Comments on Radiation Detriment Calculation Methodology, ICRP draft report TG 102
6/4/2020
Thank you for the opportunity to comment on ICRP draft report TG 102 Radiation Detriment Calculation Methodology.
Recognizing and addressing the shortcomings of radiation detriment models is necessary. Historically, there has been slow policy acceptance of new radiation research findings, extending as long as 40 years. Meanwhile, in the last 40 years, we have had three of the world’s worst civilian nuclear catastrophes, spanning the globe.
ICRP recognizes areas of improvement for calculation of radiation detriment in its Suggestions for future improvements section of TG 102. Suggestions include:
1) Improving key factors affecting detriment such as DDREF, age at exposure and sex
2) Including as yet unknown factors that could influence sensitivity
3) Changing detriment models to reflect advances in scientific understanding of radiation health effects, especially for populations with protracted exposures
4) Examining “recent findings regarding heritable effects of radiation”
5) Providing a full description of calculation steps to ensure transparency and traceability of detriment model derivation.
These suggestions are necessary and salient.
Much newer research should be integrated into ICRP detriment models, some of which is elucidated below, including new research that appears to address (in large part) a disconnect between observed health impacts and detriment models.
ICRP proposals do fall short in a number of other areas, upon which I also expound below. Summarized, these include:
Integrating chronic low-dose exposure into its detriment calculation.
Ensuring detriment factors like severity will account for disparate socio-economic factors.
Rejecting the averaging of sensitive women and children with less sensitive men.
Accounting for damage to pregnancy
Rejecting the DDREF concept
Including non-cancer impacts
COMPLETE COMMENTS ATTACHED AS PDF