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

I welcome this publication bridging the earlier ones, which I believe to be still very valuable as well, adding the rich experience from the nuclear accidents in Chernobyl and Fukushima. The document contains very sound guidance on the factors that need to be considered when taking decisions in the emergency situation and in the long term.

Still, I have two main observations, both relating to the long term. While in earlier guidance the reference level for people living in a contaminated area was to be set in the range 1-20 mSv per year, with the ultimate goal of reaching 1 mSv per year, now a reference level of 10 mSv is recommended. This choice is not substantiated. I believe it to be of little practical value, in view of the uncertainty in estimating exposures and other choices that can be made in defining the reference individuals and their lifestyles. One has to bear in mind that any reference level is often misinterpreted as a limit value, and then the magic number of 10 mSv would prove to be counterproductive. There is no need for it, actually, more important are the other criteria and prevailing circumstances that need to be allowed for. Superficial readers may just remember the summary and the tables with numbers.

The document also addresses the crucial issue of permanent relocation and the criteria for return of the evacuated or temporarily relocated population. All that is written on this subject is very valuable, but I feel three issues are not sufficiently highlighted:

• If at all possible, the decision makers should inform the evacuated population that their relocation is likely to be permanent, if this prediction results from the available information. In that way people may start right away building a new future. Indeterminate prolongation of temporary relocation is psychologically devastating.
• On the other hand, if it is foreseeable that people may return in a reasonable time (see par. 137), then one should try and maintain the community ties and start stakeholder involvement for the community to decide on a return collectively. The decision to return should not be based solely on criteria of individual dose but allow for the expected distribution of doses within the community. I appreciate it that the document now puts some emphasis on the ethical value of solidarity, inter alia in par. 30, and in par. 139 with regard to the management of contaminated food), a value that was overlooked in Publication 138. The stakeholder involvement should focus on preserving solidarity also at local level. Fundamentally, of course each individual or family will decide on its own. If the prevailing situations requires permanent relocation, then the government (or the undertaking that should manage overall liabilities) should of course compensate for the damage.  However, If people decide not to return even if this would represent no significant health risk, than they should not be entitled, in principle, to compensation of this kind.  
• It is therefore very sound that in par. 161 the Commission does not recommend any radiation protection criterion above which it is mandatory to relocate the population permanently. However, in the absence of such guidance it is most likely that people will take the same reference level as for living in the contaminated area (e.g. 10 mSv per year). The criteria are of course very much related, but at the same time apply to essentially different situations. The reference level should guide the actions taken to improve living conditions, with due attention to the most exposed individuals. One should not exclude that a return is decided at levels of exposure that are initially well above the reference level. Hence I would strongly recommend incorporating par. 161 in the Executive Summary and in the Main points, so that this essential distinction is not overlooked.

One further point is of minor practical significance but relates to the overall philosophy of the radiation protection system.  In par. 150 it is stated that employees whose exposure results from an economic activity that is maintained or introduced in the affected area are not to be considered occupationally exposed. This is contrary to the position of ILO as endorsed in the international basic safety standards as well as in the corresponding Euratom Directive. Occupational exposure relates to all exposures at work, irrespective of the exposure situation. In the same way as for NORM industries and for occupational exposure to radon, the employer has a legal responsibility for the health and safety of the employees. It may be appropriate to manage this responsibility in the same way as for a planned exposure situation, including the application of dose limits.