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Submitted by Rosemary Marcon, ARPANSA
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Australian comments on the Draft ICRP Recommendations – Part 1 of 2

Much of the Australian legislation that addresses radiation protection issues is based on the recommendations of the International Commission on Radiological Protection (ICRP). Therefore, the Australian radiation protection community need to give careful consideration to any proposed new ICRP recommendations. The following comments were prepared by the Australian Radiation Health Committee, a Committee formed under the Australian Radiation Protection and Nuclear Safety Act to advise the CEO of ARPANSA. The Radiation Health Committee is a national committee that includes a senior radiation protection regulator from each State and Territory and the Australian Government. The Australian Radiation Health and Safety Advisory Council also reviewed and added to the comments. The Council was also established under the ARPANS Act to advise the CEO, particularly on emerging issues in radiation protection and nuclear safety, issues of major public concern and on the adoption of codes and standards.

These comments are largely focussed on the possible impact of the draft Recommendations on current radiation practices. A key consideration has been whether any particular recommendation will produce a need to change current legislation and any associated regulatory guides. The need to justify the impact of possible regulatory changes through a regulatory impact (cost-benefit) analysis process has also been considered.

General Comments

• The openness of the approach adopted by ICRP with respect to its proposed 2005 recommendations is regarded as a progressive step and extremely useful.
• The intention of ICRP to clarify its guidance is welcomed. It is hoped that the final document will be able to be read as a standalone (and fundamental) document. The authors should be aware that this will likely be the first serious text on radiation safety that many people will pick up. Ultimately, it is likely to become a key resource on which many changes to radiation safety thinking and legislation will be based. While it is felt important that readers are made aware of the origins of the concepts in the document some of this content could be reduced and the readability could be improved if some sentence construction was simplified.
• The intention of ICRP to simplify the system(s) of protection and to reduce the number of criteria for protection is welcomed.
• The principle of justification is important and well established. While in general it is acknowledged that justification is a matter for governments and authorities broader than radiation protection, given that justification has been included as a fundamental principle in international radiation protection standards and guidance and in national regulatory documents for a long time, its removal means there is a need for careful explanation and guidance.
• It is also argued that changing this responsibility for judging justification does not reduce its value as a fundamental principle.
• The revised meaning of dose constraints is not clear and some parts of the document describing their use appear confused: further clarification is required.
• It appears that there will be a need for a number of constraints applicable to different situations. Such a change should be supported by more explanation and an indication of how constraints for particular situations could be established.
• Additional explanation to avoid confusion about the use of dose constraints in emergency response, including iodine prophylaxis would also be helpful.
• The basing of dose constraints and limits on multiples of natural background may not be accepted without considerable quantification and explanation. The previous approach with its linkages to risk was more scientifically-based and possibly easier to explain.
• The increased status given to industry-based dose constraints where the primary source of exposure is from a single source is cautiously welcomed. However, the potential complexities of implementing such a system are noted.
• The ‘disaggregated matrix’ that collective dose will become does not appear to be a simplification and could prove a source of confusion. While collective dose may aggregate information excessively, the new proposal currently receives only limited discussion and further explanation is considered necessary.
• The proposed framework for protection of the environment is noted, including the development of derived consideration levels for reference animals and plants, and that there is much further work needed in this area before specific recommendations can be brought forward.
• The Annex A explanatory text is clearly expressed and welcomed.
• Additional detail, setting out the various important changes between the 1990 and the 2005 recommendations would be useful.
• Regulators have commented that a clear rationale for ICRP’s changes is required, as without this rationale it will be hard, when trying to justify regulatory change through a regulatory impact analysis, to demonstrate that the difficulties (and costs) of implementing the new recommendations will provide commensurate benefits (reduction in risk).