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ICRP: Free the Annals!

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Submitted by St├ęphane Pepin and Lodewijk Van Bladel, Federal Agency for Nuclear Control
   Commenting on behalf of the organisation
Document Radiological Protection from Cosmic Radiation in Aviation

We welcome this document very much and congratulate the ICRP with the quality of the work. We have some minor suggestions:

Line 418-422: probably a typing error in this sentence. Rephrase as "The Commission also reiterated that there is no need to consider the use of designated areas in aircraft and that the annual effective doses to aircraft crew...


Line 956: “This may result from an individual assessing their exposure, and using this information to engage their employer in a dialogue, if appropriate. ”

  • Employer and employee are rarely on an equality foot in such a “dialogue”: it will be difficult for the employees to “engage their employer” without any external support and/or empowerment. When applicable, the occupational physician and/or the Health & Safety manager of the company should be involved in the process. Occupational medicine services and Health & Safety Manager should also be informed about the issue of exposure to cosmic radiation, so as to be able (a) to identify possible issues of exposure among the staff (b) to create/raise awareness with regard to this this issue, provide correct information to all persons concerned, thereby empowering those exposed to take responsibility for their own protection (c) to address the concerns of employees with respect to exposure to cosmic radiation (c) to give support to the employees in their dialogue with the employers.


  • Add a sentence like “Where applicable, the occupational physician and the Health and Safety Manager should be involved in the process, both to inform individual about the exposure related to frequent-flying and to support the employees in their dialogue with their employer. This, in turn, implies that occupational physicians and Health & Safety Manager  should be duly informed about the issue of exposure to cosmic radiation. Concerned employees should have the possibility to appeal to the regulatory body if a risk of exposure has been identified. ”


    Line 997-999: “Women who fly frequently and may be or expect to be pregnant should be provided with sufficient information…”.

  • Editorial: consider rewording green part, for instance: "...and are pregnant, may be pregnant or cannot exclude a possible pregnancy should...".

  • How to inform them ? Here also occupational physicians, health & safety manager and family doctor/gynaecologist may play an important role.

  • Add a sentence like “They may turn to e.g. their occupational physician, family doctor or gynaecologist and/or Health & Safety Manager to receive information about the exposure and the related risks and get support when engaging in a dialogue with their employer. They may turn to the regulatory body if a risk of exposure has been identified and the employer has not taken appropriate actions. “


Line 1033-1035:  “…the Commission encourages national authorities, airline companies, consumer unions and travel agencies to disseminate general information about cosmic radiation associated with aviation”.

  • Add “Occupational physicians, gynaecologists, medical doctors in general, and Health&Safety Managers in particular should be informed about this issue.”