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Submitted by Maurice Phillips, United Kingdom Ministry of Defence
   Commenting on behalf of the organisation
Document Health risks attributable to radiation
The United Kingdom Ministry of Defence (MOD) has reviewed the ICRP proposals in the ICRP foundation document titled “Biological and Epidemiological Information on Health Risks Attributable to Ionising Radiation” and has the following comments to make:

General Comments

Although it is recognised that ICRP is trying use a new name for Deterministic Effects to better describe what they are, the use of the term “Tissue Reactions” is unhelpful and likely to confuse rather than clarify. Stochastic effects also can result in tissue effects i.e. cancer in any organ or indeed, of the “Remainder Tissues” listed in Table 4.3. Hence a new name is required.

Since the consultation period started the International Agency for Research into Cancer (IARC), published, on-line, on the British Medical Journal website on Wednesday 29 June 2005 the findings of its latest study. The study has included the greatest number of radiation workers (407,391) over the greatest period of cumulative follow-up (5,192,710 person-years, average 12.75 years per person) yet performed. It is suggested that ICRP consider this study before publishing this report.

Specific Comments

Page 46 Fourth Paragraph. This section covers the dose and dose rate effectiveness factor. However, the report does not state what it considers by a high dose rate other than 200mSv delivered acutely. It is suggested that a better indication is given.

Page 55 Second paragraph bullets. Values of wT are given for gonadal cancer, thyroid cancer and cancer in the salivary glands and brain in which judgements were applied. It is recommended that more detail is given of how these judgements were arrived at to give greater transparency.

Page 57 First paragraph. The concept of detriment adjusted nominal probability coefficients for cancer and hereditary effects based upon lethality/life impairment weighted data on cancer with adjustment for relative life lost will not be an easy concept for radiation protection professionals to explain to their workforces or members of the public. It appears to go against the main philosophy contained in the draft 2005 recommendations to simplify radiation protection so that the majority of the public can understand it. ICRP may wish to revisit the wording and the narrative to simplify the text or add more explanation. It would also be useful to have comparable figures, possibly in parenthesis, using the ICRP Publication 60 detriment calculation based upon fatal cancer risk weighted for non-fatal cancer, relative life lost for fatal cancers and life impairment for non-fatal cancer to enable a direct comparison to be made with ICRP 60 values.