Reference animals and plants

Draft document: Reference animals and plants
Submitted by Christepher McKenney, U.S. Nuclear Regulatory Commission
Commenting on behalf of the organisation

The U.S. Nuclear Regulatory Commission (NRC) staff appreciates the opportunity to review and offer comments and observations on the International Commission on Radiological Protection (ICRP) Committee 5 draft report, “Environmental Protection: The Concept and Use of Reference Animals and Plants.” We continue to applaud the ICRP for providing draft reports for consultation and comment. The NRC staff appreciates the clear and careful cautions included in Chapter 6 stating that the Derived Consideration Levels are not intended to be dose limits, or substitute values. The NRC staff strongly agrees with these statements. We urge the ICRP to continue to clearly articulate this viewpoint. We also urge that ICRP clearly affirm that the objective of this effort is not the creation of new standards or requirements. The NRC has a well established system for considering environmental impacts to non-human species associated with its regulatory and licensing decisions. This system is derived from the requirements within the United States under the National Environmental Policy Act, and includes consideration of the full spectrum of possible impacts from regulatory decisions. The NRC staff has therefore examined the draft ICRP Committee 5 report in the context of this system. The draft report provides a useful step in summarizing the current state of knowledge of radiation effects in various animals and plants. As such, the majority of the report contains scientific and technical information, and the NRC staff does not have many specific comments to offer on this material. It is important to note that there are many areas, for many of the suggested reference animals and plants, where there is little or no information on radiation effects and there is currently no method to extrapolate radiation effects to other nonreference species.