I am a member of the German Commission on Radiological Protection, SSK.
I highly appreciate the efforts of the Commission to reduce communication difficulties and confusion that arise from effective dose and equivalent dose having the same units. However, the discontinuation of equivalent dose is a major alteration in the system of protection and no recent references have been provided to support this decision.
In line 440 of the draft, it is said: …” the available data indicate that differences between radiation types (e.g. alpha particles and neutrons relative to gamma rays) in their effectiveness per Gy in causing tissue reactions are smaller than differences in their effectiveness in relation to cancer induction (ICRP, 1990, 2003b).” More and more recent references would help here. Apart from radiation protection, this topic is also of relevance considering tissue effects after radiotherapy with charged particles.