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Submitted by Tuvia Kravchik, NRCN
   Commenting as an individual
Document Radiological Protection from Cosmic Radiation in Aviation
 
1.  Pages 11-12, lines 363-367: the definition of ERR is unclear and perhaps incorrect. It should be: "...the difference between the proportion of subjects in a population with a particular disease who were exposed to a specified risk factor and the proportion of subjects with that same disease who were not exposed, divided by the proportion of subjects with that same disease who were not exposed". Another versionof the ERR definition is taken from BEIR VII Phase II (2006) document: "ERR is the rate of disease in an exposed population divided by the rate of disease in an unexposed population, minus 1.0".

2.  Page 22, lines 675-676: Reduced cancer mortality is caused mainly by an increased early cancer detection. This is influenced by socioeconomic level which improves access to healthcare and also by an increased disease screening initiated and promoted by the workplace management".

3,  The ICRP recommends to treat the dose of frequent flyers, in which most of their flights were for professional duties, as public exposure and does not recommend to record these doses. On the other hand, the ICRP recommends that aircraft crew doses be considered occupational and be recorded. The different approach is not clear. In a case of a claim by a worker who flyed frequently under his professional duties and suffered from a cancer disease, it would be very difiicult to explain in court why his exposure, which was caused at the request of his management and as part of his occupational duties, was not recorded and not considered as part of his occupational exposure that should be taken into consideration when trying to establish causation.