The draft is significantly improved in comparison to the previous version. However some more developments are necessary to improve on the current high radiation protection performance for both occupational and public exposure and to bring radiation protection to a reasonable excellence.
Our common understanding is that a dose constraint is a radiation protection tool for the optimization process and should be in the responsibility of the corresponding stakeholder e.g. the nuclear industry except of public exposure. This seems not to be clear enough in the current draft. We recommend the Commission to clarify the use of dose constraints.
In addition we expect that the Commission define the principles of dose constraints, whereas the responsible stakeholder should have the flexibility to set the corresponding numerical values adequate to their specific context. This should apply to all situations.
On the international level, the key numerical values of protection should be the dose limits alone. This would allow avoiding any confusion concerning the risk that dose constraints become de facto new dose limits.
Lower bound to optimization and justification
The current draft contains no lower bound to optimization and justification and therefore gives the impression that optimization must go down to zero. This strains on the ALARA principle and will lead to confusion with existing situations. The lower the dose, the more one need to question the extra gain in protection relative to the needed effort. ALARA is a current and widely accepted radiation protection tool that should continue to be used in the nuclear industry. We recommend the Commission to reintegrate a lower bound to optimization and justification and to base radiation protection practices more strongly on the ALARA principle throughout the whole document.
Radiation protection of the environment
There is an international consensus on the need for establishing an iterative process to determine the need for, and if necessary, the form and content of additional or revised standards. Actually the knowledge is not on a level that allows for additional or revised standards. The current status that the existing radiation protection standards do provide an adequate level of environmental protection should be clearly reflected in the document to avoid uncontrolled and uncoordinated actions on the international level.
NORM and existing situations
Applying radiation protections standards to NORM situations often lead to confusing conditions relating to existing situations because of high natural background radiation. Leaving the responsibility for an adequate constraint to a specific NORM situation to the corresponding stakeholder (see also comments on dose constraints) would maintain the necessary flexibility of the radiation protection system even in the big variability of natural background radiation.