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Submitted by Max Wallis, Cyfeillion y Ddaear (Friends of the Earth Wales) Network
   Commenting on behalf of the organisation
Document Recommendations
 
1) Delete all discussion and recommendations for EXEMPTIONS and Exemption
levels (delete section 2.4 and any tables supporting exemptions)

It is quite wrong of the ICRP to take on society's role of deciding on ¡Èjustifying¡É unlimited and unknown numbers of unnecessary and preventable public exposures. In recommending that some level of radiation is "trivial" for purposes of regulation, ICRP is mixing its self-designated roles as
provider of scientific information with societal risk decision-maker. It is tacitly abrogating the whole concept of limiting "collectinv dose", a step that Roger Clarke was trying on from the NRPB, but was rejected by the UK government. The ICRP as a closed, self perpetuating body that excludes nuclear power critics 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 simply does not have public representation thus 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.

ICRP claims it does not have enough certainty about the effects of low dose
radiation on large populations (termed ¡Ècollective dose¡É estimates) to
estimate the number of cancers that will result in that population now or in the
distant future, yet ICRP thinks it has enough scientific and socio-political
information to actually release radiation to large populations - with no limit
on the number of worldwide releases or ¡Èexemptions¡É - with no limit on the
number of exemptions per facility or to a community - without their consent or
knowledge. ICRP makes a self-determination that the risks are trivial and
acceptable by the public (at the same time it discourages estimating what those
risks are). ICRP does not know how much total radiation will be released or
received when it, across-the-board, recommends not only that countries adopt
release levels but also specifies a suggested level or range. There is zero scientific justification for this recommendation (purely for the sake of the industry). The whole concept of exemptions should be
deleted from the ICRP 2006 Recommendations.

Furthermore, the ICRP should remove the lower bound (essentially an
exemption level) 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.
ICRP is prostituting itself by giving pseudo-scientific cover to giving the regulator the authority to exempt situations from regulatory requirements - ie. waiving legal obligation [page 17, paragraph (42) of Section 2.4] ICRP must get rid of this strongly objectionable recommendation together with all of Section 2.4.

2) ICRP should adopt and incorporate the Precautionary Principle in the overall framework. This came into international treaties from 1990 (Rio UNECE) and is integrated into European legislation. ICRP should stop pretending its value judgments have a technical, scientific or even a sociological basis.
ICRP¡Çs composition is completely one-sided; its mission is promotional not
protective of human health and other living beings or biosystems. As ICRP
claims to attempt to open up - become more transparent, it must include members
who are sceptical about continuing nuclear activities. Balance and credibility are absent when those risking the dose are not even represented. ICRP should be clear about which of its assertions are
scientific and cite the sources for those statements, and just as clear about
which are value judgments (such as the misguided claim that there is a
trivial or acceptable dose that can be exempted, below which resources are not
justified to regulate, or a lower band of constraint dose that does not need to
be regulated). Removing the unjustified or one-sided societal judgments could
potentially help the credibility of the ICRP.

ICRP has 3 basic principles for radiation exposure:
# Justification - a government body (such as the national legislatures or
nuclear agencies) or the nuclear industry licensee/operator decides that an
activity which releases radioactivity and exposes people to radiation is ¡Èjustified.¡É
If the public which is exposed does not get to decide, this is unethical and immoral, unfair, unacceptable. Yet
ICRP sees it as a basis for permitting doses and proceeds to provide ranges of
acceptable doses in various situations. Justification makes sense when the exposed person decides, not when that person has no say but the entities making and controlling the potential hazard
decide. It is even more questionable in non-Democratic societies, more and more
of which are establishing nuclear power and weapons industries right now.

# Optimization - a convoluted process by which the nuclear promoters determine
how much it is worth to regulate and reduce exposures. It is used as a justification for exposing people in all situations. There is no guarantee or mechanism for the exposed individuals to determine if or how much radiation is imposed on their bodies. Includes the concept of ALARA - as low as reasonably achievable - taking the industry¡Çs economic factors into consideration in deciding what is ¡Èreasonable.¡É

# Limitation of "Dose" - The UK CERRIE review found very wide variation in assessing effective dose, by factors of more than 10 in terms of cancers generated. While ICRP tries to refine 'dose' to cover eg. harm to the foetus, we know that the major harm is teratogenic and not the carcinogenic or genetic harm which are the subject of ICRP studies. Apart from the foetus, we now know there are other particularly sensitive and vulnerable sub-populations. The leading US epidemiologist, Prof. Steve Wing, in his review Health Effects Of Low Level Radiation [Statement to the Subcommittee on Energy and Environment of the Committee on Science, US House of Representatives, July 18, 2000 (www.nukebusters.org/html/health_effects.html)] said
"It is increasingly clear that there is great variability in the sensitivity of humans to low level radiation due to factors such as age, genetic susceptibility and exposures to chemical agents, infection or nutritional factors. Decisions about exposure standards should take account of the special risks faced by the young, the old and the genetically susceptible. Public health and moral principles demand that we protect the most vulnerable." The ICRP review has failed in closing its eyes to all this new science - so its dose model is increasing stripped of scientific validity. Unnecessary radiation doses should be prevented and avoided, not permitted
at low or continuous rates. When dose limits are set, they should protect the most susceptible taking uncertainties including synergistic effects into account."


