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Submitted by Ingemar Lund, Swedish Radiation Protection Authority
   Commenting as an individual
Document 2005 ICRP Recommendation
Some comments:

1) The present draft is using concepts like "exclusion" and "dose constraint" in a new way. The deviations from the concepts/definitions used in ICRP 60 and other ICRP-documents should be explained and motivated. In principle a section where the suggested system and its concepts are explained in a complete and clear way should be prepared.

2) I do not understand why the issue of Justification is given such small significance in the present draft (except Medical Exposure). Justification of practices (sources) is often performed, both when existing practices and use of radiation is changed/stopped (due to new technical developments) or introduced. Such considerations are done by operators, authorities and politicians (and others) and it is not clear to me why this is not elaborated in in the present draft. In my profession the issue of justification is for example raised in connection with exercises with or without radiation sources, in connection with the protection of the environment at nuclear power plants, and in connection with smoke detectors (optical or detectors containing radiation sources (Am-241)).

3) The relation between the individual-related protection/dose limits and the source-related protection/dose constraints is not clear and needs further elaboration. The ICRP suggests that the dose limits recommended in ICRP-60 should continue to be applicable but it is not clear to me if one power-plant, several power-plants or all power-plants (in several countries) is to be seen as a source? Is the maximum dose constraint (effective dose in a year) of 20 mSv given in Table 7, page 43 is limiting the individual worker or is it the recommended maximum dose limit of 50 mSv (100 mSv as an average in five consecutive years) as given in ICRP-60? If the effective limit (dose limit or constraint or what it should be called) is lowered to 20 mSv this should be motivated and reflected in the risk estimates.

4) Interventions and Practices use to be separated (with an acceptable explanation). The present draft system (without the concept of intervention) does not seem to retain the concept of intervention. This should be elaborated on in a more clear way. What is gained and what is lost by such a change?

5) In S2 (Page 1) it is said that "The primary aim of radiological protections is to provide an appropriate standard of protection for man without unduly limiting the beneficial actions giving rise to radiation exposure... still represents the Commission's position". Should not this statement be complemented by something about the protection of the non-human environment (or is it of secondary importance)?