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Submitted by Kazuo Sakai, Foreign Affairs Committee, Japan Health Physics Society
   Commenting on behalf of the organisation
Document Emergencies
 
Comments on the ICRP Task Group report entitled "Application of the Commission's Recommendation for the Protection of People in Emergency Exposure Situations"

1. General comments
1.1 This document is to provide guidance for the radiological protection of people in emergency exposure situation. It is reasonable to advice to use appropriate dose quantities (effective doses, equivalent doses or absorbed doses) and reference levels, depending on the situation. However, the relationship between these reference levels and the interventional levels discussed in the Publication 63 is not clear and somewhat confusing.

1.2 In Paragraph (2) it is mentioned that the document covers the exposure of the two types of people: emergency gworkersh and gthe public; however, later in the text it is not always clear that a reference levels given is for the workers or for the public.

1.3 The severity of emergency situation may vary from a minor leakage of radioactivity from a radiation source to large-scale accidents in nuclear power plants. It should be plausible to consider the setting of reference levels depending on the severity of the emergency. In particular, for a large-scale accident, to terminate the accidental events and to reduce the non-planned release might be the best process for optimization. There might be a situation where it is difficult to set a reference level. To give some examples in the document would be useful.

1.4 English expressions friendly to non-English speaking readers is appreciated. For example, instead of gpenaltiesh (Third line of Paragraph (107), page 42), gdisadvantagesh or gdemeritsh would be easier to understand; as gpenaltiesh would remind some gpunishmenth. Also, a simpler English expression should be used instead of a Latin phrase gstatus quoh (Paragraph 9).

2. Specific comments
2.1 Compatibility with the Publication 63
In the Publication 63 gPrinciples for Intervention for Protection of the Public in a Radiological Emergencyh a number of Intervention Levels were recommended; 500 mSv for administration of stable iodine and evacuation for less than 1 week, and 1000 mSv for relocation. In the present Report, however, the reference level between 1 and 20 mSv is used to judge the optimization of protection strategies in the long term after the occurrence of emergency exposure, i.e., for existing exposure situations, and that between 20 and 100 mSv is used to judge the residual dose in emergency exposure situations. The difference between these values is of one order of magnitude or more. More detailed explanation should be provided to understand the difference between the intervention levels and the reference levels.

2.2 Deterministic injuries
In Paragraph (5) the severe deterministic injuries are defined as injuries that are irreversible in nature and that severely impair the quality of life; as examples, lung morbidity and early are given as example. However, less severe and transient damage, such as transient bone marrow damage, would impair the quality of life. Some more examples should be given.

2.3 Dose to be compared with the reference level
The last sentence of Paragraph (25) reads gc, the residual dose calculated for comparison with the reference level should includes doses already received and committed,ch. This would not fit the definition given in Paragraph (23). Here, it should be stated that g the residual dose and doses already received and committed should be added for comparison with the reference level.

2.4 Measures against malicious act
Measures against malicious act should be to keep radiation sources under control so as not to be used for such act. Therefore, the principle for the optimization would be different from those for accidents. The difference between the principles should be described in more detail in sections 2.3.3 and 2.3.4.

2.5 Local emergency response management
Paragraph (76) says g(under the situation where the level of contamination vary from one area to another)c, depending on the plan and the overall emergency response management approach of the country, different authorities may be responsible for management of the different areash. However, the locally independent management would not be effective. An authority might loose the timing of action while it takes time to arrangement with other authorities. Therefore, overall central control should be emphasized.

2.6 Figure 4
The legends in Figure 4 (p35) are hard to distinguish. Also, more detailed explanation of the Figure should be provided.

3. Editorial comments
3.1 Discrepancies between the Table of Contents (TOC) and the text.
(1) gAbstracth in TOC; but, gPrefaceh in the text.
(2) g2.4.2 Personal Monitoringh in TOC, but, 2.4.2 Individual Monitoring and g2.4.2 Health surveillance gin the text.
(3) g3.1 Tuning protection strategies and reference levels to actual conditionsh in TOC; but, g3.1 Tuning protection strategies to actual conditions gin the text (gand reference levelsh is missing).
(4) The section 3.3 Protection of emergency workers in TOC is missing in the text.
(5) In TOC, Annex A reads gAssessment of thec to the residual doseh, however, h cto the projected doseh in the Annex (page 53).

3.2 Paragraph (15) line 1 (page 15): gc situation an as emergencyc should be gcsituation as an emergencyh

3.3 line 10, page 16: gc, it is not be possible to ch should be gc, it is not possible to ch

3.4 page 42: There are two sections numbered 2.4.3; should g2.4.3 stakeholder involvement in planningh be deleted?

3.5 There are redundant sentences in Paragraphs (108) and (111): gThis will of course focus on...h

3.6 page 7 (j) and Paragraph (116): ICRP Publications are cited by the publication number; usually and in other cases, they are referred by the year of publication.


The comments described above were prepared based on the discussion in the Foreign Affairs Committee, Japan Health Physics Society. Also included are the comments by Dr. Hideo Tatsuzaki, National Institute of Radiological Sciences, Japan, and Dr. Daisuke Sugiyama, the Central Research Institute of Electric Power Industry, Japan, who responded to the call for comments by the Foreign Affairs Committee.