INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTIONICRP 4818-6186-6452
18 January 2021

Resolution of Public Consultation Comments for

ICRP Publication 146 Radiological Protection of People and theEnvironment in the Event of a Large Nuclear Accident
Annals of the ICRP 49(4) 2020
Background
ICRP is grateful for the time and effort taken to review and comment on draft reports during
their public consultation period. Active public consultations are a valuable part of developing
high-quality publications. Comments are welcome from individuals and organisations, andall are considered in revising the draft prior to publication.
To ensure transparency, comments are submitted through the ICRP website and visible byvisiting www.icrp.org.
Public Consultation
The draft report was available for public consultation from 18 June 2019 to 25 October
2019. Altogether 308 sets of comments were received from individuals and organisations
covering a wide range of aspects dealt with in the report. Consequently, the Commission
undertook a significant redrafting to improve the readability and understanding and toamend some of the recommendations.
The full list of individuals and organisations that provided comments during the public
consultation process is shown in Appendix A.
Several comments suggested that the recommendations of the Commission be moreconsistent with those already proposed by other international organisations. There werealso many that requested more detail throughout the document, particularly on the phasingof an accident and the progression of societal and economic consequences over time.
More specific comments focused primarily on: the introduction of the 10 mSv per year
reference level value for the implementation of optimisation of protection during therecovery phase; the protection of responders; clarification concerning the process of coexpertise; the termination of protective actions; the management of commercial activities in
the affected areas; and, the issue of potential thyroid cancers following a nuclear accident.
Finally, although many reviewers welcomed the annexes to the Chernobyl and Fukushimareport, they asked that they be treated more coherently with the main text.
Resolution of comments
The suggestion for greater harmonisation with recommendations and requirements of otherinternational organisations, notably regarding the timeline for managing a nuclear accident,
were addressed in several ways. To clarify and simplify the reading of the report, it was
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decided to change the titles of Chapter 3 and 4 to adopt the distinction between the early,
intermediate, and long-term phases traditionally adopted by the Commission (ICRP, 1984),
instead of the distinction between ‘emergency’ and ‘recovery’ used in earlier drafts. In
addition, to make the link with the relevant international recommendations and to avoid
repeating the latter many references have been introduced in the body of the text and in theannexes referring to the most important relevant reports.
An effort has been made to provide further explanation, based on knowledge andexperience, to help the reader more deeply understand accident and post-accident
situations. In Chapter 2, for example, adjustments were made to better explain the diverse
consequences – radiological and non-radiological – of a large nuclear accident as well as
the principles for protection of people and the environment to be applied in suchcircumstances, along with the underlying ethical values. Materials are also provided in
Chapters 3 and 4 to further describe possible prevailing circumstances in the three phasesof the accident, the protective actions to be implemented, and the roles of various
stakeholders.
The two annexes related to the accidents of Chernobyl and Fukushima have been almost
totally redrafted to be fully in line with the main text.
In preparing this publication, the Commission has tried to adopt a common language
understandable by all, in particular by non-specialists and those people directly affected.
The following sections indicate how the Commission has responded to the specific points
mentioned above.
Reference levels for the long-term phase
Beyond the question of the rationale to introduce this new value of 10 mSv, many
commenters asked for a clearer explanation of the use of reference levels in relation to theimplementation of the principle of optimisation of protection in the long-term phase.
In Publication 111 (ICRP, 2019) the Commission recommended that ‘The reference level
for the optimisation of protection of people living in contaminated areas should be selectedin the lower part of the 1–20 mSv/year band recommended in Publication 103 (ICRP, 2007)
for the management of this category of exposure situations. Past experience has
demonstrated that a typical value used for constraining the optimisation process in longterm post-accident situations is 1 mSv/year.’This formulation gave rise to many comments, even criticisms, long before Task Group 93
began its work, in particular regarding the vagueness of the expression 'in the lower part ofthe 1 to 20 mSv per year band’. For the sake of clarification, the Commission therefore
adopted the following wording in the draft report: ‘Levels should be within or below theCommission’s recommended 1–20-mSv band taking into account the actual distribution ofdoses in the population and the tolerability of risk for the long-lasting existing exposure
situations, and would not generally need to exceed 10 mSv per year. The objective of
optimisation of protection is a progressive reduction in exposure to levels on the order of 1
mSv per year.’

