1. These comments are a personal response to the draft document on radon. I hesitated to submit them until the eleventh hour because I knew they would be adversely critical.
2. My general view of the draft is that it makes the problem of controlling radon exposure seem unnecessarily daunting. This may be due in part to the rather abstruse nature of some basic recommendations and the difficulty of applying them to radon. The outcome is an almost scriptural degree of exegesis cluttering the text.
3. My response may also be due to an excessively sociological slant in sections of the draft, where considerable emphasis is placed on the challenges posed by radon. Some material could profitably be included about the several national programmes that have met these challenges and might serve to encourage other national authorities.
4. My third reason for being critical concerns the structure and nature of the draft. There is an appreciable amount of repetition and redundancy and quite an abstract tone to various passages. The result is that the essential radiological content is not expressed in a sufficiently clear way.
5. For all of these general reasons, I suggest that the draft should be reworked so that a coherent concrete document emerges. It might also be prudent to await the Commission''s findings on dose conversion conventions before completing the process.
6. There is little one would wish to add to the technical comments that Tony Colgan and others have already submitted, but I should like to make just a few specific points.
7. I feel that the historical perspective is rather distorted. Reference might at least be made to some significant American contributions - the NIOSH NIESH monograph of 1971, for instance, as well as the Bale memorandum of 1951. And it is chastening to note that as long ago as 1941 the NBS set a limit of 10-11Ci/l (370 Bq m-3) for occupational exposure to radon.
8. The notion that places of work exist where exposure to radon may not be regarded as the responsibility of management is puzzling. If a worker became exposed to legionella, for example, or to carbon monoxide, or simply fell on a slippery floor, it is probable that the management would be held accountable. Why should radon be an exception?
9. And so to my last point! The draft reflects the early ICRP pre-occupation with uranium mining, which in consequence is well regulated. But other non-coal mining also needs radiological attention: more miners are employed in the industry, conditions underground can be harsh, and mortality from accidents and pneumoconiosis pronounced. The opportunity might therefore be seized in a revised draft to advocate appropriate protection against radon for these miners.