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Submitted by Horst Miska, Civil Protection Commission w. Min. of Int, Berlin
   Commenting as an individual
Document Emergencies
Comments on ICRP „Emergencies 2008“
Some more editorial remarks relating to the wording or presentation of figures have been communicated to the task group directly; here, only those regarding the content are listed.

1. General remarks: whilst ICRP 103 (2007) are comprehensive and all-embrac¬ing recommendations that “formally replace the Commission’s previous, 1990, Rec¬ommendations; and update, consolidate, and develop the additional guid¬ance on the control of exposure from radiation sources issued since 1990“, the new draft on emergencies 2008 only complements the previous recommenda¬tions relating to emergencies. Already ICRP 63 did not replace the former ICRP 40; thus, those two apparently remain valid in parallel: “These new recommend¬da¬tions are intended to complement, rather than replace, the Commis¬sion’s previous advice”. On the other hand, changes in intervention resp. reference levels are introduced.

This requires authorities responsible for emergencies planning and those for re¬sponse to review all former documents for setting up plans or when responding in an emergency. This is an impractical situation which may cause complex pro¬blems to those responsible.

It would be very helpful and commendable when the task group would create a com¬plete and comprehensive document also for emergencies; but, for readabil¬ity, it should be limited to 100 or 150 pages, tightly structured and avoiding repe¬ti¬tions, except for the summary.

2. Comments in detail:

2.1 Definition of optimisation

In accordance with ICRP 103 (§ 203), the following definition is given in § 31: “The principle of optimisation of protection: the likelihood of incurring expo¬sures, the number of people exposed, and the magnitude of their individual doses should all be kept as low as reasonably achievable, taking into account eco¬nomic and societal factors. This means that the level of protection should be the best under the prevailing circumstances, maximising the margin of benefit over harm.”

Clearly addressed are here only doses (risk for radiation damage) and eco¬nomic and societal factors, an advice to consider possible adverse side effects of protective measures is missing. But there is practically no protective action with¬out unwanted side effects; for instance life-threatening shock after admi¬nistra¬tion of stable iodine or possible accidents when evacuating a large num¬ber of persons. For me, optimisation means primarily balancing each protec¬tive action against its adverse effects which are considered already when check¬ing for justification; but there, no “fine tuning” is made. After this first balancing, economic and societal factors may be taken into account to further optimise.

Only in planned exposure situations, the restriction on doses might be reason¬able when optimising. For emergency and existing exposure situations, the follow¬ing definition of optimisation would better apply:
“The principle of optimisation of protection: the likelihood of incurring any detri¬ment for all people possibly exposed, that is the sum of radiation risk and risks attributed to the protective action, should be kept as low as reasonably achiev¬able, taking into account economic and societal factors. This means that the level of protection should be the best under the prevailing circumstances, maxi¬mising the margin of benefit over harm.”

2.2 Involvement of potential stakeholders

Paragraph 91 states: “It is important to review the proposed overall protective strat¬egy with representatives of all potential stakeholders to ensure the plan is opti¬mised with respect to these factors, . . . “. This is practically impossible in the early phase of a response, but also very difficult in the planning phase (see § 111). Firstly, most stakeholders are not interested in emergency preparedness as long as there has been no event. Moreover, different stakeholders will have opposing interests, for instance, consumers will ask for a “0 Bq diet” (as was the case after Chernobyl) while farmers would like to market their products also with higher contamination.

Finally, “societal factors” are not measurable like dose rate or wind direction and are hard to quantify objectively. Therefore, optimisation with respect to these fac¬tors is very complex, especially since e.g. public perception of radiation risks may vary drastically, depending on any recent event (or its absence) involving radia¬tion.

The objectives of the requirement to involve stakeholders and to respect public per¬ception are understandable, but their implementation should not be compul¬sory in the early phase on an accident.

2.3 Decisions in late phase or “existing exposure situation”

The problems may increase in the late phase since then, with full public engage¬ment and all “experts” being on the air, scientifically based decisions will be¬come rare. Instead, political appraisal will dominate actions such that decisions may depend more on the party in power than on scientific arguments. Therefore, ICRP should stress more scientific criteria; the other ones will play a role auto¬mati¬cally when an accident happens!

Horst Miska, Klein-Winternheim
Civil Protection Commission with the Minister of the Interior Germany, Berlin
Ex EU COM, DG ENV, Brussels
Ex Ministry of the Interior Rhineland-Palatinate, Mainz