|Comments on the ICRP foundation document (Individual)
This document is reviewed by Working Group of International Issues (WGII:Chairperson Keiji Oda), the Japan Health Physics Society(JHPS).
The five foundation documents provide no replies to the numerous comments(200 reports)@submitted in response to the previous yearfs consultation (no replies are given in these documents). The ICRP should provide answers in a specific form, not in the form of the five foundation documents, at least to numerous common comments such as constraints and the concept of intervention which many organizations including the Japan Health Physics Society (Working Group on International Issues) are concerned about. Holding an international conference to give an explanation about the results of the consultation for comments is crucial. The ICRP should make clear what parts of the documents have been changed and what parts are left unchanged in relation to the previous recommendations; and documents otherwise things will get mixed up.
If constraints are used in regulations, double standards by constraints and dose limits will be concerned about. Dose constraints should be ga tool of optimisationh, so they should not be used in regulations. The relation between dose limits and constraints should be written clearly in this document.
The concept of intervention is used in a gcontrollable existing situationh. The target of intervention is not a constraint but dose limit as written in Pub 60. This should be written clearly in the document.
Regulatory bodies or operators use constraints depending on cases. At least Commission does not provide values. So (S10) and (S16) should be deleted. The contents of two foundation documents gIndividualh and gOptimisationh should be adjusted. For example, the definition of constraints seems different between two documents.
In order to clarify the meaning of constraints, it is necessary to involve the expression that constraint is a tool of optimisation based on Pub 60. Otherwise, draft recommendations will bring the profound change into the radiological protection system.
The definitions of intervention and practice should be written clearly. In an accident (an emergency situation), the concept of intervention should be applied and an intervention level is recognized as a target.