The evolution of the system of radiological protection -
evolution or expedition?
Authors: C Rick Jones  
Published: April 2003

I congratulate the International Commission on Radiological Protection (ICRP) on the
more open and inclusive process for allowing comments and initial stakeholder
reaction to the ICRP's proposal for revisions to the system of radiological
protection. The Organization for Economic Cooperation and Development, Nuclear Energy
Agency (NEA) Committee on Radiation Protection on Public Health (CRPPH) has,
throughout its existence, been interested in the development of recommendations of
the ICRP to provide the views of regulators, experts, and in some cases, other
interested and affected stakeholders. Professor Clarke raises a number of issues and
suggestions for actions ICRP may take to enhance the understanding and transparency
of their recommendations. However, I note that although there is broad agreement that
the ICRP should harmonise and consolidate its recommendations, the ICRP has yet to
fully explain the rationale for significant changes to their recommendations at this
time. The current article (on page 129 of this issue) is a
`framework' document providing overall concepts. It is presumed that the ICRP will
modify, based upon stakeholder input, its framework appropriately and use this to
then develop detailed recommendations.

In reviewing the document, I believe the ICRP should limit its work and
recommendations to what informs policy makers on what we do and do not know about the
science of radiation effects and the associated uncertainties in the science. The
ICRP approach for reform should be an evolutionary process for the development of
new, improved radiation protection recommendations, rather than an expedition to
quickly react to specific issues raised by different groups with differing
priorities.

The statements in paragraphs 14 and 15 (at the beginning of section 3) are troubling
and are an inappropriate role for the ICRP for the following reasons.

First, the ICRP does not have the mandate, and may lack broad expertise, to
move directly from the scientific data to the incorporation of societal
sciences into the formulation of recommendations. As its charter describes,
it is an advisory body which offers recommendations and
guidance on the fundamental principles and quantitative bases upon which
safe and effective protective measures can be taken by various governments,
legislatures, and regulatory bodies around the world. The ICRP should limit
its recommendations to what the science tells us and not offer
recommendations incorporating societal issues. Moving from science to the
incorporation of societal issues in establishing radiation protection
programmes is the responsibility of policy makers, not recommending bodies
like the ICRP.

Second, the expenditure of public safety and health funds commensurate with
the risk presented is a role of national policy makers, not the ICRP. Any
proposed new system should be risk based and provide policy makers with the
information necessary to make informed decisions on the appropriate use of
limited public resources to enhance public safety and health, commensurate
with the risk. As presented, there is no clear evidence that the cost and
impact of implementing the proposed ICRP framework and resultant
recommendations would be an appropriate use of public funds. Resources to be
expended to implement the new ICRP recommendations should provide a
commensurate reduction in risk over other actions that could be taken with
these limited resources to enhance public safety and health against other
public health risks and hazards such as increased security controls,
terrorism, AIDS, fresh water, and so forth.

The proposal for basing the new system of radiological protection on multiples of
natural background radiation would unfortunately move the system another level away
from science. In paragraph 25 (second paragraph of section 5), the ICRP states that:
`The Commission now considers the starting point for selecting levels at which any
revised constraints are set ... [is about the level of] the annual dose from natural
sources.' There is no data or evidence presented to allow the reader to reach the
conclusion that this new approach will be more understood or accepted by the myriad
of interested stakeholders that will be impacted by these proposed changes. In fact,
this use was not necessarily seen as reducing public confusion and appears to be
selected on the basis of public concern (see paragraph 26), and thus would not
necessarily be applicable to established radiation exposure criteria for workers. Not
acknowledging risk, even that associated with natural background and the natural
incidence of cancer, risks the loss of public trust to the detriment of the radiation
protection community and the ICRP.

The ICRP should issue scientifically defensible numerical recommendations that will
provide security and protection of commerce, the public and workers, with identified
and specific end points (e.g., worker values that are selected to prevent a certain
probability of cancer fatalities in a lifetime or incident rate of cancer). These new
recommendations should result in a unified system of radiological protection that
explains, rationalises, and justifies all numerical values, one to the other. While
there is broad agreement that the numerical criteria that ICRP has promulgated since
Publication 60 and was issued in 1990 would benefit from harmonisation and
consolidation, numerical values should be limited to those levels below which
international trade of commodities would not be inhibited for radiological protection
reasons. In this context, it was not useful for the ICRP to declare, a priori, that doses below a
particular value should be of no concern and should thus be excluded from regulatory
consideration. This assessment of the regulatory aspects of exclusion should be left
to the regulator or national policy maker. The regulator will always assess doses,
even if they are low, especially if its stakeholders believe that it is necessary for
ensuring public safety and health. Although the assessment may not be as detailed as
those for a very high dose radiation source, the regulator will not always exclude
low dose situations from consideration if appropriate intervention can be
accomplished. Because of this, the framework and subsequent recommendations should
address the overall need for the concept of exemption.

