I appreciate the effort by the Commission in drafting the new ICRP Publication. As a scientist, and as a resident of a Japanese city contaminated by the Fukushima nuclear power plant disaster, I would like to make a few comments.
First, I acknowledge that the new Publication, as it was the case in the previous Publications 109 and 111, contains some practical and reasonable ideas in handling large-scale nuclear accidents. Nevertheless, I think the most important principle is lacking, or quite unclear at least. It must be individual human rights that comes first. Even in the case of a large-scale nuclear accident, members of the public, who have no responsibility for the accident, must have the right to limit the additional exposure below 1 mSv/year (the dose limit in the “planned exposure situation”). Any recommendation by ICRP must not be used to justify nullifying this right.
The literal enforcement of the dose limit 1 mSv/year would result in large-scale forced relocations (much bigger in scale compared to what was implemented in Japan after Fukushima nuclear disaster). It would interfere with people’s natural desire to live in their hometown. I believe that, the new Publication gives some useful guidance on how to allow people to live in contaminated areas. However, this must be based on a truly voluntary decision of each individual. This means that, the authority must allow relocation of each individual (or family) with sufficient compensation outside contaminated area (where the dose limit 1 mSv/year is exceeded). Without such a right to relocate, the recommendations in the Publication can lead to suppression of individual human rights.
In fact, in very wide areas in Japan, including some parts of Greater Tokyo which is more than 200km away from Fukushima nuclear power plant, was contaminated above the threshold for “radiation control area” according to Japanese regulations. More than 8 years after the accident, some areas still remain above such a level. Forcing the residents to continue living in contaminated areas to continue amounts to applying a different standard just based on residency, and is a clear violation of equality before the law.
Quoting Article 7 of United Nations Universal Declaration of Human Rights,
“All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination.”
No “justification” or “optimization” described in the Publication can be above the principle of equality and human rights. In the absence of the freedom of relocation (including financial guarantee), the “co-expertise process” including “dialogue processes involving different stakeholders” can result in a convenient excuse for ignoring radiation protection of individuals. The recommendations in the new Publication must include a clear reference to human rights, and an establishment of the right of relocation to a non-contaminated area. The other recommendations could be applied to the community of the residents who voluntarily chose to live in the contaminated area, provided that the contamination is below the level allowed in a long-term phase.