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Submitted by Karla Petrová, State office for Nuclear Safety,CZ
   Commenting as an individual
Document Recommendations
 
Comments to the draft recommendations of the ICRP – 02/276/06 – 5June 2006
Karla Petrová, Czech republic, 09/2006

The last draft of ICRP Recommendations of June 2006 is a document where the significant progress is seen from the previous version.

General comments
I appreciate that there is seen a consistency with the previous recommendations of ICRP and it is several times stressed in the document.
As dose constraints and optimisation are the key elements of the new recommendations the use of them, particularly for new defined existing and emergency situations, should be more clearly explained with the aim to avoid the confusion and inconsistency.
The question was already posed – also by the chairmen of ICRP – if the name “constraint” is appropriate for that broad use. This idea I fully support – however having no till now a better and optimal proposal. But the question is also if it is necessary so forcibly to try to keep only one name for all situations. However better wording in some paragraphs and more explanation using maybe some examples would be also very useful and a solution.

It would be also recommended to transport some principal and basic parts from foundation documents into the general recommendations or to use very precise reference to the Annexes or relevant Foundation documents. If somebody is not really deeply familiar with the content of all these documents sometimes could feel a lack of explanation of information which are behind some recommendations or approaches presented in the document of general recommendations.

Some specific comments

Chapter 7
There is nothing in this chapter discussing air crew exposures. It would be recommended to refer to para 86 and 87 in the document of the Scope of radiation protection regulation because in many countries there are already relatively strong requirements implemented concerning the control of these exposures and it is necessary to keep some coherence and consistency with the previous recommendations (ICRP75) which required the calculation of doses for those over 1mSv


Chapter 11
The chapter contains some valuable recommendations concerning the implementation of the ICRP recommendations by the regulator. However it would be recommended to condense it into one part based mainly on the part 11.1. The issues like stakeholder involvement, the warning on the too prescriptive legislation and the delegation of some regulatory functions are valuable and they reflect the recent trends in the regulatory activities and as such they should be preserved in the document. The part 11.2. is an extraction of the text of ICRP 60 and it is very confusing. It is focused mainly to the occupational exposure and this is not adequate and not understandable why only this kind of exposure are treated in such details there. These parts could be removed into the specific section dealing with the occupational exposures or just the reference to ICRP 75 and others could be presented. Other kind of exposure should be addressed in specific chapters in similar manners.
Also the recommendation on the quality management is very inconsistent – if ICRP feel that it is necessary to warn regulators on this problem and other – it could be just more valuable and fair, I guess, to refer to some already developed recommendations by IAEA, NEA, etc..
The text contains some terms which are not explain in the glossary even in the text – e.g. proprietors, undertaking, etc… - for the clear understanding it should be necessary to use harmonized terminology through whole text and the terminology has to be consistent with common terms recently used in the particular context – operator, owner, user, licensee, etc…