Optimisation of radiological protection

Draft document: Optimisation of radiological protection
Submitted by Dr C J Kalman, The Director NHS Lothian Occupational Health & Safety Services
Commenting as an individual

1. I am surprised that the draft is written as an endorsement of ?2005 recs. rather than ICRP input into new recs. 2. In my comments on the rec. consultation, I tried to explain my view that ICRP should not drop the 3 principles of RP as justification, optimisation & limitation. I remain convinced that it would be a disaster in public perception to do so. There is a need for consultation on the ICRP views on justification and limitation, as well as this document. It really is not good enough to have a few sentences on each in a document entitled optimisation. In addition I am not clear that I understand what the group is saying about justification. 3. The draft appears to ignore intervention in terms of urgent early countermeasures, based on averted dose. Clearly this activity is not ALARA/ALARP, nor does it fit into the graphic form shown in the text. 4. While constraints and stakeholder involvement are natural progress of the optimisation process, action is required at recomendation level to ensure that the process of use of radiation can not be prevented by small pressure groups within the stakeholder group, and also that competion between organisations is not distorted by grossly different RP systems in differing industries. ie public dose considerations in pwer supply between nuclear generation of electricity and natural gas. 5. I am disturbed by the discussuin on collective dose. It is not a concept invented by the ICRP, but rather a natural consequence of a proportional dose response relationship for stochastic effects. ICRP can not therefore un-invent it, particularly as the Health Effect document again supports the straight line. ICRP have therefore to say when it is useful, and it remains my view that setting of deminimus levels etc is the most sensible way forward. 6. It is not clear that safety culture is a meaningful concept here. First of all the outcomes in question are health related, and therefore at a minimum it should be H&S culture. More fundermentally, it is debatable wheather safety or indeed H&S should be seperated out of the overall culture of an organisation in terms of care.