radiation committee from 2005- 2010, I can see no benefit to the aircrew body in Australia by an increase of these guidance levels. In fact, conversely, I consider it a reduction in potential health benefits to the pilot and cabin crew group, especially in light of the fact of no regulatory compliance regulations and the increased flying in future years for Australian aircrew as outline in my introduction. 56 Captain Dick Comment As much as we respect the research Comment not Comment not adopted. MacKerras, and policy recommendations of the adopted Technical, International Commission on Please note that ARPANSA’s role Safety and Radiological Protection (ICRP), we is to promote national uniformity Regulatory also recognise that attempting to of radiation protection policy and Affairs Advisor separate and exclusively characterise practices across jurisdictions of on behalf of the exposures between and the Commonwealth, the States “planned” Australian events cannot satisfy all and Territories, and provide “existing” Airline Pilots’ situations and, therefore, careful advice on radiation protection Association consideration by ARPANSA must and related issues. However, replace rote acceptance of ICRP ARPANSA can only regulate recommendations. More broadly, Commonwealth entities. AusALPA is concerned that ARPANSA may be surrendering its leadership role in radiation protection of air crew by recommending increased exposure monitoring levels to the point where exposure becomes trivialised. 57 Proposed change AusALPA is advised that, of Accepted Comment accepted. AusALPA believes that 6 mSv year-1 the limited aircrew retains both national and population monitored in
radiation committee from 2005- 2010, I can see no benefit to the aircrew body in Australia by an increase of these guidance levels. In fact, conversely, I consider it a reduction in potential health benefits to the pilot and cabin crew group, especially in light of the fact of no regulatory compliance regulations and the increased flying in future years for Australian aircrew as outline in my introduction. 56 Captain Dick MacKerras, Technical, Safety and Regulatory Affairs Advisor on behalf of the Australian Airline Pilots’ Association Comment As much as we respect the research and policy recommendations of the International Commission on Radiological Protection (ICRP), we also recognise that attempting to separate and exclusively characterise exposures between “planned” and “existing” events cannot satisfy all situations and, therefore, careful consideration by ARPANSA must replace rote acceptance of ICRP recommendations. More broadly, AusALPA is concerned that ARPANSA may be surrendering its leadership role in radiation protection of air crew by recommending increased exposure monitoring levels to the point where exposure becomes trivialised. Comment not adopted Comment not adopted. Please note that ARPANSA’s role is to promote national uniformity of radiation protection policy and practices across jurisdictions of the Commonwealth, the States and Territories, and provide advice on radiation protection and related issues. However, ARPANSA can only regulate Commonwealth entities. 57 Proposed change AusALPA believes that 6 mSv year-1 retains both national and AusALPA is advised that, of the limited aircrew population monitored in Accepted Comment accepted.
rpsg-2_public-consultation-comments.docx