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Submitted by Naoyuki TOYOSHIMA, The Federation of Electric Power Companies
   Commenting on behalf of the organisation
Document The scope of radiological protection

(1)For artificial ƒ¿, ƒÀ and ƒÁ emitting radionuclides, numerical criteria should not be adopted for the concept of exclusion.

- ICRP Publication 60 (1990) and the BSS identify gexcludedh exposures as those that are essentially unamenable to control, whatever the activity concentrations may be. (Paragraph 32)

- The argument that artificial radionuclides with activity or concentration levels (ƒ¿: <1 Bq/kg, ƒÀ: <10 Bq/kg) that are minute and difficult to detect, are unamenable to control, can be hardly taken for granted. (Paragraph 123)

(2)The gminimum exemption levelh (in a dwelling: 200 Bq/cm3, in a workplace: 500 Bq/cm3) and the gexclusion levelh (40 Bq/cm3) of radon concentration may be wrongly perceived as constituting a double standard. (Paragraphs 110 and 113 to 114)

(3)The notion of allowing the minimum gexemption levelsh established by other international organizations to be defined by the ICRP as gexclusion levels,h should not be accepted. (Paragraphs 120 to 123)

(4)CODEX levels for radionuclides in foodstuffs should not be referred to as exclusion levels, because the dose criteria for the CODEX levels may be too low taking into consideration of the property of foodstuff essential to maintain our lives. ((j), Paragraph 121)

(5)We request an explicit and articulate statement of the reasons why the concept of collective dose has not been adopted in the definition of exemption.

- Paragraph 293 of ICRP Publication 60 (1990) states: gThe Commission recognizes that this method of exemption, i.e. ignoring the collective dose if the individual doses are all very small, is in use, not always explicitly, and that it often leads to conclusions that are broadly consistent with those that would result from the application of the Commissionfs system of protection. Nevertheless, this consistency is not always achieved and the Commission does not recommend the use of this technique.h

- On the other hand, the description on the collective dose cannot be found in this document. The Commission should clarify the reason of the difference.