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Submitted by Shinichiro Miyazaki, Nuclear Engineering,Ltd.
   Commenting as an individual
Document Early and late effects of radiation in normal tissues and organs: threshold doses for tissue reactions and other non-cancer effects of radiation in a radiation protection context

I would like to thank ICRP for the opportunity to provide comments on the draft document. The opportunity to submit and review other stakeholders comments on this document is greatly appreciated.

One of the main points for understanding this draft document is the “1% incidence”. Another is the evaluation of new documents published outside of ICRP after 2007.

The concept of “1% incidence” is used for defining the threshold doses of tissue injury on this document. It is effective for the future discussion to make clear the reason for using the concept of “1% incidence”.

UNSCEAR issues reports on a regular basis regarding the scientific view on health effects of radiation. The latest report regarding non-cancer was issued in 2006. The evaluation of new documents relating epidemiological and non-cancer research results published after 2007 should be done from the point of building consensus between major international organizations.

In this context, to make clear the interpretation of epidemiological studies is also important. Regarding non-cancer effects, an emphasis should be placed on the data from the Adult Health Study (AHS) for Hiroshima and Nagasaki atomic bombing survivors rather than the data from the Life Span Study (LSS), which is based on certificates of death. The AHS is well-known as a sub-cohort study of LLS and believed to provide accurate data regarding non-cancer effects.