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ICRP: Free the Annals!

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Submitted by TSUYOSHI SEMBA, Japan Nuclear Technology Institute
   Commenting on behalf of the organisation
Document Early and late effects of radiation in normal tissues and organs: threshold doses for tissue reactions and other non-cancer effects of radiation in a radiation protection context

The draft report with regard to the non-cancer diseases might have big impact to the current radiological protection system. So@this document should be needed enough discussion within ICRP and outside of ICRP like the discussions which were held with much efforts during the discussions of ICRP new recommendations.


In particular, the ICRP position should be clearly mentioned to the description regarding the radiological protection which is included in the chapter 4. If it is a simple suggestion, the constructive and transparent discussion should be done including C-4 members.


Based on the draft document, some publications including@epidemiological studies have changed the current interpretation of "non-cancer effect" of radiation exposure. There are many publications even before the new recommendations (2007). The informative explanations should be added that publications during 3 years after the ICRP new recommendations have stronger impacts compared with old publications. For example, the transparent discussions regarding the threshold of "non-cancer" diseases, the risk of cardiovascular diseases and doses are expected in C-2 and 4@committee.


In this context, paragraph (667), (668) and (669) should be left for getting the basic consensus with regard to the 1% incidence, the linear relationship of circulatory diseases in the low dose area and the mechanism of "non-cancer".

The particular examinations are inevitable because of the consistency of three principles of radiological protection which have been established in the ICRP recommendations as the essence of the current RP system.