Comment of the German-Swiss Society of Radiation Protection
It seems to us that only the treatment of the organ equivalent dose is new. Although it seems scientifically correct, the implementation seems excessive, because mSv of E and the mSv of HT . may easily be confused. For the user and especially for the layman, it is difficult to understand that we should use two units now, which are (except if wR¹1) of the numerical value in about the same size.
From the point of view of practical radiation protection, it makes no sense and mainly makes the work more difficult.
Indeed, a difference in numerical values only appears where the wR factor is different from 1. So it only affects radiological events, e.g. thyroid doses or organ doses after incorporation of radionuclides. Normally, we are doing well with E, and we need neither the organ equivalent dose nor the absorbed energy. In addition, HT seems still problematic for the lungs unless we have a working dosimetric model.
Summing up, the new conception is of a very sophisticated scientific level but does no improve the radiation protection in practise. The definition of the dose quantities has been a work of scientists who did not need to have the problems in mind of the practitioners. Until now it was never a problem for pactical radiation protection. The level of occupational doses has reached a very low state.