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ICRP: Free the Annals!

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Submitted by Richard Poeton, US EPA
   Commenting as an individual
Document The scope of radiological protection
I suggest that the distinction between sources that are excluded because they cannot be controlled, and those that are exempted because they need not be controlled, is unnecessary and artificial. It is also inconsistent with the fact that "The Commission's radiological protection recommendations are not limited in extent or scope and cover all types of radiation exposure situations regardless of the size and origin of the exposure."

Consistent with this comprehensive approach, all sources should be considered in the context of the concept of optimization. As noted in section (33), protection for cosmic rays can be considered de facto optimized. There is no need to "exclude" cosmic rays, only to characterize their nature in the context of optimization. Similar logic could be applied to the other "excluded" categories. The net result is that it is unnecessary to define a category of "excluded" sources. All that is necessary is to characterize those sources as being optimized de facto on the basis of their nature.

Similarly, instead of defining a category of exempted sources, it is better to define sources that can be considered "presumptively optimized", and therefore not needing additional controls.

By describing the universe of sources in this way, the system remains all-inclusive rather than giving the (false) impression that some sources are excluded or exempted from the system itself. All things are optimized in one way or another and the comprehensive recommendations of the Commission are maintained.