Occupational Radiation Protection (DS453)
COMMENTS FROM THE MEMBER STATES ON THE DRAFT SAFETY GUIDE DS453 OCCUPATIONAL RADIATION PROTECTION
Table of Resolution
COMMENTS BY REVIEWER
Reviewer : NRA(RASSC,WASSCCountry/Organization: JAPAN
Comment
Para/Line No.
No.
1Section5
General2

5.6/(2)

3

4

RESOLUTION
Page 1 of 3

Date:13/6/2014
Proposed new text

ReasonAccepted

Accepted, but
modified asfollows

Rejected

Reason formodification/rejection

Present contents in this section had
been improved due to removal of
the texts regarding remediation
itself. However some texts, forexample such as in Remediation
Programme are deemed not directly
relevant to occupational exposure.
The contents regarding remediation
itself should be carefully deleted.
Some examples should be added tothe text, such as policeman, firefighter.

To streamline the contents forclarification.

R

Remediation
Programmes are relevant
to occupational
exposure. Less relevant
paragraphs (around 20)
were already removed
from the document.

Clarification.

R

Sub-subsection“Reference levels”(p.67)

Sub-subsection “Reference level”
should be changed to “Reference
level in the exposure due to radon”.

R

5.21

Reference levels are generally
expressed in terms of annual
effective dose to the representative
person in the range 1–20 mSv.
However, reference levels for
exposure to radon are expressed interms of annual average radon

Clarification.
According to para. 5.26-31 of
BSS, in occupational
exposure, only in the case of
exposure due to radon, areference level is necessary.
The dose range 1-20 mSv isthe band of reference level forthe public.

It applies to much moregeneral workplacesituations, not justpolicemen and firefighters.
Reference level applies
generally, not just to
Radon.

1/193

R

This sentence comesstraight out of BSS:
paragraph 5.8.
Also see para.5.25 of the
BSS.

Occupational Radiation Protection (DS453)
concentration in air.

COMMENTS BY REVIEWER
Reviewer:Country/Organization: JAPAN/NRA(RASSC,WASSC)
Comment
Para/Line No.
Proposed new text
No.
5

Subsection“EXPOSURE
ARISING FROMREMEDIAL
ACTIONS IN
AREAS
CONTAMINATED
WITH RESIDUAL
RADIOACTIVE
MATERIAL”(p.67)

6

5.60/3-4

RESOLUTION
Page 2 of 3
Date:13/6/2014

Add a new paragraph to theposition just after the title“EXPOSURE
ARISINGFROMREMEDIAL
ACTIONSIN
AREAS
CONTAMINATED
WITHRESIDUAL RADIOACTIVE
MATERIAL” as follows.
“A relevant Safety Guide [32]addresses several aspects ofremediation mentioned below,
such as regulatory
framework, planning ofremediation including
justification and optimizationof remedial measures, andoperational aspects ofremediation.”
the reference level for
workplaces should not exceed
an annual average radon
concentration of 3001000
Bq/m3 [2]. This value
corresponds to an annual
effective dose of the order of

ReasonRejected

Reason formodification/rejection

WS-G-3.1 is cited only inparagraph 5.25 and 5.28.
Since WS-G-3.1 addresses
overall aspect ofremediation, some
explanation should be added
to the beginning of thesubsection.

R

The current text
adequately addresses
the concern from thiscomment

Editorial error.
Consistency with BSS
5.20(a).

R

These levels from thecurrent text areconsistent with the
BSS

2/193

Accepted

Accepted, but
modified asfollowsOccupational Radiation Protection (DS453)
10 mSv, assuming anequilibrium factor of 0.4 andan annual occupancy periodof 70002000 h.
COMMENTS BY REVIEWER
Reviewer:Country/Organization: JAPAN/NRA(RASSC,WASSC)
CommenPara/Line No.
Proposed new textt No.
7

5.83(a),(b)RESOLUTION
Page 3 of 3
Date:13/6/2014
Reason(a) The relevant authority
should establish a frameworkthat includes an appropriate
reference level — a reference
level of about 5 mSv might beconsidered as reasonable —and a methodology forassessing doses and keeping
records of occupational
exposure to cosmic radiation.
(b) Where the dose of aircrew
members is likely to exceed
the reference level, The
employers of aircrew needs toassess the doses, keep records
and make each worker’s doserecord available to that
individual.

Consistency with BSS 5.31
and 5.32.

3/193

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

R

5.83 needs to beconsidered together
with 5.84. Together it
is consistent with the
BSS, but it is giving
more explanation andrealistic guidanceOccupational Radiation Protection (DS453)
87.110/1-2

In terms of para. 3.73(c) of
the BSS [2], the regulatory
body is responsible for theauthorization or approval ofservice providers forindividual monitoring andcalibration services.

Consistency
3.73(c).

COMMENTS BY REVIEWER
Reviewer: Nik Mohd Faiz bin Khairuddin, Atomic Energy Licensing Board
Page 1 of 1
Country/Organization: MALAYSIA
Date: 12/06/2014
Comment
Para/Line
Proposed new text
No.
No.

with

BSS

“the regulatory bodyis responsible for theauthorizationorapproval of service
providersforindividual monitoring
and for calibration
services.”A

RESOLUTION

ReasonAcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

1.

Whole draft-

The draft to much wordy
and a lot of cross reference
need to look at.

R

Not
a
comment

2.

Table 3
[Page 60]

Dose Criterion for ADFoetus is 1Gy

Dose criteria for ADFoetus
may change to 1Gy and not
0.1 GyR

Current
value isconsistent with BSS

3.

Para 4.6(d)[Page 57]-

Does the word “workers”
includeemergency
workers?

4/193

specific

This includes all
types of workers as
defined in the SafetyOccupational Radiation Protection (DS453)
Glossary

COMMENTS BY REVIEWER
Reviewer:
G. Balčytis - Radiation protection centre
Page.29 of 262.
Country/Organization: LITHUANIA
Date: 03 June 3, 2014
Comment
Para/Line
Proposed new text
Reason
No.
No.
1

3.27

Delete the words ,,set separately for The sentence in para 3.27
each source under control and” in para ,,Dose constraints are set
3.27.
separately for each source
under control…” is toostrict and contradicts withstatement in para 3.29:,,The objective of a dose
constraint is to place aceiling on values ofindividual dose — from a

5/193

RESOLUTION

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejectionR

It does not seem tocontradict
This will be fixed inanyway during the
IAEA
editorial
process.

Occupational Radiation Protection (DS453)
source, a set of sources in
an installation, a practice, atask or a group of
operations in a specific
type of industry — thatcouldbeconsidered
acceptable in the processof
optimizationofprotection
for
those
sources,practicesortasks.”

Draft Safety Guide DS453 “Occupational Radiation Protection” (Version 3.3 dated 10 February 2014)
Status: STEP 8  Submission to the Member States for comments
Note: Blue parts are those to be added in the text. Red parts are those to be deleted in the text.
COMMENTS BY REVIEWER
RESOLUTION
Reviewer: Federal Ministry for the Environment, Nature Conservation, Building andNuclear Safety (BMUB) (with comments of GRS)
Page 1 of 13
Country/Organization: GERMANY
Date: 2014-06-10
Rele- Commen Para/Lin
Proposed new text
ReasonAccepted
Accepted, but
Rejecte
vance
t No.
e No.
modified as follows
d
3

1

1.6

“This safety guide updates theguidance given in five previous safety
guides: … and The Management
System for Technical Services in
Radiation Safety (IAEA Safety
Standards Series No. GS-G-3.2),

Please use uniform citationof publications issued in the
IAEA Safety Standards
Series.

6/193

A

Reason formodification/rejectionOccupational Radiation Protection (DS453)
3

2

2.47

3

3

2.51

2

4

2.66

3

5

2.67

3

6

2.68

3

7

2.70

which are hereby superseded.”“… conversion coefficients forconverting from the basic physicalquantity kerma to the directional dose
equivalent H'(3, Ω).”last sentence:“For occupational exposure ofapprentices and students between theages of 16 and 18 years,  is the timeto the age of 70 years.”
In practice, the progeny will rarely, if
ever, be in equilibrium, and the PAEC
will therefore be some fraction of theequilibrium value. This fraction iscalled the equilibrium factor, F :F=PAEC/PAEC (equilibrium)
Equation (11):
PAEC  (0.558 0.588  10-9  75) …
PAEC  2.37 2.40  10-7 J/m3
Equation (13):F  2.37 2.40  10-7 / 5.56  10-7
F  0.426 0.432
The choice between potential alphaenergy exposure and equilibrium
equivalent exposure is not important,since these two quantities are simply
related by a constant factor of 5.56
× 10-9 J•h•m-

Editorial correction. Anystatement of the directionaldose equivalent H' should
include a specification of thereference depth d and the
direction Ω of the radiation(see Para 2.45).
Editorial (missing word).

A

Inclusion of the formula forthe equilibrium factor F forclarification. This was
already accepted during thereview by committees(Draft Version 3.2), but notincluded in the current draft.
Typing error. According toTable 1, the potential alphaenergy per unit activity is
0.588  10-9 J/Bq for 218 Po.
Consequential error resulting
from Equation (11) in Para
2.67.
The value of the exponent
should be in the same line asits mathematical sign. If
possible, place the value andthe unit in the same line.

A

7/193

A

The editors candecide if this is
redundant or not

A

A

A

See answer tocomment 4
SwedenOccupational Radiation Protection (DS453)
3 per Bq•h•m-3
When adopting this approach, anappropriate value for the equilibrium
factor F has to be assumed. The use ofa default value of 0.4 is usuallyadequate for this purpose indoor Radonin dwellings and similar workplaces.

2

8

2.71

2

9

3.10

“Optimization of protection and safety
needs to be considered at all stages ofin the lifetime of equipment andinstallations facilities, as well as for theentire duration of activities, in relation
to both exposures from normal
operations and potential exposures. Fora facility, these stages usually include
design, construction, commissioning,
operation and decommissioning (orclosure). Consequently, all of them As
a consequence, all situations  fromdesign, through operation todecommissioning and waste
management  should be considered in
the optimization procedure.”

3

10

3.53

1st sentence:“The prior radiological evaluation
should describe, as precisely asnecessary, the situation involving

The F factor strongly
depends on the room size
and also humidity of the air.
This was already accepted
during the review bycommittees (Draft Version3.2), but not included in thecurrent draft.
According to the IAEA
Safety Glossary (2007
Edition), the term ‘facilities’is more comprehensive andincludes ‘installations’. The
term ‘activities’ includes‘radioactive waste
management’ (i.e. alladministrative andoperational activities
involved in the handling,
pretreatment, treatment,
conditioning, transport,
storage and disposal ofradioactive waste). With
respect to facilities andinstallations, it is moreaccurate to refer to stages in
the lifetime rather than tosituations.
To be in line with the title of
the related subsection as
well as with the wordingused in Paras 3.52 and

8/193

R

Current text is
consistent with
BSS
requirements on
occupational
exposure

This will beconsideredduring theeditorial process.

AOccupational Radiation Protection (DS453)
311

3.59 (g)

3

12

3.92

3

13

3.128

1

14

3.161

occupational exposures.”“The provision of personal protective
equipment, if applicable (see paras 3.92
and 9.529.609.63);”
last sentence:“Further details on the use of personal
protective equipment are given in paras
9.529.609.63.”
4th sentence:“… for N monitoring periods per year,
the recording level RLj (in becquerels)
for intake of radionuclide j in a given
monitoring period …”“As a result of the criteria in paras
3.158 and 3.160, the following
industrial activities are, or may be,
subject to the requirements for planned
exposure situations [22]:…
(10) Production of tin, copper,
aluminium, zinc, lead, and iron andsteel;(11) Production of cement(maintenance of clinker ovens);(1112) Combustion of coal;(1213) Water treatment.;(14) Geothermal energy production.”

3.543.56.
Use of personal protective
equipment is dealt with inParas 9.529.63.
Use of personal protective
equipment is dealt with inParas 9.529.63.
Completeness andconsistency with thedefinitions of
1. the investigation level ILj
for intake of radionuclide
j provided in Para 3.124
and2. the critical value Mc j forintake of radionuclide jprovided in Para 7.198.
A number of industries that
require mining or processingof highly mineralised waters(like coal mining or geothermal energy production) aredealing with residues withactivity concentrations far
above 1 Bq/g.
Annex VI of the newEuropean BSS (Council
Directive
2013/59/EURATOM of 5
December 2013) identifies
another two industrial
activities involving NORM,

9/193

A

A

A

R, butsome
modific
ationsproposed

The 2 additional
industrial
activities are notincluded becauseof lack ofpublished
exposure data,
but some text is
added reflecting
this:“As a result of
the criteria inparas 3.158 and3.160, and taking

Occupational Radiation Protection (DS453)
namely geothermal energy
production and cement
production. With regard to
the new items (11) and(14), reference to theCouncil Directive is strongly
recommended.

into accountcurrent publishedmeasurements ofoccupational
exposure, thefollowingindustrial
activities are, or
may be, subject
to therequirements forplanned exposure
situations [22]: “Usage of geothermal energy
requires drilling boreholes
and inserting pipes forpumping high-temperature
fluids from the rock ground.
The rocks may also containminerals which tend to forma scale inside the pipes andproduction equipment. In
the presence ofradionuclides such as
radium, the mineral scale,production sludges andwaste water will contain
NORM. The primaryradionuclides produced withthe geothermal fluids are
Ra-226 and Ra-228.
3

15

4.3

2

16

4.15

last sentence:“Protection of workers who are
accidently exposed … should be in linewith BSS [2] and in GSR Part 7 [28].”
Table 2: Guidance values for restricting
exposure of emergency workers

Editorial.

The content of Table I.1 of
GSR part 7 was changed

10/193AA

The final table
will be availableOccupational Radiation Protection (DS453)
for Rev. 6.0 (16. April2014). Please change thistable accordingly.

2

17

4.22

“Female workers who are aware thatthey are pregnant or breast-feeding
should, in order to provide adequate
protection for the embryo or foetus,
notify the appropriate authority andshould be excluded from emergency
tasks listed in Table 2, in order toensure that the embryo, foetus ornewborn child and or the infant are isafforded the same broad level ofprotection as is required for membersof the public (para 3.114 of the BSS
and para I.4 of the GSR Part 7).”

2

18

5.42

2nd sentence:“This includes responsibility forprotection and safety during thetransport, processing, storage,
predisposal waste management anddisposal of the radioactive waste
arising from the remediation.”

Clarification in order toAimprove the readability andcomprehensibility of thewhole sentence. The originalstatement is difficult tounderstand because thesecond clause “and or the
infant are afforded the levelof protection …” does notreally fit to the first clause.
For Rev. 6.0 of DS 457, in
I.4 a limit of 50 mSv for thefull period of in utero
development of the embryoand fetus was introduced.
According to the IAEA
A
Safety Glossary (2007
Edition), the term
‘predisposal management’
includes any waste
management steps carriedout prior to disposal, suchas processing (i.e.
pretreatment, treatment andconditioning), storage and11/193in GSR part 7
and will bechangedaccordingly.
This will beconsideredduring theeditorial process.

Occupational Radiation Protection (DS453)
2

19

5.49

2

20

6.91 (a)3

21

7.10 (a)

2

22

7.21

Indoor radon concentrations in private
dwellings differ between countries because of differences in geology,
climate, construction materials,
construction techniques, type ofventilation provided (natural or otherwise) and domestic habits. Within
individual countries, there may bemarked regional variations. Data on
indoor radon concentrations around theworld are given in Ref. [34]. The
arithmetic mean values for various
countries vary from 7 to 200 Bq/m 3 .
Arithmetic mean values in highbackground areas vary from 112 to2745 Bq/m3 . In some parts of northern
Europe, maximum values of up to
84 000 Bq/m3 have been reported. The
population weighted worldwide
arithmetic mean is 39 Bq/m3 .
1st sentence:“Sometimes, when itinerant workers
perform maintenance services, changes
are made to the default settings of thesystem (e.g. fluoro modes in which the
X ray beam is pulsed rapidly on/off).”“… in comparison with Table A.41 in
ICRP Publication 74 [8]);”
Delete: ”on the wrist, or”

transport activities.
Clarification that data forprivate dwellings are used.
For Bavarian water
treatment facilities, indoor
radon concentrations
exceeding some 100.000
Bq/m³ had been reported.
This was already accepted
during the review bycommittees (Draft Version3.2), but not included in thecurrent draft.

R

Explain the meaning of‘fluoro modes’ as somereaders may not be familiar
with the imaging modes ofdigital X ray fluoroscopy.
Editorial (missing parenthesis).
The correction factors for
dosimeters on the wrist arevery high forinhomogeneous fields. The

12/193A

A
A

Rejected to beconsistent withUNSCEARdocument(reference 33)(e.g. fluoro
modes in which
the X ray beam ispulsed)Occupational Radiation Protection (DS453)

3

23

7.105

3

24

7.182

2

25

7.198

3

26

7.210

2nd sentence:“More frequent periodic checks(routine testing  see paras
7.887.897.92) …”last sentence:“The individual relative bias statistic B ri
for the ith measurement in a category(series) with respect to the correct
value of the measurand is defined as:… where Ai is the value of the ithmeasurement in the series being
tested.”2nd and 3rd sentence:“… where e(g) j is the dose coefficientfor ingestion or inhalation ofradionuclide j, as appropriate (insieverts per becquerel), and m(t0 ) j is
the fraction of the intake remaining in
the body or in the excretion sample
after an elapsed time period t0 between
the intake and the time of sampling.
The intake is usually assumed to occur
at the mid-point of the sampling period,in which case Eq. (21) applies for t0 .”last sentence:“Biokinetic mModels for these routes

factor and the associateduncertainties are often notconsidered. This was
already accepted during thereview by committees(Draft Version 3.2), but notincluded in the current draft.
Routine testing of personal
dosimetry systems is dealt
with in Paras 7.897.92.

A

Clarification andconsistency with theterminology used in Para
7.183.

A

Correct description of allparameters in Equation (33).
Compare with Para 3.130.

A

Adjust wording to be more
specific with regard to theA

13/193

Occupational Radiation Protection (DS453)

3

27

7.214

3

28

7.223

3

29

7.228

of exposure are described in Appendix
IV.”kind of models.

1st sentence:“… reference models (i.e. … and ageometric standard deviation (GSD) of
2.5) [131]).”
2nd sentence:“Examples of analyses performed after
the administration of the chelating
agent Ca-DTPA (Calcium salt of
diethylene triamine pentaacetic acid) incases of accidental intakes of actinides…”

Editorial (superfluous parenthesis).

The abbreviation Ca-DTPA
is introduced in Para 7.223
for the first time, but is explained afterwards in Para
10.34. Move the explanation
to this place.

A

1st sentence:“High levels of exposure of accidentally
exposed workers may be associatedwith nuclear or radiologicalemergencies such as a nuclear
emergency at a nuclear power plant, acriticality accident at a nuclear fuelcycle facility, an accident at anindustrial irradiation facility, or aradiological emergency involving a lostor stolen source.”

Reference to a typical caseshould be provided. Within
the last 40 years, mostcriticality accidents
occurred during process
operations with fissile
material in solutions or
slurries at nuclear fuel cycle
facilities. Details areprovided in the following
publication:
Los Alamos National
Laboratory, A Review ofA

14/193A“Examples ofanalyses
performed after
the administrationof the chelating
agent Ca-DTPA(calcium salt of
diethylene
triamine
pentaacetic acid)in cases ofaccidental intakesof actinides …”
Accepted to add
the reference, butthere is no needto add the
additional text

Occupational Radiation Protection (DS453)

2

30

8.4

3

31

8.10 (e)132

8.24 (h)“The management system of a service
provider using radiation should be inaccordance with all relevant IAEA
safety standards, namely GSR Part 3[2], GS-R-3 [5] and GS-G-3.1 [6].”“Engagement of relevant management;”“Ensuring Establishing andimplementing an integrated
management system that includes
safety, health, quality, environmental,
security, social and economic aspects
as appropriate so that safety is notcompromised.”

Criticality Accidents, 2000
Revision, LA-13638, May
2000.
For completeness, therelevant IAEA safety
standards should bespecified here.

Editorial (remove space).
1.) It is not clear what thephrase “ensuring …
aspects as appropriate”
does mean. Clarification isrequired. It seems that thisitem relates to Para 4.1 of
the Draft Safety
Requirements DS456“Leadership andManagement for Safety”(revision of GS-R-3,
version dated 13 July2013).
2.) Social elements, such ascommunication with the
public and otherinterested parties, should
also be considered in the

15/193R

GS-R-3 is underrevision; “Themanagement
system of aservice provider
using radiation
should be inaccordance withthe relevant IAEA
safety standards”- editorialAA“… safety,
health, quality,
environmental,
security, societal
and economic
aspects asappropriate. “
The whole
document is toenhance safety.
This will beconsideredduring theeditorial process.

Occupational Radiation Protection (DS453)
integrated management
system (compare with
Para 4.1 of DS456).

2

33

9.10

last sentence:“The design philosophy of a ventilation
system for radioactive areas in a
facility or activity sometimes is tocontain and confine radioactive
materials by:a) Maintaining adequate negative
pressure with respect to theatmospheric pressure;b) Directed flow of air from potentiallylower radioactive less contaminatedareas to potentially higher
radioactive more contaminatedareas, i.e. a pressure drop from the“clean areas” (higher pressure) tothe “dirty areas” (lower pressure);c) …”In our opinion, the term‘sometimes’ causes anunintentional weakening of
the statement provided. If
there are other noteworthy
design philosophies of aventilation system forradioactive areas, theyshould be addressed in thisparagraph as well.
Item b):
It seems to be more precise
to refer to the potential
contamination/activity level
as the term ‘radioactive
areas’ usually stands for‘controlled and supervised
areas’.

16/193A

Modified as:“ T he purpose of the
primary ventilation
system in a facility is
to provide fresh air
to the workplaces toremove airborne
contaminants
generated by theoperations. Carefulattention should begiven to the design ofthe ventilation
network, including
the calculation andverification of rates
and velocities of air
flow, to ensure that it
is adequate forcontrolling airborne
contamination. In
many facilities
control of airborne
contamination isachieved by:a) Maintaining
adequate negative
pressure with respect
to the atmosphericpressureb) Providing anadequate orprescribed number of
air changes in theworkplace;c) Providing theappropriate exhaustOccupational Radiation Protection (DS453)
air off gas cleaningsystems (including
scrubbers and/or
HEPA filtration) sothat the discharges
from the facility will
be within authorized
limits. T he dischargeof the exhaust air
should be through astack of appropriate
height to provide thenecessary dilution for
the releases toprotect members of
the public.”

2

34

9.12

Delete the items (a)(g) and modify thewording of this paragraph as follows:“The ventilation officer in a mineshould: have the functions specified inpara 3.176 (a)(g).”

The functions andresponsibilities of aventilation officer in a mine
are already addressed in
Para 3.176, thecorresponding items (a)(g)are nearly identical inwording. Avoid unnecessary
doubling of information.

17/193A

Ok to refer toparagraph 3.176:“The ventilation
officer in a mineshould: have theresponsibilities
specified in para
3.176.”
3.176 changed to:
The ventilation
officer has thefollowing
responsibilities:(b) Ensuring theproper operationof the ventilation
systems(including
auxiliary
ventilation

Occupational Radiation Protection (DS453)
systems which, in
undergroundmines, may beprone to rapid
deterioration),
initiating any
necessarymodifications andensuring that any
deficiencies are
addressed
promptly;(g) Being familiar
with the propertiesof radon and its
progeny, whereapplicable

3

35

9.14

3

36

9.40

3

37

9.66

1st and 2nd sentence:“The proper functioning operation of
the primary and auxiliary ventilation
systems throughout the operatingphase of the facility should be ensured.
The healthiness of the systems should
and, if necessary, be indicated asaudio-visual alarms in the control
room/RPO display panel, so that
prompt action for the protection of theworkers can be initiated.”
3rd sentence:“… special cylindrical form beta
detectors (see para. [9.36]).”
2nd sentence:“Any NORM that cannot be contained
effectively within the process and1.) Modify wording to avoid
a circular phrase(“operation …
throughout the operatingphase”).
2.) The ventilation systems
should trigger alarm
signals only in case of
demand, i.e. for airborne
contamination exceeding
the safe working levels.
Editorial (delete brackets).

For completion.
The paragraphs mentioned
in parentheses provide

18/193A

A

A“Any NORM thatcannot becontainedOccupational Radiation Protection (DS453)

3

38

App. II,
II.32

becomes airborne should be controlled
by means of a good ventilation system
in order to prevent the release of contaminants and to minimize occupational
exposure (see also paras 9.10, 9.13,
9.14 and 9.16).”

further useful guidance withrespect to the ventilation
system for mineralprocessing operations.

“Neutrons with energies below 10 eV
can be detected through interaction
with the nitrogen nuclei of the gelatine
resulting in the production of recoil
protons based on 14 N(n,p)14 C
reactions.”

For completeness.

19/193Aeffectively within
the process andbecomes airborne
should becontrolled bymeans of angood adequate
ventilation
system in orderto remove
prevent therelease of
airborne contaminants and tominimize
occupational
exposure (seealso paras 9.10,
9.13, 9.14 and9.16).”“Neutrons withenergies below
10 eV can bedetected throughinteraction with
the nitrogen
nuclei of thegelatine resulting
in the productionof recoil protons
from 14 N(n,p)14 C
reactions.”Occupational Radiation Protection (DS453)
3

39

App. II,
II.50

3rd sentence:“The operating principles of criticality
dosimeters need to be different thanfrom those for of the routine neutron
dosimeters because …”

Grammar.

3

40

App. III,III.5

2nd sentence:“… intended to measure ambient dose
equivalent H*(10), and often directionaldose equivalent H'(0.07, Ω).”3

41

App. III,
III.6

3

42

App. III,
III.25

3

43

App. III,
III.262

44

App. IV,

2nd sentence:“Installed instruments designed for use
where beta and low energy photon
radiation are not expected often havelarge (of the order of 5 L 5000 cm3 )steel walled chambers filled with argon
at high pressure.”
3rd sentence:“For beta and low energy photon
radiation measurements, thin sensitive
layer silicon diodes are suitable forH'(0.07, Ω) evaluation, …”
1st sentence:“A good beta dose rate monitor forH'(0.07, Ω) can be made using …”
1st sentence:

Editorial correction. Any
Astatement of the directionaldose equivalent H' should
include a specification of thereference depth d and the
direction Ω of the radiation(see Para 2.45).
For direct comparison withA
hand held instruments
designed for use at normal
occupational dose levels, thesame measuring unit as in
the 1st sentence should be
used here.
Editorial correction. TheA
measuring quantity is the
directional dose equivalent.

Editorial correction. The
measuring quantity is the
directional dose equivalent.
1.) The term ‘adsorption’

20/193A

A

A“The operating
principles ofcriticality
dosimeters need
to be different
than from thosefor of routine
neutrondosimeters
because …”

Occupational Radiation Protection (DS453)

2

45

IV.1

“Intakes of radionuclides can occur via
various pathways, viz., namely
inhalation, ingestion, injection anddermal adbsorption (through the intact
skin or a wound).”App. V,
V.24“For intakes of tritiated water, theconcentration of tritium in urine is thesame as in body water and can be used
to assess body content and dose rate
without reference to an excretion
model. Direct dose assessment for
intakes of tritiated water is provided in
Annex VI of Ref. [238].”

needs to be replaced by‘absorption’, in order toprovide a correct
designation of therelevant physicochemical process and tomaintain consistency
with the terminology
used elsewhere in thisdocument (comparewith Paras 7.202, 7.210
and IV.21). Additional
clarification provided inparentheses isrecommended.
2.) Avoid usage of Latin abbreviations, if possible.
With respect to the directdose assessment for intakesof tritiated water, the IAEA
Safety Reports Series No.
37 provides further
guidance. A reference tothis publication is therefore
recommended.

Please include new Ref. [238] in thelist of references:“INTERNATIONAL ATOMIC ENERGY AGENCY, Methods for assessing
occupational radiation doses due to intakes of radionuclides, Safety Reports
Series No. 37, IAEA, Vienna (2004).”

21/193A

Occupational Radiation Protection (DS453)
3

46

App. V,
V.39 (e)Ref. [26]

3

47

2

48

Annex,
A-15

249

Annex,
A-31

5th sentence:“… (more than about 3 mg/m3 m3) …”“… Radiation Protection andManagement of NORM Residues
Management in the Phosphate
Industry, …”“The technique most commonly used
is single colour FISH (sFISH), whichenables the detection of interexchanges, such as dicentrics andtranslocations. In order to assess
induced translocations among different
labelled chromosomes, multi-colour
FISH (mFISH) and, for whole genome
analysis, multiplex FISH (M-FISH)
have been developed. M-FISH is themethod of choice for studying complex
interchromosomal rearrangements. It isa 24-colour technique to identify andevaluate the size, shape, and number ofchromosomes in a sample of bodycells.”

Editorial.

A

Correct title of the IAEA
Safety Reports Series No.
78.

A1.) To avoid ambiguities,
each of the three FISH
techniques mentioned inthis Para should belabeled with the
dedicated acronym
commonly used inscientific publications.
2.) Please include a short
description of M-FISH
for the sake ofcompleteness.

A

Include new last sentence:

Essential amendment inorder to highlight the“… the detection limit is expected to be limitation of low-frequency
in the range 0.51 Gy. In cases where in vivo EPR measurements
the external radiation field has both afor mixed gamma/neutron
gamma and a neutron component (e.g. radiation fields. Further
as a result of a criticality accident), in
details to this issue arevivo EPR spectroscopy of teeth
provided in the following
essentially provides information on the publication:dose received from the gamma
M. Zdravkova et al.,22/193R

In the EPR
section criticality
accidents should
not be mentioned
as this is not
specific for
criticality
accidents

Occupational Radiation Protection (DS453)
component of the radiation exposure.”

