|Any publication by the ICRP should be clearly written and have the general objective of improving radiation protection. I believe the document "The Scope of Radiological Protection" does not meet the first of these criteria and will not lead to a better understanding of the scope of the principles of radiation protection. In general the document appears to be heavily reliant on publications of the IAEA and not to have sufficiently considered approaches developed elsewhere.
In the case of doses received by air crew as a result of cosmic radiation, the document's authors appear to be unaware that there has been regulation within the European Union for several years which has limited the individual doses that may be received by air crew and that this regulation has improved knowledge and assessment of this source of exposure as well as providing a high level of protection against radiation hazards to such crew. While it is clearly correct to exclude doses from cosmic radiation at ground level from the scope of radiation protection regulations, this is not the case when human activities such as civil aviation result in increased doses to a large global workforce. Doses due to cosmic radiation in the field of civil aviation should not be excluded and should be exempted only in cases where the flight altitudes can be predicted to result in annual effective doses to individuals of less than 1 mSv.
There is some confusion in the reasoning given for applying the exclusion principle to artificial radioactive substances. I believe that there is no case for applying exclusion to artificial radioactivity which is always amenable to some form of control. Such control may of course be undesirable or unacceptable and this can be dealt with by using exemption to prevent unwarranted regulation.
I think the remarks made in relation to the concept of clearance could be rewritten to improve clarity and to take better account of the comprehensive work done by the European Commission in this area; I would add that the comments opposing the use of "conditional clearance" are apposite. Clearance can and should mean only the complete removal of the cleared material from regulatory control.
I believe the document to have some helpful aspects, but it should be completely rewritten to improve clarity and remove ambiguity.
I would like to thank the Commission for providing the opportunity to comment on its proposed publication.