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Submitted by Jack Valentin, Jack Valentin Radiological Protection
   Commenting on behalf of the organisation
Document Ethical Foundations of the System of Radiological Protection

Of course this is an excellent document with a lot of useful information - how could it not be, with so much work behind it and so many clever people involved?

That said, now let me focus on what I regard as the main problem with it. I think the document does not focus on the ''Ethical Foundations of the System...'' - it deals with tools and checks that should be applied when trying to ensure that RP is handled in an ethically satisfactory manner, but it does not help the reader to take RP decisions because it evades the issue of conflicting goals..

(Here, it would have been useful to apply the terminological difference between ethics, as a school of thought about behaviour and decision-making, and morals, as the extent to which one bothers to follow the selected ethic. I am aware that not all ethicist make this distinction, that some regard ethics and morals as synonymous, but the distinction does simplify discussions).

The reader gets the impression that the classical theories (virtue-utilitarian-deontological) aren''t really important, while the four core values will solve all RP problems. Unfortunately, that''s not true. It is telling that the core values were once formulated by a deontologist and a utilitarian trying to find a common denominator that they could agree on. In other words, everybody agrees that these four values should be respected. But radiological protection is not free of conflicting objectives. There are lots of practical situations where ones preferred fundamental theory (and, as a corollary, political persuation) will decide which route to take - often leading to completely different and contradictory solutions, all of which however are (or at least, can be) compatible with the core values.

This is not to say that the core values are useless - they are important and it is helpful to have them explicitly listed and explained.

However, much of the material which is now in Annex A should have been presented in the main text and the importance of the deontology/utilitarianism conflict for decision-making should have been underlined. Ideally, the Annexes should include some worked examples of possible different conclusions and RP decisions taken by different people favouring primarily utilitarian or primarily deontological ethics. If the examples could then also show adherence to, and deviations from, the core values, so much the better.