3

50

Annex,
A-32

3

51

Ref.
[A-25]

Retrospective Dosimetry
after Criticality Accidents
Using Low-Frequency EPR:
A Study of Whole Human
Teeth Irradiated in a Mixed
Neutron and GammaRadiation Field, Radiat. Res.
160 (2003) 168–173.
st
1 sentence:
Such an Annex does not“The basis for luminescence
exist in the document. We
techniques in retrospective dosimetry is assume that this statement
the same as that described in Annex Ishould refer to Appendix II
Appendix II for luminescence(for luminescence
techniques in prospective dosimetry.”
techniques in prospective
dosimetry, see Paras
II.10II.24).
“… Use of Electron Paramagnetic
Editorial (missing letter).
Resonance Dosimetry with Tooth
Enamel for Retrospective Dose
Assessment, …”

AA

DS-453 “Occupational Radiation Protection”
COMMENTS BY REVIEWER
Reviewer:
BAPETEN/BATAN
Page 23 of 2
Country/Organization: INDONESIA
Date:20 June, 2014
Comment
Para/Line
Proposed new text
ReasonAccepteNo.
No.
d23/193RESOLUTION

Accepted, but
modified asfollows

Rejected

Reason formodification/rejection

Occupational Radiation Protection (DS453)
COMMENTS BY REVIEWER
Reviewer:
BAPETEN/BATAN
Page 23 of 2
Country/Organization: INDONESIA
Date:20 June, 2014
Comment
Para/Line
Proposed new text
No.
No.
1.

2.57

--- It needs to specify when and inwhat circumstances the formula (6)can be applied.---

2.

4.17

When military personnel are designatedas emergency workers, every effort
should be made so that they areprotected in the same way as otheremergency workers. In this case a
voluntary basis may be excluded. The
voluntary basis for response actions inwhich the doses received might
exceed 50 mSv by emergency
workers is usually covered in theemergency response arrangements.

3.

6.41

---Definition of qualified expert should
be clearly clarified ---RESOLUTION

Reason- The document should be
able to provide sufficient
informationforthereaders.
We need to ensure thatthe personnel involved in
the emergency response
team
areequallyprotected and also tokeep the statement is
flexible in accordancewith the GSR Part 3.
The proposed text isaimedtomaintain
flexibility as in several
countries the military
matter may not be that
simple.
- If qualified expert shouldbe always included, does
it
mean
that
the
personnel should need tobe certified? It may be agreat burden to somelicensees. In some cases
the qualified experts havebeen accommodated by

24/193

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

R

This is justinformation on future
developments.

R

If the military aredesignatedasemergency workers
than they should betreated as any otheremergency worker
and this is covered in
4.23

R

The qualified expert
is defined in the BSS.
No glossary can be
included in the Safety
GuideOccupational Radiation Protection (DS453)
COMMENTS BY REVIEWER
Reviewer:
BAPETEN/BATAN
Page 23 of 2
Country/Organization: INDONESIA
Date:20 June, 2014
Comment
Para/Line
Proposed new text
No.
No.

RESOLUTION

Reasonthe ministries.
- We may need tocorrelate with the RPOs.
- The readers will find it
easy to refer.

4.

---- Values of WR and WT (Radiation
weighting factor and Tissue weighting
factor) should be stated within the
document.---

5.

-

6.

Annex

We propose that several important - It will be easier for thedefinition can be defined in a separate
readers to understandsection within the document---We need to add Generic Criteria -to It will be easier for thethe annex for protective action andreaders to understand theother response action in emergency
whole context of the
exposure situation to reduce the risk of
document
stochastic effects as stated in GSRPart 3----25/193

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejectionR

It is a policy not toduplicatethedefinitions
from
other
IAEA
documents.
The
values are in the BSS
No glossary can be
included in the Safety
Guide
To avoid duplication
totheextentpossible.

RR

Occupational Radiation Protection (DS453)

COMMENTS BY REVIEWER
Reviewer: Representative to the RASSCCountry/Organization: BELGIUM
Commen Para/Lin
Proposed new text
t No.
e No.
1

6.6
6.10
6.11

Comment :As stated in the BSS, the unborn orbreast-fed infant or child should beafforded the same broad level ofprotection than other members of
the public.
This “broad level” should lead tothe interpretation that the complete
system of radiation protection
measures should also apply tothese individuals: justification of the
exposure, optimisation and finallydose limitation. It is therefore
insufficient to only look at therespect of the dose limit formembers of the public to deal with
their protection.
In judging on justification of their
exposure, there may evidently be apotential conflict of interest withthe “right to employment” of themother, but the “right to protectionof the child” should nevertheless be
considered also, as when justifying

RESOLUTION
Page 1
Date: 2014/06
ReasonConsiderations should betaken into account when
dealing with pregnant orbreast-feeding women, who
are or might beoccupationally exposed toionizing radiation, in order toprovide adequate protection
for their unborn or breastfed infants or children.

26/193

Accepted

Accepted, but
modified as follows

RejectedR

Reason formodification/reje
ction
Considering
practicalities, thecurrent text
seems to beappropriate. For
more informationrefer latest ICRP
recommendations(Reference 39
and 40 in thedraft guide).

Occupational Radiation Protection (DS453)
any other planned exposure
situation.
With regard to the dose limit,
account should be taken of the factthat the normal duration ofpregnancy in humans is roughly 9months, not one year. If we would
judge child-to-be as “generalpublic”, then the dose limit for thecomplete duration of pregnancy
should not exceed the value of .75
mSv.
But if we are to provide a “samelevel of protection” to the unborn,infant or young child, as the BSS
requires us to do, then accountmight need to be taken of theirwell-documented greater radiosensitivity, as compared to the
public in general, i.e. a public of
mixed age composition. One could
think of an “age-related sensitivity
factor” which would apply in thesecases, by which to divide the(general)public dose limit for thesevulnerable individuals. If, forexample, a factor of 5 would be
judged appropriate, then the dose
limit for the entire duration ofpregnancy would only be .15 mSv.
And finally, the principle of
optimisation should also be applied:
it may be useful to remind that27/193

Occupational Radiation Protection (DS453)
radiation protection is not restricted
to keeping exposures below theapplicable dose limit, but that
ALARA also applies here.

COMMENTS BY REVIEWER
Reviewer: KOZLODUY NPPCountry/Organization: BULGARIA
Commen Para/Lin
Proposed new text
t No.
e No.

RESOLUTION
Page 1
Date: 2014/06
Reason1

7.198/3“…the critical value MCj (inbequerels) for the measured bodycontent of the radionuclide..”The word “intake” should
be replaced by “themeasured body content”.
The text contradict theformula (33)2

7.198/5

to is the elapsed time period“m(t0 )” should be replaced
by “t0 ” The text contradictpara 2.49, page 13.

28/193

Accepted

Accepted, but
modified as follows
AA

RejectedReason formodification/reje
ction
Retain the word
intake, but
substitute “ forthe intake” by“associated with
the intake’See comment 25
from GermanyOccupational Radiation Protection (DS453)

COMMENTS BY REVIEWER
Reviewer: Scientific and Engineering Centre for Nuclear and Radiation Safety
State Atomic Energy Corporation, ROSATOM
Page 1Country/Organization: RUSSIAN FEDERATION
Date: 2014/05/06
Commen Para/Lin
Proposed new text
Reason
t No.
e No.
1

7.166

The detection limit DL can beevaluated for a given radionuclide andmeasurement procedure before thesample measurement takes place. It
specifies the minimum activity in thesample (for indirect methods) which
can be detected with a specified
probability β of a false negative. The
DL allows a prior decision to be madeas to whether a measuring method issuitable for the given monitoring
programme.

RESOLUTION

Accepted

Accepted, but
modified as follows

It should be specified thata posteriori decision must be
based on the DT criteria,
not the DL.

Rejected

Reason formodification/rejectionR

Covered by
7.167

Decision of the presence of theradionuclide in the sample or in the
body is not to be taken for comparing
the measurement result with the DL.

2

4.29

More detailed guidance on exposure

The impact of the factors

29/193A

Instead:addOccupational Radiation Protection (DS453)
assessment in emergencies is given inparas 7.222, 7.223 and 7.228-7.243.

mentioned in paras 7.222
and 7.223 most often (if notalmost always needs to beconsidered in the case of
emergencies. The section“EXPOSUREASSESSMENT” (paras
4.25-4.29) of the draft does
not provide a clear
recommendation of thenecessity to consider thesefactors.

sentence:“The guidance
given in 7.222
and 7.223 may
also be relevantforemergencies.”

COMMENTS BY REVIEWER
Reviewer: 2
Country/Organization: RUSSIAN FEDERATION
Commen Para/Lin
Proposed new text
t No.
e No.
1

2.29

2

2.30

3

Section4

4

7.20

5

7.24

RESOLUTION
Page 1
Date: 2014/06/01
Reason

It is necessary to clearly indicate that
Wr… It should be mentioned that effective
dose is ony the calculated values as
noted in ICRP103
Table 3 and 4.6 doses not agree toTable 2 and 4.15. We suggest to delete
4.16 completely including Table 3
7.20 is written incompletely and nonunderstandable way

Accepted

Accepted, but
modified as follows

Rejected

Reason formodification/reje
ction

R
R

A

A

7.24 correctly notes that individual
dosimeters of neutrons have limited

R

30/193(already
addressed)
Table 3 deleted.
Para 4.16
modified.
This will beconsidered in theeditorial process.
The guidance
provided in theOccupational Radiation Protection (DS453)
range of energy. Suggested
measurement of spectrum at theworkplace is labor consuming and is
not a very exact procedure. We
suggest to make calibration of such
dosimeters at workplaces using
ambient dose dosimeters (detectors ofthermal neutrons in moderator)

text issufficiently
detailed

TITLE: Occupational Radiation Protection, DS453 Version 3.3 of 10 February 2014
COMMENTS BY REVIEWER
Reviewer: Sorin Mancas (RASSC corresponding member appointed in January 2014)
Page..1.. of...1.
Country/Organization: ROMANIA / CNCAN Bucuresti
Date: 5 June 2014
Comment Para/Line No.
Proposed new
ReasonNo.
text
1Para 7.14 / Delete:- Contradicts letter (a)letter (d)…”continuous- If not deleted, dose assessments onand”…
the basis of routine workplace(see page 105)
monitoring results would be notfeasible where it is usually justified
and approved: e g in dental radiology,
osteodensitometry, mammography.
Continuous monitoring in such
workplacesispracticallynot

31/193RESOLUTION

Accepted

Accepted, but
modified as follows

Rejected

Reason formodification/rejection

R withmodifica “(d) Where individual
tions
doses are assessed on
the basis of routine
workplace monitoring
results, thatmonitoring should becontinuous andrepresentative of allOccupational Radiation Protection (DS453)
necessary.

working areas within
the workplace.”

Draft Safety Guide : DS453 Occupational Radiation Protection : WNA Members Comments
COMMENTS BY REVIEWER
RESOLUTION
Reviewer:
WNA’s Radiological Protection Working Group
Page Country/Organization:
World Nuclear Association
Date: 2014-06-13
Comment
Para/Line
Proposed new text
ReasonAccepteAccepted, but
Rejected
Reason for
No.
No.
d
modified as
modification/rejection
follows
WNA 1
These comments should be read in the context of our general comments submitted for the draft DS457 document, with a view to review the series of(General)documents holistically, not in isolation. Also, the publication timescales need to be considered based on the order of publications both within IAEA andalso considering outputs from external organisations, such as the ICRP. As an example, the IAEA Fukushima report has not been published, and thissafety guide needs to fully consider outputs from that.
WNA 2
Appendix III is incomplete. The appendix focusses for workplace monitoring only on instruments for the assessment of external exposure. Surface(General)contamination monitoring as well as air contamination monitoring are important factors to define protective actions at workplaces in order to avoid
contamination or incorporation.  Add these types of instruments and change the title accordingly.

32/193

Occupational Radiation Protection (DS453)

WNA 3

WNA 4

Reject: all necessary information is present in Section 9 and Appendix V. Moving such information to Appendix III would involve structural changes tothe document which are not feasible at this late stage
3.25 (b)
Identify all relevant economic, social, The existing wording may
A
Identify all relevantradiologicaland
non-radiological lead to misinterpretation
economic,social,factors (sometimes non-radiological that non-radiologicalradiologicaland,factors as well) for the particular factors are of less concern;
where appropriate,situation under review that distinguish this is not necessarily the
non-radiologicalbetween the identified options, e.g. case.
factorsforthecollective dose,
distribution ofparticularsituationindividual dose, impact on public
under review that
exposure,
impacton
futuredistinguish between
generations, investment costs;
the identified options,e.g. collective dose,
distributionofindividual
dose,
impact on public
exposure, impact on
future generations,investment costs;
Adding new
Para(afterpara3.47)

SPECIAL CIRCUMST ANCES
3.#1
In special circumstances, provided thata practice is justified and is designed andconducted according to good practice, and thatradiation protection has been optimized but
occupational exposures still remain above thedose limits, and that it can be predicted thatreasonable efforts can in due course bring theoccupational exposures under the limits, theRegulatory Authority may exceptionallyapprove a temporary change in the dose limit.
Such a change shall be approved only ifformally requested by the registrant or licensee,
if the Regulatory Authority determines that thepractice is still justified and is satisfied thatappropriate consultation with the workers

As an example, at the restoration
stage after the nuclear power
plant accident, it can be foreseenthat workers/helpers on and offsite may receive relatively highdoses. Fukushima is a primeexample where this may be thecase.
A more flexible approach tooccupational dose limits may be
more effective during thesesituations in comparison with thedose limit during the routine
operation of nuclear power
plants. T his may allow

33/193

R

This part is no longer
in the BSS

Occupational Radiation Protection (DS453)
concerned has taken place.
3.#2
Should special circumstances exist
which require a temporary change in some dose
limitation, the registrant or licensee may apply
to the Regulatory Authority for such atemporary change.
3.#3
No temporary change in a dose
limitation requirement shall be made without
approval by the Regulatory Authority.
3.#4 . T he registrant or licensee shall, in any
application for a temporary change in a dose
limitation:(a) describe the special circumstances requiring
the temporary change; and(b) provide evidence to demonstrate that:(i) all reasonable efforts have been made to
reduce exposures and that protect ive
measures and safety provisions have been
optimized;(ii) the relevant employers and workers,
through their representatives whereappropriate, have been consulted andtheir agreement obtained on the need fora temporary change and on the conditionsof the temporary change;(iii) all reasonable efforts are being made to
improve the working conditions to thepoint where the dose limits specified inpara. 3.33 ; and(iv) the monitoring and recording of the
exposures of individual workers are
sufficient to demonstrate compliance withthe relevant requirements of this guideand are sufficient to facilitate the transferof exposure records between relevant
employers.
3.#5
Any temporary change in a dose
limitation shall:(a) be in accordance with the dose limitation
for special circumstances given in following
para.3.#6;

workers/helpers to carry out plant
restoration work after an accident
more effectively. It may be very
important in specific situations,for example, where skilledworkers who have experience of
the work carried out during earlystages of an accident are able tocontinue to engage in follow-up
restoration work.
Specifically, as shown in the left
column, it is reasonable, under
exceptional circumstances, topermit the dose averaging for up
to 10 consecutive years, such thatthe total effective dose received
in full working life would be
prevented from exceeding about
1Sv received moderately
uniformly year by year, as shownin the ICRP recommendation.
T he concept of “dose limitationin the special circumstances”, is amatter prescribed in BSS(1990)
and RS-G-1-1(1999).

34/193

Occupational Radiation Protection (DS453)(b) be for a limited period of time;(c) be subject to annual review;(d) not be renewable; and(e) relate to specified work areas.
3.#6
When, in special
circumstances, a temporary change in the dose
limitation requirements is approved pursuant topara.3.#1 to para.3.#5:(a) the dose averaging period mentioned inpara. 3.34 may exceptionally be up to 10
consecutive years as specified by theRegulatory Authority, and the effective dose
for any worker shall not exceed 20 mSv per
year averaged over this period and shall not
exceed 50 mSv in any single year, and thecircumstances shall be reviewed when thedose accumulated by any worker since thestart of the extended averaging period
reaches 100 mSv

WNA 5

4.6 - first
sentence

WNA 6

4.15
Table 2

WNA 7
WNA 8

4.16/Table 3

4.17

-

The emergency plan should include thefollowing considerations regarding theprotection of emergency workers:
Leave out “This value may be…”

ADFetus …AD (delta’) Fetus
Leave out

Point out that it is only partof the content of an
emergency plan
Even if the table is a copy
paste from GSR part 7, thereadability would improve
if the text in the rightcolumn “This value…” isleft out. The text is foundin with the same
formulation in the para 4.15
(last sentence) just above
the table.
Use the same spellingA
If military personnel takepart in the emergency workand therefore are part of

35/193R

It is not adding anyvalue
We have to take theTable as it is.
The final table will beavailable in GSR part
7. This will beconsidered in theeditorial process.

R

Editorial
If the military aredesignatedasemergency workers

Occupational Radiation Protection (DS453)

WNA 9

4.21

Leave out

WNA 108.1

WNA 11

8.4

The services provided by technicalservice providers might, but notlimited to, fall into two categories:
The management system of a service
provider using radiation shall comply
with national requirements and should
be in accordance with all relevant
IAEA safety standards.

WNA 128.10

the emergency
organization, there is no
reason to specificallyaddress them here.
The information in theparagraph is already in thedraft.
a repetition of part of 4.19
(a)implicit from 4.19
repetition of text in 4.19(a) and (b)Already in 4.14
Not to exclude and limit
new possibilities
National requirements are
to prevail and normallyincorporate the IAEA
standards

For a service provider, safety culture
can be established by:…..
For a service provider same safety
culture recommendations apply as forthe facility operator.

than they should betreated as any otheremergency workerR

It is not entirely
covered in 4.19 and
4.14R

No other categories
have been identified
to dateSee comment 30
fromGermany.
National
requirements are not
to be mentioned inthis guide
Facility operators are
not mentioned
anywhere in the
document.
However we would
recommend
following addition to
the text of 8.10(e):“Engagement of therelevant management
and staff”

R

R but withmodificati
ons to thetext

36/193

Occupational Radiation Protection (DS453)
WNA 13

8.14

The management system
documentation is often contained in aquality manual that includes or makes
reference to the supporting
documents,14 including:…
Emergency preparedness plans;
Calibration data and traceability, intercomparisons etc;
Dosimetry.
(b) Management documents;

R

WNA 14

8.14

WNA 15

8.17

WNA 16

8.29

WNA 17

8.31

Human resources include all the people
in the organization who are involved inachieving the objectives.

Does that mean that staff not
involved in work directly
linked to the objectives is not
human resource?

A

WNA 18

8.37

With regard to the working environment,
consideration should be given to how
best to combine the consideration ofhuman factors and physical factors with

Does not seem appropriatethat IAEA goes into thisarea of competence.

A (do not include
additional text)

Does that include thefollow up of requirementscompliance, periodical
reviews of the management
system and non-conformity
management?
Unnecessary details
A

The form and layout of the
management system documentation
should fit into the internal
communication culture of theorganization.
… (f) perform periodic (usually Missing responsibility on
annual) review of the management reviews
system.

37/193The list is not meant
to be exhaustive. It isalso addressed in
8.103 and 8.109

AManagement
documents,forinstance documents
relating to some of
the topics covered inparas 8.56 to 8.75

A(f) perform periodic(usually
annual)reviewsofthemanagement system.
Delete the whole ofthe first sentence

The proposed
additional text does
not match section
headingOccupational Radiation Protection (DS453)
achieving the goal of enhancing theperformance of the organization.
Attention to workload, stress factors,social structure within the organization,internal communication, workplacesafety, ergonomics, lighting, ventilationand many other factors can all be
combined to enhance the overall
effectiveness of the organization inachieving its objectives. The
organization should develop descriptionsof minimum criteria for the workplace
conditions necessary to achieve thevarious objectives.
Radiological protection should be
integrated with Health and Safety as wellas Environmental management.

(Infrastructure andworkingenvironment)

WNA 198.40

In the planning schedule, accountshould also be taken of the need forplanning for ensuring the traceabilityof measurement results to the SI
system and for establishing
information on uncertainties for thesemeasurement results.

Since this paragraph deals
with the development
process, it might bereasonable to place thisrecommendation in thecorresponding paragraph“Planning” after 8.26.

WNA 20

8.48…
Actions described are more(a) Repeated tests (possibly done using validation of the results
different instruments for analysis);then control of the process.
(b) Checks on introduced blank or test
samples;(c) Plausibility tests on the results,
done by applying expert knowledge,
etc.

38/193R

Current location ismore appropriate

R

Current text is more
appropriate

Occupational Radiation Protection (DS453)

WNA 21

Independentassessment

WNA 22

8.66

WNA 23

Managementsystemreview

WNA 24

8.68

WNA 259.48 Line 3

The results of these measurements
should be recorded as proof of thecontrol of the production processvalidation of the final product.
Independence to perform the audits
can be achieved by creating a crossaudit department which works acrossfunctions (where resources allow).
The mandate and scope of the auditing
team/person should be clarified andcommunicated.

Since the chapter is called
independent assessments,
but deals mainly withinternal audits, it could be
useful to describe how theindependency within theorganization can beachieved… (d) Actions that were planned, thepersons responsible for the actions andthe time schedules that were decided
upon, the date for follow up ofdecisions; …
Management system reviews are to be Description on what it is,prepared by… with the purpose of….. purposes, how often andand carried out at least …..
who is responsible ismissing.
For services in radiation safety, nonconformances could include:… (f) incorrect output data used foranalysis(g) Incorrectly performed sampling or
sample treatment
In general, water and steam are is the
Steam is not a preferred
preferred decontamination agents
decontamination agent. By
using steam the risk
generating airborne
contamination (aerosols)
should not be

39/193A

A

A

Proposed text to beinserted as a newparagraph after 8.59.

R

Already covered by
the expression “timeschedules”

R

Covered in GS-R-3,
no need to repeat
hereOccupational Radiation Protection (DS453)
underestimated.

IRPA collected comments from its associated members – provided as follows.
COMMENTS BY REVIEWER
Reviewer:
Italian Association of Radiation Protection
Country/Organization:
IRPA/ AIRP
Comment
Para/Line
Proposed new text
No.
No.
1

GeneralRESOLUTION
Page.... of....
Date:
ReasonThe comments we have received within
AIRP about the document underconsideration, show a very positive
judgment about the objective of such
document: to guide on meeting therequirements of the BSS for occupationalradiation protection.
It has been appreciated the idea of
having an integrated and unified
document, which at the same time,presents an update of the five guidance
related to the Occupational Radiation
Protection. In this way, the document isproviding a general guidance on thedevelopment of occupational radiation
protection programs, with attention toboth monitoring and assessment ofworkers’ exposure due to externalradiation sources and from intakes ofradionuclides. It gives also guidance on
the requirements for the radiation
protection of workers involved in themining and processing of raw materials,

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection
General comment, no
specific proposal

40/193

Occupational Radiation Protection (DS453)
and focusing on technical service
provided in radiation safety.
Many appreciations, as expected, havebeen obtained for some of the concepts,
already present in the guidance RS-G-1.1
and covered again in the present draft,such as in the introduction, at 1.5: “ …
that radiation protection is only one
component that should be addressed toprotect the overall health and safety of
the worker. The RPP should beestablished and managed together withother health and safety disciplines, suchas industrial hygiene, industrial safety
and fire safety. “ and at 1.8: “ . . .toprovide an integrated approach to thecontrol of exposure, including potential
exposure, due to external and internal
irradiation from both artificial andnatural sources of radiation. “ ;concepts, which are reinforcing the ideaof an integrated approach both internallyto Radiation Protection and in a wider
and more general health and safety
protection.
We have also seen some comments
concerned about the extension andlength of the present draft, which isconsiderable and such to make its fullconsultation quite hard and its use alsodifficult. On the other hand, we have also
had comments on specific topics, like theinternal exposure, stating that thecoverage of this matter was not adequate
and not sufficiently complete.
The

41/193

Occupational Radiation Protection (DS453)
complexity of this topic may require amore in depth drawing up of the text for abetter and more significant contribution
to the objective of meeting therequirements of BSS.

2
3

Para 2.8
Pag. 6 and7To remove: In general
For the sake of clarity, take into
consideration to cite the corresponding
requirements (of the BSS) in all of the
4 parts on REPONSABILITIES, andnot only in the last two parts. That is
consider to cite the corresponding
requirements (of the BSS) related toparas 2.15, 2.16, 2.17 (of this draft
DS453). In particular consider tocite in para 2.15, the Requirement 2 of
the BSS, which is specific for
Responsibilities of the government andincludes the articles here cited in thisDS453 as paras 2.13-2.28 of the BSS.
With the same intention, consider tocite: in para 2.16 the Requirement 3,
which is specific for Responsibilitiesof the regulatory body (paras 2.292.38 of the BSS); in para 2.17, theRequirements 19 (para 2.69-2.72 of
the BSS) and the Requirements 20(para 2.73 of the BSS) specific of theregulatory body to the occupational
exposure. Consider it could be more
useful and convenient to refer tospecific requirement rather than toparagraphs.

RR

42/193This has already been
considered very
carefully during the
preparation of the
document underconsideration of thegeneral policy of
keeping repetitions
from the BSS to aminimum.

Occupational Radiation Protection (DS453)
4

It could be proposed here, for theDS543 text, to avoid the use of theword management to define the set of
employers, registrants and licensees,
and to use the three terms by leaving
them separated and if necessary, by
repeating them every time is needed.
By doing that, the readers of the
document, can easily and clearly
understand
with
whom
the
responsibility lies and they can clearly
identify who among the three principal
parties is responsible for thecommitments for protection andsafety. As an alternative, it may be
proposed to use a single word,
different than management, like for
instance ‘principal parties ’, as alreadyused in the recent TECDOC 1731
(2013)
on
Implicationsfor
Occupational Radiation Protection of
the New Dose Limit for the Lens of
the Eye which at 3.1 recites “ …
The principal parties (e.g. employers,
registrants and licensees) are required
to promote and maintain a safety
culture…” by recalling para 2.51 of
the BSS. Again, instead of using thesingle and simple word “management”,
a possibility is to use the word
management combined with a word
defining that better “management” as‘management body’ or ‘management

In
RS-G-1.1.
(1999)‘Occupational
Radiation
Protection’, within para 1.6.
dedicated to the descriptionof the objective of the Guideisreported: “…Therecommendations given areintended for regulatory
authorities, but this Safety
Guide will also be useful toemployers, licensees andregistrants, to management
bodies and their specialist
advisers, and to health andsafety committees concernedwiththeradiation
protection of workers. …” .
In the same guide, para 2.35
qualifiesthat : “ Insummary,
registrants,
licensees and employers ofworkers are responsible for
ensuring that exposures arelimited (…), that protection
and safety is
optimized(…), and that appropriate
radiologicalprotection
programs are set up andimplemented(…).
The
implicationsofthefulfillmentof
these
responsibilities
aredeveloped in a number ofplaces in this Safety Guide.
These responsibilities shall

43/193R

The term“management” isclearly defined in 2.18.
The specific meaningof the term“management” is clear
from the context.
This issue will in any
case be considered by
the IAEA editors.

Occupational Radiation Protection (DS453)
team’.

beplacedonthemanagement within theorganizations of registrants,
licensees or employers. For
simplicity,theterm‘management’ will be usedtodenote‘registrants,
licensees and employers’ inthe following sections of thisGuide, except where there isa need to specify which
entity is concerned.”
In BSS (2011) the terms:
registrants, licenses andemployers (the terms arepresent all together and not
singled out), are cited in 11 of
the 52 requirements and inparticular in Requirement 4,
14, 19, 20, 21, 23, 24, 25, 26,
27, 28 over the text, mainlyin the part dedicated tooccupational exposure.
In the present draft DS534,
in para 2.18 : “In planned
exposuresituations,employers, registrants andlicensees(hereinafterreferred to simply using theterm ‘management’) areresponsible for ensuring that
protection and safety is
optimized, that applicable
dose limits are complied

44/193

Occupational Radiation Protection (DS453)
with, and that appropriate
RPPs are established andimplemented.”
The question and the objectof this comment concerns thefacts that the text of theDS534 quite extended (threetimes more pages than the
textof
RS-G-1.1.
‘Occupational
Radiation
Protection’) and at the sametime, integrating as many as 5
documents, we can finddifferent uses of the word
‘management’.
As an example, in the BSS
text, the term ‘management’is always used with the same
meaning and in expressions
such as: management of risk,of the exposed situations, ofspent fuel, for protection andin expressions like waste
management
andasmanagement system.
On the contrary, in the DS543
theintroductionof“management = employers,
registrants and licensees”
maygenerate
some
confusion giving different
meanings
to statements
where
the
word
“management “ is used with

45/193

Occupational Radiation Protection (DS453)
different significations.

5

2.29
2.30

and to use the expression “ definition ofequivalent dose” and “definition ofeffective dose” instead of the“determination” as it is in the draft.
The same in the case of para 2.33,
changetheexpression“The
determination of RBE weighted
absorbed dose..”

6

2.34

The suggestion is to define andintroduce this quantity elsewhere in theDS453 draft, as an example in the part
dedicated to Optimization.

7

2.36

“ … the equivalent dose received byany small area of the sensitive layer ofthe skin is less than ten times larger
than the effective dose, the radiation
is said to be strongly penetrating. If
the equivalent dose is more than ten
times larger than the effective dose,the radiation is said to be weakly
penetrating. “ Even if this statement
is strictly taken directly from theoriginal version of
ICRU 39 (1985),
the following more clear statement
could be better to use: the equivalentdose received by any small area of thesensitive layer of the skin is lower thanThe collective dose should
be used and understood as
aninstruments for
optimisation,aswellindicated in 2.34. It is asort of subsidiary quantity
and not a dosimetricquantity.

46/193R

Determination is themore appropriate
word.

R

Already defined in thesafety glossary.
To avoid too many
duplications.

R

The current text is
adequate.
This issue will in any
case be considered by
the IAEA editors.

