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Submitted by Celso Osimani, A.I.R.P. not I.R.P.A.
   Commenting on behalf of the organisation
Document Emergencies
 
Please note than the organisation that I am replying on behalf of is the A.I.R.P. and not the I.R.P.A. My previous comment was attributed to the I.R.P.A. in error.

1. In the definition of "radiation emergency exposure situation" (2) the Commission avoids any reference to the words "radiation dose" preferring the term "undesirable consequences". This is a generic definition, and in our opinion inappropriate to the context of exposures in emergency situations.

2. The concept of an "existing exposure situation" (15), has been introduced from previous ICRP documents. This is an interesting concept as it emphasises the difference between the management of the emergency situation and the condition of "normality or near normality" that must return at some point in the territory where the incident occurred.

3. Also in these recommendations as in 103 of 2007 the concept of bound optimisation with respect to a datum level (mSv) (27) is introduced), (91). The use of a datum level in terms of dose when socioeconomic appraisals are carried out or appropriate non radiological considerations within an optimisation process for protective measures in emergency conditions seems restrictive and ambiguous. However, it is not clear whether the use of such reference values takes account of these aspects or excludes them. According to this case it is not clear whether the non radiological appraisals enter the process of optimisation, which should be related to a dose limit.

4. The optimisation process (86) checks whether the dose pickup in that part of the year is less than the fixed limit. This procedure could represent something new, even if conceptually it is obvious that an optimisation process will be iterated until an optimised level of protection is achieved.
5. The emphasis that the Commission has on the importance of communication with the so-called " stakeholder" is a positive point. It is in the planning phase of the emergency response (predisposition of the emergency plan) and in emergency management. This improves response time of and guaranties more effective participation (111), (112), (113), (114).
6. The "workers" that take remedial and protective actions in the first phase of the emergency, must be protected by an optimisation process and with appropriate reference level of dose pickup. (116).
This would be an innovation, but it is also true that good practise of radiation protection of workers and the use of common sense, should be extended to the to those who plan the management of the emergency to analogous considerations.
However it is positive that the Commission looks to protect workers by referring to an optimisation process.