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Submitted by David Webbe-Wood, Food Standards Agency UK
   Commenting on behalf of the organisation
Document Recommendations
 
General Comments

We are pleased to note that ICRP have significantly amended the draft to take account of the many comments received. We feel that the current draft is an improvement and particularly welcome the clear statement of the ICRP's principles of justification, optimisation and limitations. The sections on the scope of the regulations and the use of dose constraints are also now adequate. We also welcome the view that the recommendations do not suggest any need for changes to protection standards based on the previous recommendations in ICRP Publication 60.


The ICRP requested comments on specific areas of the new draft; these comments are given below:

ICRP Request
There were many comments on the sections on scope, exclusion, and exemption in the previous draft Recommendations. ICRP would now particularly appreciate comments indicating whether the present treatment of these topics is adequate in the present draft.

Comment
The treatment of these topics, in conjunction with the treatment in the foundation document, is adequate.

ICRP Request
Many comments on the previous draft Recommendations indicated that the Principle of Justification had not been presented clearly enough. ICRP would now particularly appreciate comments indicating whether the present treatment of this topic is adequate in the present draft.

Comment
The treatment is adequate and it is clear that responsibility for justification lies with national authorities not the ICRP. It may be worth making explicit that there are more than one way of considering a practice which can form part of a larger practice or type of practice e.g. is transport of spent fuel part of electricity generation, transport of radioactive material or a practice in its own right.

ICRP Request
Comments on the sections concerning the Principle of Optimisation in the previous draft Recommendations indicated that the word ‘matrix’ could be misinterpreted and that the concept of ‘stakeholders’ was unclear. Draft reports on the topics of optimisation and of representative persons have since been subjected to consultation. ICRP would now particularly appreciate comments indicating whether the present treatment of these topics is adequate in the present draft and in the light of clarifications in the aforementioned draft reports.

Comment
When taken with the treatment in the foundation documents the treatment of this issue is adequate.


ICRP Request
Comments received on the topic of Dose Constraints showed that this tool had been treated somewhat inconsistently in the previous draft Recommendations. ICRP would now particularly appreciate comments indicating whether the present treatment of this topic is adequate in the present draft.

Comment
The treatment of this topic is appropriate

ICRP Request
Comments received on the previous draft Recommendations indicated that the topic of natural sources of radiation had not been covered in sufficient depth. ICRP would now particularly appreciate comments indicating whether the present treatment of this topic is adequate in the present draft

Comment
Again the treatment of this issue in the current draft is appropriate


We also have a number of comments on the detail of the revised draft. these are given below:

Paras 30 and 185: The requirement to keep inequality in the distribution of doses as low as possible is somewhat strange. In practice the distribution of doses from discharges into the environment are going to be very unequal with the reference individual getting the highest doses and the majority of the population getting effectively zero doses whilst all get the same benefit (e.g. electricity generation). The discussion in para 199 which states that part of the reason for source related constraints is to limit inequality is better.

Para 245: The last sentence of this paragraph appears to imply that the exposure of the public from hospitals occurs largely whilst members of the public are in the hospital (not as patients) rather than as a result of discharges. There is no reason whilst public exposure from hospitals as a result of authrised discharges are any more difficult to control than those from other sites.