The Future of Radiation Protection An IRPA Perspective

1. HERCA Meeting, Liverpool, May 2019 The Future of Radiation Protection An IRPA Perspective Roger Coates, IRPA President

2. Role of IRPA The international voice of RP professionals 52 Associate Societies Representing 67 countries • Over 18,000 individual members Our members cover all fields of radiation protection, including practitioners in medical, nuclear and other industry sectors, regulators, government advisers and researchers. We encompass the full spectrum of national experiences, from large developed countries through to practitioners working in small developing nations

3. IRPA Strategic Priorities • To promote our role as the international voice of the RP profession • To support the Associate Societies by developing, enhancing and sharing good practice and high standards of professionalism. • To support the education and training of RP professionals

4. System of Protection Consultation Practitioner’s views on the System of Protection - and how it can be communicated • General perceptions: complexity & ‘understandability’ • Presentation of uncertainty in risk estimates at low dose • Context of natural background exposure • Dose limitation and dose limits • ALARA and Reasonableness (+ Conservatism & Graded Approach) • Communication and public understanding Report published in Journal of Radiological Protection (open access) - see IRPA website

5. System of Protection Consultation Practitioner’s views on the System of Protection - and how it can be communicated Subtext • Have we gradually developed an over-complex system which is becoming far removed from ‘common sense’? • Is the system, and the way it is implemented, delivering reasonable ‘value for money’ for society?

6. IRPA Consultation with the ASTop tier issues arising • Uncertainty in risk at low dose/rate (few mSv/y) • Honesty in what we know and what we don’t know • Avoid ‘the risk is 5% per Sv’: it’s a prudent hypothesis for protection, not a scientific fact • At normal levels, the risk uncertainty has an upper bound – evidence from natural background. • Many argue over ‘LNT versus Threshold’ - but it will not be clear in the foreseeable future! The key question is – ‘How to take decisions at ‘a few mSv/y’ • all we really know is that if there is a risk, it is small

7. IRPA Consultation with the ASTop tier issues arising • Natural background • It’s the dominant exposure source, and should be used to give a context • It can help to emphasise that there is no difference between natural and man-made radiation • It cannot be used to promote acceptability of another exposure type , although it can give a helpful context to aid understanding Discuss later!

8. Dose Limits – A Key Issue • Dose Limits • ‘Limit’ strongly implies a border between safe and danger. No amount of ‘small print’ can negate this • Why are dose limits so high profile? They only relate to non-medical planned exposure, and are hardly ever used in practice • The public dose limit of 1 mSv/y confuses the public – it is less than natural background • Are limits really needed? Regulators feel the need for the legal construct, but can this be met another way? Can ‘limits’ be folded in to ALARA? • Limitation of exposure is OK – applies across planned, existing and emergency exposure and can be linked to ALARA A difficult and potentially unwelcome debate to be had!

9. IRPA Consultation with the ASTop tier issues arising (3) Practical Protection Issues • Prudence and Conservatism • ALARA and Reasonableness • The Graded Approach

10. Prudence – what does it mean? • The ability to recognise and follow the most suitable or sensible course of action • Care, caution and good judgement, looking ahead • Skill and provident care in the use of resources • Care and wisdom in planning for the future • A sensible and careful attitude in making judgements and decisions: behaviour that avoids unnecessary risks • To make informed and carefully considered choices without the full knowledge of the scope and consequences of an action

11. Prudence At the level of principle who could possibly disagree? • wisdom, suitable, sensible, care, caution, good judgement, carefully considered choices

12. Prudence At the level of principle who could possibly disagree? • wisdom, suitable, sensible, care, caution, good judgement, carefully considered choices But these concepts are judgemental What is ‘suitable’, ‘sensible’ or ‘good judgement’ in one situation (eg high risk level) may not be appropriate at a much lower risk level

13. Prudent Walking Glacier walking in the High Alps

14. Prudent Walking Glacier walking in the High Alps Summer walk around my village

15. Prudence and conservatism In day to day practice, prudence has translated into the need for a conservative approach – in assessments, safety cases and operational approaches. This requirement is often reflected in international and regulatory guidance and expectations. But this inevitably introduces an intrinsic bias towards lower and lower doses.

16. Prudence and conservatism So the key question is: How much prudence and conservatism is appropriate in various practical situations?

17. Clearance - a Case Study in prudence and conservatism Clearance allows the removal of material (including wastes and reusable material) from regulatory control. or Like exclusion and exemption, it is aiming to focus the regulatory system onto issues of significance, not trivia.

