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Submitted by Ayse Gönül BUYAN, Turkish Atomic Energy Authority
   Commenting as an individual
Document 2005 ICRP Recommendation

First, I would like to express with pleasure the changes brought by scientific developments in the subjects such as radiation weighting factor, tissue weighting factor, risk factor, the fact that they cover the approaches to prevent conceptual confusion such as equivelent dose / dose equivalent and the fact that there are also no approaches suggesting important systematic changes especially in the ICRP 60 recommendations. I believe that frequent changes in such concepts, which influence large masses and broad applications will create difficulties providing stability for the regulations of the countries as well as the resultant complexity may diminish the protection system.

My observation based on my experience show that the full adaptation of such great changes require a period of time between 5 to 10 years, especially in the countries with high population and having many radiation sources.

Within this frame, my opinions are given below.

1. Dose constraints handled in closed expressions in the ICRP 60 appear to be more clear in this document. However, many more studies are required in order to facilitate the practical application of this concept. Some examples are the determination of the activity/activity concentration on the sewer system in a country where sewage infrastructure varies and waste treatment systems are not available and the determination of the factors to be used depending on source and irradiation conditions, in determining shielding criteria, one of the most important arguments about radiation protection.

2. Basically, the concept of dose constraint brought by ICRP 60 has provided a good transition process for the people and employees in order to decrease dose limits. The fact that the annual dose average of the employees of medical fields in about 3-5 mSv in recent year validates it. I think that keeping an presently are the annual effective dose of 20 mSv as the annual limit presently are useful for the flexibility provided, considering some special conditions.

3. In case of necessity, I think that using the 20 mSv level for individuals, dose constraints to patient relatives and not performing strict approaches to research-purpose irradiation will bring comfort to practical applications.

4. Depending on the source and irradiation characterization, I believe that the stakeholder participation in the radiation-related decisions will be important contributions in respect of enriching the knowledge and especially the peoples acceptance of certain irradiation situations. However, another thing that I find important is that some of the regulators with practical experience should be available in the structure of the regulatory body.

5. ALI is a concept applied about 25 years, whose practical use has been accustomed well. It provides a practical approach in evaluating the greatness of an activity level. The fact that ALI means the annual dose value for the employees has settled in all the societies now. I think that using the concept of ALI and adding the other tables related with the activity/activity concentration will be more useful.

In my opinion, explanatory documents are required to provide and accelerate the applicability of the new recommendations of the ICRP, which brings a significant approach in respect of simplifying the concepts related with radiation protection. “The Road Test Report” of the CRPPH is an important document to provide significant contributions to this matter.