General Comments on behalf of the NEA Committee on Radiological Protection and Public Health
This is an excellent document. The draft provided references and explanations on the effective dose and other units and provides an interesting and rich source of information.
The draft is clear, and it is remembered in some parts of this draft document, that the effective dose cannot be used in place of a proper and specific risk assessment approach based on estimates of organ/tissue doses, effectiveness of different radiation types, and age-, sex- and population-specific risk factors.
We can agree that effective dose is of practical value for comparing doses, for example from different diagnostic examinations, provided that the representative patients or patient populations for which the effective doses are derived are similar with regard to age and sex.
At the same time a better clarification on the intended use of the protection quantities is needed. It seems a good proposal to consider no more the equivalent dose (Sv) as a protection quantity, but to use absorbed dose (Gy), instead of equivalent dose, for the limits to avoid the tissue reactions.
This draft document could be also taken the opportunity, in relation to the concept of “detriment”, to introduce also (e.g. in the paragraph 2.2, or within the Glossary at the voice Detriment, or in any other more general part of the document) what already expressed in general in ICRP 118 regarding detriment: “(a) The Commission issued revised recommendations for a system of radiological protection in Publication 103 (ICRP, 2007). This included consideration of the detriment arising from non-cancer effects of radiation on health.”
In particular, the CRPPH agrees with the following statement “the Commission considers that the use of equivalent dose to set limits on tissue doses to prevent tissue reactions should be discontinued.”
From an editorial viewpoint, in general, several terms should be defined in footnote in Tables and Figures.
In addition to these general comments, the CRPPH, through nominated experts, has thoroughly reviewed the ICRP Draft “The Use of Effective Dose as a Radiological Protection Quantity” providing specific comments to the document which have been sent to the ICRP in a pdf file. Such file is available upon request.