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Wassenaar, Richard <personal information redacted>
July 15, 2019 11:49 AM
Consultation (CNSC/CCSN)
Nordion Comments on June 15, 2019 Notice, Canada Gazette, part I, Volume 153, Nubmer 24
Nordion Comments to RPR revisions.pdf
Good Morning,
Attached, please find Nordion’s comments to the proposed revisions to the Radiation Protection Regulations.
Should you have any questions, please don’t hesitate to contact me.
Sincerely,Richard
Richard Wassenaar, PhD, MCCPM, CHPDirector, Regulatory and EHSNordion447 March Rd, Ottawa ON, K2K 1X8personal information redacted
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A Sotera Health company
July 15, 2019
Mr. Brian TorrieCanadian Nuclear Safety CommissionP.O. Box 1046, Station B280 Slater StreetOttawa, Ontario K 5S9
Re: Nordion Comments on Canada Gazette, Part I, Volume 153, Number 24, Notice of June 152019
Dear Mr. Torrie
Nordion wishes to thank the CNSC for the opportunity to comment on the proposal changes to theRadiation Protection Regulations, as outline in the notice of June 15, 2019 in the Canada Gazette,Part 1.
Attached, please find a table of industry comments that Nordion has participated in creating.Specifically, Nordion has concerns over the following:
1) The new regulations propose to provide pregnant and breastfeeding women the decision toself-disclose their situation. Nordion is in agreement with this change. However, theregulations must ensure that any obligations of a licensee with respect to providingaccommodating work or emergency response duties for pregnant and breastfeeding womenare only applicable once a woman has self-disclosed to the licensee.
2) As part of the change for women to self-disclose their pregnancy, there is an additionalrequirement being introduced for licensees to inform female nuclear energy workers of therisks associated with exposure of the embryos and fetuses to radiation and risks to breastfedinfants from intakes of nuclear substances. There is a significant amount of informationsurrounding this area of health physics from numerous sources. Many licenses may not beequipped to properly compile this information into something that can be presented in aninformative way. The CNSC should assist licensees by providing a summary of such risks.
3) The addition of Subsection 20(3), exempting containers used for temporary storage ofradioactive substances from paragraph (1) b), will help reduce an administrative burden thatdoes not have any clear safety benefits. However, it is not clear exactly how this newregulation will be interrupted by various stakeholders (i.e. inspectors vs. licensees). Furtherdiscussions between licensees and the CNSC would be beneficial to ensure this regulation isproperly understood.
We look forward to further discussion with the CNSC on this proposal.Sincere
chard WassenaarDirector, Regulator & EHS
Attached: Industry Comments on Canada Gazette, Part 1, Volume 153 Number 24
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A Sotera Health company Industry comments on Canada Gazette, Part I, Volume 153, Number 24 Regulations AmendingCertain Regulations Made under the Nuclear Safety and Control Act (Radiation Protection)
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Impact on Industry, if major commentSuggested Change [ if applicable)Industry issue MajorComment/Request for
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MAJORRIAS, Section For licensees of uranium mines and mills, the removal of how radonprogeny is calculated from the regulations (and REGDOC) means there isno clear review and consultation process for any proposed changes to thedose conversion factor from exposure (WLM) to dose (mSv).How radonprogeny is included in the effective dose calculation is fundamental to thedetermination of whether the dose limits are being met. As a result, thereis a need for clarity on both the actual calculation and the process orchanges. Since there is no cost identified with this change,it is assumedthe CNSC intends to continue to accept the current conversion factor of 5mSv/WLM.However, this is not documented in the current draft ofREGDOC-2.7.2. If a change to the radon progeny dose conversion factor isproposed in the future,it should undergo a Regulatory Impact Analysisequivalent to that done for regulations.The CNSC committed to atechnical review and consultation specific to a change to the dosecalculation for radon progeny in DIS-13-01 Proposal to Amend theRadiation Protection Regulations (pg.12).
Contrary to the RIAS, the details of how radonprogeny are to be calculated in effective doseare not in the current draft of REGDOC-2.7.2,Dosimetry: Ascertaining Occupational Dose. Thisis a significant omission for licensees of uraniummines and mills.
The regulations should detail the methodfor how radon progeny is included in theeffective dose calculation for uraniummines and mills; specifically, the doseconversion factor between WLM andmSv.
1.13
Please see related comments 12 and 13.
