has to be taken, including prolonged exposure situations after emergencies.” 72 Line 25-27 Comment: This section introduces Retrospective adjustments Accepted retrospectivity. The MCA urges introduce uncertainty and caution. risk for operators. 73 Line 31 Proposed change Typo Accepted Comment accepted. – Amend: There is no above’ ‘(a) Corrected 74 30, 31, Proposed change Inconsistency this refers Comment not Comment not adopted. – – 32 MCA suggests Lines 30-32 be to material’, adopted ‘radioactive retained but later in the draft guide, which is defined in the Guide is aligned with GSR Part 3. it is stated that the draft guide glossary as meaning applies regardless of the activity designated by the ‘material concentration. Therefore the relevant regulatory body as definition of material’ in being subject to regulatory ‘radioactive the section is unclear. MCA control because of its recommends a thorough check on radioactivity’. The the consistency of the document definition of ‘radioactive with respect to material’ is legally derived ‘radioactive material’. from ARPANSA regulations, which notes that material less than 1Bq/g (U238 and Th232 decay chain radionuclides) is not subject to regulation. 75 34-37 Proposed changed Radon exists naturally, so Comment not Comment not adopted. – Add levels outlined in Annex the implication is that all adopted An Annex is not considered ‘above ‘part’ a’ to and radon progeny in workplaces are subject to of a document and therefore ‘Radon workplaces other than those existing exposure cannot be referred to in the workplaces for which exposure due situations and the Scope but can be referred to in to other radionuclides in the guidelines apply. the text of the document from uranium decay chain or the thorium The MCA recommends Section 2 onwards. decay chain is controlled as a amendment to avoid planned exposure situation’. confusion. 76 38-40 Proposed change It is inconsistent with the Comment not Comment not adopted. – definition of adopted ‘radioactive
has to be taken, including prolonged exposure situations after emergencies.” 72 Line 25-27 Comment: This section introduces retrospectivity. The MCA urges caution. Retrospective adjustments introduce uncertainty and risk for operators. Accepted 73 Line 31 Proposed change – Amend: There is no ‘(a) above’ Typo Accepted Comment accepted. Corrected 74 30, 31, 32 Proposed change – MCA suggests Lines 30-32 be retained but later in the draft guide, it is stated that the draft guide applies regardless of the activity concentration. Therefore the definition of ‘radioactive material’ in the section is unclear. MCA recommends a thorough check on the consistency of the document with respect to ‘radioactive material’. Inconsistency – this refers to ‘radioactive material’, which is defined in the glossary as meaning ‘material designated by the relevant regulatory body as being subject to regulatory control because of its radioactivity’. The definition of ‘radioactive material’ is legally derived from ARPANSA regulations, which notes that material less than 1Bq/g (U238 and Th232 decay chain radionuclides) is not subject to regulation. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 75 34-37 Proposed changed – Add ‘above levels outlined in Annex a’ to ‘Radon and radon progeny in workplaces other than those workplaces for which exposure due to other radionuclides in the uranium decay chain or the thorium decay chain is controlled as a planned exposure situation’. Radon exists naturally, so the implication is that all workplaces are subject to existing exposure situations and the guidelines apply. The MCA recommends amendment to avoid confusion. Comment not adopted Comment not adopted. An Annex is not considered ‘part’ of a document and therefore cannot be referred to in the Scope but can be referred to in the text of the document from Section 2 onwards. 76 38-40 Proposed change – It is inconsistent with the definition of ‘radioactive Comment not adopted Comment not adopted.