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Submitted by Christiane Poelzl-Viol, German Federal Office for Radiation Protection
   Commenting on behalf of the organisation
Document Ethical Foundations of the System of Radiological Protection
 
The draft report “Ethical foundations of the system of radiological protection” describes the ethical principles forming the basis of the numerous recommendations published by the ICRP throughout the previous ICRP publications. For this reason, the publication is a comprehensive review on how the ICRP has used ethical values in developing the system of radiological protection – not always explicitly, but nearly from the beginning implicitly and then later on also expressed in single words or phrases. In this context, key components of ethical theories and principles underpinning the ICRP system of radiological protection are presented and discussed in detail.

1. General comments
The draft report is a good and necessary publication presenting and discussing the ethical foundations of the IRCP logic as a basis for plenty of recommendations over the last decades. It is highly welcome that the ICRP tries to reflect upon the ethical basis of the system of radiological protection, which has been developed in that scientific expert community and which is the basis of national regulations and legislation in many countries.

Valuable are the insights in the development of the system of radiological protection. It provides an idea of the battles fought with representatives of different branches. It shows how knowledge and new insights increase awareness of complexity and thus increase complexity of protection approaches and related terms. Moreover, it also shows that those ethical values inherent in the concept production process have not been subject of discussions for a long time.

One fundamental weakness of this publication is the retrospective view. Of course, ethical aspects were part of ICRP member’s discussions and recommendations, quite simply because thinking of human beings always is based on ethical and moral principles, as they are part of society. However, ICRP is a high-level expert group “(…) to prevent cancer and other diseases and effects associated with exposure to ionising radiation, and to protect the environment”, with members representing “…the leading scientists and policy makers in the field of radiological protection”. Looking in retrospective at all the work and interpreting something into it, which was neither explicitly aim nor part of the concept process, is not consistent with the self-conception of ICRP. Accordingly, at several places in the document it would be refreshing to read as kind of a self-reflection that there are aspects, developments and terms with actually a lot of ethics inside, but that the commission had not the attention at that time to discuss it more in depth.

Facing today’s societal debates and the call for considering societal needs and perceptions in the radiation protection system, it is an important step to identify those aspects, were ethical considerations have to be included. From our point of view, however, it should be better pointed out and discussed in more detail throughout the publication, that the scope and objective of this report gives the ICRP perspective. Although the review is very important, it can only be the starting point of a much wider discussion, including the rest of the society and politics culminating in “ethical foundations of the system of radiological protection” in the end. This still seems to be a long way, which should be emphasized in more detail.

One important step on that way, which is underrepresented in the document from our perspective, is the importance of communication between the ICRP and the society and politics in order to develop true and general ethical foundations. Of course, this topic is touched in the chapters “4.2. Transparency” and “4.3 Inclusiveness”. However, the focus here is different. Communication between experts and the society and politics for a broad discussion, information and formation of consent should be more than only openness about decisions and activities or accessibility of information. It seems to be a more complicated process of informing and involving the society and politics to discuss and develop general ethical foundations, especially dealing with the consideration of the direct impacts to human health and the environment as well as consideration of economic and social costs and benefits.

In that context, it would be interesting to hear more details about perspectives or about a future action plan of the ICRP solving this difficult task. Accordingly, an outlook is missing how ICRP will deal with ethical aspects in future. Will there be ethic experts always be present to bring in the ethical milestones of the discussed radiation protection topic? Will there be a session “ethical aspects related to the discussed topic”? Will there be another retrospective view in a few decades? Or will there be hints, which of the discussed aspects could have ethical relevance? Will there be further working groups to specify all the general statements made?

2. Specific remarks

Main points (line 210 ff)
Some of the “Main points” do not have an explicit message. For example, 223- 225 on stakeholder involvement (“involve all relevant stakeholders”), 230-232 on protection of the environment (“negligible impact”).


1.    Introduction

1.1.        Background
Line 398:
“the discussion of ethical considerations is not absent from ICRP publications”: the implicit presence of ethical aspects should not be equated with that expression.

1.2.        Scope and objective
Line 450-454
(8) “(…) broadly facilitates the decision making process and communication on radiation risk.” Very general phrase.

2.    Evolution of the present system

2.1. The early days: do no harm
Line 510-513:
just as an example, each of the terms “justified”, “reasonably” and “tolerable” contain (or better: should contain”?) a whole system of complexity, ethical considerations and societal values. This is not discussed sufficiently in that document.

Line 553
“(…) but the basic ethical principle remained the same” à which ethical principle? Doing no harm as cited a few lines above?

2.2. A more complex problem: managing risk, a matter of balance
Line 562
(21) “a growing concern” à whose concern?

2.4. Considering the diversity of exposure situations
Line 649 f
“(…) and it is difficult to manage these situations without directly involving the affected people.” Is meant that “because affected people cannot be involved directly”?

4.3. Inclusiveness
Line 1079 ff
“(…) turn to the much larger group of citizens generally… they can be of great value in developing our total radiation protection philosophy”. A great appeal to involve society more than 35 years ago, but without real consequences on ICRP’s approach, only with the consequence that it led to one sentence in ICRP 2007a.

Line 1111
Critic: Empowerment here used in the sense of a top down approach.