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Submitted by Hartmut Schulze, German-Swiss Fachverband
   Commenting on behalf of the organisation
Document Protection of the Environment under Different Exposure Situations

The German-Swiss Fachverband recognizes the efforts of the ICRP to protect plants and animals against high radiation. Our opinion is to apply a holistic sight to this objective. Another point is that the scheduled recommendation should give practical advice to apply it for environmental impact assessments. So the draft of the system of environmental radiation protection presented here by ICRP needs still a lot of discussion and work.

We support the idea that it is not about the protection of single individuals in contrast to the human but the protection of populations, the conservation of biological diversity, of species and ecosystems. But RAPs and representative organisms are always individuals and the DCRLs reflect the possible effects on individuals. It seems unanswered how radiation has an effect on ecosystems.

Some significant differences in protection of man and protection of the environment have been concealed in the draft. The assumption that if man is protected also the environment will be should be retained as described in the document ICRP 103. Not to mention this would give the false signal that the environment has been insufficiently protected in the past.

The document sees in “major nuclear facilities” the prominent area of application of the new system of environmental radiation protection. It overlooks by this that radioactive discharges are very well and tightly regulated in all countries with nuclear installations. This well regulated and controlled field does not need further affords of protection.

Emergency exposure situations should be excluded from the system generally. Here the basic assumption that protection of man ensures also protection of the environment prevails.

The document has as starting point the environment which may be affected by radiation. Another starting point would be to investigate the source of radiation and start from there. To find an appropriate solution both aspects have to be taken into account. So, we propose that ICRP will involve all stakeholders ranging from professionals dealing with the protection of plants and animals to experts from the nuclear industry. So the R.P. community should find an appropriate way of a possible development of environmental radiation protection with due regard of the current situation in operating nuclear facilities.

In dealing with existing exposures the exposure by natural sources is unsatisfactory mentioned in contrast to ICRP 91. Natural radiation sources are part of every environment.

The criteria for choosing the DCRL’s in Annex 1 are not transparent.

The Swiss-German Fachverband suggests discussing the protection of environment in a wider context and to enclude more other institutions for example UNEP or IRPA. It is necessary not to distinguish between radialogical protection and other environmental protection. The Fachverband is available to collaborate in such a process.