|We welcome the opportunity to respond on these draft recommendations.
Our primary comments are:
1 We do not support the inclusion of the 0.1 and 0.01 Bq/g exclusion levels. They are neither well explained nor well-founded in science.Their incorporation in the proposals is not in keeping with the remainder of the document in style or intent and could in fact spark distracting debate.
2 The ALARA/ALARP concepts and language appear to be being "lost" somewhat within the term Optimisation.This is a concern, given that practitioners now understand and respond well to advice under the former terminology.
3 Further clarity on the commission's view on the appropriate and inappropriate uses of Collective Dose is needed.
4 The concept of Constraints, although clarified somewhat since their first mention in previous publications, still requires careful explanation about their value in practice.
5 The elements of the recommendations relating to Medical Exposures ,which is of interest to a large part of our customer base, could be more coherently collated and presented in the document.