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ICRP: Free the Annals!

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Submitted by Leonard R. Smith, Council on Radionuclides and Radiopharmaceuticals
   Commenting on behalf of the organisation
Document Radiological Protection in Security Screening
                                                                                                             November 8, 2012

Members of the Council on Radionuclides and Radiopharmaceuticals (CORAR) are major manufacturers and distributors, in Canada and the USA, that are worldwide suppliers of radionuclides, radiopharmaceuticals and sealed sources for medical therapy and diagnosis, environmental and biomedical research and industrial quality control.  CORAR members transfer many packages of radioactive materials across country borders that involve short lived radionuclides primarily for medical uses.  Delays in transferring these packages due to screening and potential denial of transfer can compromise the intended use.  CORAR members participate with the IAEA to identify delays and denials and minimize these by educating carriers and border controllers.
CORAR appreciates the need for the draft ICRP guidance on security screening.  However, CORAR is concerned that there appears to be no awareness or provisions for ensuring that the screening process does not inadvertently cause delays or denials.  We do, of course, appreciate that the primary purpose of the ICRP''s draft guidance is to optimize occupational and public radiation protection and security.  However, denials and delays of radioactive packages can potentially cause an increase in radiation exposure due to unnecessary handling and/or the subsequent need to ship replacement packages.  Moreover, delays and denials have a potential for adverse impact on the efficacy and cost of medical diagnosis and treatment.
CORAR therefore recommends that the ICRP guidance consider including mention of training requirements to ensure that operators performing the screening can recognize legitimate packages.  CORAR has made similar comments to the NCRP on similar guidance documents that are currently being developed.
CORAR appreciates the opportunity to provide these comments.

Yours sincerely,
Leonard R. Smith