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Submitted by Ann McGarry, Radiological Protection Institute of Ireland
   Commenting as an individual
Document Recommendations
 
Comments on the Draft ICRP Recommendations 02/276/06

General

1. The format includes both narrative and specific recommendations in the individual paragraphs - it would be useful to highlight specific recommendations in each chapter. In a small number of cases, the narrative adds to the confusion rather than clarifying the point. (examples para 36, 40)

2. It would be useful to reference page numbers in the glossary of key terms and concepts.

3. When ICRP undertook to review the 1990 recommendations, concerns were expressed particularly by regulators about the need for change at this stage. ICRP clarified that the new recommendations would not introduce fundamental changes (para 12). It is appropriate that ICRP’s thinking is clarified in the preface.

However, I think it is confusing to continue to make reference back to this point in the body of the text by including phrases such as “is to be seen as” and “should not be understood”. ICRP brings forward its recommendations; it does not intend that changes will be necessary to radiological protection regulations (para 12), but as it cannot be familiar with all regulations it cannot be sure that some changes will not be necessary. This will be a matter for regulatory authorities reviewing the recommendations.


Specific comments


Para 34 The use of the term “source” to indicate a cause of an exposure, not necessarily a physical source of radiation. Using a word with two meanings in the text can lead to confusion. This follows through in paragraphs 160 and 161.

Para 36 For clarity it would be helpful to include the numerical value for the threshold for tissue reactions in this para.

para 39 It would be useful to include the definition of “intervention” adopted in the document in the Glossary i.e “protective actions that reduce exposure”

Para 40 I wasn’t clear what this para meant.

Para 44 The inclusion of the final sentence “national attitudes to the regulation of exposures to naturally occurring radioactive material are extremely variable” is not helpful. What does ICRP recommend?

Paras 42/45/165 The last sentence in para 42 indicates that “exemption” can only apply to personal entities whereas para 45 indicates that “certain practices and sources may be exempted”. Para 165 refers to “exposure from exempt practices or exempt sources” Which is correct?

Para 46 This para indicates that “exemption should not be entirely linked to triviality of risk because it is a broader concept” but it does not give examples of what else might be considered. It would be useful to include examples.

Para 157/164 Considering occupational exposure, medical exposure of patients and public exposure – they are called 3 “types” of exposure. Later in the para they are called “exposures in different groups”. In para 164 they are “categories of exposure”. A single terminology should be adopted to avoid confusion.

Para 157 In para 157 a distinction is made between “workers who are exposed to radiation sources as part of their work” and “exposure” to radon at work”. From this and later paras, the impression is given that ICRP does not intend exposure to radon at work to be classified as “occupational exposure”. However, taking into account the definition of occupational exposure in para 166 i.e. “radiation exposures incurred at work as a result of situation that can reasonably be regarded as being the responsibility of the operating management”, exposure to radon at work would be considered to be occupational exposure. This point could very usefully be clarified either directly in the text or by making reference to the appropriate ICRP publication.

Para 167 The last sentence “The component of public exposure due to natural sources is by far the largest, but this provides no justification for reducing the attention paid to smaller, but more readily controllable exposure to man-made sources” could be replaced by “The fact that exposures to the public from man-made sources are more readily controllable than the exposures to natural sources, provides no justification for reducing the attention paid to this much larger component of public exposure”. This and some other comments in the text can give a misleading impression of ICRPs view of the importance of different types of exposure and the efforts that should be devoted to reducing them.

Para 168 Given the concerns expressed in relation to the significant increases in medical exposure of patients, it might be appropriate to draw attention to the similarities with the general situation i.e the need for strict application of the principles of justification and optimisation rather than to highlight the differences with other planned exposure situations.

Para 331 It might be useful to integrate some of the material in relation to accidents in radiation therapy into the section dealing with medical exposure. The design of equipment and premises and of the working procedures while an integral part of accident prevention are also key elements of the optimisation of “routine or non-accident” exposures