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Submitted by Yoshikazu Kumamoto, Retiree from the National Institute of Radiological Sciences, Japan
   Commenting as an individual
Document Recommendations
Thank you for letting us to comment on the new ICRP draft. Compared with the ICRP Publication 60 and the former draft, the texts are more understandable for us (A Japanese) and many terms are described more clearly.

- We think that the Chapter construction of the ICRP Pub 60 is better than that of the present draft in terms of form. The chapter of the exclusion and exemption, of the history of the recommendations and of the description of the reason why the changes have been made are better placed at the end of the draft. The Recommendations should stand alone. The referring to the annex and to the old documents is to be required only when detailed information are needed.

- In (93), it is very nice that the unit of the absorbed dose for tissue reactions is recommended. We propose the name for this quantity, “tissue reaction dose” or “deterministic effects dose”. Further, when neutrons are concerned, it might be necessary to use RBEs more than one, so we propose the unit "gray-equivalent" be used for tissue reaction dose. The temporary RBEs for tissue reactions should be recommended. We propose 2 for neutron and 5 for alpha particle exposure, based on the open literatures.

- (99) Because matters concerning radiation need to be frequently explained to the general public, we think that easy understanding of radiation is important. We propose "Morgan" for the unit of the equivalent dose and "Mg" as an abbreviated form. It is confusing if values of the equivalent dose and effective dose have the same unit after the equivalent dose is multiplied with the tissue weighting coefficients, even though the same unit is mathematically correct.

- In (114), it is said "The wT for the remainder tissues (0.12) applies to the arithmetic mean dose of the 14 organs and tissues listed in the footnote to Table 4.", and in 120 "The current remainder formulation specifies 12 tissues common to both genders and one gender-specific tissue in each gender (prostate in the male and uterus/cervix in the female) for a total of 13 tissues." The latter is understandable, but the former is a little bit confusing.

- Paragraph (163) is difficult to understand. Is the terms 'practices' and 'interventions' to be abandoned hereafter?

- The important terms should be explained when they appear for the first time. For example, the description such as, “The Commission has specified dose limits for exposure to members of the public in planned situations.(174)” should be described when “dose limits” appears.

- In Table 5, “The annual equivalent dose for organs other than lens of the eye, skin and hands and feet should be less than 100 mSv” should be added as a note. When the only one organ, for example, the gonads is irradiated, 20 mSv/.08=250 mSv. This is larger than 100 mSv per year recommended in the draft.

- If the description, “tissue reactions (also called deterministic effects) “, is used, then “cancer and hereditary effects (also called stochastic effects)” should be adopted.

- Give the definition of “emergency” and “accident” in the Glossary. Which encompass which?

- “Stakeholder” should be included in Glossary. Does the term include people who oppose the use of radiation?

- We think that “dose limits” is more basic than “constraints” in the safety system. When the values of dose constraints at the border of a radiation facility and behind a shielding wall are fixed, the dose limits, 20 mSv per year for the workers and 1 mSv per year for the public, will be starting points to realize the safety at the corresponding points.
By the way, if “constraints” is accompanied always with “dose” or “risk”, it will be very easy to remember what the terms mean.
Further, the term, “constraints”, gives a strong impression to us. So is it not possible to use “limits” instead of “constraints” as “source dose limits” and “source risk limits”?