|I am writing on behalf of the Canadian Nuclear Association (CNA) to provide our comments on the draft ICRP recommendations on Radiological Protection. These comments are general in nature and I would refer the ICRP to comments submitted by Robin Manley for more specific details on the views of a broad cross-section of the Canadian radiation protection community including representatives from a number of CNA member companies.
While the CNA feels that the current draft is an improvement from the 2004 draft and applauds the ICRP for its consultative process, CNA members feel that there remains considerable work to do in clarifying and better defining terminology as well as providing better rationale (ie: constraints). The CNA also remains convinced that there is neither adequate justification or the need for changes, which if adopted, would compel new regulations.
While recognizing the challenges of terminology in an international document, CNA members feel that the document could be enhanced by clearly defining what the ICRP means by terms such as exclusion, exemption and clearance. The CNA believes that the concept of clearance should be added to Section 2 of the recommendations and that clearance be clearly defined. CNA recommends that Section 2.4 be used as the basis for the harmonization of the concepts of exclusion, exemption and clearance in international standards.
One of the major concerns with the document is the definition and use of constraints. CNA members recommend that the section on constraints begin with a clear definition and rationale. We would also recommend moving most of the discussion of constraints to a single section and minimizing substantial discussion in other sections. CNA members would also like to see the ICRP allow greater input from operators when establishing dose constraints.
The CNA strongly supports the ICRP’s recommendation that collective dose estimates should not be used as a predictive tool to estimate hypothetical numbers of cancer deaths, particularly into the distant future. In fact, the CNA would like to see this reference strengthened.
Finally the CNA would like to strongly encourage the ICRP to do another round of consultation after the next revision.