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Submitted by DEI/SECRE, IRSN
   Commenting on behalf of the organisation
Document Reference animals and plants
 
(Only general comments are provided)
The approach that is described throughout the document strongly mimics what has been developed for the human radioprotection system while proposing to adapt the later to build the system for the radioprotection of the environment. This consistency between the two approaches is necessary. However, one other major point to respect while developing the system of radioprotection of the environment is to fit as far as possible the existing approach and associated methods for chemical substances. This point is too poorly developed throughout the document. Having a look on the methods of ecological risk assessments for chemicals, one key issue is always underlined: the object and the level of protection that are targeted (e.g. the structure and functioning of a given ecosystem or the reproductive capacity inside a particular population of a given species, or each individual for endangered species, etc). This is unclearly explained as only exposure and effect at the individual level are mentioned while omitting the underlying assumptions needed when one wants to propagate the protection to upper ecological levels. Existence of indirect effects through food webs is also not mentioned.
The proposed approach could gain credibility underlining that one of the major difficulties in the implementation of ecological risk assessments for radionuclides is a lack of knowledge and data for chronic low-level exposures and internal irradiation pathways. These data gaps imply that the protection of natural populations and ecosystems from chronic low-level exposures to ionising contaminants will require development of methods of extrapolation from existing knowledge or at least a strategy of how to treat lack of knowledge. ICRP should encourage also such research development.
More specifically, throughout the text, we have found only two references supporting the need for consistency with other stressors: in bullet (25) expressing the need for consistency in regulatory approach and in bullet (22) promoting the similarity between the concept of RAPs and the one of assessment and measurement endpoints cited by Suter (1999). The latter is probably a misunderstanding of the definitions given by Suter (1999). It is difficult to understand the points that are shared with the definition given for reference organisms: Assessment endpoint is an explicit expression of an ecological value to be protected and a measurement endpoint is a measurable response to a stressor that is quantifiably related to the assessment endpoint. We guess that there were a confusion with “ecological receptors” (?).
The justification for a proper use of taxonomy merits to be shortened to highlight the most important message (section 3.3), and also to be correct (various mistakes can be found). The state-of-the-art on effects of ionising radiations on plants and animals needs to be completed as it is necessary to clearly state what is known and what is unknown, and to balance the description between the various taxonomic groups (e.g. section 5 is too heavily devoted to mammals and vertebrates).