Occupational Radiation Protection (DS453)
ten times the effective dose, theradiation is said to be strongly
penetrating. If the equivalent dose islarger than ten times the effective
dose, the radiation is said to be weakly
penetrating.
In this way, theexpression
which
may
createmisunderstanding ‘less than ten times
larger that’ could be avoided.
8

2.47“ For exposure of the lens of the eye,the recommended depth is 3 mm, butthere are at present no publishedconversion coefficients for convertingfrom the basic physical quantity kerma
to the directional dose equivalentH'(3). “ it is very clear. However thereis the suggestion to consider to add
some comments on this, also in theview of ICRP 116, “(64) In the caseof monitoring the dose to the lens of
the eye, the operational quantity H'(d,Ω) with d = 3 mm was recommended
for use by ICRU. However, if themonitoring device is not designed tomeasure H’(3, Ω), H'(0.07, Ω) may be
used as a surrogate.”.
Moreover, it could be considered to
add a table/scheme summarizing theuses of the operational dose quantities
in monitoring external exposures (asan example, it could be Table 2.4 in
ICRP 116).

A

The following sentence
added at the end ofparagraph 2.47:
However, if themonitoring device is
not designed tomeasure H’(3, Ω),H'(0.07, Ω) may be
used as a surrogate.
Introduced here thereference to ICRP
Publication 116 andto IAEA TECDOC
1731
Table is not necessary.

47/193

Occupational Radiation Protection (DS453)
93.15

In para 3.15 related to optimization ofprotection and safety, attention is
given on the dose to the lens of the eyereferring to worker in medical field
and it is mentioned that when dealing
with X ray machines the optimization
process involves local rules. In thissense, when the part on local rules istreated e.g. in para 3.86, a proper
attention could be here renewed with a
specific reference, and moreover inpara 3.88 the use of goggles (protective
glasses)couldberemembered, in the general view ofprotective clothingR

Paragraphs 3.86 and3.88 are general innature and such levelof detail is notnecessary.

10

3.51

It could be added some considerationon the doses received by workers ininterventional procedure, in view of
the new limits for the lens of the eye.

R

Paragraph 3.51 isgeneral in nature andsuch level of detail is
not necessary.

11

3.92

take into consideration that the ‘new’ Para 3.95 of the BSS does
attention to the limit of the lens of the not explicitly mention theeye is really ‘new’ also in RPP and to case of protective glasses.
the worker and in this sense it could
be worth to put the proper evidence on
it. The concept expressed in para 9.53
It is a very good example of a concept
which could be expressly introduced
and added also in chapter 3 at the levelof
optimization or of radiation
protection program (e.g. within paras

R

Paragraph 3.92 isgeneral in nature andsuch level of detail is
not necessary. Details
are given in the quoted
cross-references.

48/193

Occupational Radiation Protection (DS453)

12

3.95

13

3.119

14

3.124

3.8 -3.86), instead of simply
mentioning that the use of personal
protective equipment are given in paras
9.52-9.60.
The suggestion is to take into
consideration cases in which there is a
short time available for making
decisions and thus not sufficient time
to follow all the RWP preparation
procedure, by adding at the end ofpara 3.95, the following sentence:“For tasks which need special
radiological precautions, a RWP
based on a short approval process by
the RPO, could be consideredsufficient, specifically for the tasks
characterized by the availability ofshort time for the decision toundertake a specific radiation work
(e.g. the need of prompt maintenanceof an accelerator; tasks related toshort half lived radio nuclides).”
it is written “…The objective should
be to establish as comprehensive a
record as is reasonable of credible,
formally assessed exposures. Accountshould be taken of the factors
affecting the accuracy of theassessment. …” and it looks like anunclear and difficult to understandstatement.
it is written “ ... the expected levels
and variability of the quantities being

R

This opens the door topossible misuse of the
RWP concept.

Editorial
This will be taken careof by IAEA editors.

A

49/193Replace “measured” by“determined”

Occupational Radiation Protection (DS453)

15

5.88

16

7.45

17

7.47

measured (e.g. effective dose, intake)and the type and frequency ofmonitoring. …” but the quantities
such as effective dose is notmeasurable.
it is suggested to include also the ICRP
Publication 123, Assessment ofRadiation Exposure of Astronauts inSpace, published in 2013.
The suggestion is to pay attention to
Eq.24 (DS543) and add some notewhen considering the differences withprevious formulation in RS-G-1.3.
Moreover consider if it is useful tospecify H1 = H0 in both the parts (H1≤ H0 and H1 ≥ H0 ) of the Eq. 24,
since for H1 = H0 it is unequivocally[1-2 H0 / (H0 + H1 )]=0 .

In para 7.47 for Hp(10),A

In para 7.45., by referring A
acceptancelevelofuncertainty
andtheallowable accuracy interval,
the upper limit RUL and thelower limit RLL are givenby the Eq. 23 and 24. The
same point is treated in RSG-1.3 ‘Assessment ofOccupational
Exposure
Due to External Sources ofRadiation’ where lower
limit and upper limit were
given by the Eq.2 and Eq. 3
respectively. By comparing
the formulation of theequations, we can see thatthe equations for the upper
limits are the same in thetwo documents, while theequations for the lower
limits look different in thetwo documents.

Hp(0.07)

Formula has beenchecked; it is correct
as it is in the current
versionA

50/193

The text can beOccupational Radiation Protection (DS453)

18

10.5

and Hp(3) the indication in given of H0(the lowest dose that needs to bemeasured) in relation to a monitoring
period of one month. Moreover theaccuracy intervals for Hp(10) and Hp(0.07) are shown graphically (asalready shown in IAEA RS-G-1.3).
The accuracy interval for Hp(3) is
missing. If this information for Hp(3)is not available it could be useful tomention it, or for example, put areference to para 7.16, if this is thecase: “ ... dosimeters
designed
specifically for Hp(3) are not yet
widely available ...”.
to modify the first part, as follow:“The occupational physician, including
any private occupational physician
employed on a part time basis, should
be knowledgeable, through training
and retraining where necessary, on atleast the radiation physics andbiologicaleffectsofradiation
exposure, the means of control ofexternal and internal exposure, and theinterpretation of exposure data anddosimetric assessments [156]. In
order to ensure that the occupational
physician is able to perform all the
relevant tasks, a recognition of his/her
capacity to act in that respect should
be done by the competent authority.
With the support of specialists where

modified as suggested:“The accuracy
intervals for Hp(10)and Hp(0.07), the mostwidely used quantities,
are shown graphicallyin Fig. 4”.

R

51/193The extra details
provided are regarded
as too prescriptive tocover different
situations.

Occupational Radiation Protection (DS453)

19

Appendix
IV

20

IV.16

appropriate, the occupational physician
should be in a position to use thisknowledge
not
only
in
the
implementation of the workers’ healthsurveillance programme . . . . .“In Appendix IV, related to Biokinetic
modelsforinternal
exposure
assessment, in the part related toingestion and in the part related toinhalation,
it could be useful toremember that BSS includes in
Schedule III respectively the table III2B and the table III-2C with the list ofcompounds and values of gut transfer
factors f 1 used to calculate committed
effective dose per unit intake via
ingestion and via inhalation forworkers.
In para IV. 16, when mentioning the
ICRP Human Alimentary Tract Model,
this model is referred for 2 times as‘new model’ and moreover isunderlined that it has ‘now’ beendeveloped in ICRP Publication 100.
One comment is that ICRP 100 dated
2006 and the suggestion is just to
erase the word ‘now’ in theexpression ‘has been developed’.
Errata corrigea) X ray is written as: X ray, X-ray, X
Rayb) In para 2.52. is written HT(g) but
it has to be changed in hT(g)R

Already given in themain text (Para. 7.201)

AA

52/193a) The correct way is
X rayb) c) d) accept

Occupational Radiation Protection (DS453)c) update reference 106 as‘EURADOS Report 2013-01, IDEAS
Guidelines (Version 2) for the
Estimation of Committed Doses from
Incorporation Monitoring Data’.
d) Pag. 230 in reference [15] it iscorrect to write 23 February 2012 andnot 2013

COMMENTS BY REVIEWER
Reviewer:Country/Organization:
USA/IRPA
Comment
Para/Line
Proposed new text
No.
No.

RESOLUTION

Page 1 of 11
Date: May 29, 20141

2.1(iii)

Delete “Existing exposure situations
include situations of exposure tonatural background radiation”.

2

2.4

Delete, “Examples of excluded
exposures are those from 40 K in the
body and from cosmic rays at the
Earth’s surface”.

ReasonEvenhighbackgroundradiation areas around theworld present doses too low
to observe adverse effects.
What “need for control”
exists?
The examples of 40 K in the
body and cosmic rays at the
Earth’s surface should be
exempt from this standard
not only because they areunamenable to control, but

53/193

Accepted

Accepted, but
modified asfollows

Rejected

Reason formodification/rejection

R

Quotation from the
BSS

R

Those reported are
actually examples of
excluded.

Occupational Radiation Protection (DS453)

3

2.10

Delete “and diagnostic”.

4

2.34

“These quantities takes account”

5

3.6

The text states “Exemption or
clearance is the appropriate regulatory
option if the radiation risks are too low
to warrant regulatory control or if theimposition (or retention) of regulatory
control would yield no net benefit…”

mainly because they cannot
be demonstrated to carry any
hazard. Exposure to cosmic
radiation could be reduced bybanning high altitude flight,
and evacuating areas ofhuman habitation at altitudes
above sea level. We don’ttake these measures because
they are unwarranted in theabsence of demonstrable risk.
Why are diagnostic medical
exposures exempted from therequirement for optimization?
As proposed by ICRP Report
No. 105 and ICRU
Publication 74, diagnostic
medical doses should be
optimized too, so that doses
are as low as reasonably
achievable while maintaining
diagnostic value.
Delete “s” from “take” to begrammatically correct.
How is “net benefit” to be
calculated? Use of a linear,no-thresholdmodelofradiation risk, assumed byregulation, predicts that risks
are reduced all the way down
to zero dose, so how is it
possible that a dose reduction
results in no net benefit under

54/193

A

Delete the text
“except fortherapeutic anddiagnostic medical
exposures”.

AR

It is the reglatory
control, not the dose
reduction, that can
produce no net
benefit.

Occupational Radiation Protection (DS453)
6

3.7“…for bulk material containing
radionuclides of natural origin, the 10
μSv criterion is not appropriate since itis one or two orders of magnitude
below the normal variations in
exposure to natural backgroundradiation”.

7

3.12(b)

The process of optimization shouldtake account of:
The distribution of individual andcollective exposure among different
groups of workers;

83.25(c)

Identify all relevant economic, socialand radiological factors (sometimes
non-radiological factors as well) forthe particular situation under review
that distinguish between the identified
options, e.g. collective dose,
distribution of individual dose…

this assumption?
If
thecriterionforappropriatenessis
being
below normal variations in
exposure to backgroundradiation, why is this only
applied to NORM? The body
doesn’t care where theradiation originated.
Why? If a linear, nothreshold model of radiation
risk is assumed, as requiredbyregulation,what
difference is 0.1 mSv
received by 10 individuals, or
1 mSv received by 1
individual in terms of
population
risk?
This
assumes all individuals are
below applicable dose limits.
How is this issue to beconsidered in practice?
Why consider distribution ofindividual doses? If a linear,no-thresholdmodelofradiation risk is assumed, as
required by regulation, what
difference is 0.1 mSv
received by 10 individuals, or
1 mSv received by 1
individual in terms of
population
risk?
This
assumes all individuals are

55/193R

The existing text is
consistent with the
BSS. Unlike the caseof NORM,
background levels ofartificial radionuclides
are almost zero.

R

Collective dose ismerely a tool for
optimization. Forradiation protection
individual dose is theimportant quantity.

R

We cannot ignore thepossibility of highindividual doses
received by a small
proportion of theworkers.

Occupational Radiation Protection (DS453)

9

Figure 310

3.162(d)“…doses are always expected to bewell below the threshold for
deterministic health effects, and that
there is never any real prospect of aradiological emergency.”

11

4.14(c)When undertaking actions to avert alarge collective dose.

below applicable dose limits.
How is this issue to beconsidered in practice?
The significance of the twocolors of bars should be
explained either in the title of
the graph, or in a footnote to
the graph.
This text seems to be
implying that a radiologicalemergency cannot exist as
long as doses are below thethreshold for deterministic
effects. If that is the case,why did the Fukushimasituationrequiretheevacuation of thousands ofpeople, all of whom were
expected to receive doses
well below deterministic
thresholds? While I agree thata radiological emergency ishighly unlikely for theactivities listed, pegging it todeterministic thresholds ispuzzling.
According to the LNT risk
model assumed to apply tothe exposed population, as
requiredbyregulation,
exposing a worker to a dosein excess of 50 mSv would
be justified as long as the

56/193RA

The text in the figure
is self-explanatory.

Modification to thetext:“The recognition that
doses are always
expected to be well
below the thresholdfordeterministic
health effects; In
addition, there is
never
any
real
prospectofaradiologicalemergency.”R

The current text does
not imply that theworker’s exposure“would be justified aslong as the collective
dose averted is >50
mSv” .

Occupational Radiation Protection (DS453)

12

4.15, Table The value of 500 mSv should be2
exceeded only under circumstances inwhich the expected benefits to others
clearly outweigh the emergency
worker’s own health risks

13

5.76

14

5.81

Exposure to cosmic radiation at
ground level is regarded as unamenable
to control and is therefore excluded
from the scope of the BSS.

collective dose averted is >50
mSv. This is not a very large
collective dose.
500 mSv is still below thethreshold for deterministic
effects listed in Table 3, so
according to the LNT risk
model assumed as requiredby regulation, to apply to the
exposed population, exposing
a worker to a dose in excess
of 500 mSv would bejustified as long as thecollective dose averted is>500 mSv.
Cosmic rays at the Earth’s
surface should be exempt
from this standard not only
because they are unamenable
to control, but mainly
because they cannot bedemonstrated to carry any
hazard. Exposure to cosmic
radiation could be reduced bybanning high altitude flight,
and evacuating areas ofhuman habitation at altitudes
above sea level. We don’ttake these measures because
they are unwarranted in theabsence of demonstrable risk.
Given that maximum doses toaircrew is on the order of 6.5

57/193R

The final table will beavailable in GSR part7 and will beconsidered in theeditorial process.

R

The text is consistent
with the BSS

R

These questions are
addressed elsewhereOccupational Radiation Protection (DS453)

15

5.85

16

7.242

17

7.251

The biodosimetry methods may not beappropriate for low dose exposuresless than 50–100 mSv.

mSv – over a factor of 10
below the level where cancer
risks are detectably increased
even for acute exposures,and given the absence ofconsistentevidenceofincreasedrisks
inepidemiological studies offlight crews, when is it
deemed warranted to monitor
these doses? Furthermore,
what remedial actions arepractical to lower thesedoses?
This section is eminently A
sensible, and the logic used
here
shouldbeusedthroughout.
The lower limit of detection
for biodosimetry techniques
depends not only on dose,but on dose-rate, age, and
time
since
exposure.
Sensitivity is also a functionof the number of (typicallylymphocytes) cells scoredand the fraction of the
genome stained or painted percell.
Are records of medical
imaging exams required as acondition of employment(e.g. an entrance, exit, or

58/193in this section.

No specific change
proposed.

R

Direct quotation fromthe BSS.

Occupational Radiation Protection (DS453)

18

8.37

19

20

8.54

9.64

With regard to the working
environment, consideration should begiven to how best to combine theconsideration of human factors andphysical factors with achieving thegoal of enhancing the performance ofthe organization. Attention toworkload, stress factors, social
structure within the organization,internal communication, workplacesafety, ergonomics, lighting,ventilation and many other factors can
all be combined to enhance the overall
effectiveness of the organization inachieving its objectives. The
organization should develop
descriptions of minimum criteria for
the workplace conditions necessary toachieve the various objectives.
Communication in an organization
providing services in radiation safety
can be achieved by:(a) Organizing regular meetings of key
personnel;(b) Using communication tools(electronic billboards, intranet, etc.);(c) Having similar methods of internal
communication.
In workplaces where there are areas

periodic chest X-ray) also a
mandatory part of theoccupational
exposure
record?
I don’t disagree that these A
factors are desirable fortechnical service providers(and any employer), but Iquestion the appropriatenessand necessity of including
this text in a document onradiation safety.

Comment
alreadytaken into account(WNA
comment#18)

I don’t disagree that thesefactors are desirable fortechnical service providers(and any employer), but Iquestion the appropriatenessand necessity of including
this text in a document onradiation safety.

R

This guidance isconsidered to beneeded.

According to the LNT risk

R

The reduction in

59/193

Occupational Radiation Protection (DS453)
with potential for high levels ofradiation exposure, when no otherpracticable means of control areavailable, job rotation may beconsidered as an administrative control
to restrict the exposure of individual
workers. However, the use of thismethod should be kept to a minimum,and job rotation should never be used
as a substitute for the development anduse of appropriate methods ofindividual exposure control.
21

10.29

22

I.3(ii)“…the annual effective dose expected
to be received by the worker would
range from 2 mSv per year (250 Bq/g
× 0.008 mSv per Bq/g) to 10 mSv per
year (250 Bq/g × 0.04 mSv per Bq/g).
This would suggest that, in terms ofthe graded approach, the exposure
situation would be of fairly significant
concern for protection and safety”.

23

II.34

One disadvantage of nuclear track
emulsion is its high rate of fading.

model assumed by regulation
to apply to the exposed
population,
thisrecommendation makes nosense, as long as all workers
are kept below regulatory
limits. Spreading dose overlarger numbers of workers
doesnotchangethecollective dose.

If the initial, periodic, or exit
medicalexam
requiresradiological imaging exams asa condition of employment,
records of these exams, andthe radiation doses they
deliver, should be maintained.
I
questionthecharacterizationof
thisexposure scenario as “fairly
significant
concernforprotection and safety”. Evenat acute doses of about 100
mSv (10-50 times higher thanpostulated here), there is no
detectable increase in cancer
risk. This exposure scenario
involves chronic exposure, so
is of even less concern.
Section II.6 did a good job ofmaking it clear that signal60/193individual doses
achieved by job
rotation is an
importantconsideration.

A

R

Unnecessary level ofdetail and in any caseit relates to medical
exposures.

R

The dose of 10 mSv
is half the annual
dose limit forworkers, andconsequently of fairly
significant concern.

One disadvantage of
nucleartrack

Occupational Radiation Protection (DS453)

24

A-6

Cytogenetic damage in peripheral
blood lymphocytes (PBL) includes
dicentric chromosomes, chromosome
aberrations, micronuclei andtranslocations.

25

A-7

Dicentric frequencies in PBL show aclear linear quadratic dose–effectrelationship up to ~5 Gy for acutephoton exposures.

26

A-15

In order to assess induced
translocations among different labelledchromosomes, multi-colour FISH and,for whole genome analysis, M-FISH
have been developed.

27

All

fading is only an issue prior
to development of the film.
This section should do thesame. Fading is not an issue
after the film is developed.
The listing of chromosome
aberrations in this sentence isnotstrictly
correct.
Dicentrics, micronuclei, andtranslocations are examplesof chromosome aberrations.
Other examples include rings,
multicentrics,
andRobertsonian fusions.
This is true only if theanalysisisperformed
promptly after exposure. The
frequencyofdicentrics
declines fairly rapidly after
exposure,
particularly if
doses are high enough to
induce lymphocyte turnover.
This text implies that multicolour FISH and M-FISH are
different techniques. The
acronym M-FISH stands for
multi-colour FISH. Spectral
karyotyping is a similar
technique to paint eachchromosome pair with aunique signal.
My
mostsignificant
comment
is
that
the

61/193emulsion is its highrate of fading before
being processed.

R

A

Reject unlessinconsistent withoriginal reference.

Dicentric frequencies
in PBL can show aclear linear quadratic
dose–effectrelationship up to ~5
Gy for acute photon
exposures.
R

See answer to thecomment #48 ofGermanyOccupational Radiation Protection (DS453)

28

All

dedication of any resources
to the control of exposures as
low as 1 mSv per year is illadvised. This is well within
the
range
of
naturalbackground variability. Even
acute doses 100 times higher
than this level have not beenreliably
associatedwithincreased cancer risks, letalone deterministic effects.
And
finally,
directingattention to doses this low
contributes
torampant
radiophobia,
which
exaggerates hazards fromlow radiation doses far out of
proportion to other hazards,
and to the hazards ofcontrolling doses this low.
The prolonged evacuation of
Fukushima residents – which
has led to over a thousand
deaths from stress othermental health issues – is aprime example.
Although I have serious
objections to using the LNT
assumption for low doserisks and regulatory policy,
this is not the place for thatdebate. Nonetheless, if LNTis to be assumed by

62/193

Occupational Radiation Protection (DS453)

29

Table
6,
Summaryof testing

regulation,thentheregulations should at least be
consistent with the statedassumption. Several of myprevious comments relate tothisdisconnect between
specific
recommendations
and the LNT assumption.
While a de minimis dose levelmakes eminent sense (seecomment 28), no such levelhas been recognized orstated. It should be, and therecommendations referred tohere would be consistent
with such a policy.
Periodic testing frequency isstated as annually or more
frequently. In the US, thecalibration
standardforportable survey instruments(ANSI N323A and B) and air
monitoring systems (ANSI
N42.54 draft) are currently
undergoing revisions. The
two portable instrument
calibration standards havebeen combined into a single
standard and is approved
awaiting publication. This
standard incorporates new
protocols that allow forextending the calibration

63/193

R

The
recommendations inTable 6 are areflection of current
practice.

Occupational Radiation Protection (DS453)

30

Table
7,
Surface
Contaminati
onProbeSensitivities

interval beyond one year byperforming and documenting
simpletesting
betweencalibrations. These protocols
will be beneficial to users thatare operating remotely from acalibration
facility(e.g.
military) or have either limited
use or limited resources suchasemergency
responseorganizations (e.g. police andfiredepartments).
The
periodic operability checks
are intended to demonstrateconsistency of operation
between calibrations.
The
instrument
types
described and the associated“calibration factors” appear
to be based on the probe
response to the 60Co beta
particle with a maximum
spectrum energy of 0.310
Mev. In the US, “calibration
factor” (also referred to as
detector efficiency) for thedetector probe is stated as
detector response as counts
output for each nuclear
particle that intersects thedetector probe window (e.g.
cps/dps). The values in Table
7 are comparable to the64/193

R

Table 7 is just an
illustration of the factthat the sensitivity of
theinstrument
increases with thesurface area of theprobe (see Text in9.39).

Occupational Radiation Protection (DS453)
detector response to a 2π
surface emission source(ISO-xxxx, etc.) with the
exceptionofthe
ZnS+scintillator
detector,which
appearstobeapproximately a factor of 3-4
too low. As such, the tablevalues are not appropriate forconvertingafield
measurement
totheequivalent surface source
activities stated. To obtain thesurface activity in units of
Bq/cm2, surface attenuation(e.g. films, paint, etc.) andsurface backscatter. Consider
the following algorithm forconverting detector responseto equivalent surface activity.
S0(Bq/cm2)=(RDRB)/εiεs(1 - fb)WD
Where:
RD – detector
response (cps)RB – background (cps)εi – detector efficiency(cps/dps)
εs – surface attenuation
effects (film, coating
WD - detector window area
(cm2)
Note:

the

values65/193forOccupational Radiation Protection (DS453)“calibration factor” in Table 7
are equivalent to the detector
efficiency parameter in theabove equation.

COMMENTS BY REVIEWER
Reviewer:
Donna Newman Director Professional Practice ISRRT
Page...1. of....
Country/Organization:
ISRRT- IRPA
Date:5/28/2014
Comment
Para/Line
Proposed new text
No.
No.
1

Page 4 of262

I.
INTRODUCTION.............................
................... 1
II. FRAMEWORK FOR
OCCUPATIONAL RADIATIONPROTECTION.................................. 3
III. EXPOSURE OF WORKERS IN
PLANNED EXPOSURE

RESOLUTION

ReasonTo
avoid
confusion
between chapter and page
number

66/193

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

R

In conformance withstyle guidelines for
IAEA publications.

Occupational Radiation Protection (DS453)

2

Page 12SITUATIONS.................................. 18
IV. EXPOSURE OF WORKERS IN
EMERGENCY EXPOSURESITUATIONS ..................
................56
X WORKERS’ HEALTHSURVEILLANCE ..........................
185
RESPONSIBILITIESThe government
2.15. The responsibilities of
2.39. For monitoring of the lens of theeye, a depth of 3 mm is recommended
by the ICRU [7],Page 17

Page 213.15. The optimization of protection
and safety should be considered at thedesign stage of equipment andinstallations, when some degree of
flexibility is still available. The use ofengineered controls should be
examined….Add to the section thatwith the advancement in technology
every piece of equipment needs to be
optimized and appropriate shielding
used when it doesn’t hinder thequality of the images
3.17. Management should record
information on the…..add a) Quality
Assurance and administrative
procedure….

Reason Quality assurance
should be included in allcomponents of optimizationfor occupational exposure

67/193R

Unnecessary details

R

Unnecessary details

Occupational Radiation Protection (DS453)

Page 21

Page 24

Add d)_Verification of training,education and competency ofworkers
3.18. The primary responsibility for
optimization lies with management.
Commitment to an effective
protection and safety policy isessential at all levels ofmanagement, but particularly at
the senior level.
Change sentence to read The primary
responsibility for implementation andoversight lies with t management
3.34. In terms of Schedule III of
the BSS, the dose limits foroccupational exposure of workers
over the age of 18 years, are:Subpart C--Occupational Dose
Limits20.1201 Occupational dose
limits for adults.
(a) The licensee shall control theoccupational dose to individual adults,
except for planned special exposures
under § 20.1206, to the following dose
limits.
(1) An annual limit, which is the more
limiting of-(i) The total effective dose equivalent
being equal to 5 rems (0.05 Sv); or(ii) The sum of the deep-dose
equivalent and the committed dose
equivalent to any individual organ or

and also the training plays
into the optimization

Pleaseconsidertheoccupational dose limits
from the NRC in the US asa basis for the safety
standard series section
3.34. I have included theinformation for a reference.
The proposal is too strict
with regards to the limits
they wish to impose which
the institutions have tocompile with if thisdocument and limits are
accepted. The burden on
the individual’s institutions
would be too great. The
limitations
subsequently
imposed upon individuals in
the workforce who workwith radioactive material s

68/193R

The existing text is
more appropriate

R

The paragraph is inline with current BSS

Occupational Radiation Protection (DS453)
tissue other than the lens of the eyebeing equal to 50 rems (0.5 Sv).

would also be too great andtoo limiting. The NRC(2) The annual limits to the lens of the looked at this and haveeye, to the skin of the whole body, and already concluded that thecurrent radiation limits areto the skin of the extremities, whichmore than satisfactory.
are:5rem/ yr is body limit for(i) A lens dose equivalent of 15 rems
occupation exposure is low(0.15 Sv), andenough and further limiting
to 2 rem/yr is to limiting(ii) A shallow-dose equivalent of 50
and so we should considerrem (0.5 Sv) to the skin of the wholeswitching this out to thebody or to the skin of any extremity.
NRC standing.
(b) Doses received in excess of theannual limits, including doses received
during accidents, emergencies, andplanned special exposures, must be
subtracted from the limits for planned
special exposures that the individual
may receive during the current year
(see § 20.1206(e)(1)) and during theindividual's lifetime (see §20.1206(e)(2)).
(c) When the external exposure isdetermined by measurement with an
external personal monitoring device,
the deep-dose equivalent must be usedin place of the effective dose
equivalent, unless the effective dose
equivalent is determined by adosimetry method approved by the
NRC. The assigned deep-dose
equivalent must be for the part of the
body receiving the highest exposure.

69/193

Occupational Radiation Protection (DS453)
The assigned shallow-dose equivalent
must be the dose averaged over thecontiguous 10 square centimeters ofskin receiving the highest exposure.
The deep-dose equivalent, lens-dose
equivalent, and shallow-dose
equivalent may be assessed fromsurveys or other radiation
measurements for the purpose ofdemonstrating compliance with theoccupational dose limits, if theindividual monitoring device was not in
the region of highest potential
exposure, or the results of individual
monitoring are unavailable.
(d) Derived air concentration (DAC)
and annual limit on intake (ALI) values
are presented in table 1 of appendix B
to part 20 and may be used todetermine the individual's dose (see §20.2106) and to demonstratecompliance with the occupational dose
limits.
(e) In addition to the annual dose
limits, the licensee shall limit thesoluble uranium intake by an individual
to 10 milligrams in a week inconsideration of chemical toxicity (seefootnote 3 of appendix B to part 20).
(f) The licensee shall reduce the dosethat an individual may be allowed toreceive in the current year by the70/193

Occupational Radiation Protection (DS453)

Page 31

Page 32

Pg 36

amount of occupational dose received
while employed by any other person(see § 20.2104(e)).
3.73. The accountability system forradiation generators and radioactive
sources should include an inventory
that contains records of the locationand description of each radiation
generator or radioactive source and theactivity and ….. Please add to thisparagraph the following In addition thesystem should include leak testing of
the source before it is first used thenperiodically after to ensure no
removable contamination or leaking
has occurred.

3.77. Work with unsealed radioactive
sources can result in contamination of
the air and surfaces, and this in turncan lead to intakes ……. Add asentence that states consideration indesign to include negative pressure torooms and fume hood with negative
pressure to decrease intake ofradioactivity in the air
Add G) to evaluate adjacent room
when new equipment is installed toensure exposure are correct to the> NRC Regulations (10CFR) > PART 35—
MEDICAL USE OF
BYPRODUCT MATERIALPART 35—MEDICALUSE OF BYPRODUCTMATERIAL
35.67 Requirements forpossessionofsealedsources (2) Test the source
for leakage at intervals not
to exceed 6 months or atother intervals approved by
the Commission or an
Agreement State in the
Sealed Source and Device
Registry
Add to the support to
reduce exposure

To clarify
when newfusiontechnology
isinstalled and shielding is

71/193R

The
proposedadditional text is not
relatedtoaccountabilityRNot
relatedtoclassification of areas

R

Unnecessary detailOccupational Radiation Protection (DS453)
Pg 38

Pg 39

Pg 46

public or worker
Add Conversely, workers handlingradionuclides…. As well as othermedical personal that are caring for thepatient when they are housed in thehospital may need to be monitored aswell.
e) add to end of sentence to include
personal that are caring for the I-131
treatment patient such as nursing staff
ect.
3.141. It is the management’s …….
radiation protection information andtraining add on a annual basis andensure competency

correct
Add information regarding
inpatient i-131 treatment in
hospital setting to provide
monitoring for all personalthat is involved
To ensure you have amonitoring program for all
essential personal included
in procedure that may
receive radiation exposure
To establish that
education needs to beongoing not just once

59 Write a and b in the form of two Too muchreferencedifferent paragraphs
For example:
TABLE 2.
A. Guidance value
guidance
These values apply for:values for(a) the dose from exposure to external
restricting
penetrating radiation.
exposure of ............................andemergency(b) the total dose (effective dose orworkers
equivalent dose ................... as[28]
appropriate. B. HP(10)HP(10) is the personal dose equivalentHP(d) where d = 10 mm. Hp(10) also
represents
Hp(3)................................... (see para.
5.71 of GSR Part 7).
Page
of 262text

72/193foraR

Detailed guidance on
occupational
exposures in medical
practices will be
included in DS399

R

Detailed guidance on
occupational
exposures in medical
practices will be
included in DS399
Covered by 3.140(a).

