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Submitted by Dr. Theodore Rockwell, Radiation, Science & Health, Inc.
   Commenting as an individual
Document 2005 ICRP Recommendation
A Harmful and Unnecessary Step Backwards

The proposed ICRP 2005 document is ill-advised and harmful, both in concept and detail. It makes no mention of the vast amount of literature showing, to quote NCRP-136, “it is important to note that the rates of cancer in most populations exposed to low-level radiation have not been found to be detectably increased, and that in most cases the rates have appeared to be decreased.” Supporting data have been published in the professional literature and presented repeatedly to various regulatory bodies. See, for example,

Perhaps mindful of this fact, ICRP drops all previous effort to justify its requirements on the basis of risk. In fact, it offers little justification at all for extending its regulatory arm down to a fraction of a percent of natural background.
It concedes that “there is no major problem identified with the practical use of the present system of protection in normal situations.” Despite this fact, the report virtually scraps all previous guidance and proposes a new system, based on new principles, with new terminology and more complex and more burdensome requirements. No justification is given for these changes.

It disguises the concept of ALARA by calling it “optimization,” stating as its mission to create a state of mind that looks at every radiation exposure situation with the question: “Have I done all that I reasonably can to reduce these doses?” Since radiation dose generally results from people attending to operations and equipment in a radiation zone, a regulatory incentive to minimize such critically important safety functions actually works against safety without producing any health benefit.

ICRP’s phobic attitude toward radiation is shown by its continued insistence on treating even natural radiation as a hazard, requiring that natural radiation be regulated when it is considered “controllable” (e.g. radon and mill tailings) and ignoring it otherwise (e.g. airplane passengers, dwellers in high natural radiation areas, medical therapy).
The report warns against misuse of collective dose, but then sets up requirements that will inevitably increase its use in falsely “predicting” thousands of deaths were none would realistically be expected. This is particularly harmful in dealing with emergencies, where a minor event can be made into a life-threatening panic, and rescue workers prevented by unwarranted fear of radiation from doing their duty.

As a final insult to science and common sense, the report suggests that regulatory authorities will normally set even lower vales “but probably not by as much as a factor of ten.” This is after suggesting that where there may be multiple dominant sources, still further restraints are advised.

The report also recommends that a vast new research program be set up to determine the effects of low-dose radiation on all non-human species, which would lead to waste of public resources and even further constraints on our use of technologies involving radiation.

I strongly recommend that this entire report be rejected out of hand. It is a scientific embarrassment and a harmful and unnecessary assault on all beneficial uses of radiological technologies.
All that is really needed is to amend current regulations with a statement that “Doses below 5 or 10 rem/year are not harmful and may be beneficial. ALARA below those levels serves no useful purpose.” And “Collective dose should not be used as a measure of excellence in radiation protection, nor should it be used to predict detrimental effects such as illness or death. The only meaningful doses are those to individuals. Minimizing collective dose is not meaningful.