MAJOR Even if the scientific research supported a measureable linkagebetween dose and cataract formation, Nuclear Energy Workers atmost nuclear facilities are largely unaffected by this type ofexposure. The CNSC should clarify there are workers in the medicaland NDE fields who may not be sufficiently protected and it is theseindividuals they are targeting with the amendments.
RIAS, Section14, para. 1
Amend to read, “Radiation exposureto the lens of the eye, above athreshold dose, has been linked to itsopacification (or clouding of the lens,which in its advanced stages, isreferred to as a cataract). Data hasshown that personnel involved inindustrial radiography and medicaldiagnostic and interventionalradiology have a higher risk.”
In 2016,the United States Nuclear RegulatoryCommission decided not to proceed withrulemaking in this area because it would result inlittle,if any, improvement in occupational orpublic safety. (Please see U.S. Federal Register/Vol. 81,No. 249). In fact,recent scientificresearch suggests it is not possible to establish alink between radiation exposure and cataractproduction. These findings call into questionwhether there is an identifiable threshold forcataract formation.
2.
The proposed 5-year limit creates a significant administrative burdenDelete the second bullet and MAJORRIAS, Section Industry has significant concerns with the3.
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Impact on Industry, if major commentDocument/Excerpt of
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Suggested Change ( if applicable ) MajorComment/Request for
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Industry issueif
only to demonstrate that Nuclear Energy Workers are sufficientlyprotected from a threshold of questionable validity. Also, there couldbe an impact on the livelihood of tradespeople who will be subject todose estimates based on overly-conservative surrogatemeasurements. Boilermakers and other tradespeople who work atmultiple licensed sites will receive overly-conservative doseestimates at each of the sites. This will cause them to prematurelyapproach the permissible dose limits and impact their availability todo radioactive work. Canada already faces an undersupply oftalented tradespeople and an overly-conservative 5-year limit willonly exacerbate that issue with no corresponding benefit to workersafety.
recognize that licensees should beexpected to minimize dose to the lensof the eye through their ALARA (aslow as reasonably achievable)programs.
14 para. 3,bullet 2
proposed introduction of a 5-year limit in thesection on equivalent dose limits for the lens ofan eye. If passed, this new limit would introducesignificant operational challenges to licenseeswith no improved safety benefit to workers.
Specially, the 1st bullet in Section 14 sets atarget of no single year exceeding 50 mSv.However, the second bullet sets a 5-yearlimit of 100 mSv, which is effectively a 20mSv limit for any given year.
While industry believes it can adapt to the proposed reduction in thecurrent limit from 150 mSv to 50 mSv in a one-year dosimetry period, the5-year limit does not enhance safety commensurate with its associatedchallenges and, therefore, is inconsistent with industry's ALARA principles.
MAJOR Worker safety is industry’s top priority. As written, this falsely impliesthat licensees were only concerned with financial impacts. As percomment #3, Canadian industry already faces an undersupply oftalented tradespeople and an overly-conservative 5-year limit willonly exacerbate that issue with no corresponding benefit to workersafety.
Amend to read, “However, theyquestioned the benefit of some of theproposed changes given the potentialadministrative and financial burden.They also specifically challenged thescientific credibility of the linkagebetween a lens of the eve dosethreshold and cataract formation.”
RIAS,RegulatoryDevelopment,para. 4
Industry concerns went beyond theadministrative and financial burden. Theyquestioned the science behind the thresholdand limit and the absence of a methodologyfor measuring lens of the eye dose in mixedradiation fields. Licensees suggest theCNSC conduct an epidemiological or healtheffects study on Canadian nuclear energyworkers regarding radiation-induced lens ofthe eye opacification/cataracts.
4.
Worker safety is industry’s top priority. As written, this falsely impliesthat licensees are comfortable with workers receiving health effectssuch as cataracts.
MAJORAmend to read, “claiming that thechange in the dose limit is notwarranted, considering that the healtheffects (cataracts) are regarded aseasily treatable;’’
RIAS,RegulatoryDevelopment,Section 14,bullet 3
The text suggests that stakeholders arecomfortable with workers receiving healtheffects such as cataracts. Stakeholders
5.
were, in fact, opposed to treating, orsuggesting that cataracts be treated, asequivalent to cancer-related dose effects.The 4m bullet is incomplete and contextually MAJOR Worker safety is industry’s top priority. As written,this falsely impliesAmend to read, “... citing significantRIAS, re.6.
