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Submitted by Manfred Tschurlovits, ÖVS Austrian Radiation Protection Association
   Commenting on behalf of the organisation
Document Health risks attributable to radiation

1.1 General comments

Being neither an expert in biology nor in epidemiology, but a simple user of ICRP documents, I have to be in a position of quiet admiration of the material collected and compiled.
Nevertheless, some comments appearing in reading and at attempting to understand this document are presented.

A glossary seems highly desirable, as some new terms are created (as 1863; quality of life factor, or redefined 1569, genetic effects 1693, etc, etc)

1.2 Details
Line 188: The wording ¡§scientifically plausible¡¨ is an impressive new creation in weakness, but will perhaps not accepted generally. The addition of a phrase as ¡§in the region beyond natural cancer incidence and natural background) seems better acceptable

192 ¡§uncertain possibility¡¨ is some tautology

196: I guess that the increase is not uncertain, as the DDREF is not physical continuous function but rather the number chosen is uncertain

212 a change from 6.0 to 5.9 is not worldshaking as the uncertainty (cautiously not given here) is much larger. The small difference does not justify changes.

278: ¡§¡K prospectively estimating risk¡K¡¨. As some misuse was done in the past (as ¡KXX number of death by¡K exposure) some more careful rewording might be appropriate.
A procedure how to demonstrate compliance with dose limits taking into account different uncertainties of estimates and limits seems appropriate to be developed ( see ) possibly a new task

862: The term ¡§Tissue reactions¡¨ seems appropriate

1000: delete average as ¡§population¡¨ represents already an average

1021: a little more general: as it is still difficult to communicate in term of different radiation effects, the wording should be more precise (see below) and similar terms should be used exclusively to one effect and not for the other.
In particular, ¡§probability of death¡¨ and ¡§percentage of survivors¡¨ express similar issues, but refer to an individual and to a collective. Therefore, the term ¡§probability¡¨ should be used only for stochastic effects. See 1134 incidence

1098: also a little more general: in order to avoid: it should be clarified, that only the following terms apply
effect Dose quantity Radiation weighting by
Stochastic effect Effective dose Sv wT
Tissue reaction Absorbed dose G y RBE

1215: deterministic effects: are already out of use??
1246: As heading includes ¡§estimates¡¨ , the symbol „l is overdone.

1258 ¡Kbetween absorbed dose¡K..

1556: As this is a conceptual change, the first few lines have to be incorporated into 182 ff Conclusions

1926 the uncertainty of 0,081 lower that that of 0,05 to justify three significant numbers?

1992 ff Tables 4.1 ff

The different uncertainty expressed in these tables should be brought in line
The numbers are given as 1000, 101,3, 12,2 or 5 as different significant numbers.

4.1 and 4.2, skin: In scientific nomenclature, 1000 implies not 999 and not 1001. As the uncertainty is substantially higher, 103 is more appropriate

2089 Table 4.4 For a ¡§nominal¡¨ coefficient, 5,9 and 6,0 can not claim to be actually a change

2297 again 43,69 pretend an impressive accuracy, 44 better

A5 and table A 6.Is a scientific reason to refer to 10000 persons in A5 and 100000 in A6? In both cases, scientific nomenclature of using 10X was created for purposes like this.

2500 ¡§amount¡¨ of radiation is obsolete, should read dose, probably absorbed dose

2757 65.00 should read 65, reasons shown above

2805: subject of a definition in a glossary

3141 „l 750 to 1500 or „l(750 to 1500) ; „l can be deleted , see also 1992 ff
3151 does ¡§radiation exposure¡¨ include natural background. ¡§no further radiation¡¨ ???

Coherence with other drafts
Some issues addressed here are appearing in other ICRP documents in consultation as ¡§basic quantities¡¨ , but not mentioned. e.g collective dose etc