ITALIAN ASSOCIATION RADIOPROTECTION (AIRP) COMMENTS ON “RADIOLOGICAL PROTECTION IN MEDICINE” DRAFT 12 JANNUARY 2007 The members of the Italian Association of Radiation Protection (AIRP) thank the Commission for the opportunity to present comments on the draft of Radiological Protection in Medicine, a supporting document to the incoming Recommendations. GENERAL COMMENTS In the framework of the 2007 Recommendations, this new draft, provides an indispensable and well defined document for the unique aspects of radiological protection in medical exposures. There is a general very high appreciation for the efforts done by Committee 3 in these years and for the quality and number of documents published on radiological protection and safety in specific medical applications of ionising radiation. The brief synopses, summarizing the most relevant radiation protection aspects and focusing on those specific topics of concern for medical practitioners and supporting staff, are making the document fully comprehensive of the present guidance and they are making it a proper basic educational tool. As a note, it appears that the role of quality assurance is referenced as regard to Institutional Arrangements or as regard to specific applications (e.g. radiation therapy accidents) while there is not in the present document a general address to quality assurance. A more explicit consideration of the role of quality assurance in radiological protection in medicine, with a dedicated paragraph, would be appreciated. By considering the draft documents in support to Recommendations and Recommendations themselves, a higher level of consistency in phrasing and in the use of some specific terms is generally desirable. SPECIFIC COMMENTS Page 9, lines 11-14 and Page 16, lines 8-15 For sake of completeness, the few assumption and calculation, that lead to the probability of cancer induction in a lifetime, as conferred by a single radiological examination (page 9) and the evaluation of the increase in the probability of cancer for the mentioned absorbed dose (page 16) should be explicitly introduced. Page 10, line 5 The ICRP preliminary view about the genetic susceptibility, as expressed in Publication 79 should be here briefly summarized. Page10 line 16-19 It would be useful, by referring doses under 100 mGy, to add the indication “at low LET radiation” even if the contest of the document concerns medical exposures, Page 10 lines 21-24 While referring to malformation a threshold of 100 to 200 mGy or higher is here indicated, in other documents (Biological and Epidemiological Information on Health Risks Attributable to Ionising Radiation: A Summary of Judgements for the Purposes of Radiological Protection of Humans-12/180/06 and the draft Recommendations 12.01.07) it seems that a dose of 100 mGy is considered for the induction of malformation. Page 16 lines 8-15 The reported example about a 45-year old adult undergoing an annual whole-body CT examination for 30 years, seems not appropriate and realistic example. This exposure should be considered only when justified by the context of a severe sickness, where the life expectancy of the patient may be less than 30 years. Page 20, lines 10-16 The part describing the introduction of a practice in medicine may be seen as an over simplification. In modern medicine, new practices are usually quite complicated and their introduction requires years of pre clinical research, investigational protocols, registration of products and clearance of equipment. International and national guidelines from health authorities and professional bodies usually support the introduction of a new practice and clarify its appropriate use. Page 22, lines 3-5 To present the advantages of multimodal equipment like PET-CT merely in terms of “much easier interpretation of images” seems to be reductive. An increasingly wide number of references have shown the advantages of jointly PET-CT compared to separated PET and CT, in terms of diagnostic accuracy and rate of changes in patient management. Page 28 lines 29-31 In addition to the indication that the dose from an excessive radioiodine administration may be reduced by the early administration of stable iodine, data from literature or references should be mentioned and included to better argue this point. Page 32, lines 1-10 Concerning the exposure of comforters and carers of patients the Commission here considers that a value of 5 mSv per episode (i.e., for the duration of a given release of a patient after therapy) is likely to be reasonable. In this indication young children are not explicitly excluded while the draft Recommendations has considered that: (357) For individuals directly involved in comforting and care, other that young children and infants, a constraint of 5 mSv per episode (i.e., for the duration of a given release of a patient after therapy) is likely to be reasonable. Page 39, lines 4-6 It is really important to clarify the separate roles and responsibilities of the figures involved in medical applications of ionizing radiation and, at this point of the document, a short discussion on this item appers to be opportune to be added. Moreover it is desirable to mention the need for a strict cooperation between the involved professionals.