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Submitted by URABE Itsumasa, NUCLEAR SAFETY RESEARCH ASSOCIATION ( Environmental Radiation Protection task group)
   Commenting on behalf of the organisation
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Comments on the Environmental Radiation Protection

On the necessity of recommending environmental radiation protection

It is well known that the necessity for the environmental protection has been recognized even in the field of radiation protection. But it may be premature that the new recommendation on radiological protection contains issues on the environmental radiation protection because of the reasons as follows:

1. Evidences of the adverse effects in the population level of organisms have not been confirmed in the natural environment even in the accidental condition of nuclear facilities.

2. Demands for protecting natural environment through the protection of fauna and flora will depend on the political and economical conditions of the country. It is quite possible that the people will gradually understand that the variation of the radiological conditions of the natural environment can be detected and controlled by the current monitoring system of environmental radiation which will be continuously making progress in measuring techniques.

3. Important scientific and technical problems such as selection of Reference Animals and Plants and estimation methods of radiation doses of non-human species are still under investigation. If the framework of the environmental radiation protection is strongly required in the future, it will be recommended from the view point of setting safety standards for practicing environmental radiation protection on the basis of more reliable scientific and technical information given by the investigations on the problems to be solved now.

4. It is apparent that the radiation protection system should be fundamentally established on the basis of the knowledge clarified scientifically, but, it is also imaginable that it takes too much time and resources to understand systematically the effects of the organisms in the natural environment. So, at the first stage of discussing protection of non-human species, it may be appropriate to investigate the protection standards which were already proposed by IAEA or USDOE for the environmental radiation protection on the basis of the realistic acute effects appeared in plants and animals.