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Submitted by J.Welbergen, Dutch Society of Radiation protection
   Commenting on behalf of the organisation
Document 2005 ICRP Recommendation
 
The Dutch Society of Radiation protection should appreciate, that if the
> announced New Recommendations 2005 are going to be accepted, a more
> evolutionary fine-tuning of ICRP publication 60 is made instead of a whole
> new serie of publications (100?).
> There is no indication of the promised simplification and increase in
> transparency . It often remains unclear, whether ICRP60-recommendations
> are still valid or overridden.
>
> After consultations the Dutch Society of Radiation Protection
> hasformulated the following statements as outcome of the discussion with
> her members:
> - No major problems are identified in the present system of protection
> during normal situations! So why New Recommendations?
> - (macro) Justification is determined by Society, (micro) Justification is
> a part of RP system and determined by RP-experts. So they should therefore
> be a part of the New Recommendations!
> - The definition of "dose constraint" and single source are unclear. The
> introduction of a source dose constraint does not contribute to a better
> understanding of the principals of RP.
> - The Dutch Society for Radiation Protection (NVS) is not convinced by the
> arguments of the ICRP to rename deterministic effects into tissue
> reactions and equivalent dose into radiation weighted dose. Introduction
> of new terminology leads to a lot of confusion. It also negatively
> influences the credibility of the 1990 Recommendations, and therefore the
> NVS strongly opposes the proposed changes.
> - We support the attempt to introduce environmental elements into the RP
> system.
> - We welcome the introduction of lower boundaries (exclusion levels).
> - The introduction of a threshold for the teratogenic effect is very
> useful.