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ICRP: Free the Annals!

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Submitted by GARCIER, EDF
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
Electricité de France and its Radiological Protection Council held a plenary session with its members,
and would like to give you their comments on the ICRP draft recommendations for changes in the radiological protection system.

These comments were drawn up by the membership as a whole and they all have a different approach to radiological protection: some are medical doctors, others engineers in charge of supervising workers in the nuclear field and you will find a list of the council’s members appended.

The new radiological protection recommendations take note of changes in scientific knowledge and in society and propose that greater account should be taken of the individual within society.

All the Radiological Protection Council members are sorry that a strong principle has disappeared, namely «if the risk for the health of a group’s most exposed individual is insignificant, the risk for the health of the group’s individuals as a whole is insignificant».

Our first remarks concern dose constraints and we think that the new definitions of constraints as set out in the draft could disrupt the fundamentals of radiological protection which is implemented in industrial facilities. Radiological protection is based on dose limits, optimization (or ALARA) and dose constraints. In our industries, these are operational constraints which lead to optimization.
They are therefore constraints on work and never constraints on sources, be they single or multiple.
As defined by ICRP, the notion of constraint would become even more restrictive than a dose limit.
Moreover, the Radiological Protection Council thinks that these constraints should be for information purposes and never defined by the authorities because in that case, any overrun would become a violation incompatible with industrial operation.

On another point, we think it a good thing to recommend that the values put forward by the IAEA be used for exclusion levels. Discordance between values proposed by international institutions always makes the public wonder why and jeopardizes the credibility of each of the institutions.

The use of sieverts only for the effective dose will certainly help reduce confusion and wrong use of the unit. It does not, however, seem necessary to propose another unit, since the term "radiation weighted dose" in tissues or organs is sufficiently explicit. The introduction of a new unit could go against the aim of clarification for users.

Using a matrix to replace the collective dose will put an end to its wrong use, which ICRP initially warned against, but which has very often been the case, namely a risk calculation totally lacking in any scientific basis, consisting of multiplying very low exposures by very large numbers. The principles for drawing up this matrix should, however, be clearly stated when the recommendations are published.