|I am providing the followig comments based on my experience as the NEA Secretariat to the Committee on Radiation Protection and Public Health.
I feel that this document should not be published as it is, and would need substantial revision before it could be published.
I say this primarily because the document is significantly out of phase with the ICRP draft general recommendations provided in RP06. In particualr, the text of the draft recommendation on scope is written from the perspective of "Practices and Interventions", which is not the approach that is taken in RP06. Because the ICRP general recommendations, that will be based on the RP06 draft, represent the Commissions most fundamental recommendations, I feel that other recommendations must be clearly in line with these. As such, the document on scope as it is currently written, with its use of terminology and philosophy from publicatoin 60 that has been significantly changed in RP06, is not correctly in phase with the Commission's emerging philosophy. I would recommend that the document on scope should be rewritten with RP06 in mind, and re-submitted for public comment after RP06 has been finalised and approved, such that all relevant philosophical aspects in RP06 can be incorporated into a new document on scope.
To give a specific example of this, paragraphs 15 - 20 of Section 2.3 are written from the perspective of practices and interventions. It is only in paragraph 21 that the "new" approach is mentioned (and even here, the text refers to "prospective" situations not "planned" situations). Further, the RP06 description of exclusion and exemption (paragraph 42 of RP06 for example) is much better and should be used as the basis for discussion in the scope document. (One caviat to this endorsement of RP06 paragraph 42, however, is the overly perscriptive insistance that exemption is ONLY of a person or legal entity. In common usage it is often said that sources, for example smoke detectors, are exempted, and I see no value in being overly precise with the application of what should be a common and easily understood word - at least in English!).
I would also like to note that throughout this document, the 1996 BSS and other IAEA documents are referenced as providing definitions of the exclusion and exemption principles and criteria. These documents are based on earlier Commission approaches, which will be superceded by new Commission recommendations. As such, at the very least it is not clear that these references should be used as a basis for new recommendations in this area. It should further be noted that the 1996 BSS itself will enter a revision phase itself in the near future, most likely in October 2006, such that its use as a basis for new Commission recommendations is at best questionable.
I also think that the draft is very complicated and overly long.
The various discussions of vocabulary seem unnecessary. The paragraphs on latin roots do not improve the documents argumentation. The footnotes that provide overly perscriptive definitions of common words (e.g. control, regulation, dichotomous, scope, legislator, regulator, etc.) do not assist the Commission in its goal to "simplify" its recommendations. The discussion of dichotomous control could be significantly shortened.
Paragraph (k) of the executive summary provides a description of "automatic exemption criteria" for "material in a practice", "while in transport", or "irrespective of their ammount in a practice or for unrestricted release from a practice", each referring to different tables in different documents. While this complicated summary of existing international approaches is comprehensive, it more illustrates national regulatory authority desire for felxibility than the coherent approach to material management that seems to be the overall recommended in this draft.
Paragraph 61 refers to the discharge of effluents, however expressly states that this is not the concept of clearance, but rather that of authorised discharge. The CRPPH has stated that there is no regulatory rational for such distinctions, arguing that the focus of authorisation of release of radioactive materials from regulatory control should be on optimisation (as is suggested in RP06). This thus fits perfectly well with the concept of exemption. In fact, the term clearance itself is a sub-category of exemption, and distinguishing clearance from exemption is seen as overly complicating the situation.
Finally, I would suggest that the recommendations expressed in this draft are overly perscriptive and preemptive of national authority. While it is clear that some international agreement is needed for the regulation of the movement of radioactive materials, many of the situations addressed in the scope document are strictly of national concern (e,g, sites and facilities do not move; not all commodities, concrete rubble for example, are shipped long distances or across borders). As such, the advice that would be of most use to radiological protection authorities and practitioners concerns the types of criteria that could be considered when deciding what, if any, regulatory controls should be imposed. The Commission's caution along these lines, in the context of exemption levels, is expressed appropriatley in the last half of paragraph 74. The scope draft also states in paragraph 21, "The distinctiveness of these ratiation exposure situations logically influences the concept of scope and its quantitative definition." Clearly, national regulatory authorities often need to make judgements taking into account the specific circumstances at hand. As such, I would prefer that any future recommendation on Scope focus on elaboration of approaches and criteria rather than on specific, unnecessarily universal numerical values.
As a last comment, I should note that the upcoming NEA/ICRP stakeholder dialogue conferences, organisted in collaboration with the ICRP (Tokyo in July, Washington DC in August, Prague in October), as well as the September meeting of our Expert Group on the Implications of ICRP Recommendations, will be discussing the concepts of exclusion and exemption. I would hope that the input from these important meetings would be considered when finalising the Commission's recommendations on scope.