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Submitted by Debra McBaugh, Conference of Radiation Control Program Directors
   Commenting on behalf of the organisation
Document Recommendations
 
1.We support the development of these new recommendations even though the changes are not large. It will be an incentive for U.S. regulations to begin using ICRP 60 values and terminology which would be helpful. We use them for our scientific work but cannot for any regulatory work.

2.The document needs to be much more readable and easier to understand. We will need to explain it clearly to the public when we adopt it into regulations (public hearings are required). It is also must be easily understood by radiation protection staff who will use it.

3.Provide simple examples of optimization, especially for medical practices.

4.Replace the word “constraint” with another term, perhaps planning tool or objective. In an emergency, the constraint may be higher than the limit, whereas generally the term constraint indicates constraining something below the value. A word is needed for a goal that can be set below or above the limit.

5.While not all states have concerns about addressing exposure to biota, those of us with large Department of Energy Facilities would greatly appreciate a framework for dealing with environmental impacts as is described in the current document. This comment would not be agreed upon by all 50 states.