R

R
GSR Part 7 final
table
will
be
considered in theeditorial process.

Occupational Radiation Protection (DS453)
Page 60 of262
TABLE 3.
criteria forpreventingorminimizing
severedeterministiceffects[28,29]Too many references on
Divide the table in two. For
the same page
exemple:TABLE 3.1. criteria for preventing or
minimizing severe deterministic effects
External acute exposure (<10 h)No.
Appendix F
p. 71

Fundamentals
C. Hazards of exposure toradiation(1.) Verify patient
identification(2.) Explain/Provide patient
instructions

Appendix Ji. p.80

Table taken fromexisting standard andcannot be changed

The patient should comefirst in an examR

Not identifiable
this documentin

Same as aboveR

Not identifiable
this documentin

All allied medical personnel
need to practice goodradiation
hygieneforthemselves and patients.
Provided the refereence for
us Nuclear regulatory limits
for pregancy wondering if
these were looked at also.
Wondering how determinedR

Not identifiable
this document

in

R

Based
on
ICRP
recommendations
and existing IAEA
standards

TABLE 3.2. criteria for preventing or
minimizing severe deterministic effects
Internal exposure from acuteintake (Δ = 30 d)dMove (I.) to the top of the list:
Verify patient identification andprovide patient instructions

Appendix K

Pg.83

R

6. Facilities must provide radiation
safety education annually to all patientcare personnel.
6.11 Please consider below
information to be incorporated in thisparagraph…….
The Nuclear Regulatory
Commission's (NRC's) regulations onradiation protection are specified in 10
CFR Part 20, "Standards for

73/193

Occupational Radiation Protection (DS453)
Protection Against Radiation"; and 10
CFR 20.1208, "Dose to an Embryo/Fetus," requires licensees to "ensurethat the dose to an embryo/fetus
during the entire pregnancy, due tooccupational exposure of a declaredpregnant woman, does not exceed 0.5
rem (5 mSv)." Section 20.1208 also
requires licensees to "make efforts toavoid substantial variation above a
uniform monthly exposure rate to a
declared pregnant woman." A declaredpregnant woman is defined in 10 CFR
20.1003 as a woman who has
voluntarily informed her employer, inwriting, of her pregnancy and theestimated date of
Other sections of the NRC's
regulations also specify requirements
for monitoring external and internal
occupational dose to a declaredpregnant woman. In 10 CFR 20.1502,"Conditions Requiring Individual
Monitoring of External and Internal
Occupational Dose," licensees are
required to monitor the occupationaldose to a declared pregnant woman,using an individual monitoring device,
if it is likely that the declared pregnant
woman will receive, from externalsources, a deep dose equivalent inexcess of 0.1 rem (1 mSv).
According to Paragraph (e) of 10 CFR

The existing language isredundant and the over useof the words “management
andmanager”
areconfusing.
Listing duties makes themstand out better.

In this section in pg you
don’t say deep dose is thiswhat you mean should
include it if so otherwise
confusing

74/193

Occupational Radiation Protection (DS453)

Pg 102

Pg 152

ManagementSystemfor
ProvidersofTechnical
Services
p. 1588.29

20.2106, "Records of Individual
Monitoring Results," the licensee must
maintain records of dose to anembryo/fetus if monitoring was
required, and the records of dose to
the embryo/ fetus must be kept withthe records of dose to the declaredpregnant woman. The declaration ofpregnancy must be kept on file, but
may be maintained separately from thedose records. The licensee must retainth
7.8 a) add after research, nuclear
medicine, PET/CT , Nuclear
Pharmciesb) add after interventional,
cardiology/radiology and nuclear
medicine, PET/CT and Nuclear
Pharmcies
8.10 add k) enviorment where
employee are encouraged to raise
concerns and concerns review
promptly and with feedback given intimely manner
8.29 The organization providing
radiation safety services often
recommend the organization appoint
one person, who in addition to theirregular duties, will act as the
management system coordinator.
The coordinator should haveappropriate experience in the tasks forwhich he or she is appointed and haveTo
technology
where
highest emitting radition
found (Cyclotrons and pet
depts)RA

The existing language isredundant and the over useof the words “management
andmanager”
areconfusing.
Listing duties makes themstand out better.

75/193Covered by existingtext

Already covered inmodified (e)Editorial-will be consideredduring the editorial
process.

Occupational Radiation Protection (DS453)

p.160
8.40

p.161
8.47

8.48

p.162

the authority assigned in writing to do
the following:(a) Develop and coordinate theManagement system, which includes
but not limited to:1.) performing activities designed toensure compliance with relevant
standards;
2.) harmonizing procedures anddocuments;
3.) reviewing operations;4.) identifying and reporting any
non-conformance (i.e. the nonfulfillment of a requirement) to the
management ;5.) conduct training in awareness ofthe management system for the staff;
6.) other duties as assigned
The planning schedule should ensure
traceability of measurement results to
the SI system and establish
information on uncertainties for thesemeasurement results.
For consultancy services
measurements may include:

Existing statement is wordy
and redundant.

Editorial-will be consideredduring the editorial
process.

No
comma
required,
replace “could” with “may”
which indicates giving
permission.
Same as above.

Editorial-will be consideredduring the editorial
process(a) For measurement andcalibration these services thesechecks may include:manage
Customers’ property, including

Redundant use of term

76/193

Editorial-will be consideredduring the editorial
process
EditorialOccupational Radiation Protection (DS453)
8.52

p.164
8.66

8.70

8.71

8.72
p.165

intellectual property , should besafeguarded throughout all the
production processes. This property
and methods to protect it should bespecified in advance. For
example…………..
(a) The person(s) involved in thereview;(b) Factors considered;(c) Decisions reached;(d) Actions planned, the person(s)responsible for the actions and timeschedules decided upon
A corrective action procedure isinitiated:a.) following a complaint;b.) negative feedback received; from acustomer;c.) discovery of non-conformance bystaff;
D.) and/or during an audit.
A preventative action may follow a
corrective action or be taken alone
during the development of new testingor management procedures due to adecision made…
……. The finding will determine if
an informal or extensive formal
investigation
may result.

-will be consideredduring the editorial
process

Clear and concise
Identifies one or more
personmay
share
responsibility.

Editorial-will be consideredduring the editorial
process

Easier to read

Editorial-will be consideredduring the editorial
process

Grammatically
cumbersome

Editorial-will be consideredduring the editorial
process

Less redundant

Editorial-will be consideredduring the editorial
process

77/193

Occupational Radiation Protection (DS453)

DS453
COMMENTS BY REVIEWER
Reviewer:Country/Organization: IRPA/Japan Health Physics Society
Date: 30 May 2014
Comment
Para/Line
Proposed new text
No.
No.
1

After 3.47
(Addition ofnewparagraphs)

RESOLUTION
Page.... of....

SPECIAL CIRCUMSTANCES
3.#1 In special circumstances,provided that a practice is justified andis designed and conducted according
to good practice, and that radiation
protection in the practice has been
optimized but occupational exposures
still remain above the dose limits, andthat it can be predicted that reasonable
efforts can in due course bring theReasonIn the restoration stage
after the nuclear accident,
the recovery workers in theaccident site are forced to
be exposed to relatively
high radiation dose. In suchsituation, a flexible
application of dose
restrictions for workers
should be necessary to
carry out the restoration

78/193

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection
Alreadyanswered(see comment #4 of
WNA)

Occupational Radiation Protection (DS453)
occupational exposures under thelimits, the Regulatory Authority may
exceptionally approve a temporarychange in a dose limitation. Such achange should be approved only ifformally requested by the registrant or
licensee, if the Regulatory Authority
determines that the practice is still
justified and is satisfied thatappropriate consultation with theworkers concerned has taken place.
3.#2 Should special circumstances
exist which require a temporarychange in some dose limitation, theregistrant or licensee may apply to theRegulatory Authority for such atemporary change.
3.#3 No temporary change in a dose
limitation requirement should be madewithout approval by the Regulatory
Authority.
3.#4 The registrant or licensee
should, in any application for a
temporary change in a dose limitation:(a) describe the special circumstances
requiring the temporary change; and(b) provide evidence to demonstrate
that:(i) all reasonable efforts have been
made to reduce exposures andthat protective measures andsafety provisions have been
optimized;

work after accident
reasonably practical. It willbe essentially important thatthe skillful workers who
have experience of thework in early stage after an
accident are allowed tocontinue the restoration
work within a certain
period of time.
The general principles forthe radiation protection ofworkers in accident andemergency situations havebeen provided in ICRP
Publ. 75, which says:- In accident andemergency situations,doses may exceed the dose
limits. (para.60)- If continued exposure ispermitted, it would beappropriate for the
management, in
consultation with theworker, and subject to any
requirements of theregulatory agency, toestablish a formal dose
limitation regime to be
applied for the remainder ofthe control period. A

79/193

Occupational Radiation Protection (DS453)(ii) the relevant employers andworkers, through theirrepresentatives whereappropriate, have been consulted
and their agreement obtained on
the need for a temporary change
and on the conditions of thetemporary change;(iii) all reasonable efforts are being
made to improve the working
conditions to the point where thedose limits specified in para. 3.34
; and(iv) the monitoring and recording of
the exposures of individual
workers are sufficient todemonstrate compliance with therelevant requirements of thisguide and are sufficient tofacilitate the transfer of exposure
records between relevant
employers.
3.#5 Any temporary change in adose limitation should:(a) be in accordance with the dose
limitation for special circumstances
given in para.3.#6;(b) be for a limited period of time;(c) be subject to annual review;(d) not be renewable; and(e) relate to specified work areas.
3.#6 When, in special
circumstances, a temporary change intemporary dose restriction
based pro-rata on theremaining period of time towhich the dose limit relates
might be appropriate.
(para.61)- Consideration also needs
to be given to thesubsequent management ofa worker who as a result ofan accident has received asignificant exposure but
whose total dose for the
relevant period has notexceeded the relevant dose
limit. In those situations
where continuation of
normal working practiceduring the remainder of theperiod may lead to the total
dose exceeding the relevant
dose limit, management
may decide to change theworker’s duties to avoid
this happening. While
recognizing the legal statusthat regulatory agencies
have given to the dose
limits, the Commission
recommends that suchsituations should be dealt
with in a flexible manner.
(para.62)

80/193

Occupational Radiation Protection (DS453)
the dose limitation requirements isapproved in pursuance with para.3.#1
to para.3.#5: the dose averaging period
mentioned in para. 3.34 may
exceptionally be up to 10 consecutive
years as specified by the Regulatory
Authority, and the effective dose forany worker should not exceed 20 mSv
per year averaged over this period andshould not exceed 50 mSv in any
single year, and the circumstances
should be reviewed when the dose
accumulated by any worker since thestart of the extended averaging period
reaches 100 mSv.
2

4.12

The initial phase of a response to anuclear or radiological emergency ischaracterized by a lack of information
about the event, a scarcity of materials
for implementation of protective
measures and the need for urgency inimplementing protective actions.
Therefore, there is little or no scopefor applying the optimization process
when managing the protection of
emergency workers during this initial
phase. Efforts should be aimed at
reducing any exposures as far aspracticable taking into account thedifficult conditions of the evolving
emergency.

- The doses received inemergency situations
should not compromise thefurther employment of theworker in work withionizing radiation.
(para.148)
The additional text is
proposed on the basis of
the prescriptions given in
Appendix I and Schedule IIin the Safety Series 115(previous BSS) regarding
the dose limitation in
special circumstances.
In our experience after the
nuclear accident inFukushima, there was aserious shortage ofprotective tools.

81/193A

Occupational Radiation Protection (DS453)
3

5.21

Reference levels are generally
expressed in terms of annual effective
dose to the representative person in therange 1–20 mSv. However, reference
levels for exposure to radon are
expressed in terms of annual averageradon concentration in air.

4

7.221

Add specific examples of parameters
for calculating the equivalent dose to atissue or organ, or the committed
effective dose.

Section 5 describes
exposure of workers inexisting exposure situations
including exposures fromremedial action in acontaminated area, 222 Rn
and 220 Rn, and cosmic
radiation to aircrew andspace crew. However, thedose range 1–20 mSv is theband of reference level forthe public.
Clarification.
A

COMMENTS BY REVIEWER
Reviewer: The Romanian Society for Radiological Protection (office@srrp.ro) Page 1 of 4
Country: IRPA/ROMANIA
Date: 23.05.2014
Comment
Para/Line
Proposed new text
ReasonNo.
No.
13.128 , lastline

Add: An alternative is to use arecording level established duringauthorization of the monitoring
system.

GENERAL COMMENT
Due to mobility of theradiation workers , ageneral agreement should
exist on the recording and82/193

R

Consistent with BSS
paragraph 5.8 and
5.25

The use of modellingparameters specificto the individual(e.g., the transfer
rates of the systemic
biokinetic model)

RESOLUTION

AcceptedAccepted, but
modified asfollows

RejectedR

Reason formodification/rejectionExisting text is
sufficient.

Occupational Radiation Protection (DS453)

2

3.129

3

3.132 , firstline

4

3.36 , line
1

How to apply this , if the minimum
level of detection is used as recordinglevel ?
As part of authorization process, themanagement….

Average dose over 10 cm2.

reporting levels used byseveral services !!
How to apply this , if theminimum level of detection
is used as recording level ?
All should be decided
within the process ofauthorization of the planned
exposure situation , inagreement with theregulatory authority.
Discrete radioactive particles
contamination events
produce relatively large
doses to very small area ofskin , but they are known toresults in insignificant healthdetriments. It was recognizedthat the shallow dose
equivalent calculated for 1
square centimeter was overly
conservative for DiscreteRadioactive Particles
contamination events. The
assigned shallow-dose
equivalent must be the dosemust be the dose averaged
over the contiguous 10
square centimeters of skinreceiving the highest
exposure. The arguments forthis statement are presented
for example in NUCLEARREGULATORY

83/193R

Issue addressed inparagraph 7.257

RThis is amanagement
responsibility.

R

Text is consistent
with BSSOccupational Radiation Protection (DS453)
COMMISSION 10 CFRPART 20 , RIN 3150-AG25 ,Revision of the Skin Dose
Limit , which provides a
documented justification forusing average dose of 10 cm2, instead of 1 cm2.

57.113 ,
al.(b) , line
1

Accreditation by a relevant authorityof….

6

7.113 al.(c)line 1

Certification by a relevant authority
that….

7

7.254 , line
3..workplace monitoring and healthsurveillance.

8

Page 6

Add : Other relevant authority
2.17 The responsibilities
with regards the protection andsafety of other relevant authorities ,e.g. medical , emergency ,accreditation , a.s.o. , should be clear
defined9

7.3 line 3

Hp(3) and/or Hp(0.07)

Authorization should bedone by regulatory body
based on several
documents emited by otherrelevant authorites for
Authorization andCertification.
See above

R

These are notresponsibilities of
the regulatory body.

R

Coordination of doserecords also with data fromhealth surveillance is very
important.
See : Ministry of Public
Health – Health Surveillanceof Radiation Workers.
National
Accreditation Body –accrediatation of the
management system of
doimetry service , audits
To avoid confusions.
A
Depending on several
factors, only one or two ofthem may be….necessary

R

These are notresponsibilities of
the regulatory body.
Covered by 10.29,
and noting that
medical records are
confidential.
Other
relevant
authorities do nothave responsibilities
forradiation
protection (if they
do, then they arethemselvestheregulatory body)

84/193R

Occupational Radiation Protection (DS453)
10

7.10 , al.(b), line 1..eye lens dosimetry is asuitable….(delete “usually the only”)

1110.2 , line 1….in the proximity of the workplace ,suitable facilities and access for…

12

10.5 , line 2

Delete “where necessary”

13

10.18 , line
2

Put “ophtalmological examination” ,instead of “visual testes”

14

10.29

It would be useful to preserve all
worker records in agreement with
7.269

(not all !).
For a separate lensdosimetry , the conditions
from 7.7. and 7.8 shouldbe met.
It was mentioned in the
text above (7.10) andbelow (“b” , (ii)) that ,actually , for dose
determinations in photon
radiation, other methods
are available too (not only
the separate”…!).
Actuall , a small workplacein the vicinity do not
need…a suitable medical
facility. It is enough tohave access to an
appropriate facility (locatedin the proximity).
All mentioned topics arealways …necessary.

Comments
iscovered by the use
of
the
word
“usually”

R

Current text is more
appropriate

A

Only by this type of A
examination
the
len’s
opacities can be detected
It would be useful topreserve all worker records
in agreement with 7.269

Occupational Radiation Protection Draft Safety Guide DS453

85/193R

through training
and, whennecessary,
retraining

R

Existing
adequate

text

isOccupational Radiation Protection (DS453)
COMMENTS BY REVIEWER
Reviewer: Swedish Radiation Safety Authority, Sweden
Page 1 of 7
Country/Organization: SWEDEN
Date: 2014-06-22
Comment
Para/Line
Proposed new text
ReasonNo.
No.

RESOLUTION

AcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejectionR

It is anquotation.

ongoing

Reference
ICRP103
necessary.

tonot

GENERAL
The document is well written and isrelevant and useful – particularly when
considering the generational shift in theradiation protection field.

1.

Page 3, 2.1,
(i)

2.

Page
2.34

10,

The scope of the safety guide covers
all aspects of occupational exposure aspresented in the International BSS GSR Part 3. However, the protectionof “volunteers” in emergency exposure
situations (as pointed out in 4.4) is notcovered in this safety guide.
The advice of the drafted guide covers
the consensus in the field and has been
updated to include the developments
and valuable references from the last
10 years (recommendations, ISOstandards, development in dosimetry,other measuring technology etc.)
without being too detailed.
Change the end to read:“…operating procedures and bytraining.”
Instead of: ”The term collective
effective dose…´´´and …expressed inthespecialname ‘man-sievert

The end quotation mark is
missing at the end of 2.1 (i)ICRPstill referstocollective dose as a‘quantity’ measured in the

86/193A

Occupational Radiation Protection (DS453)(man Sv)’ consider using, compatible
with ICRP; The quantity collective
effective dose (ICRP 103, B.5.9)…
and …in the unit with the specialname ‘man-sievert’ (manSv)

unit ‘mansievert’ (and also
continues to warn against
summing
up radiation
exposures over a wide
range of doses, over very
long time periods and overlarge geographical regions,and to calculate on thisbasis
radiation-related
detriments).
It
seems
somewhat A
conflicting to (8) since thenumerical factor 1.2 for the
standard breathing rate
(m3 /h) is missing.
For clarity (units are used a A
bit incoherent in (15) and(16) – consider review
when units are used andnot.
The statement as written
could be read that theprotection of the worker isless important than theprotection of the patient
and the clinical outcome.
These factors must be
considered at the same
time?

3.

Page
2.60

15,

The last sentence: By definition, 2000
DAC.h corresponds to an intake ofIinh,L. could be confusing.

4.

Page
2.70

17,

Suggests changing the last sentence to:…are simply related by a constantfactor of 5.56 x 10-9 J/Bq.

5.

Page
3.13

20,

6.

Page
3.15

21,

The formulation seems a bit negative.
Consider using a more neutral
formulation, such as:
Considered options in the optimizationof protection of workers should notlead to undue exposure of others or, inthe medical field, unacceptablereduction in the protection of thepatient or the efficacy of the clinicalprocedure.
Delete the word more in:
There is no logical reason A
In the nuclear industry, situations are way an approach is lessmore complicated, and a more structured just because it is87/193The sentence is notconflicting to (8), but
it is actuallyconfusing and isdeleted.

R

Current
text
consideredappropriateisOccupational Radiation Protection (DS453)
7.

Page
3.25

22,

8.

Page 30,
3.64(f),
and (g)9.

Page 36,
3.94 (j)

10.

Page
3.116

41,

structured approach is needed….
simpler?
Consider deleting the word more in the Same argument as above A
beginning of the sentence:but also the word (more) is
not needed here if referral
A more structured approach to the is not made to something
selection….
that is less structured….
It is not clear that Industrial Safety andIndustrial Hygiene only relates toradiation protection?
If this is not the case the qualificationsof the experts in these areas might not
be solely be determined in the RPP?
Clarify!
Change from (j) Conventional safety For clarity - although the A
to (j) Co-ordination with protective work with planning andmeasures for conventional safety
implementing
protective
measuresisusuallyintegrated at facilities andregistrants, the BSS isabout RP?
The second sentence: An assessment
should certainly be conducted if thetotal annual effective dose is expected
to exceed 5 or 6 mSv for instance
seems
odd?
This
kind
of
considerations seems more appropriate
when controlled and/or supervised
areas are set up.

The BSS states that “Forany worker who regularly
works in a supervised areaor who enters a controlledarea only occasionally, theoccupational exposure shallbe assessed on the basis of
workplace monitoring or
individual monitoring, as
appropriate” this would
seem to mean that an

88/193R

A

Current text is clear
and appropriate.

The second sentence
can be removed.

Occupational Radiation Protection (DS453)

11.

Page 47,
3.146

12.

Page 51,
3.162 (a)Suggest changing the last sentence:…, a qualitative discussion of thetrivial risk from the minimal exposure
they may receive and specificdirectives
regardingprohibited,
required or recommended actions.
It is stated that the adoption of thegraded approach to regulation isparticularly important for industrial
activities involving NORM because of :(a) The economic importance ofmany NORM industries
This is a very surprising statement andshould be deleted or better explained.

13

Page 55,
3.178

It is stated that: In situations where theradionuclide activity concentrations in
the materials being handled aremoderate, it is important to recognizethat the silica content of the airborne
dust is likely to be of greater concern
for occupational health than theradionuclide content.

assessment
isneededregardless of the expected
effective dose (assumingthat the ones regularly
working in controlled area
have
individual
monitoring)?
Avoid using these value A
judgements since even if in
most cases the incurred
doses indeed are low they
could be significant (whyotherwise give advice?)
It is difficult to see that thisis something special for
NORM industries? Nuclear
power
production,
hospitals, the use ofradiation
sourcesinindustry etc
isalso
importantfornational
economy (and a gradedapproach should by theway better be applied also
there)?
For clarity – we presume
that the protective actions
against silica would be
beneficial also to radiation
protection and that this was
the intended message?

89/193R

NORM industries
differ from the otherindustries mentioned
in the examples,
because the issue of
regulation is often
borderline.

R

Suggested changing
does not improve
clarity.

Occupational Radiation Protection (DS453)
Suggest changing this to:
In situations where the radionuclide
acitivity
concentrationsin thematerials being handled are moderate,
the silica content of the airborne dust
could still require that protective
actions are required from an industrial
safety point-of-view (e.g. protective
masks, ventilation) which also would
reduce any intakes of radioactive
material.
14.

Page
56,
4.2 – 4.4

15.

Page 59-60

Retain the original Table IV-2 andTable IV-1 from the BSS or remove
the guidance values for fetus underlive saving actions and actions toprevent severe deterministic effects:
Hfetus < 100 mSv (e.g. harmonize withrecent updates of GSR Part 7).

We appreciate that IAEA
finally realizes that the
introduction of the term
emergency worker did notcover all workers exposed
during emergency exposure
situations. This improve on
the limited thinking of GSR
Part 3. As written in 4.4,
“volunteers”
arenotcovered by the guide andthis is regrettable.
It would seem more proper
to retain the original Table
IV-2 and Table IV-1 fromthe BSS since these are theones agreed and publishedin the GSR Part 3?? It isquestionable if new tables
should be included in theguide?
In any case it seems not

90/193Rwithmodificati
ons

Helpers in emergency
are members of the
public and may be
more appropriate for
GSR
part
7.
However, footnote3,
modified in line with
the GSR Part7.

We have to take theTable as it is.
BSS table will be
retained, however,the final table fromGSR Part7 will beconsidered during theeditorial process.

Occupational Radiation Protection (DS453)

16.

4.28,
Page 63

4.28 is identical with 4.19 inInternational BSS but the “shall”
statement of the GSR Part 3 ischanged to a “should” statement.
We suggest to keep the formulation of
the requirement document and toquote 4.19 of the BSS “withinbrackets” as done in many places ofchapter 3 of the guide.

17.

18.

properhave
pregnant
women to carry out suchwork!?
In this way also theimportant latter part of 4.19
will be kept, e.g. However,qualified medical advice
shall be obtained before
any further occupational
exposure if a worker hasreceived a dose exceeding
200 mSv or at the requestof the worker.
In general we think it is notadvisable to change “shallstatements”
fromtheSafetyRequirement
document into “should
statements” in the Safety
Guide . – check this in thefull text!
The Safety guides is about
workers(occupational
exposures)
andanyexposure during work is
defined as occupational
exposure according to GSRPart 3 (BSS)

4.30, Page Change the last sentence to read:
63
However, qualified medical advice
should be obtained before any further
occupational exposure if anaemergency worker or accidentally
exposed employee has received a dose
exceeding 200 mSv or at the request of
the worker.
4.31, Page The last sentence of 4.31 is very It seems desirable to use
63
strange. Either a referral is made to the structure of IAEA:s

91/193A

4.28 can beeliminated, as it is not
relevant for dose
assessment and isalready covered by
4.30.

R

Current text is
adequate.

R

Publication of GSR
Part 7 is anticipatedOccupational Radiation Protection (DS453)
GSR Part 3 (this is apparently a guideto GSR Part 3) or to another guide if
the word should is used!
If referral to GSR Part 7 (GS-R-2?)
should be made the word shall should
be used:….protective actions and other
response actions shall be taken inaccordance with GSR Part 7
19

Page
65,
5.9 (b)20

Page 71,
5.42 (b)21

Page 92,
6.63 (d)22Page 107,
7.25

standards(requirementswith shall statements andguideswithshouldstatements).

GSR Part 3 is decided andaccepted by all cosponsors - GSR Part 7 isstill a draft document notdecided on.
The IAEA BSS (GSR Part 7) defines Follows the GSR Part 3
regulatory body as an authority or a definition and the IAEA
system of authorities designated by the Glossary.
government of a State as having legal
authority for conducting the regulatory
process,
includingissuingauthorizations, and thereby regulating
nuclear, radiation, radioactive waste
and transport safety. The footnote 6 is
not in coherence with this definition –use regulatory body!
The term “good engineering practice”
seems a bit judgmental – could this be
written in another way?
Waivers? – Please explain in what way Does only seem to be athis constitutes a compensatory wayofnottakingmeasure?
responsibility in a legal
correct way?
Something seems wrong with the Do not understand how
sentence:
one can use a dosimeter in“a set of radiation field
The choice of a dosimeter for use in a parameters”?
particular set of radiation field

92/193in the near future.
The issues raised will
be in any caseaddressed during the
IAEA
editorial
process.

R

R

It is a widely
accepted term.

A

Delete (d)A

The choice of adosimeter for use ina particular set ofradiation fieldparameters mayOccupational Radiation Protection (DS453)

23

Page 133,
7.163

24

Page 137,
7.188(b)25

Page 139,
7.195

Final

parameters may require a particular
normalization factor to be applied inorder to minimize errors in themeasurement of Hp (10) and in theestimation of effective dose.

Furthermore, how can a“particular normalization
factor” minimize errors?

Suggest changing the second sentence:
Such a laboratory may also be used
for measuring environmental samples,but high level measurements (e.g.
measurements ofreactor waterchemistry) and low level measurements(e.g. bioassay or environmental
sample measurements) should be
performed in separate laboratories.
The identification of “rogue data” –please explain the meaning or choose
another word

In order to make the A
sentence clearer – it isotherwise a bit confusing!

require a particular
normalization factor
to be applied inorder to minimize
errors uncertainties
in the measurementof Hp (10) and in theestimation ofeffective dose.

Please explain!

The term “rouge data”
seems too technical to begenerally understood –perhaps an explanation
should be included in afootnote?
Consider introducing a reference to For clarity.
page 13! ...according to the scheme
presented in Fig. 2 (page 13) andparas 2.49-2.54.
We find the material in A
Appendices I-V to be mostuseful and appreciate its
inclusion in the draft Safety
Guide!

93/193Replace “rogue data”
with “outliers”
IAEA editor will fix
in the final editing.

A

R

Not necessaryOccupational Radiation Protection (DS453)

COMMENTS BY REVIEWER
Reviewer: Ondrej Kvasnicka, Radim Figalla
Page 1 of 1
Country/Organization: CZECH REPUBLIC
Comment
Para/Line
Proposed new text
No.
No.
1

3.15/4-6

In
image guided interventional
procedures, for example, where there
is potential for workers to receive asignificant dose to the lens of the eye,attention should be paid to theinstallation of fixed shielding and to theselection of equipment.

RESOLUTION
Date: 2014-05-26
ReasonAccepted

To minimize the dose to thelens of the eye is in directAcontradiction to
optimization principle.

