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Submitted by Lynn Howard Ehrle, National Association for Public Health Policy(NAPHP)
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
 
The ICRP 2005 Recommendation is fatally flawed.
1. Nowhere in the document is there an estimate of the total number of radiographs worldwide. In 1964, the U.S. Public Health Service and the American College of Radiology estimated there were 500 million X-ray examinations.
No further national surveys have been performed. Worldwide, there are at least 2.5 billion diagnostic and therapeutic exams each year.
2. Nowhere in the document is there quantification of the increasing numbers of computed tomography(CT) examinations nor that Mettler and others now estimate that, in the U.S., about 67% of the total dose from all X-ray procedures is delivered by CT.
3. Nowhere in the document is there a discussion of the mutagenic impact of low-dose(as low as 10 mSv) in the pediatric age-band, including long-term non-cancer effects.
4. Nowhere in the document is there a discussion of conflicts of interest and their considerable imprint upon radiologic policy and practices.
5. Nowhere in the document is there recognition of wholesale violations of the Nuremberg and Helsinki requirements on "informed consent" as regards diagnostic X-ray examinations.
6. Nowhere in the document is there any recommendation to eliminate unnecessary or redundant X-ray exams, now estimated to be in the range of 20-30%.
7. Nowhere in the document is there any attempt to quantify the significant impact of genomic instability or the "bystander" effect.
8. Nowhere in the document is there a discussion of radiation risk vis-a-vis ischemic heart disease.
9. Nowhere in the document is there an expression of the necessity for additive/synergistic studies involving radiation and chemical agents.

THE DOCUMENT SERIOUSLY UNDERSTATES THE RISK FROM LOW-DOSE IONIZING RADIATION.

UNTIL THE ICRP INVITES INDEPENDENT NONGOVERNMENTAL ORGANIZATIONS TO SEAT ITS REPRESENTATIVES ON THE FULL COMMISSION AND WORKING GROUPS, ALL OF ITS DOCUMENTS WILL BE VIEWED WITH SUSPICION. iT IS NOW TIME TO OPEN THE ICRP ROLADEX TO INDEPENDENT SCIENTISTS AND POLICY ANALYSTS.

Lynn Howard Ehrle, NAPHP Senior Policy Analyst(age 72)
Member, National Writers Union, UAW 1981
Affiliate Member, Conference of Radiation Control Program Directors(CRCPD)