Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident

Thursday, October 24, 2019

International Commission on Radiological Protection
280 Slater Street
P.O. Box 1046, Station B
Ottawa, Ontario K1P 5S9
Canada

To the members of the International Commission on Radiological Protection:

I thank the International Commission on Radiological Protection (ICRP) for the opportunity to comment on draft recommendations, TG93 Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident.

I am very disappointed that the ICRP’s recommendations for "recovery" from nuclear disasters will increase risk to health, particularly for women and kids, through its so-called “recovery” processes. These processes support shifting health and recovery responsibilities from industry and government to individuals and communities, despite difficulties in implementing them over the long term. This makes the recovery process more about recovering the nuclear industry's money and shattered reputation than the lives it has ruined. These processes are also instituted with the assumption that they will be carried out to the letter and that there will be no discernible health impacts, despite the difficulties in maintaining the processes and current research showing that low doses harm health.

The ICRP recommendations make nuclear power a more appealing energy source than it actually is by convincing governments and people that recovery is possible and that living in a contaminated environment is workable. By the ICRP's own admission, this is likely not true.

The ICRP should adjust its recommendations in the following manner:

• The ICRP should recommend that, at the least, women (particularly those of childbearing years) and children depart land contaminated by nuclear disasters.
• The ICRP should abandon encouraging broad public acceptance and use of any process that tries to convince people they can live in radioactive contamination, such as the "co-expertise processes" ICRP's draft supports. Even if all processes are non-coercive and transparent, they may still fail to meet ICRP exposure recommendations; be abandoned over time due to cost; or abandoned due to the arduous nature of the constant vigilance necessary to maintain them.
• The ICRP should abandon optimization and justification principles, on which the “co-expertise process” relies, because these principles do not comply with the right to health per the United Nations Human Rights Council determination.
• The ICRP should recommend contaminated land not be used for agriculture.
• The ICRP should recommend food contaminated with man-made radionuclides not be consumed, particularly by women and children; and that import and export of contaminated food occur only for research purposes.

“The ultimate test of a moral society is the kind of world that it leaves to its children.”
-- Dietrich Bonhoeffer

Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.

Sincerely,
Christopher Lish
San Rafael, CA