94/193

Accepted, but
modified asfollows

Rejected

Reason formodification/rejection
Acceptproposed
3.15

text

new
for

Occupational Radiation Protection (DS453)
2

3.116/4-5

3

9.16

An assessment of the exposure ofindividual workers should beconsidered in normal and foreseeable
abnormal conditions if, for any single
component of the exposure (e.g.
strongly penetrating photon irradiation,neutron irradiation, internal exposure),
the corresponding annual effective
dose is expected to exceed 1 mSv.
Consideration should also be given to
the likelihood and possible magnitude
of potential exposures.
For the effective operation of primary
and auxiliary ventilation systems in a
facility:(b) Ventilation is an important safety
related system. For the safety of theworkers, all important systems suchas fans, blowers, HEPA filter systems
etc should have stand-by systems foruse during maintenance activities. Allsuch sensitive systems should be
operable with alternate power supply(like diesel generators) where
necessary so that process systems canbe shut down safely while allmonitoring systems will continue towork.

The combination should A
certainly – for instancedoesn’t
supportcomprehensibility of the
text.

This is generally very
difficult to implement.
Most of the “ventilation”
paragraphs are describing
the situation in mines,
although explicitly it isstated only by few of them.

95/193

See comment
from Sweden.

A- includes response
to UK comment 52

10b) Ventilation is an
important safety
related system. For
the safety of theworkers, allimportant equipment
such as fans,blowers, HEPA filter
systems,
consideration should
be given to theprovision of etc
should have stand-bysystems including All
such sensitive
systems should be
operable withalternate power
supplies (like diesel
generators) where
necessary. In thisOccupational Radiation Protection (DS453)
way process systems
can be shut downsafely during
maintenanceactivities while allmonitoring systems
will continue towork. Consideration
should also be given
to real time indicatorsof system
performance to alert
operators of exhaustsystem failure or
malfunction.

96/193

Occupational Radiation Protection (DS453)
COMMENTS BY REVIEWERCountry/Organization: IRAQ / Ministry of Science & Technology (MoST)/
Radiation & Nuclear Safety Directorate (RNSD)
Date:
Comment
No.
1

2

3

4

5

6

Para/LineNo.
Para. 5.78
Line 1

Proposed new text
6100-12200 m

Reason9000-12000 m
7500-10000 m

We should cancel
space between thenumbers

7.2
Line 1

Where individual monitoring ofworkers is to be performed, eachworker before monitoring should
be provided with an integrating
personal dosimeter.
And can give information ondose rates and determine thetype of radiations. Such adosimeter can be useful for
optimization purposes.
While an active dosimeter isusually used for purposes ofdose control, and an indicator
for the presence of radiation in
the region, it can also be usedwith prior approval from
regulatory body.
In certain cases

To be more clarified

7.5
Line 1

7.6
Line 1

AcceptAccepted, but modified asfollows

We should cancel
space between thenumbers

Para 5.79
Line 2,6

7.4
Line 4RESOLUTION

RejectReason for modification/rejection

R

Editorial: Conformance with
Agency style
Editorial: Conformance with
Agency style, The space in000” should be deleted

A

R

This change is not needed

R

Proposed text is not correct

R

Proposed text is not correct

To be more clarified

To be more clarified

To be more clarified
R

97/193“In most cases” is correct“9Occupational Radiation Protection (DS453)
Country/Organization: Iraq/ Ministry of Science & Technology (MoST)/ Radiation& Nuclear Safety Directorate (RNSD)
Date:
Comment
Para/Line
Proposed new text
ReasonNo.
No.
— for example in medical uses of7
7.7
To be more clarified
radiation, where protective clothingLine 3RESOLUTION
Acceptsuch as lead aprons can be used and thethickness of lead aprons is known toreceive the dose allowed by the use ofsuitable algorithms —it is advisable touse one dosimeter under the protective
clothing and one on an unshielded partof the body. T he readings from thetwo dosimeters can then be combined
to give an estimate of the total
effective dose. T here are manyalgorithms available, and the accuracy
depends on many factors such as the
thickness of any lead apron worn, theuse of a thyroid shield, and exposure
parameters. Further information on
the use of such algorithms can befound in Refs [42–44].

8

9

7.10
Line 16

8.31

10
2.24

(i) If the radiation field isinhomogeneous, the dosimetershould always be located near
the eyes, and in contact with theskin and facing toward theradiation source;
Process of equipping andupdate individuals with theunderstanding, skills and accessto information, knowledge andtraining that enables them toperform effectively
management system
That are needed to achieve thegoals, provide the means to meet
all requirements and deliver the
products of the organization shallbe identified, and theirdevelopment shall be planned,
implemented, assessed andcontinually improved.

Accepted, but modified asfollows

RejectR

Reason for modification/rejection

Proposed text is not correct

To be more clarified
R

Proposed text is not correct

Human resources
R

This level of detail is unnecessary

management system

98/193R

Covered by 2.26

Occupational Radiation Protection (DS453)
Review of IAEA DS453 Occupational Radiation Protection
COMMENTS BY REVIEWER
Reviewer: CANADA
Page 1of 3
Country/Organization: CANADA
Date: June 20, 2014
Comment
Para/Line
Proposed new text
ReasonAcce Accepted,
No.
No.
pted
but
modified
as follows
Red strikethough are recommended deleted text.
Green are proposed additional or new text.
See previous sub-version for original industry comments and my proposed edits (MM).
1
2.3.4
Replace “man-sievert” in the following Replace “man-sievert” intext with “person-sievert”:
the current text with
The term collective effective dose may “person-sievert”, as it more
be used as an instrument for
accurately describes the
optimisation, for comparing
modern work force
radiological technologies andconsisting of men andprotection procedures. These quantities womentakes account of the exposure of all
individuals in a group over a given
time period or during a given
operation executed by this group in
designated radiation areas. The
collective effective dose is calculated
as the sum of all individual effective
doses over the time period or during
the operation being considered andexpressed in the special name ‘man
person-sievert (person-Sv)’.
2
3.5
A fuller description and perhaps
Acknowledging thatclarification of paragraph 3.78 of theparagraph 3.78 of the BSS
BSS would enhance Draft Safety
describes the concept that
Guide DS453.
employers, registrants and99/193RESOLUTION

Rejected

Reason for modification/rejectionR

ICRP still uses man-SievertR

Present text is clear

Occupational Radiation Protection (DS453)

3

3.110

Proposed revised text for thisparagraph:
For visitors making short andinfrequent visits to controlled areas,
individual monitoring may be
performed but is not necessarily
required. However, a record of theradiological conditions of thecontrolled areas visited (for example,
data from workplace monitoring orfrom individual monitoring of thevisitors’ escort) and the length of timespent in these areas during the visits
must be retained.

licensees must ensure thatworkers exposed toradiation from sources
within a practice that are
not required by or directly
related to their work areafforded the same
protection against such
exposure as a member ofthe public, the document
may benefit from further
clarification on thisconcept.
As currently written, thetext in 3.110 iscontradictory, in that it isstated that individual
monitoring and record
keeping is not necessary
for visitors making shortand infrequent visits tocontrolled areas. But, it isthen further stated thatessentially some record to
support the assumption that
there was no likelihood of asignificant exposure must
be made. This, in turn, is aform of ascertaining andrecording a dose to thevisitor in this instance.
Also, “significant
exposure” is not defined in

100/193A

For visitors making short andinfrequent visits to controlled areas,
individual monitoring may be
performed but is not necessarily
required. However, a record of theradiological conditions of thecontrolled areas visited (for example,
data from workplace monitoring orfrom individual monitoring of thevisitors’ escort) and the length oftime spent in these areas during thevisits should be retained.

Occupational Radiation Protection (DS453)

4

7.270

Delete clause 7.270 and add ‘personalmonitoring equipment to clause 7.272.

5

Section9.56(j)Delete the indicated text below.
Respiratory protective equipment
should be examined, fitted and tested
as appropriate by a competent person
before being issued for use and at least
once every three months when in use;the current text, so it is notclear how to base thedecision for not performing
individual monitoring andrecord keeping.
The primary record ofinterest is the doseassignment record. The
maintenance of calibration
records for personalmonitoring equipment foran extended period may
impose a significant
operational burden withlimited added safety value.
Challenges or investigationsof individual doseassignments are usuallytimely and within a few
years. Recommend use ofa retention period for
personal monitoring
equipment which is alignedwith that of calibration
records for workplacemonitoring equipment..
Staff should be trained andfit tested for respiratory
protection; this is alignedwith “(b) Management
should ensure that the
respirators fit and are usedproperly.”

101/193R

It is important to keep the calibration
records for personal monitoring for
longer periods

A(j) Respiratory protective equipment
should be examined, fitted and tested
as appropriate by a competent person
before being issued for use and at
least once every three months
periodically during use; the results ofOccupational Radiation Protection (DS453)
the results of these examinations andtest and details of any repairs should
be entered in a permanent register,which should be kept for the period
specified by the regulatory body.

6

Section 10,
Workers’
HealthSurveillance

It is recommended that this be worded
such that the management has the
responsibility to see that the following
health surveillance services areprovided either directly by theemployer or indirectly by State or
governmental institutions.

If the end user examination
finds that the protective
equipment is defective,then the item should besegregated and returned formaintenance. The increase
operational burden ofregistering the examinations
performed by the end user
and the record retention do
not provide increased
safety.
Maintenance records,
including repair, should be
kept when appropriate.
In many jurisdictions,health surveillance isindependently performed
and provided bymanagement andgovernmental bodies.

102/193

these examinations and tests anddetails of any repairs should berecorded which should be kept forthe period specified by the regulatory
body;

R

The present formulation is adequateOccupational Radiation Protection (DS453)

COMMENTS BY REVIEWER
ReviewerCountry Organisation:

UNITED KINGDOM

Comment
Nr

Para Nr. &Line

Proposed new text

1.

Relev
ance andusefulness —Are the statedobjectives
appropriate,
and are they
met by the
document?

Not Applicable

RESOLUTION

Date: 19 May 2014
ReasonAcce Accepted Rejec
pted modified ted
as follows

Relevance and usefulness —Are the stated objectives
appropriate, and are they met
by thedocument? – Yes

103/193

Reasonif modified/rejectedOccupational Radiation Protection (DS453)
2

3

Scope andNot Applicable
completeness— Is thestated scope
appropriate,
and is it
adequately
covered bythedocument?
Quality and Not applicableclarity — Dotherequirements/
guidance inthe document
represent thecurrent
consensus
amongspecialists inthe field, andare they
expressed
clearly andcoherently?

Scope and completeness — Is
the stated scope appropriate,
and is it adequately covered bythedocument? – Yes.

Quality and clarity — Do therequirements/
guidance in the document
represent the current
consensus
among specialists in the field,
and are they expressed clearlyand coherently? – Yes.

104/193Occupational Radiation Protection (DS453)
4

GeneralNot applicable

5

GeneralNot applicable

6

Efforts
Replace 'limit' withshould be'optimised'made to limit
the degree ofcontaminatio
n and the size
and numberofcontaminatedareas within afacility.

7

2.2…and some exposures due
to natural sources andresidual activity resulting
from man-made events…

This document provides
sensible information andguidance on the “Occupational
Radiation Protection”. The
document is longwinded inachieving its objectives andcertain sections are very
detailed, but the guidance
generally appears to be sound.
The scope and content of the
document in some places is at avery detailed technical level
which may be better
reproduced elsewhere.
Should be 'optimised' rather
than 'limited' as UK designate
on potential as internal doses
are informally restricted to nil
i.e. zero tolerance concepts on
intakes

9.29: “Efforts should be made to control contamination andthe size and number of contaminated areas within afacility. “A

These are just examples
Existing and planned exposure
situations are not limited tonatural sources

105/193R

Occupational Radiation Protection (DS453)
8

2.10,3.20

9

2.18

10

2.23

11

3.11(b)Clarification for medical
practitioners

need clarification about medical
practitioners using equipment
as opposed to those undergoingtreatment.
…are responsible forConstraints are a component of
ensuring that protection and optimization (see 3.8 (b))
safety is optimized byapplication of constraints
and dose limits, and thatappropriate RPPs are
established andimplemented.
For occupational exposure Scope of statement shouldin planned situations andinclude existing exposuresome existing exposure
situations
situations, the principle party
is the employer.
process with the following Additional components ofsequence: planning, setting optimization approachobjectives, assessment ofpotential hazards,
implementing the necessarycontrols, monitoring…

106/193A

See comment 3 from USA/IRPA

R

Optimization is separately addressed elsewhere

R

This would introduce confusing: existing exposures
are covered in the second sentenceR

The additions are not examples of the “management
by objectives” processOccupational Radiation Protection (DS453)
12

13

3.18

3.19,3.59

14

3.25

15

3.38(b)

16

3.43

17

3.44

Management has the
Essential component ofresponsibility to ensure that management commitment
adequate resources areavailable to enablesatisfactory execution of the
RPP.

Given the IRPA initiatives on
ethics, Stakeholder engagement
and RP Culture, could a section
be added on these?
Observation, additional bullet John Croft (formerly
point as a) use checklists to NRPB/HPA/PHE) has carried
generate options
out work with the EU on
ALARA ‘ALARA . I suggest
some of his ideas could beincorporated into the section
e.g use of checklists togenerate options or refer out tohis bookAn equivalent dose to the
To be consistent with the doselens of the eye of 15mSv in limits in Article 11, paragrapha year;3(a) of Council Directive
2013/59/Euratom.
…the single year effective For clarificationdose limit of 50 mSv…

A
The commitment of management should bedemonstrated by written policy statements thatmake radiation protection criteria an integral part ofthe decision process, and by provision of adequate
resources, and clear and demonstrable support for
those persons with direct responsibility for radiation
protection in the workplace.

Observation

to keep within the effective
dose limit of 100 mSv

For clarification

Stakeholder engagement and safety culture arecovered in the relevant sections…

R

Unnecessary detailR

Consistency with BSS

Editorial– will be considered in the editorial process
Editorial– will be considered in the editorial process

107/193Occupational Radiation Protection (DS453)
18

3.54(f)An assessment of potential To address the potential of
public exposures inunauthorized individuals notuncontrolled or unrestricted considered radiation workers
areas and resulting from
effluents from the facility

R

Unnecessary detail

19

3.56

A radiological evaluation
Management of change is ashould be conducted prior to critical component of radiation
any new or modified
protection programs
operations as part of acomprehensive health andsafety management ofchange process.

R

Comment is not relevant here, and it is covered in
3.58

20

3.63

…depending on the size ofthe organization, as well as
the size and complexity ofradiological operations, tocreate a specific advisorycommittee…

21

3.70

The need for an advisorycommittee is commensuratewith radiological operations

The appointed expert should Changes with radiation
be consulted for review of protection impact require
any proposed changes toreview by qualified expert
facilities, operations andpersonnel with potential
impact on radiation
protection.

108/193

A
3.63. In order to coordinate decision making
concerning the choice of measures for protection
and safety, it may be appropriate, depending on thesize and complexity of the facility, to create a
specific advisory committee with representatives of
those departments concerned with occupational
exposure.
A
3.70. Management should consult the appointed
qualified experts as appropriate on aspects of the
RPP, including the designation of controlled andsupervised areas, the preparation of local rules, theprovision of personal protective equipment and thearrangements for monitoring of the workplace andworkers, and on any subsequent changes having asignificant impact on protection and safety.

Occupational Radiation Protection (DS453)
22

3.73

This inventory has to be
updated and verified
periodically.

23

3.81

…physical barriers involving Additional emphasis to address
locks and interlocks may be exposed sources and active
practical to install andequipment in unattended
operate and may be required situations
already for security reasonsand to control access tounattended sources andradiation emitting equipment.

24

3.88

(m) Emergency response

For completeness

A

25

3.93

When work is to be
conducted during whichsignificant radiation orcontamination levels may be
encountered…

The term “significant” issubjective and needs to bequantified for clarity, forexample three tenths of therelevant dose limit.

A

26

3.106

27

3.113

Verification is required toensure accountability

Clarification,

Bulk Pu has an external dose
rate
Corrective actions should be For completenesstaken as necessary anddocumented.

109/193A

R

Unnecessary detail(m) Emergency preparedness and response, whereappropriate“The RPO should take part in the planning of thework involving significant exposures, and should
advise on the conditions under which work can beundertaken in controlled areas. “RR

It is an example which is not specifically referring tobulk Pu
It is covered in (e)Occupational Radiation Protection (DS453)
28

3.118

…whether there is apotential for significant
individual exposure…

29

3.144

30

3.150

Where work involving
significant exposure toradiation is to beundertaken…
Formal records of eachIs this a minimum requirement?
worker’s training and testing Some local regulation may
should be maintained, andrequire longer retention
retained for three years after
cessation of employment

31

3.176

…a suitably qualified
ventilation expert..

32

4.15

Observation

The term “significant” issubjective and needs to bequantified for clarity, forexample, three tenths of therelevant dose limit.
The term “significant” issubjective and needs to bequantified for clarity

The term “officer” is overly
prescriptive (and an odd
wording) when in most
locations only a qualified expert
is needed
Use ICRP 60 dose values to'save plant' and advert public
exposure

110/193

R

What is significant is a local judgement

R

What is significant is a local judgement

A“Formal records of each worker’s training andtesting should be maintained, and retained for an
appropriate period after cessation of employement.”

R

Ventilation officer is a standard term

R

Follow GSR7, see previous commentsOccupational Radiation Protection (DS453)
33

4.16 table 3.

34

5.6(2)

35

5.41 :

Clarification, Observation

Although the acute radiation
effects
0.2 Gysyndrome
for radionuclides
and otherwith Z≥90e
effects
2 Gy forat doses
radionuclides> 1Gy arewith Z≤89e
difficult to estimate, and as arough order of magnitude
guidance is useful, thescientific basis for actinides
having a lower dose for thiseffect needs consideration as
there has been one case of
exposure to an alpha emitter(210 Po) where deterministic
effects have been observed atorgan level
Workers exposed during
Planned and existing exposureplanned operations as part of situations may overlap in somethe existing exposure
scenarios
situation…

R

Follow GSR7, see previous comments

R

The overlap applies only to 5.6 (1)Observation

R

Already addressed in the paragraph:affected“

As part of ethics andstakeholder engagement, needto consider involving publice.g. get buy in (learning from
Chernobyl and Fukashima
Dachi)

111/193“partiesOccupational Radiation Protection (DS453)
36

5.60

In general, the reference
To be consistent with the doselevel for workplaces should limits in Article 54, paragraph 1
not exceed an annualof Council Directive
average radon concentration 2013/59/Euratom.
of 300 Bq/m3 [2]. Thisvalue corresponds to anannual effective dose of theorder of (would needamending if reference level
was reduced), assuming anequilibrium factor of 0.4 andan annual occupancy periodof 2000 h.

R

Current values are consistent with BSS

37

5.60

R

Footnote 3 is on emergencies

38

5.77

Editorial comment –footnote number 3&7
appear inconsistent
Exposure to individuals to
For clarification
cosmic radiation above
ground level is notconsidered occupational
exposure when the exposed
individual is travelling by air
for business purposes.

R

This can be occupational exposure but notnecessarily warranting control

39

6.38

(f) Details of controls thatare the responsibility of the
facility to ensure
optimization of exposure

For completenessA(a) Details of any radiological hazards andassociated controls, and an estimate of the
maximum radiation doses likely to be received by
the contractor’s employees during the contract;112/193Occupational Radiation Protection (DS453)
40

6.64

h) Changes in facilities,
For completeness
operations or work practices

A

41

6.87

For completenessR

Too much details, and does not apply only toitinerant workers

42

7.21

Training should be provided
to address the need to avoid
exposure of the dosimeter
while it is not being worn,
including inadvertent
exposure to sources orradiation equipment andexposure to security x-ray
while left in a checked bag
during travel.
It is preferable to prevent
localized exposure to theextremities by avoiding
direct handling of sources
and by employing
appropriate shielding andremote handling devices.

To address situations, such as
nuclear medicine and nuclear
pharmacy where it is difficult
to assess extremity dose due to
direct handling of sourcesR

Not relevant for this section

43

7.142

Particle size of thecontaminant to be sampled
must be considered toensure selection of theappropriate filter.

This is critical to proper air
sampling of particulates

R

Particle size is adequately covered in different
sections

44

7.193

(n) Differences in quenching For liquid scintillation counting
between sample andcalibration standard

113/193Ah) Any changes in facilities, operations or work
practices(n) For liquid scintillation counting, differences inquenching between sample and calibration standardOccupational Radiation Protection (DS453)
45

46

7.232

9.8 and 9.9

For extremity dosimetry in A depth of 0.07mm is a more
emergencies, especially for standard assessment of
the hand, a simple, single
equivalent dose to the skin andelement dosimeter should be extremities as recommended in
sufficient. For the best
ICRP 116 and therefore
accuracy in measuring low dosimetry measuring Hp (0.07)
energy beta radiation, theis readily available. While a
detector should be thin and depth of 0.4mm may be seen
filtered by a thickness ofas an appropriate assessment
tissue substitute such thatfor emergencies, arethe dose at a nominal depth dosimeters measuring Hp (0.4)
of 40 mg/cm2 (or 0.4 mm) readily available for use incan be assessed (see para. emergencies? If not, can an
7.230(c)).
alternative be given in thisguidance e.g. would Hp (0.07)
or Hp (10) be a suitable
substitution (as with lens of theeye dose measurements inparagraph 7.230(b))?
Guidance and/or a
To address needs for shieldingreference is needed here on beta particles
elsewhere in this TECDOC
regarding shielding
requirements for beta
emitting materials

114/193A

Additional text added:
However, if such dosimeters are not readily
available, suitable alternate methods using Hp (0.07)
or Hp (10) dosimeters may be used.

A
9.9. Shielding should be considered in work
involving X rays, gamma rays, neutrons and otherhigh energy particles (which may include highenergy beta particles).

Occupational Radiation Protection (DS453)
47

9.9

48

9.23

49

9.8 and 9.9

Observation
Need to demonstrate ALARP
It is common practice forrather than specific cases
dose rates to be restricted
such that, for an assumed
annual exposure period of2000 h, the annual doses
would not exceed 5 mSv incontact with the shield and 1
mSv in the vicinity ofexperimental hutches along
the beam lines.
Any spillage of radioactive consider use of reasonably
material should be cleaned
practicable as opposed
up as soon as practicable in practicable as in the event of aorder to minimize the spread spill, consideration should beof contamination. The area given to control of incident,
should be decontaminatedappropraite PPE/RPE forby the removal of all loose cleaning up spill and doseradioactive contamination
associatedand contaminated materials
as much as practicable.
Replace 'practicable' with'reasonably practicable'
Guidance and/or areference is needed here on
elsewhere in this TECDOC
regarding shielding
requirements for beta
emitting materials

To address needs for shielding
beta particles

115/193

R

No specific proposal given

R“Practicable “ already conveys the required meaning

See 46

Occupational Radiation Protection (DS453)
50

9.9

51

9.10(d)52

9.16(b)Observation
Need to demonstrate ALARP
It is common practice forrather than specific cases
dose rates to be restricted
such that, for an assumed
annual exposure period of2000 h, the annual doses
would not exceed 5 mSv incontact with the shield and 1
mSv in the vicinity ofexperimental hutches along
the beam lines.
…(including scrubbers,
To include media used toadsorbers and/or HEPA
collect some airborne gases
filtration)…
Ventilation systems should
be fitted with real-time
indicators of system
performance such as
photohelics and flow ratemonitors with alarmcapability.

Needed to alert operators of
exhaust system failure or
malfunction

116/193

See 47AA

See comment 3 from Czech RepublicOccupational Radiation Protection (DS453)
53

9.18

When ventilation is used to This paragraph is too specificcontrol airborne
as other situations may requirecontamination, the local
actions to be taken if theoperating instructions should ventilation fails e.g. in fuelspecify the actions to becooling ponds, even though it istaken in the event of aa wet environment, ventilation
failure of the ventilation
may be required to control
systemairborne activity due toevaporation from contaminatedobjects causing activity to
become resuspended.

117/193A
9.18.
In some situations, such as in an underground mineor inside a building where the dry processing ofradioactive minerals is carried out, the local
operating instructions should specify the actions to
be taken in the event of a failure of the ventilation
systemOccupational Radiation Protection (DS453)
54

9.31

Because skin contamination This paragraph is describingA
by certain radioisotopes,
two different situations andsuch as tritium, cannot be
therefore should be split intoreliably detected by
two separate paragraphs tocurrently available hand held avoid confusion i.e. (1) actions
or automated monitoring
to be taken if measurement is
instrumentation, individual not possible due to the naturechecking is not anof the radionuclide and (2)appropriate means ofactions to be taken if
detecting such skinmeasurement is not possible
contamination. Whendue to external factors such asindividual exposure to such high background.
contamination hazards ispossible, additional emphasisshould be placed on
bioassay programmes androutine contamination andair monitoring programmes.
(New paragraph) If
background radiation levels
or other local conditions at
the exit point preclude theperformance of personal
contamination detection, theexit point should be moved
to an alternative location, forinstance to an area withlower background levels. If
relocation of the exit point is
not practicable, individuals
should proceed directlyfrom the exit point to an
appropriate area to performthe necessary checks.

118/193Occupational Radiation Protection (DS453)
55

9.35

Objects within potentially
For completenesscontaminated areas should
always be monitored prior to
removal.

A

Added in 9.30:
9.30 Exits from contaminated areas should include
provisions to facilitate retention of contamination in
the area and for monitoring of individuals and thearea to ensure control has
been maintained. Individuals exiting contaminatedareas should be monitored, as appropriate, for thepresence of surface contamination. At a minimum,
individuals exiting contaminated areas should
perform a check, using either portable or automatedmonitoring devices, as appropriate.
Where the only contaminated areas are laboratory
bench surfaces or fume hoods, or wherecontamination potential is limited to specific portionsof the body, the checking should concentrate on
affected areas. On removal from contaminatedareas, all objects including tools, materials,
equipment and personal items, should be monitoredby competent personnel. Workers should be madeaware of the necessity for such monitoring.
Include additional text according to comment #83
of France. (from 9.31)
If background radiation levels or other local
conditions at the exit point preclude the performanceof personal contamination detection, the exit pointshould be moved to an alternative location, forinstance to an area with lower background levels. If
relocation of the exit point is not practicable,
individuals should proceed directly from the exit
point to an appropriate area to perform thenecessary checks.

119/193Occupational Radiation Protection (DS453)
56

9.36

Detailed guidance needs tobe added here or elsewherein the TECDOC to address
the use of wipe samples
where needed to detect andmeasure removable surface
contamination.

Detailed guidance is needed
regarding the use of wipe
samples for detection andmeasurement of removable
contamination. GuidanceinAppendix V.45 and V.46 isinadequate.

57

9.43

apply cosmetics

missed off the listR

No more details needed on wipe samples

A
9.43. No person should eat, drink, chew gum or
tobacco, smoke, or take snuff or apply cosmetics inworking areas where radioactive material could beingested.

58

9.44

The employer should
There should be no eating inprovide – at locations
contaminated areas
outside of working areas
where contamination may
exist and that are reasonably
accessible to every
worker…

120/193A

Occupational Radiation Protection (DS453)
59

9.49

Guidance and/or a
For completenessreference is needed here on
elsewhere in this TECDOC
regarding contamination of
hair, eyes, mucous
membranes, etc, in addition
to skin and wounds

9.49. Personal contamination includes contaminationof personal clothing, skin, hair, eyes, mucous
membranes and wounds. In this context, personal
clothing includes work clothing provided by theemployer, but does not include protective clothing
provided solely for contamination control purposes.
9.50. When contamination is detected, the RPO
should be informed, in order to ensure adequate
characterization of the potential for significant doseby assessing the extent of the contamination,
retaining samples of the contamination as necessary
to perform a detailed dose assessment and to initiate
decontamination procedures. Levels ofcontamination that trigger the need for dose
assessments and decontamination methods shouldbe established for site-specific radionuclides.
9.51. Intrusive decontamination methods, such as
tissue removal, require medical assistance. In thecase of skin contamination by contaminants such asradioactive iodine, decontamination by washing or
using detergent may not be effective; in the eventof serious contamination, medical advice should besought immediately.
9.52. Contaminated personal clothing should be
decontaminated by laundering or other appropriate
method, monitored, and returned to the owner or, if
necessary, disposed of as radioactive waste.

121/193Occupational Radiation Protection (DS453)
60

9.50

61

9.55

62

9.56

Observation

large organisations havededicated units for thisIf levels of airborne
To simplify this type ofcontaminants exceed theassessment each known
safe working levels (Derived supervised or controlled area
Air Concentration – DAC)
could have its defined DAC for
specified by theeach nuclide used in the area,
management of the facility, then following a survey prior toappropriate respiratory
any potential release RPE
protective equipment should would be defined against that
be worn by those persons
nuclide.
undertaking actions tocorrect the situationn) Proper fit of respirators For completenessrequires the removal of
facial hair to ensure anadequate seal.

