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Submitted by Pr Yves Cordoliani, French Society of Radiology
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
4.2.4 Radiation effects on the embryo and fetus

We are concerned about the formulation of the second sentence of the paragraph 116 :
"...for practical purposes, the Commission judges that risks of malformation after in utero exposures to doses in the range up to a few tens of mGy may be discounted"

ICRP 84 clearly stated that malformative effects have a true threshold "of 100 to 200 mGy or higher" and provided very useful guidelines on management of exposure of a pregnant woman by radiological examination. To be able to provide clear reference from ICRP helped radiologists to reassure pregnant women before a justified examination or after exposure of an unknown pregnancy. A large majority of radiological diagnostic examinations delivers doses lower than 100 mGy but many examinations result in doses higher than 20 mGy. To replace the value of 100 mGy by a hazy "few tens of mGy" would compromise the positive effects of the ICRP 84 on the management of these events and lead to unjustified interruptions of pregnancy for doses lower than 100 mGy.