management’s commercial and promotional interests they have little or – nothing to gain from actively managing their workforce’s radiation exposure to the detriment of the roster and there is little incentive for them to select a reference level that might cause that outcome. 60 Capt. A. C. Proposed change IFALPA understands the Comment not Comment not adopted. Ruas, Capt. Air crew exposure should be importance that ICRP 132 adopted Rodrigues classified as a planned exposure, not and EURATOM BSS Guide is aligned with GSR Part 3. and SFO as an existing exposure. converge in the Theresia classification of the aircrew Eberbach on as planned exposure half of situations. Considering that International this Public consultation Federation of Draft applies to existing Airline Pilot exposure situations and Associations given the fact that the (IFALPA) document assumes the ICRP 132 definition that classifies the aircrew as existing exposure situations, we reinforce the recommendations presented below regardless of the ICRP 132 and EURATOM BSS divergence in the matter. 61 Proposed change Those who are liable to Accepted Comment not adopted. IFALPA recognizes 20 mSv/y as the receive an effective dose average annual dose of ionizing greater than 6 mSv per The reference level of aircrew has radiation for pilots, so in this regard year should be classified as been revised down to 6 mSv per the reference level of 10 mSv/y is in Category A workers. The year.
management’s commercial and promotional interests – they have little or nothing to gain from actively managing their workforce’s radiation exposure to the detriment of the roster and there is little incentive for them to select a reference level that might cause that outcome. 60 Capt. A. C. Ruas, Capt. Rodrigues and SFO Theresia Eberbach on half of International Federation of Airline Pilot Associations (IFALPA) Proposed change Air crew exposure should be classified as a planned exposure, not as an existing exposure. IFALPA understands the importance that ICRP 132 and EURATOM BSS converge in the classification of the aircrew as planned exposure situations. Considering that this Public consultation Draft applies to existing exposure situations and given the fact that the document assumes the ICRP 132 definition that classifies the aircrew as existing exposure situations, we reinforce the recommendations presented below regardless of the ICRP 132 and EURATOM BSS divergence in the matter. Comment not adopted Comment not adopted. Guide is aligned with GSR Part 3. 61 Proposed change IFALPA recognizes 20 mSv/y as the average annual dose of ionizing radiation for pilots, so in this regard the reference level of 10 mSv/y is in Those who are liable to receive an effective dose greater than 6 mSv per year should be classified as Category A workers. The Accepted Comment not adopted. The reference level of aircrew has been revised down to 6 mSv per year.
rpsg-2_public-consultation-comments.docx