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Submitted by Lodewijk Van Bladel, Federal Agency for Nuclear Control
   Commenting as an individual
Document Ethical Foundations of the System of Radiological Protection

The current system of radiological protection is in essence still very antropocentric and is concerned alomost exclusively with human protection.

Publication 91 discussed a framework for assessing the impact of ionising radiation on non-human species but restricted this framework to environmental concerns, dealing with "anonymous" reference animals and plants, expresssing environmental conservation concerns, maintenance of biodiversity, meeting of environmental quality objectives and ecosystem health.
This leaves us with an important conceptual gap when considering the need for radiation protection of individual animals, such as companion animals or animals used in sports. In modern day veterinary applications of ionising radiation such animals may get exposed to high doses of ionising radiation, leading not only to non-negligeable stochastic effects but even to tissue effects.

Every human medicine application of today tends to show up in veterinary practice tomorrow, and many techniques are first tested on animals before appearing on the human medicine scene. What tends to make things more problematic is that the responsible persons (most often VD''s) have a lacking or insufficient education and training in anything that is beyond plain x-ray applications and that the equipment used is often second hand and sometimes really obsolete.

Although animal radiation protection needs may be partially covered by correctly applying the protection principles for the human persons more or less involved in these procedures (VD''s and their assistants, owners, handlers), one can easily imagine scenarii in which the indiviual animals get exposed to very high doses without commensurate human exposure, e.g. in CT scanning or teletherapy. This very idea of possible harm to individual animals that cannot be excluced by correctly applying the (human-oriented) radiation protection principles was explicitly admitted in earlier publications such as ICRP 26 and 60.

At present, animals exposed to ionisng radiation are not treated by the radiation protection system any differently  than lifeless objects. They are "things" and in many radiation protection authorities veterinary applications are dealt with as part of "industrial applications".
This approach, or lack of appropriate approach, has become completely alienated from general ethical principles and societal concerns with regard to animal welfare.

I would therefore invite the ICRP to devote due attention to developing the ethical basis for the radiation protection of (individual) animals, without which the ethical foundations are quite incomplete as they do not reflect the globaly accepted ethical considerations that underpin animal welfare concerns.

I thank the ICRP in advance for the attention devoted to this remark and suggestion.

Sincerely yours,

Lodewijk Van Bladel