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ICRP: Free the Annals!

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Submitted by Paul Kennedy, The UK Food Standards Agency.
   Commenting on behalf of the organisation
Document Protection of the Environment under Different Exposure Situations

Because many of the sections deal with non-human species in isolation rather than as part of their impact as food stuffs to man, the comments we can make are probably quite limited.

However, in certain exposure pathways described in the document, which could potentially drift into some of the work relating to the food chain, particularly if there is an unclear distinction between “farmed species” and “wildlife.”


General Comment and Lines 2030-2043:We would wonder whether this document would require FSA to undertake a wildlife assessment in addition to those currently done for man and those undertaken by the Environmental Regulators and Applicants.

General Comment:There appears to be the odd discrepancy in the lexicon, in that although most of the document is written in International (American) English, there are a few parts which are written in using UK Spelling.

We presume that International English would be more appropriate for this document.

Line 168, Executive Summary This might read better with “(RAPs)” after, “Reference Animals and Plants” rather than at line 253, which is the first noting of the abbreviation in the text.

Line 303, Glossary This might read better with a space between “practices” and “that.”

Line 1352 With regard to “farmed” animals, would game species, such as venison or pheasant fall within this category?

Line 1393 We were wondering whether gender of wildlife species has a measurable effect on the doses calculated.

Lines 1498-1510 We would wonder whether something equivalent to a “habits survey” for animals would answer many of the questions posed in this paragraph.

Lines 1653-1670 Some of the exposure pathways might, depending on species of interest might affect assessments to the food chain and certainly these have been discussed in meetings relating to heterogeneous contamination.

Lines 1768-1774 This section deals with reference shapes and sizes of the reference organisms.

Would consideration of geometry of certain organisms (as can happen with certain human “worker” exposures) be helpful in terms of the assessment?

Appendix 1: Tables of Dose Rates and Effects for Reference Animals and Plants We feel it is not very clear whether this is a compilation of the Dose Concentration Factors or the effects of dose upon the organism.