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Submitted by José Gutiérrez, Spanish Radiation Protection Society
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation

( PART 1)


1. It is essential that the document clearly identify the bases (both the scientific as well as the “operational”) supporting the new recommendations now being offered, as well as the extent to which those bases supporting the radiation protection system recommended to date are maintained or modified.
Likewise, the document should identify, without any shadow of doubt, which recommendations currently in force remain valid and which are changed or simply clarified.
This might be achieved in the “Introduction” to the document, although it would be necessary for the subsequent development of the text to be coherent with it.

2. The text of the document includes an announcement of the subsequent publishing of an appreciable number of additional explanatory documents. Since the starting point in this respect is a basically stable situation as regards the radiation protection system recommended by the ICRP, it would appear to be necessary for the publishing of these documents to take place before (or in combination with) the publishing of the new recommendations.
3. It is necessary for the text to be carefully controlled in order to ensure the coherent use of various terms of great relevance when applying the radiation protection system: “controllable source”; “controllable exposure”; “occupational exposures”; “normal situation exposure”; “practice”; “exclusion”; etc.
In addition, the introduction of new concepts or of new terms for concepts already in existence and widely accepted should be avoided unless absolutely essential.
4. The recommendations now presented include a dual degree of discretion in their application: on the one hand they are less rigid than the current recommendations in various aspects, and on the other they explicitly recognize the existence of wide margins for the users.
The sum of these two characteristics introduce a high risk of losing the excellent degree of harmony achieved and currently existing at international level, which is considered to be an important asset of the radiation protection system and of the role played by the ICRP within it.
5. As a consequence of the comments above it seems reasonable to further reconsider the date now foreseen for the publication of these recommendations. It looks like additional significant efforts should be devoted first in analysing and in ensuring that their publication will bring about the positive effect desired, as well as to resolve consequently many of the difficulties posed by application of the current system.