|Dear Sir or Madam:
I have comments that I submit for your consideration:
1) The recommendations should include an "operational cutoff" below which doses to individuals need not be further analyzed or considered, for example in calculating collective doses to populations. I propose that this level be 10 uSv - in line with the lowest recommended dose constraint. This would not necessarily imply an acceptance of a threshold for radiation effects - but rather a practical lower bound at which virtually all informed observers would agree that ant incremental risk is far to low to observe. I believe that this approach would be more readily accepted than the dose matrix approach, which seems somewhat undeveloped.
2) Any unnecessary "tinkering" with terminology should be avoided. Extensive investments of time and money have been made to develop a level of understanding in the vast workforce exposed to ionizing radiation of terms such as "deterministic effect". Changing the terminology will cause confusion and expense far beyond that associated with any unintentioned meanings. Similarly, it has been stated that the ICRP will de-emphasise the use of term "ALARA" - what a distaster for the countless workplaces that have worked so hard to incorporate ALARA into their safety culture.
Thank you for your consideration of these comments,
Dave Tucker, CHP