The draft ICRP document contains some important issues related to the radiological protection system. First of all, NORM is considered to make the typical exposure situation by low dose/ low dose rate radiation. The current biological research data regarding carcinogenesis have been showing the big difference from the cell-oriented biological hypothesis in ICRP Pub103. The use of a graded approach needs to understand the risks of the low dose/ dose rate specific situation for getting the realistic decision. The risks by low dose/ dose rate radiation will be scrutinized more based on the current tissue-oriented biology data. Without clear definition of low dose/ dose rate risk, to define “the magnitude of the hazards” is very difficult not only specialist but also stakeholders Secondly, Fukushima disaster has been showing the necessity of discussion regarding the practical approach to types of exposure situations. This means NORM also need more discussion regarding types of exposure situations and the graded approach based on actual experiences.