“Annals of the ICRP ICRP PUBLICATION 1XX Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident Update of ICRP Publications 109 and 111”: hereinafter referred to as “ICRP 109 & 111 Revision”.
In considering the practical safety of radiation, it is essential to consider specific risk values for health hazards caused by radiation. The question is how much risk is considered safe after the risk assessment is obtained. The Environmental Protection Agency (EPA) of U.S.A. has announced the regulation value of various toxic substances in the environment. EPA's criteria for determining hazardous substance limits seem to be 10-4 or less, with lifetime risks ranging from 10-4 to 10-6.
Since 2005, large-scale epidemiological studies on low-dose exposure in populations equal to or greater than the study populations in Hiroshima and Nagasaki have been published. On the basis of these findings, Dr. Okujyou Iwami, a doctor authorized by the Japanese Society of Neurology, examined the lifetime risk of excess cancer death of 1 person per 10,000 persons calculated by BEIRVII, a large-scale epidemiological study summarized by the American Academy of Sciences, and the Japan Society of Occupational Health, and concluded that "In the case of chronic repeated exposure, the 1 year external exposure should be less than 0.013 mSv in order for the most sensitive newborn women not to suffer a lifetime excess cancer mortality risk of 10 -4.*" "The ICRP sets the 1 year public exposure limit at 1 mSv. Why is it 80 times higher than 0.013 mSv? Yasuto Sasaki, a member of the ICRP, and others cited that society would tolerate 1 in 10,000 excessive deaths as one of the grounds for ICRP recommendations. But there is deception here. The excess mortality risk mentioned by Dr. Sasaki and his colleagues is a risk generated around the age of 20 by 1 mSv of single exposure. Public exposure from the environment is lifelong, but a single exposure reverses the argument." he said*.
*"Consider the safety of radiation" Iwami Okujyo 2018.6 .1 Citizens’ Nuclear Information Center Information No. 528 http://sanriku.my.coocan.jp/180601anzenn.pdf
In light of the above
The following comments are given on "ICRP 109 & 111 Revision" Table 6.1 on page 55.
1) In Table 6.1, there is a reference level for public. However, for the public, a reference level should be established for the most radiosensitive population belonging to the population. It is important to protect groups such as children and pregnant women, who are most vulnerable to the effects of radiation exposure, that the standards for controlling exposure of the public are established. Are children and pregnant women eligible for this reference level for adults? Is there any plan to recommend a Reference level for children and pregnant women?
2) In Table 6.1, "The long-term goal is to reduce exposures to the order of 1 mSv per year" is included in the Public Existing exposure situation. In particular, the lifetime risk to health should be clearly indicated to the public when the public is exposed to an excessive dose of 1 mSv per year.
Reference levels for optimization of the protection of people are listed in Table 6.1.
In addition to 1 mSv, numerical values of 10 mSv, 20 mSv, and 100 mSv are also mentioned. The relationship between these numerical values and lifetime risks such as disease and death should also be shown to the public.
3)In the American Academy of Sciences BEIRVII report in June, 2005, the large-scale epidemiological study results are summarized. This result may not be reflected in Table 6.1. Based on these results, the figures in Table 6.1 should be reviewed. Isn't it necessary to review them based on new knowledge?
4)From the excess cancer mortality lifetime risk of 1 in 10,000 calculated by BEIRVII and the Japan Society for Occupational Health, "in the case of chronic repeated exposure, the most sensitive 0 year old woman to avoid a lifetime excess cancer mortality risk of 10 -4, the 1 year external exposure should be less than 0.013 mSv” , the annual dose of 1 mSv should be reviewed in consideration of lifetime risk.