DS457
COMMENTS BY REVIEWER

RESOLUTION

Reviewer:
Page.... of....
Country/Organization: Japan Health Physics Society (JHPS)
Date: 30 September 2013
CommentNo.
Generalcomment 1

Para/LineNo.

Generalcomment 2

Specificcomment 1

Proposed new text

ReasonSafety requirement on "Countermeasurestaken in existing exposure situation” should
be separately discussed and prepared as
GSR-Part 8.

Draft DS457 for GSR Part 7
only treats preparedness andresponse for an emergency
exposure situation andsubsequent transition to an
existing exposure situation.
Although GSR Part 3 treats anexisting exposure situation inits Chapter5, a specificdocument on safety
requirement for existing
exposure situation should beseparately discussed on thebasis of lessons learned fromthe Fukushima nuclear
accident, and prepared as
GSR-Part8 to complete theIAEA Safety Standards.
Generic criteria given in Table
II.2, 3, 4, 5 are mainly
provided by the concept ofintervention above whichsome action should be taken,
while the generic criteria forthe transition to an existing
exposure situation (i.e., aneffective dose of 20 mSv perannum) are provided by theconcept of reference level as atarget dose when some action
is taken.
The goal of emergency
response is to prevent severe

The concept of “intervention levels”
developed by the process-based approach inICRP 1990 Recommendations and that of“reference levels” developed by thesituation-based approach in ICRP 2007
Recommendations are different, although
the numerical values itself are the same.
Care should be taken to this, and eachshould be distinctively used in the DS457.

Page 6, line 7(c) To avoid or minimize prevent severe
deterministic effects;

Accepted

Accepted, but
modified as follows

Rejected

Reason formodification/rejection

Specific
comment 2

Page 31, line
19-24

Specificcomment 3

Page 38, line
1-13

5.94. Arrangements shall be made forproviding useful, timely, truthful,consistent, clear and appropriate
information to the public in a nuclear orradiological emergency, with account takenthat the usual capabilities forcommunication might have been damaged
as consequence of the emergency or its
initiating event (e.g. by an earthquake,flooding, etc.) or overburdened by publicuse. These arrangements shall include
arrangements for keeping the international
community informed, as appropriate.
In addition, arrangements shall be also
made during the normal condition forencouraging the spread of knowledge onradiation protection so that the people canunderstand the meanings ofcountermeasures taken in the nuclear orradiological emergency.
5.136. The government shall ensure that, aspart of its emergency preparedness,arrangements are in place for thetransition from an emergency exposure
situation to an existing exposure situation.
These arrangements shall involve interestedparties. The arrangements shall take into
account that the administrative decision for
the transition from an emergency exposure

deterministic effects.
ICRP Pub.103 says “(29) The
Commission’s system ofradiological protection aims
primarily to protect humanhealth. Its health objectives are
relatively straightforward: tomanage and control exposures
to ionising radiation so that
deterministic effects areprevented, and the risks ofstochastic effects are reduced
to the extent reasonablyachievable.”
One of the key lessons learned
after the Fukushima nuclear
accident was that the people
could not appropriately act
even if they could obtainvarious quantity ofinformation. This is because
the people don’t have enoughopportunity to learn theknowledge on radiation
protection during the normalcondition. In fact, many
concerns such that there wereno specific radiation protection
criteria for children andpregnant women were raised
following the Fukushima
nuclear accident.
It is important to emphasizethat the generic criteria given
in Appendix II are the default
values (not rigid), and national
criteria to be practically
implemented should bedecided in consideration of thesituation of nuclear andradiological emergency.

Specific
comment 4Page 38, line
14-17

situation to an existing exposure situation
might be taken at different times indifferent geographical areas. The planning
process shall include: the roles andfunctions of organizations; methods oftransferring information; methods forassessing radiological consequences andnon-radiological consequences; ensuringconsistent system of national genericcriteria to be applied from the start of theemergency until the emergency phase isterminated (see Appendix II); review of thehazard assessment; establishment ofnational guidelines for termination of an
emergency phase by returning to a planned
exposure situation or by transition to anexisting exposure situation, as appropriate,e.g. by adjusting protective actions andother response actions; and arrangementsfor on-going public communications,monitoring public opinion and the responseof the news and information media. It
should be noted that the generic criteria
given in Appendix II are the default values,
and national criteria to be practically
implemented should be decided withflexibility in consideration of the situationof nuclear and radiological emergency.
5.137. After a decision has been made on
the termination of the emergency phase byeither returning to a planned exposure
situation or by transition to an existing
exposure situation, radiation monitoring
system (individual monitoring andenvironmental monitoring), healthsurveillance strategy, and transmission ofpractical knowledge within the population
about the control of the radiologicalsituation to current and future generations
shall be conducted established subject tothe requirements for planned exposure
situation or existing exposure situation, asappropriate [14].

Past experiences including theFukushima nuclear accident
show that authorities have to
set up infrastructures tosupport the implementation of
all protection strategies,
including self-help strategies
implemented by the affected
population. The disseminationof a ‘practical radiologicalprotection culture’ within all
segments of the population,and especially withinprofessionals in charge of
public health and education, isalso an important element ofSpecific
comment 5

Page 50, line
12-13

Specificcomment 6

Page 50, line
28-32

II.2. These generic criteria are generically
optimized for taking appropriate protective
actions and other response actions in a
nuclear or radiological emergency. Notethat these generic criteria are the default
values, and national criteria to bepractically implemented should be decidedwith flexibility in consideration of thesituation of nuclear and radiologicalemergency.
(c) ‘Safe Below levels of health concern’
when the generic criteria in Table II.1 andTable II.2 are not projected or received,since no protective actions and other
response actions are justified from theradiological point of view to reduce the riskof stochastic effects or to minimize prevent
severe deterministic effects as there will beneither observable increase in incidence ofcancer nor any severe deterministic effect.

