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Submitted by Wells Eddleman, NC CItizens Research Group Inc. Science Office
   Commenting on behalf of the organisation
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The claim that "everything is slightly radioactive" hardly supports a conclusion that some level of radioactivity, including nuclear fission products, actinides, etc must be accepted in everything. Such fallacious "reasoning" ill becomes a scientific organization. I knew Dr. Karl Z Morgan former chairman of ICRP and I doubt he would countenance such an idea. See his Bulletain of the Atomic Scientists articles.
Section 2.4 and all support for "exemptions" must be deleted. The radiation does not provide "exemptions" from its effects and it is hubris of the sort King Canute so wisety refuted almost 1000 years ago to pretend otherwise. What this really is , apparently, is a sop to governments and other operations who won't pay to clean up their messed up operations and contaminated areas, equipment, buildings etc
You should also adopt the precautionary principle, that things must be proved safe to be considered safe, instead of being considered "safe" or "safe enough" absent definitive proof they are dangerous. Examples, human carcinogens. Absolute proof requires numerous dead people. This is madness, and requiring such proof for every suspected or potential carcinogen would require the entire world be turned into guinea pigs.. Even Hitler set limits on radiation exposure to the uranium mines of Joachimsthal. Safety first.
Wells Eddleman, Staff Scientist, NC Citizens Research Group Durham, North Carolina USA