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ICRP: Free the Annals!

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Submitted by Shinichiro Miyazaki, Kansai Electric Power
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
E@The process to make the ICRP recommendations started to be open to the public, which let the discussion activated. This will most likely contribute to build the radiological protection system in the future and to standardize the understanding of the persons concerned.

EThe new definition of gDose Constraintsh is the most concerned issue for us.
The concept of constraints has had always a big significance in its 40 years history since Publication 9, although the word gdose constrainsh appeared in Publication 60 for the first time. In the ICRP documents gconstraintsh has been defined as one of the procedures of optimization, and the concept of gconstraintsh is often introduced in the radiological protection systems authorized by the regulators.

Therefore, the new draft of the recommendations that defines the gdose constraintsh as the most fundamental level of protection and also its numerical values may lead some disorders. It is necessary to explain clearly why the concept of the constraints should be changed. The indicated reasons for that seems to be not persuasive enough: the simplification of the radiological protection system and consolidation of the public protection on the assumption that some sources are overlapped.

If the gconstraintsh should yet be redefined as the most important concept, as in the new draft, in spite of the demerits, there must be no contradiction between dose constraints and dose limits.@In this context, the maximum dose constraint for workers should be 50mSv/y and for public should be 5mSv/y, based on the description of Publication 60. In addition, as numerical values of constraints mean the total value of one year, when hours are limited, it should be changed depending on hours. This should be written in the new recommendations clearly.