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Submitted by Jane Lumb, Health and Safety Executive
   Commenting on behalf of the organisation
Document The scope of radiological protection
We welcome the opportunity to comment on ICRP’s draft publication "The Scope of Radiological Protection Regulations" 02/258/05 - spring 2006 version, and recognise the value of ICRP’s work on such a complex issue.
We have some general and more specific comments, which we hope are helpful. Should you wish further clarification on our comments we would be pleased to provide them.
General comment
Overall the draft provides a useful update on the concepts underlying exclusion, exemption and clearance and recommends what the numerical limits should be to apply to these concepts. With some amendment it would clarify ICRP's thinking on these subjects and be a welcome addition to the Annals of the ICRP.
Specific comments
We have a number of comments on specific sections, detailed below:
· We are concerned about possible interpretation of the title. It is up to national regulatory bodies taking international guidance into account, rather than ICRP, to define the boundaries of regulatory control. It is, however, quite reasonable for the ICRP to provide guidance on the scope that they envisage for the application of their recommendations; it is therefore suggested that the title of the draft document be changed - perhaps to "The Scope for the Application of Radiological Protection Recommendations".
· The introductory sections 1-3 could usefully be simplified. The sections 4-7 are useful and generally clear. It would be better to have definitions in a glossary at the front of the document rather than as footnotes the first time the word or term is used. This would make it easier to refer to the meanings while reading the document.
· Para 12. The term 'minute' is used here. A definition of what this means would be useful.
· Para 18. The term 'endeavour' may not translate well and could be misinterpreted. Use and suitable definition of the term “practice” throughout would solve this problem
· Para 19. Should 'or a new receptor group be identified' be added after '...pathways to humans change'?
· Para. 22. This states that "the type of exposure should not in principle influence the definition of the scope of the regulatory system" but no evidence is provided to substantiate this assertion; the amenability of control, the need for control, and the benefits of control in relation to occupational, medical and public exposure could lead to the scope of the regulatory system being different for these types of exposure. It is suggested that the last two sentences are deleted.
· Para 23. Replace 'expected' with 'could be'.
· Para 25. Replace 'minute' with 'trivial' as used in footnote 30, and define what is generally meant by 'trivial levels of dose'.
· Para 29. We suggest a sentence is added to clarify that this includes both the situations where people agree to exposure (voluntary) and where they consider that they have not agreed to them (imposed)
· Para. 41. The last sentence is of concern, and may not be correct; it is suggested that it is deleted.
· Para 42. It is not obvious that since the risk factors have increased that the level of a few tens of microSv is still conservative. It is suggested that the second sentence be deleted.
· Para.43. The use of "imprecisely interpreted" and "a significant ratcheting down of the original judgement" could be interpreted to imply a criticism of the IAEA BSS exemption criteria. The original judgement referred to was made by few people whereas the IAEA BSS had input from a much wider group of stakeholders who could also take into account the revised radiation risks. It is suggested that this paragraph should be re-written to be more supportive of the IAEA BSS criteria.
· Para 50. This mentions the 1 man-sievert criterion for exemption, and notes that this does not mean that a practice giving a larger collective dose could not be exempted. This is supported and it suggested that ICRP should make it clear that the 1 man-sievert criterion should be regarded as a screening level below which detailed consideration isn’t needed whereas above the level substantiation of the reasons for exemption would be needed.
· Para 52. It may be possible to exempt potential exposure situations on the basis of frequency.
· Figure 2. This is a very good representation of the situation.
· Para 60. We do not agree that control of the material has been lost when patients are discharged from hospital after taking I-131. The control is vested in the patient. It is for the regulatory authority to ensure that proper information is given to the patient to allow them to exercise that control.
· Para 88. This says that exposure to cosmic rays at altitudes above ground level may be considered for either exclusion or generic exemption, whereas specific requirements are incorporated into this European radiation protection legislation aimed at establishing a radiological protection system for aircrew. It is suggested that Para 88 is revised to reflect this.
· Para 117. While there are arguments to consider both practices and intervention in relation to radioactivity in commodities, there are reasons to only consider practices - provided there are alternative suppliers of the commodities. Whatever the circumstances leading to contamination of a commodity, from the point of the user of the commodity it could be argued that they would be adding exposure by use of contaminated material instead of an uncontaminated alternative.
· Para’s 123 and 134. These refer to numerical exclusion levels for alpha radionuclides and beta and gamma emitting radionuclides. The values do not provide the flexibility provided by radionuclide specific values and cannot reflect the nuances of the use of the values, for example as described in IAEA RS-G-1.7. It is suggested that ICRP reconsider either restricting their document to the concepts relating to defining the scope (ie not specifying numerical levels) or using radionuclide specific values.
· Para 126. This paragraph is unclear. It should be reviewed and reworded to clarify its meaning.
· Para 132. We note that this accepts that there are different regulatory regimes and not just prescriptive ones. This is welcomed.

If you wish to discuss or would like more information, please do not hesitate to contact me.

Kind regards

Jane Lumb