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Submitted by Peter O'Connell, USDOE Office of Health
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
 
Major coments
Tables S1 and 7
The recommendation for public evacuation and relocation, is substantially different from guidance currently provided by the United States (EPA Guidance). Current guidance calls for evacuation at 10 mSv TEDE up to 50 mSv or sheltering when it provides protection equal to or greater than evacuation, based of consideration of factors such as source term characteristics and temporal or other site-specific conditions. The United States recommends relocation if doses in the first year will be equal to greater than 20 mSv TEDE; doses in any single year after the first will not exceed 5 mSv TEDE; and the cumulative dose over 50 years (including the first and second years) will not exceed 50 mSv TEDE. In some instances, the United States objectives are conservative by a factor of twenty or more than the Report's maximum constraint. The Report should consider lower recommended doses for public evacuation and relocation.

Paragraphs S18, S19, 244
The need for the development of a new framework for non-human species needs to be justified. The new framework will result in significant expenditure of radiological protection resources, in many cases to the detriment of existing programs. While there may be lacking a strong scientific basis for the assumption the protection of man is adequate for protection of the environment, there is an equal lack of scientific basis that use of suggested reference biota will provide protection for other biota.

Paragraph 22
The introduction of terms “natural or artificial” provides no benefit. They add confusion and their use is not needed in the document.

Paragraph 48
Last sentence should be rewritten to state “All stochastic based protection quantities rely on these hypotheses.” As written, the statement is not accurate for deterministic effects.

Paragraph 66
Second and third sentences should be rewritten to delete “and can be easily shielded. Hence, its contribution to the effective dose is mostly small.” As written, the statement is not accurate for facilities where the radiation source consists of low-energy photon radiation; (e.g., x-ray facilities). For these facilities the only contribution to effective dose is from low-energy photons.

Paragraph 146
Delete/replace second sentence with “Exposures to family members providing comfort for medical patients requires special consideration.” As worded, it implies that exposure of medical staff and near-by members of the public are in the same class of exposures as medical exposures.

Paragraph175
The third sentence needs clarification. As written, the statement that any women who “may” be pregnant should have a level of protection comparable to members of the public could apply to any women of child bearing age. This recommendation should be limited to any women who declare pregnancy.

Editorial Comments

Paragraph 22
Reference the footnote (1) in this paragraph. This is first use of terms “natural or artificial.”

Paragraph 40
The reference at end of the paragraph should be to Section 3.4.1 not Section 3.6.

Paragraph 54
Suggest adding the following sentence to the end of the paragraph “The radiation weighted dose still should be recorded and properly documented to ensure that this more basic quantity is available for use in epidemiological studies and individual risk assessments.”

Paragraph 73
Fourth sentence should correct “ths” to read “this”.

Table 2
In the second column, last row, suggest revising second sentence to read “See Figure 1, Line (c) and equations (8).” This would clarify that the recommendation applies to the function represented by line (c).

Paragraph 98
In first sentence replace word “they” with “may”.

Paragraph 105
In second sentence replace word “judgements” with “judgement.”

Paragraph 132
The reference at the end of the paragraph should only be to Chapter 7 not paragraph 128.

Figure 2
The notation on top right picture should indicate “Medical” not “Radiological.”

Paragraph 213
The reference in the fifth sentence should be to Chapter 6.2 not Chapter 6.4.

Paragraph 223
In the first sentence “Reference Levels” should not be capitalized. The last sentence should begin with “The diagnostic reference level” not “The derived reference level.”

Paragraph 234
The last sentence should be clarified to read “…from normal authorized discharges of 0.1 mSv or less and an ICRP cancer death risk for members of the public of 0.05 Sv-1, and again….”

Paragraph A7
Spell out the terms “excess relative risk” and “excess absolute risk” in this paragraph the first time they are used.

Paragraphs A26 and A 27
The equations have what appears to be double multiplication symbols.