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However, the introduction of the value of 10 mSv per year to logically delimit the lower partof the band raised many more comments. What was the rationale for introducing a newvalue? Why 10 mSv per year and not a lower value? In addition, several comments rightly
underline the importance of preserving the maximum flexibility in selecting reference
values, which basically serve as a guide for the implementation of the principle of
optimisation and therefore must fit the prevailing circumstances.
Considering the comments, in Publication 146 the Commission adopted the following
formulation: ‘For the long-term phase, the reference level should be selected in the lower
half of the recommended band of 1–20 mSv per year for existing exposure situations,taking into account the actual distribution of doses in the population and the societal,
environmental and economic factors influencing the exposure situation. The objective of
optimisation of protection is a progressive reduction in exposure to levels towards the lower
end of the band or below if possible.’This formulation specifies the range of the band of 1-20 mSv per year in which thereference levels should be selected (in the lower half) and the objective of the optimisation
process which is 'to reduce exposures to levels that are close or similar to situations
considered as normal' as clearly specified in Publication 103 (ICRP, 2007, Para. 288).
Management of Responders
An aim of the recommendations is to ensure appropriate protection and suitable working
conditions for the responders, likely to be the most exposed individuals. With this in mind, adistinction is made between activities on-site (in the damaged installation) and off-site (inthe affected areas), and the three phases of the accident (early, intermediate and longterm).
The notion of responder was introduced to encompass people diverse in terms of theirbackground, status, and degree of preparation and training on radiological protection.
Compared to the emergency worker as mentioned in the International or European Basic
Safety Standards (BSS), the protection approach is similar apart from the issue of dosecriteria. Both BSSs require that the exposure of emergency workers remains below thevalue of the occupational dose limit whenever possible. In addition, according to theInternational BSS, it shall be ensured that no emergency worker is subject to an exposurein excess of 50 mSv (corresponding to the maximum dose limit for a given year) while theEuropean BSS fix a reference level of 100 mSv. The Commission also recommends a
reference level of 100 mSv (the upper bound of the band 20-100 mSv typically for
emergency exposure situations). In all cases, flexibility is planned, recognising thepossibility of exceptional circumstances. In the long-term phase, the BSSs consider the
responders to be workers and recommend the application of the occupational dose limit
while the Commission recommends the use of reference levels, at the same value or below.
Since the exposure situation is emergency or existing depending on the phase, theCommission recommends the use of reference levels for the optimisation of protection andto guide the implementation of protective actions, for both responders and the general
population. The application of dose limits is not appropriate in emergency and existing
exposure situations following an accident; this only applies in planned exposure situations
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when the source has been deliberately introduced and exposures are fully under control
and regulated.
In the long-term phase on-site, the exposure situation is reasonably characterised, and thesource is mostly under control, although some technical difficulties may remain, andunforeseen situations may occur at any time. For the management of responders, therecommended dose criterion (20 mSv/y or below) is a reference level and the requisites foroccupational exposure should apply as relevant. It is recognised that some authorities andstakeholders may desire to apply dose limits. This may be suitable, but not essential, incircumstances when the source is well characterised and controlled. However, even in sucha situation, exceeding the dose limit is not necessarily an indication of failure in the
management of the situations. Moreover, a strict application of the dose limit may lead to a
critical turn-over of responders and an increased collective dose. Furthermore,circumstances on-site may require planning for exposures higher than the reference level.
In that case, the Commission recommends special arrangements limited in time, whichshould be prepared with the greatest care after deliberation among concerned parties withthe aim of optimising protection.
Taking into account the comments received, the Commission made some adjustments theuse of reference levels for the protection of responders, summarised as follows.
For protection of responders on site, the reference level during the early phase should not
generally exceed 100 mSv, while recognising that higher levels, in the range of a few
100 mSv, may be permitted to responders in exceptional circumstances to save lives or toprevent further degradation at the facility leading to catastrophic conditions. Lower
reference levels may be selected based on the situation, in accordance with the severity of
the accident. During the intermediate phase, the reference level should not exceed
100 mSv. For the long-term phase, the reference level should not exceed 20 mSv per yearwith possible special arrangements limited in time. The Commission recommends that
