ICRP DRAFT RePORT
Comments of Vereinigung Cockpit
In the draft the same topic is repeated in different places. Our position will be given only once to minimize doubling.
The basic defect of the draft is defining the exposure to cosmic radiation as an „existing exposure situation“.
Replace lines 186/187 by:
Most of the measures already are common practice for example as reactions on volcanic ash but they have to be put in common understanding also for radiation protection.
2. Misunderstanding ICRP basic principle of justification (lines 184/185)
In our understanding the principle of justification means that the benefits outweigh the harm of the activity. With regards to optimization and dose limitation of the individual a protection strategy has to be developed and implemented.
3. Set the dose constraint to 6 mSv/year (lines 194-196)
Dose reference levels are only applicable in existing or emergency exposures but not in planned exposures. If one seriously wants to apply the ALARA principle, a dose constraint of 6mSv/year is justified and practical experience, as it is proven by the German Dose register. (Cf. )
4. Classify frequent flyers for duties (couriers) as occupationally exposed persons (lines 210-215)
Couriers often fly more frequently than „normal aircrew“. Therefore the case-by-case basis by a voluntary agreement is not appropriate. The status of the couriers has to be declared as occupationally exposed persons.
5. Education and information of all persons involved in planning and carrying out flights (lines 218/219)
The exposure of aircraft crew and passengers during a real flight depends at first on flight planning. Therefore not only the crew but also the dispatching staff have to be educated in radiation protection through courses and educational programs (CBT etc).
Therefore replace lines 218-219 by:
(i) Educate the dispatching personnel and aircrew in radiation protection through initial courses and recurrent programs (computer based training).
(ii) In the flight plan the expected doses shall be stated.
6. Assessing the doses (lines 220/221)
ICAO Annex 6 Part I - Operation of Aircraft - (November 2010) requires :
As handy dosimeters (even TEPCs) have been developed, the International Federation of Airline Pilots Associations requires:
Therefore replace lines 220/221 by:
7. These data should be … kept for sufficient time (lines 223/224)
The term „sufficient time“ has to be specified in more detail. The swiss dose register keeps doses for 100 years. Regarding epidemiological studies but also individual medical histories the storing time should assume the swiss regulation.
8. Adjusting the flight roster (lines 225-227)
Adjusting the flight roster is one instrument of optimization. Therefore the optimization of the roster shall not be left to the operation management’s discretion.
9. SEP: retrospective dose calculation is NOT the only means of protection! (lines 554-558)
Except for research and high-altitude aircraft (IACO Annex 6 Nr. 6.12) there are no dosemeters on board of aircraft. As already stated (Nr. 6 Lines 220/221), there is a need of on-board measuring devices in order to lower the exposure during a SPE. Even if those instruments do not measure the correct absolute value, they can indicate unusual increases in dose rate. Consequently there is no need to display exact figures, it is sufficient to give off a warning (“red light“) if the dose rate exceeds a certain threshold.
10. Lightning and TGF are not unknown phenomena (lines 567-579)
The statements concerning TGF are quite superficial. Measurements of lightnings on board of an Airbus A350 exist and the theory is also very, developed . On average an aircraft is struck by lightning every 1000 flight hours  , which means that a pilot averages one lightning strike per year. Apparently the task group did not take flights through the ITC into account where during a lightning strike aircrew are exposed up to 30mSv (this being the most optimistic calculation).
Wrong! Standard flight profiles refer to great circle routes and standard altitudes. If the „optimum flight level“ is flown, exposure increases already by about 25%. Furthermore a deviation of the geographic longitudes and latitudes can change the exposure in a significant manner . (See also our comment Nr.6)
12. Existing exposure is in contradiction to ALARA (line 744/745) (cf. comment 1)
(40) The commission regards human exposures in aviation resulting from cosmic radiation as a PLANNED exposure situation.
13. The position of the task group is not in line the standard procedures of the airline industry (lines 886-897)
In solar particle situations greater than „NOAA S2“ US Airlines reroute polar flights and decrease flight altitudes (FL<310) . Increased fuel consumption and time delay are not significant  .
As already stated.
15. Calculate/ measure each flight individually (lines 966/967)
As already stated (cf. comment 11) „typical effective dose rates“ are not appropriate because the exposure at real flight profiles and flight routes is usually misrepresented by „a standard flight profile“. As the crew complement typically changes on every trip, the annual exposure of a crew member cannot be derived by an „annual aircrew dose“.
The wording may encourage airline to conceal this information. As the airline is normally the only recipient of the exposure data concerning the health of the individual, it shall be mandatory to forward this information to the individual.
17. The class 1 medical is not at all equivalent to the „Radiation Medical“ (lines 976-980)
Even though aircrew undergo regular medical examination, the task is limited to assessing a crew member either fit or unfit to fly. The scope is not directed towards long term health effects but to check the ability to fulfill their duty until the next examination.
Furthermore - since crew members are typically concerned to lose their medical if a certain condition becomes known - the dialogue between examiner and worker is often limited to the exact scope of the examination (sometimes even by law).
Therefore replace lines 976-980 by:
Aircrew undergo regular medical examination assessing them to be „fit“ or „unfit to fly“ for the validity period of the certificate. The scope is consequently not directed towards long term health effects and therefore cannot adequately replace specific medical examination regarding radiation exposure.
18. There is a basic misunderstanding: The crew complement is not fixed, it changes on every trip (lines 981-983)
For safety reasons the crew complement is assigned anew for every trip. Thus the flight crew scheduling has to monitor the exposure of each individual.
By the way: If the position "existing exposure" of the Task Group would be maintained and not changed in "planned exposure" the paper would be inherently contradictory.
19. „Women who ... may be or expect to be pregnant“ = Women younger than 50 years (lines 997-999)
As a measure of antidiscrimination and practicability, all women who fly frequently should be informed.
Literature and Remarks
 Fahey T. , Scott G.; Hazard Avoidance Procedures &Use of Space Weather Information; Weather Workshop Aviation & Space Weather Session 24 April 2012 Boulder, CO; http://www.swpc.noaa.gov/sites/default/files/images/u33/SpaceWx_20minFINAL_ver3.pdf
 The difference in terminology between planned and other exposure situations (emergency and existing) has been retained by the Commission to express the fact that, in planned situations, the restriction on individual doses can be applied at the planning stage, and the doses can be forecast so as to ensure that the constraint will not be exceeded.
 cf. EURADOS WG 11 Meeting, Paris, 28-29. September 2015
 Matthiä, D. et al, Mitigation Measures during a GLE, J. Space Weather Space Clim. , 5 , A17 (2015)
 Kochkin,P. et al. In-flight measurements of energetic radiation from lightning and thunderclouds, Journal of Physics D: Applied Physics, Vol 48 ( 2015) Nr. 42
 Boeing Aero Magazine QTR_4/12 http://www.boeing.com/commercial/aeromagazine/articles/2012_q4/4/
 Dyer et al.; The QinetiQ Atmospheric Radiation Model and Solar Particle Events;
 Fahey T. , Scott G.; Hazard Avoidance Procedures &Use of Space Weather Information; Weather Workshop Aviation & Space Weather Session, 2012 Boulder, CO
 e.g. Matthiä, D. et al.; Economic Impact and Effectiveness of Radiation Protection Measures in Aviation during a GLE; Space Weather Workshop, 2015, Boulder, CO:
Vereinigung Cockpit e.V. Unterschweinstiege 10 60549 Frankfurt