dose below the reference level, is selected. The problem with this process in practice is that there are so many permutations of strategies that could be considered, that the process could quickly become complex. It is therefore advisable to adopt a more pragmatic approach, in which individual protective measures are optimised separately, and then, issues associated with their application in combination identified and explored, as discussed below. As noted in Section 1.4.2, a strategy composed of individually optimised protective measures will not necessarily itself be optimised, whilst an optimised strategy may contain actions implemented in a way that, taken in isolation, would not be optimum.

Paragraph 89:
• The concept described in the last part of the paragraph is confusing and needs to be clarified, particularly with respect to the role of intervention levels [“These types of protective measures can readily be optimised separately and the relevant intervention levels used as a direct guide. However, the intervention levels should be applied flexibly, since it may be better to widen the area of application of a protective measure to take account of local geographic and demographic factors, for example, encompassing a whole community even if the expected averted dose for some parts of that community will be below the relevant intervention level.”]

Paragraph 90: [“… thereby reducing the resources that would be required for tablet distribution in the absence of evacuation.”]: It is felt that this example does not make sense, as tablet distribution would not occur if there is an order to shelter in place (they would already have it if pre-distributed). Clarify the example, making a note of timeliness

Paragraph 91:
• The concept of feasibility should be noted.
(91) The resources required to implement protective measures are not the only factors that might interact within an overall protective strategy. Other such factors include individual and social disruption, anxiety and reassurance, and indirect economic consequences. It is important to review the proposed overall protective strategy with representatives of all potential stakeholders to ensure the plan is optimised and feasible with respect to these factors, as well as with respect to dose and the resources required. This wider review of the protection strategy may well indicate a role for additional actions, which, in isolation, do not appear optimum (or even justified). Alternatively, it may indicate that the optimum strategy should modify or omit other actions, even though they appeared justified and optimised when only dose and direct resource requirements were considered.

Paragraph 94: Delete this paragraph and combine with the paragraph 95

Triggers
Paragraph 95:
• Put paragraph 94 at the beginning of paragraph 95, and delete text about doses not being readily measureable
• Combine all discussion on triggers in the same location.
(95) Once the response strategy has been optimised, measurable triggers for initiating the different parts of that plan should be developed. Since most protective measures taken in the early phase need to be taken promptly, any delay in decision making would be counter-productive. Therefore, protective strategies should include early phase triggers (which may include default operational intervention levels (OILs), emergency action levels (EALs), and observables/indicators of on-scene conditions, as described by [IAEA 2002]) that can be used immediately and directly to initiate appropriate protective measures. Triggers may be expressed in terms of any observable circumstances or directly measurable quantities, such as plant conditions, dose rates, wind direction. Triggers may be related to dose considerations, but are more likely to be quantities that indicate that the situation has occurred for which the plan (or a group of actions within the plan) was developed. Similarly, triggers may be identified which indicate that the event is outside the range of scenarios considered when the plan was developed, thus warning decision makers that the scale of protective measures may need to be escalated from those set out in the plan (in particular, the areas over which early phase protective measures are introduced may need to be significantly enlarged). Once the occurrence of a trigger has been identified, decision makers can advise that the appropriate part of the protection strategy should be immediately implemented, without further delay or discussion.

Paragraph 98:
• It is the actions, not the triggers, that are protective. Text has been modified.
(98) In some emergency exposure situations, it may become apparent that protective measures are required that were not envisaged within the plan, or for which the actions implemented were not sufficiently protective. In this case, decision makers should first implement all those urgent actions indicated by the triggers, but may then take additional actions not indicated by the planned triggers. In other words, the triggers should be used to facilitate prompt decision making, but not to prevent necessary flexibility to respond appropriately to the exact circumstances of the emergency. This is discussed further in Section 3.