responsible organisations take all practical actions to avoid unnecessary accumulation of
exposures for responders involved in both the early and intermediate phases.
For protection of responders off-site, the Commission recommends selection of a reference
level not exceeding 100 mSv for the early phase and 20 mSv per year for the intermediatephase. For the long-term phase, the reference level should be selected within the lower halfof the 1 to 20 mSv per year band, since the exposure should be managed using the samerequisites as for the general population in affected areas.
The co-expertise process
Several comments suggested initiating the process of co-expertise from the emergency
response and relying on it during preparedness planning for possible future accidents.
In the draft, the co-expertise process was proposed for the development of practical cultureof radiological protection with a view to promoting self-help protective actions in the longterm phase. In final version, the approach is recommended from the intermediate phaseonwards (see Chapter 3). In addition, the ethical dimensions of the process have beendeveloped to emphasise its role in the restoration and preservation of human dignity.
Support of the co-expertise process helps radiological protection professionals appreciate
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the ethical structure of radiological protection while respecting the choices of those affected.
The co-expertise process approach aids the organisation of citizen vigilance during theimplementation of local projects. As explained in the chapter on the long-term phase, theco-expertise process is inherent in the implementation of self-protective actions withadequate support from the authorities. Finally, the approach is also recommended for
preparedness planning in Chapter 5.
Termination of protective actions
Some comments underlined that although the recovery process could be consideredfinished in some affected areas, the situation for the population in these areas may remaindifficult due to the stigmatization of the territory, its products (especially agricultural andfishery), and even of the people who reside there.
In the long-term phase, even after the end of protective actions, people should be able tobenefit from the support of authorities and experts, not only to ensure adequate protection
against radiation, but also to guarantee sustainable living and working conditions and a safe
environment ensuring respectable means of subsistence and way of life. To pass on
experience and build the future, the Commission recommends that all necessary attention
be paid to the development of accompanying measures to support initiatives and citizens'projects in the fields of education, culture, and memory, which contribute to a decent life
and the sustainable development of the living conditions of present and future generations(section 4.4.3).
Management of business activities
Publication 146 clarifies the responsibility of employers to provide adequate information on
the radiological situation to their employees and their families and to implement radiation
monitoring adequate and self-protective actions if necessary.
These provisions are introduced during the intermediate phase (section 3.4.2.5) as well as
during the long-term phase (section 4.4.1.3). The recommendation of the Commission is to
manage the people employed for various economic activities in the affected areas asmembers of the public. However, for workers involved in activities inducing specificexposure situations, such as foresters, the Commission recommends that they beconsidered occupationally exposed.
Thyroid cancers
Because the Fukushima health management survey detected an increase of thyroid cancer
cases in Fukushima children aged 0-18 years as early as 2011-2013, several comments
called for advice from the Commission on this subject. The Task Group carefully reviewed
all the scientific work concerning the analysis of the cause-and-effect relationship carriedout, by the international organisations competent in the matter such as WHO / IARC andUNSCEAR, and by researchers from Fukushima Medical University and other researchorganisations. Based on this review the Commission recommends how to plan healthsurveillance of the affected population after an accident, in particular with regard to potential
thyroid cancers.
Annexes on the Chernobyl and the Fukushima accidents
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As suggested in several comments, the two annexes of have been completely revised sothat their content conforms more to the structure of the main text therefore making
comparison easier. In this revision, the main references of the international organisations
were mentioned as they contributed to the analysis of the accidents at Chernobyl and
Fukushima and to the evaluation of their consequences. The Commission considers that it
is not its responsibility to supplement or even these contributions.
References
ICRP, 1984. Protection of the Public in the Event of Major Radiation Accidents - Principles
for Planning. ICRP Publication 40. Ann. ICRP 14 (2).
ICRP, 2007. The 2007 Recommendations of the International Commission on RadiologicalProtection. ICRP Publication 103. Ann. ICRP 37 (2-4).
ICRP, 2009. Application of the Commission's Recommendations to the Protection of People
Living in Long-term Contaminated Areas After a Nuclear Accident or a Radiation
Emergency. ICRP Publication 111. Ann. ICRP 39 (3).

