1. General The reading of the draft is only beneficial for a person who is a seasoned warrior in reading ICRP recommendations or who has a tutors (as one of us (MT) had in the late Dan Beninson).Otherwise there is a good chance to resign before one has all the jam. This because is not distinguished whether a paragraph is: * New conceptional issues * Background material * Supplementary material * Regulative * Explanatory * Essentially taken from ICRP 60 For this reason, the reader, in particular users as administrators might going lost as they can not easily see the nature and hence the importance of a sentence or a paragraph. A restructuring as shown above will improve acceptance of future developments. Let us remind the development of ICRP 60. In the final version there are two parts: a general part (also published as user edition) containing the essence of the document (some 75 pages) and extended annexes (some 125 pages) explaining details and background of the recommendations. This structuring was made later because during consultation readers of the first draft, which was consisting of one very long text without structure, made many comments stating that the original draft is too difficult to read and to understand in the present form. The present draft of ICRP 2005 has the same shortage as it is difficult to read and fundamental major issues and regulations are mixed with lengthy detailed explanations. For that reason, the text shall be restructured into a main part (less than 40 % of the total) and explanatory material. For example, let us consider 3.4.: Radiation weighting factors. The main part should include para (59), where in the first sentence a statement “to be applied for stochastic effects only” has to be introduced. In addition, para (79) with the table of wR should be included. All other material is to be moved to an annex. In addition, some terms not defined are used. A glossary might be extremely helpful. 2. Content The proposed new paragraphs as definitions and thoughts issues are a progress in terms of better understanding and from a conceptional point of view. However, two issues may eventually interfering acceptance and eventually practical application: a) see 1. above, b) administrators, who are by definition not in the frontier of development, will at present not see sufficient reasons to set in force which large effort something new, where they are still tired after implementation of ICRP 60 and not seeing a clear benefit of changes. For example, as it is not clear how the Commission can view a source-related system the most effective radiation protection tool (165), some hints that the system lead to an actual improvement in protection seems necessary. 3. Selected comments in detail (7) The Commission in the past has provided the single most influential input with respect to radiation protection on a sound scientific basis for national legislation. Without specific guidance for national authorities on numerical values of the dose constraints, these values may vary significantly between countries, rendering all past efforts for harmonization of radiation protection legislation invalid. A proposal for default values might help in introducing the concept. (14) Radiation quality is a term used in metrology for practical reasons to refer to certain exposure conditions for photons only in order to avoid the description of the spectrum. Here the term is misused and should be replaced by properties of radiation The introduction of Radiation weighted dose might avoids some existing confusion between the terms “dose equivalent” and “equivalent dose”, especially also in their translation. The change is appreciated for clarification. Any changes in radiation and tissue weighting factors, based on sound scientific evaluations, are certainly an improvement to the current system. A general system for the protection of non-human species is valuable; the methods proposed appear scientifically valid. 4. Conclusions The progress is appreciated in general, but a thorough restructuring in three parts is necessary: a) clear highlighting and presentation of new concepts and reasons to justify their implementation ? JUSTIFICATION of ICRP 2005 in general b) express reasons what parts of ICRP 60 remain still valid and what parts not c) discrimination between material of different nature in the draft (between new terms, definitions, explanations, see 1. above, etc) ?OPTIMIZATON OF PRESENTATION of the recommendations Manfred Tschurlovits (Vice-President), Alexander Brandl (Secretary), Franz Josef Maringer (President) Austrian Radiation Protection Association OEVS Vienna, Austria