|Thank you for providing the Scottish Environment Protection Agency (SEPA) with the opportunity to comment on the above consultation document.
This revised draft of the recommendations has greater clarity than the initial draft and together with the foundation documents allows the recommendations to be built upon sound scientific arguments. SEPA has provided general comments below and specific comments in Appendix A.
The recommendations seek to introduce three classifications for exposure situations: ‘planned’, ‘emergency’ and ‘existing’ rather than the current classification of ‘practice’ and ‘intervention’. Whilst there are potential advantages in adopting the proposed classification, the differentiation between these three terms is ambiguous and SEPA would ask that these terms be clearly defined. In contrast, the current usage of practice and intervention, although having a number of limitations, is generally well understood and has been clearly defined in existing legislation; introduction of these ‘new’ classifications could require revisions to current legalisation.
The use of the principle of collective dose has a number of limitations which has been extensively debated by the radiological protection community over recent years. The recommendations appear to have omitted that collective dose remains a valuable tool for assessing total radiological detriment and has particular relevance where critical exposure(s) to individuals are not of principle (regulatory) interest e.g. in considering exemption levels or exemption of certain practices. Although care needs to be taken with the presentation of collective dose, out of context, and in particular where the time period or population is very broad or infinite, the tool does allow options to be compared with each other assisting the process of optimisation. Hence, SEPA would suggest that the recommendations include commentary of the value of this tool.
As a public body committed to openness and transparency, SEPA feels it is appropriate that this response be placed on the public record. If you require further clarification on any aspect of this correspondence, please contact Paul Dale, Principal Policy Officer, SEPA Corporate Office, at the address shown below.
Head of Environmental Policy
Page Paragraph Suggestion
5 5 Following the term ‘threshold effects’ the phase ‘deterministic effects’ could be inserted in brackets to aid consistency.
8 11 Third bullet – Instead of ‘fundamental principle’, SEPA suggest that this is the most ‘most basic level’ of protection for individual workers and members of the public.
9 15 References XX, YY and ZZ require to be completed.
10 19 SEPA suggest that ICRP Committee 5 could consider the use of Environmental Quality Standards as these are linked to the value of the environment.
11 23 SEPA welcome the recommendations and suggest that this paragraph is moved further forward in this Chapter to stress the importance.
12 25, 27 The term ‘desirable human endeavours’ is yet to be clearly defined. SEPA would welcome a clear definition being provided.
13 29 The term ‘linear non-threshold’ is written is various ways throughout the report, it is suggested that this principle is consistently used in the report.
22 Figure 1 SEPA would suggest that the use of an equation is unnecessarily precise when greater uncertainties exist in any assessment, and would recommend that a (updated) step factor is adopted.
52 192 The section on optimisation has been substantially improved.
70 277-8 SEPA would request clarification as to whether the 1 mSv dose constraint apples in this situation if a new ‘practice’ occurred (planning opposed to intervention).