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Re: U.S. NRC proposes changes to shallow dose exposure limit



> This is in keeping with the recommendations found in NCRP 130.



While this proposal is an improvement, the NRC needs to move towards 

acceptance of dose weighting. The skin, being an organ, should be 

viewed as other organs are, and where there are weighting factor 

applied, if the NRC would accept the methodology, such as what is 

outlined in HPS N13.41-1997.



In my opinion, it is still unrealistic and not logical to assign a 

SDE based on the highest 1 cm, 10 cm or whatever number of cm's one 

wants to consider, when in all practicality, the cumulative dose 

effect to the person is insignificant. Now, for very high dose 

particles, I can agree that averaging needs to be assessed. However, 

for the general population of workers, using the highest dose nees to 

be re-thought.



------------------------------------------------------------------------

Sandy Perle					Tel:(714) 545-0100 / (800) 548-5100   				    	

Director, Technical				Extension 2306 				     	

ICN Worldwide Dosimetry Service		Fax:(714) 668-3149 	                   		    

ICN Pharmaceuticals, Inc.			E-Mail: sandyfl@earthlink.net 				                           

ICN Plaza, 3300 Hyland Avenue  		E-Mail: sperle@icnpharm.com          	          

Costa Mesa, CA 92626                    



Personal Website: http://www.geocities.com/scperle

ICN Worldwide Dosimetry Website: http://www.dosimetry.com



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