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RegulatoryDevelopment,Section 14bullet 4
inaccurate as currently written. financial and administrative burdenwith the proposed change and theassociated impact on their operation,in particular for those exposuresituations with non-uniform fieldswhere the lens of an eye dose couldbe the limiting exposure for workersbecause of the need to conservatively
that licensees were only concerned with financial impacts.
estimate rather than measure theexposure.”
RIAS,RegulatoryDevelopment,Section 14, 2nd
para., lastsentence
As per comment #1, the US NRC rendered adecision not to proceed with rulemaking inthis area, because of the lack of a clearsafety benefit.
Delete the final sentence, -However-itis-clear-that-lens opacities-andfesultin§-r-adiatiQn‘induGed-Gatar-aGtsare-a -health-ef-feGt-that-Gan-andshauld-be-prevented̂
MAJOR This is a misrepresentation. The results are inconclusive andsubject to challenge and that should be reflected here.
7.
No rational is provided for distinguishingbetween the skin as a whole,and the skin of thehands and feet.The proposed change to "skin ofthe hands and feet" could add more confusionthan clarity. Section 14(3) states that "when theskin is unevenly irradiated,the equivalent dosereceived by the skin is the average equivalentdose over the1cm2 area that received thehighest equivalent dose." Therefore, all dosereceived by the "skin of hands and feet" must beincluded in skin dose,because the skin isunevenly irradiated.
It would still not be clear to industry how to apply the equivalent limit tothe hands and feet.
For clarity, remove the term "skins ofthe hands and feet" for the followingreasons:1) the ICRP has never defined what"hands and feet" mean2) the limits for "skin" and "skin ofthe hands and feet" are the same3) it would close any distinctions thatmight allow a single location of theskin to receive up to1Sv of dosemerely because it occurs on a handor foot
8. RIAS,RegulatoryDevelopment,Sections 8 and
MAJOR
14
Industry has significant concerns with the sectionon labelling and believes a workshop with CNSCstaff is necessary to ensure commonunderstanding.
For containers intended to be used only within the licensee's facility, likethose for waste, adding specifics on radionuclides inadvertently creates asafety risk when staff are trained to evaluate risk based on hazardconditions (dose rates or air concentrations).Waste cans are frequently
Industry requests the CNSC host aworkshop to ensure the requirementsare clearly understood and key termsdefined.
9. RIAS,Section 20,
MAJOR
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emptied by trained and qualified staff. There is also an administrativeburden that would require each bag or container to be sampled, analyzed,tags printed and affixed to the item.
Licensees agree containers and devicescontaining nuclear substances should be labelledto alert persons to the presence of a nuclearsubstance and the real or potential hazard/riskthat exists.However,NEWs are trained torecognize hazard levels and understand the riskswhen reading posted radiation fields (e.g.mrem/h,mSv/h,MPCa or DAC, cpm,etc.) Giventhis, listing radionuclides and associatedactivities on waste containers intended to staywithin a nuclear facility does not improve thesafety for personnel. Licensees agree thatcontainers/sources shipped out of the facilityshould have the appropriate specifics.
Items for discussion could include:Defining 'container' and 'device'.Does it mean radiation device perNSRD regulations?Applying the exemption to thelabelling requirements for containersor devices in an area subject to theboundary and point of access signsin s. 21.
Also, clear regulations promote better compliance.The absence ofdefinitions can lead to licensees' interpretations which may not meet theintent of the regulation's requirements.
Also, the exemption cited in this section does notapply to containers and devices in a designatedposted area which imposes measurementrequirements that are unnecessary.
RIAS, Table 1 The analysis does not account for theadditional staff that will need to be hired, on-boarded, trained, etc. to take the place ofthose staff that prematurely approach theirpermissible dose limits.
Incomplete / inaccurate cost information. Changes to resourcingneeds would be significant with no corresponding benefit to nuclearsafety. Some licensees estimate the changes could cost anadditional $6-12 million for maintenance and major componentreplacement outages. Other licensees estimate up to $500,000 willbe required initially - and $250,000 annually - to amend workpractices/procedures to comply with the proposed limits.
As per comment #9, industry requeststhe CNSC workshop include a reviewof its cost model and thediscrepancies between the RIAS andthe impacts provided by industry.
10. MAJOR
Also, no formal request has been made forcost information. An informal request wasresponded to in December 2018, but therehas been no follow-up discussion.
