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Submitted by Horst Miska, Civil Protection Commission w. Min. of Int., Berlin
   Commenting on behalf of the organisation
Document Emergencies
Second Comment on ICRP „Emergencies 2008“

Additional general remarks to supplement my comment of 7/28/2008:

The new draft on emergencies 2008 is rather vague instead of being specific thus limiting its practicability. The preface states “The TG expects that detailed implementation of the Commission’s recommendations is a matter for the relevant national authorities.” But without specific recommendations, the national implementations will diverge such that comparable measures at both sides of borders are not warranted. Based on the experience in a working group updating national recommendations and being responsible for nuclear emergency preparedness in a state with nuclear power plants at the borders, the difficulties at frontier areas are familiar to me. Response leaders should coordinate their decisions with their neighbors, but this will be hampered by different regulations. Moreover, the population will not understand different protection policy due to diverging national recommendations.

Therefore, more specific guidance for instance regarding the use of reference levels should be given. In ICRP # 63, intervention levels for sheltering (5 – 50 mSv) and evacuation (50 -500 mSv) were stated as averted (external) dose, for administration of stable iodine (50 – 500 mSv) as averted equivalent dose to the thyroid. The current draft only proposes very generally 20 -100 mSv as “reference level” and uses the expression “total dose” without defining this dose. To ensure practicability and harmonization across borders, please introduce well defined reference levels for the main protective measures; and do not hide these in the text, but clearly state them in tables which enhance readability of the document.

To be effective, command and control are needed – as in fire fighting to respond in the early phase of a nuclear emergency, not democratic decision finding. In the late phase, more democratic procedures based on broad discussions become possible. This is only partly reflected in the report when the “reflex” use of protective measures is proposed. But this aspect should be kept in mind for the whole document and facilitated more specific recommendations.

Horst Miska, Klein-Winternheim
Civil Protection Commission with the Minister of the Interior Germany, Berlin
Ex EU COM, DG ENV, Brussels
Ex Ministry of the Interior Rhineland-Palatinate, Mainz