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Submitted by John P. Hageman, MS, CHP, Southwest Research Institute
   Commenting as an individual
Document 2005 ICRP Recommendation
Comment regarding section S18, Regarding exposure to plants and animals:

This section opens the door to bog down serious radiological protection by focusing limited resources on any and all non-human species. Despite the statement that protection will be modeled for a “limited number of animal and plant types” the precedence for such protection raises the potential requirement of any specific type of non-human life form. For example, these dose protection criteria could be applied to bacteria, which is a non-human life form. Thus, this section (S18) can be interpreted to control or entirely exclude irradiations for food sterilization, fruit-fly control, and use of animals in fundamental research for cancer therapy and risk assessment.

This control of radiation exposure to non-human life forms should not be included in 2005 ICRP Recommendations.