"Averaging¡É radiation risks.
It is time that ICRP acknowledged and accounted for non-cancer health risks from radiation like cardiovascular diseases, reduced immunity, development defects in the foetus, as well as cancer.
CERRIE considered how should (relatively new) biological knowledge, like the bystander effect
and other uncertainties about the impact of radiation at low doses be incorporated into existing radiation standards, but ICRP has failed to address this. ICRP needs to acknowledge and
account for the large potential for much greater health damage from multiple
exposures to radiation and other hazardous materials and conditions in the
environment. Radiation damage is multiple, additive, cumulative and synergistic
and should be considered such by ICRP. Some of these concerns are addressed
with suggestions for quantifying the risks and uncertainties in the European
Committee on Radiation Risk (ECRR) in its 2003 Recommendations of the ECRR: The
Health Effects of Ionising Radiation Exposure at Low Doses and Low Dose
Rates for Radiation Protection Purposes: Regulators¡Ç Edition. ICRP should take
this report fully into consideration and publish its views for response before proceeding with new recommendations.

Should ¡Èacceptable¡É radiation levels (above natural background) be set for BIOTA (animals, plants and the environment)? The answer to this has to be - no. The European Habitats Directive prescribes that any harm to listed (designated) species is to be excluded. The variation in suceptibility between species is such that using criteria for "reference species" cannot be scientifically justified. Attempting to develop the reference fauna-and-flora system approach of Pentreath (1999; 2002) is seen to be the huge scale of the task. Even for non-listed species, the extent to which a ¡Æreference¡Ç approach based on a few well-defined reference organisms could usefully be applied to many different specific locations or circumstances, and the individual basis is very limited, not taking account of impacts on higher levels of organisation. The FASSET project and IUR supported the reference flora and fauna approach despite finding it to be impracticable, with large gaps in the sensitivity matrix (Strand et al., 2000; IUR, 2000). A very basic ¡Æreference fauna and flora¡Ç approach to establish release rate limits was applied by the IAEA in its consideration of redefining annual release rate limits for the purposes of the London Convention (IAEA, 1988). Both the USDOE and the Canadian approaches also make use of some form of generic reference ¡Æorganisms¡Ç or entities for assessing compliance with predefined dose rate limits or for calculating doses to exposed organisms to calculate a risk quotient by comparison with dose-effect data on relevant endpoints. The model tried to follow the ICRP's "reference man", but that focussed on cancer-endpoints. For animals and certainly for fish, the most vulnerable stage is the egg/embryo, and setting protective levels taking acount of bioconcentration would generally lead to unattainably low levels. This forces us back on wider, non-scientific judgements, which ICRP is unqualified to make.

Thus, ICRP's setting legal radiation exposure levels for animals, plants, and ecosystems is (like the IAEA's in 1988) not scientific but aimed to help radiation polluters escape liability for environmental contamination and exposure to non-human species. This is quite unacceptable from a supposedly scientific body.

We note that ICRP is continuing to recommend the same old public and worker exposures even though
a) known cancer incidence risks have increased somewhat (by a third in National Academies of Science BEIR VII report from 8.46 to 11.41 cancers per 10,000 person rads or 100 person grays) and
b) progress in bio-medical science shows that radiation damages more cells in the current and future generations of cells than those directly hit by radiation (bystander effect)
c) progress in genetics shows harm to the genome at much lower exposures, and that this harm may be synergistic with chemical and other 'insults' to human cells and wider human health.

As the Aarhus Convention is now in force (on Access to Information, Public Participation and Decision-making and Access to Justice) and implemented in the EU via the Public Participation Directive 2003/35/EC, we argue that ICRP has to follow its requirements in this consultation. That requires ICRP to prepare a full report on the submissions from ourselves and others, show which of our points are accepted and how, and give clear and cogent justification for the points it chooses to reject. This should be made public as soon as possible (3 months in the UK) and well in advance of proceeding to final recommendations. Please inform us that you will adopt some process along these lines and tell us when the response report will be available.

Max Wallis / on behalf of Cyfeillion y Ddaear.