|NEI Comments – Part 2 of 2
The ICRP has proposed concepts and criteria for excluding certain types and levels of sources from the scope of applicability of its recommendations. In general, the underlying rationale appears to encompass: (1) practical difficulties in controlling some sources, (2) consistency with some of the current applications of the exclusion concept, and (3) avoidance of excessively expending resources with little expectation of improving the level of protection.
We support the notion that the recommendations should include a well-defined basis and approach for determining which sources should universally require consideration of actions to justify, control and optimize exposures. We believe that such a basis and approach should be commonly agreed and consistently applied between nations to facilitate trade and commerce and to help define international agreements on mutual radiological protection obligations for trans-boundary situations that involve actual or potential exposure. We also believe that the recommendations should state the obvious –that parties (e.g., nations and localities) always retain the option to require and take actions to further control and optimize exposure for sources within their jurisdictions that may be excluded on a more global basis. In this light, we view the ultimate objective as being to develop a coherent framework for inclusion of sources, not exclusion of sources.
The issue of exclusion (or inclusion) is complex and controversial. Therefore, we welcome the ICRP’s initiative in this regard as a means of opening a global discussion and debate on this issue in the context of radiological protection. As with the concept of justification, radiological protection is “only one input,” but it is an important input and we believe that the ICRP can legitimately expect to arrive at a conclusion within that defined context. To help facilitate this, we encourage the ICRP to provide much more information on the historical experience and benchmark concepts described in the draft recommendations, as well as additional details on the ICRP’s rationale –possibly in the form of an additional “foundation document.”
The ICRP has invested much time and effort to gain a broad range of input and advice in the development of a full set of draft radiological protection recommendations. As the product of an iterative process, the concepts and criteria in the draft recommendations reflect varying levels of “maturity” and leave much to be achieved in terms of internal coherence and consistency. We encourage the ICRP to take as much additional time and effort as needed to arrive at a next generation of radiological protection recommendations that will stand the test of time as well as the current set.