We would like to echo the statements of many who have already commented to these proposed changes. Even though the science of the report appears sound, the practical application needs more discussion. The potential cost of implementing these changes may not have a justifiably desired impact of decreasing risk to workers in radiation environments.
The costs of development, manufacture, and implementation of a new dosimeter or dosimetry system could be substantial. As a larger organization that has over 800,000 active personal dosimetry wearers with over 3 million dosimeters of varying types, these costs could possibly be absorbed in normal operating and R&D budgets; however, the risk of smaller companies could be quite substantial. These costs may drive them out of business.
We think that it would be extremely prudent to perform a study on current personal dosimetry systems with the new definitions against current standards prior to any discussions on implementation. This process would help determine the magnitude of changes required to current systems and help determine the costs that companies may incur.