3) The Concept and Use of Reference Animals and Plants for the purposes of Environmental Protection General aspects A well developed glossary seems important because the subject of this report was not yet considered by ICRP. As an average reader is probably not necessarily interested in the same extent in fresh water, marine and terrestrial biota, the document is better readable when structured into: • General aspects • Issues relevant to fresh water environment • Issues relevant to marine water environment • Issues relevant to terrestrial environment Approach laid down in (13) is very reasonable, but should be extended to activity concentrations to avoid possible problems in dose assessment Some terminology is not in line with other ICRP documents (see below) The deterministic assessment is a pragmatic approach, as stochastic methods are going to see the light of day in ICRP documents. A stochastic approach should be mentioned a tleaast Comments (7) “…not put at risk”: although the term is in common language used to express risk in a qualitative form, it seems better to use the term “risk” only quantitatively (as risk coefficient), perhaps better here something as endangered p.10 top line: can a “thing” live at all??? (13) See comment to (95) (14) should “ to safeguard the environment” not better replaced by “ to safeguard the health of non-human biota in the environment” ?? (55) and (56) “ water concentration values , … unit concentration” should be uniform (see comments of on “dosimetric quantitites” p.34 above (57) ff: All explanatory material , ie. different approaches should be moved to an annex (63) In addition, the term “radiation quality” is coined already in standardisation to describe given exposure conditions (potential, filtration, etc) rather than the presentation of a spectrum. (78) - particles with an energy of 10 MeV are not really known, delete “with energies… ..MeV” (74) ff: All explanatory material, ie. different approaches should be moved to an annex (74) –(89) should be replaced by a system adopted by the ICRP with newly coined terms, names, quantities and units using exclusively for describing the exposure of nonhuman biota to avoid confusion with human exposure conditions. This system has to used exclusively in the document (95) This applies apparently to external exposure, but should be extended to internal exposure as “natural background activity concentration in biota”