In these comments below, I am only referring to the regulation of low level radiation. High levels of radiation should be regulated with simple rules for efficient maintenance of good health of the population. ICRP 2005 draft: Page 2: (S6) This is because there is presumed to be some probability of health effects even at small increments of exposure to radiation above the natural background. ICRP 2005 draft: Page 16: For protection purposes, it is assumed that these effects increase with increasing radiation dose , with no threshold, and that any increment of exposure above the natural background produces a linear increment of risk. Comments on the above two items: WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! WRONG! (a) These presumptions are contrary to the position statement of Health Physics Society, which states in part: "Below 5-10 rem (which includes occupational and environmental exposures), risks of health effects are either too small to be observed or are nonexistent." (See: http://www.hps.org/documents/radiationrisk.pdf) These presumptions are also contrary to available data on cancer incidence of various populations which have been subjected to a wide range of background radiation levels. LNT hypothesis is DEAD. (b) The worldwide natural background radiation is not a constant. It varies considerably from location to location, with no significant observed adverse health effects from being exposed to elevated natural background radiation levels. In fact several studies have reported the opposite: i.e. improved health with increased background radiation. Thus, the basic assumptions made above are without merit. Thus, the current draft which is based on these wrong assumptions is to be rejected. _________________________________________________________________________ ICRP 2005 draft: Page 42: (158) The worldwide average annual effective dose from all natural sources, excluding radon, quoted in the UNSCEAR (2000) report is 1.2 mSv with a range of 0.8 to 2.4 mSv. This has been rounded by the Commission to 1 mSv/yr. A general scheme for the need for action and the level of dose, as a fraction or multiple of the average annual natural background, has been proposed by ICRP and is shown in Figure 3. Comment on above item: In the absence of any demonstrated adverse health effects at these low radiation levels, using the average value of 1 mSv/year as dose limit is not justified. Since people have lived in much higher background radiation levels in many parts of the world, and they have not shown increased incidence of cancer, the dose limit should be based on the highest background levels in which people have lived without increased incidence of cancer, e.g. 1/3 of the highest natural background levels without increased incidence of cancer, to give a safety margin. The present regulatory low dose limit for public has certainly led to tremendous waste of our resources without any measurable benefit (except to the regulatory bodies and the radiation protection associated industries) _________________________________________________________________________ ICRP 2005 draft: Page 42: (159) The need for action is likely to be high if an effective dose from a single source is more than about a hundred times the global average background dose. Individual effective doses of about 100 mSv are therefore about the most that should be allowed for workers in any other than saving life or preventing serious injury, or preventing catastrophic circumstances. Comment on above: Why hundred? The factor of hundred times the global average is arbitrary and is unjustified. The limit should be set at a fraction (e.g. 1/3) of the smallest dose that has been shown to be harmful, in order to give a margin of safety. _________________________________________________________________________ _________________________________________________________________________ GENERAL COMMENTS: It is unfortunate that superstitious beliefs such as LNT Hypothesis are held with religious fervor by the ICRP members and the members of so many National Organizations (IGNORING EVIDENCE and WITHOUT SOUND BASIS) to the detriment of the population at large by diverting vast resources from other needed beneficial societal expenditures. Belief in LNT hypothesis is causing more harm than good. The members of ICRP should note that ICRP will be held responsible for causing tremendous waste of our precious resources by their dogmatic adherence to and propagation of the discredited LNT hypothesis. It is irresponsible of ICRP to make these recommendations without justifying the reasons behind their superstitious beliefs. Has a cost-benefit analysis been done by the ICRP for the consequences of the recommendations? The costs are tremendous. The benefits are small. The recommendations are not justifiable. A recent report (http://www.jpands.org/vol9no1/chen.pdf) describes the much-reduced cancer mortality rate of a group of population in Taiwan that was exposed to increased levels of radiation from contaminated steel in buildings 2 decades ago. This adds to the body of evidence that is collecting in support of the idea of radiation hormesis. In the ICRP Draft, there is no discussion or acknowledgement of the body of literature on the hormetic effects of low level radiation. It is indeed ironic that the organizations that are supposed to be improving our health are doing the opposite by ignoring experimental evidence and acting in a dogmatic and superstitious manner. ICRP should abandon the present draft, go back to the drawing board, admit to the errors in previous recommendations based on LNT hypothesis, arrive at a reasonable level of regulation based on experimental evidence, and get it right this time. What we need is a revolutionary change and not an evolutionary change in the attitute towards low level radiation based on factual evidence. I do not have much hope that the present ICRP or the national organizations are capable of such a revolutionary change in view of the tremendous economic interest that is served by the presently prevalent radiation-phobic radiation protection standards. A grassroots movement by the scientific community or legal action by affected people may be needed to force the national organizations and ICRP to act in the best interests of the people.