|1. General Comments
2. The ICRP system of protection for humans is based on the protection of INDIVIDUALS. The protection of non-human species is based on protection of biodiversity and breeding populations (ie, the ecosystem), NOT individuals. There is therefore a fundamental incompatibility between the approaches for humans and non-human species. The document pays lip service to this difference but then goes on to try to develop “Environmental Reference Levels” that are effectively dose limits for individuals of non-human species.
3. Given the difference in approach for humans and non-human species, the idea of a system of environmental protection that runs in parallel to the existing framework of protection is fundamentally flawed. Additionally, the ICRP’s approach generates an entire framework that is difficult to implement and based on data sets that are lacking significant proportions of data. In these circumstances, it seems premature for ICRP to issue guidance for non-human species as the available scientific data is sparse and relates to effects on individuals rather than effects on populations and ecosystems. It is recommended that this document is substantially revised to reflect these limitations, and consideration is given to withdrawing the requirement for “Environmental Reference Levels”.
4. It is recognised that there is little research or information regarding the effect of radiation on ecosystems or at species level. The entire document seems to be based on the very academic research of a small number of authors and some previous ICRP papers (and there is significant vaunting of these documents throughout the paper). Indeed, the scientific independence of ICRP could be questioned because the key papers quoted are largely written by the ICRP members who then produced this document. There would appear to be little independent scrutiny of the opinion of a few researchers with vested interests in this field.
5. The document attempts to create an environmental equivalent of “Reference Person” and “Representative Individual” even though these concepts do not fit well with an ecosystem approach to protection. However, there are significant portions of data missing for the reference animals and plants and it is difficult to see how any reliable ICRP guidance on this matter can be developed from such limited data. Equally, with such poor datasets, the resulting method for assessment can only be considered as guesswork at best. In these circumstances, it is considered that ICRP have acted prematurely and have failed to put into perspective the effects of ionising radiation as opposed to other ecological stressors.
6. It was also noted that there is no “gap analysis” identifying the area where research is still needed nor any identification of the significance of those data gaps. There is no plan to significantly improve the data sets by increasing the number of reference animals and plants to provide more ecologically relevant trophic levels or by filling in the gaps in the data for the current, unrepresentative reference species. The approach is flawed from an ecosystem perspective as many facets of the ecosystem such as predator/prey relationships and the critical importance of lower organisms such as fungi and bacteria have been ignored.
7. Should any operator attempt to use the assessment method proposed, they would require a significant amount of work and would not necessarily reassure the public that the environmental consequences of radiation work have been carefully assessed. A site specific assessment of the ecosystem is needed for each possible site where there is a release of radioactivity for up to 12 reference animals and plants (depending on the biodiversity of the area). Each of these reference species would have its own environmental reference level and all of these would be different. The process would need to be applied to emergency, planned and existing exposure situations resulting in up to 36 (12 x 3) individual assessments for each source at each possible release site. There is then no framework for deciding which of these assessment outputs is critical and should be limiting nor any means of integrating all these outputs into a single, useable result.
8. In summary, the proposals contained in this document have only limited scientific validity due to the limited data from which the conclusions are drawn. The proposed assessment methods are based on ecologically unrepresentative species which means that the output of the analysis can be questioned at any time. Also, the analysis method proposed requires extensive operator and independent scientist inputs and is therefore very difficult and time consuming to undertake. The main effect of this document is to add costs to the operators for no benefit, as the conclusions of any analysis carried out will always be open to challenge.
9. Specific Comments
342 – What is a source – this is not a clear definition. It appears to be any radioactive item or x-ray generator, includes sealed sources. The document doesn’t give any minimum limits of radioactivity for an object to be a source; it could encompass items that are currently excluded from regulation due to their low activity.
342 – Does this mean that for mobile radiography an environmental assessment needs to take place for each location that radiography is done at? This could mean a large number of environmental assessments would have to be done which have no purpose.
777 – Is it possible to consider how different the representative organism is from the Reference Animals and Plants in terms of known radiation effect? Very little is known about the radiation effect on reference animals and plants and these are the most studied, the effect on representative organisms could differ greatly.
872 – This seems to be a contradiction. The commission believes that environmental protection should not add unnecessarily to the complexity of the assessment. The commission then suggests that back calculation should be used to derive a rate of discharge for both humans and biota that would not lead to a breach of either level. This would be a more complex and time consuming analysis.
881 – The document consistently states that the environmental reference levels are not dose constraints/limits but then compares dose constraints and environmental reference level in a manner that indicates environmental reference levels are equivalent to dose constraints.
1256 – The document omits predator/prey relationships which have been shown to have a large effect on the population size and structure. If radiation has a greater effect on the prey or predator population then the predator/prey relationship would be impacted. This may be key for an ecosystem however it is not possible to measure impact using only the suggested Reference Animals and Plants, only one of which could possibly considered a ‘top predator’.
1281 – Unclear how this procedure would take into account highly mobile populations such as Deer which will not always be located within the zone of interest and may have seasonal migration patterns. Would seasonal assessment need to be conducted?
1597 – This indicates that environmental impact of an emergency situation needs to be analysed and planned for. If the emergency happens in another area of the site with a different ecosystem another environmental assessment needs to be undertaken. This leads to another layer of administration in emergency planning.
1775 – Given the biodiversity of some of the areas in the UK alone it is difficult to see how 12 Reference Animals and Plants can represent a wide range of animal shapes/sizes let alone entire ecosystems across the globe.
1811 – If there is clear evidence that there are substantial variations in radio sensitivity why is the approach of trying to fit all organisms into one of 12 Reference Animals and Plants being taken? Surely more research is needed!
2204 – UK Legislation not included in the table of legislation compared, it is not clear how the protocol would fit with current UK environmental legislation.
2209 – No indication of the area that the population size given inhabits. The table indicates a population size but for different reference Animals and Plants the population must be spread across different sized areas, what are these?
2209 – In the table there aren’t any lower species such as Fungi as Reference Animals and Plants, these are a key element of any ecosystem and omitting them makes it difficult to see how the ecosystem can be assessed.