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Submitted by Kurt C. Wilner, Self
   Commenting as an individual
Document Recommendations
Comment on International Radiation Recommendations (ICRP 2006)
Radiation from human-made nuclear waste should NOT be “exempted” from regulatory control (Section 2.4 Exclusion and Exemption).
In recommending that some level of radiation does not warrant regulation, ICRP is inappropriately taking on the societal role of “justifying” unlimited and unknown numbers of unnecessary and preventable public exposures. ICRP is mixing its self-designated roles as provider of scientific information with societal risk decision-maker. Since ICRP is a closed, self perpetuating body, without nuclear power critics, it has no moral or representative authority for making assumptions about the acceptability of risks from involuntary doses to members of the public from the nuclear power fuel chain. ICRP has no authority to assess what additional, unnecessary radiation risks members of the public around the world in this and future generations consider trivial or acceptable, because it has *no* public representatives among its decision-makers.
ICRP does not know how much total radiation would be released or received as a result of its simplistic recommendations not only that countries adopt release levels but also specify suggested levels or ranges. There is absolutely no scientific justification for these recommendations – these are, rather, an economic concession to an industry. The whole concept of exemptions should be deleted from the ICRP 2006 Recommendations. Specifically, the following section should be deleted: "what could be exempted from some regulatory requirements because regulatory action is unwarranted...the legislative framework should provide the regulator with the authority to exempt situations from regulatory requirements, particularly from those of an administrative nature such as notification and authorization…Exemption…relates to the power of regulators to release from specific regulatory obligations…waiving…legal obligation. ” [page 17, paragraph (42) of Section 2.4]. Essentially, *all* of Section 2.4 should be deleted.
ICRP also should remove the lower bound from the radiation levels throughout its text and in its charts on “constraints,” doses, and bands of regulatory control (including Section 5.8.2 para (204) and Table 4, p. 61). Industries should be responsible for and protect the public from all doses, not just those above an ICRP-selected level.
Moreover, ICRP should restructure its framework to incorporate or replace its basic principles with the Precautionary Principle
Most sincerely yours, Kurt Wilner