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Submitted by Hiroyuki Ryuu, Federation of Electric Power Companies of Japan Radiation Management Committee Chair
   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

 @Submitted@by@Hiroyuki Ryuu@@@@



@@@@@@@@@@@@@Federation of Electric Power Companies of Japan

                @@@@@@@@@@@@@Radiation Management Committee

                @@@@@@@@@@@@@Chair Hiroyuki Ryuu


  I would like to thank ICRP for the opportunity to provide comments the draft document. On behalf of FEPC RMC I would like to submit our comments on the document as followsD


(1) General comment

We do hope that ICRP would give careful considerations from the scientific viewpoint on the determination of threshold doses since there remain high uncertainties regarding non-cancer effects of low dose irradiation. Discussion involving a wide range of stakeholders should be held before incorporating the threshold dose into the radiological protection system.


(2) Particular comments

E         The epidemiological data, which the draft report places a basis for the review of threshold doses, lack consistency, and there is no established theory regarding linear dose responses. In addition, there is no biologically plausible mechanism. Therefore, it is necessary to accumulate more data and clarify the biological mechanism of non-cancer effects of low dose irradiation.

E         It is necessary to take into account the effect of doses and dose rates in determining the threshold dose and dose limit.

E         The review of threshold doses should be conducted in a careful and steady manner in consistent with the positions stated by important international organizations, such as UNSCEAR.

E         Regarding threshold doses for lens, the description about opacity and cataract should be distinctly separated.

E         An annual threshold dose of 12mGy for cardiovascular disease should be eliminated since such a numerical value is not supported by any epidemiological or biological basis.