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Submitted by KOJI TAKASAKI, JAPAN ATOMIC ENERGY AGENCY
   Commenting as an individual
Document Interpretation of biossay data
 
I think that this Guidance is well compiled and is a good reference. But I comment the following, although I may have a misunderstanding of contents.

1. Chapter 2.1 (page 7)
Although the investigation level is described, the investigation level is not mentioned in the new Recommendation. Only investigation level should not be described in this Guidance. Constraints and Reference levels corresponding to the new Recommendation, including the investigation level and recording level, should be compiled separately in other document.

2. About Level 1
This Guidance says gRoutine individual monitoring for intakes of radioactive material should be used for workers where there is a reasonable probability that committed doses from intakes of radionuclides in a year will exceed 1 mSv.h (Chapter 2.4 page 9) On the other hand, dose assessments of routine monitoring in 0.1-1mSv are also described. (Chapter 8.2.3 and Fig. 8.1) These are inconsistent. It is difficult to understand what is meant.
If routine monitoring in 0.1-1mSv means only dose assessments by workplace monitoring, that should be described more clearly.

3. Chapter 7.2 (pages52)
In the case of intakes of radioactive material, individual dose assessment should be required as realistically as possible. It should be explained that the view that good fit is sufficient for level 2 unlike level 3. And the reason of 6mSv should be shown.

4. Chapter 7.2 (page 52)
I recognized that recording level is 0.1 mSv substantially in this Guidance. Probably, management of individual dose must be changed significantly for recording level of 0.1 mSv, since the recording level of 1 mSv-2 mSv is used in Japan.
The necessity and the merit of recording level of 0.1 mSv should be explained and be discussed more.

5. Other Comments
1) There are no figures of Fig. 5.1 and Fig. 5.2 in TABLE AND FIGURES.
2) Workplace Monitoring is more adequate for the title of Chapter 4.4 than Environmental Monitoring.