COMMENTS OF THE “SPANISH RADIATION PROTECTION SOCIETY” TO THE DRAFT ICRP RECOMMENDATIONS (ICRP 05) (November 2004) (PART 3) 11. Subject- Exclusion and authorization of exposures (Main Text) ICRP.- In both paragraph (25) and in paragraph (26) the term “authorization” is used in a sense that might collide unnecessarily with regulations already implemented in certain countries. Comment.- It is proposed that the word “authorization” be replaced with the word control in both cases, as well as in the title of section 2.3, such that the concept of authorization be understood as being just one specific type of control. 12. Subject.- Quantities used in radiological protection (Main text). The induction of cancer and hereditary effects (Main text). ICRP.- In general, the wording of point 3 of the text (especially points 3.3 and 3.4), and of point 4.2, would appear to contain excessive detail, and their contents certainly clash with the rest of the document as regards the level of detail. Comment.- It is recommended that only the essence of the current content be maintained in the main text and that the rest of the more detailed information be included in an Annex. 13. Subject. Dose constraint values on the basis of natural background (Main text) ICRP.- The maximum values proposed by ICRP for “dose constraints” are established taking the natural radioactive background value as a reference, excluding the contribution made by radon. Comment.- This approach is highly arguable in the realm of occupational exposure and modifies previous ICRP approaches (publications 26 and 60), in which the values proposed as limits were always based on considerations of risk (for example comparing the occupational risk of work with radiations with that of other industries). The new ICRP approach might not be understood by society in general and might also give the impression of a certain arbitrariness. Furthermore, the wording of paragraphs 160 and 161 is fairly confusing and might give rise to errors in interpretation. 14. Subject.- The exposure of women (Main Text) ICRP.- Paragraph 175 indicates as follows: “The Commission considers that this policy will be adequately applied if the mother is exposed, prior to her declaration of pregnancy, under the system of protection recommended by the Commission. Comment .- The policy of the Commission is established in the interests of protection, and the previous recommendations had already eliminated limitation of exposure to the abdomen of women, considering that the basis used for the control of occupational exposure is the same as for men, except in the case of pregnancy. In view of the above, it is proposed that the aforementioned text be revised as follows: “The Commission considers that this policy will be adequately applied if the mother is protected, prior to her declaration of pregnancy, under the system of protection recommended by the Commission for occupational exposures”. 15. Subject.- Concept of “radiation worker” (Main text) ICRP.- Paragraph 169 introduces the concept of the “radiation worker” (which was not contemplated in previous recommendations), establishing an apparent link between those considered as being exposed workers and access to the controlled zones. Comment.- Neither the ICRP recommendations nor the international standards had established to date that a worker should be classified as a “radiation worker” merely on the basis of access to the controlled zone. Such classification has always been based on the possibility of the occupational doses received by the worker exceeding a given fraction of the annual dose limit. It is habitual practice in many countries that members of the public may access the controlled zone as long as the conditions of access ensure that the doses received by such members of the public remain far below the dose limits applicable to them. There would be an important (and negative) impact in these countries if, as a result of the new recommendations, any person accessing the controlled zone had to be classified as an exposed worker. 16. Subject.- Dose limit for the skin (Summary and main text) ICRP.- The new recommendations indicate that the dose limits established in ICRP-60 continue to be valid. Comment.- The dose limit for the skin established in ICRP-60 (500 mSv averaged over a surface area of 1 cm2) was based on a study performed by the US Nuclear Regulatory Commission, which demonstrated that the initial approach adopted in the first draft of these recommendations (500 mSv averaged over 100 cm2) did not prevent the appearance of deterministic effects in the event of contamination by “hot particles”. In 2002, the US Nuclear Regulatory Commission reconsidered its previous position, establishing that the dose limit for the skin be averaged over 10 cm2, due to its considering that the average over 1 cm2 was unnecessarily restrictive. It is considered that the ICRP should adopt a similar approach. 17. Subject.- Optimization of protection (Summary) The characteristics of the optimization process (Main text). ICRP.- Optimization is maintained as one of the principles of the protection system complementing dose restrictions. Comment.- There is an obvious need to clarify the meaning of the principle of optimization and the way it is applied. It would be appropriate for the text of this point to provide explanatory and clarifying information, distinguishing the application of this principle in the various situations of exposure: - Normal vs. emergency or post-accident - Workers vs. public - Planning of activities vs. performance of activities Likewise, it is considered necessary that the definition, consideration and application of the “dose matrix” be clarified and specified in the processes of optimization. 18. Subject.- Limits on effective dose for public exposure (Main Text) ICRP.- These are included in paragraph (185), the values established in the previous recommendations being maintained. Comment.- From a practical point of view, both the actual significance of the public dose limit and the feasibility of its being controlled continue to be controversial. Following the summary included in paragraph 192 of publication 60, it would be advisable to clarify the real meaning of this limit, explaining the low degree of practical significance that it has and the advisability of not overvaluing such significance, placing the emphasis (in this case in a special manner) non the restrictions associated with individual sources. 19. Subject.- Medical Exposures (Main Text) ICRP.- Paragraph 215 begins by indicating that “The physicians involved in the processes that irradiate patients should always be trained in the principles of radiological protection” Comment.- The process of irradiating patients includes the intervention not only of the doctor required for diagnosis or therapeutical treatment, but also of other professionals who participate in the protocols and activities required for delivery of the dose, this implying a risk of exposure to ionizing radiations, as well as the implications of their role in protecting the patient. Consequently, it is proposed that this paragraph be revised, its wording possible beginning as follows: “The physicians as well as the other professionals involved in the processes that irradiate patients should always be trained in the principles of radiological protection”. Consideration should be given also to the fact that these professionals may play a relevant role in the optimization processes. 20. Subject.- Annex B (B-.1) Introduction. ICRP.- Paragraph B2 refers to the establishment of “constraints” relating to the “quantities of radionuclides deliberately introduced into the environment”. Comment.- It should be taken into account that in the definitive management of radioactive wastes such introductions are sometimes performed deliberately and to values of activity far in excess of any imaginable “constraint”. It is suggested that the text be revised in order to avoid direct contradictions with radioactive waste management activities.