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Appendix A
List of individuals and organisations that submitted comments
during the public consultation period
Individuals
Akemi Konuma
Akemi Shima
Aki Hashimoto
Akifumi UEDA
Akihiko Gyoja
AKIKO MORIMATSU
Akira Tanabe
Alan Fellman, Ph.D., C.H.P.
Aoki Mihoko
Arata Ookubo
Asada Masafumi
Atsuko MASANO
AtsushiAtsushi Aragane
Augustin Janssens
Barbara Wefing
Bob Applebaum
Chia Yoshida
Chiharu Hisaichi
Christopher Lish
DaipenDenise Lytle
Eisuke Naramoto
Emi Sakagami
Etuko Maruyama
Fumiaki Toudou
Fumio MATSUDA
Guento MISAWA
Harada Hirofumi
HarukoHashizumeKenso, KawaharaKoki
Hide Nakagawa
HIdeko Wada
Hideo Oguri
Hideyuki Koyama
Hiroshi Kurihara
Hiroshi Nishi
Hisako Sakiyama
Ichiro Yamaguchi
Ishikawa Kazuhiro
Jane Danjin

Jim Lykins
Jun Ichiro TADA
Jun'ichi Nukushina
Junko Suzuki
KAKUTA NAOKO
Kakutaro Kauchi
Kamoshita Miwa
Kaneko Yoshiko
KAORI OYAMA
Kaoru Kobashi
Katherine O'Sullivan
Kato Rin
Katsuo Ikeda
Kazuyoshi Takahashi
Keiko
Kenji Imaoka
Kenneth Kepler
Kenzo Fujimoto, Ph.D.
Kevin Rolfes
Kimiko Namba
Kishida Madoka
Kiyoshi Enomoto
Kiyoshi Koyama
Kiyoshi Uchide, MD
Koichi Takitani
Kosaku Yamada
Koyama Shinjiro
Kuroda Shizuyo
Kyoko Shima
Laura Hanks
M. Mihara
Madoka Murai
Majia
Maki Kumagai
Makoto Takahashi and Anja Rue
Mamoru HAYASHI
Mari Hoshikawa
Marina Watabe
Masaki Oshikawa
Masashi Shirabe
Masato IDA （井田 真人）
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Masatoshi Ohyama
Masui Akito
Matsuzaki Michiyuki
Michael Crowden
Michiko AIKAWA
Michio Murakami
Mineki Nishikawa
Mio Tonoya
Miwa Chiwaki
Motomi Ushiyama M.D.
Nagaaoe Yasuko
Nagase Satoko
Naoki KUBO
Naoki Tajima
Naomi Maki
Naoyuki Murakami
Nishikawa·Kazuo
Noboru Kojima
Norihisa Sakaguchi
Noriko Nonaka
Oki Kiyoko
ONO HIROSHI
Osamu Imaizumi
Pamella K. Kilavi
Patrick Bosold
Patrick Smeesters
Paul Langley
Philip Thomas
Reiko Saito
Rieko Takahashi
Rintaro Nishigaki
Robert Travaline
Ruiko Muto
Sachiko Yamanaka
Saki Okawara
Sandra Couch
Sandy Sanders
Satoko Tanaka
Satoru Ono
Sayoko Yamadera
Seiko Nishikawa

INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION
Seri Ishikawa
Shibayama
Shie Ida
Shigeru Taguchi
Shin Aiuchi
Shingo Itonaga
Shinpei Tanno (Sugar Nat)Shiro Ogura
Shizue Tomoda
Shoko Ohnuma
SOKAWA, Yoshihiro
Stephen and Robin Newberg
Stephen Gliva
Steven M Baker, Ph.D.
Sugiura Motoki
TADAYOSHI NARITA
Takagi Izumi
Takagi Kuniko
Takao SHIRAKURA
Takashi Akutsu
Takeaki Yatsuhashi
Takezo TAKAHASHI
Tamie Ando
Tariko Nishikawa
Taro Abe
Taro TANAKA
Teruko Nishida
Tim Deere-Jones
Tito Galdo
Toch
Tom Hougham

