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Submitted by BERARD Philippe, CEA DSV Prositon
   Commenting as an individual
Document Occupational Intakes of Radionuclides Part 1


Here are my comments on the draft of Occupational Intakes of radionuclides Part 1.


First a general overview of Part 1, it’s a fundamental publication and well done. This report and the following are expected by the profession and will be very useful for the interpretation of bioassay data. I appreciated the consideration of uncertainties and variability, the independent treatment of progeny, the actualization of biokinetic models, etc.


I have divided my comments into 3 groups

A – Important comments for modifications or changes

B – Technical comments for a need of additional explanations

C -  Editorial comments



A – Important comments for modifications or changes


Page 22 Glossary : Minimum Detectable Amount (MDA)

The concept of the performance criteria of measurements has changed. According to ISO (GUM, ISO 11929, ISO 28218 etc..) and in the rest of text of part 1, 2, 3 and 4 of this document, only detection limits or limits of detection are used and are normative. It’s better to have the definition of detection limit than MDA in the glossary.


Page 39 (52) line 1365

Modify “ the committed effective dose from intakes of radionuclides occurring within the year” by “the committed effective dose from intakes of radionuclides occurring within 12 consecutive months”.


Page 117 line 4174

Need a definition of what is a “positive” measurement

How take into account values under the detection limits?


Page 121 (335)  line 4340

“For urine sampling, another widely used method is to normalise to the amount of creatinine excreted per day; 1.7 g and 1.0 g for males and females respectively.” There are formulae to calculate individual creatinine excretion instead of a theoretical value.



B – Technical comments for a need of additional explanations


Page 96 3.5.4 treatment of radioactive progeny produced in systemic compartments

The assumption of independent kinetics is applied to progeny radionuclides produced in systemic compartments. It’s a good thing but how use this concept in practice. In the text : An alternate “automated’ default treatment of this problem… it will generally not be evident how the progeny ….. need to be developed….


Page 97 (3.6) Medical Intervention and page 124 (6.4.5) influence of decorporation therapy

“If medical treatment to prevent uptake or enhance excretion is administered, then the data provided in the models summarised above cannot be used directly to assess committed effective doses from monitoring information “ and “The use of interventional techniques may partially or completely invalidate the use of standardized model approaches described above to estimate the intake and dose”  need to be developed to make advices….


Page 101 (245) line 3545 Bioassay data

“For this reason, method (iv) has been adopted in this series of reports, with the intake determined using the male biokinetic model where sex-specific models are provided. It is recommended that this method should be adopted for the interpretation of bioassay data.” The reason has to be developed ….


Page 41 (62) line 1438 and page 105 (262) line 3690

Typical breathing rate is in page 41 (62) line 1438 1.1 m3 h-1 and in page 105 (262) line 3690 1.2 m3 h-1; need homogenisation


Page 120 (330) line 4289

“In addition it is important to evaluate the influence of radiopharmaceuticals that may have been administered for diagnostic or therapeutic purposes.”  need to be developed..


Page 123  (348) 6.4.4 chronic Exposures

To short explanations on how to use equilibrium values in the case of chronic exposures.


Page 127 (366) line 4614

“If the uncertainties in the measurement or in the excretion/retention function are affected by a bias, the constant-chronic method produces a biased result, but the bias in the result can be eliminated by the use of appropriate adjustment factors” need to be more explicit or developed



C -  Editorial comments


Page 26 (33) line 861 : .. after working days.

Page 34 (36) line 1150 ( )  (Niita et al; 2010)

Page 34 (37) line 1158 Photon and electron transport are

Page 36 (44) line 1273 delete )

Page 45 (79) line 1608  replace offspring:adult ratios by offspring to adult ratios

Page 97 (230) line 3366  (ICRP,   , 2008)

Page 98 (233) line 3408  (Bq s-1)

Page 104 (252) line 3614 modify Bottle-Mannikin Absorption (BOMAB) phantom for whole body monitoring, the Lawrence Livermore thorax phantom for lung monitoring

Page 106 (265) line 3716  replace PAS:SAS by PAS/SAS

Page 108 ((274) line 3782 : the effective half-live of the radionuclide and is progeny

Page 108 ((276) line 3806  change : where accidental intakes by incidental intakes

Page 111 (291) line 3918 : modify viz.

Page 112 ((295) line 3958  replace period by time interval

Page 139 7.4 line 5095 modify the title : Quality Assurance by Quality assurance of tabulated data