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ICRP: Free the Annals!

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Submitted by Kathleen Stevenson, UKAEA
   Commenting on behalf of the organisation
Document Optimisation of radiological protection
Overall the document is informative and well structured, providing a useful summary of how the topic has evolved. This allows the reader to understand the scope of the changes recommended in 2005 and set them in a logical context.

Para (25) The concept of dose constraints could be further amplified, neither the text or figure 1 help significantly with clarification of this topic.

Para (28)/(76) The concept of safety culture being introduced within the recommendations is to be welcomed. It does need to be carefully managed to ensure it is not too narrowly interpreted or becomes too prescriptive.

Para (39) There is a high degree of focus on environmental issues. It is important that ICRP recommendations are consistent with best practise in the environmntal area but ICRP should continue to focus it's recommendations on occupational exposure.

Para (54)/(55) Involvement of stakeholders in key decsions is important but responsibility should not be taken away from the operators, and should not be allowed to confuse the role the regulators have. Stakeholder opinion should be a valuable input to decision making but not ultimately be the decision maker. Stakeholder opinion should also be kept proportionate to the operation/process being undertaken.