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Submitted by Sarah Darby & Alastair Gray, University of Oxford
   Commenting as an individual
Document Radiological Protection against Radon Exposure
 

Comments on ICRP Radon Consultation


Sarah Darby and Alastair Gray


 


The statement that radon policy should be formulated from a public health perspective [para (h) of Executive Summary] is to be welcomed, as is the observation that an efficient national radon protection strategy needs to focus on reducing the radon risk of the general population over several decades via planning, design and construction of buildings [paras (t) & (v ) of Executive Summary and para (91) & Figure 6 in main text].  We also welcome the comment that the implementation of preventive measures in new buildings can often be cost-effective [para (46) of main text] and note that  additional references in which the cost-effectiveness of radon preventive measures is demonstrated are Gray et al (2009) and  Health Protection Agency (2009). Details of these references are given below.


We are, however, puzzled by the statement ‘Remediation in existing buildings is also often cost-effective’ [para (47) of main text].  It is notable that no reference is given for this statement and, in fact, Gray et al (2009) and  Health Protection Agency (2009) both concluded that remediation in existing buildings was rarely cost-effective.  We suggest that para (47) be either removed or  else reworded to a statement that that can be justified and that appropriate supporting references be provided.


We also question the prominent role given to reference levels and dose limits in the document [paras (l)-(r) of Executive Summary and several places in main text].    As is illustrated in the figure below, the overwhelming majority of radon-related lung cancers occur following exposure at relatively low concentrations.  Therefore, attempting to place radon within the traditional ICRP framework, including the recommendation of reference levels and dose limits, seems unlikely to further the stated aim of reducing the radon risk of the general population over several decades.   Rather, it is likely to divert a disproportionate amount of effort towards identifying the few individuals who exceed these levels.


 


Sarah Darby, Professor of Medical Statistics, University of Oxford


&  Alastair Gray, Professor of Health Economics, University of Oxford


 


 References


Gray A, Read S, McGale P, Darby S. Lung cancer deaths from indoor radon and the cost effectiveness and potential of policies to reduce them. British Medical Journal 2009; 338: 215-218.


Health Protection Agency.  Radon and Public Health. Documents of the Health Protection Agency RCE-11. Health Protection Agency: Oxfordshire. 2009.




Numbers of radon-induced lung cancer deaths in the UK each year by long-term average radon concentration at home (from Gray et al, 2009).