Comments of the Federal Agency for Nuclear Control (FANC: Belgium) on the draft (5 June 2006) Recommendations of ICRP
The present comments are focusing on three issues the FANC considers to be crucial after having reviewed the new draft (5 June 2006) ICRP Recommendations. They are not intended to be exhaustive.
1. The major issue is the lack of precautionary approach for at least some of the risks induced by the exposure to ionizing radiation. Precautionary approach must be understood here as recommending measures of precaution or prevention to avoid serious detrimental health effects that, in spite of persisting uncertainties, are a plausible consequence of exposure to ionizing radiation. The ALARA approach is limited in practice to the risk of radiation-induced cancers. In particular:
a. Regarding genetic risk, the basic question is whether we know enough about possible long term radiation-induced genetic effects to close the debate and to formulate recommendations as if the risk of effects in the generations beyond the second one equals zero.
b. Regarding irradiation of pregnant women, ICRP should clearly underline the uncertainties in the evaluation of the risks after in utero irradiation and in the setting of reliable threshold doses and be more cautious in its recommendations, especially for exposures in the medical field and in existing situations. ICRP should particularly avoid suggesting that “100 mSv” be a global and “definite” threshold for any significant effect.
c. New data challenging the current dose threshold for radiation-induced cataracts are now available. The same goes for the possible induction by radiation of non-cancer diseases at much lower doses than currently assumed. ICRP should explicitly take these elements into account in its judgements and protection recommendations, particularly in the relatively high dose situations that can occur in medical applications and in prolonged exposures.
2. Globally, the issue of the individual differences (due to age, gender, genetic susceptibilities) is practically not (or not enough) taken into account in the draft recommendations, not even in the high exposure situations. The same is true for factors, other than dose, directly influencing the risk, such as the dose rate (general use of a DDREF of 2). This oversimplification is not a necessity, as there are various easily attainable solutions to take such differences into account, especially in high dose-rate situations like in medical radiology. ICRP should consider more tailored recommendations, whenever possible, to reduce inequity with regard to the inflicted risk.
3. The currently proposed values for “exclusion” levels for natural radionuclides may lead -in some particular situations- to very high exposures. ICRP should clearly state that there are exposure situations in which the use of these levels could be inappropriate (e.g. bulk building materials, large contaminated areas).