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Submitted by Christophe Murith, Swiss Federal Office of Public Health
   Commenting on behalf of the organisation
Document Reference animals and plants
 
Swiss Comments concerning the Draft Paper of ICRP on the "Concept and Use of Reference Animals and Plants for the purposes of Environmental Protection"
The paper has been studied by the Swiss Federal Office of Public Health (OFSP). It seems primordial that this draft should not be in contradiction with the three important concepts: reasonableness, sustainability and homogeneity mentioned in the draft "Assessing Dose of the Representative Individual for the Purpose of Radiation Protection of the Public".
One should not forget that the protection of human is of prime necessity. With this in mind the radiological Protection system has defined standards of environmental control and limitations on the quantities of radionuclides released in the environment. In a time of economising resources, the RP priority is to ensure that this human protection is warranted. In this context accidental events (industry, medicine, and radioactive legacies) remind us that this goal is not achieved and need to be follow in the medical, industrial and natural (e.g. radon) fields.
To control the impact of radioactive releases in the environment, the best indicators and integrators of contaminations are well known and differ from one country to another even from one site to another. Experience exchanges of laboratories in charge of radioactivity surveillance in the environment (intercomparisons, seminaries, workshops…) seem to us the most efficient tools to gain a good quality level of control and to promote the state of the art and harmonisation for the sampling and the subsequent analyses.
The argument that the non human species controls could help in understanding interaction of radiation with living material is weak, because in the risk assessment the opposite argument is often used as a limitation (e.g. epidemiologic studies observations in animals aren't transposable to humans). Moreover radiobiological studies are best suitable to respond to this purpose.
The main interest in the proposed draft is to give an overview about present knowledge concerning studies on non human species. But it seems us illusory to regulate this field that is very complex and research oriented because of the presence of other environmental stressors and pollutants (natural selection, chemical and biological effects…). One must be careful not to create a new controversial topic as the "low dose" one.
We are not convinced that the non human species concerns will lead to an added benefit in radiological protection. We think that it could detrimental to the credibility of RP if too high importance is given to this subject whilst a lot of work is still to do to reduce high doses and potential risks associated with ionising radiation. It doesn't' mean to abandon the studies in the non human species field, which is an interesting one in term of research, but to ask oneself the question of the relevance and the pertinence to actually introduce some kind of new international regulation concerning this domain. One must before ensure that the basic environmental surveillance tools are implemented (dense and sparse networks) and recommendations could for example stress and help environmental surveillance authorities to define appropriated sites where different harmonised types of measurements have to be performed in defined environmental media by a given frequency to allow correlations between them, in a sense of a minimal radioecological program with registration of validated data in a central data base. Concrete proposals that take into account the concept of sustainable development and established principles for the management of waste in the environment (e.g. comments on the limits of the principles of dilution) were expected from the radiological protection community.