Tomoko Okuuchi
Tomoya YAMAUCHI
Toshinori YAMAKI
Toyoda Mamoru
Tsuyoshi Ebina
Tsuyoshi Fujioka
TSUYOSHI SANOUJIBASI AKIRA
Umehara Kiyoko
Y Adachi
Yamadera. Sayoko
Yamamoto Hidehiko
YASUKO NAKAMURA
Yasushi KAKIHARA
Yasushi Nozawa
Yasuyuki Taneichi
Yayoi Yoshida
Yoko Chase
Yoko Ohara
Yoko Shimosawa
Yoko Tamaki
Yokoyama Marina
Yoshihiko Wada
Yoshiko ANDO
Yoshiko Sasaki
Yoshinori Ueno
Yukie Kanno
Yukiko Tanaka
Yukio Takashima
Yuko Yoshida
Yumiko Fuseya

Yutaka Hamaoka
Yuya Kamoshita
中村泰子 Nakamura Yasuko
井野博満 Hiromitsu INO
伊藤かつみ
佐藤千鶴子
勝守 真知子
原田 浩
宗川吉汪
小澤洋一
尾崎のりまさ山口サエ子
山本 美秀子
岩州 信太郎
弦巻英市
服部賢治 Kenji Hattori
木村雅英 Masahide KIMURA
林衛
林勝彦
根本 仁
武井隆明
水澤 靖子
永田文夫
永野 勇
温品惇一 Jun'ichi Nukushina
瀬川 嘉之 Yoshiyuki SEGAWA
牛山 元美
矢ヶ﨑克馬 Katsuma YAGASAKI
足立義子
青木美保子

Organisations
ACRO, France (ACRO.eu.org)
Australian Radiation Protection and Nuclear Safety Agency (ARPANSA)
Beyond Nuclear
Campaign Against Radiation Exposure
Canadian Nuclear Safety Commission
Chernobyl-Hibakuhsa Support, Kansai, Japan
Citizen and Scientists Demanding Standards That Protect People From Radiation Exposure
Citizens' Commission on Nuclear Energy (CCNE)
Citizens' Nuclear Information Center (CNIC)CRIEPI, JapanEDF Energy
Federal Office for Public Health Switzerland
Friends of the Earth Japan
German Commission on Radiological Protection (SSK)
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Greenpeace, Radiation Protection Advisors unit
Health Canada - Radiation Protection Bureau
IPPNW Germany
IRSN
Iryou Mondai Kenkyukai
Japan Health Physics Society
Miyake Consulting House
National Institutes for Quantum and Radiological Science and Technology
NERIS - European platform on preparedness for nuclear and radiological emergency response and recov
OECD-NEA CRPPH-EGIR
Organisation of thinking atomic
Planning Committee for the international conference 'Applicability of Radiation-Response Models to Low Dose Protection Standards
Public Health England
Refugee's group in Japan asking for the refuge right
Rotarians4Ban of nuclear weapons
Save Fukushima Children Lawyers' Network (SAFLAN)
Scientists for Accurate Radiation Information (SARI) and XLNT Foundation
Spanish Society of Radiological Protection (SEPR)
Swedish Radiation Safety Authority
Takagi School
Takaokachikukouikiken no gomimonndai wo kangaerukai
The Federation of Electric Power Companies of JapanThe Ishikawa Medical & Dental Practitioners Association
The plaintiffs' group of the Fukushima Nuclear Disaster Compensation Trial, Kyoto, JapanThe Society for Radiological Protection
The Stella Group, Ltd.
Thyroid Cancer Support Group ”Ajisai No Kai” 甲状腺がん ਞ
Vattenfall AB
VGB PowerTech e.V., Working group radiation protection
World Nuclear Association
一般社団法人 被曝と健康研究プロジェクト
原子力規制を監視する市民
原発いらん！山口ネットワ
原発を考える町田の会
名古屋市民測定 C ラボ
山口被爆二世の会
平和と民主主義をめざす全国交歓会
放射線被曝を学習する会
放射能から子供を守る会・
望月牛女子
福島原発告訴団
福島県飯舘村民有志会、日本大学飯舘村支援チーム
経産省前テントひろば
虹とみどりの会

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