122/193-R

Unnecessary detailR

This is covered by (b)Occupational Radiation Protection (DS453)
63
9.58

Where there is thepotential for
In line with world best radiologicalcontamination,
control practice it is EDF Energy policy
individuals should to minimise the extent of potentiallywear appropriate contaminated working areas at its sites
protective clothing and to maintain contamination levels
to prevent thewithin those working areas ALARP
contamination of through good practice and housekeeping.
their personal
As a result temporary potentiallyclothing, working contaminated areas are often establishedclothing and skin. for the duration of a task and are
In some cases it
declassified, following radiological survey
may beand any necessary decontamination, on
appropriate forcompletion of the task. Such temporary
personal clothing potentially contaminated working areas
and working
are often not served directly by change
clothing to be
and shower facilities and protective
removed before
clothing is removed, and personnel are
donning protective monitored for contamination, at local
clothing. The
barriers. Operating experience at EDF
employer will
Energy sites indicates that the use of
specifyprotective clothing over personal clothing
appropriate
and working clothing is generally
protective clothing adequate to prevent personalrequirements incontamination. A graded approach is usedeach case, based in the specification of protective clothing
on the level ofrequirements, and the need to shower
risk, and will also following work, based on the level, andspecify cases
nature, of any potential contamination inwhere individuals the working area.The requirement toare required toremove personal clothing and working
shower on leaving clothing for all work in potentiallycontaminatedcontaminated areas, and to shower on
workplaces.
each occasion following work in 123/193
such
The employer
areas, at EDF Energy sites would require
should provide
significant changes to plant layout and tosuitable clothing
established radiological control practices
storage facilities
with no real benefit to radiologicalA

Replace paras 9.57-9.60 with the following:
9.57. Where there is the potential for contamination,
the employer should specify appropriate protective
clothing requirements, based on the level of risk.
The employer should provide the necessary overalls,
head coverings, gloves, boiler suits and impermeablefootwear and aprons (including lead shielding
aprons, where appropriate) in accordance with therisks of external and internal exposure and as
appropriate for the working conditions. Work
clothes including gloves and footwear should be
provided to every worker whose personal clothing islikely to become contaminated during the course ofwork.
9.58. The employer should also specify cases whereindividuals are required to shower and change
clothes on leaving contaminated workplaces, andshould provide suitable clothing storage facilities andwashing facilities.
9.59. Individuals should wear the specified
protective clothing. In some cases it may beappropriate for personal clothing and working
clothing to be removed before donning protective
clothing. Personal clothing and working clothingshould be changed in suitable locker rooms, whereappropriate with a washroom in between, to control
the spread of radioactive contamination.
9.60. When contaminated work clothes are stored,
laundered or otherwise decontaminated, or disposedof, the employer should put in place measures toprevent the spread of contamination to otherpersons or workplaces and to minimize theexposures of individuals and the release ofcontaminants to the environment. The employer
should provide suitable laundry facilities, bootOccupational Radiation Protection (DS453)
64

9.61

65

9.64

66

10.4

When the exposure isThis would be required to be
predominantly due toconsidered during a risk
penetrating radiationassessment and would form
(gamma or X rays),part of possible control
consideration should bemeasures.
given to the use ofprotective glasses containing
lead.
JOB ROTATION
Suggest noting that justification
In workplaces where there would be required i.e.
are areas with potential for demonstration that no otherhigh levels of radiation
control measures have been
exposure, when no otheridentified during the assessment
practicable means of control process.
are available, job rotation
may be considered as anadministrative control torestrict the exposure ofindividual workers.
However, the use of thismethod should be kept to aminimum, and job rotation
should never be used as a
substitute for thedevelopment and use of
appropriate methods ofindividual exposure control.
(e) To administer agents to These agents should be
prevent or reduce update
administered by or under thesuch as prophylactic agents authority of a qualified(such as KI for radioiodine) physician
and chelating compounds.

124/193R

Not appropriate in this location, it is covered
elsewhere

R

Comment already covered in present text

R

Covered in 10.34, and 10.4 is on health surveillance
programmes

Occupational Radiation Protection (DS453)
67

10.13

68

10.24

69

10.34

Medical examinations of
Are termination medicals aworkers should be
proposed NEW requirement?
performed before the start Not currently part of UK
of employment, periodically arrangements.
thereafter, and at thetermination of employment.
In a medical examination at See above (10.13)
the termination of
employment, any work
related impairment should be
identified and, if necessary,arrangements should bemade for further periodic
and follow-up examinations
by the worker’s physician
after employment hasceased. This is line with a
specific recommendation of
the ILO [158], which states:“the competent authority
should ensure that provision
is made for appropriate
medical examinations or
biological or other tests orinvestigations to continue tobe available to the worker
after cessation of theassignment…”
Examples of such therapies To include a particularly
include.. administration ofimportant example
KI to block the thyroid fromradioiodine uptake…

125/193

R

This is guidance, not a requirement

R

See above comment 67

R

It is not a therapy applied to overexposed workers

Occupational Radiation Protection (DS453)
70

71

Appendix II Need to indicate in each
Clarification
11.10, 11.19, section the types of radiation
11.23, 11.25 for which the monitoring
method is appropriate.

R

Appendix II
II.27

.

Although the majority ofThis paragraph implies that aAthese dosimeters are useful legal dosimeter must be able toas alarm dosimeters for use record both Hp (10) andin controlled areas and for
Hp (0.07) doses. Can ashort term radiation control dosimeter not be consideredof workers’ exposures, they ‘legal’ for one type of doseare not all suitable for use as assessment i.e. Hp (10) or
official or legal dosimeters. Hp (0.07), recognising that two
This is mainly because some dosimeters may be required to
dosimeters do not measure be worn e.g. EPD for wholebeta radiation as well as
body dose and TLDs forphotons and some have too extremities, if both types ofhigh an energy threshold for dose assessments are required
photons. Other important
for the task being undertaken.
factors are reliability and the In certain situations however,risk of data loss [175].
having one dosimeter recording
Furthermore, most devices only one type of dose may be
have difficulties inall that is required e.g. whenmeasuring pulsed radiation. only strongly penetrating
Some active personalradiation is present.
dosimeters do not record
both Hp (10) and Hp (0.07),
therefore two different typesof dosimeters may berequired to be worn.

126/193

Already specified in the headings

Occupational Radiation Protection (DS453)
72

Appendix III …use of GM counters in
Clarification
III.12
pulsed radiation fields, suchas some diagnostic x-ray
equipment, may lead to…

73

Appendix IV An AMAD of 5 μm is
IV.9.
considered to be the mostappropriate default particle
size for radionuclides in theworkplace [131], whereas
an AMAD of 1 μm is used
as a default for members of
the public.
Appendix V (f) Sampling for alphaV.39
emitting radionuclides otherthan NORM materials will
require a delay between
sample collection andcounting to enable decay ofshort-lived Rn-222 progenythat would contribute to
sample counts.

74

A

Does the AMAD of 5um apply
to all persons in the workplace,non-classified workerscontractors-visitors and young
person’s 16-18yo?

CompletenessRA

127/193

Correct spelling of X ray
Editorial– will be considered in the editorial process

AMAD is related to the workplace, not to theindividual(f) For alpha emitting radionuclides other than thosein NORM a delay between sample collection andcounting may be needed to enable the decay ofshort-lived 222 Rn and 220 Rn progeny that would
contribute to sample counts.

Occupational Radiation Protection (DS453)

Reviewer : CAEACountry/Organization: CHINA
CommenPara/Line No.
t No.
1

1.1
line3

2

2.33
Line 4/5

3

3.21
Line 3-4

4

3.22
Line 3
3.24
Line 9-10

5

COMMENTS BY REVIEWER
Page 1 of
Date: 20/6/2014
Proposed new text

RESOLUTION

ReasonAcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

Radioactive sources andirradiation installations orradiation generators
Besides equivalent dose, therecommended dosimetricquantity is the RBE weighted
absorbed dose ADT in tissues ororgan T.
the regulatory body shouldinspect the implementationcommitments for optimizationand evaluate the effectperiodicallyparticularly senior management

Irradiation installations orradiation generators include
X ray machine and so on
It could match 2.13, 2.29,
4.15, 4.16 and avoid
misunderstanding or
confusion

R

The list is not intended to
be exhaustiveR

It is more confusing
when it is added

It might be more practicaland effective thanenforcement onlyR

is already covered

It could match 3.18

R

Confirm decision aiding
techniques are quantitative or
qualitative.

It is inconsistent with para
3.23 “The process of
optimization of protection
and safety measures may
ranges from intuitive
qualitative analyses toquantitative analyses using
decision aiding techniques”“including” is the correctword
For clarification 3.23 isadjusted :3.23. The process of
optimization of protection
and safety measuresusing decision aiding
techniques may range
from intuitive qualitative
analyses to quantitative
analyses, but has to be

128/193A

Occupational Radiation Protection (DS453)

6

3.25

with account being taken of both
exposures from normal
operations and potential events:

A verbal adjustment

7

3.92

When engineered andadministrative controls are…

A verbal adjustment

8

3.128
Line 12-14

Suggestion: Describe thedefinition of “recording level”
explicitly in the case of individual
monitoring for external exposure

Whether “the minimum levelof detection” refers to the
instruments in minimum
detection level which isconflict with para 3.129 “Evenif the measured dose,
exposure or intake is below
the recording level, themeasurement result should
always be maintained in thedose record for the workplace
and/or the individual.” It is
impossible to detect data
below the instruments
minimum detection level.

129/193A

sufficient to take all
relevant factors into
account in a coherent
way so as to contributeto achieving the following
objectives:
3.25. A more structured
approach to the selectionof appropriate protection
and safety measures
should include thefollowing steps, withaccount being taken ofboth exposures fromnormal operations and of
potential exposures:AA

3.128: no changes
3.129. For internal dose
assessment, if the doseor intake is below therecording level, themeasurement result
should always be
maintained in the doserecord for the workplace
and/or the individual.

Occupational Radiation Protection (DS453)
9

3.160

10

7.231

220
Suggest to modify:
Rn is not referred to in
The 222 Rn progeny referred to in (b) but in (a)(a) and (b) are 218 Po, 214 Pb, 214 Bi
and 214 Po. The 220 Rn progeny
referred to in (a) are 216 Po, 212 Pb,
212
Bi, 212 Po and 208 Tl.”…and the radiation weigthing
A mistakefactor WR for neutron….

COMMENTS BY REVIEWER
Reviewer: National Nuclear Regulator, Radiation safety section
Country/Organization: SOUTH AFRICA
Comment Para/Line
Proposed new text
No.
No.
1

1.8

N/A

2

1.8

N/A

3

5.75

If, on the other hand, exposures ofA

A

RESOLUTION
Page 1 of
Date: May 2014
ReasonThe Radiation Protection
Programme (RPP) is theuseful tool in monitoring andmanaging occupational
exposure, therefore guidance
provided on the developmentof the occupational RPP is
most appropriate and it is welladdressed in the guide.
The intended integrated
approach to the control ofoccupational exposure, byaddressing both technical andorganizational aspects wasfound to be relevant
adequately addressed by theguide.
The intention is to emphasise

130/193

AcceptedAccepted, but
modified asfollows

RejectedR

Reason formodification/rejection

Actually

thecomment

Occupational Radiation Protection (DS453)(secondlast
sentenceofparagraph)

concern are identified, the government
should ensure that exposures inworkplaces are incorporated into an
overall national action plan for indoor
radon or if it is because of the result ofan authorized action, that appropriate
steps are taken in that workplace todecrease the radon activity concentrationby the party responsible.
N/A

4

Para 1.7

5

2.19

N/A

6

2.52

To derive the value of committed
equivalent dose to a tissue or organ, theintake is multiplied by HT(g), thethat the Government must
identify the responsible party(persons or organizations) tocharacterize exposure andestablishing an action plan.

In according to the statedobjective of the draft, theguide is intended primarily forthe regulatory body. This
however, is not reflected in
the contents of the document.
The contents are directed
mainly to the registrants,
licensees and employers. The
document does not give clear
guidance on the establishmentof the regulatory system forensuring protection andsafety.
Clear guidance (example) on
how the regulatory bodyshould enforce therequirements on workers(Requirement 22 of GSR Part3) is not covered explicitly by
the guide.
A comma replaced by colons.
Colons make it clear thateverything that comes after

131/193

relates to 5.56.
This issue is alreadycovered by 5.61-5.62.

R
withmodification

The purpose of thisdocument is not toestablish a regulatory
system (this is covered ina specific document of theagency).
To be consistent with thecurrent Safety Guide,“primarily” should bedeleted.

R

The purpose of thisdocument is not toestablish a regulatory
system (this is covered ina specific document of theagency).

R

Will be in case addressedby IAEA editorial officeOccupational Radiation Protection (DS453)
committed equivalent dose per unit intake
for ingestion or inhalation, as appropriate,by the group of age g.
Same comment as for 2.52

HT(g) is a definition of it.
This is not so clear when acomma is used.
Same comment as for 2.52
This will be consistent withthe paragraph 3.74 theManagement to considerclassifying the working areas
whenever there is
occupational exposure toradiation.
The position of the phrase“e.g.” has being changed toinclude “level of activity
concentration” as part ofexamples of details ofradiation surveys.

7

2.53

8

3.59(e)

The classification of the radiological
areas

9

3.113 (c)Give details of radiation surveys, e.g.
level of activity concentrations in air,date, time, location, radiation levels,
instruments used, surveyor, or othercomments;

10

3.160

11

4.8 (b)

12

5.35

R
R

A

The 220 Rn progeny referred to in (a) are216
Po, 212 Pb, 212 Bi, 212 Po and 208 Tl.”
Providing instructions immediately before
their use to those emergency workers notdesignated as such in advance2 - on how
to perform their specified duties underemergency conditions and how to protect
themselves (‘just in time training’);220

Rn is referred to in (a),not (b)To indicate the break between
the two parts of the sentence.
The original sentence wasincomprehensible.

A

The legal and regulatory framework,
supported where necessary by guidancematerial, should provide for adequate
protection of individuals (including
workers) and the environment when

The sentence is rephrased forgrammatical purposes.

A

132/193

Will be in case addressedby IAEA editorial office
Current formulation isadequate and consistent
with BSS.

Give details of radiation
surveys, e.g., date, time,location, dose rate,
airborne activity
concentration, instruments
used, surveyor, or othercomments;
Already addressed inprevious comments

A

This refers to para 5.31
and not 5.35.

Occupational Radiation Protection (DS453)
remediation is undertaken.
13

6.58

Some itinerant workers will work in
professions that require qualification or
certification schemes to demonstratecompetence” has to be rephrased forgrammatical purposes.

Operate was replaced byrequire, to make the sentence
more comprehensible.

COMMENTS BY REVIEWER
Reviewer:
R. Bly, STUK,Country/Organization: FINLAND
Comment
Para/Line
No.
No.
1.1

Proposed new text

RESOLUTION
Page.... of....
Date: 16th June 2014
Reason…with different stages of the nuclear The use of radioactive
fuel cycle; the use of radiation in sources
and
x-ray
medicine,…
machines in medicine does
not
cover
use
of
accelerators, cyclotrons or
BNCT (neutron beams).

…radionuclides of natural origin or
exposure to cosmic rays.

Replace “operate” with“have”.

A
modified

Cosmic rays covered in
5.73-5.75.

133/193

AcceptedAccepted, but
modified asfollows
A

Rejected

Reason formodification/rejection

Occupational
exposure to radiation
can occur as a resultof various humanactivities, including
work associated withthe different stagesof the nuclear fuelcycle; the use ofOccupational Radiation Protection (DS453)

1.5

4

4.15 Table
2

4.16 Table
3

The RPP should be established andmanaged together with other healthand safety disciplines, such as medical
hygiene, industrial hygiene, industrial
safety and fire safety.

Innuclearmedicinelaboratories
medicalhygiene requirements haveto be reconciled withradiation
protection
requirements,
especiallyconcerning ventilation.
Exposure of workers in A
emergency
exposuresituations
shouldbechecked to be in line withsafety requirements DS
457.
Table 2 should be modified A
to be in line with the DS
457.
Table 3 with footnotes A
should be modified to be inline with the DS 457.

134/193

A

radiation in
medicine, scientificresearch, agriculture
and industry; andoccupations thatinvolve exposure tonatural sources.
materials containing
elevated
concentrations ofradionuclides ofnatural origin.
such as industrial
hygiene, medical
hygiene, industrial
safety and fire
safety.

Editorial– will be consideredintheeditorial
process
Editorial– will be consideredintheeditorial
process

Occupational Radiation Protection (DS453)
4.19

5.63

7.206

Categories should be in linewith the DS 457 (inwhich there are emergency
workers and helpers).
If, despite all reasonable efforts by the It is not very clear, whichA
employer to reduce radonis the reference level (300concentrations in the workplace, such or 1000 Bq/m3) referredconcentrations remain above thehere. As stated in 5.60, inreference level, the relevantbuildings with highrequirements for occupational
occupancy factors for
exposure in planned exposure
members of the public
situations will apply (see para.
such as kindergarten,schools, hospitals etc
3.160(b)). This outcome is highly
unlikely except in some underground exposure of all occupants
is controlled using themines where there might be practicalreference level for
limitations on restricting the entry ofradon into the air and on the amount of dwellings i.e. 300 Bq/m3(?). Therefore, it may notventilation that can be provided (seebe “highly unlikely” that thepara. 3.175)
reference level is exceeded.
Instead “unlikely”
expression can be used.
Higher values, based on biokinetic and There is a reference to a
dosimetric modelling, are now being
draft document ([129]proposed by the ICRP [129] — 5.9
INTERNATIONAL
mSv per mJ·h·m–3 for indoor radon
COMMISSION ON
and 3.0 mSv per mJ·h·m–3 for radon RADIOLOGICAL
in mines.”
PROTECTION,
Occupational Intakes ofRadionuclides, Part 3,
Draft Report for
Consultation, ICRP Ref.
4838-4528-4881, 20

135/193– will be consideredintheeditorial
processA

ICRP is now
recommending theuse of dosecoefficients based on
biokinetic anddosimetric models[reference to ICRP
statement on radon isadded].

Occupational Radiation Protection (DS453)
September 2012).
It would be moretransparent if only reports
available to everybody werecited. The status of the
new biokinetic anddosimetric modeling israther unclear andconfusing. Therefore,
referring to it should beconsidered to be left out
from the Safety Guide.

TITLE : DS 453
COMMENTS BY REVIEWER
Reviewer:Country/Organization: FRANCE
Date: 2014/06/20
Comment
Para/Line
Proposed new text
No.
No.

RESOLUTION

Reason136/193

Ac
cep

Accepted, butReje
cted

Reason for modification/rejection

Occupational Radiation Protection (DS453)
ted

1.

PREFACE/Line 302.

1.2/Line 6… It updates the guidance given in
six previous safety guides: (list to becompletedwith
NS-G-1.13“Radiation Protection Aspects of
Design for Nuclear Power Plants”)

In the frame of NPP New
Builds or replacements oflarge components for theLong Term Operation ofexisting plants, a chapter
on nuclide source term
minimization
throughmaterial selection (e.g.
corrosion
product
inventory)
and
plant
operation (e.g. coolant
chemistry,
purificationmeans) should be added tothis safety guide, in
accordance with otherrequirements in IAEA
Safety Standards SSR-2/1“Safety of Nuclear Power
Plant:
Design”(e.g.
requirements 50 and 81)
and subsequent Safety
Guides (in particular NSG-1.13“Radiation
Protection
Aspects of DesignforNuclearPower
Plants”).

Text to be completed with IAEA According
Safety Standards SSR-2/1 reference No.1

to comment

137/193

modifiedasfollows
R

Outside the agreed scope of the
document

R

Outside the agreed scope of the
documentOccupational Radiation Protection (DS453)

3.

1.6/

4.

2.10

5.

2.22

6.

2.25

7.

2.33

“Safety of Nuclear Power Plant:
Design”
Text to be completed
According to comment
No.1
Except for therapeutic and diagnostic It would be better to delete
medical exposure
the part of sentence whichis confusing because
occupational exposure in
the medical field shall also
be optimized“The government or the regulatory This paragraph may referbody shall determine which practices
to the RS-G 1.7 dealingor sources within practices are to bewith exclusion andexempted from some or all of theclearance
requirements of these Standards. The
regulatory body shall approve whichsources, including materials andobjects, within notified practices orauthorized practices may be cleared
from regulatory control.”The management system must also
address human factors by supporting
good performance and good practices
to prevent human and organizational
failures, with attention being given to
the design of equipment, thedevelopment of operating procedures,
limits and conditions as appropriate,
training and the use of safety systems
to reduce the consequences of humanerror.
The dose limits (for effective and The lens of the eye is not
equivalent doses) are such that considered in the definition

138/193R

Outside the agreed scope of the
document
Already covered by the resolution tocomment #3 of IRPA/USA

R

RS-G-1.7 is not completely consistent
with BSSR
withThe dose limits are such that
deterministic effects will not occur forAAOccupational Radiation Protection (DS453)

8.

2.34

9.

2.48

10.
2.63/table 1

deterministic effects will not occur of effective dose
for the organs and tissues included in
the definition of effective dose andfor the lens of the eye.

modi
f.

those organs and tissues included in thedefinition of effective dose.

The term collective effective dose
may be used as an instrument for
optimisation,forcomparingradiological
technologies
andprotection procedures. a dose
estimate may be defined for tasks
withsignificant
exposure,
including the latest state-of-theart in terms of source term
reduction measures and workorganization.
Delete the box “dose rate” in fig 2

The safety guide should
include common bestpractices for all plant
operators
and/orsubcontractors. The dose
estimate is in accordancewithoptimization
principle, as recalled in
sections 3.11 (b) or 3.31.

R

Unnecessary level of detail

The dose rate is not used
to calculate intakes fromindividual measurements

R

The figure is consistent with Ref. [8]and the calculation is technicallypossible.

Correction of half-life :218Po half-life = 3.07 min
214Pb half-life = 26.9 min
214Bi half-life = 19.8 min
214Po half-life = 162.3 µs

Half-life and energies
valuesneedtobecorrected
taking into
account the work of the
BIPM
:
Table
of
radionuclides (Vol.7-A=14
to 245 (2013)5.66 instead of 5.56

R
with
modi
fications

IAEA follows the NuDat database(Brookhaven National Laboratory –NuDat 2.6) and Reference added inTable 1. 218Po corrected as per thelatest database to 3.098 min.
Other radionuclides – no change

R

Values consistent with those adopted in
the resolution to comment 10.

R

Values consistent with those adopted in

11.

2.70

PAEC (in J/m3 )= 5.66 10-9 EEC

12.

2.71

However,

workplaces

such

as Thissentence may be

139/193Occupational Radiation Protection (DS453)
underground
mines
or
water
treatment
facilities may show
significantly lower F values.
The higher the air renewal rate is,the lower the equilibrium factor F
is.
+ Replace 5,56 by 5.66 in formula17+ Replace the result 4.45 by 4.53

confusing. Basically, thehigher the air renewal rate
is,
the
lower
the
equilibrium factor F isTable 1 is duly amended
at the end of the
document.

“high” is too restrictive.
“high” should be defined
precisely in term ofactivity of thorium.

R

Current text is adequate.

The equilibrium factor canbe used for radon because
its half-life is much longer
than the half-life of theprogenies of interest. But
for thoron chain that is not
the case, the half-life of
the parent, the thoron gas,is shorter.
The short lived progeny of thoron are Better not to talk about
likely to be out of equilibrium with the equilibrium for thoron andparent.
its progenies (that are all
short lived). The thoron
half-life
being
much
shorter than the half-life of
212Pb and the following
progenies, the thoron will
vanish long before thoseR

The existing text already covers the issueof the short-life of thoron and theequilibrium factor.

R

The existing text already covers the issueof the short-life of thoron and theequilibrium factor.

13.

2.72

“Thoron is not normally of concern
in workplaces, except where material
with a high thorium content isprocessed or stored,

14.

2.72

In such instances, a similar approachto that for 222Rn progeny can befollowed except for the equilibrium
factor that is not a relevant
quantity for thoron.

15.

2.72

140/193

the resolution to comment 10.
(see also resolution to comments 5-7 ofGermany)Occupational Radiation Protection (DS453)
progenies appears
Remove “The assessmentof an equilibrium factor”
because this has no
physical meaning. It is notpossible to make the same
assumption that thosemade for the radon
because the half-life of theradon is far higher thanthose of its short lived
progenies
That is the big difference
between radon and thoron,
radon does not have thetime to disintegrate somuch in the lung but
thoron has.
The thoron measurement
cannot be used to evaluate
212Pb, 212Bi and 212Po
activity concentration but
to evaluate 216Po only.

16.

2.72

The assessment of an equilibrium
factor and For dose assessment
purposes, an approach based on themeasurement of thoron progeny
concentration is easier usuallychosen.

17.

2.72

18.

2.72

19.

3.6

20.

3.10

One could add: a measurement ofthoron in order to take into accountthe deposition of the first progeny,
the 216 Po, in the lung that can deposit
because of the short half-life ofthoronBecause thoron will be normallyfound close to its source (thorium or
radium), the measurement of thoron
progenies (212Pb, 212Bi and 212Po)
should be enough for dose
assessment.
, including materials and objects and Ionizing radiation sources
may often be X Ray
generators,
generators or accelerators
especially in the medical
field
Optimization of protection and safety A reference to NS-G-1.13
needs to be considered at all stages of “Radiation Protection
the life of equipment and installations, Aspects of Designin relation to both exposures from for Nuclear Power Plants”

141/193R

The existing text already covers the issueof the short-life of thoron and theequilibrium factor.

R

The existing text in paragraph 2.73
already covers the issue of the short-lifeof thoron and the equilibrium factor.

R

The existing text in paragraph 2.73
already covers the issue of the short-lifeof thoron and the equilibrium factor.

R

Generators will be exempted rather thancleared and this issue is covered in 3.7

R

See resolution to previous commentsOccupational Radiation Protection (DS453)
normal operations and potential
exposures. As a consequence, allsituations — from design (Ref NS-G1.13),
throughoperationtodecommissioning
and
waste
management — should be consideredin the optimization procedure.

21.

3.12

(e) Good practices
sectors.
(f) Economic aspects

in

22.

3.24

To be added:
In any case, a record-keeping of the
ALARA decision making process andconclusions should be provided ateach major step of the projectthrough engineering reports.

23.

3.25

24.

3.43

should be added. In a
future version of thispresent
guide,
therelevance to add someprovisions from NS-G1.13 eventually applicableto other types of facilities
than NPPs may bestudied.

relevant

A

These reports have to bemade available toauthorities to ensure thatan optimization processwith continuous
improvement was
performed.
(b) Identify all relevant economic, Releases and wastes couldsocial and radiological factors also be relevant in the(sometimes non-radiological factors decision-making process.
as well) for the particular situation
under review that distinguish between
the identified options, e.g. collective
dose, distribution of individual dose,
liquid and gaseous releases, impact
on public exposure, amount ofwastes, impact on future generations,investment costs;(b) The employer and the regulatory
body, in consultation with the worker

142/193

A(f) Social and economical aspects

R

Covered by 3.17

R

Already covered in the existing text.

(b) The employer and the regulatory
body, in consultation with the worker

Occupational Radiation Protection (DS453)(through his or her representatives
where
appropriate)andtheoccupational physician, agree on atemporary dose restriction and theperiod to which it applies.

25.

3.48

26.

3.55

(through his or her representatives
where
appropriate)andtheoccupational
physicianwhereappropriate, agree on a temporary dose
restriction and the period to which it
applies.

The general objective of the RPP is toimplement the application of the
management
responsibility
forradiological protection and safety
through the adoption of management
structures, policies, procedures andorganizational arrangements that arecommensurate with the nature andextent of the radiological risks. The
RPP therefore should cover all themain elements contributing toradiological protection.

The scope and content of
the as-described RPPseems too wide. If the
purpose of the RPP is forcontrol, then it should be
restricted to radiation
protection management,
ALARA programme andmeasures, as the safety
aspectsarealreadyincluded in the Safety
Analysis
Report.
Operational information onrisks(radiological,
mechanical, safety, fire…)
to individuals in charge of
the works usually is inother types of documents(e.g.
Radiation Work
Permit, see section 3.95).
To be added:
This kind of information is(x) Use of experience feedback of very important and usefulcomparable facilities or systems for new builds andalready
implementing
best changes in a facility
practices(sourcetermminimization,organizationof

143/193

R

A

Follow IAEA Saftey Glossary

Added to (b):Use of literature data and informationfrom comparable facilities.

Occupational Radiation Protection (DS453)
27.

3.80

28.

3.88

29.

3.145

30.

3.167

31.

6.10

32.

33.

work)
Add : For instance, , it may be Useful to address different
types of facilities otherappropriate to designate as athan mines
controlled area for practical purposes.

m/ Use of personal and collective
protective equipment(e.g. designers, engineers, planners,
technicians of maintenance, etc.)
involving external exposure to gamma
radiation emitted from processmaterial involving external exposure
to radiation emitted from processmaterial…attributabletooccupational
exposure will not exceed 1 mSv/y.
Modifications of the monitoring
programme for internal exposure
might be needed because someradionuclides
might
be
have
characteristics more relevant for
foetal doses than for maternal doses.

For instance, for practical purposes, insome underground uranium mines it may
be appropriate to designate as acontrolled area the entire undergroundarea, and similarly in some diagnostic
medical facilities the entire examination
room.

A

Change (c) to(c) Use of personal protective equipment
Not an appropriate example

R
Beta radiations may bealso considered.

R

Newborn child may bebreast-fed for more than 1
year“Characteristics”
issuggested to precise what
is relevant

R

Where a service provider is part of alarger organization, the organizationalA

Following ICRP recommendations; after

This will be fixed during editorial
process.
R

144/193

This is a section on NORM. Additionally,
the paragraph considers the most likely
exposure situations

declaration of pregnancy, such that it isensured that the additional dose to thefetus would not exceed about 1 mSv during
the remainder of pregnancy‘hot particles’ has to be
defined.

7.246

8.6

A

Unnecessary emphasis.

Occupational Radiation Protection (DS453)
arrangements should be such thatdepartments that may haveconflicting interests, such as
production, commercial marketing or
financing departments, do not
adversely influence the service
providers’ ability to comply with therequirements of their management
system, especially those for thequality of the service provided.
1.

8.10

34.

8.10 d)Periodically evaluating the observanceof these rules and procedures;
Periodically analyzing difficulties
in the application of these rules
and procedures

35.

8.10 i)

Dissemination and promotion ofknowledge of actual incidents andaccidents, but also of weak signals
like recurrence of events, to learn
from their occurrence and to improve
the safety culture

36.

8.20

Add a bullet…This should include theidentification of:(a) Customer requirements;

This section on safety
culture is very weakcompared to the
expectations set in DS456
For safety enhancement, it
is more interesting tounderstand why rules andprocedures are not applied
rather than to evaluate
observance of rules.
Incidents and accidents
are of course a powerfulmean of learning, but it isimportant to pay attention
to events without
consequences but thatgive information on therobustness of theorganization.
Technical requirements
have to be identified. They
may or not be covered bycustomer requirements or

145/193R

All relevant and key points have been
covered. More text will further limit theusability.

A

Periodicallyevaluating
theimplementation and effectiveness ofthese rules and procedures;

A

Disseminationand promotion ofknowledge of actual incidents andaccidents,
to learn fromtheir
occurrence, and any reocurrence, and to
improve the safety cultureR

Implicit in (a) and (b)Occupational Radiation Protection (DS453)

37.

8.21

38.

8.29

39.

