Comments of the NSC secretariat of Japan on the draft ICRP 2006 recommendations General Comments: 1. The secretariat of the Nuclear Safety Commission (NSC) of Japan appreciates the continued efforts of the ICRP to improve the draft recommendations, and thanks the ICRP for providing us with this opportunity to submit comments on the draft recommendations. 2. The secretariat also appreciates that the draft recommendations keep more continuity than change from Publication 60 as to the concepts of radiological protection, and particularly, that the three fundamental principles of radiological protection system, namely justification, optimization and dose limitation are maintained. 3. The secretariat also acknowledges that, not all, but most of the issues are clearly explained in the new draft. For example, the ICRP retained the concept of collective dose, but described clearly how it should and should not be used. 4. After the release of the draft recommendations for public comments, licensees and experts in Japan have had many occasions for deliberation to give active comments on many aspects of the draft recommendations. The secretariat of the NSC shared most of technical questions and comments expressed in the third Asian Regional Conference. 5. Considering that the IAEA and national governments need, respectively, to formulate a model of regulatory system based on the ICRP recommendations and to establish and implement their own regulatory systems, the secretariat expects further opportunities for dialogue between the ICRP and regulatory authorities, in particular, based on multilateral regimes such as the OECD/NEA, and also hopes that the ICRP recommendations be further streamlined not only for the fundamental concepts of radiation protection, but for the better understanding and implementation through the world. Specific Comments: 1. Justification The secretariat understands that the principle of justification is that no decision on any radiological activity should be adopted unless it produces more good than harm, or sufficient benefit to offset the detriment it causes. From this viewpoint, the secretariat understands that there are no differences in the concept of justification between the new draft and the Publication 60. Judgement on the justification has been done appropriately through political/social processes in Japan. The ICRP's statement of gThe responsibility for judging the justification usually falls on governments or government agencies to ensure an overall benefit in the broadest sense to societyh might be an oversimplified statement for the actual implementation, as we see a broad range of radiological activities 2. Dose Constraints The concept of dose constraint was expanded from that of Publication 60 as stated to be the most fundamental level of protection. There have been, and it will further be required for, discussions on the applicability of this concept. This must be clarified hopefully before the finalization of the ICRP recommendations. The secretariat considers that the practicability of the recommendations, namely avoiding the two-fold structure in regulatory system, and the consistency to the current system, in particular the implementation of ALARA, should be appropriately taken into consideration.