In sections 4.2 to 4.4 the guide has Section 4 also states the an introductory discussion about following decision should then “A exposure of persons to radon, be made as to what management cosmic rays, and radionuclides in or intervening action may be commodities and bulk materials. It required, taking full account of then provides guidance for situations the costs and benefits of the in which exposure are above the action. The outcome of the initial relevant reference level (see lines assessment should help guide the 565, 583, 638, and 643). decision–making process.” This is not the case with exposures due to contamination of areas by residual radioactive material - the discussion goes directly to the remediation of these areas (an action carried out if the relevant reference level is exceeded). There is no discussion about habitation of land with residual radioactive material in a situation where the reference level is not exceeded and remediation has not, and need not, be carried out. In these situations the option may be to do nothing at all, or to have in place a management plan that for example, leaves in place the extant natural or built environment so that exposure does not increase (note that this is not the same as remediation which is meant to reduce an existing exposure). 119 Section 4.4 This clause says a protection strategy Noted. should be developed by the employers in conjunction with the Any protection strategy should relevant regulatory authority. be developed in conjunction with However, this type of exposure is the relevant regulatory authority. only addressed under Section 3 – Guidance for public exposure, so is
In sections 4.2 to 4.4 the guide has an introductory discussion about exposure of persons to radon, cosmic rays, and radionuclides in commodities and bulk materials. It then provides guidance for situations in which exposure are above the relevant reference level (see lines 565, 583, 638, and 643). This is not the case with exposures due to contamination of areas by residual radioactive material - the discussion goes directly to the remediation of these areas (an action carried out if the relevant reference level is exceeded). There is no discussion about habitation of land with residual radioactive material in a situation where the reference level is not exceeded and remediation has not, and need not, be carried out. In these situations the option may be to do nothing at all, or to have in place a management plan that for example, leaves in place the extant natural or built environment so that exposure does not increase (note that this is not the same as remediation which is meant to reduce an existing exposure). Section 4 also states the following “A decision should then be made as to what management or intervening action may be required, taking full account of the costs and benefits of the action. The outcome of the initial assessment should help guide the decision–making process.” 119 Section 4.4 This clause says a protection strategy should be developed by the employers in conjunction with the relevant regulatory authority. However, this type of exposure is only addressed under Section 3 – Guidance for public exposure, so is Noted. Any protection strategy should be developed in conjunction with the relevant regulatory authority.
rpsg-2_public-consultation-comments.docx