8.31

(b) Related statutory and regulatory
requirements;(#) technical requirements(c) Organizational resources
necessary;(d) Requirements for communication
with the customer.
To this end, the management should
establish a monitoring process underthe management system that isdesigned to assess and analyse all
customer reactions so as to enable
the organization to take actions
designed to result in the continuous
improvement of effectiveness andsafety.
In an large organization that provides
services in radiation safety, it is often
the case that the top manager
appoints one person as management
system manager to act on his or her
behalf regardless of other duties.

Replace the chapter by:
The human resources should be
adequate to meet the predetermined
man
power
requirements. This requires aprevision of future needs due tostaff renewing and workload
evolution.

regulatory requirements…

Improving safety is also agoal.

Not true for small
companies with a few
staff…
Consider deletion as theappointment of amanagement systemmanager is only a footnote
in GS-G-3.1 (footnote 3).
It is necessary to integratea dynamic view ofresources because they
are not stable and therequirements are alsochanging.

146/193A

R

Current text is appropriate

R

Existing text is adequateOccupational Radiation Protection (DS453)
40.

8.32

41.

8.32

42.

8.33

43.

8.34

44.

8.37

The infrastructure requirements ofeach process, including the ones
derived from regulatory requirements,
should be reviewed to identify the
resources that will be required for the
successful accomplishment of thestated objectives.
For calibration and testinglaboratories, where the workplaceenvironment could influence thequality of the results, the regulatory
body may impose additional
requirements such as special
authorities to be used for calibration
services to ensure the correct
certification and calibration ofequipment.
The objective of the process tocontrol monitoring and measuring
devices is should be implemented toestablish an effective means of
ensuring, with a high degree ofconfidence,…
Combine 8.34 and 8.33

Clarifications

R

Existing text is adequate

Not specific to thecalibration and testinglabs…
See previous comment on
8.32 for taking into
account regulatory
requirements.

R

Existing text is adequate... Attention to workload, stressfactors, social structure within theorganization, internal communication,
workplace safety, (including
ergonomics, lighting, ventilation) andmany other factors can all be
combined to enhance the overall
effectiveness of the organization in

Clarification as lighting
and ventilation, as well as
ergonomics, contribute toworkplace safety.

Clarification

A

Same topic

the The process for the control ofmonitoring and measuring devices isshould be implemented to establish aneffective means of ensuring, with a highdegree of confidence,…
R

147/193A

No longer necessary if changes to 8.33
are adopted.
Deleted this part as per the WNA
comment 18.

Occupational Radiation Protection (DS453)
45.

8.37

46.

8.42

47.

8.47

achieving its objectives.
Additional paragraph:
For people working at sites awayfrom permanent facilities, or inassociated temporary or mobile
facilities, an analysis of working
conditions, especially coactivity
risks, should be completed before
the beginning of the work.
In monitoring the performance of its
processes to ensure that theprocesses remain effective and that
customer satisfaction is provided, aservice organization should review
the following:(a) Timeliness — reaction to thecustomer as influenced by theprocess structure;(b) Capability — amount ofthroughput for the process (ability tomeet the requirements relevant for theservice) ;(c) Efficiency — resources allocatedto the process and the possibilities fortheir reduction without compromisingcompliance with regulatory
requirement and quality.
8.47. For consultancy services, thesemeasurements arrangements couldbe:(a) Additional calculations using otheralgorithms;(b) Checks on data entry;

It is important to havespecific arrangements forpeople who work in
different places.

R

Not necessary (working environment
include the addressed issue)

Clarifications

A

In monitoring the performance of its
processes to ensure that the processes
remain effective and that customer
satisfaction is provided, a service
organization should review the following:(a) Timeliness — reaction to thecustomer as influenced by the process
structure;(b) Capability — amount of throughput
for the process (ability to meet relevant
requirements);(c) Efficiency — resources allocated tothe process and the possibilities for their
reduction without compromising quality
andcompliancewithregulatory
requirements.

Clarification (to beconsistent with suggestedchange to 8.45/8.46)

A

Change measurements to measures (alsoin 8.46).

148/193Occupational Radiation Protection (DS453)

48.

49.

8.48

8.52

50.

8.55

51.

p 162

(c) Comparison of the results withprevious experience.
8.48. For measurement andcalibration services these checks
could be:(a) Repeated tests (possibly doneusing different instruments foranalysis);(b) Checks on introduced blank ortest samples;(c) Plausibility tests on the results,
done by applying expert knowledge,
etc.
The results of these measurements
should be recorded as proof of thecontrol of the production process.
Create a headline before 8.52 :“proprietary information”
Organizational changes in serviceproviding organizations rarely have a
direct impact on safety. If they do,
the guidance in Ref. [6] should be
followed to ensure that there is no
adverse effect on product or service
quality.
Should organizational changes becontemplated in service-providingorganizations, the guidance in Ref.
[6] should be followed to ensurethat there is no adverse effect on
product or service quality.
Modification of the title

Clarification (to beconsistent with suggestedchange to 8.45/8.46)

A

Change checks to measures.
Retain the last sentence but delete ofthese measurements.

The postulate thatorganizational changes
have rarely impact onsafety is not consistent
with lessons coming fromthe experience feedback
from industrial accidents..
the sentence is too
affirmativeA

Should organizational changes becontemplated in a service-providingorganizations, the guidance in Ref. [6]should be followed to ensure that there isno adverse effect on product or service
quality.

Characterization is larger

A

Performance measurement, assessment

Last sentence to be moved
up to 8.46
Clarification

A

149/193Occupational Radiation Protection (DS453)

52.

8.57 (b)

53.

8.73

54.

8.73

55.

8.75

Characterization, assessment and than measurement that is
only covering quantitative
improvement
data on the functioning of
the organization.
(b) Application of basic statistical All indicators cannot be
methods (histograms, distributional quantitative. It isanalysis, mean values, etc.) or necessary to also consider
qualitative analysis methods to qualitative data that will
monitoringdata on customer allow analyzing causes ofsatisfaction, the performance of evolutions of quantitativeequipment, measurement throughput indicators.
and similar indicators of theeffectiveness of services provided tothe customer;
Some questions that should be Causes with an s, because
considered when determining root there could be different
causes of a problem include:
root causes.
Complement the list :It is necessary to(i) Doestheworking investigate whether somechanges in the working
environment changed?
environment contributed
to the event.
Delete 8.75

Too general and not safety
oriented

and improvement
Add “performance” also to 8.57.

A

A

A

(d) Has the working environmentchanged?
Change the lettering accordingly

R
with
modi
f.

It addresses the issue of Performance
improvement
Change paragraph as suggested:
Correction of errors and prevention oflosses are two ways to make
improvements within an organization.
It should review its performance andevents that took place and identify and150/193Occupational Radiation Protection (DS453)
implement improvements.
56.

8.76

57.

8.77

In some States, organizations
providing calibration or testing19
services seek accreditation by third
parties to internationally recognized
standards such as ISO/IEC standard
17025 [86]. Such accreditation isrecommended The guidance provided
here will help such organizations todevelop a management system that
could be accredited if there is astrong business case for pursuing
accreditation.
Delete 8.77

58.

8.78

Delete 8.78

59.

8.82
8.83

Rearrange 8.82 and 8.83 as follows:
8.82. Laboratories proposing tosubcontract tests and calibrations
should inform the affected clients of
the arrangements in writing and, as
appropriate, gain the approval of theclient, preferably in writing.
For calibration and testinglaboratories, subcontracting means
placing work within the scope of its

It is not the purpose of an
IAEA guide to explain how
to succeed in an ISO
accreditation.
However, suchaccreditation may berecommended by IAEA.

A

See comment on 8.76. It
is not the purpose of an
IAEA guide to explain how
to succeed in an ISO
accreditation.
See comment on 8.76. It
is not the purpose of an
IAEA guide to explain how
to succeed in an ISO
accreditation.
More logical order

A

A

A

Fine with moving original text of 8.83 tothe top of 8.82.
The text for 8.83 is modified as follows:
Subcontractors should be required todemonstrate the same level ofcompetence as is the accredited
laboratory that is serving as the prime
contractor This can be accomplishedeither by.

151/193Occupational Radiation Protection (DS453)

60.

8.84

accreditation with a third party
outside the immediate control of the
primary contracting laboratory. It
does not include, for example,
contracting with a referencelaboratory to provide intercomparison
samples, contracting with an
employment agency to provide
supplementary support workers, orsimilar activities.
8.83 Subcontractors should be
required to demonstrate an adequate
the same level of competence as is
the accredited laboratory that isserving as the prime contractor. Thiscan be accomplished either by thesubcontractor holding an equivalentaccreditation in its own right or by
the prime contractor completing aquality system audit of thesubcontractor’s operation.
8.83. Laboratories proposing tosubcontract tests and calibrations
should inform the affected clients of
the arrangements in writing and, as
appropriate, gain the approval of theclient, preferably in writing.
Delete 8.84

61.

8.88

Delete 8.88

The level of competence of thesubcontractor should be adequate for thetechnical services to be provided. Thiscan be demonstrated either by….

Subcontractor may have abetter level ofcompetence…

The para gives conflicting
positions for who is
responsible so it is betterto delete it.
Duplicates 8.70

152/193

A

A

Deleted the heading « CustomerOccupational Radiation Protection (DS453)
feedback » together with 8.88 andchange Paragraph 8.70 as follows :

62.

8.90

Transform 8.90 into a footnote

8.90 weakens 8.89

A policy and procedure for the
resolution of complaints received fromclients or other parties should be inplace. A corrective action procedure isstarted after a complaint is made by, or
feedback is received from, a customer,
or upon the discovery of a nonconformance by staff or during an audit.
Corrective actions should becommensurate with the magnitude of the
problem and the associated risks.
Records should be maintained of allcomplaints and of the resulting
investigations and corrective actions.
Delete 8.90 and change 8.89 as follows:A

With regard to technical records, thelaboratory should retain, to the extent
practicable, the records of original…
63.

8.93
8.94

Delete 8.93 and 8.94

8.93 and 8.94 duplicate
8.60 and 8.61

A

Move 8.93 to after 8.61, with themodification indicated below, and leave
8.94 untouched.
8.93 8.62 The internal audit programmeshould address all the elements of the
management system. , including testingor calibration activities.

64.

9.1 to 9.5

Locate 9.1 to 9.5 in the subsection

R

153/193

The text in 9.1-9.5 covers more than justOccupational Radiation Protection (DS453)
dealing with ventilation (after 9.9)

with
modi
f.

ventilation.
Paragraph 9.2 and 9.3 to be changed asfollows
9.2 Appropriate monitoring should be
performed to determine the adequacyand effectiveness of engineered controls.
For instance, when engineered controls
such as ventilation, vacuum cleaners orcontainment devices are used to reduceor maintain radionuclide activity
concentrations in the work environment,
the air quality should be monitored.
Generally…
9.3 Temporary engineered controls,
such as temporary shielding,containment devices and portable orauxiliary ventilation may need to be usedduring non-routine operations such as
maintenance, modifications, anddecontamination and decommissioning.

65.

9.1

66.

9.4

Additional engineered controls using
facility systems and components areshould be used to protect individuals
when the physical design features ofa facility do not provide sufficient
containment of radioactive material.
For example,…
Temporary containment devices may
be particularly useful in controllingthe spread of contamination when

Clarification (no need to
speak about additionalfeatures)

Clarification

AR

154/193

when Where the physical design featuresof a facility do not provide sufficient
containment or shielding of radioactive
material, additional engineered controls
using facility systems and components
are should be used to protect individuals.
For example, …
It could be foreseeableOccupational Radiation Protection (DS453)

67.

9.5

68.

9.8

69.

9.9

unforeseen leakages occur in thenormal containment system or when
maintenance work requires thecontainment system to be opened.
“should be equipped with high HEPA are not efficient inefficiency particulate air (HEPA) filtering
radioactive
filters or iodine filters if radioactive vapors.
vapors are produced”… At the design stage, adequate
thickness of the shield material isprovided to give acceptable level ofprotection to the workers during
normal as well as abnormal situations.
As far as possible, appropriate andeasily available materials are used
for permanent shielding purpose:water,
polyethylene,
normalconcrete (density 2.35), lead-glass
and iron.
The design of shielding should ensurethat the individual external dose innormal working condition is lower
than the dose constraint.

Ashould be equipped either with highefficiency particulate air (HEPA) filters
or with adsorbers, as appropriate.

R

To avoid non usual andexpensive
shieldingmaterials

To avoid by design
heterogeneous
shieldingthicknessand/ornecessityforlocalshieldingtransportationand storage in radiation
zones

Additional local shielding should be
provided avoided by design; they
can be provided later on to reduce
the radiation field as needed. Passive
area monitors …
Locate 9.9 before 9.8
9.9 set the need for

155/193

R

Existing order of paragraphs is correct.

Occupational Radiation Protection (DS453)

70.

71.

72.

9.9

9.10 (d)9.15

shielding and 9.8 how toshield…
It is common practice for dose rates More general definition
to be restricted such that, for an and pragmatic way toassumed annual exposure period of define shielding thickness.
2000 h, the annual doses would notexceed 5 mSv in contact with theshield and 1 mSv in the vicinity ofexperimental hutches along the beamlines.
… It is common practice for theshielding thickness to be optimized
such that, for an assumed annual
exposure period of 2000 h, the upper
dose or dose rate of the applicable
local radiation zoning in contact withthe shield is not exceeded, also given
the radiation sources of surrounding
rooms.
Providing the appropriate exhaust air
off gas cleaning systems (including
scrubbers and/or HEPA filtration
and/or iodine filters) so that thedischarges from the facility will be
ALARA and as per the authorizedlevels. The discharge of the exhaust
air should be through a stack ofappropriate height to provide thenecessary dilution for the releases toprotect the members of the public.
Locate 9.15 before 9.11

HEPA are not efficient infilteringradioactive
vapors.

A

Remove the whole sentence.

R

Already addressed in the resolution oncomment #51 of UK.

R

Current structure is adequate.

Clarification stressing theneed to be ALARA and not
only below limits

This para is general andshould appear before the156/193Occupational Radiation Protection (DS453)

73.

9.17

74.

9.18

75.

9.22

76.

9.23

Locate 9.17 before 9.13

The employer should establish
standard operating procedures(SOPs), including procedures for thecleanup of spillages, restricting
access to the area, implementing
contingency plans, monitoring ofaffected persons, advice from RPO
or Qualified Expert, management ofwaste arisings, and where relevant
notifications to relevant authorities, tobe followed in the event…
Any spillage of radioactive material
should be cleaned up as soon aspracticable in order to minimize thespread of contamination after
determining the extent of thecontaminated area. The area should
be decontaminated by the removal of
all loose radioactive contamination

specificities addressed in
9.11 to 9.14
General expectations
should appear prior to
specific expectations
Why is thisrecommendation limited tounderground mines orbuildings where dry
radioactive material isprocessed ?
This would also be true inseveral rooms of an
NPP…
Reporting criteria to theregulator are to be set by
the regulator…

Clarification

R

Already addressed in the resolution tocomment #53 of UKA

managementofwaste
arisings,
notifications to relevant authorities as
required, to be followed in the event…

R

157/193

Current structure is adequate.

Unnecessary level of detail.

Occupational Radiation Protection (DS453)

77.

9.25 (a)

78.

9.26

79.

9.26

80.

9.28

81.

9.29

and contaminated materials as muchas practicable.
(a) Specific design features aimed atcontainment of confining radioactive
material to prevent it from causing
surface contamination in the firstplace;
Especially during non-routine work
such as equipment maintenance,
design features such as thosementioned in para. 9.25(a) and (b)may be the primary methods ofpreventing and controlling workers’
internal exposures from inhalation

To control the spread ofcontamination and restrict individual
exposures, a graded, multiple tiersystem provisions such as erection ofphysical barrier (with change offootwear), cordoning of the affectedareas, should be used in and aroundcontaminated areas.
Control of workers’ exit fromcontaminated areas ensures thatradioactive material is not
inadvertently removed transferredfrom the area by personnel orequipment.

Clarification

A

Prevention should beemphasized

In the bullet list,
recommendation to use
charcoal filter may be
added to therecommendation of HEPA
Unclear recommendation
with reference to “multiple
tier approach”

Clarification

R

A

A

A

158/193

Existing text is adequate

Add “or adsorbers”
resolutions)(seepreviousOccupational Radiation Protection (DS453)
82.

9.30

83.

9.31

84.

9.34

85.

86.
87.

9.35

9.36
9.37

Necessary monitoring of tools orother material and equipment shouldbe performed by trained radiologicalcontrol personnel.
Transfer the end of 9.31 (ifbackground radiation… necessary
checks) at the end of 9.30
A contamination monitoring
programme should be carried out aspart of the prior radiologicalevaluation and ongoing safetyassessments, and to verify theeffectiveness of the measures forpreventing and controlling surface
contamination.
The instruments and techniques used
for contamination monitoring should
be appropriate for the types, levels
and energies of the radiationencountered.
Contamination
control devices should be locatedin areas with a low radiation
background. Instruments should be
regularly maintained…
Locate 9.36 after 9.39
The measurements, in counts per
second, need to be converted to unitsof becquerels per square centimetre.
Some surface contamination meters
are programmable. The user sets the
instrument’s likely response to theradionuclide in use and obtains a

No reason to restrict task
to radiological control
personnel.

R

Same topic

A

Prevention should beemphasizedA

See resolution to comment 55 of UK

See resolution to comment 55 of UKR

Not necessary details

R
R

Existing structure is adequate.
Existing text is adequate.

Otherwise, the detector is
influenced andcontamination might not
be detected.
More logical orderNot a recommendation

159/193Occupational Radiation Protection (DS453)

88.
89.
90.

9.38
9.40
9.41

91.

9.42

92.

9.43

93.

9.48.

direct measurement of surface
contamination (in becquerels per
square centimetre).
Merge 9.38 with 9.37
Locate 9.40 after 9.41
These tests are should be conductedby qualified experts using calibrated,uniformly contaminated plaques withan active area of similar dimensions
to the detector.
To minimize the spread ofcontamination, the employer should
provide, in addition to personal
protective equipment, washingfacilities for all workers,

Same topics
More logical order
Clarification

R
R

Existing structure is adequate.
Existing structure is adequate.

R

To prevent inadvertent intakes byworkers, the employer….
Move 9.44 to after the end of 9.42,
delete “to prevent the intake ofradioactive material” and add “toilet
facilities”.)
Not appropriate here

A

Clarification

A

No one should eat, drink, chew gum
or tobacco, urinate, smoke or takesnuff in working areas whereradioactive material could be ingested.
Other cleaning agents should beselected
based
upon
their
effectiveness, hazardous properties,
amountofwaste
generated,compatibility with the contaminatedsurface and other systems or items
that may be contaminated (including
protective clothing and waste
handling systems), and ease of
disposal (see ISO 8690:1988
Decontamination of radioactively
contaminated surfaces -- Method

A

160/193

Reference to the two ISO standards
added.

Occupational Radiation Protection (DS453)

94.

9.52

95.

9.58

96.

9.64

for testing and assessing the easeof decontamination and ISO
9271:1992 Decontamination ofradioactively
contaminatedsurfaces-Testingofdecontamination
agentsfortextiles)Personal protective equipment should
be selected with due consideration of
the hazards involved. The equipment
should not only provide adequate
protection but also be convenient andcomfortable to use.
If the user must wear more than one
personal protective equipment, a
special care should be drawn on thecompatibility between them.
Where there is the potential forcontamination warranting suchprovisions:- personal
clothing
andworking clothing should bechanged in suitable locker
rooms, where appropriate
with a washroom in between,
to control the spread ofradioactive contamination ;- Individuals should shower
and change clothes on leaving
contaminated workplaces.
However, the use of this methodshould be kept to a minimum, and job
rotation should never be used as aInterfaces between them
may be the weakest pointof the protection provided
to the user.

R

Details already contained inShowering is not
systematic and lockers
room may be limited to afew hangers…

R

Already addressed in comment #63 ofUK

Clarification

R

Job rotation is aimed to reduce individual
dose (already in text), not collective
dose.

161/193Occupational Radiation Protection (DS453)

97.

10.7

98.

10.23

99.

10.27

substitute for the development anduse of appropriate methods ofindividual and collective exposure
control to maintain individual andcollective dose ALARA.
The
occupational
physician,including any private occupational
physician employed on a part timebasis, should be knowledgeable,
through training and retraining
where necessary, on the medical
effects of radiation exposure, themeans of control of exposure, andthe interpretation of exposure data
and dosimetric assessments
The occupational physician shouldtakeresponsibility
forcase
management in the event of asuspected overexposure.
In special circumstances where
workers
who
smoke
have
experienced lengthy exposure todusts and/or radioactive gases andparticulates,theoccupational
physician may need to consider
instituting a programme of sputum
cytology

R

What is the purpose and A
the interest of sputum
cytology in this case?,give a reference or delete
the paragraph (lung cancer
screening using sputum
cytology have not bedemonstrated to influencelung cancer mortality)
The occupational physician should be If the limit is in term of
informed when it is suspected that an dose,
the assessment
accidental intake may exceed a limit could take several days ormonths. In this case, thespecified by the regulatory body

162/193

Already covered in 10.5

Delete 10.23 (it’s the physician who
decide)R

Redundancy (covered by the word
“suspected”)

Occupational Radiation Protection (DS453)

100.

Appendix I
1.1

This is because the dose is quite
strongly influenced by the types ofradionuclide
andtheactivity
concentrations in the material,reflecting the underlying linear
relationship between these twoparameters.

101.

Appendix
II.41

A dosimeter based only on PADC has
an energy threshold of about 100–150
keV, but its low energy response canbe improved for example by the useof a plastic filter which contains
nitrogen. Low energy neutrons reactwith nitrogen by the capture process
to produce protons with an energy ofabout 0.5 MeV. Its angular response
is not always very good but if themean response is averaged overangles of 0°, 20°, 40° and 60°,
a response that is flat to within ±30% is obtained in the 0.15–14 MeV
region an acceptable response canbe achievable. The use of thenitrogenous
plastic
filteralso
produces a satisfactory response
from neutrons in the energy range
from thermal to 10 keV. This type ofoccupational
physicianshould be informed beforetheassessmentisperformed.
The sentence is not clear. AItismathematicallyincorrect to state theexistence of a linear
relationship between aquantitative
variable(“activity concentration”)
and a qualitative variable(“types of radionuclide”).
Performances of the recoil
track detectors dependofmanyparameters(quality of the material,material used for thedetector
container,
specificitiesofthechemical treatments andof the optical means used
to read the tracks,
methods to analyze thetracks).
So,
Characteristics
andachievable performances
given in this paragraph are
not general enough for all
recoil track detectors.

163/193

This is because the dose is quite strongly
influenced by the radionuclide activity
concentrations in the material, reflecting
the underlying linear relationship between
these two parameters.

A, mSv can go as low as 0.1 mSv. with ahigh level tuning.

Occupational Radiation Protection (DS453)
detector is not sensitive to photons, itdoes not suffer much from fading
and the dose threshold
is 0.2 mSv can go as low as 0.1 mSv
with a high level tuning.
Table 1 :Radionuclide

218Po
214Pb
214Bi
214Po

Half life
(s)
3,07
26,9
19,8
162,3

184,2
1614
1188
0,0001623

alpha energy
(J)

keV
6002

Yield
(%)

PAE
J/Bq

9,6152E-13

1007833 1,25485E-12

100
sum

164/1935,88987E-10
2,92192E-09
2,15071E-09
2,93822E-16
5,66162E-09

Occupational Radiation Protection (DS453)

Reviewer: ENISS
Page: 1 of 19
Country/Organization:
05 2014
Comment
Para/Line
No.
No.

General comments

DS453 Occupational Radiation Protection (10 February 2014)
ENISS Comments
RESOLUTIONENISSProposed new text

Date: 27
Reason

A
cc
ep
te
d

In general we welcome the publication of this Safety Guide. It seems
reasonable to gather the guidance regarding occupational exposure
for all types of exposure situations in one document. The document
is, however, difficult to read due to its length, the structure is notvery convenient for the reader and it is often not easy to identify thekind of facilities or activities concerned. The guide seems to bemainly written for complex facilities and small users may havedifficulties to find out what is useful for them.
It also appears to be difficult to use the guide with respect tospecific topics, for example, the individual monitoring from external
exposure is very fragmented between sections and appendices (idemfor the monitoring from internal contamination).
The document could benefit from a reduction of pages trying toeliminate all the redundancies and simplifying or eliminating parts not
adding much to the scope of the document (eg appendix biokinetic
models).
Chapter 4: is to quite a large extent (about half of the para) copiedfrom BSS and GSR Part 7. Therefore little further guidance is given(or references to such guidance). The references to GSR Part 7 arequestionable since this is only a draft.
Chapter 8: when services are provided at the customers site, therelation of the service provider’s management system and the

165/193

Accepted, but
modifiedasfollows

Re Reason for modification/rejection
je
ct
ed

GSR Part 7 is in advanced stage of approval.
This will be considered during the editorial
process.

Occupational Radiation Protection (DS453)
customer’s one need to be clarifies. Also the relation and applicationof sub-contracting companies is not mentioned in the chapter (apartfrom the accreditation part).
Chapter 6: more clarity would be needed on the share of
responsibilities between employers of a facility and contractor foritinerant workers in regard to: dose assessment, dosimetry, records,
training and health surveillance. A lot of examples are used thatcreate confusion.
Chapter 7: the wound model of ICRP 156 is not mentioned. There
should be a point in the section: "Interpretation of measurements anddose assessment".
Chapter 9: problems with the ventilation is mentioned only in regards
to the mines but not for the nuclear cycle facilities where ventilationis also essential (for example, reprocessing plants and installations
where alpha emitters are handled).

1

2.27

2

2.34

Detailed proposals for changes are marked in red.
Add subtitle Protection
Protection Quantities (before 2.7)
Quantities before
requirement 2.7 asfollowing paragraphs
address this issue.
The term collective effective dose may The collective dose is not abe used as an instrument forprotection quantities. It
optimisation, for comparing
makes more sense toradiological technologies andexplain its use inprotection procedures. These
optimization section for
quantities takes account of theexample after the concept
exposure of all individuals in a groupof dose constraint (3.32)
over a given time period or during agiven operation executed by this groupin designated radiation areas. The
collective effective dose is calculated

166/193

R

Already explained in the text

A

Already addressed in resolution to comment#6 of Italy (IRPA/AIRP)Occupational Radiation Protection (DS453)

3

2.47

4

2.52.

5

2.58

as the sum of all individual effective
doses over the time period or during
the operation being considered andexpressed in the special name ‘mansievert (man Sv)’.
For exposure of the lens of the eye,the recommended depth is 3 mm, butthere are at present no publishedconversion coefficients for convertingfrom the basic physical quantity kerma
to the directional dose equivalentH'(3).
However, if the monitoring devices is
not designed to measure H'(3),H'(0.07) may be used as surrogate asreported in ICRP 116 [85].

Ref. ICRP 116

To derive the value of committed
equivalent dose to a tissue or organ,
the intake is multiplied by hT(g) HT(g),the committed equivalent dose per unit
intake for ingestion or inhalation, as
appropriate, by the group of age g. For
routine occupational exposure
evaluation adults group of age isconsidered except for apprentices.
In situations of exposure to a single
The proposed text isradionuclide by inhalation or ingestion, unclear and may create
with no external exposure, the limit on confusion

167/193

Already addressed in previous resolution tocomment #8 of Italy (IRPA/AIRP)

A

R

Original text is clear and needs to be retained.

Occupational Radiation Protection (DS453)

6

3.15
New

7

3.23

8

3.25

(a)

intake IL corresponding to the limit Lon effective dose is defined as givenby:(7) ) I L = L/e(g)where e(g) is the applicable value ofthe committed effective dose per unit
intake. When there is internal exposure
to a range of radionuclides and/or
external exposure, the total effective
dose should be calculated bysummation of the individual
contributions and compared with therelevant limit on effective dose.
New: A RPP is not necessarily a single
document. It may be the sum of
documents issued for an application
for a license, a operational manual or asimple user guide, especially forregistered practices.
The process of optimization ofprotection and safety measures may
range from intuitive qualitative
analyses to quantitative analyses using
decision aiding techniques, but has tobe sufficient to take all relevant factors
into account in a coherent way so as
to contribute to achieving thefollowing objectives:(a) Identify all practicable protection
options that might potentially reduce
the occupational exposure;(b) Identify all relevant economic,
social and radiological factors

For clarification to avoid
bureaucracy.

R

Not relevant

Too much sophisticatedR

Existing text is adequate.

Exaggerated, not needed
and not practice.

R

The existing text is necessary.

168/193Occupational Radiation Protection (DS453)

9

3.26

10

3.27

11

3.28

(sometimes non-radiological factors aswell) for the particular situation underreview that distinguish between theidentified options, e.g. collective dose,
distribution of individual dose, impact
on public exposure, impact on future
generations, investment costs;(c) Quantify, where possible, therelevant factors for each protection
option;(d) Compare all options and select the
optimum option(s);These techniques must be seen as
tools to help structure problems inorder to compare the relative
effectiveness of various possible
protection options, to facilitate theintegration of all relevant factors andto improve the coherence of decisions
taken
Dose constraints are may be used for
optimization of protection and safety,[…]
Dose constraints are may be applied tooccupational exposure and to public
exposure […]Dose constraints are set separately foreach a source under control
After exposures have occurred, tThedose constraint may be used as abenchmark for assessing the suitabilityof the optimized strategy for

Not necessaryR

See previous comment

Dose constraints are not arequirement but an option.

R

Text from BSS.

R

Text from BSS.

Not each source needs tohave a dose constraint,
only if appropriate.
Otherwise in contradiction
with 3.30 last sentence

169/193Occupational Radiation Protection (DS453)

12

3.29

13

3.59

14

3.63

protection and safety that has been
implemented and for making
adjustments as necessary
It is necessary to ensure that dose
constraints are set such that dose
limits for occupational exposure arecomplied with when workers incur
exposures from multiple sources ortasks.
(c) The integration of occupationalradiation protection with other areas ofhealth and safety such as industrial
hygiene, industrial safety and fire
safety;In order to coordinate decision making
concerning the choice of measures forprotection and safety, it may beappropriate in large facilities,
depending on the size of theorganization, to create a specificadvisory committee withrepresentatives of those departments
concerned with occupational
exposure. The main role of thiscommittee would be to advise senior
management on radiation protection
the RPP. Its members should therefore
include management staff from therelevant departments and workers withfield experience. The functions of thecommittee should be to delineate themain objectives of radiation protection
the RPP in general, and operational

To reach that objective
dose constraints are notneeded. It can simply becontrolled by personnel
dosimetry.

