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Submitted by Mrs S A Liddle, The Society for Radiological Protection
   Commenting on behalf of the organisation
Document Radiological Protection against Radon Exposure
 

To: ICRP



7th June 2012





Dear Sirs





Ref: Draft ICRP report "Radiological Protection against Radon Exposure"





We welcome the guidance on radiological protection against radon exposure. However we do have some concerns regarding the proposals:





  • We believe that the document publication is a little premature as we cannot comment on the suitability of the reference level 300Bq.m-3 until the new radon dose coefficients are published and we understand how this equates to dose.




  • The document is proposing the use of different doses per unit intake for workers and the public, we would prefer a simpler method of only using a single value.




  • The recommendations appear to conflict with other publications such as the Basic Safety Standards (IAEA and EU). ICRP is advocating a reference dose level of 10mSv, but until the dose per unit intake is known we do not know how this equates to an indoor radon level for a typical period of occupancy.




  • The IAEA approach to radon suggests a framework of dose limit, suggested concentrations and understanding the parent daughter ratio. The IAEA approach is preferred.



  • Regards,





    Yours faithfully











    Sheila Liddle



    Secretary for SRP Legislation and Standards Topic group