Draft document: Recommendations
Submitted by Chris Kalman, Lothian University Hospitals Division
Commenting as an individual

I am very happy to see the amount of changes in the new recommendations draft. In particular, the majority of the points which I attempted to raise in the earlier consultation have been addressed. The report now does, in my view, give an appropriate level of exposure to the principles of radiation protection. My preference, however, would still be to see a titled section on principles in the index. As the recommendations currently read, a non-expert would have to read a significant amount of text to identify basic principle consideration. It is gratifying to see a significant coverage of collective dose, and some description of the nature of the use of this concept. I was also pleased to see that safety culture is now more appropriately considered in terms of event reduction and the text identifies radiation in terms of health effects. That being said, I think it would be useful to include the phrase ‘safety culture’ within the definition list. My principle remaining concern centres on the potential for radiation protection systems as advised by the Commission to feed public alarm and misunderstanding with the potential for gross differences in regulatory requirements between different sources. Paragraph 46 indicates that the criteria for deciding whether regulatory controls are warranted has multiple attributes and should not be determined by radiation dose clone. This is clearly appropriate and sensible. I would however suggest that the Commission makes it clear that its recommendation apply to all radiation dose situations, and systems where doses of similar magnitude attract vastly different regulatory requirements cannot be justified in radiation protection terms, and are unlikely to aid public understanding. The requirements for exemption listed in paragraph 45 include a statement that the source should be ‘inherently safe’. It is not clear exactly what it meant by this phrase and it does not appear in the definitions. While it may be possible to define regulatory criteria for exemption, it is also important to translate these into the system of regulation for non-exempt practices. For example, if an industry is exempt because its doses are considered trivial, it has no requirement to consider dose reduction. A non-exempt industry with a dose reduction programme may lower its doses to the trivial level of the first, what is the regulatory justification for pressing for still further expenditure and reduction? Such considerations could end up in circumstances where the radiation protection requirements were considered anti-competitive. These concepts are discussed in the recommendations again in the paragraphs around 290. Para 292, in particular, talks about the potential for perceptions. What appears to be missing is a clear statement from the Commission, that it does not hold this perception and that a vital part of its recommendations are that there is no such difference in risk. I am not sure that I could agree that public concerns led the Commission to focus on man-made sources, I have always regarded the Commission’s recommendations as being related to radiation exposure. It may be true that there are political and public perceptions in these areas, however I believe that there is an absolute requirement for the radiation science community to make it clear its recommendations for radiation protection that all sieverts are equal.