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Submitted by Mr R J Brown, UK Ministry of Defence, Defence Safety & Environment Agency
   Commenting on behalf of the organisation
Document Radiological Protection in Security Screening
 
It is reasonable for security screening to be considered as a planned exposure situation and subject to the usual requirements of justification, optimisation and dose limitation.  Also that justification must involve consideration of issues other than just radiation protection and that the possibility of multiple exposures needs particular attention.

The rationale for individuals (such as airline crews) being treated as members of the public while undertaking work for which they are receiving financial gain and where it is only to be expected that screening will be a regular feature of their employment is not particularly robust or compelling.  Especially as there is no distinction between screening by an individual''s employer rather than a third party.  It is also unclear why ICRP see scanning by "organisations that may not have experience or expertise in radiation protection" as a feature of this activity.  Surely the position should be that organisations undertaking scanning must have suitably qualified experts to advise on radiation safety requirements and that equipment operators should be suitably qualified and experienced?

References to societal factors and the importance of issues other than just radiation protection do not seem to be reconciled with what is presented as a more fundamental requirement for individuals to receive some benefit from any exposure.  This latter view also seems to raise questions about the ICRP position on medical research as this is another situation where the benefit is to society rather than the individual.  It is noted section 4.2 defines public exposure as deliberate exposure not directly related to the health of the individual and that although the existence of medical research is acknowledged on one occasion, medical exposures are more usually presented as exposures where the patient gains a health benefit.

Exit screening to prevent misappropriation of items that might be used for criminial purposes has not been considered and needs inclusion.  Categorising a stowaway as an "inadvertently exposed individual" and by implication as someone exposed while engaged in lawful rather than unlawful activities needs more justification than simply an unsupported statement that involvement in both lawful and unlawful activities should involve "substantially" the same level of radiation risk.  The possibility that stowaways may have more malicious intentions than infringement of immigration controls does not seem to have been considered.

In summary, the document has much to commend it but some key issues seem to be addressed in a rather superficial and inconsistent way.  Introducing a new category of exposure for situations where societal rather than individual benefit is the key outcome may be overdue.