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Comments on Radiological Protection fro Cosmic Radiation in Aviation
General Comments
The comments we have received, as Association, about the document under consideration, show positive judgments both about the objective, the structure of document, and the presentation that incorporates the basic principles and enters into practical application, in a field where the individual and collective occupational exposures are significant and increasing and where a synergy between RP, flight safety and airline business needs could be useful and probably is seeking. It has been appreciated the initial part of introducing the origin of cosmic radiation for the exposure assessment in aircraft and the discussion on the level of excess risk. It has been also appreciated the approach used and the suggested process in considering the exposures frequent flyers with exposure possibly comparable to those of aircraft crew, and moreover the suggestion to adjust the flight frequency for pregnant frequent flyers. Specific Comments -A first point regards the glossary. It was recognized as clear and appreciated the footnote on page 24: “At the time of the publication of the present report, the Commission was revising the glossary enclosed in Publication 103 because of some imperfections and inconsistencies with the text so that the report is referring to the text of Publication 103 rather than to its glossary.” Nevetheless by reading this draft now, some voices related to main concepts, should need attention for seeking consistency. Here after two examples, on Justification and on Optimisation: -Justification: -In Publ 103, 2007, the definition considers the process of determining whether … a proposed remedial action … in existing exposure situation is likely to be beneficial .. -Justification:-In this draft, the definition considers the process of determining whether … the decision to control exposure … in existing exposure situation is likely to be beneficial .. -Justification: - As an example with reference to a recent publication (Publ 124, 2014) the definition considers the process of determining whether … a proposed remedial STARTEGY … in existing exposure situation is likely to be beneficial .. - Optimisation: -In Publ 103, the optimisation of protection is the process of determining what level of protection and safety makes exposures , and the probability and magnitude of potential exposures, as low as reasonably achievable … -Optimisation:-In this draft the optimization is a process aiming to keep the magnitude of individual doses, the number of people exposed and the likelihood of potential exposure as low as reasonably achievable … -line 257-258- Change “… is cosmic radiation originating outside the solar system.” with “… is cosmic radiation originating outside the solar system, either in the Milky Way or outside it.” -line 390-392 – A reference could be useful in relation to the sentence :“The future use of new ultra long-range jets …” -line 436-439 – “Given the high proportion of female cabin crew, the report also addresses the topic of the exposure of pregnant women “ to be change in “The report also addresses the topic of the exposure of pregnant women”. -line 485-486-Change “GCR is mostly prototons (85%) with an energy fluence ..” with “ GCR consists of about 85%protons, 14% alpha particles and 1% havier nuclei. The proton energy fluence ..” -line 513- 515- Fig. 2. Change “ … from 1964 to 2014 (Paris …) “ with “ … from 1964 to 2014, in Kerguelen Islands, in the southern Ocean (Paris …) “.
-In 2.5 Exposure of aircraft crew. Could be useful also to cite the data and information in (Anderson JL, Mertens CJ, Grajewski B, Luo L, Tseng C-Y, Cassinelli RT II. Flight attendant radiation dose from solar particle events. Aviat Space Environ Med 2014; 85:828–32.) on radiation dose during solar particle events and the equivalent dose to the conceptus. -In 2.6 Epidemiology - Suggestion to cite and briefly report the conclusion of the interesting work (Grajewski B, Whelan EA, Lawson CC, Hein MJ, Waters MA, Anderson JL, MacDonalds LA, Mertens CJ, Tseng C-Y, Cassinelli II RT, Luo L – Miscarriage in flight attendants- Epidemiology 2015; 26; 192-203) on miscarriage risk among flight attendants, made on the basis of data from 3 US airlines and comparison with a teacher group of minimal air travel. |
-lines 717-719 (37) - Consider to change “ .. with the central consideration being optminisation process below appropriate dose restrictions.” In “ .. with the central consideration being optminisation process a requirement below appropriate dose restrictions.”
-lines 734-743 (in 39) – Even if this draft document is more focused on existing exposure situations, consider to maintain the order of presentation, as in ICRP 103 and other publications, as: -planned, emergency and existing exposure situations
-lines 756-757 (in 41) - Consider to continue to use, as in ICRP 103 and in the glossary of this draft, for the three categories of exposures: occupational, public and medical exposure of patients.
-lines 7563-764 (in 41) – Consider to change in “Public exposure encompasses all exposure of the public other than occupational exposures and medical exposures of patients.”
-line 779-780 (in 43) – Consider to change “…justification principle is applied in making the decision as to whether to take action to reduce exposure and avert further additional ones “ in “…justification principle is applied in making the decision as to whether to take action to reduce exposure and avert further exposure“
-line 804-811 (in 47) – By talking about optimisation it is written “ …. As low as reasonably achievable (ALARA) below appropriate individual dose criteria, taking into account economic and societal factors. “ ….. “the Commission recommends using individual dose criteria (reference levels and dose contraints) in the optimisation process (Paragraph 226 of Publication 103). “. Moreover in line 339-340 (in glossary) we have : “…(ALALRA) below the appropriate dose criteria (constraints or reference level), ..”. The suggestion: -since the wording dose criteria and individual dose criteria in not reported in ICRP 103, the suggestion is to be consistent with the used wording in this draft, and moreover to take the opportunity to introduce in the glossary “dose criteria” or “individual dose criteria” may be considering also, more in general to include also the ‘dose limits’.
-line 813-815 (in 48) – Consider to change “ … judged to be inappropriate to allow exposure occur ..” as “…judged to be inappropriate to plan to allow exposure occur ..” in consistence with what written in ICRP 103 and in this draft glossary and moreover to change “protective actions should be implemented” as “protective actions should be planned and optimised” as in ICRP 103 (234) and if you want also specifically “ should be implemented” but to cite “optimised” should be useful.
- line 844-848 – Consider to move “taking into account economic and social factors” from line 846 to 848 after “as low as reasonably achievable”
-line 927-927 – Thank you for the recommendation that general imformation about cosmic radiation should be made available for all passengers for example through the airlines’ websites, it will be very useful.
- Frequent flyers-The definition of frequent flyers as in the glossary, and then introduced in (61), is very basic and really the registration in a frequent flyer programme could have or not have an indicative value. In (62) the Commission encourages who may be concerned by their exposure to use dose calculators and to adapt their flight frequency as they feel the need. In this context, since the point on the attention to the flyer radiation exposure is already introduced, a tentative value of frequency in relation frequent flyers, and moreover of the frequency which result in exposures comparable to aircraft crew could be proposed in (62) and in (63).
-4.2.3 Aircraft crew – Consider to add, for a more comprehensive approach, a sentence on dose to the lens of the eye similar to that in IAEA 1731, 2013 (Implications for Occupational Radiation Protection on the New Dose Limit for the Lens of the Eye) by remebering again that in existing exposure sitation the dose limits do not apply and that due to the homogeneity of the radiation field the dose to the lens of the eye can be assumed to be similar to effective dose .
-Tab 4 -Suggestion to write “ Reference level to be selected in the 5-10 mSv/year range “ as already in the text and not “. . . 5-10 mSv/year band”
-Some of the documents in the references are not cited in the text, and viceversa.