DS453
COMMENTS BY REVIEWER

RESOLUTION

Reviewer:
Page.... of....
Country/Organization: Japan Health Physics Society
Date: 30 May 2014
CommentNo.

1Para/LineNo.
After 3.47
(Addition ofnewparagraphs)

Proposed new text
SPECIAL CIRCUMSTANCES
3.#1 In special circumstances, provided
that a practice is justified and is designed
and conducted according to good practice,and that radiation protection in the practicehas been optimized but occupational
exposures still remain above the doselimits, and that it can be predicted thatreasonable efforts can in due course bringthe occupational exposures under the limits,
the Regulatory Authority may exceptionallyapprove a temporary change in a doselimitation. Such a change should beapproved only if formally requested by theregistrant or licensee, if the Regulatory
Authority determines that the practice isstill justified and is satisfied thatappropriate consultation with the workers
concerned has taken place.
3.#2 Should special circumstances exist
which require a temporary change in somedose limitation, the registrant or licensee
may apply to the Regulatory Authority forsuch a temporary 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

ReasonIn the restoration stage after
the nuclear accident, therecovery workers in theaccident site are forced to beexposed to relatively highradiation dose. In suchsituation, a flexible applicationof dose restrictions for workers
should be necessary to carryout the restoration work after
accident reasonably practical.
It will be essentially importantthat the skillful workers who
have experience of the work inearly stage after an accident
are allowed to continue therestoration work within acertain period of time.
The general principles for theradiation protection of workers
in accident and emergency
situations have been provided
in ICRP Publ. 75, which says:- In accident and emergency
situations, doses may exceed
the dose limits. (para.60)- If continued exposure ispermitted, it would beappropriate for themanagement, in consultation
with the worker, and subject toany requirements of the

Accepted

Accepted, but
modified as follows

Rejected

Reason formodification/rejection

any application for a temporary change in adose limitation:(a) describe the special circumstances
requiring the temporary change; and(b) provide evidence to demonstrate that:(i) all reasonable efforts have been madeto reduce exposures and that
protective 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 needfor a temporary change and on theconditions of the temporary change;(iii) all reasonable efforts are being madeto improve the working conditions to
the point where the dose limits
specified in para. 3.34 ; and(iv) the monitoring and recording of theexposures of individual workers are
sufficient to demonstrate compliancewith the relevant requirements of thisguide and are sufficient to facilitate
the transfer of exposure records
between relevant employers.
3.#5 Any temporary change in a dose
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, atemporary change in the dose limitation
requirements is approved in pursuance withpara.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,

regulatory agency, to establish
a formal dose limitation
regime to be applied for theremainder of the control
period. A temporary dose
restriction based pro-rata on
the remaining period of time towhich the dose limit relates
might be appropriate. (para.61)- Consideration also needs tobe given to the subsequent
management of a worker who
as a result of an accident hasreceived a significant exposure
but whose total dose for therelevant period has notexceeded the relevant dose
limit. In those situations wherecontinuation of normal
working practice during theremainder of the period maylead to the total dose
exceeding the relevant dose
limit, management may decideto change the worker’s duties
to avoid this happening. While
recognizing the legal statusthat regulatory agencies havegiven to the dose limits, theCommission recommends thatsuch situations should be dealt
with in a flexible manner.
(para.62)- The doses received inemergency situations should
not compromise the further
employment of the worker inwork with ionizing radiation.
(para.148)
The additional text is proposedon the basis of theprescriptions given in
Appendix I and Schedule II in

2

4.12

3

5.21

4

7.221

and the effective dose for any worker
should not exceed 20 mSv per year
averaged over this period and should notexceed 50 mSv in any single year, and thecircumstances should be reviewed when thedose accumulated by any worker since thestart of the extended averaging period
reaches 100 mSv.
The initial phase of a response to a nuclear
or radiological emergency is characterized
by a lack of information about the event, ascarcity of materials for implementation ofprotective measures and the need forurgency in implementing protective actions.
Therefore, there is little or no scope for
applying the optimization process whenmanaging the protection of emergencyworkers during this initial phase. Efforts
should be aimed at reducing any exposures
as far as practicable taking into account thedifficult conditions of the evolving
emergency.
Reference levels are generally expressed interms of annual effective dose to therepresentative person in the range 1–20
mSv. However, reference levels for
exposure to radon are expressed in terms ofannual average radon concentration in air.

Add specific examples of parameters forcalculating the equivalent dose to a tissueor organ, or the committed effective dose.

the Safety Series 115 (previousBSS) regarding the dose
limitation in special
circumstances.

In our experience after the
nuclear accident in Fukushima,
there was a serious shortage ofprotective tools.

Section 5 describes exposureof workers in existing
exposure situations including
exposures from remedialaction in a contaminated area,
222
Rn and 220 Rn, and cosmic
radiation to aircrew and spacecrew. However, the dose range
1–20 mSv is the band ofreference level for the public.
Clarification.