Draft document: Recommendations
Submitted by Rudolf Alexakhin, Russian Institute of Agricultural Radiology and Radioecology
Commenting on behalf of the organisation

In connection with the new Draft of the ICRP basic recommendations (previously termed Recommendations 2005), I'd like to express my views on the section related to Chapter 10 "Protection of the Environment". It is given 7 paragraphs (351-357) in the Draft. The appearance in the basic recommendations of a special section on radiation protection of the environment (biota) is, certainly, a positive phenomenon. This section was absent in the previous 1990 recommendations (Publication 60). It reflects the tendency of growing ICRP interest to problems of radiation protection of the environment. Actually, the sphere of ICRP influence extended from man to nature protection. In recent years the ICRP has made several real steps towards this direction (in particular, Publication 91 has been issued and separate committee, C5, within the ICRP structure has been established). Evaluating the incorporation of Chapter 10 into the Draft ICRP Recommendations as obviously positive step, I'd like, however, to make some essential comments. Really, only 7 paragraphs are too little for the problems of radiation protection of the environment. The problem needs to be highlighted in a more detail. Even in the ICRP itself there are much more materials on the problem. The Draft lacks the description of the essence of the problem: what is radiation effect in nature, what are specific features of the course of radiation effects, dose dependences? No data are presented on the radiosensitivity of the major ecosystems of the planet. Remains undefined what and in which way needs protection in nature against radiation effects. In recent years the ICRP activity is being oriented towards the formation and support of the ecocentric approach to radiation protection of the environment (as opposed to the anthropocentric thesis - protected is man, protected are the biota, according to ICRP Publications 26 and 60). Although paragraph 353 confirms that this postulate is valid "…the Commission continues to believe that this likely to be the case". Orientation to ecocentrism in a scientific aspect is, in our opinion, beyond question. From the point of view of a real pragmatism, one can, however, imagine what great economic difficulties may arise from the introduction of ecocentrism. It means that for each facility that contains radionuclides reference living organisms need to be determined (and this is under their huge variety), necessary for which is knowledge of dose dependences; then arises a problem of regulation (standardization) of radiation effects on biota, etc. And all this with the correctne ss of the anthropocentric principle. It is unlikely that such ICRP strategy in the biota protection against ionizing radiation will be readily supported by practical operators and managers of nuclear power engineering and industry. I nevertheless repeat that in a scientific aspect the idea of ecocentrism should be subject to analysis and evaluation. My vision of ICRP Recommendations 2005 is a compilation of practical advices and scientific description of problems. From this point of view the whole subsection 10.2 "Reference Animals and Plants" is a technical description (generally necessary and correct) of a future work of the ICRP (to be more exact Committee 5). At the present stage it is preparation of recommendations, it isn't guide for action. Overall, in our opinion, reading of section 10 "Protection of the Environment" puts many questions in the reader and user and gives few answers. At the same time, in general assessment one cannot but indicate a whole range of positive and needed positions. To summarize, it is necessary to include in the ICRP Recommendations the chapter "Protection of the Environment".