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Re: Nucl Week on French Acad of Med statement on LNT & "Disinformation"



The Council Directive 96/29/Euratom of 13 May 1996  it's very clear in its article 9, Member States may decide an annual amount.
 
Article 9

Dose limits for exposed workers
1. The limit on effective dose for exposed workers shall be 100 millisieverts ('mSv`) in a consecutive five-year period, subject to a maximum effective dose of 50 mSv in any single year. Member States may decide an annual amount.
2. Without prejudice to paragraph 1:
(a) the limit on equivalent dose for the lens of the eye shall be 150 mSv in a year;
(b) the limit on equivalent dose for the skin shall be 500 mSv in a year. This limit shall apply to the dose averaged over any area of 1 cm², regardless of the area exposed;
(c) the limit on equivalent dose for the hands, forearms, feet and ankles shall be 500 mSv in a year.
 

There is a Communication from the Commission concerning the implementation of Council Directive 96/29/Euratom dated of 30.4.98

Article 9

The Directive has decreased the effective dose limit for exposed workers from 50 mSv in a year to 100 mSv in a consecutive five year period, subject to a maximum effective dose of 50 mSv in any single year.

While respecting the limit of 100 mSv in a consecutive five year period Member States are entitled to decide instead on an annual amount. In this case the effective dose limit would be 20 mSv in a year. Member States which wish to adopt stricter dose limits shall comply with Article 54.

Article 54

As a result of Article 54 of the Directive, in the case a Member State is to adopt stricter dose limits, it has also to inform the other Member States. The Commission would normally be notified under Article 33 of the Treaty.

 

In  particular, another example: The German Radiation Protection Standards, accept the Directive 96/29, however includes the Wismut reclamation workers under the new radiation workers standards (such as an annual dose standard of 20 mSv rather than 50 mSv). It allows for Wismut workers, however, for the exceedance of the life time dose standard of 400 mSv, provided the excess dose rate is limited to 10 mSv per year and the worker gives written consent; (otherwise many of the workers currently employed by Wismut would have to cease their work).
Moreover, workers cleaning up uranium mining sites that had been abandoned before 1960, are not subject to the new radiation worker regulations, but only to the less stringent regulations for work in natural radiation environments.

A colleague from German can add comment about
 
I have the pdf form on Communication from the Commission concerning the implementation of Council Directive 96/29/Euratom dated of 30.4.98
If a colleague wish a copy please let me know.
 
Jose Julio Rozental
Israel
 
----- Original Message -----
To: Radsafe
Sent: Friday, January 18, 2002 9:56 PM
Subject: Fw: Nucl Week on French Acad of Med statement on LNT & "Disinformation"

Ooops,
    I meant to send this to radsafe yesterday but forgot to add the radsafe address in the reply.
 
Regards
        Julian Ginniver
----- Original Message -----
Sent: Thursday, January 17, 2002 10:39 PM
Subject: Re: Nucl Week on French Acad of Med statement on LNT & "Disinformation"

The UK have also adopted a 100 mSv over 5 year limit.  The UK's legislation (The Ionsing Radiations Regulations 1999) is based on the same Euratom directive that has to be enshrined in the National Legislation of each member state.  I as understood from the consultation stage of the draft UK legislation this was at the specific request of a nuclear operator.  As Ben Morgan identified there may be differences between consecutive years in the dose recieved by individuals.  This is particularly noticable on Nuclear power plants that have an operating cycle of greater than 12 months.  In this case there may be a year where very little dose is recieved this would be followed by a period where very large individual and collective doses were recieved.  The use of the rolling 5 year limit would allow personnel to exceed the 20 mSv/y limit as long as over the 5 rolling five years they did not exceed the 100 mSv limit.
 
In the UK it is necessary to identify in advance that an operator might wish to apply the 100 mSv/5y limit and also to identify who individual that will require the application of this dose limit and to notify the NII (the UK NRC).  The NII may require the employer to apply the 20 mSv/y limit (that is refuse the use of the 100 mSv/5y limit).  In addition the NII will require the employer to demonstrate that any dose recieved by this employee is As Low As Reasonably Practicable(ALARP). BTW ALARP is the UK term for ALARA as the phrase Reasonably Practicable is defined in English Law.  In addition when the identified employee exceeds the standard 20 mSv/y dose limt the employer must undertake an investigation (review) of the exposure (this is despite the fact that the it was planned to exceed this limit and that the NII had already been notified that this would occur). 
 
All of these requirements are designed to limit the use of the rolling 100 mSv/5y dose limit to pre-planned activities where it has been demonstrated in advance that it is not practicable to comply the 20 mSv/y limit.  The 100 mSv/5y limit cannot be applied retrospectively in the event of an accidental overexposure.  In addition once it has been decided to adopt the rolling 100 mSv/y to an employee there are restrictions on reverting to an annual basis for the dose limit for this individual.
 
Regards
        Julian Ginniver
 
----- Original Message -----
Sent: Thursday, January 17, 2002 8:35 PM
Subject: RE: Nucl Week on French Acad of Med statement on LNT & "Disinformation"

Greetings:
 
A 20 mSv/y limit and a 100 mSv over 5 y limit are not necessarily the same thing. As proposed by ICRP, the limts were 100 mSv over 5 y with no single year to exceed 50 mSv. This allows for doses above 20 mSv in some years (nuclear plant maintenance outages, research programs, etc.) to be balanced out with doses below 20 mSv in other years.
 
While it adds up to the same thing, a 20 mSv/y limit does not provide this flexibility and, I believe, this is what the French Academicians are protesting.
 
Regards,
 
Ben