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Submitted by Anne Nisbet, Public Health England, Centre for Radiation, Chemical & Environmental Hazards
   Commenting on behalf of the organisation
Document Ethical Foundations of the System of Radiological Protection

General comments

This is an informative report for radiation protection professionals who do not have a background in ethics. The document has a good structure and is generally well written and provides the right level of detail. It provides useful insight into the evolution of ethical and social values in radiation protection. It distinguishes between core ethical values and procedural values, which adds clarity and understanding. The Annexes however, are less relevant to RP professionals and the authors should consider excluding Annex C from the report as it strays into subjective discussion of popular religious texts.

Specific comments

Line 104 – consider ‘longstanding’ rather than ‘long’

Line 226 and elsewhere, there is mention of ‘deterministic effects’ - should these now be referred to as ‘serious tissue reactions’?

Lines 226 – 229 (and elsewhere) there is mention of deterministic effects being prevented. This is a little strong – ‘wherever possible’ should be considered as an alternative. In interventional radiology, there are circumstances where, prior to the procedure beginning, it is clear that there will be deterministic effects but the procedure goes ahead anyway because the condition is life threatening. This example raises a range of ethical questions that might have been explored in this document (or perhaps a future document focussed on medical exposures).

Line 338 – The ICRP TG92 (terminology and definitions) recently proposed the following slightly different definition on precautionary principle: ‘Precautionary principle: To put in place measures to prevent or reduce risks, when science and technical knowledge are not able to provide certainty, mainly in the field of the environment and health’.

Line 492 – there is reference to Fig 2.  However, there is no Fig 1 in the report, so this figure number needs to be changed.

Line 500 – consider ‘ethics’ to replace ‘ethical and social values’ in the second box of the figure (this is then consistent with Line 1139 in the conclusion. The other boxes already have abbreviated terminology.

Line 502 – amend to Fig. 1.

Lines 651 – 654 refer to stakeholder engagement when optimising protection. In medical exposures, there are well developed views about stakeholder involvement in individual justification – consider referring to WHO as an example.

Line 652 – ‘decision’ should be replaced by ‘decisions’

Line 671 – suggest ‘with the application of dose restrictions’

Lines 691 – 693  The ICRP TG92  suggest the following ‘The principle of application of dose limits, which declares that the total dose to any individual from regulated sources, other than medical exposure of patients, should not exceed the appropriate limits recommended by the Commission’

Line 696 – implies dose limitation applies to all exposure situations, not just planned.

Lines 762 – 763 The sentence ‘Prudence therefore has a direct relationship to action and practice’, does not make sense and may be superfluous. Suggest delete.

Lines 786 and 788 refer to doses of 100 mSv but it is not clear when taken out of context that these refer to effective doses. Suggest add ‘(effective)’ before the word ‘doses’ in both sentences.

Lines 830 – 841 address justice. Distributive justice is fairness in the distribution of advantages and disadvantages (according to the text). Lines 836 – 838 then talk about limiting individual exposures but for medical exposures, fairness means access to appropriate examinations and for many parts of the world this means increasing the number of exposures, while accepting these should be optimised.

Line 834 remove the ‘and’ before ‘fairness’, otherwise the sentence doesn’t make sense.

 Line 843 would suggest replace ‘protection measures’ with ‘protective measures’ to be consistent with other references in the text.

 Lines 847 – 848 describe RP criteria as seeking to address individual exposures that are higher than the average. However, most reference levels are not expressed in relation to population averages but in terms of absolute levels of individual exposure. Might it be better to refer instead to ‘higher’ (or ‘high’) exposures?

 Lines 863 – 864 refer to “the two principles of social justice”.  Online resources suggest that there may be multiple ways of framing principles of social justice, rather than the two chosen for the document.  Perhaps refer to “two principles” not “the two principles”?

 Lines 865 – 866 state that “the principle of equity in the situations reflects the personal circumstances in which individuals are involved”.  It is not obvious what this means. 

 Lines 866 – 867 refers to ‘reduce the range of exposure’ – might it be less ambiguous to say ‘reduce the magnitude of individual doses’?

