|This document addresses important concepts having significant influence on the current radiological protection system, including the future risk concept, usage of epidemiologic study results, and gexisting exposuresh, which is a new concept described in ICRP Pub103. Therefore, we should carefully review the document and have thorough discussion.
E As described in ICRP Pub99 (Low-dose extrapolation of radiation-related cancer risk), ERR per 100Bq/m3 radon concentration (WHOfs number) or 300 Bq/m3 (ICRPfs number) seems unreasonable considering the power of epidemiologic studies. It is necessary to consider the consistency with the ICRP publications.
E The risk concept should be reviewed and reorganized if necessary. Reviewing risks from radon exposure to non-smokers driven by high risks from radon exposure to smokers is not consistent with the concept of radiological protection. ICRP has been carrying out risk evaluations based on the nominal value which was produced to consider effective doses and dose limits. Incorporating risks from smoking into the concept of nominal value will deviate from the original intention of radiological protection.
Although smoking was not originally incorporated into the concept of nominal value, smoking is one of the important carcinogenic factors from the social viewpoint. If radiological protection for low dose exposures cover the management of cancer risks as well, it is necessary to deliver a message to the public from the viewpoint of radiological protection that risks from smoking are not independent from radiation exposure. ICRP may be required to clearly state that the control of smoking will lead to reducing risks from radiation exposure.
The term gentry pointh, which appeared in the statement of November 2009, has not been used since then. After the publication of ICRP 103, ICRP has already published some publications. Even the concept of three types of exposure situations has been still moving. ICRP should consider the important concepts which are contained in the publication once again in front of the coming nuclear era.