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Submitted by Satoshi Yoshida, National Institute of Radiological Sciences
   Commenting on behalf of the organisation
Document Reference animals and plants
<General comments>

This draft comprehensively describes the concept and use of Reference Animals and Plants in radiation protection of the environment, and thus it can be published with minor revisions.
However, we strongly expect that the ICRP continues to make an effort to develop a framework for environmental protection at the population and community-levels, whose importance is described at Paragraph 384 of Chapter 7.

<Specific comments>

- Table 1: It is not so common, however, earthworm is used as food or medicine. Therefore, the earthworm can be marked as +.

- Table 2: It is not clear whether the organisms in the table correspond with the definition of the RAP or not. For example, according to the definition, the Trout should live only in freshwater. However, there is a mark also in marine. On the other hand, if the organisms in the table represent more general ones, the Crab should have a mark also in terrestrial, and the Earthworm should have a mark also in water (such as bloodworm).

- Paragraph 49: The family Lumbricidae is also common in Japan (eastern Asia). It might be better to change ewestern Asiaf to eAsiaf.

- Paragraph 49: ecocoonf is more popular than ecapsulef. After the chapter 4, this term was changed to geggh. It is better to use the same term throughout the report.

- Table 3: According to the definition of reference earthworm, the earthworm in the table should be Iteroparous.

- Paragraph 65: All of this work would normally form part of an overall eEnvironmental Impact Assessmentf.
The system of the Environmental Impact Assessment is different depending on the country. In some case, it might be difficult to combine the Assessment for radiation with the others. Therefore, it is recommended to change the sentence to "All of this work would normally form part of an overall eEnvironmental Impact Assessmentf, although the situation might differ depending on the country."

- Paragraph 68: c and these sensitive stages of the life cycle for many forms of aquatic organism, or even for the adults.
The gaquatich should be removed, since this is the case also for terrestrial organism such as earthworm.

- Paragraph 69: In paragraph 111, the preliminary dose estimation considering the accumulation of radionuclide in specific organ showed only minor contributions. However, studying the radionuclide distribution inside the organism is still required for more precise determinations of dose and effects. It is recommended to add following sentence to the list in the paragraph 69.
"Un-uniform distribution of radionuclides in an organism or specific accumulation of radionuclides in particular organ."

- Paragraph 72: Some works to create the voxel phantoms for animals have been started. Therefore, it is recommended to add following sentence at the end of the paragraph.
"In addition, some works to create the voxel phantoms for animals (e.g., voxel mouse) have been started (Kinase et al., 2008; Stabin et al., 2006; Bitar et al., 2007; Taschereau and Chatziioannou, 2007; Dogdas et al., 2007) for more precise dose estimation."

S. Kinase, M. Takahashi and K. Saito, Evaluation of Self-Absorbed Doses for the Kidneys of a Voxel Mouse, J. Nucl. Sci. Technol. Suppl. (in press)

M. G. Stabin, T. E. Peterson, G. E. Holburn and M. A. Emmons, Voxel-based mouse and rat models for internal dose calculations, J. Nucl. Med. 47, 655-659 (2006).

A. Bitar, A. Lisbona, P. Thedrez, C. S. Maurel, D. L. Forestier, J. Barbet and M. Bardies, A voxel-based mouse for internal dose calculations using Monte Carlo simulations (MCNP). Phys. Med. Biol. 52, 1013-1025 (2007).

R. Taschereau and A. F. Chatziioannou, Monte Calro simulations of absorbed dose in a mouse phantom from 18-flurorine compounds. Med. Phys. 34, 1026-1036 (2007).

B. Dogdas, D. Stout, A. F. Chatziioannou and R. M. Leahy, Digimouse: a 3D whole body mouse atlas from CT and cryosection data. Phys. Med. Biol. 52, 577-587 (2007).

- Paragraph 207-216: Data for medaka fish are available also for morbidity. It is recommended to add following sentences in the section of morbidity of fish.
"In medaka (Oryzias latipes), the radiation effects on developing brain have been examined (Yasuda et al., 2006; Yasuda et al., 2008). Medaka embryos at a later developmental stage (stage 28) were acutely irradiated with 1, 2, 3, 5 and 10 Gy of X-rays, all of which are lower than the LD50 of the embryos. All the irradiated embryos survived; however, from 6 to 35 h after X-ray irradiation, massive clusters of radiation-induced apoptotic cells were observed mainly in the optic tectum. The number of massive clusters was dose dependent, and the threshold dose for brain cell death was about 1 Gy (Yasuda et al., 2008). These apoptotic cells disappeared thereafter, and the irradiated embryos continued to develop apparently normally. The grown irradiated embryos, however, had smaller brains and eyes than the non-irradiated control embryos. At hatching, the irradiated (10 Gy) embryos exhibited histological abnormalities in the brain and retina, although most of them hatched normally (Yasuda et al., 2006)."

T. Yasuda, K. Aoki, A. Matsumoto, K. Maruyama, Y. Taguchi, S. Fushiki and Y. Ishikawa, Radiation-induced brain cell death can be observed in living medaka embryos. J. Rad. Res., 47, 295-303 (2006)

T. Yasuda, M. Yoshimoto, K. Maeda, A. Matsumoto, K. Maruyama and Y. Ishikawa, Rapid and simple method of quantitative evaluation of neurocytotoxic effects of radiation on developing medaka brain. J. Rad. Res., 2008 (in press)

- Paragraph 384: Works for accessing the effects on community level and ecosystem level are already started. Therefore, it is recommended to change the last sentence as follows.
"Nevertheless, some works were already started somewhere (e.g. Fuma et al., 2003; Doi and Kawaguchi, 2007), and thus developing an understanding of the effects of radiation on a limited number of animals and plants, at the c.."

Doi, M. and I. Kawaguchi, Ecological impacts of umbrella effects of radiation on the individual members. J. Environ. Radioactivity, 96, 32-38 (2007).

Fuma, S., N. Ishii, H. Takeda, K. Miyamoto, K. Yanagisawa, Y. Ichimasa, M. Saito, Z. Kawabata and G.G. Polikarpov, Ecological effects of various toxic agents on the aquatic microcosm in comparison with acute ionizing radiation. J. Environ. Radioactivity, 67, 1-14 (2003).

- Tables 30 to 35: There are some inconsistencies with text. In tables 30 and 31, DCCs for external exposure should be removed according to paragraph 122. In tables 34 and 35, gGrass meristem - planeh should be gGrass meristem (layer) - planeh. In tables 32 to 35, the columns for internal exposure should be vacant.

<Typographical errors>

- Page 5
4.5.9 The Reference Earthworm =>4.5.9 The Reference Earthworm

- Paragraph 55
Cyclosporean => Cyclosporeae
The Cyclosporeae is not a name of family but class.

- Table 3, Population characteristics of duck, frog, trout, flatfish and crab
Iterparous => Iteroparous

- Paragraph 76, line 7
Remove g)h.

- Paragraph 141, line 3
Jung et al. 201 => Jung et al. 2001

- Page 103
Figure 9 hides a part of the text (paragraph 375).

- Tables 28
Biota: soil => Biota: animal

- Tables 30, 31, 36, 37 & 38
Biota: animal => Biota: vegetation