The Need for a Robust Basis for Changes to Radiological Protection Recommendations

Radiological Protection Working Group

Confidence in the system of radiological protection requires that the system itself, and any changes to it, have sound underpinning, wide acceptance and provide for appropriate stability. The concept of justification is a central pillar of this system, requiring that all revisions to exposure levels do more good than harm. This general approach should also be used when revising the system of radiological protection itself. Therefore, amendments to recommendations that make up the system of radiological protection, including those of the International Commission on Radiological Protection (ICRP) and International Atomic Energy Agency (IAEA), must be ‘justified’ in the sense that the changes must be balanced, proportionate and result in improved health, safety or environmental protection, and the efficient use of societal resources. Conversely, proposed changes that have the potential to adversely impact industries involving radiation are not justified unless they would provide a clear societal benefit.

Public perception of radiation, and an associated overly conservative approach within authorities and the profession, often leads to minimization rather than optimization, resulting in great cost to the nuclear industry as well as wider economic and societal impacts. A prime example is the ALARA (as low as reasonably achievable) principle, which is often misinterpreted to mean ‘as low as possible’, resulting in doses being constantly reduced, even at very low levels where there are no measurable health improvements for workers or members of the public, and often adding extra layers of complexity and cost.

The Association acknowledges the fundamental role of the ICRP in recommending the principles and system of radiological protection, which is designed to protect people and the environment from the harmful effects of ionizing radiation, without unduly limiting the individual or societal benefits of activities involving radiation. Similarly, the Association acknowledges the IAEA as the pivotal body that develops international standards on radiological protection through international consensus.

Recommendations of the ICRP and publications of the IAEA are most often incorporated by individual countries into their regulatory systems of radiological protection, and as such become legally enforceable requirements. From an industry perspective, it is therefore important that such recommendations and requirements have a firm basis in science, are justified through improvements in health, safety or protection of the environment based on an ‘all-hazards’ approach, and are practicable and reasonable. Potential changes to the system of radiological protection, including those related to the ongoing programme of research on low dose health effects, must be properly considered and discussed with practitioners prior to implementation.

As a result of these considerations, World Nuclear Association recommends the following:

Recommendation 1

Any changes in the scientific-based factors used in the system of radiological protection should lead to improvements in health, safety or environmental protection as demonstrated via a holistic approach covering all risks and benefits, including economic and societal factors. The assessment should include the potential impacts of the changes on all practitioners.

Industry, regulator, worker and public confidence in the system of radiological protection depends on scientific reliability and appropriate stability. With this is mind, regular changes to the scientific-based factors used in the system have an impact on radiological protection practitioners. Changes must be justified and based on an all-hazards approach, leading to a net health and safety benefit especially taking account of wider economic and societal factors.

Recent examples of changes to the scientific-based factors where the revised recommendations may not meet these criteria include:

• New inhalation and ingestion dose factors, which require extensive analyses of material.
• Hasty implementation of new dose limits to the lens of the eye without allowing practitioners enough time to develop appropriate measuring equipment changes.
• Revised definitions of dose quantities, increasing the complexity of a well-understood and robust system, while generating unnecessary cost to the industry for no measurable health improvement.
• Inconsistencies in recently-published statements on radon and its impacts.

Recommendation 2

World  Nuclear Association notes that there is a strong international programme of research on low dose science and health effects. Potential changes to the system of radiological protection based on updated scientific knowledge must be properly considered and discussed with practitioners prior to implementation.

Research continues on the impacts of low doses. This research should be considered within the context that there is currently a lack of evidence of any adverse effect on human health at the radiation exposure levels experienced in industrial settings. However, the industry will continue to support research when impacts, dose mechanisms or situations are unclear.

The identification of potential impacts at low doses should include the magnitude and severity of those impacts. In this regard, the industry cautions against interpretations of research outcomes which lead to overly-conservative approaches, and supports the IAEA stance that controls be commensurate with the risk.

Due consideration also needs to be given so as to not cause unnecessary public concern in presenting the uncertainties relating to risks at low levels of radiation.

Recommendation 3

Changes to the recommendations that make up the basis of the system of radiological protection, including those of the ICRP and IAEA, should be justified through an all-hazards assessment, including consideration of economic and societal factors.

In 2019, the ICRP noted that it would be reviewing its well-established and comprehensive system of radiological protection in forthcoming years. In addition, in January 2020, the ICRP released its strategic priorities for 2020-2024 which are to:

• Refine the system of radiological protection.
• Strengthen engagement with stakeholders.
• Ensure the ICRP continues to operate as a well-governed and forward-looking organization.

In 2021, the ICRP released a discussion document[1] on the review process, outlining areas of potential consideration for change. World Nuclear Association supports the ICRP objective of stakeholder engagement, particularly with end-users, for any new or revised system. It is the Association’s position that any potential changes to approaches and systems that are currently working well need careful consideration, and need to be well-justified through an all-hazards approach, especially considering economic and societal factors.

The Association considers the ICRP’s broad review as an opportune time to revisit the linear no-threshold (LNT) model as the primary basis for decision-making on low doses, and recently expressed its views and recommendations on this much-debated topic in two different papers[2].

Regarding radiological protection, World Nuclear Association is the nuclear industry’s interface with several international institutions, including: as a special liaison organization to the International Commission on Radiological Protection (ICRP); an observer on the International Atomic Energy Agency (IAEA) Radiation Safety Standards Committee (RASSC); with the IAEA Emergency Preparedness and Response Standards Committee (EPReSC); the World Health Organization (WHO) Radiation Emergency Medical and Preparedness and Assistance Network (REMPAN); the OECD Nuclear Energy Agency (NEA) Committee on Radiological Protection and Public Health (CRPPH); and the NEA Expert Group on International Recommendations (EGIR).

The Association’s Radiological Protection Working Group (RPWG) consists of experienced radiological protection professionals from a range of sectors including uranium mining, fuel fabrication and recycling, electricity generation, education, research, decommissioning and waste disposal. The RPWG brings together a wealth of diverse operational and policy expertise in radiation management and protection, and provides the industry’s perspective on important radiological protection issues. Members of the RPWG are internationally recognized radiation protection practitioners and represent the Association and the industry on various committees.