Reference animals and plants

Draft document: Reference animals and plants
Submitted by Naoyuki Toyoshima, The Federation of Electric Power Companies
Commenting on behalf of the organisation

1. General Comment on the Whole Foundation Document This foundation document does not reflect many comments to the draft version of a new ICRP recommendation that was released last year. ICRP should issue answers in a concrete manner to many common comments. 2. Comment on Data Accumulation Paragraph 3 states that ionizing radiation is also one of the factors having adverse effects on the environment. However, it is necessary to accumulate scientific data in order to clarify if the effects on animals and plants in the environment are caused by radiation or chemical substances, etc. 3. Comment on the Selection of Reference Animals and Plants In the paragraph 37, 12 types of reference animals and plants are specified. However, the reference animals and plants should be selected after the related data is accumulated and after the examination on what kind of effects radiation has on animals and plants is conducted. 4. Comment on the effect on the Criteria for the Human Paragraph 3 states it necessary that the approach for the environmental protection shall be related as closely as possible to the current radiation protection system. However, if the reference value to the human that is recommended at present by ICRP is made severer from the viewpoint of the environmental protection, it will result in reinforcing the regulations and restrictions on the use of nuclear energy and on the utilization of radiation for medical treatments and agriculture, and it will affect men's life and economic activities. Therefore, the view on the criteria for the human and the view on the criteria for those other than the human should be clearly divided.