the strategy. Experience has
shown that the development ofsuch an infrastructure is basedon three key pillars: radiation
monitoring system, healthsurveillance strategy, andtransmission of practicalknowledge (ICRP pub.111,para.62).
It is important to emphasizethat the generic criteria are thedefault values (not rigid), andnational criteria to bepractically implemented
should be decided inconsideration of the situationof nuclear and radiologicalemergency.
The generic criteria should not
be used to explain thedistinction between “safe” and“unsafe” to the public, on thebasis of the experience after
the Fukushima nuclearaccident. The generic criteria
are the levels below which noradiological countermeasures
are justified and no publichealth concerns areconsidered.
Following the Fukushima
nuclear accident, the word“safe” has been often used
when they refer to radiation
protection criteria associatedwith the stochastic effect.
Unfortunately, however, thisapproach often made thegeneral public misunderstandthat the criteria mean thedistinction between safety anddanger. On the basis of ourSpecific
comment 7

Page 55, line
7-10

Table II. 2

II.12. Generic criteria of 1/10 of the genericcriteria for early protective actions andother response actions given in Table II.2 isestablished for food, milk and drinking
water restrictions to ensure that the dosefrom all exposure pathways, including
ingestion, will not exceed the genericcriteria for early protective actions andother response actions given in Table II.2.
For radioiodines for which radiologicalprotection is not appropriately providedonly considering the effective dose, special
attention should be paid not to exceed theequivalent dose to the thyroid of 50 mSvper annum.
Table II.2. GENERIC CRITERIA FOR
PROTECTIVE ACTIONS AND OTHERRESPONSE ACTIONS IN AN
EMERGENCY TO REDUCE THE RISKOF STOCHASTIC EFFECTS AND TOPREVENT THE INCICENCE OF
THYROID CANCER(To add)
HThyroid: 50 mSv per annum (Take earlyprotective actions and other responseactions)
HThyroid: 50 mSv in a month (Take longer
term medical actions to detect and toeffectively treat radiation induced healtheffects)
Table II.3. GENERIC CRITERIA FOR
FOOD, MILK, DRINKING WATER AND

experiences, the governmentand radiation protection
professionals should recognizethat it is practically difficult toobtain the understandings by
the simple word of “safe”, andinappropriate use of the word
can lead to the public distrust.
From the viewpoint of theprevention of the incidence ofthe thyroid cancer, appropriate
radiation protections cannot beprovided only considering thegeneric criteria given by theeffective dose. In balance withthe generic criteria for iodine
thyroid blocking,countermeasures should betaken not to exceed theequivalent dose to the thyroidof 50 mSv.

Table II. 3

OTHER COMMODITIES TO REDUCETHE RISK OF STOCHASTIC EFFECTS
AND TO PREVENT THE INCICENCEOF THYROID CANCER IN AN
EMERGENCY(To add)
Generic criteria
HThyroid: 50 mSv per annum

Table II. 4

Table II.4. GENERIC CRITERIA FOR
VEHICLES, EQUIPMENT AND OTHERITEMS TO REDUCE THE RISK OF
STOCHASTIC EFFECTS AND TOPREVENT THE INCIDENCE OF
THYROID CANCER IN AN
EMERGENCY(To add)
Generic criteria
HTyroid: 50 mSv per annumSpecificcomment 8Page 59, line
6-9

Specificcomment 9Page 61, line
3-18

II.19. Exceeding the generic criteria in
Table II.5 does not mean that thecommodities and food are unsafe in termsof the radiation induced health effects (seepara. II.4). Commodities and food are to beconsidered unsafe in terms of the radiationinduced health effects (see para. II.5) only
if the generic criteria in Table II.1 or II.2
are projected to be exceeded.
II.24. The decision to terminate theemergency phase and the concurrent
transition to an existing exposure situation
shall be taken after: (a) confirmation thatthe source of exposure is fully characterized
for all members of the public living
normally in the area who may be exposed
to radiation in wide distribution of annual
individual doses ranging from the very low
to several tens of mSv *1; (b) the exposure
situation is understood and remains stable;(c) any restrictions on normal living

From the viewpoint of thespecific comment 6, thissentence referring to the
distinction of safe and unsafe
should be deleted or the word
“unsafe” should be replaced toanother phrase.
It should be noted that existing
exposure situations generally
give rise to wide distributionof annual individual doses
ranging from the very low to,
in rare cases, several tens ofmSv (ICRP pub. 103, para.
285).
A target dose of an effective
dose of 20 mSv per annum
should be appropriately used
as a reference level inconditions are limited and provisions are inplace to confirm compliance with such
restrictions; and (d) ensuring that interested
parties including members of the public areconsulted and kept informed about the basis
for the adjustment and transition placing theassociated health hazards in perspective.
*1 With due consideration and verificationof the fulfilment of conditions set in para.
II.24, reference levels, set in terms ofindividual annual effective residual dose(mSv/y), shall be used in conjunction withthe planning and implementation of theoptimization process for exposures inexisting exposure situations. The
appropriate reference levels shall be chosen
in the annual effective dose of 1-20 mSv
per annum.band.

accordance with the ICRP
2007 Recommendations, andthe application after thetransition should be provided
as a footnote. In existing
exposure situations, reference
levels should be used inconjunction with theimplementation of theoptimization process for
exposures in existing exposure
situations (ICRP pub. 103,para.286), and the appropriate
reference levels should bechosen
in the 1–20 mSv bandproposed by ICRP (ICRP
pub.111, para.48).