1. lines 519-521 emphasise the generality of the risk coefficients which are therefore averaged for both sexes and state also that "these risk coefficients are not intended for use in estimating risk to specific individuals". But it should be acknweledged that in the daily real life, these risk coefficients are used for estimating dose, and therefore risk, to specific individuals. Consequently, the process of averaging risk coefficients of both sexes and implementing them to real individuals, which are men or women (but not both), is very much unclear and leads to a lot of discredit among workers.
2. lines 674-675 state that there are "greater nominal riek coefficients and detriment for females by a few tens of percent", but recommends to use the same dose reference values (like dose limit) to males and females (except during pregnancy or breasfeeding periods) because of the uncertainty of the risk coeffeicints. But the uncertainties in the risk coefficients are completely arbitrary, while the risk coefficients to females are for most cases, higher than males. Once again, it is not clear for many female workers why these differences in risk are not supported by different dose limitations.
3. lines 1119-1126 state that there is no dependency of skin cancer risk on the place of skin irradiation and therefore relate the risk of skin cancer to the average doses to the total area of the skin. But there are a lot of indications that the cancer from irradiation by solar radiation, for example, is mostly diagnosed in skin areas that were mostly irradiated by the sun (like scalp, neck, palm, etc.)