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Submitted by Tor W√∂hni, NRPA - Norwegian Radiation Protection Authority
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
The Norwegian radiation protection authority (NRPA) is the competent authority with regard to the radiation protection in Norway, and the regulatory body with regard to the national radation protection legislation.

In Norway, the radiation protection legislation has recently been revised. The new radiation protection act was put into force in 2000, and a new set of regulations on January Ist this year. The act as well as the regulations reflect many of the basic ICRP recommendations, i.e. the principles of justificationand optimization, dose limits etc. We are pleased to observe that the present draft does not contain major revisions requiring immediate changes in our legislation.

Our comments to the new 2005 ICRP Recommendations refer to the legislative and regulatory aspects of the draft document. ..

- The concept of dose constraints was also applied in ICRP60, as a guideline for which dose levels could be achieved by optimization in various fields. In the new document, dose consttaints seem to be applied in a more formal manner, and it is not clear whether the recommendation is to formalize them in the same way as dose limits. This should be described in more detail. The increased focus on dose consrtaints has led to an appearent reduced importance of the dose limits. This may be unintentional; and if so the basic dose limits should be presented in a more explicit way.

- The principle of justification is one of the comerstones in the basic system of radiation protection, and is as such incorporated into the Norwegian legislation mentioned above. Although we recognise that the responsability of judging the justification to a large extent may fall on agencies outside the radiation protection cornmunity, it is still a principle that should be regarded on all levels. In the new Norwegian regulations put into force this year, it is stressed that every undertaking planning to use a radiation source, should consider altemative methods. We thus feel that this principle is useful down to the smallest scale, and should be returned to its proper positon as one of the cornerstones in 1he basic ICRP recornmendatlons.

- The exclusion principle is applied in the draft document, and reference is made to the exemption cnteria used by other mtematlonal orgarnzatlons like IAEA and EU .The concepts of exclusion, exemption and clearance (which is not mentioned in the document) are easily confused. ICRP should either give a clear definition of these terms, or better even contribute to .a simplification by reducing the number of concepts.

- In the draft document it is recommended not to use the concept of collective dose on its own in making decions, but rather the disaggregated data in the form of a dose matrix. The matrix will always contain more information than the corresponding integrated concept collective dose, and as such it may be a useful tool. Likewise we agree that for some purposes it may not be
meaningful to extend the integration over very large periods of time, or over very minute individual doses. However, from a societal point of view the total aggregated quantity may often represent the best measure for the total collective health or risk impact accociated with a particular practice. We thus feel that the draft document goes too far in discrediting the collective dose concept, which has for decades been successfully applied in optimisation processes.