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Submitted by Takashi Nakamura, Deputy President of Radiation Council of Japan
   Commenting as an individual
Document 2005 ICRP Recommendation
 
Comments for maximum dose constraints

1) No physical/biological meanings on the values of 100, 20, 1 and 0.01 mSv/y, only the round numbers, because these values are not based on the biological risk estimates.
2) The ICRP recommendations shall only give the concept of the radiation protection, such as dose constraints, but not give the definite numerical values of dose constraints.
3) Even if the ICRP strongly requires to give the numerical values, the maximum dose constraints shall be 500 mSv for emergency workers, 100 mSv for occupational exposure, 5 mSv for normal situations, otherwise the dose constraints, not maximum dose constraints, must be given as the ranges, such as 100 to 500 mSv for emergency workers, 20 to 100 mSv for occupational exposure, 1 to 5 mSv for normal situations.
4) The regulation must be based only on the dose limits and the dose constraints must be used only as a guide line or a goal for efforts.

Comments for exclusion level

1) The numerical numbers of the exclusion levels are also no-risk-connected round numbers. These values are smaller than the NORM levels in industrial use, which induces a big confusion. The values must be re-considered and a clear explanation about the levels is required.

Other comments
1) All numerical values, such as radiation weighting factors, tissue weighting factors, dose conversion factors and so on, must include errors in scientific basis. How the ICRP considers the errors ?