A

The setting of any dose constraints should besuch that dose limits for occupational
exposure are complied with when workers
incur exposures from multiple sources ortasks.

Outside the scope of a RP
standardR

RPP cannot be developed in isolation

The objective is radiation
protection. An RPP, if
there is one, is only one
tool.

R

Current text is appropriate

170/193Occupational Radiation Protection (DS453)

15

3.64

16

3.65

17

3.70

radiation protection in particular, tovalidate the protection goals, to makeproposals regarding the choice ofmeasures for protection and safety andto give recommendations tomanagement regarding the resources,
methods and tools to be assigned to
the fulfilment of the RPP.
The RPP management should specify
the need for and designate qualified
experts in the relevant fields, such as:(a) Radiation protection;(b) Internal and external dosimetry;(c) Workplace monitoring;(d) Ventilation (in underground mines,
for instance);(e) Occupational health;(f) Industrial safety;(g) Industrial hygiene;(h) Radioactive waste management.
Management should ensure that therelevant services of qualified experts
are provided and that the persons
providing such services relating toradiation protection work in close
cooperation and maintain closeworking contacts with persons
responsible for the control of nonradiological hazards.
Management should consult theappointed qualified experts asappropriate on aspects of radiation

See aboveA

Retain RPP
Accept delete (f) and (g)Outside the scope

Outside the scopeR

It is RP and not the
programmethatisessential.

R

171/193

Current text needed.

Occupational Radiation Protection (DS453)
18

3.73

19

3.76

20

3.83

protection the RPP,
The accountability system for radiation Disposal is a word
generators and radioactive sources
dedicated to the long term
should include an inventory that
underground disposal
contains records of the location anddescription of each radiation generator
or radioactive source and the activity
and physical/chemical form of eachradioactive source. This inventory has
to be updated periodically. In addition,
consideration needs to be given to
keeping records on any special
instructions for each radioactive
source held and details of the storage
disposal of any such source
An area should be designated as acontrolled area when management
considers that there is a need to adopt
procedural controls to ensure an
optimized level of protection andcompliance with the relevant dose
limits [..]Such an approach may still beappropriate, but it should not be usedwithout careful radiological evaluation.
For instance, account should be takenof the length of time for which thedose rate remains at or above thedefined level and the risk frompotential exposures
The essential purpose of a supervisedarea is to identify those parts of theR

Deleted text may give awrong impression of thefeatures of RP.

R

Text importantWrong interpretation of the
purpose of a supervisedR

Follows the BSS

172/193Occupational Radiation Protection (DS453)
workplace that should be subject toregular review of the radiologicalconditions to determine whether the
status of the area should be changed— as a result, for example, of
circumstances that were not foreseenin the prior radiological evaluation —or whether there has been somebreakdown of control, either in thedesign features or in the proceduresthat operate in any adjacent controlled
area.

21

3.85

22

3.87

23

3.88

Although it may be appropriate inmany cases for It is not necessary forthe boundaries of supervised areas tobe marked with caution signs, thismay not always be necessary or
productive. For example, it may benecessary to designate supervised
areas in parts of hospitals to which
members of the public may haveaccess; signs at the entrances to suchareas may cause unnecessary concern.
The local rules and procedures should
correspond to the design andobjectives of the facility concernedand should be designed to aid the
optimization of protection and safety.
The local rules and procedures shouldarea.
To avoid misinterpretation,reference should be madeto the definition of theconcept of supervised area
provided in the COUNCIL
DIRECTIVE
2013/59/EURATOM
of 5 December 2013:"supervised area" meansanareasubject
tosupervision for the purposeofprotection
againstionising radiation;
There is no need to marksupervised areas and thisshould be clearly stated.

R

The
importantandoverruling objective is
protection and safety.

R

The local rules there areR

173/193

Consistent with IAEA BSS

There are no procedures in supervised areas

Occupational Radiation Protection (DS453)

24

3.92

25

3.93

describe the organizational structures
and the procedures to be followed incontrolled and supervised areas andmay include some or all of theprovisions for various components of
the RPP, such as:

also in supervised areas

When engineered and operational
controls are not sufficient to provide
an optimized level of protection for thetasks to be performed, management isrequired in terms of para. 3.95 of the
BSS to provide suitable and adequate
personal protective equipment that has
been properly maintained and tested,
as appropriate.
When work is to be conducted during
which significant radiation orcontamination levels may be
encountered, or when the work iscomplex (involving several groups ofworkers and numerous activities),
advance work planning is one of themost important means of achieving
optimization of protection and safety.
The RPO should take part in theplanning of work involving significant
exposures, and should advise on theconditions under which work can beundertaken in controlled areas. The
situations which warrant the use ofdetailed work plans and work permits
are generally encountered in theNotallprotective
equipment have to beprotected beforehand.

R

Out of scopeR

174/193

Current text is appropriate

Occupational Radiation Protection (DS453)

26

3.93

27

3.94

28

29

3.95

3.99

nuclear industry, but may also befound in non-nuclear industries (e.g. inthe maintenance or dismantling ofaccelerators).
The situations which warrant the useof detailed work plans and work
permits are generally encountered in
the nuclear industry, but may also befound in non-nuclear industries (e.g. inthe maintenance or dismantling ofaccelerators). Additional guidance on
the use of work planning for
optimization has been published by
OECD/NEA [19] [xx].
(d) Operation state of the plant (e.g.
for a nuclear power plant, cold or hot
shutdown, operation at full or
decreased power);(j) Conventional safety.
The RWP is issued by the persons incharge of the planning of theoperations, in collaboration with the
RPO.
(d) An estimate of individual andcollective exposure for each work
step;
The monitoring programme should bedesigned by management qualified
expert on the basis of the priorradiological evaluation discussed inparas 3.53–3.55, with due account

The last publication of the
NEA on work management
and optimization is :"WorkManagement to Optimize
Occupational RadiologicalProtection at Nuclear
Power Plants - OECD 2009
NEA No. 6399." It could
be included in thereferences

A

Replace Ref[19] with the more recent one

R

Out of scope.
Radiation work permit is
exclusively the competenceof the RPO.

R

Too detailed
It is the qualified expert
which is competent for
that, not the management.

175/193A..designed in consultation with an appropriatequalified expert….

Occupational Radiation Protection (DS453)

30

3.122

31

3.123

32

3.129

33

3.137

34

3.141

being taken of regulatory
requirements.
They should be defined bymanagement in the RPP, their purpose
being to facilitate the control ofoperations and exposures.
Investigation levels should be used in a
retrospective sense only and should
not be confused with dose constraints
Even if the measured dose, exposure
or intake is below the recording level,
the measurement result should always
be maintained in the dose record forthe workplace and/or the individual.
The dose records should be easily
retrievable and should be protectedagainst loss. Such protection is usually
may be obtained by maintaining
duplicate sets of records in well
separated locations, so that bothcopies cannot be destroyed in a single
incident.
It is the management’s responsibility
to ensure that workers who may beoccupationally exposed to radiationand persons with assigned
responsibilities in the RPP receive
general radiation protection
information and training. This should
include training of workers’
representatives and members of
relevant safety committees whereappropriate.

They canelsewhere.

bedefinedR

RPP is the logical place

Dose constraints will withhigh probability be used as
investigation levels.
Resultsbelow
therecording level are Zerovalues.

R

Not a valid reasonR

See Comment 2-IRPA/Romania
See comment no.8, China
Modified to cover internal exposure

Dose
records
aremaintained by the operator
and the dosimetry service
organization, so they are
already duplicated.

RR

Too vague

176/193

Text is clear

Occupational Radiation Protection (DS453)
35

3.142

36

3.150

37

3.153

38

4.6/first
sentence

Senior management should be trainedin the risks associated with radiation,
the basic principles of protection andsafety, their main responsibilities
regarding radiation risk management
and the principal elements of the RPP
RP-regime.
Formal records of each worker’s
training and testing should bemaintained, and retained for three
years after cessation of employment.
The regulatory body licensee should
provide guidance on establish
qualification requirements for eachcategory of job. This guidance should
address the minimum educational level,minimum training and retraining
requirements and minimum experiencefor each job category should bedetermined. In addition, the regulatory
body should enforce requirements
concerning the recognition ofqualifications relating to certain duties
and responsibilities, such as those of
RPOs. Alternatively, The regulatory
body should review and approve, if
appropriate, proposals regarding
training requirements made bylicensee’s management

To be in line with thepractice.

R

Too heavy workload for asmall added value.

R

Modified in response to comment X fromcountry X

Establishing the training
path is not the
responsibility of theregulatory body.
Furthermore the RPO is
not assumed to be qualified
by the regulatory body.

R

Consistent with the relevant IAEA standards

The emergency plan should include the Point out that it is only partfollowing aspect regarding protectionof the content of anof emergency workers:
emergency plan

177/193

A

With regard to the protection of emergency
workers, the emergency plan should
include….

Occupational Radiation Protection (DS453)
39

4.15/Table
2

This value may be…”

40

4.16/Table
3

ADFetus …AD (delta’) Fetus

41

4.17

When military personnel are designatedas emergency workers, every effort
should be made so that they areprotected in the same way as otheremergency workers.

42

4.21

Even if the table is a copy
paste from GSR part 7, thereadability would improve
if the text in the rightcolumn “This value…” isleft out. The text is foundin with the same
formulation in the para
4.15/last sentence justabove the table.
Use the same spelling

If military personnel takepart in the emergency workand therefore are part ofthe emergency organization
there is no reason to
specifically address them
here.
Tasks should be assigned depending
The information in theon the category of emergency worker 178aragraph is already inas follows:
the draft.
(a) Category 1 emergency workers
A repetition of part of 4.19
should carry out actions to save life or (a)prevent serious injury and actions to
implicit from 4.19
prevent severe deterministic effects
repetition of text in 4.19
and actions to prevent the development (a) and (b)of catastrophic conditions that could
Already in 4.14
significantly affect people and theenvironment;(b) Category 2 emergency workers
should not be the first choice for

178/193

Editorial
This will be considered during the editorial
process.

A

R

R

editorial
This will be considered during the editorial
process.
No necessarily in all cases

4.21 relates specifically to tasks. Any
repetition will be addressed by the IAEA
editors
4.2 replace “to” by “that may ”
Emergency workers, who have specified
dutiesOccupational Radiation Protection (DS453)

43

4.26

44

4.28

taking life saving actions;(c) Category 1 and Category 2
emergency workers should carry out
actions to avert a large collective
dose3.
(d) Category 3 emergency workers
should carry out those actions inwhich they will not receive a dose of
more than 50 mSv.
The degree of accuracy required forany exposure assessment should
increase with the level of exposure
likely to have been received by theworker. Some pre-establishedguidance may help in the managementof exposures of emergency workers in
Category 1 and Category 2, expressedin terms of dose and directly
measurable quantities such as dose
rate or air concentration.
Workers should not normally beprecluded from incurring further
occupational exposure because ofdoses received in an emergency
exposure situation.

Also the workers of
category 2 can receive highdose values

Article is not needed
because covered by Art
4.30

R

A

The proposed additional text is not necessary.

Relocate 4.28 to after 4.23 and move 4.24 toafter 4.21
Modify para 4.30 as follows :Although, an emergency worker or
accidentally exposed employee who receives
doses in nuclear or radiological emergency
should normally not be precluded fromincurring further occupational exposure,qualified medical advice should be obtained
before any further occupational exposure if
an emergency worker or accidentally exposed
employee has received an effective dose

179/193Occupational Radiation Protection (DS453)
exceeding 200 mSv or at the request of theworker.

45

5.19

A reference level is an important toolin the optimization process. It
represents a level of dose (or risk inthe case of potential exposure) above
which it is judged to be inappropriate
to plan to allow exposures to occur. In
considering the various possible
remedial or protective actions, areference level serves as an upperbound on the range of options
considered; this will ensure that the
optimized protection strategy will be
aimed at reducing doses to some value
below the reference level.

The potential exposure is
only defined for planned
exposure situation

A

46

5.88

Monitoring and dose assessment are
essential inputs to the ongoing
optimization process. Further guidanceis provided in Refs [37, 38, xx].

A

47

8.1

48

8.4

49

8.10

The services provided by technicalservice providers might, but notlimited to fall into two categories:
The management system of a service
provider using radiation should be inaccordance with national requirements
and all relevant IAEA safety standards.
For a service provider, safety culture
can be established by:

It can be added between
the references publication
ICRP 123: Assessment ofRadiation Exposureof Astronauts in Space
Not to exclude and limit
new possibilities
National requirements are
to prevail and normallyincorporate the IAEA
standards
The same safety culture
recommendations should

180/193…may be divided into two categories

A

R

This is upto national authorities….

R

Not necessaryOccupational Radiation Protection (DS453)

50

8.17

51

8.31

52

8.37

…..
For a service provider same safety
culture recommendations apply as forthe facility operator.
The form and layout of the
management system documentation
should fit into the internal
communication culture of theorganization.
Human resources include all the people
in the organization who are involved inachieving the objectives.

With regard to the working
environment, consideration should begiven to how best to combine theconsideration of human factors andphysical factors with achieving thegoal of enhancing the performance ofthe organization. Attention toworkload, stress factors, social
structure within the organization,internal communication, workplacesafety, ergonomics, lighting,ventilation and many other factors can
all be combined to enhance the overall
effectiveness of the organization inachieving its objectives. The
organization should develop
descriptions of minimum criteria for
the workplace conditions necessary to

be used by all organisations
involved

Unnecessary details

A

Does that mean that staff
not involved in work
directly linked to theobjectives, is notconsidered as a humanresource?
Does not seem appropriatethat IAEA goes into thisarea of competence.

A

181/193

See modification based on previous
commentsA

See modification based on previous
comments
Already addressed.

Occupational Radiation Protection (DS453)

53

8.40

54

8.48

55

9.8

achieve the various objectives.
Radiological protection should be
integrated with Health and Safety as
well as Environmental management.
In the planning schedule, accountshould also be taken of the need forplanning for ensuring the traceabilityof measurement results to the SI
system and for establishing
information on uncertainties for thesemeasurement results.
…
(a) Repeated tests (possibly done using
different instruments for analysis);(b) Checks on introduced blank or test
samples;(c) Plausibility tests on the results,
done by applying expert knowledge,
etc.
The results of these measurements
should be recorded as proof of thecontrol of the production processvalidation of the final product.
[...].The adequacy of the shielding forthe proposed work program should beapproved by the regulators and any
breach of shielding causing exposureof the workers should becommunicated to the regulators

Well, since this para deals
with the development
processs, it might bereasonable to place thisrecommendation in thecorresponding para
“Planning” after 8.26.
Actions described are more
validation of the resultsthen control of the process.

There is no rationale to put
a special attention on theshielding. Shielding is oneof the 3 pillars of ALARA.
It is not the current
practice to make theshielding means submitted
to the approval of theregulatory body and there
is no rationale that it should

182/193

See WNA19

See WNA20

AOccupational Radiation Protection (DS453)
56

9.34 
9.41

Surface contamination monitoring
It is proposed to scratch those article
or to summarize to only one and linkto an appropriate safety guide

57

9.47

The employer should ensure thatworkers are provided with first aid
training that is specific to the job

58

9.52

Personal protective equipment should
be selected with due consideration of
the hazards involved. The equipment
should not only provide adequate
protection but also be convenient andcomfortable to use. Attention will be
brought to the benefit of wearing theprotective equipment on the overall
exposure. In particular one should
avoid any increase of exposure causedby the additional constraints of theprotective equipment.

be from now.
Those articles deal with thecharacteristics and use of
the contamination
measuring equipments.
This paragraph does not fit
really in the scope of theDS453 as this is a radiation
protection expertise domain
in its own, that deserve acomprehensive treatment indedicate safety guidance.
The proposed articles from
9.34 to 9.41 are necessarily
incomplete. These should
be addressed in a separate
guidance document.
Scope of DS453 isradiation protection

Application of the
optimization principle
ALARA.

183/193

A

R

Useful guidanceR

relevant

Personal protective equipment should beselected with due consideration of the hazards
involved. The equipment should not only
provide adequate protection but also be
convenient and comfortable to use
Consideration should also be given to thepossibility of an increase in exposure causedby the additional constraints of the protective
equipment.

Occupational Radiation Protection (DS453)
59

9.55

If levels of airborne contaminants
exceed the safe working levels(Derived Air Concentration – DAC)
specified by the management of the
facility, appropriate respiratory
protective equipment should be wornby those persons undertaking actions
under those circumstances to correct
the situation. While corrective
measures are being undertaken, thearea should be monitored to estimate
possible exposures [...]

It is industrial reality that awork other that the one
here mentioned (to correct
the situation) has to be
performed under poor air
quality, requiring
respiratory protection.

60

9.56

[...]

Same remark as for theAshielding (9.8) : there is norationale providing a special
focus on the respiratory
protection program.

(m) The programme for respiratory
protection should be acceptable to theregulatory body and the respiratory
protective equipment should be as per
the quality requirements set by theregulatory body

184/193A

Occupational Radiation Protection (DS453)

COMMENTS BY REVIEWER
Reviewer: Peter Colgan on behalf of Radiation Health Committee
Country/Organization: AUSTRALIA/ARPANSA
Comment
Para/Line
Proposed new text
No.
No.

RESOLUTION
Page..4 of.6.
Date: 30 June/2014
ReasonAcceptedAccepted, but
modified asfollows

Rejected

Reason formodification/rejection

1

GeneralOverview of the Document: The document would benefit fromeither a new structure where the duplication between sections is
reduced or potentially the document be separated into a number ofsmaller documents for each exposure situation. For an operator oruser of the resulting documents, it is unlikely they would want all
exposure situations and would prefer a document with focuses on
the area of specific importance.

R

Duplication between
sections is notexcessive. The
structure and content
of the document are
in accordance withthe approved DPP.

2

GeneralDepth of the Document: The document in some ways tries tocombine the function of a Safety Guide with that of a reference text.
The depth to which the science is delved into is far more than would
normally be expected in a safety guide. It also is beyond the level
which would be required by most users of the guide and this excess

R

The structure andcontent of the
document are inaccordance with theapproved DPP.

185/193Occupational Radiation Protection (DS453)
of knowledge will detract from the usability of the document formost operators. A lot of the scientific information should not be
included in the main text and could either be served by appropriate
referencing or by the use of technical appendices to separate thescientific detail from the more practical implementation material. The
major concern is that a user of the Safety Guide will not be able tofully use the document and as such the effectiveness will bedecreased. A Safety Guide should not try and replace a reference
text on radiation protection but should provide the guidance to thebasic information and how it can be applied.
3

General4

GeneralBreadth of the Document: The document has an extremely large
breadth and attempts to cover all aspects of occupational radiation
protection. Although commendable, this desire to cover all basesmeans that not all aspects apply to all operations. For an operation todetermine what would be applicable requires considerable effort andnon-consideration may require additional work to justify the rejectionof the component. The use of flowcharts or some other manner fornavigating the document for different scenarios might be a method
to improve the usability of the document.
Use of the Document: The document, as a Safety Guide, is notintended to be a regulatory instrument and is intended to provide a
supporting document to the Basic Safety Standards (BSS) which
may be utilised within a regulatory format. However, experience has
shown that IAEA documents often are used for regulatory purposes
even when this is not the intended use. In some regulatory regimes,
IAEA documents have actually been given legal status and this cancause difficulties and legal issues with such a comprehensive
document. In some ways this confusion on its regulatory status isincreased due to the frequent referencing to the BSS and this canmake it difficult for the reader to distinguish between BSS andguidance recommendations. A direct statement that the Safety
Guide should not be considered a regulatory document should be

186/193R

The structure andcontent of the
document are inaccordance with theapproved DPP.

R

This draft Safety
Guide is part of the
Safety Standards andits legal status (or,rather, lackthereof) is nodifferent from that ofother Safety Guides.

Occupational Radiation Protection (DS453)
5

General

6

General7

Generaladded into the scope.
Assessment of Occupational Exposure: The section on
Assessment of Occupational Exposure could be a separate safety
guide which just concentrates on this aspect. Although its inclusionin the document does provide completeness, the sheer amount of
information raises the question whether it would actually be used.
This section would be better served by either being a separate
document or a technical appendix with the overview provided in themain body.
Worker Health Surveillance: The health surveillance of radiation
workers is an area which is often difficult to manage and also has
the potential for raising the risk profile of radiation beyond the actual
risk. Although most of the information may be appropriate for large
facilities, the applicability of it to smaller areas of radiation use may
be problematic. Recommendations that the occupational physician
should be familiar with the work area and take control in an
overexposure situation is unlikely to be practical for most smaller
operators. This type of specialised knowledge, capabilities and close
relationship to an operation only exists in the minority of operations
and trying to apply to all workers is unlikely to be successful.
Conclusion: Although the Draft Safety Guide is extremelycomprehensive and goes into considerable scientific depth, thisactually works against the usability of the document. It is strongly
recommended that the structure of the document be re-examined to
improve the usability of the document. This could be done by further
use of scientific appendices, the greater use of technical references,the highlighting of the key points, or the separation of the document
into smaller components which are more targeted for as individual
exposure scenario (planned, existing and emergency). The current
document seems to be attempting to combine the usefulness of a
Safety Guide with a reference text. As such calling it a Safety Guide
is inappropriate and the document is more representative of a

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The structure andcontent of the
document are inaccordance with theapproved DPP.

R

For smaller areas ofradiation use, theamount of specialized
knowledge of theworking conditions
on the part of theoccupational
physician will becorrespondingly
lower, so it shouldn’t
be problematic.

R

The structure andcontent of the
document are inaccordance with theapproved DPP.

Occupational Radiation Protection (DS453)

8

Specific

9

Specific

10

Specific

11

Specific

Technical Report and should be referred to in this format. Thisdecreases the usability of the document and hence the need forseparation of the deep scientific information from the guidancematerial. Finally the scope of the document needs to be more clearly
define to prevent the use of the document as a quasi-regulatory legal
instrument
The term ‘radiation protection and safety’ is evident in the early
chapters of DS453, referring to radiation protection of persons andthe radiation safety of sources. However by Chapter 8 (Management
Systems) the term is almost exclusively ‘radiation safety’. Suggest
the entire document be checked for consistent use of terminology

As DS453 is a guideline document and not a requirements level
document, the normal practice is not to use the terms ‘shall’ or‘must’. It is suggested that the document be checked for theincorrect use of such terms - for example in 5.8.3(c) where in line 6
it states ‘the employer must adapt the working conditions..’ whenreferring to pregnant aircrew.
References to lower level IAEA documents should not be made in
IAEA Safety Guides as a matter of IAEA policy, and attention isdrawn to three ERP documents at references 30, 31 and 146. These
references should be removed, and the use of footnotes employed toindicate to the reader the existence of information that, whilst
relevant, has not undergone any Member State peer review process
as is normally employed for IAEA publications.
There is a lack of discussion on procedures for managing

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AR

The problem occurs
only in Section 8(paras 8.1, 8.2, 8.19,
8.29, 8.38, 8.41,
8.45, 8.54, 8.65,
8.67, 8.68). For
consistency with therest of the document,
the word “safety” inthese paras havebeen replaced by“protection andsafety”
These terms are onlyused where there isreference to a
Requirements
document.

R

It is acceptable forlower level IAEA
documents to bereferenced.

R

In principle, theOccupational Radiation Protection (DS453)

12

Specific

13

Specific

14

Specific
7.3

occupational exposures associated with the management of wastes
and residues. In mineral extraction and processing the generation andmanagement of wastes and residues is an integral part of theextraction and processing.
There is no guidance on procedures for compiling records ofoccupational exposure for emergency workers or itinerant workers
in a national registry.
FIG 3 – clarification is needed. This highlights a more general issueof how planned and existing exposure situations are defined by the
ICRP and in GSR-3. These definitions say nothing at all about
radionuclide concentrations, and are quite simple to apply. However,in DS453, the definitions have been (effectively) changed, and are
now based on radionuclide type and concentration.
 For example, uranium mining is a planned exposure situation;
regardless of the radionuclide concentration. For othernatural radionuclides, the situation is planned or existing
based on whether the activity concentration is greater thanor less than 1 Bq/g. This has the potential to cause
considerable confusion, particularly when it is combinedwith the statements in GSR-3 that mineral extraction andprocessing is a planned exposure situation and waste
management may be (depending on radionuclide
concentrations), but use of commodities containing naturalradionuclides is automatically an existing exposure situation.

7.3 – When discussing the requirements a regulatory body should
place on the service provider of a dosimetry service prior to approvalof that service, the requirement to supply dosimeters capable ofmeasuring Hp (3) is made so as to assess the dose to the lens of the

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R

R

procedures are thesame, regardless ofthe source of
exposure.
A national dose
registry is not used in
all countries.
Fig. 3 is merely anillustration to showthat many minerals
are around 1 Bq/g or
less. Uranium mining
is treated nodifferently from anyother type ofmineral-related
activity although, due
to the generally highactivity
concentration, ismore likely to be
subject to therequirements forplanned exposure
situations. The text is
entirely consistent
with the BSS in thisregard.
This para. hasalready beenaddressed in
response toOccupational Radiation Protection (DS453)
eye. Such a suggestion is inconsistent with guidance in numerous
other places in the document, including 7.10 and 7.16(d), where it isacknowledged that ‘such dosimeters are not yet widely available’. It
is suggested that all comments relating to Hp (3) dosimetry
measurements and requirements be checked for consistency andaccuracy.

15

Specific
9.8, 9.9

9.8 and 9.9 - SHIELDING, along with reducing time and increasing
distance, is one of the main principles for reducing radiation
exposure in occupational situations. However the amount ofshielding guidance provided in DS453 (two paragraphs 9.8 and 9.9)
is considered inadequate, particularly when compared to theseemingly excessive detail provided on monitoring measurements
and monitoring instruments (including also two appendices). As aminimum it is suggested that references to the publications of the
NCRP be made for the shielding design calculations. NCRP Report
151 - Structural Shielding Design and Evaluation for Megavoltage
x- and Gamma-ray Radiotherapy Facilities, which addresses the
structural shielding design and evaluation for medical use of
megavoltage x- and gamma-rays for radiotherapy, is widely used in
the radiation protection community. For shielding calculations s
related to x-ray therapy installations of less than 500 kV and forbrachytherapy, NCRP Report No. 49, Structural Shielding Design
and Evaluation for Medical Use of X Rays and Gamma Rays ofEnergies Up to 10 MeV, which was issued in September 1976, isstill relevant. NCRP Report 147 Structural Shielding Design for
Medical X-Ray Imaging Facilities presents recommendations andtechnical information related to the design and installation of
structural shielding for facilities that use x rays for medical imaging– including therapy simulators

190/193

comments fromother countries.

Rwithmodificati
onsThis para. wasalready addressed in
response tocomments fromother countries. As
shielding design isdealt with in detail byother publications thecurrent text is
appropriate.
However, newreference SSG-8
which is radiation
safety of gamma,
electron and x
irradiation facilities(this document
references theindicated NCRP
publications andothers such as BS
4094 parts 1 and 2
on shielding for
gamma and Xradiography) has

Occupational Radiation Protection (DS453)
16

Replace7.110,
7.111,
7.112, and
7.113(Approval of
dosimetryservices)with:Requirements of dosimetry services
7.111. Dosimetry service
providers should be technicallycompetent, able to generate technicallyvalid results and have adequate
administrative, technical andmanagement systems.
7.112. A service provider
should be able to provide an acceptable
degree of accuracy in the assessmentof dose, to achieve and maintain a highlevel of reliability, to communicate theresults of routine dose assessments tothe employer and/or the regulatory
body in a reasonable time and to
rapidly communicate the results ofdose assessments made in the event ofan accident, occurrence or incident. In
addition to satisfying technicalrequirements, a service provider
should satisfy relevant management
system requirements (see Section 8).
7.113. The service provider
should:(b) Have an accredited
management system in accordancewith a relevant international standard
such as ISO/IEC 17025 [86];(c) Be able to certify that thedosimetry system is traceable to theappropriate national standard and isbased on conversion coefficients for

The certification of
accuracy and theappropriateness of thequality management system
could be undertaken by anoutside body and not only
the regulator or agovernment body.

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been added.
The existing text
does not specificallyrequire thecertification of
accuracy by theregulatory body. The
service provider only
has to demonstrate
the necessarycompetencies.

Occupational Radiation Protection (DS453)
the operational quantities inaccordance with international
recommendations and standards;
177.265/line 2

Delete:‘compiled by the dosimetry service
providers’There are methods otherthan dosimetry service
providers for compilingdose records; records canbe collected by a regulatory
body or employer andpassed on to the national
registry.

18

I.1 and I.2

Add:
When dealing with bulk materials the
exposure scenario can be as importantas (or more important than) the typeof radionuclide and the activity
concentrations in determining dose.

This approach can bemisleading, especially when
dealing with bulk materials.
Asserting that the dose isstrongly influenced by thetypes of radionuclide andthe activity concentrations
ignores the fact that the
exposure scenario is also
extremely important. For
the same material and thesame activity
concentrations, changing
the exposure scenario cansignificantly change the
dose.

19

I.3

Add:
These examples should only be
regarded as guidance. They should not
be taken as applying in all workplaces.

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A

R withmodificati
on alreadyagreed forI.1 inresponsetocomments
fromelsewhere.

With the agreed
modification, the text
now makes sense.
The Influence of the
exposure scenario isaddressed by quoting
the wide ranges ofdoses.

R

This is covered by
the existing text,
particularly the useof the words “broadOccupational Radiation Protection (DS453)

20

III.29May need clarification

Is the dose equivalent range
20-200 mSv/h or 20-200
Sv/h? This may be atypographical error.

193/193

A

indication” in I.1 and“indicative” in I.2
Corrected.
“covers the dose
equivalent range 30µSv/h–100 mSv/h,with an energy
response of ±30%over the energy
range from thermal
to 10 MeV”.