(113) This paragraph speaks about controlled areas (lines 1345, 1352), but from the context it is visible that it is not meant “controlled areas” in the regulatory meaning (like in article 37 of EU BSS COUNCIL DIRECTIVE 2013/59/EURATOM). It can happen that the “true” controlled areas would need to be delineated, but it depends on the expected radiation situation. Therefore we suggest to use only general term designated area:
“(113) To limit unnecessary public exposure, a designated or controlled area for radiological exams or therapy procedures should be established and physically demarcated with warning signs (e.g. Fig. 6.1). As many equine radiography exams are performed in stables with mobile generators, additional measures should be taken to delineate the exposure area to avoid unforeseen exposure of members of the public not involved in the examination. Performing such procedures in stables with solid concrete or brick walls should be preferred where this is possible, because of the shielding offered. Placing signage at the entrance can then suffice. If procedures need to take place in the open field, delineating the controlled designated area with appropriate signage is much more demanding as it needs to consider all risks involved, not just radiological hazards.”
(114) Similarly the beginning of paragraph (114) uses words “In general, members of the public should be kept outside controlled radiation areas,“ (line 1356). But such a wording could lead to misunderstanding. In this context it was obviously meant to speak in broader context than only about controlled areas like in like in article 37 of EU BSS COUNCIL DIRECTIVE 2013/59/EURATOM. Here in this context we recommend to use wording similar to this: “In general, members of the public should be kept outside areas where radiation activities are performed,”.
(145) Graded approach is an essential principle in radiation protection. And it must be implemented also in the veterinary applications. Therefore it must be highlighted here where practical recommendations towards the practitioners appear that the graded approach must be taken into account. Therefore we suggest that the first sentence of this paragraph on lines 1680 and 1681 should be modified:
“It is recommended that the safe execution of veterinary applications be guaranteed by the implementation a quality assurance program at managerial level with applied graded approach.”
And the rest of this paragraph (lines 1681 – 1685) should include graded approach right in the recommendation – it is not possible to imagine any situation when an incident or accident that would be so bad that it would need analyzing, reporting, lessons learned or no-shame, no-blame settings would occur in X-ray diagnostic applications in veterinary medicine. Therefore these sentences should be targeted right in this document towards nuclear medicine and radiation therapy applications.