Submitted by Binika Shah, World Nuclear Association Commenting on behalf of the organisation
WNA Comments on ICRP Draft Report “The Use of Effective Dose as a Radiological Protection Quantity”
The World Nuclear Association supports the intent of this report. The nuclear industry is acutely aware of the misunderstanding caused by the use of both effective and equivalent dose, and we believe that this change may allow improved communicability of the system in future. There are still some areas which need developing further, and we would welcome the opportunity to contribute to the discussions in these matters.
Below are some general and specific comments:
We understand that the changes described in this document look to improve the current situation and will be implemented with the next general recommendations, and not earlier. Whilst the ambition is to discontinue the use of equivalent dose, it will not be possible to effectively regulate until limits are available for the absorbed dose. Once it is implementable, industry (and other stakeholders) will need time to adapt the corresponding processes.
The need for the recommendations in this report may have been avoidable if there had been greater investment in the education of the population about the merits of a system which has been demonstrated to be robust, reasonable and pragmatic.
At present, there is little easily digestable information for a non-technical specialist in this draft report – we believe that its inclusion would add value.
There is some merit in the continuity of collective effective dose, but with it being very explicitly clear where its limitations may lie. Whilst we agree that there is value in its use as one of several metrics in the optimisation process, it has been misused for a long time as a tool for estimating health effects (either retrospectively or prospectively). This report should reinforce this point clearly, and not allow for any misinterpretation on this matter which could potentially be seen in the text on its application during a severe nuclear accident in paragraph (92).
In updating the dose limit associated with tissue reactions, ICRP should consider the establishment of a factor substituting the radiation weighting factor so that radiation risks can be easily evaluated even in a mixed radiation field.
Individual monitoring has been highlighted in many places within the text. Is the ICRP paving the way towards more individual monitoring? We do not believe that it is merited where doses to the majority of workers are extremely low.
In this draft document (46) it mentions that for doses in excess of 100mSv delivered at high dose rate, a DDREF of two applied in determining solid cancer risk at low dose /dose rates will not apply. The ICRP should identify and explain the level above which a DDREF of two is not applicable to evaluate radiation risk.