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Submitted by C. Osimani, AIRP (Associazione Italiana Radioprotezione)
   Commenting on behalf of the organisation
Document Reference animals and plants
Comments and points of view from the Italian Radiation Protection Association AIRP, on the Report ¡¥Environmental Protection: the Concept and
Use of Reference Animals and Plants¡¦ (Draft, Dec 2007)

General comments
The members of the Italian Radiation Protection Association AIRP and the Partner Societies thank the Commission for the opportunity to present comments and points of view on the draft report ¡¥Environmental Protection: the Concept and Use of Reference Animals and Plants¡¦. AIRP believes that in general and even more on the subject of environmental protection, the involvement of the end-users in drafting guidance is a very positive attitude. This offers the possibility to consider the depth and breadth of experiences of the end-users, and for an improved and greater attention during the implementation phase.

Within AIRP there is interest in the work in progress by the Commission and Committee 5 on environmental protection. However, the members' views can be described as discontinuous and controversial depending on the area of radiation protection. Of greater interest are the perceived ethical-social values. There are a wide range of opinions present within AIRP. This ranges from an enthusiastic appreciation of the ICRP efforts, after the publication of ICRP 91, to a complete disillusion of this new approach by the Commission. It is perceived that the intrinsic complexity of this material will make the implementation of any recommendations unpractical and unfeasible .

The Commission's aims are well defined ¡§..broadened its scope in order to address the subject of environmental protection. Its aims now include that of preventing or reducing the frequency of deleterious radiation effects to a level where¡K¡¨. This direction, which is based upon ethical and philosophical aspects and the need to be able to demonstrate full compliance with adequate environmental protection, is recognised as a brave approach in the light of the present understanding and knowledge of radiation effects on the biota. However, at the same time it will be easily criticized on the basis of lack of data.

AIRP internal discussions have shown that from one side the approach appears to be premature if scientific aspects are considered. However, if the concern and the critical attention given to the environmental protection is considered this approach is overdue,. Attention to environmental protection implies the need of a specific protection framework integrated within the existing radiation protection system. to define a political direction This may take a long time for effective international implementation.

Specific comments

A short glossary for the terms introduced in the report may be of help and needed. This excludes the terms related to biological description, but including the terms of specific interest for radiation protection (for instance DCF, rescaling factors, CSDA, morbidity¡KDCL, secondary reference animals and plants) Depending on the amount of work involved in this operation and if a more general distribution has been considered for this report a comprehensive glossary would be appreciated.

The inter-comparison for absorbed dose and absorbed fraction, calculated with different dosimetric approaches and presented in Appendix B for photons external irradiation was of great interesting. It could also be useful to have a similar inter-comparison taking into consideration different dosimetric approaches, for example in the calculation of absorbed dose rate per unit concentration for beta internal irradiation.

Paragraph 102, in EƒÒ < 10 keV the letter ƒÒ is missing. Some of the fi are in italics and others not. The percent fractions of the internal DCFs which are due to different type of radiation for internal exposure are indicated as f1, f2, f3. Note that in the contest of internal exposure of humans and in particular in the HATM, f1, f2,f3 ¡K are used for absorbed fraction of intake leaving different regions of alimentary tract with final destination the general circulation. If feasible, it would be less confusing to use different symbols/letters.

The introduction and meaning of DCL is well expressed and DCLs are suggested to be ¡§¡Kas points of reference at which one should consider what is known about the effects of radiation on particular types of animals or plants¡K¡¨ and ¡§ ¡K are NOT intended to be regarded as dose limits, or ¡¥substitute¡¦ values for them.¡¨ . Nevertheless the existence of such levels will initiate numerous discussions and interpretations. It would be greatly appreciated to have a supporting document, which could be as a result of cooperation among ICRP and other entities, presenting some typical and basic examples, , together with others factors following the decision processes, as tentatively listed in par 354.

In paragraph 147 it is explained that ¡§No attempt is made here to interpret such effects (referring to effects on individuals) at a ¡¥population¡¦ level because this would also require a detailed description, evaluation, and interpretation of the dynamics of a ¡¥model¡¦ population of each type in order for the data to be sensibly interpreted.¡¨. This question remains of utmost importance and prompt attention to it would be welcome.