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Submitted by Yoshikazu Kumamoto, retired
   Commenting as an individual
Document 2005 ICRP Recommendation
The following comment is the addition to my comment submitted on 11/30/2004.

1. Dose-rate effectiveness factor (DDREF)
In paragraph 105, a DDREF of 2 is recommended “for all equivalent doses resulting from absorbed doses below 0.2 Gy and from higher absorbed doses when the dose rate is less than 0.1 Gy per hour”. Does the recommendation allow us to calculate the number of excess cancer deaths among men and women exposed to photons
with values obtained by multiplying the coefficients in Table 6 by 2 under the dose condition other than that mentioned above (defined in paragraph 74 in the 1990 recommendations in ICRP Publication 60).

2. Limits for individual organs or tissues
Values in Table 9 (paragraph 186) are defined in order to prevent the tissue damage (deterministic effects), so the dose should be an RBE-weighted absorbed dose and the unit should be Gy-Eq. The factors should be RBE values, not radiation weighting factors.

The first topic is written based on Dr. Wolfgang-Ulrich Müller’s comment submitted on 10/5/2004.