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Submitted by Rick Tinker, Australian Radiation Protection and Nuclear Safety Agency
   Commenting on behalf of the organisation
Document Radiological Protection from Cosmic Radiation in Aviation

The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) welcomes the opportunity to comment on the ICRP draft report for consultation, “Radiological Protection from Cosmic Radiation in Aviation“.

Overall the report is aligned with the philosophy of Publication 103 which is to recommend a consistent approach for all type of exposure situations, with the central consideration being optimisation. The Report will strengthen current national practices in optimising cosmic exposure in aviation and builds on international harmonisation between radiation protection and airline regulators.

A European perspective is presented in the Report with a majority of peer reviewed research originating from European countries. Consideration should be given to exploring research undertaken in other regions such as Asia. 

Examples of different types of exposure groups of aircraft crew could be provided. For example aircraft crew can also include medical staff (flying doctors in Australia), sky marshals, crew on chartered flights, etc.

Specific Comments

Line 382: The opening two sentences are not consistent with the expression style used throughout the report.

Line 479: Consider replacing the word “monitored” with “estimated”, which better reflects the use of code.

Line 871: A lead in sentence for the dot points is required.

Line 892: The grammar of this paragraph should be reviewed to improve readability.

Line 900: Consider replacing adapt with adjust.

Line 901: Consider replacing “combining” with “consideration of”.

Line 910: The sentence starting with “Because” is a repeat of the sentence in paragraph 56.

Line 929: Members of the public may find these calculators too detailed and complex. There are also Apps that can estimate passenger exposures. Providing detailed examples will become dated with time. Suggest removing examples. The approach taken in line 944 is a preferred approach to addressing this matter.

Line 974: The main purpose for maintaining dose records over time is to ensure workers have access to their exposure history. The sentence beginning with “To facilitate” should also reflect this requirement.

Line 975: Better guidance on “sufficient time” should be provided. The IAEA International Basic Safety Standards, General Safety Requirements Part 3 states that: “Records of occupational exposure for each worker shall be maintained during and after the worker’s working life, at least until the former worker attains or would have attained the age of 75 years, and for not less than 30 years after cessation of the work in which the worker was subject to occupational exposure.”

Line 1001: Clarification of this sentence is required. This refers to 1 mSv member of public limit that is used for workers in a planned exposure situation not a reference level 1 to 20 mSv that is to be used for existing. It implies, but does not state, that the Reference Level for the embryo/fetus of 1 mSv is consistent with the 1 mSv dose limit.

Line 1031: A reference is required for the "right to know principle".

Line 1088: The conclusion and/or paragraph 82 needs to address protection of embryo and fetus.

Line 1092: The phrase “margins for manoeuvre” should be rephrased. Suggest “options available”.