One-for-OneRule
Operating experience confirms that changes of this type havesignificant impacts on administrative burden as per comment #10.
Industry disputes the statement, ‘The CNSCdoes not expect the proposed Regulations toincrease the administrative burden of
Delete this statement.11- MAJOR
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licensees or applicants. Therefore the One-for-One rule does not apply to the proposedRegulations.”
1, 5(1), 5(2),12. The definitions of radon and radon progenyshould apply to exposures occurring as adirect result of a CNSC-licensed activity,such as exposures to radon and radonprogeny in uranium mining and milling, asstated in REGDOC 2.7.1 *
Amend the document to clarify that itapplies to exposures occurring as adirect result of a CNSC-licensedactivities (e.g. uranium mines and mills)only and that radon and radon progenyfrom natural sources do not need to beincluded in effective dose calculations.
Without clarity, the inclusion of radon and its progeny could lead some tomisinterpret that dose from naturally occurring radon progeny must beascertained.The concept of effective dose sufficiently captures the whole-body dose from all sources of radiation resulting from licensed activities.
MAJOR19(f)
KD13. Contrary to what is stated in the RIAS, thedefinitions of working level and working levelmonth have not been included in the currentdraft of REGDOC-2.7.2 to support the calculationof effective dose.
This term should be defined for uraniummines and mills only throughout thedocument.
Uncertainty and inconsistency.MAJOR
7 (1) (d) and 10 Bullet (d) of Section 7 (1) changes therequirement to provide a "worker's radiationdose levels" to the "worker's radiation doselevels received on an annual basis." Licenseesmay not be able to collect workers' personaladdresses or other contact information.
14. Add a bullet to Section 10 on NEWobligations that says,"If ) theworker's current mailing and/or
Industry needs supporting regulations to require NEWs to provide acurrent mailing/email addresses so licensees can meet this obligation.
MAJOR
email address"
7 (1) (e) The requirement to inform all NEWs of theirduties and responsibilities during an emergencymay not be realistic depending on the level ofdetail expected.Emergencies,by their verynature, are not always predictable and it maynot be possible to accurately foresee theemergent conditions.
15. Amend the requirement to specifyproviding a general description ofexpected responsibilities duringemergency scenarios and include anexplanation of risks with doses up to theemergency dose limits without explainingspecific responsibilities.
Depending on the level of detail expected,this may be impossible withseveral thousand nuclear energy workers on some sites at any given time.Without clarity, this could unintentionally create instant and widespreadnon-compliance.
MAJOR
7 and 11 Industry supports the repeal of the provision fora female NEW to self-disclose her pregnancy to
16. Amend the regulations to clarify that theresponsibility lies with the pregnant or
Without this,it is difficult for licensees to comply with the requirement toensure that pregnant workers are not used in the control of an emergency.
MAJOR
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the licensee as long as the regulations are clearwith regard to licensees' obligations.Thisproposal aligns with the international practice ofvoluntary self-disclosure of pregnancy andnursing.
nursing NEW to declare their status tothe licensee in writing. Until such adeclaration is provided, the licensee hasno obligation to accommodate workassignment or dose limits associated withpregnant or nursing status.
Also, the risks and rights may have been given to the female NEW manyyears prior to becoming pregnant.Declaring pregnancy to the licenseesaffords an opportunity to provide her with the most current informationand refresh her on the risks.
8, 10 and 1817. For the purposes of epidemiological studiesusing the National Dose Registry (NDR) data,"sex" (i.e.male/female) is the relevant quantityof interest,not "gender." It is unknown whetherNDR will be updated to accept data for genders.If this change is made,the acceptable/expectedgenders should be defined and changes to NDRsubmission requirements communicated tolicensees in advance.
At this time, adopting the term "gender" increases uncertainty since thechange is inconsistent with reporting under the NDR.
Maintain "sex" as the descriptor. MAJOR
11(1) and (2) The requirement to accommodate workers asdescribed is already covered by existingprovincial and federal laws.
18. Remove the redundant requirementsrelated to accommodations.
Clarification
11 (2) As currently written,the regulations do notindicate whether a pregnant NEW can revokeher declaration of pregnancy.
19. Amend Section 11to include thefollowing:"A female nuclear energy
worker may revoke, at any time, herwritten declaration that she is
Other jurisdictions allow pregnant NEWs to revoke their declaration.Withthe addition of the ability to voluntarily declare,it gives a female NEW anew method to cope with the psychological pain of spontaneous orinduced abortion by simply revoking the declaration instead of informingthe licensee of the fate of the foetus.
