Japan HPS , Sendai, December 2019

Practicality, Common Sense, and Value forSociety
An IRPA Perspective
Roger Coates, IRPA President
1System of Protection Consultation
Practitioner’s views on the System of Protection- and how it can be communicated• General perceptions: complexity & ‘understandability’• Presentation of uncertainty in risk estimates at low dose
• Context of natural background exposure• Dose limitation and dose limits• ALARA and Reasonableness (+ Conservatism & Graded Approach)• Communication and public understanding

Report published in Journal of Radiological Protection (open access)see
2 IRPA website-System of Protection Consultation
Practitioner’s views on the System of Protection- and how it can be communicatedSubtext• Have we gradually developed an over-complex
system which is becoming far removed from‘common sense’?
• Is the system, and the way it is implemented,
delivering reasonable ‘value for money’ for society?
3

IRPA Consultation with the AS
Top tier issues arising

Practical Protection Issues• Prudence and Conservatism• ALARA and Reasonableness4

Prudence – what does it mean?
---The ability to recognise and follow the most suitable or sensible
course of action
Care, caution and good judgement, looking ahead
Skill and provident care in the use of resources
Care and wisdom in planning for the future
A sensible and careful attitude in making judgements and decisions:behaviour that avoids unnecessary risks
To make informed and carefully considered choices without the fullknowledge of the scope and consequences of an action5

Prudence
At the level of principle who could possibly
disagree?
•wisdom, suitable, sensible, care, caution, good judgement,
carefully considered choices6Prudence
At the level of principle who could possibly
disagree?
•wisdom, suitable, sensible, care, caution, good judgement,carefully considered choices

But these concepts are judgemental
What is ‘suitable’, ‘sensible’ or ‘good judgement’ in one
situation (eg high risk level) may not be appropriate at a much
lower risk level
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Prudent Walking

Glacier walking in theHigh Alps8

Prudent Walking

Glacier walking in theHigh Alps

Summer walk around myvillage
9Prudence and conservatism
In day to day practice, prudence has translated into the needfor a conservative approach– in assessments, safety cases and operational approaches.

This requirement is often reflected in international andregulatory guidance and expectations.
But this inevitably introduces an intrinsic bias towards lower
and lower doses.
10Prudence and conservatism
So the key question is:

How much prudence and conservatism isappropriate in various practical situations?

11Clearance - a Case Study in prudence andconservatism
Clearance allows the removal of material (including wastes and reusablematerial) from regulatory control.

orLike exclusion and exemption, it is aiming to focus the regulatory system
onto issues of significance, not trivia.
12Clearance criteria
IAEA Safety Series 89, 1988

An issue of Tolerability
What is a trivial dose?
- what is likely to be acceptable to individuals?
- context of natural background exposureConclusion: ‘Some tens of µSv per year’
Based on LNT and other prudent judgements- eg ‘a few percent of natural background’

A very low dose!!!!!!

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So how to put clearance into practice?
From philosophy to the practical application of clearance:
i. Application to a specific situation
ii. Conversion to Activity Concentration [µSv/y to Bq/g]iii. Practical measurement margin – confidence in theoutcome because it is legal complianceiv. Sum of fractions – combination of several nuclides
v. Activity distribution in cleared material
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Clearance Outcome
Is it ‘Some tens of µSv/y’ ?

NO!

In practice, clearance gives actual doses a factor of at least 100
lower - not more than around 0.1 µSv/yContext: Lowest typical personal dose ~ 2 mSv/y for everyone
from natural background
Taking account of clearance, a few reference persons get2.0001 mSv/y.

Clearance Outcome
Is it ‘Some tens of µSv/y’ ?

NO!

In practice, clearance gives actual doses a factor of at least 100
lower - not more than around 0.1 µSv/yContext: Lowest typical personal dose ~ 2 mSv/y for everyone
from natural background
Taking account of clearance, a few reference persons get
2.0001 mSv/y.

Is this what we want from the System of Protection??

Implications
Managing waste as radioactive material is much more
expensive than ‘free release’.
Eg. UK experience: to reduce from 1 Bq/g to 0.1 Bq/gfor Cs137 costs several $ Billion over lifetime.
Based mainly on decommissioning considerations

Is this money well spent??

17

Wider implications
Prudence is right in principle, but its application isjudgemental.
Prudence must be balanced with other ethical values:
Eg Beneficence – doing the best that can be done withsociety’s resources

Society has limited resources: if used on inappropriate
prudence/conservatism, this is an opportunity cost which
does not give best value for society
How do we save the most lives?

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Conservatisms in our RP System
We have drifted into accepting conservatisms in our day today work, without consciously assessing its impact or what
is really appropriate.
Indeed, we don’t really know how much conservatism wehave – its usually well hidden.
We really don’t know what actual doses are resulting frommany of our activities!
And we are using a lot of society’s resources unnecessarily!

Tolerable and Reasonable

Issue 1: In order to make judgements on what

exposures are Tolerable and Reasonable, we must
understand what the dose really is!!

Avoid undue conservatism

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IRPA Consultation:
ALARA and ‘Reasonableness’
Historically ALARA has beena success – eg nuclear industry
occupational exposures• ALARA and Reasonableness– Accepted as the controlling factor for exposures, but how do wedecide what is ‘reasonable’?
– When have we done enough? Is it right to expect ever lower andlower doses??

