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The draft should reflect more the principle of optimization as the central recommendation in ICRP 103.
Nowadays exist computational tools for flight planning to optimize fuel consumption and flight time. These optimization programs can be extended to include route doses as an additional optimization criterion. Not necessarily with highest priority but as a mean for the pilot to make a rational and informed decision. The individual route doses saved may seem to be small and negligible, but this should not be a legitimate argument. We often optimize work steps in the nuclear and other work sectors by micro-Sieverts.
On route, dose rates and its changes are nowadays easier to measure than during the times of ICRP 60. Dose rate instruments at least in long-haul-aircrafts on very northern routes may also be a practical tool for pilots to optimize route doses.
This ICRP recommendation addresses a global audience. It should avoid a Eurocentric perspective. Therefore, it should consider the enormous increase of polar flights between America and Asia by business globalization (from 401 flights in 2001 to 9.658 flights in 2010, cf. FAA Examination of Space Weather in support of Aviation, AMS 7th Symposium on SWx, January 2010).
It should also be future oriented and consider the technical development of ultra-long-range aircrafts with cruising altitudes of 15.000 m and the organizational development with longer non-stop flights (e.g. New York - Singapore, 15h).
It should widen its protective view to other occupational groups exposed to cosmic radiation (frequent flyers such as air couriers, sky marshals, medical flight services). They may receive considerably higher annual doses than many monitored aircraft crewmembers.
Other than in workplaces on the ground radiation protectors have little knowledge about the commercial pilot job and what degrees of freedom commercial pilots on intercontinental routes have in flight planning and on route. Thus, stakeholder involvement of pilots and airline organizations is most important in order to figure out what means for optimization can be applied.
Usually, national regulations follow the ICRP recommendations. Here it is the other way round: Within Europe the protection of aircraft crews is already implemented successfully in numerous European countries for more than a decade and plenty empirical data are available based on official dose monitoring of aircraft crews. Thus, an ICRP recommendation should not deviate from an already successful national practices but improve these practices by giving guidance to optimize cosmic exposure under the aspect of future challenges.
188-192: Consider air couriers, sky marshals, medical flight services as occupationally exposed.
227: ad (ii) On-board dose and dose rate measurements
363-367: Excess relative risk. the definition should be cross-checked by a radiation epidemiologist
525: Fig 3 see comment to Fig. 7
577-579: I doubt that this is always possibe: tropical thunderstorms occur frequently around the equator region in ca. 5 km altitude. Destination airports at tropical islands or alike leave little room to avoid thunderstorms.
614-617: Dose calculation applies for does monitoring but not for optimization on route.
Fig. 7: Write " Frequency distribution of annual doses for aircraft crew compared to nuclear and industrial workers"
Correct legend: "Nuclear and industrial workers ..."
Correct (Frasch 2011) with the reference "Frasch G., Kammerer L., Karofsky R., Schlosser A., Spiesl J., Stegemann R. 2011 Die berufliche Strahlenexposition des fliegenden Personals in Deutschland 2004 – 2009, BfS-SG-15/11, p. 42, Salzgitter August 2011."
Fig 7 is not exactly the same as in the publication. Please check and choose. Download under
This may also be a better reference for Fig 3.