prevent its effective use in practice. 68 General The draft guide would benefit with For clarity. Accepted Comment accepted with comment the inclusion of a section which: modifications. - Outlines the regulatory context and the of the guide Scope has been re-written to ‘fit’ - Defines the intended audience or clarify the reader of the user of the guide document and how this Guide is - Clearly defines how the guide is to applied. be applied. 69 General The draft guide indicates that The MCA recommends Accepted Comment accepted with Comment regulation of radiation is potentially controls should be modifications. now required below 1Bq/g covering commensurate with the in fact all materials. This means that assessed risk. Scope has been re-written to the scope is essentially infinite which clarify the reader of the reduces the practicality of the draft document. guide. This reinforces the perception Existing exposure situations by that radiation is dangerous at low is everything, regardless levels. The MCA suggests changes be of regulation. incorporated to reduce the scope to situations where radiological impacts are significant. 70 Line 7-8 Comment: The MCA supports the The MCA has stated Accepted Noted statement that the central previously that the consideration is the of dose principle reasons for the ‘system limitation’. low occupational and public doses are due to the optimization process and supports the draft reflecting this. 71 Line 20-21 Proposed change For clarity. Accepted Comment accepted with – Existing exposure situations are modifications. exposure situations that already exist when a decision on control has Re-written as follows “Existing to be taken’. MCA suggests adding exposure situations are exposure section 2.2 of this guide’ after situations that already when ‘see this. a decision on the need for control
prevent its effective use in practice. 68 General comment The draft guide would benefit with the inclusion of a section which: - Outlines the regulatory context and the ‘fit’ of the guide - Defines the intended audience or user of the guide - Clearly defines how the guide is to be applied. For clarity. Accepted Comment accepted with modifications. Scope has been re-written to clarify the reader of the document and how this Guide is applied. 69 General Comment The draft guide indicates that regulation of radiation is potentially now required below 1Bq/g covering in fact all materials. This means that the scope is essentially infinite which reduces the practicality of the draft guide. This reinforces the perception that radiation is dangerous at low levels. The MCA suggests changes be incorporated to reduce the scope to situations where radiological impacts are significant. The MCA recommends controls should be commensurate with the assessed risk. Accepted Comment accepted with modifications. Scope has been re-written to clarify the reader of the document. Existing exposure situations by is everything, regardless of regulation. 70 Line 7-8 Comment: The MCA supports the statement that the central consideration is the ‘system of dose limitation’. The MCA has stated previously that the principle reasons for the low occupational and public doses are due to the optimization process and supports the draft reflecting this. Accepted Noted 71 Line 20-21 Proposed change – Existing exposure situations are exposure situations that already exist when a decision on control has to be taken’. MCA suggests adding ‘see section 2.2 of this guide’ after this. For clarity. Accepted Comment accepted with modifications. Re-written as follows “Existing exposure situations are exposure situations that already when a decision on the need for control
rpsg-2_public-consultation-comments.docx