Beyond the minimal set of numerical values, ICRP should be producing
performance-based recommendations and leave the details regarding the implementation
of its recommendations to the regulators and policy makers. As an example, basing
radiological protection of the living environment on reference fauna and flora
(mirroring the occupational system of protection) is prescriptive and inappropriate.
It is important to note that there is broad agreement that, in general, the current
system of radiological protection is protecting non-human species in the human
habitat and this point should be more prominent in ICRP documents and communications.
One approach ICRP should consider would be to indicate the performance goal(s) for
the protection of the living environment, such as reproductive success or
biodiversity. ICRP should recommend a system that defines the quality of the
environment we wish to leave to the next and future generations. Using reference
fauna and flora, and its associated uncertainties, is only one implementation tool to
demonstrate the protection of the living environment. The tool selected should be at
the discretion of the implementing organisation to demonstrate the satisfaction of
the ICRP performance goal(s).

There has been no demonstration by the ICRP that the current
regulatory programme for the protection of the living environment is generally
not adequately protecting the environment. Paragraph 14
explicitly states that its primary aim is to contribute to the establishment and
application of an appropriate standard of protection for human beings and now
explicitly for other species. There is now a perception by some that because the
protection of the environment has not been demonstrated, that an entirely new set of
recommendations from the ICRP must therefore be forthcoming. In developing a
recommendation to attain these aims, the ICRP will most certainly impact the making
of national and international policy in the setting of national regulations and
international standards, and in general, in the implementation of radiological
protection. However, there is broad agreement that the inclusion of a framework for
numerical values for non-human species protection criteria is premature. Such a
statement from the ICRP would imply that the level of scientific and social knowledge
needed to support the designation of levels of harm and levels of concern already
exits in detail. This is not yet the case. A better first step would be to conduct
the studies needed to identify deficiencies in the current implementation of
radiological protection programmes in place to protect, or limit the impact on, the
living environment. Based upon the identified and accepted opportunities for
enhancement of environmental protection, a more focused set of ICRP recommendations
could be developed. Implementation of a new set of ICRP living environment
recommendations based upon the current occupational protection model would create the
very set of problems we are trying to resolve in the new ICRP framework. In order to
be effective and supported, any new ICRP recommendations should be performance-based,
appropriate to the hazard present, and should balance not only improvements in the
level of protection, but also the direct and indirect costs of change.

The ICRP should continue to expand its engagement with interested and affected
stakeholders, be responsive to stakeholder input, and the CRPPH is prepared to team
up with the ICRP to road test their proposals to first demonstrate their value added
to society. This will facilitate the efficient and cost effective implementation of
any new future recommendations and enhance their acceptance.

To address the above issues, new ICRP recommendations should have the following
characteristics.

Demonstrate enhanced worker and public safety and health, and protection of
the living environment.

A sound foundation in science.

Understandable by a broad audience.

Developed using an open, transparent, and inclusive process with
stakeholders.

Accepted by stakeholders.

Allow policy makers to strike a balance between safety and fiscal
responsibility.

For more discussion on the above issues I would refer readers to the following
documents of the NEA/CRPPH [1-3].

References

[1] OECD/NEA 2000 A Critical Review of the System of Radiation Protection:
First Reflections of the OECD Nuclear Energy Agency's Committee on Radiation
Protection and Public Health (Paris: Nuclear Energy Agency) [2] OECD/NEA
2001 Policy Issues in Radiological Protection Decision Making: Summary of the
2nd Villigen (Switzerland) Workshop (January 2001) (Paris: Nuclear Energy
Agency) [3]OECD/NEA 2002 The Way Forward in Radiological Protection - An
Expert Group Report (Paris: Nuclear Energy Agency)

The CRPPH looks forward to a continued collaboration with the ICRP. Rather than
launching an expedition to complete this work by 2005, the CRPPH hopes to work with
the ICRP to ensure that their recommendations reflect the above important
considerations in promoting the efficient and cost effective implementation of ICRP
recommendations to result in the evolution of sound enhancements to workers, the
public, and environmental safety and health.