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Submitted by Peter Marsden, Association of University Radiation Protection Officers
   Commenting on behalf of the organisation
Document Recommendations
Consultation Response from the Association of University Radiation Protection Officers (AURPO).
The AURPO is grateful to the ICRP for presenting these draft recommendations and giving the opportunity for consultation. We are in broad agreement with the principles laid down in the latest document and consider the clarity to be an improvement on the previous draft. We do, however, have some general and specific comments to make.
Perhaps in response to the comments on the first draft, some aspects of the recommendations are described several times. Whilst this makes the cover-to-cover reading somewhat repetitive, it does help those readers wishing to look up a specific item to get their information in proper context. However, the true meaning of some concepts, most importantly dose constraint, can only be fully grasped by reading the bulk of the recommendations.

1. Introduction
The suggestion in paragraph 12 that national legislation will not need to change is welcome. However, there are several references to dose constraints being set at a national or local level (eg. Paragraph 211). A national dose constraint can only be legally binding if it is set using legislation. Various professional bodies might be willing to recommend national dose constraints, but do not have the authority to impose them.
Paragraph 18 refers to a system of assessment but it is not clear what is being assessed.

2. Aims and Scope
We are pleased to see the principles of justification, optimisation and limitation are continued.
Paragraphs 30 and 33 between them cast uncertainty on the purpose of dose constraint as an optimisation tool. We accept the use of a constraint as a prospective planning tool, but if planning exposures to be less than a given constraint is insufficient and ALARA prevails, does the constraint serve any practical purpose? It is in danger of becoming a source-related dose limit, especially if its value is determined at a national level.
In general we agree with the content in sections 2.3 and 2.4 on scope, exclusion and exemption. The first bullet point in paragraph 45 may need clarification. Does the 10uSv refer to a source in the absence of any control, or after control has been put in place?

3. Biological Aspects
We are happy with the consistency in approach. No further comments.

4. Dosimetric Quantities
We welcome the recommendations on use of dose quantities, particularly the proper use of effective dose highlighted in paragraphs 139 – 144 and the limitations of collective dose in paragraphs 145 – 148.

5. System of Radiation Protection of Humans
The three types of exposure situations described in paragraph 162 are potentially confusing. In particular, the distinction between planned situations and existing exposure situations is not clear. Our interpretation is that a planned situation is either an existing situation where control has been applied, or a future situation to which control will be applied. However, taking the title “planned” alone, this could be taken to mean future situations only. More disturbingly, “existing situations” could be taken as meaning any exposure situation which exists now, whether it be controlled or not, whereas we believe the intention is that it only applies to situations where the exposure already exists but the control does not. This confusion might be reduced if the situations were given different names. As it is the presence or lack of control which distinguishes these two situations, we recommend that their names reflect this, rather than the misleading implication of present or future situations.
Paragraph 171 distinguishes between workers in controlled areas, and “other workers, such as administrative and support staff” who are treated as members of the public. This theme appears again in paragraph 395. Although UK legislation does not make this distinction, universities, in common with most other users of radiation, do follow the principle of treating employees who do not work with radiation as members of the public when planning facilities and applying constraints. However, making the distinction between radiation workers and non-radiation workers would be very difficult to enshrine in law. For instance, most university users of ionising radiations receive annual doses less than the public dose limit, but we still regard them as radiation workers.
Paragraph 175 does not explain the difference between a member of a critical group and the new concept of a representative individual. Further clarification would be helpful.
Section 5.7.1 provides a good description of the Principle of Justification.
The final sentence of paragraph 201 should clarify whether it refers to dose constraints in general, or only those in emergency or existing exposure situations.

6. Medical Exposure of Patients
Could the wording in paragraph 264 be changed by adding “unless pregnancy is an integral part of the research. In these cases strict controls should be placed on the use of radiation for the protection of the foetus.”
Paragraphs 267 and 268 refer to volunteers for research. Whilst these volunteers are normally patients, they are not exclusively so. Similarly, one would not describe the individual exposed for medico-legal purposes as a patient (paragraph 269). Should the title of this chapter be reduced to “Medical Exposures” to take account of these exposures to persons who are not patients?

7. Exposure to Natural Sources
No comments

8. Potential Exposures
We agree with the Commissions approach to potential exposures.

9. Emergency and Existing Situations
Please refer to earlier comments on the term “existing situations”.

10. Protection of the Environment
No Comments

11. Implementation
We find this chapter particularly valuable and clear in its description of how the recommendations should be implemented, both at a national and organisational level.

This ends our comments. Thank you.