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Submitted by H.-H. Landfermann, Bundesministerium für Umweltschutz (German Ministry for the Environment)
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation

Opinion of the Federal Environment Ministry (BMU) on the ICRP 2005

The new ICRP recommendation was brought about by a desire for simplification and consistency of the existing system for radiological protection and for latest scientific developments to be given due consideration, since the last fundamental recommendation by the ICRP, No. 60, was published 15 years ago.

Taking into account the points above, a new ICRP recommendation is welcomed in principle. However, several points for consideration remain open with regard to the current "draft for consultation".

- Even if the ICRP recommendation no. 60 is revised, the new recommendation should not contain reference to the ICRP 60. It should be fully comprehensible in itself.
- An outline of the entire system at the beginning would be welcomed:
o The entire concept of radiological protection should be outlined by means of:
- justification
- optimisation and
- restriction of the dosage.
o All substances are radioactive, therefore the beginning of the radiological protection system is only to apply once a threshold (exclusion value) has been reached. (There is a lack of justification for the values given for natural and artificial exposure. Specifically: why is radon at the workplace only taken into consideration above such high levels?)
o Exposure from the different radioactive sources is to be restricted by constraints of different levels depending on the exposure situation (table p. 1). The allocation of the dose values to the exposure situations should be justified more clearly. (Specifically: is the lowest dose constraint still in line with the exclusion value?)
o Dose limits serve to protect the individual. Justification should be given for the values, especially in the case of natural exposure. What will the concept for considering natural exposure be like: total exposure or only exposure enhanced by human activities?
o An internationally uniform definition of the reference person as member of the critical population group would be desirable for calculating public exposure.
o With regard to optimisation, a clear definition of the collective dose for the population and for those exposed occupationally should be given.
There are also further suggestions and specific questions:
o Why should the age-specific consideration be lifted? This cannot be politically tenable.
o Thought should be given to greater age-specific and gender-specific consideration.
o Considerations regarding radon should be revised following submission of the new health studies and the values to be taken into consideration should be justified.
o The ICRP should give its own information on the accuracy of calculating the dose, especially with regard to identifying the individual risk following increased exposure and under normal conditions for the general public.
o A few words of clarification should be included concerning the problem of incorporating radioactive substances in females exposed to radiation occupationally and the resulting exposure of the unborn child.
o In the case of very inhomogeneous exposure, the data on the effective dose is in many cases not informative enough, e.g. in the areas of medicine and radon. Is there a better criterion?
o Data is no longer given concerning exemption values (start of supervision) or clearance (release of radioactive substances from supervision). Are both of these to be covered by the exclusion values?