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Submitted by Tadeusz Musia³owicz, Central Laboratory for Radiological Protection
   Commenting as an individual
Document 2005 ICRP Recommendation
Tadeusz Musialowicz
Central Laboratory for Radiological Protection
Warsaw, Poland

Comments on the ICRP 2005 draft recommendations

Page 2 table S1 and page 43 table 7.

1. Optimized emergency levels in international regulations (IAEA safety Series No 116, Vienna 1996) refer to the average over suitably chosen samples of the population, not to the most exposed individuals. For temporary evacuation this level equals 50 mSv in a week. Proposed by the ICRP maximum constraint 100 mSV in a year for public evacuation, applies to the most exposed person. Similar problem exists with maximum constraint for countermeasures such as sheltering and iodine prophylaxis in emergency situations.
Different approach to this important problem in the IAEA regulations and ICRP recommendations does not facilitate a preparation of national regulations. Please try to harmonize your recommendations with international standards.

2. Dose limit 20 mSV in a year is accepted for continuously exposed workers as the average annual dose leading for possible life-dose 1 Sv. In the case of occasionally exposed helpers, situation is completely different. Maximum dose constraint 20 mSv in a year proposed for helpers to support and comfort patients, seems to me to low. Dose constraint for helpers should be at least 50 mSv, or if ICRP does not wish to multiply recommended maximum constraint values, - 100 mSv in a year (like for workers in not very serious emergency, situations) can be accepted.

Page 45 para.175

3. Last sentence should be change as follows:
“The working conditions of a pregnant worker, after declaration of pregnancy, should be such as to make it unlikely that the radiation weighted dose to the fetus will exceed about 1 mSv during the pregnancy. For a period before the declaration, exposure assessment should be performed".
Justification: If a level of protection for any conceptus shall be comparable to that
provided for members of general public, the exposure of the fetus
before a declaration of pregnancy should be, as for as possible, also
taken into account.

Page 52 para205.

4. line 13 “inter-Agency” with “international”

5. line 14 “FAO et al” with “IAEA”

Justification: These standards are world-wide known as the IAEA international basic
safety standards.

Page 54 para.213 line7

6. Typing error, replace “chapter 6.4” with “chapter 6.2”.