|The following Consultation comments on the second draft of the 2005 Standards Recommendations of the International Commission on Radiological Protection are submitted on behalf of the national Sierra Club in the United States. We respectfully request that the Commission withdraw this draft for further reconsideration. To our regret, this second draft shows few improvements of protection from radiation damage, with respect to the many issues that we, and many others who commented on the previous draft, had criticized.
We incorporate by reference our comments on the prior 2005 draft document; because they still apply to most of the revised document. We do ask the Commission to review those previous comments for applicability to recommendations in the current version. In addition, we offer for this record the invited Sierra Club comments presented at the August 28-29, 2006 OECD-NEA conference in Washington, D.C. A copy was given directly to Dr. Lars-Erik Holm.
Among our numerous concerns and suggestions for improving the standards to achieve greater protection from the many sources of radioactivity, perhaps the most significant is the need for regulatory control from all sources of possible exposure, especially for members of the public.
Workers in the nuclear industries are more likely to receive a reasonable amount of information and training in practices to minimize their workplace doses. However, the ICRP's recommendations should call for management to strengthen its policies and practices to minimize even seemingly remote possibilities for avoidable exposures of employees and to fully inform. Regulatory practices, at least in our nation, appear, instead, increasingly to be relaxing regulatory operational requirements, thereby increasing the likelihood of unnecessary doses to workers. This issue should be addressed fully.
As for medical practice, many x-rays and other irradiations are now recognized to be needless, and thus are additive doses detrimental rather than beneficial for the recipient. Members of the public would benefit from educational programs by physicians and the entire medical industry to understand useful from unnecessary exposures. To this end, we urge ICRP to recommend that medical practitioners provide patients with dosage information from every exposure for which the doses can be calculated, and recommend that patients keep individual records of their exposure history, as we do for vaccinations and some medications, especially for children. Therapeutic exposures are presumably determined by competent physicians in the best interests of the patient. However, exposures of family, visitors, hospital staff, and other casual encounters post-irradiation are noted in the document as a serious issue. We suggest that ICRP urge educational radiation monitoring programs for the public who are at unanticipated, and undetectable risk. The Commission's recommendation for such programs can help to familiarize them with "normal" exposure levels and the meaning of abnormally high instrument readings, as well as their doses and cumulative exposures.
It is, however, in the realm of the standards recommendations primarily affecting the public -- unaware individuals and entire populations -- in a world that has increasing sources of exposures -- that this ICRP draft revision seems most in need of further review and improvement.
The ICRP's recommendations continue to omit consideration of "the new biology," the highly significant research and findings of microbiologists over the last two decades. The recommendations should be based in part on the low dose radiation impacts at cellular, molecular, and DNA .levels. These include, but are not limited to, genomic instability, imperfect cell repair, adaptive response, bystander effects, and others that were well described in the ICRP Committee 1 Task Group 2004 document "Low-dose Extrapolation of Radiation-Related Cancer Risk." These findings are ignored by the Commisison, ostensibly because it is claimed that the research is not fully confirmed. This position is not tenable under the principle of precaution which we have previously urged ICRP to adopt. At minimum, the caution of maximum conservatism should be applied to permissible exposures. If ultimately the caution and the lowest achievable exposures can be irrefutably demonstrated to be unnecessary, relaxation might occur, but in the interim, the public would have the fullest protection.
Similarly, the Commission dismisses long-term genetic consequences of low-dose exposures, again claiming there is insufficient "proof" of damage observed, despite the research identifying cellular damages at even low-level exposures. Maximal caution is appropriate for the protection of subsequent generations. Despite objections from some of those associated with the nuclear energy industries, the ICRP can give more credence to the Linear No-Threshold hypothesis, now accepted as cautionary by numerous agencies. The LNT should be extended to standards at even the lowest exposure levels.
Of perhaps broadest scope are ICRP's recommendations to 'exclude'
altogether from regulatory control potentially vast amounts of re-defined "low-level" materials or wastes, to be redefined as "low-activity." If exclusion is allowed, hey would be dispersed, many recycled and unidentifiable, with evidently no accountability for doses that contribute to damage for recipients.. The same is true for "exemption" from regulation, with little or no responsibility post-issuance of a "general license." The Commission should prohibit both.
The Commission should recommend more restrictive standards for ovum, embryo, and fetus than even for rapidly growing young children. The earliest exposures would be even more indictable and of genetic consequence unnoted. Abandon the use of Standard Man in all dose calculations. Averaging of exposure factors should be abandoned or at least avoided, especially in calculations doses and organ doses from internal emitters. "Collective dose" calculations should
continue to be used but only in appropriate contexts. .
The several more general bases for ICRP decision-making - e.g., optimization, justification, constraint, averaging, risk analysis, social factors (including economic factors for the industry but not the affected public) - are all open to skewed definitions and manipulations that will continue to alter the standards recommended and adopted to favor the interests of the industry, rather than the public, who are supposedly the object of the ICRP's responsibility.
Last year we recall Dr. Holm's presentation to the U.S. NRC's staff about ICRP's proposed consideration of radiation protection for all other forms of life - the entire biota. It was encouraging, and long overdue. This is, of course, an enormous undertaking. We encourage intensive focus on the radiation impacts on the other inhabitants of the biosphere and their fearfully complex interrelationships and interactions. This matter has become a far more crucial issue with the rapid advance of global climate change and the unknown consequences for the earth's biota..
Finally, there is concern that the "recommendations" of this private, self-selecting organization may be adopted as mandatory for all nations belonging to, and subject to acceptance of decisions of, other international organizations -- in particular, the various trade agreements (such as GATT, NAFTA, WTO, etc.) that promote international global commerce and "harmonization" (such as IAEA with its recently adopted transportation regulations for radioactive materials and wastes). Although such preemption authority may not currently be exercised by these or other international organizations
-- many of them associated with the United Nations -- we are advised that the authority to require sovereign nations and their subordinate bodies to comply with regulations adopted by these bodies is always present and may be exercised by vote of a majority of the members. We respectfully urge ICRP to express its opposition to any such proposal.
The entire revised draft document, and many of its annexes, would be improved by additional careful editing.
For all these, and many more, reasons, we do request that the ICRP again withdraw these recommendations and revise them to maximize human and environmental protection from radiation and radiological harm.
Thank you for attention to our comments.