April 7, 2023
Werner Rühm, Chair, ICRP
Christopher Clement, Scientific Secretary, ICRPKai Michiaki, Member, ICRP
Kelsey Cloutier, Head of Stakeholder Engagement and Communications, ICRP
Dear Sirs,
We write to you on behalf of the Citizens Commission on Nuclear Energy(CCNE), a civil society think tank established in Japan after the Fukushima nuclear
accident. We communicated with you in 2019 when ICRP conducted a public
consultation on the draft of "Radiological Protection of People and the Environment
in the Event of a Large Nuclear Accident" (Pub.146) to ensure that the newrecommendations reflect the real lessons learned from the Fukushima disaster. We
would like to thank you again for your consideration, during that compilation
process, of the participation of the parties directly and variedly affected by theaccident.
Now we welcome the ICRP's 7th International Symposium on the Systemof Radiological Protection to be held in Japan from November 6th to 9th, 2023. We
are writing to request some logistical arrangements and to propose three thematic
sessions that should be added to the symposium.
Considering the fact that the symposium is held in the country where
people have been experiencing the impacts of the Fukushima nuclear accident,
and also the fact that the ICRP is currently working to revise the General
Recommendations, we believe that it should be quite beneficial, not only forJapanese citizens, but also for the ICRP, to promote the participation of Japanesecitizens and researchers who have a detailed understanding of the situation after
the Fukushima crisis.
Therefore, we would like to take this opportunity to make the following
proposals for ICRP 2023 in order to reassess the situation of the Fukushimadisaster and to deepen the scientific evaluation of the impacts of the nuclearaccident.
１) Logistical arrangements for the symposium
We believe the following logistical arrangement is key in promoting Japanesecitizens' participation in the symposium, especially for “Session 2: Dosimetry forthe next General Recommendations”, “Session 4: How experience of the1Fukushima Daiichi accident is improving RP”, and additional three sessions we
propose later.
These sessions should be held in Fukushima to ensure a broader participationof the residents directly affected by the accident.
According to ICRP2023.jp, “In-person Sessions will NOT be streamed live foronline registration.” The sessions, however, should be held in a hybrid format,
or in-person sessions should be streamed, and comments and questions fromcitizens should be accepted to secure participation of Fukushima refugees
from other parts of Japan.
English-Japanese and Japanese-English interpreters should be provided.
The length of the sessions should be at least doubled, considering theinterpretation delay.
The registration fee, 120,000 JPY for onsite and 50,000 JPY for online should
be waivered or nominal for citizens participating in these Fukushima-relatedsessions.
2) Thematic session “Listening to citizens voices on Fukushima’s experiences:
Reflection of ICRP 146”
In the consultation process of ICRP Pub.146, several public seminars were held byJapanese citizen groups, including CCNE, with the cooperation of ICRP members(we thank Dr. Kai and Dr. Honma in particular), which boosted the number ofJapanese submissions commenting on the draft. While we appreciate that you
reflected some of the comments into the ICRP146, we must say the description ofthe situations in Fukushima remains insufficient or partial from civil society pointsof view. Therefore, in addition to the “Session 4: How experience of the Fukushima
Daiichi accident is improving RP”, in which selected scientists present their papers
as indicated in your program, we propose another session to reexamine theradiological protection issues at the Fukushima accident from the general public
viewpoint. We believe the following topics should be covered in the session andreflected in the forthcoming revision of the General Recommendations.
Confusion over the scientific explanation of the health effects of radiation,such as LNT.
Inconsistency in the Japanese government policy of radiation protection: forexample, the reference level that remains without review even after 12 years,
insufficient inclusion of stakeholders, etc.
The physical and mental burdens of citizens caused by the nuclear disaster.
2

Inviting citizens who have not participated in the ICRP dialogues so far can
provide valuable insight.
3) Thematic session “Thyroid Cancer in Fukushima.”
The 2020/21 Fukushima Report published by UNSCEAR leaves room for criticism,
particularly regarding its dose estimations, assessment of the results of thyroidexamination,riskcommunication,etc.

Inrevising

ICRP’sGeneral

Recommendations, ensuring a scientific assessment based on a wider range of
discussions is crucial. For this reason, we propose a session for scientificdiscussion of the health effect of the Fukushima accident focusing on the thyroid
cancer cases detected in Fukushima. It would be a meaningful scientific discussion,
open to the public, between the researchers of Fukushima Medical University who
are the main authors of the UNSCEAR report, and the researchers who are criticalof the UNSCEAR report.
4) Thematic session “Towards Revision of ICRP General Recommendations: ageneral public perspective”
Based on the sessions 2) and 3) proposed above, this session discusses specificelements that should be incorporated to the new General Recommendation toprotect citizens from radiological harm, including human rights violations during
nuclear emergency. This session will focus on the following topics.
Confirm LNT as a scientific fact established by reliable large-scale radiation
epidemiological studies, rather than a mere assumption.
How to improve the decision-making process without excluding general publicstakeholders.
Basic discussion on the ALARA principle: Does economic compensation makeamends for human rights violations?
As for the three sessions proposed above, we are ready to nominate
appropriate speakers (citizens and scientists). It will be our pleasure to cooperate
in organizing the symposium.
We would appreciate it if you could respond within April 2023. Thanking
you in advance for your kind and earnest consideration.
Yours sincerely,
Kenichi Oshima, Chair, CCNE (Professor, Ryukoku University, Kyoto, Japan)
Shoko Murakami, Chief Secretary, CCNE3