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

Thank you for the opportunity to comment onTG93 Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident draft recommendations.

First, I feel strongly that ICRP’s recommendations for “recovery” from nuclear disasters will actually INCREASE risks to public health, particularly for women and kids. These recommendations support shifting health and recovery responsibilities from industry and government to individuals and communities, despite the myriad difficulties in implementing them over the long term. Individuals and communities are not equipped to take this on--and they are not the ones who would be responsible for an accident in the first place. So these recommendations are basically an effort to rig the process in favor of protecting industry investment, and against the communities whose lives have been literally destroyed. Destroyed by the actions of entities who will shirk all accountability when they screw up, and with such high stakes. 

Here's how ICRP can make this better:

• Recommend that, at the least, women (particularly those of childbearing years) and children depart land contaminated by nuclear disasters.
• 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.
• 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.
• Recommend contaminated land NOT be used for agriculture.
• 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.

Thank you again for the opportunity to weigh in. I for one do not want recovery from such a disaster to be in the hands of the people who are MOST AFFECTED and LEAST CAPABALE of an effective response.