Paragraph 99:
• It is felt that there is undue weight placed on the use of triggers in the intermediate and late phase. They are less relevant at this stage of the response. ICRP is requested to find appropriate terminology here, ie, triggers for early phase, other broader indicators for intermediate and later phases.
(99) Established criteria or indicators may also be helpful for deciding on and delineating the extent of protective measures in the intermediate and late phases. It will not generally be useful to specify these criteria or indicators in the planning phase, as they will need to be related to the exact circumstances of the emergency. For example, once the radionuclide composition of environmental contamination is understood, a dose rate criterion could be applied to delineate where temporary relocation would be advised. Whilst specification of the triggers themselves in the emergency plan may not be appropriate, it may be helpful to include an agreed framework for developing triggers in ‘real time’. The inclusion of such a framework is likely to result in wider acceptance of the ‘real time’ triggers when they are developed.

Supporting measures
Section 2.4: ICRP is requested to clarify whether this section is dealing only with components to support optimization in planning, or whether it is intended to describe how to build an emergency response programme (which seems to be beyond the stated scope of the document). If the former, then the focus needs to change; if the later, then it is incomplete.

Environmental Monitoring
Section 2.4.1
• This is one aspect of emergency arrangements, but not necessarily relevant to the application of optimisation, etc (see previous comment re: section 2.4). If environmental monitoring is mentioned, then also need to include environmental modeling, and other aspects.
• This section should be revisited, as it does not seem to address planning. Rather the focus seems to be on response. Suggestion to keep paragraph 100 and condense or delete the following paragraphs as they are addressed elsewhere.

Paragraph 100: Some text changes proposed
(100) In support of decision making, the key roles of environmental monitoring are to:
• identify the extent and level of contamination;
• facilitate the scaling of modelled source terms
• identify whether trigger levels, as specified in the emergency plan, may be exceeded;
• indicate that circumstances are sufficiently different from those planned for that much larger, or very different response is required;
• provide the basis for more accurate estimation of residual doses – both those already received to date and those expected to be received in the future, for comparison with the reference level specified in the emergency plan.

Paragraph 101:
• If the text is kept, then it should be stated that the data is for ongoing optimisation during response, not during planning. Text change proposed
(101) In order to appropriately design, implement and manage protection in an emergency exposure situation, it is essential that any assessments of the quantities and nature of radioactive material involved are supported by environmental monitoring data. Actual measurements of various types may be used to update dose calculations that have been estimated based on release assumptions, and will help to define the extent of radiological effects. Knowledge of actual environmental contamination will also support decisions with regard to where various protective measures should be considered, thus providing an idea of the order-of-magnitude of the resources necessary to appropriately respond. Environmental monitoring data is one of the key tools for the ongoing optimisation of protection during the response.

Paragraph 102: In the first sentence, it is noted that the issue of sizing resources is an important planning issue and this concept should be kept.

Paragraph 103: If kept, then shorten and also add HOW (ie, different scenarios – accident, malicious)

Individual Monitoring
Section 2.4.2: It is noted that this section is written from the perspective of response. This should be redrafted to make the text more planning oriented.

Paragraph 105: The text [“eg from dose meters they are required to wear routinely)”] is an occupational issue. There should be better clarity here re: public and worker dose monitoring

Health surveillance
Section 2.4.2 Health Surveillance
• Number of section is incorrect
• It is not clear how this is a supporting strategy to optimisation

Paragraph 106:
• It is noted that while health surveillance following Chernobyl addressed public health concern, it did not necessarily decrease it. The text has been modified accordingly.
(106) There are different reasons to perform long-term medical follow-up (health surveillance) of affected people, such as to provide advanced medical care for affected people; to address public concern with regard to their health status, and to obtain new scientific knowledge for enhancing radiation protection. Each of the reasons could form the basis for medical follow-up. However, for medical care of the affected population, the reason for establishing a registry and providing medical follow-up is: early detection, and hence effective treatment of cancer that may be induced by radiation.

