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Submitted by Mrs Sheila Liddle, The Society for Radiological Protection
   Commenting on behalf of the organisation
Document Emergencies
 
Response to ICRP Consultation for the Protection of Persons in Emergency Exposure Situations 42/194/08
1. The Society for Radiological Protection (SRP) view is that the document is based on academic purity rather than practical application and could be more customer focused. It does not distinguish between science and operability. In practice, emergency planning and response needs to be very straightforward, practical and pragmatic in order to be fit for purpose. It would be beneficial if the document was separated into two sections, the first operationally focussed with practical recommendations and the second, containing the theoretical analysis for the user to refer to if required.
2. It would aid the clarity of the document if it was aligned with the two phases of implementation: emergency planning and emergency response. As it is presently laid out, it switches between phases. Similarly the terminology is also inconsistent in places.
3. It does not explain how this document will interface with extant documents, ICRP 63 and ICRP 96. The document makes references to these other documents, implying that the earlier recommendations will be extant.
4. Paragraph 19 refers to consideration of RBE, it is worth stating that it would not be appropriate to delay dose assessment during the early stages of the emergency response where reliance would be placed on electronic personal dosemeters, which are calibrated in terms of effective dose and occupation DDREF.
5. Paragraph 32 states that justification and optimisation are to be considered across all exposure pathways. This will be difficult to achieve in practice as the decision making process will involve a range of stakeholders with differing views, from protecting responders to members of the public. There are concerns about stakeholders being involved during the early stages and the financial implications making engagement particularly challenging.
6. There will need to be a balance between dose to emergency responders to saving dose to a wider population. It is possible to calculate likely theoretical doses, but the actual dose will depend on the information available during the early phases of the incident.
7. The scope of the advice refers to all emergency situations, but it does not indicate how far this should extend. Paragraph 44 state “plans are prepared for all types of emergency exposures” without any limitations or constraints on the word “possible”. Adequate consideration needs to be given to the implications of adopting this approach and there is a risk that efforts may be expended on emergency situations where they are not warranted.
It would therefore be useful to have a statement in the publication which indicated a probability cut off level. Not all countries have significant resources to expend on planning and this should be linked to the size and the extent of the exposed population.
8. Whilst ICRP fundamentally address the management of the radiation hazard and risk, however the importance of the conventional health and safety risk should be incorporated as an important component of the optimisation process.
9. 2.4.4 Paragraph 117, refers to consideration given to using pregnant women as first responders. There is no other guidance on using women as first responders, however any guidance may fall foul of discrimination legislation.
10. Figure 4 is a rather difficult chart to understand, ground and ingestion exposures are broken down into time after the event, but inhalation is not. Labels Sm-rel & Lg_rel should be explained in the text It would be more appropriate to express contributions in absolute rather than relative terms (using typical source terms.
11. Annex B, B6 Evacuation will need to consider the numbers of people and the effect of the action on the public as it will depend on the type of emergency.
12. Finally the general view is that the document needs to be more operationally focused as opposed to philosophically driven.