MAJOR
pregnant.Upon receipt of thisrevocation, the licensee mustproceed as if it had never beeninformed of the pregnancy orbreastfeeding."
20. The proposed new dose limits for the lens of aneye will be identical as the WB effective dose
14 Retain the 5 rem (50 mSv) per yearequivalent dose, but remove the
There is no scientific consensus for the proposed 5-year equivalent dose of100 mSv (10 rem),which current research shows is not required. As per
MAJOR
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limits. Industry supports the reduction of theannual dose limit from 150 mSv (15 rem) to 50mSv (5 rem), but opposes the proposed 100 mSvover a 5-year dosimetry period.
proposed 10 rem (100 mSv) over 5 years. comment #3, the proposed 5-year dose would introduce operationalcomplexities and administrative challenges to demonstrate that workersare below regulatory dose limits. In the absence of accurate dosimetry forlens of the eye in beta radiation fields, surrogate measurements would beused to provide a conservative estimate of dose. In turn, theseconservative estimates would lead to the premature removal of workersfrom performing radioactive work.
21. The proposed changes to the table to subsection13 (1),Item1Column1,does not convey that apregnant NEW can revoke her pregnancydeclaration.
14 This is not an issue if the suggestedchange for Section 11is incorporated
A licensee would be forced,by the letter of the regulations,to maintainthe special dose limit for a pregnant NEW unless the pregnant NEW hasthe ability to revoke her declaration.
MAJOR
22. In the table to subsection 13 (1),the proposeddose limits allow for a lower dose limit for a childof a breastfeeding worker (1mSv) (i.e. Personwho is not a nuclear energy worker) than afoetus (4 mSv),when the foetus is moreradiosensitive.
14 Amend to include the following note,"Subsection (1) does not apply inrespect of a child of a breastfeedingNEW."
Without clarity, for 1-131for example, this would cause a disparity where apregnant NEW could receive 4 mSv effective dose and her foetus wouldreceive 11mSv CED. But the same NEW with the now child,born onJanuary1st, would be limited to receiving 0.38 mSv effective dose per yearbecause her child would be limited to1mSv CED (assuming 1-131).
MAJOR
23. The proposed change to subsection 14(1)provides no definition of equivalent doses.Having one is important in the context of thedose limit regarding the lens of the eye.
15 Define equivalent doses in Section 14 (1)(i.e. the equivalent dose for the lens ofthe eye is Hp(3),or accepted alternative).
Without a definition,particularly in mixed radiation fields, there isuncertainty around measurements of true Hp(3) doses and potential forsignificant overestimation. In addition,a definition would requiredosimetry providers to show how estimation algorithms estimate theHp(3) dose,as opposed to what they would consider an "eye dose".
MAJOR
24. 15 While there are no proposed changes to Section15, Emergencies, licensees believe there is anopportunity to add clarity to this section whilethe regulations are being amended. Please seethe requested change in the next column,whichis an expectation/interpretation mentioned inother regulatory documents (REGDOC 2.10.1,Emergency Management and Fire Protection,Volume II and REGDOC 2.7.1, Radiation
Include a statement in Section 15 of theamended regulations to read: "Dosereceived from emergency responseactivities should be treated separatelyfrom regular occupational doses."
Clarification
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Protection). Reinforcing this in the RPRs wouldcreate additional clarity.
25. 15 Regarding the table for Section 15 of theregulations, given that the equivalent dose limitsfor items 2 and 3 are the same,and they bothrefer to skin equivalent doses, it is not obviouswhy they need to be differentiated.
If the separate listing of dose limits foritems 2 and 3 is meant to force differentreporting and dosimetry requirements,that should be clarified somewhere inthe RPR,potentially in Section 5.
Clarification
26. 18 The definition of "management system" cannotbe found in the regulations.Also, industry has no issue with the replacingparagraphs 18 (b) and (c) in the regulations aslong as the changes in terminology do notintroduce new requirements.
ClarificationInclude a definition for "managementsystem" and confirm the terminologychanges in 18 (b) and (c) carry no newrequirements.
27. 20 Licensees have concerns with proposed changesto Section 21. For licensees with facilitiesdesigned for the purpose of processing largevolumes of radioactive material, e.g. uraniummills, there is little benefit to putting signage onevery entrance to those facilities indicating thatthe radioactive material is present.
