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Submitted by Tor Wøhni, NSFS - Nordic Society for Radiation Protection
   Commenting on behalf of the organisation
Document Recommendations
In December 2004, the Nordic Society for Radiation Protection commented on the draft 2005 recommendations of ICRP. Our comments were then presented under a number of sub-headings, and the present comments are arranged in the same manner.

We are pleased to note that a second round of consultation is arranged, according to our central proposal under this heading.

Our original comments under this heading mainly referred to the lack of transparency on a number of issues. With the publication of the foundation documents (Annex A) this situation is now greatly improved. The method for calculating detriment and the tissue weighting factors are now thoroughly described, and particularly table 4.1 is very informative. The reasons for and the effects of including the genetic risks of the first two generations only are now better explained (in 6.5.3), although we still think that this will be regarded by many as reduction in the level of protection.

The original comments of NSFS seem to be taken care of, as there is now published a foundation document (Annex B) explaining the rationale behind the proposed w~ values.

The general system of protection.
In this section NSFS made a number of comments, a.o the use of "constraints". The practical application of dose constraints has now been clarified, and it is underlined that this is a source related concept used for prospective purposes. The distinction between constraints and dose limits is now better explained. In several paragraphs it is stressed that optimisation shall still be performed below the dose constraint, and thus it is expected that actual doses will be lower than the constraint. It is not quite clear whether this is totally consistent with previous use of the term, i.e. as used in ICRP 60. Here dose constraints were presented as an intergral part of the optimisation process, i.e. to some extent the dose constraints represented the optimal level
of dose. If the meaning and content of the concept is changed, this should be more clearly explained.

Protection in medicine.
As pointed out in our comments to the 2005 Recommendations, medico-legal exposures should be addressed more thoroughly. In the 2006 draft only a few sentences concerning medical exposures required by insurance companies are presented. Important issues like medico-legal exposures for security checks, crime investigation, smuggling etc is not discussed. These issued are to-day becoming increasingly important, and should be subjected to a much broader treatment. We don't think the suggested constraint of a few mSv per episode is appropriate for all these areas.

Applications and regulatory systems.
Our original proposal under this heading was to insert a chapter on implementation of the commission's recommendations, and we are pleased to note that this has been done in the new chapter l l of the updated revision.