international relevance and satisfies Australia, we have cohorts The reference level of aircrew has the ICRP principle the can of pilots with exposures been revised down to 6 mSv per “that contribute meaningfully to the around 5.5-5.7 mSv year-1 year. optimisation process”. and cabin crew with exposures around 6.0-6.5 mSv year-1. Importantly, more recent changes in aircraft types and routes have seen an increase in exposures from around an average of 3.5 mSv year-1 for Qantas pilots in the early 2000s to much higher levels today. 58 Proposed change AusALPA asserts that Comment not Comment not adopted. The EURATOM Basic Safety Australia is not compelled adopted Standards makes it clear that the to adopt ICRP 132 (or ICRP Australia as a membered state of exposure of air crew to cosmic 103) verbatim and strongly the IAEA is obliged to implement radiation should be managed as a recommends that, to the where possible the requirements planned exposure situation, contrary extent permitted by the of GSR Part 3, therefore having to the approach taken by the ICRP. Constitution, ARPANSA aircrew managed as an existing should adopt the extant exposure situation is consistent aircrew protection with GSR Part 3, ICRP 103 and provisions of the ICRP 132. EURATOM Basic Safety Australia is not compelled to Standards. adopted the EURATOM Basic Safety Standards as we are not members of the European Union. 59 Proposed change ICRP 132 places the Comment not Comment not adopted. The best illustration of why a responsibility on adopted reference needs to be imposed management”. Guide is aligned with GSR Part 3. “operating is simply the current state of Both AusALPA and IFALPA radiation exposure monitoring by consider this approach to Australian airlines. be unlikely, but more probably incapable, of success. The most obvious conflict arises as a consequence of
international relevance and satisfies the ICRP principle “that the can contribute meaningfully to the optimisation process”. Australia, we have cohorts of pilots with exposures around 5.5-5.7 mSv year-1 and cabin crew with exposures around 6.0-6.5 mSv year-1. Importantly, more recent changes in aircraft types and routes have seen an increase in exposures from around an average of 3.5 mSv year-1 for Qantas pilots in the early 2000s to much higher levels today. The reference level of aircrew has been revised down to 6 mSv per year. 58 Proposed change The EURATOM Basic Safety Standards makes it clear that the exposure of air crew to cosmic radiation should be managed as a planned exposure situation, contrary to the approach taken by the ICRP. AusALPA asserts that Australia is not compelled to adopt ICRP 132 (or ICRP 103) verbatim and strongly recommends that, to the extent permitted by the Constitution, ARPANSA should adopt the extant aircrew protection provisions of the EURATOM Basic Safety Standards. Comment not adopted Comment not adopted. Australia as a membered state of the IAEA is obliged to implement where possible the requirements of GSR Part 3, therefore having aircrew managed as an existing exposure situation is consistent with GSR Part 3, ICRP 103 and ICRP 132. Australia is not compelled to adopted the EURATOM Basic Safety Standards as we are not members of the European Union. 59 Proposed change The best illustration of why a reference needs to be imposed is simply the current state of radiation exposure monitoring by Australian airlines. ICRP 132 places the responsibility on “operating management”. Both AusALPA and IFALPA consider this approach to be unlikely, but more probably incapable, of success. The most obvious conflict arises as a consequence of Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3.