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Submitted by Masahiro Doi, National Institute of Radiological Sciences
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
 
[1] Regarding the Table S1 (Table 7) :

1-1) I think the Table S1 (as well as Table 7) will be a highlight of new ICRP recommendation, and may be quoted separately from the relevant paragraphs. Therefore, Table S1 should be simple for the stand-alone use to avoid confusion and misunderstanding.

1-2) To simplify the Table S1, situations for workers and those for public should clearly be distinguished. It may be helpful to rearrange the contents of Table S1 into Three rows, such as "Maximum dose constraint", "Situation to which it applies", and "Remarks".

1-3) By following the current Table S1,
-----------------------------------------------------------
Maximum dose constraint ; 100 mSv per year

Applied to the following situations: as
[emergency for workers]
[Evacuation and relocation for public] and
[High levels of controllable existing exposures]

with remarks that
[There is neither individual nor societal benefit from levels of individual exposure above this constraint. Saving life or preventing serious injury or preventing catastrophic circumstances are excluded from the emergency situations.].
-----------------------------------------------------------
Maximum dose constraint of 20 mSv per year :

Applied to the following situations as :
[normal for workers]
[Countermeasures such as sheltering, iodine prophylaxis in accidents for public]
[Controllable existing exposures such as radon for public] and [Comforters and carers to patients undergoing therapy with radionuclides]

with remarks that
[There is direct and indirect benefit for the exposed individual. Workers receive information and training, monitoring or assessment].
-----------------------------------------------------------
Maximum dose constraint : 1 mSv per year

Applied to the situation as:
[normal for public]

with remarks that
[There is societal benefit, but not direct benefit for the exposed individual. Public receives no information, no training, and no individual assessment.].
-----------------------------------------------------------

1-4) Fact basis for the numerical value of Ò100 mSv per yearÓ should be clarified.

1-5) 0.01 mSv per year is the "minimum value of any constraint", which should be distinguished from other values of "Maximum dose constraint".

[2] Regarding the Protection of the environment:

2-1) I believe that the radiation protection of the environment is a challenge, which is currently essential to sustain public trusts in the whole system of radiation protection.

2-2) I think the new policy statement for future radiation protection of the environment should be written in a new single paragraph to replace the policy statements in 1977 recommendation (paragraph 14, Publ.26) and in 1990 recommendation (paragraph 16, Publ. 60). It must be clarified that these existent ICRP policy statements have been proved implicitly, which should, for the future, be demonstrated explicitly.