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Submitted by Richard O''Brien, Australian Radiation Protection and Nuclear Safety Agency
   Commenting on behalf of the organisation
Document Reference animals and plants
Specific Comments (editing)
There appear to be several symbols and characters that have not printed correctly. The fonts need to be checked.

Page 9, Paragraph 9, Line 4. “involves” should be replaced by “involved”.

Page 10, Paragraph 13. The (Williams, 2004 ) reference does not appear in the list of references.

Page 11, Paragraph 16, third point. There seems to be something missing after the words “and that because ecotoxicological studies are also increasingly”.

Pg 26, Paragraph 67, Line 1. “And terrestrial situations…” should read “Terrestrial situations…”

Pg 28, Paragraph 76, Line 7. The closed bracket after “organisms.” is out of place and should be deleted.

Page 36, Paragraph 96, Line 4. “the value of full absorption limit” should be replace by “the value of the full absorption limit”

Pg 43, Paragraph 125, Line 10. “And some studies…” should be written as “Some studies…”

Pg 68, Paragraph 242, Line 4. The second closed bracket after “1972” is out of place and should be removed.

Specific comments (structure)
Page 7, Paragraphs 3 and 4. The detailed summary of the evidence currently available on the need for specific protection of the environment and the level of risk is in Section 5. There should be a cross-reference to this very early in the document, and a brief summary of the evidence in the introduction, to convince the reader (early) that the need for protection of the environment is justified.

Page 9, Paragraph 10. This paragraph is vague and sounds more like a wish list than a clear proposal on how to proceed.

General Comments
There is no mention of aquatic mammals and there is only one reference insect, which is surprising. It seems that the disclaimer is made for omissions with the mention of a follow-up report (Paragraph 70), which implies that the reference animals and plants are not totally useable.

Has any thought been given to using the dolphin as a reference animal? Dolphins inhabit coastal areas, estuaries, tidal rivers, etc, and are therefore potentially exposed to a broad range of contaminants.

It is also surprising that the proportions for organs considered (particularly testes) are based on reference man (Paragraph 109) rather than specific animal data. The reference animals and plants seem to be based on ‘hand waving’ rather than specific data, but this is possibly taken into account by referral to the follow-up report.

Section 4.5.1. It is puzzling that no attempt is made to estimate internal dose, for a large mammal like the deer, using compartment models. Such models (for the cow and the sheep) have been described by Simmonds et al (1995) in “Methodology for assessing the radiological consequences of routine releases of radionuclides to the environment” (EUR 15760 EN). Since the physiology of the large mammals is complex, the ellipsoidal approximation is rather crude. The radiation protection community would certainly not use this kind of approximation for internal dosimetry calculations for humans.

The choice of reference plants and animals seems to be rather Euro-centric (or biased towards the northern hemisphere). Presumably the deer can be used to represent many other animals of similar size (gazelle,…, etc.) but the restriction to a single “large” terrestrial mammal seems rather severe. Given the ubiquity of the dog, the goat and the pig, in particular, and the acknowledgment that data are available for these animals (Paragraph 152), the choice of the deer does seem a little puzzling, unless the intention is to avoid animals and plants that could be considered as predominantly domesticated or cultivated. If this is the intention, it should be stated very clearly.

It is clearly stated that an effort has been made to choose reference plants and animals for which data on radiation effects are available (Section 2.2), but in Section 5 it is acknowledged that there is little or no data available for some of the selected reference plants and animals (e.g. the bee).

The use of Derived Consideration Levels can simplify the approach but is open to the criticism that it does not take the actual exposure scenario into consideration.