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ALARA and ‘Reasonableness’• But there is a growing concern that there is anexpectation (e.g. from some regulators) of ‘ever lower
doses’ – minimisation, not optimisation• An emphasis on ‘As Low As’, not what is Reasonable• Again, is this the best use of society’s resources –driving doses ever lower?
• How low is ‘low enough’ in the circumstances?

IRPA is promoting dialogue
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Paris ALARA Workshops
2 workshops in Paris - SFRP/IRPA:
February 2017 and October 2018.

Paris ALARA Workshops
One key issue arising:

How much should we spend, and who pays?
Examples:• Hospital waste tank
• NPP

Is the person paying the price a party to the decision??
- No taxation without representation!

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Value for Money• The Workshops recognised the need to look at Value forMoney for society when judging what is ‘reasonable’– Cost Benefit Analysis has proved to be limited– So how to do it???
– Is there a regulatory role???

Value for Money• The Workshops recognised the need to look at Value forMoney for society when judging what is ‘reasonable’– Cost Benefit Analysis has proved to be limited– So how to do it???
– Is there a regulatory role???
From a recent meeting of European regulators (HERCA):“The economic impact of regulation must be on ouragenda”

Taking a wider look at theSystem of Protection

Key issue
How to take decisions at ‘a few mSv/a and lower’?
- when we don’t really know the risk, other than:‘If there is a risk, its very small’27

Taking a wider look at theSystem of Protection

Key issue
How to take decisions at ‘a few mSv/a and lower’?
What is the framework for making these decisions?
Note the IRPA Consultation Sub-Text:

Are we losing touch with Common Sense?
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The context of natural background exposure
Every person receives at least 2mSv/a (and many receive significantly
higher doses)- Everything else is an addition to thisPersonal lifestyle decisions add a ‘Delta’ to this:• Whether to change house• Where to holiday• Whether to fly• What food we eat. [Etc]29This Delta could easily be ± 0.5 mSv or more

The context of natural background exposure
Personal lifestyle decisions add a ‘Delta’ to this:• Whether to change house• Where to holiday• Whether to fly• What food we eat. [Etc]This Delta could easily be ± 0.5 mSv or more
Such decisions are made daily, with no concern or interest(and usually no knowledge) of radiation risk.
Rightly so!
30

The context of natural background exposure
So why do we put so much emphasis and effort into
controlling doses down to well within the Delta?
Almost all real RP decisions we make have no material
impact on the total dose received by an individual- 95% of all exposure decisions do not change the‘few mSv/a’ context for any individual31

How does (should!) this play under Tolerability of Risk?

The classic example
Clearance – the 10 µSv/a criterion

Actually its nearer 0.1µSv/a because of conservatisms!
Doses to a very few individuals!
- up from 2mSv/a to 2.0001mSv/a
It costs many tens/hundreds $M

32

The classic example
Clearance – the 10 µSv/a criterion

Actually its nearer 0.1µSv/a because of conservatisms!
Doses to a very few individuals!
- up from 2mSv/a to 2.0001mSv/a
It costs many tens/hundreds $M

Cornwall holiday in the UK

Tens of thousands of holidaymakers each year
Each person gets several tenths mSv additional dose
No-one is remotely concerned or interested

33

The classic example
Clearance – the 10 µSv/a criterion
Actually its nearer 0.1µSv/a because of conservatisms!
Doses to a very few individuals!
- up from 2mSv/a to 2.0001mSv/a
It costs many tens/hundreds $M

Cornwall holiday in the UK
Tens of thousands of holidaymakers each year
Each person gets several tenths mSv additional dose
No-one is remotely concerned or interested

Is this giving value for money (best use of resources) to society?
Does it align with Common Sense?

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What is Common Sense?
Definitions:• Sound judgement derived from experience rather than study• The ability to behave in a sensible way and make practical decisions• Sound practical judgement that is independent of specialised
knowledge• Wisdom, insight, prudence, intuition, practicality

Surely we want to apply these values!
35How to apply Common Sense?
The Four Ethical Values:• Prudence, Beneficence, Dignity, Justice
But in all practical situations we need to balance thesevalues

Applying Common Sense will help us!
36

What is ‘reasonable’ at low doses?
We always want to be ‘reasonable’ - but in a proportionate
way!
Radiation is just one of many safety hazards – so integrate
the approach into an overall safety culture
A good culture includes:• Engaging with all parties involved in the exposure• Appropriate education and training• Maintaining a work environment allowing openness and challenge• Learning and sharing from experiences• Strong leadership
•37

Etc

Tolerable and Reasonable – Key Issues
Issue 1: In order to make judgements on what exposures

are Tolerable and Reasonable, we must understand what thedose really is - avoid undue conservatism!!

Issue 2: How can we best ensure that society receives

good value for money from our decisions?

Issue 3: How should we bring the concept of Common

Sense into our value system for Tolerability andReasonableness?

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Key Issues for the Future• Focus on the larger doses which make a difference to aperson’s total exposure• Don’t ignore the smaller doses, but :– Integrate into ‘normal life’, alongside other safety issues– Be proportionate– It’s just a part of wider safety culture and wider life
• Don’t seek to drive out every last µSv at great expense to society• And communicate like never before!

The Nightmare‘Thought Experiment’
In the light of new scientific evidence at high to medium
doses, radiation risk is reviewed- assuming LNT, the risk factor is doubled
Which of the following are the consequences?
• Occupational and public dose limits are reduced• Clearance levels are reduced• Regulatory pressure to review exposures• High radon areas are evacuated• Air travel is restricted40

See you all in Seoul
15th International Congressof the International Radiation Protection Association
11 – 15 May 2020 | COEX, Seoul, Korea