Dear Commission
Here is my Comment to ICRP draft. I would be glad if you take this in mind.
1. Applying reference levels in recovery process is not suitable. Dose limit of 1mSv per year to public should be strictly observed because it has been already stipulated in many nations, and became established. The Commission often states in the draft the words “exposures in the order of 1mSv per year”. These should be rewritten to “1mSv per year”.
2. Japanese Government perverts reference levels in the 2007 Recommendations, and has been ignoring the dose limit of 1mSv for more than 8years, applying 20mSv per year as the guideline for releasing evacuation order. Thus, for 8years, more than a million people in Fukushima Prefecture live in or near the contaminated areas where dose exceeds 1mSv per year, not banned from haunting, without any warning. National and local government thus pervert reference levels to free them from obligations to protect people from radiation exposures. So, dose limits should be applied for radiation regulations and in protection practice.
3. The critical problem when applying reference levels is that an applicable period for them is not recommended. Then, total dose exposure to people could not be limited legally or practically. The Commission recommends reference level of 10mSv per year in the draft. This is not sufficient to restrict total dose of individuals. Remembering the description in the 80th paragraph of the draft, the Commission should also recommend, for example, time limit of 1year for 10mSv/year, or 6 months 20mSv/year.
4. I am afraid that the Commission dose not recognize several serious harmful effects on health.
Children thyroid cancer cases in Fukushima Prefecture exceed 230 after the accident. The incident rate is 10 time more than before the accident. Moreover, many thyroid cancers have developed among the adult evacuees. The comment in the B42th paragraph of the annex B to the draft, “Children thyroid cancer cases found in Fukushima Prefecture are unlikely to be the result of radiation exposure after the accident” is wrong. The epidemiological articles by Prof.Tuda, etc, and the ones by Doc.Yamamoto, etc show that co-relationship between the incidence of thyroid cancer and the dose rate in the areas.
Furthermore, the epidemiological article by Prof.Scherb, Doc.Hayashi, Doc.Mori shows that perinatal mortality after the Fukushima accident has increased in Fukushima Prefecture and the ones nearby, which include areas with relatively low dose rates.
So wide and periodic hearth examination should be implemented, not only for thyroid check, or not only for children.
5. The Commission emphasizes so-called co-expertise. This will mislead radiation protection for people. I hope that Commission revoke recommendations concerning co-expertise in the draft.
The First reason for this is that co-expertise implemented in Japan is perverted as means to exempt authorities from obligations to protect people from radiation. In Fukushima Prefecture evacuation cancel order has been implemented in the areas ¡ã 20mSv per year, and no supports are given by authority to those who hope to evacuate from the areas where annual dose exceeds 1mSv. So many people who cannot evacuate are left behind. In co-expertise dialogues any support for evacuation is not put on the agenda, but economic issues is emphasized and self-protection is recommended and safety is persisted. As national and local government are now propelling such co-expertise, people’s hopes for evacuation and wide health examination are refused. “Dialogues among authority and experts and residents”, organized by authorities or economic/social influential persons in the area, often oppress people’s mind in deep and cause distrust against authorities of nation and prefecture.
The second reason is that self-protection is often perverted in Fukushima. In Date City case, without sufficient explanation and agreement, dosimeters were given to residents and individual dose data were collected and published in an inadequate manner. Commission should recognize this case.
The third reason is that co-expertise dose not include the evacuees.
Sincerely
Kiyoshi Koyama, Osaka, Japan