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Submitted by Dr. Rosalie Bertell, International Inst. of Concern for Public Health
   Commenting as an individual
Document 2005 ICRP Recommendation
1. ICRP is continuing to use an average dose to the organ in the face of many indications that non-homogeneous distribution is the norm rather than the exception. This will reduce the true dose to exposed tissue in sensitive organs. This together with the weakening of recommendations for dose limits will severly undermine health protection.

2. ICRP is ignoring all of the recent (and past) research on the complex low dose reactions, including a bi-phasic curve, by-stander effects, and genomic instability. The recommendations should become more protective of workers and citizens exposed to very low doses.

3. Elaborating its theoretical superstructure, when the structure is not rooted in reality, produces only a myth on which the lives and health of many people will be sacrificed. Truth is being sacrificed for an elegant theory.

I find these new recommendations a travesty of "science".

Dr. Rosalie Bertell