|The Japan Health Physics Society / Working Group on International Issues (JHPS WGII)
The Task Group of Radiological Protection of the Environment
Comments on the Concept and Use of Reference Animals and Plants for the purposes of Environmental Protection
We appreciate the consultation process and the opportunity to provide our comments on the report.
1) Position of the Foundation Document
It is too early to include the detailed description on radiological protection of the environment into the recommendations. ICRP should, before anything else, answer numerous common comments submitted in response to the previous yearfs consultation for comments on the draft recommendations, including the following:
When useful activity involving radiation exposure is performed, it is important that a framework for environmental protection would be recommended in a manner that the perspective for the environment stated in the ICRP Pub. 60 could be further extended. However, the concept of radiological protection of the environment has not been well defined yet.
In the first place, ICRP needs to build a fundamental consensus by explicitly responding the basic comments it has received.
As is usually the case, ICRP recommendations have been used for more than ten years since they were revised. For radiation protection of the environment, not only a basic concept is yet to be established, but also basic data are now being collected through efforts such as the ERICA project. Continuity and consistency are essential factors that the recommendations should take into consideration.
Incorporating the recently announced foundation documents into the new recommendations seems to be a premature attempt. ICRP should, based on discussions with stakeholders, consider introducing this document into the new recommendations as the need arises. This would enable the ICRP to stay consistent with the notion that there is no major change in the existing assertion that protecting human beings enables protecting ecosystems. At the same time, this is also necessary to secure a scientific perspective for environmental protection.
ICRP must make clear that the environmental protection should be protected in terms of sustainable development of human beings.
2) Accumulation of Data
Accumulating a substantial amount of systematic data is crucial. Although data are being amassed under the ERICA project and through other activities, these data are yet to be organized. ICRP should consider incorporating the data into the recommendations after assuring that the data are sufficiently organized. (The ICRP must also make clear what are at hand and what will come soon from among necessary data.)
Discussion must be devoted to the specific needs for the protection of the environment. A debate on the necessity of protection of non-human species should identify problems from the scientific point of view, based on actual data on the effects of radiation on the environment and fauna and flora. Furthermore, ICRP should assess doses based on the information of radioactive substance and radiation levels in the environment and should reassess the concept and method of the current environmental management which has been carried out in a manner that radiation sources were managed in accordance with the standards.
3) Range of Protection
The range of specific potential radiation exposure situations of non-human species must be made clear and discussed under the concrete definition of time and space by assuming the operations of specific facilities within the context of the conventional assertion that protecting man will ensure protecting the environment.
4) Perception of Selecting Reference Animals and Plants
The foundation document insists on the necessity of protecting non-human species against the background of general environmental issues. It is important that this perception should include the following views.
(1) Reevaluation of the validity of the current criteria for selecting reference animals and plants as used in environmental radiation monitoring.
(2) The foundation documents stated several reasons for difficulty to generalize the effects appeared in the biota from those in the selected reference animals and plants. But this is the essential problem for selecting reference animals and plants and, consequently, it causes some suspects on the validity of the environmental protection philosophy itself, which is based on the radiation effects on reference animals and plants. The foundation document should include the statement on the validity of selecting reference plants and animals for radiation protection of the natural environment.
(3) Environmental protection is meaningful as long as the radiation effects on reference animals and plants are related to the change in the natural environment that is expressed by physical and chemical quantities. A study is needed to focus on understanding of the relation between radiation effects and the related environmental information as well as the assessment of doses for animals and plants.