ICRP2005-Recommendations Comments of the German-Swiss Association for Radiation Protection Summary: The FS appreciates the important role of ICRP and welcomes explicitly the activities to review regularly the recommendations and to contribute to their further development. But - the present proposal does not achieve those improvements (simplicity, transparency) for the conceptual or the practical radiation protection, which would justify the efforts needed for the realization of these recommendations. -the announced foundation documents are so substantial that the further discussion of ICRP2005 should wait until these are published Therefore, the FS recommends summarizing the relevant quantitative changes in the form of an addendum to ICRP publication 60. Comments and Proposals 0. General Aspects 0.1 Repeatedly earlier ICRP-publications are referenced (including ICRP 60), but it remains unclear, which part of these recommendations are still valid, and which are obsolete. Proposal: Clarification 0.2 The mixture of historical reviews, comments of earlier ICRP-positions, new scientific results with more philosophical aspects makes it difficult to identify the relevant changes and requires the simultaneous reading of several other ICRP-publications. Proposal: There are two alternatives, the second of which is preferred by the authors of these comments: - All recommendations being effective in 2005 are completely summarized in a comprehensive (but shorter) text. All other information regarded as necessary is summarized in a separate part. Or -Summarize in a much smaller publication the essential innovations. 0.3 There is little reflection whether the terms used are easily translatable into the most important languages. Severe problems are foreseeable for translation. Proposal: The members of the ICRP international bodies should be asked to propose translations into their national languages, thus ensuring that the problems are identified in time and that the intentions of the commission are met without the possibility of misinterpretations. 0.4 There is no chapter giving definitions of essential terms such as „normal situation“, „controllable“. As these terms will be in the centre of many discussions the compilation of the definitions in one chapter would be helpful. Proposal: Add a glossary 0.5 Some texts, tables or figures show quantitatively the differences in comparison to ICRP 60, others do not. (e. g. Fig 1 vs. Table 2). Proposal: Improved uniformity 0.6 The chapters / sections are not sufficiently coordinated and aligned. Further the use of important terms is not unified. E. g. important aspects discussed in Chapter 4 are of relevance already in Chapter 3. Other example: In (185): nominal detriment, In Table 6: nominal detriment coefficient, In (113): nominal risk coefficient Proposal: Substantial revision aiming at more harmonization of the whole text. 0.7 There are no clarifying texts on intervention Proposal: Add advice on intervention measures. 1. Chapter 1 1.1 Dispensable, a description of the ICRP’s claim and tasks would be more helpful Proposal: Omit history; add a part defining the legitimization and claim of ICRP. 1.2 (8) does not fit here into this context. Proposal: Move (8) into Chapter 2 aiming at a clear description of the objectives and basis of the recommendations. 2. Chapter 2 2.2 (15) the term „controllable“ is explained by using nearly the identical term (“can be controlled”) Clarification (in a glossary) 2.2.(18) Even though it still is looked at as an important prerequisite for radiation safety: the formulation here leaves it unclear whether justification is still one of the fundamental principles. Proposal: State explicitly in Chap 5 that justification is an important principle for all controllable practices. 2.2 The commission abandons the recommendation of methods for justification. But it would be helpful to have common criteria for justification. Proposal: Define criteria for justification (maximum individual exposure, waste disposal, risks associated with alternative practices, cultural and local circumstances, …) 3. Chapter 3 The introduction of the new term („Radiation weighted dose“) does not mean any real improvement with radiation safety but means real efforts and costs (training, instruments, …) and also uncertainties among the users. The adaptation of the tissue weighting factors is explicitly welcomed. 3.2 (40): The referenced Section 3.6 is not existent Presumably reference to 3.5.2 3.5 unclear headline: „application“ of what? Proposal: Practical application of radiological quantities” 3.5.1 (93) such announcements of future activities are not needed Proposal: To be omitted 4. Chapter 4 4.2.4 (105): The justification of DDREF is not sufficient. Proposal: Improve the scientific argumentation 4.2.4 (118): The term „prolonged“ must be quantified and it must be clarified that the mother’s dose is meant (“about 100mSv”) and not the dose during pregnancy. Additionally, the notion “well below about” sounds strange. Proposal: Clarify. 5. Chapter 5: 5.1 (126)+(127) dispensable, 5. 1 (127) constitutes that isolated exposures can be treated separately, that there is no need to take into account the network of exposures. Proposal: Omit (126)+(127), head line „Introduction“ in accordance with other chapters 5.2 The need to justify is no longer mentioned. Proposal: Introduce justification as a principle of radiation safety. 