Paragraph 107:
• First sentence: ICRP is requested to clarify what risks are being referenced – otherwise it implies that medical follow-up can damage health
• Much of this paragraph addresses decisions between individual and medical practitioner, and is therefore out of realm of planning. Suggest deleting paragraph, otherwise clarify the message.
• Delete reference to DS-44 (draft document)
(107) Long term medical follow-up has both potential benefits and risks. Early recognition of the cancer represents a net benefit both to the individual and to society. However, potential penalties both to the patient and to the medical care system should be also considered. Potential risk for the patient includes performing invasive and potentially harmful procedures (e.g., fine needle biopsy of thyroid), ultrasound detection of clinically insignificant nodules (leading to false positive results), and the psychological pressure of regular examination, which influences the quality of life. The potential risks to the consequences for the medical care system, e.g. overload in terms of both personnel and equipment, need to be identified and appropriate cost- and risk-benefit analyses should be undertaken (including not only morbidity and mortality associated with surgery, but also the need for long-term patient compliance and the necessity for life-long medication, e.g. replacement hormone therapy after removal of the thyroid gland). This should be of special consideration for countries with limited resources allocated for long-term medical follow-up of people with very low risk of radiation-induced cancer.

Communication with the Public
Section 2.4.3:
• Both this 2.4.3 (Communication…) and the next 2.4.3 (Stakeholder Involvement…) are mixing communications and stakeholder aspects. These two aspects need to be clearly separated.
• Suggest change to title of this section: Information to the Public

Paragraph 108: The text seems to be focused on response. Suggest to move this to section 3. Also, the type of communication will depend on the timeline of the emergency (information vs dialogue)

Paragraph 109:
• Change to first sentence proposed
(109) At the planning stage, it will be important to dialogue with as many potentially affected stakeholders as possible so as to appropriately identify the most effective protection strategy….(etc)

Paragraph 110
• All emergency management authorities should be trained in communications, not just the RP staff. Text changed proposed in last sentence.
(110) For communicating with stakeholders in all phases of an emergency exposure situation processes and procedures will need to be identified and made ready to implement if necessary. Training of emergency management authorities in aspects of public communication will be necessary.

Stakeholder involvement in planning
Paragraph 111: ICRP is requested to clarify the guidance in this paragraph as it suggests that in planning, all possibly affected populations should be informed, which is not possible. This cannot be defined in the planning stage, particularly for emergencies that do not occur at fixed facilities, and may cover very large geographical areas and timeframes.

Paragraph 112:
• Some text changes proposed, ie , should mention stakeholders, not just public, as well including stakeholder views as appropriate.
(112) The Commission wishes to emphasise that this does not simply indicate the furnishing of information regarding an emergency exposure situation. While early in an emergency exposure situation there may certainly be need to direct members of the public regarding the application of specific, urgent protective measures, there will also be a need to discuss options with the stakeholders at the planning stage and at the stage of implementing non-urgent protective measures. By involving stakeholders, decision makers and those responsible for planning and implementing protection strategies can make their choices most optimally, incorporating stakeholders’ concerns and views as appropriate, as well as of relevant radiological protection science.

Paragraph 113
• Again, stakeholders are more than just the public; and it is not just RP staff that need training in stakeholder involvement aspects. Text changes proposed.
(113) To accomplish this, it will be essential that the needed plans, procedures and infrastructures are put in place before an emergency exposure situation occurs, and that those stakeholders likely to be affected are aware of the plans and the reasons for different messages being provided. Appropriate training of emergency management authorities in stakeholder involvement is an essential part of this.

Protection of emergency workers [ICRP 1991 b and 2005 a, revised BSS]
Section 2.4.4
• It is noted that this is a core element of the document since it is the protection of people. This should not be under “Supporting elements”
• Remove reference to revised BSS – cannot reference a draft document

Paragraph 115: Modify last sentence as follows: “This would include, but not be limited to, police, rescue personnel, fire fighters and medical personnel.”

