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ICRP: Free the Annals!

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Submitted by Janice Milne, SEPA
   Commenting on behalf of the organisation
Document Optimisation of radiological protection
 
The Optimisation of Radiological Protection
Thank you for providing the Scottish Environment Protection Agency (SEPA) with the opportunity to
comment on the above consultation document.
In any further consultation, we would urge the Commission to ensure that all stakeholders are provided
with the means to engage fully. A useful model for relaying technical information to audiences with
various levels of awareness of specific issues is that developed by the organisation ‘GreenFacts’
(http://www.greenfacts.org). GreenFacts provides an information and educational website on
environmental issues in which the information is presented in several layers, beginning with the most
basic description of the issue where terminology is defined, and progressively including more technical
information within each of the subsequent layers. We believe this format provides a valuable approach
for information provision that acknowledges the different needs of stakeholders.
SEPA uses the principle of optimisation in many of its considerations of authorisations to ensure that
discharges use best practicable means (BPM) to minimise the impact on the environment which is
comparable to the ALARA concept.
It is our belief that the application of optimisation principle before the commencement of an undertaking
can reduce the potential impacts on the environment and we therefore consider that the schematic in
Figure 1- Planned situations should be revised to demonstrate that application of optimisation can
reduce the dose as the operation begins.
As an environmental regulator, SEPA are aware that the principle of protection of biota is being
considered by ICRP. SEPA are interested to know how environmental considerations would be
included in an optimisation principle, when such a principle is built around doses to man and therefore
explicitly exclude any environment where man is not present. Do these considerations relate purely to
man’s use of the environment or more broadly?
SEPA is supportive of paragraph 39, which introduces BAT and BATNEEC and moves the focus from
reduction of the probability of exposure/harm to emission reduction at source.
Paragraphs 48 to 54 outline the possible role of an individual in determining the outcome of an
optimisation process. It is unclear to SEPA, how such an individuals’ concerns could facilitate the
optimisation process. Although it is vital that all information is gathered and individuals view that a given
dose is acceptable should not mean that the optimisation process has been completed.
The concept of a dose matrix is of potentially high value. However, the critical group should be retained
and relative weights should be assigned to this group rather than the mean individuals’ dose.

As a public body committed to openness and transparency, SEPA feels it is appropriate that this
response be placed on the public record. If you require further clarification on any aspect of this
correspondence, please contact Paul Dale, SEPA Corporate Office, at the address shown below.
Yours faithfully
Janice Milne
Head of Environmental Policy