Add a subsection to exempt theapplication of s. 21(1) to facilities whosepurpose is the bulk processing andhandling of radioactive materials.
Maintenance of a significant number of signs creates an administrativeburden with no corresponding safety benefit. Operating experience showstoo many signs can actually create confusion,not clarity.
MAJOR
Also, licensees request the rationalebehind the change to posting to vehiclesin Section 21. Industry believes thisbetter covered by a REGDOC.
Industry has significant concerns that Section24.1is overly broad as currently written.Thisconcern also relates to RIAS Section 22:Proposednew section on radiation detection andmeasurement instrumentation.
28. 22 Industry believes the subtleties oflanguage are very important in this areaand propose this be discussed as part ofthe workshop proposed in comment #9.Specifically, licensees urge the CNSC toamend 24.1to read,"Every licensee mustensure that instruments and equipmentthat are used for radiationmeasurements related to direct,personnel protection are selected, tested
"Radiation measurements" include in-core flux detectors and otherdetectors related to radiation processes not related to radiationprotection. As written,it would be illegal to have a licenced fixed gaugeout of calibration because it would not be "calibrated for" its intended use(because it 'measures radiation'), having nothing to do with RadiationProtection.
MAJOR
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and calibrated for their intended use."
Compliance for using new dose factors (0.12 and0.88) should align with the effectiveimplementation for new eye dose limits which isJan1,2021.
29. 25 Revise to align with the new lens of theeye dose limits.
Without adequate time for implementation,industry could be in non-compliance with the new regulations upon their publication.
MAJOR
Compliance with s.15(2) within the proposedtransition period is not possible. Industry notesthat in Europe,this took five years to implement.
Section 15(2) should not come into effectuntil January1,2024 to allow fordosimetry services for mixed radiationfields to become available for monitoringof Hp(3). This is consistent with theimplementation period in Europe.
30. This is currently an evolving field,and there are no certified dosimetryservices in North America that provide Hp(3) for mixed radiation fields.
25 MAJOR
Industry has concerns with a subjective conceptsuch as ALARA (as low as reasonably achievable)being explicitly tied to administrative monetarypenalties as they are in Items 2-5 in Part 3.
Remove the phrase "as low as reasonablyachievable" from Items 2, 3,4, 5.
31. Part 3 It is inappropriate to link a subjective concept with a monetary penalty.MAJOR
Industry has concerns with Item 34, provision15(7),"Requesting a pregnant woman toparticipate in the control of an emergency"
32. Part 3 Amend to read "Requesting a NEW whohas declared pregnancy to participate inthe control of an emergency."
Unless a pregnant woman was required to declare pregnancy,it is possiblethat a licensee could unknowingly request a pregnant woman participatein the control of an emergency.
MAJOR
Schedules 1and Changing the tissue weighting factors and theradiation weighting factors to match ICRP 103recommendations would invalidate all previousdose conversion coefficients. The ICRP has yet torelease all dose coefficients based on the 2007recommendations.
33. Retain the weighting factors from theICRP 60 recommendations until allcurrent dose coefficients are updatedto the new recommendations.Theother option would be to treat eitherset of weighting factors as equallyvalid.
Industry would have to self-fund the development of dose conversioncoefficients for all radionuclides and situations,something theinternational community of Health Physicists has yet to do.This cost is notconsidered in the regulatory impact statement.
MAJOR2
Schedule 2 It is assumed that a spelling error is present initem 3 of schedule 2,and such the correctreading is "Protons and charged pions."
Without a change,the regulations would not provide a radiation weightingfactor for protons.
34. Change the first instance of"neutrons" to "protons" as per ICRP103.
MAJOR
Schedule 2 Column1specifies "all energies" for some types Leaving the table as proposed would make items 3 through 5 technically in35. Remove "energy range" and "all MAJOR
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of radiation so that "energy range" does notappear necessary.
energies" as they are redundant. SeeICRP 103.
error because column1does not denote an energy range.
Schedule 2 As currently written, the industry could lawfullyuse any "continuous function of neutron energy"as a weighting factor.
36. Reference the continuous function ofneutron weighting factor from ICRP103. The alternatives would be toprovide a graph like schedule 3 of theRPR or include the equations directlyto reconstruct the function.
Industry would not be able to follow the same standard without thisclarification.
MAJOR
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