Paragraph 116:
• This paragraph should be simplified. ICRP should clarify the listed classes of emergency workers, as it may not address all possible responders, ie onsite workers, including those involved in the response, and offsite responders, including RP specialists and non-specialists (bus drivers, etc). The management for these two categories is not the same.
• While the last bullet is a quote from ICRP63, those undertaking recovery actions are not emergency workers. Consider dealing with as part of existing exposure situations.
• Last sentence: delete “always” at end of sentence (“Whereas, in 1991, the Commission cited optimisation as an aspiration, it now judges that an emergency preparedness culture has developed sufficiently to recommend that optimisation of the exposures be undertaken.”)
• ICRP needs to rewrite this as a more self-contained and clear paragraph in order to highlight the changes from ICRP63.

Paragraph 117:
• Concerning guidance for pregnant women, the paragraph should specify that the first responders in question would be those in the affected areas, exposed to a radiation risk - otherwise it is too broad. Also suggest changing “employed” to “engaged” as it is not an issue of employment
• Proposed alternate text: females who have declared that they are pregnant or are nursing should not be involved in emergency actions involving high radiation doses (ICRP, 2005a).
(117) The Commission’s advice, as set out in Publication 63, regarding the appropriate provision of training and information to emergency workers, and, for those in category 1, ensuring they are undertaking the risks voluntarily, remains unchanged. Furthermore, the Commission now explicitly recommends that women who have declared that they are pregnant, or who are nursing an infant, should not be engaged as first responders undertaking life-saving or other urgent actions.

Paragraph 118: This paragraph is not considered relevant, and it references a draft document (revised BSS). Suggest to delete.

Implementing protection strategies
Section 3: This section largely repeats what was already discussed in Section 2: Planning, without bringing in new aspects. The text should be shortened to focus on the concepts relevant to implementing the protective strategies, and improved with respect to the flow of actions to be taken, ie, implement the protective strategies according to the emergency situation identified, evaluate their effectiveness, undertake tuning based on actual conditions (radiological and operational).

Paragraph 119
• It is suggested to delete the following as unnecessary detail [“their tendency to rapidly evolve, and the wide possible range of emergency conditions (i.e. weather conditions, geographic location, population habits, etc.) could result in situations that do not match the assumptions that were used to develop optimised protection strategies such that”]
(119) In the context of the ICRP’s system of radiological protection, there is at least one fundamental difference between prospectively planning to address the consequences of a radiological emergency exposure situation, and managing consequences that are in the process of occurring or that have already occurred. In the context of planning, optimisation is performed using the appropriate reference level as the upper bound to optimisation, eliminating any protection solutions that result in individual residual doses exceeding the reference level. Protection for all those exposed is optimised, and residual exposures resulting from the application of the protection strategy are below the reference level. In the inherently unpredictable nature of emergency exposure situations, some actual exposures may well exceed the pre-selected reference level. As such, in the context of managing the consequences of an emergency that is in the process of occurring or that has already occurred, the predefined reference level is used as a benchmark against which to judge the results of implementing an planned protection strategy, and for guiding the development and implementation of further protective measures if necessary (see Fig. 3b).

Paragraph 120
• The residual doses resulting from the implementation should be compared against what was expected (as part of feedback), not just the reference level. ICRP is requested to determine how best to incorporate this concept, recognizing the inherent level of uncertainty. Some alternate text is proposed.
(120) When reviewing the effectiveness of an on-going response or taking decisions on the implementation or variation of protective measures, it is important to compare the total residual dose with the reference level, ie the sum of doses actually received with those expected in the planning stage. A comparison that neglects the component of dose already received, may result in the implementation of individual protective measures that appear optimum in themselves, but an overall response that is not appropriately optimised.

Tuning protection strategies to actual conditions
Paragraphs 121 and 122: The distinction between planning and implementation are not clear in paragraphs 121 and 122. ICRP should consider deleting these two paragraphs are combine the concepts with the following two sub-sections: Implementing protective strategies; and and Tuning protective Strategies)

Paragraph 121: This paragraph is very long and should be shortened / simplified

Tuning protection strategies in the early phase
Comment: Suggest renaming as Implementing protection strategies in the early phase, since these need to be implemented before they are tuned.

