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Submitted by Larry Siegel, None
   Commenting as an individual
Document Recommendations
 
1) Delete all discussion and recommendations for EXEMPTIONS and Exemption levels (delete section 2.4 and any tables supporting exemptions)

2) Encourage ICRP to adopt and incorporate the PRECAUTIONARY PRINCIPLE in the overall framework.

ICRP simply does not have public representation thus has no authority to assess what additional, unnecessary radiation risks members of the public around the world in this and future generations consider trivial or acceptable.

ICRP claims it does not have enough certainty about the effects of low dose radiation on large populations (termed “collective dose” estimates) to estimate the number of cancers that will result in that population now or in the distant future, yet ICRP thinks it has enough scientific and socio-political information to actually release radiation to large populations – with no limit on the number of worldwide releases or “exemptions”— with no limit on the number of exemptions per facility or to a community—without their consent or knowledge. ICRP makes a self-determination that the risks are trivial and acceptable by the public (at the same time it discourages estimating what those risks are). ICRP does not know how much total radiation will be released or received when it, across-the-board, recommends not only that countries adopt release levels but also specifies a suggested level or range. There is absolutely not scientific justification for this recommendation – it is purely economic for the sake of the industry. The whole concept of exemptions should be deleted from the ICRP 2006 Recommendations.

Furthermore, the ICRP should remove the lower bound (essentially an exemption level) from the radiation levels throughout its text and in its charts on “constraints,” doses, and bands of regulatory control (including Section 5.8.2 para (204) and Table 4, p. 61). Industries should be responsible for and protect the public from all doses not just those above an ICRP-selected level.

ICRP suggests governments decide what they want to regulate and what they don’t, then establish “what could be exempted from some regulatory requirements because regulatory action is unwarranted...the legislative framework should provide the regulator with the authority to exempt situations from regulatory requirements, particularly from those of an administrative nature such as notification and authorization…Exemption…relates to the power of regulators to release from specific regulatory obligations…waiving…legal obligation. ” [page 17, paragraph (42) of Section 2.4] I suggest ICRP completely get rid of this strongly objectionable and unacceptable recommendation and all of Section 2.4.

ICRP should immediately cease this recommended abrogation of regulatory responsibility by removing all of Section 2.4 from the 2006 recommendations and all subsequent documents.

ICRP should restructure its framework to incorporate or replace its basic principles with the Precautionary Principle.