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Submitted by Barbara L. Hamrick, Organization of Agreement States Executive Board
   Commenting on behalf of the organisation
Document Recommendations
I am writing on behalf of the Organization of Agreement States (OAS) Executive Board, to provide comments on the International Commission on Radiological Protection (ICRP) Draft Recommendations. The OAS Executive Board is appreciative of this opportunity to comment on this important document, and for the opportunity to have provided comments during the stakeholder dialogue on the draft 2006 ICRP proposals in Washington, DC, United States, 28 - 29 August 2006.

The OAS is a voluntary, scientific and professional society comprised of management and staff level representatives from those states (Agreement States) that regulate radioactive materials within their state borders under an agreement with the U.S. Nuclear Regulatory Commission (NRC). Our organization is committed to the improvement of radiation regulation and fostering cooperation and collaboration among the Agreement States and with the U.S. NRC and other Federal agencies to provide a comprehensive and coherent system of regulation of radioactive materials.

The comments of the OAS Executive Board are as follows:

1. The OAS Executive Board agrees with comments made by U.S. NRC Commissioner Peter B. Lyons in the Welcome Address at the stakeholder dialogue on August 28, 2006, particularly with respect to the need to provide stronger caveats regarding the use of the “collective dose” concept in an epidemiological context when examining large populations (or small populations across large geographical distances or long time periods) that are subject to low doses or low dose-rates. The uncertainties associated with these projections are such that estimates of projected cancer incidence (or mortality) may vary by orders of magnitude for the same basic event, depending upon how the population is selected and characterized, how the projected dose is estimated, and other relevant assumptions that must be made. These problems do not take into account the further uncertainty associated with the Linear No Threshold Hypothesis in the low dose or low dose-rate regions, which serves as the underpinning for these projections. Such projections are neither informative nor scientifically valid; therefore the OAS Executive Board recommends that the ICRP Recommendations include more definitive statements and examples regarding the inappropriateness of the use of collective dose in these situations.

2. The OAS Executive Board is concerned that the concept of “constraint” is not clearly defined as yet in the ICRP Draft Recommendations. If, as discussed at the stakeholder dialogue in Washington, DC, United States, a “constraint” is simply meant to be a planning tool, rather than an additional de facto limit, that should be clarified in the Recommendations. In particular, the text of the first paragraph in Section 5.8.1 (198) should be revised to more effectively reflect the intention of the ICRP (i.e., “constraint” is referred to in that paragraph as the “most fundamental level of protection,” which tends to imply, if not state out right, that it is meant to function as a limit). The OAS Executive Board also suggests, in this regard, that consideration be given to a more appropriate term, such as “planning value,” since the term “constraint” tends to imply “limit” in the English language.

3. The OAS Executive Board is a strong proponent of public education on issues related to radiation and risk. In particular, in the context of the malicious use of radioactive material, public education in advance of such malicious use will be the cornerstone of an appropriate and effective response. It is the opinion of the OAS Executive Board that consideration should be given to including a recommendation that public agencies include advance public education on radiation and its related risks in planning for potential malicious uses of radioactive material. Advance public education can serve to avert both panic and the inappropriate diversion of medical resources by affected persons at low risk of harm from the incident.

4. Finally, the OAS Executive Board is concerned that the proposed efforts related to the protection of the environment (Section 10 of the ICRP Draft Recommendations) are premature. While the OAS Executive Board agrees that attention should be given to this important issue, the initial steps should include a clear presentation of the goals. These might range from the extreme of having “no impact” on any given ecological system, to protecting individual biological organisms (whether animal, plant, fungi, protist, or moneran) from deterministic or stochastic effects, to protecting populations from significant genetic impacts, to protecting the health and diversity of a defined ecosystem, to protecting populations from extinction. It is the OAS Executive Board’s opinion that the proposed approach (to define “reference species” in a manner analogous to “reference man”) suffers from a natural tendency to anthropomorphize our environment, and fails to address the more fundamental questions of what is intended to be protected (i.e., individuals, populations, or ecosystems) and from what harm (i.e., death, increased risk of death, genetic harm, reproductive harm, or an ecosystem change of any kind). The OAS Executive Board also believes these fundamental questions should be addressed in partnership with other organizations in the context of all potential environmental damage (e.g., from chemical hazards, or development and construction). Issues related to the protection of the environment are not unique to the field of radiation protection, but embrace all impacts that humankind has upon its neighboring life forms. The big questions should be answered first and goals better defined before we expend any significant effort trying to answer questions that may become irrelevant.

Thank you again for this opportunity to comment.

Barbara L. Hamrick, CHP, JD
Chair, Organization of Agreement States