I was uncertain about submitting my opinions given my limited knowledge in the fields of radon and dosimetry. However I have worked several years within radiation protection, and drawing from this background I have drawn these personal opinions:
- Given that cessation of smoking reduces the risk of radon-related lung cancer more than addressing a home’s radon problem, I am not sure that the recommendation to apply risk factors for smokers to the entire population is in the best interest of global public health, nor justified economically. [Mendez, Warner, Courant, Effects of Radon Mitigation vs smoking cessation in reducing radon-related risk of lung cancer, American Journal of Public Health, 1999, Vol. 88, N. 5, 811-812]
- The document requires national authorities to characterise radon exposure in their country, and to set a national radon reference level. The document only discusses the application of one reference level, 300 Bq/m3. This reference level has a basis in simplicity; not in the matters that are to be considered by national authorities (e.g. social and economic costs to home owners, business owners; effects on health policies; practicality given radon backgrounds within the country; age and types of building construction).
- The more rigorous application of a reference value of 300 Bq/m3 will have the largest impact on older buildings; some of these buildings may have historic significance such that radon remediation measures are prohibitively costly or damaging to the structure. Further guidance for buildings of historic interest would be beneficial.
I thank you for giving me an opportunity to express my concerns. I hope that they worthy of your consideration for either incorporation, or clarification/expansion within the document.