Paragraph 123
• Terminology issue. The focus of decisions should be on implementing the correct protective strategy.
• Some text changes proposed
(123) The early phase of an emergency exposure situation can be characterised as taking pre-planned actions as best possible to manage any emergency consequences. The focus of protection strategy decisions will be on implementing the pre-planned protective strategy that best fit the actual situation.

Paragraph 124:
• Some text changes proposed; delete “releases” in the second sentence, as the exposures are the basis for the action
(124) In the early, uncertain phase of an emergency exposure situation, the radiological protection objectives of a protective strategy should be to avoid severe deterministic effects and to keep the risk of stochastic effects as low as reasonably achievable. To accomplish this, there may well be the need to act very quickly and without much concrete knowledge of exposures…(etc)

Tuning protection strategies in the intermediate and late phases
Comment: ICRP is requested to check consistency of phases against definition of “exposure situations”. Consider including the late phase in existing exposure situations. In this case, “Late” should be deleted from the title of this sub-section.

Paragraph 125:
• It is noted that there will always be assumptions and models at any time during the response. Text modified accordingly.
• Third sentence modified refer to planning of future action, not future planning.
(125) As an emergency exposure situation progresses, and understanding of the exact circumstances increases, decisions will increasingly be based on actual circumstances rather than only on pre-planned responses. As understanding increases, and the need to act becomes less urgent, there will also be an increased need plan future protection strategies in greater detail than included in the plan, and thus to involve the relevant stakeholders in decision framing and decision making processes when judging the justification of protective strategies, and when optimising their application. For this planning of future action, to deal appropriately with the situation at hand, a pre-determined reference level will be a useful tool… (etc)

Paragraph 126:
• Some text changes proposed; delete “worse”
(126) If, in application, protection options do not achieve their planned residual dose objectives, or result in exposures exceeding Reference Levels fixed at the planning stage, then a timely reassessment of the situation is warranted to understand why plans and results so significantly differed. New protection options could then, if appropriate, be selected and applied.

Stakeholder involvement in the implementation of protection strategies
Comment: The concepts of public vs. broader range of stakeholders, as well as information vs. dialogue are mixed. ICRP is requested to clarify this.

Paragraph 127: Modify the first sentence as follows: “Once an emergency exposure situation has occurred, there may be a need to direct stakeholders with regard to following the planned, urgent protective measures that need to be taken.”

Paragraph 129:
• ICRP is requested to clarify the last sentence. Does it really mean that two types of situations are managed in parallel for the same area? It is suggested to modify last sentence as follows:
(129) …“In the long term, however, as the emergency exposure situation transitions to an existing exposure situation, ongoing stakeholder involvement should become self-standing and independent.”

Feedback of experience
Paragraph 130: Suggest to combine this with the previous section on tuning of strategies

Termination of protective measures
Section 3.2: This section should also recognize that the termination of protective measures is also the outcome of an optimization process

Paragraph 131: There should be a clear message from ICRP that when protective measures are withdrawn, this should be accompanied by clear advice on what this means. Also need to ensure that there is no conflict with the long-term management. There needs to be consistent advice across the transition.

Paragraph 132: The first half of the paragraph is repetitious. ICRP is requested to edit this.

Paragraph 133:
• In the first sentence, ICRP is requested to clarify what is meant by relevant.
• In the second sentence, clarify that this refers to populations sheltered at home. If sheltered in a central location, then discussions may be possible.
(133) It is important to involve, wherever possible, relevant stakeholders in discussions regarding termination of protective measures. While it will be difficult, if not impossible to discuss decisions with populations sheltered at home, it will be essential to discuss decisions to return to evacuated areas with those who have been evacuated and the termination of protective measures implemented during the intermediate and late phases.

Transition to rehabilitation
• In the absence of the document on existing exposure situations, comments on Section 4: Transition to Rehabilitation cannot be provided. However, the concepts and wording here need to be consistent with the concepts in the other ICRP document.