 Lines 867 – 868 state that adherence to the principle of equal rights ‘guarantees equal treatment for all with regards higher levels of exposure’.  This argument is not very clear and, again it is not clear that it applies equally when looking across different sources of exposure. In many countries there is no ‘right’ not to be exposed to very high levels of indoor radon exposure.  There may be obligations or requirements on property owners etc. but these are not the same as rights conferred on those who are exposed. ‘Guarantee’ is quite a strong word to use here – possibly too strong – maybe better to express as ‘implies’ or ‘expects’.

 Line 870 expresses dose limits in terms of ‘the level of risk deemed tolerable…’ in general terms.  This should be qualified with reference to “…the tolerable level of risk from relevant sources of exposure…” since dose limits do not apply to some sources of exposure.

 Line 892 states that every individual deserves unconditional respect.  However, the text immediately following this, gives a list of human attributes that could be interpreted as definitive.  There is at least one attribute (sexual orientation) that is usually included in such lists but is not in the current text. It might be more helpful if the text referenced some personal attributes as examples rather than establishing a definitive list. Text might be ‘... respect, irrespective of personal attributes or circumstances such as age, sex....’

 Line 893 - One of the items listed (social condition) is not clear in its meaning and might be misinterpreted.  Could this be clarified? Was the intention to refer to socio-economic status perhaps?

 Lines 895 – 899 cite Kant (1785) as an example of one ethical theory on dignity. Suggest this is too detailed. Truncate sentence as follows ‘Dignity has a long history as a central value in many ethical theories’. Do not include quotes from Kant.

 Line 929 – this is the first time that the concepts of reasonableness and tolerability are introduced - there needs to be mention of these concepts earlier, perhaps under ‘evolution of the system of radiological protection – end of section 2.5’.

 Line 995 – delete ‘similarly’

 Line 1009 – replace ‘protection actions’ with ‘protective actions’ for consistency with line 1015.

 Lines 1052 – 1054 discuss ‘the right to know’.  The context used to exemplify this is information about health and safety in the workplace.  This is extended to ‘…the environment of communities’.  This is not a frequently used phrase so does not lend itself to clear shared meaning. In some contexts, there may be an ethical obligation around privacy. In the context of radon in private dwellings, in many countries it is accepted that information about radon levels (and presence of any mitigation system) is not required to be published, although some jurisdictions may expect radon information to be provided to prospective purchasers, perhaps as part of the commercial transaction. There is an underlying ethical basis for this referenced in Line 1021 which references ‘the involved parties’.  In the case of radon in a private dwelling, the involved parties might be the property owner, the occupants (family, lodgers, tenants etc.) and prospective purchasers.  It would not seem appropriate to include the general public or occupants of neighbouring properties as “involved”. The disclosure aspect might be more clearly represented if it were applied to ‘…the shared environment of communities’, perhaps with some examples.

 Line 1071 – replace ‘operationalised’ with ‘is applied in practice’

 Line 1141 – add a comma after justice otherwise it is not clear that there are four core ethical values.

 Line 1143 – Suggest adding ‘harmful’ before effects. Also the sentence does not refer to the benefits that may be considered.

 Line 1148 ‘sources’ should be ‘source’.

 Line 1152 may be clear to radiation protection experts but it does no clarify that stochastic effects are health effects and the no threshold assumption relates to the assumption that radiation risk is assumed to be linearly related to dose received. As this sentence forms part of the conclusion, it may be helpful to clarify here.

 Line 1165 – for a given ‘planned’ exposure situation and category of exposure

 Line 1176 – consider replacing ‘structuring’ with ‘overarching’

 Line 1191 suggest adding ‘as low as’ before ‘reasonably achievable levels’

 Line 1193 – consider replacing ‘enlarging this aim’ to ‘enlarging the scope’

 Line 1195 – ‘situation’ should be ‘situations’.

Comments from:

Neil McColl

Steve Ebdon-Jackson

Antony Bexon

Anne Nisbet