5.2 Fig. 2: The figure is misleading and not understandable without further discussion Proposal: Omit or revise 5.2 (137) the term “risk constraint” was not defined before. Proposal: Reference to glossary or chapter 10 5.3.2 (145) requires repeated reading before it is understandable Proposal: reformulate 5.3.3 (147) radiotherapy is not always “voluntary” Proposal: With the patient’s consent 5.4 These remarks do not deal with the application and thus reduces readability. Proposal: Move this section to earlier chapters. 6. Chapter 6 6.1 Fig. 3:The figure is in conflict with parts of the text: e.g. in the fig “low” is well below 0.01 mSv, while in (164) 0.01 mSv indicates a “low need for action” Proposal: Adapt the figure to the texts 6.3 Dose constraints are formulated as „maximum values, which can be reduced by the regulator. Proposal: Guidance should be given, in which cases regulators could define dose constraints below the „maximum” constraints. 6.3.1 (173) Pure announcements of future results do not provide the help needed here. Proposal: Integrate the results of Cte 4 here 6.3.3 (175): The formulation of the whole chapter could be more precise. The policy of ICRP means, that the protection of women, and in the consequence of sentence 1 also of men, must aim at the observation of a limit for the members of the public.. Thus it remains an important question: Are measures in the case of non-pregnant women required to protect a “future” embryo? This may be complicated in the case of radionuclide incorporations preceding a pregnancy. Further, a monthly dose limit for external dose could be expected to limit the embryo’s exposure to 1mSv (as a member of the general public). Proposal: Formulate in a way excluding misinterpretation. Clarify: does “may be pregnant” mean that there is a suspicion that…. 6.3.3 (176) “high accidental doses” is not quantifiable Proposal: Only accidental doses 6.4 (178) wrong reference to (146) Proposal: resolve 6.5 (181, 182) only of interest for historians Proposal: Omit 6.6 (187)(188) topic of Chapter 7 Proposal: Use as “Introduction” to chapter 7 7. Chapter 7 7.1The importance of stakeholder involvement for the optimisation process is considerably increased. The responsibility for optimization is not clear Proposal: Clarify the operator’s responsibility for the optimization. Give practical guidance for this process, including quantitative treatment of optimization. Prevent conflicts among competing interests by reducing the significance of stakeholder discussions. Proposal: There should be defined values at which optimization of radiation protection is completed. 7.2 (197)-(200): Here the collective dose is extensively introduced and then it is qualified as unnecessary and not useful Proposal: Omit all definitions of collective dose and only restrict to judgement as in the first sentence of (200). (201, 202): As the much abused "collective dose" has been replaced here by a better defined concept, the change should be underlined by a different, more appropriate name. Proposal: Use "Group Dose" instead 7.2 (203): The recommendations of the “foundation document” are so substantial for the whole system that there is no possibility to publish the draft ICRP2005 without the announced Cte4 recommendations Proposal: The publication of ICRP2005 must wait until committee 4 published the “foundation document” 8- Chapter 8 Exclusion Levels are specified only for the most hazardous nuclides. Proposal: It should be clarified that the recommended Exclusion Levels are the lowest ones derived from the most hazardous radionuclides. For other radionuclides higher Exclusion Levels should/can be derived radionuclide specifically. ICRP should give guidance from what dose constraint such Exclusion Levels should be derived (e. g. some 10 µSv). 8.1 and 8.2: any number of activity concentrations is useless without any definition of averaging mass. Proposal: Clarify definition by giving a mass for averaging 9. Chapter 10 10 (234) The chapter is not sufficiently precise; the uncertainties result in a reduced applicability for practice. The earlier described safety culture makes sufficient allowance for these concerns. Proposal: Reduce the chapter to two paragraphs, one stressing the need for safety culture in all practices, the other pointing out the need for comprehensive emergency planning and preparedness at all levels. 10. Chapter 11: ICRP questions the position that the current system of radiation protection for human beings also provides an appropriate standard for environmental protection. Relevant influence regarding protection of non-human species is the radionuclide release into the environment, not the dose model. Including protection of non-human species into new ICRP recommendations seems to be a break in philosophy. On the other hand the influence of chemical toxicity of substances (including radioactive substances) released into environment must be considered, and the gap of knowledge in this field seems to be too large to include the protection of non-human species into ICRP recommendations at present time. The new approach is premature, not only because the topic requires sociological and political discussions before treating radiation protection in detail; further, the scientific basis is still inadequate. The approach is also not necessary, because it fills at most a theoretical conceptual gap, far away from the practical necessities.