|The Nuclear Information and Resource Service asks the International Commission on Radiological Protections to
1) Allow comments to be emailed to your secretariat as well as uploaded on to the website as the website is not
always accessible and the space for upload onto the site is limited
2) Reject the notions of exclusion and exemption of manmade radioactive materials especially from nuclear power and weapons production:
The radioactive materials generated should be managed with a goal of preventing exposures not dispersing the material thus the exposures.
Discourage and prohibit deregulation of nuclear materials and activities. Reject the notions exclusion and exemption for manmade radioactive materials,
and practices (artificial sources of exposure). Reject use of a threshold to deregulate nuclear materials.
3) Expand consideration of radiation impacts to include all deleterious effects, not just fatal cancers and gross genetic effects. Incorporate
increased radiation risks from the studies of the bystander effect and genomic instability. Take into account increased risks found in recent
research on low-level radiation impacts, including bystander effect and genomic instability. Recognize the greater damage
associated with internal emitters, including the greater biological effectiveness of alpha emitters. Account fully for organ impacts from inhalation
4) Replace “Standard (or “Reference”) Man” or “Most Exposed Individual” with “most sensitive members” of potentially exposed populations in
calculations and regulations.
5) In calculating doses and risks to individuals, include all sources of exposure (“routine” and accidental releases from reactors, industrial,
medical and military facilities, “recycled” wastes in consumer products, etc.)
6) Support the NIRS’ nominations to ICRP’s new Committee #5 on nonhuman and environmental exposures, Drs. Judith H Johnsrud and Dennis
Nelson from the US.
[This is only a partial submission of our comments.]