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Submitted by Keiji ODA, Committee for International Correspondence, Japan Health Physics Society (JHPS)
   Commenting on behalf of the organisation
Document Radiological protection in medicine
We understand the importance of this document, which deals with overall framework of radiological protection in medicine, summarizing comprehensively the related documents already published after Pub.73 and the new Recommendations. We'd like to point out some improvements below.

(a) The specific protection system in medicine should follow the principles of general protection system based on the new Recommendations adopted in March. Namely, Chapter 6 should be moved to Chapter 2.

(b) Some statements such as summation of trivial doses and application of LNT hypothesis should be modified so as to be consistent with the new Recommendations.

(c) The summary should be required in the last chapter.

(d) We consider that the security of radiation sources should be discussed more explicitly in this document.

(e) In general, the dose rates used in medical area are high, although the dose is low; and the irradiation is carried out repeatedly with some time intervals. Therefore, in Chapter 3, emphasis should be put on the effects of dose fractionation, rather than dose rate effects.

(f) Surely the definition of "Practice" is important, but the discussions in section 7.2 are too lengthy to be understandable.

(g) We entirely agree with the description "the final responsibility for the radiation exposure lie with the physician". It should be also exaggerated that the physicians are responsible for the radiological practice in medicine. The accountability and informed consent should be discussed more deeply.