18. Clearance criteriaIAEA Safety Series 89, 1988 What is a trivial dose? - what is likely to be acceptable to individuals? - context of natural background exposure Conclusion: ‘Some tens of µSvper year’ Based on LNT and other prudent judgements - eg ‘a few percent of natural background’

19. So how to put clearance into practice? From philosophy to the practical application of clearance: a) Application to a specific situation b) Conversion to Activity Concentration [µSv/y to Bq/g] c) Practical measurement margin – confidence in the outcome because it is legal compliance d) Sum of fractions – combination of several nuclides e) Activity distribution in cleared material

20. Assessment Modelling Many clearance scenarios modelled: • parameters representative of the specific model time at exposure, geometrical assumptions, resuspension factors etc, • standard radiological parameters environmental transfer factors, dose per unit intake etc. Each scenario typically 5 – 12 parameters (multiplied) • Factor 1.2 conservative: 2.5 – 9 outcome • Factor 1.5 conservative: 8 – 130 outcome

21. Assessment Modelling - International advice • ICRP 101: Assessing dose of the Representative Person for the purposes of RP of the public and optimisation Use of 95 percentile data • IAEA Guide: Prospective radiological environmental impact assessment and protection of the public “The assessment methodology needs to be conservative in order to avoid underestimating the impact” We tend to follow this guidance for all assessments and judgements – at any dose level, for any purpose!

22. Conservatisms in the system

23. Clearance Outcome ‘Some tens of µSv/y’ was set as a (very) prudent level. In practice, clearance gives actual doses a factor of at least 100 lower - not more than around 0.1 µSv/y Context: Lowest typical personal dose ~ 2 mSv/y for everyone from natural background Taking account of clearance, a few reference persons get 2.0001 mSv/y.

24. Clearance Outcome ‘Some tens of µSv/y’ was set as a (very) prudent level. In practice, clearance gives actual doses a factor of at least 100 lower - not more than around 0.1 µSv/y Context: Lowest typical personal dose ~ 2 mSv/y for everyone from natural background Taking account of clearance a few reference persons get 2.0001 mSv/y. Is this what we want from the System of Protection??

25. Implications Managing waste as radioactive material is much more expensive than ‘free release’. Eg. UK experience: to reduce from 1 Bq/g to 0.1 Bq/g for Cs137 costs several £ Billion over lifetime. Is this money well spent?? Hence need to review the Bq/g values: • Could be increased by factor 10-100 and still meet the top tier criterion • But not much support at IAEA! “Yes, but ….”

26. Wider implications Prudence is right in principle, but its application is judgemental. Prudence must be balanced with other ethical values: EgBeneficence– doing the best that can be done with society’s resources Society has limited resources: if used on inappropriate prudence/conservatism, this is an opportunity cost which does not give best value for society How do we save the most lives?

27. Conservatisms in our RP System We have drifted into accepting conservatisms in our day to day work, without consciously assessing its impact or what is really appropriate. Indeed, we don’t really know how much conservatism we have – its usually well hidden.

28. Conservatisms in our RP System We have drifted into accepting conservatisms in our day to day work, without consciously assessing its impact or what is really appropriate. Indeed, we don’t really know how much conservatism we have – its usually well hidden. It feeds many other areas of practice: • ALARA - what is Reasonable??? • Regulatory caution? Yes – we want to be ’safe’, but we also want value for society

29. Practical protection issues:ALARA and ‘Reasonableness’ Historically ALARA has been a success – eg nuclear industry occupational exposures • ALARA and Reasonableness • Accepted as the controlling factor for exposures, but how do we decide what is ‘reasonable’? • When have we done enough? Is it right to expect ever lower and lower doses??

30. ALARA and ‘Reasonableness’ • There is a growing concern that there is an expectation (e.g. from some regulators) of ‘ever lower doses’ – minimisation, not optimisation • An emphasis on ‘As Low As’, notwhat is Reasonable • Again, is this the best use of society’s resources – driving doses ever lower? • How low is ‘low enough’ in the circumstances? IRPA is promoting dialogue 2 workshops in Paris: February 2017 and October 2018.

31. ‘Low Dose’ proportionality What should be reasonably done at low doses? • Engaging with all parties involved in the exposure • Appropriate education and training • Maintaining a work environment allowing openness and challenge • Learning and sharing from experiences • Strong leadership • Etc

32. Its just Safety Culture!Radiation is no different!

33. Public Exposure But there is a public sensitivity which we cannot ignore So where appropriate we must all engage But beware assuming what ‘the public’ actually want • does driving to low doses really ease public concern? • Or does it make them think ‘this man-made radiation must be really dangerous’ - and remember that someone has to pay. Usually its all of us!

34. Paris ALARA Workshops Main Conclusions: • It’s a deliberative process: judgements are situation-dependent • Aiming to achieve a reasonable “compromise” with all (informed) stakeholders • BUT key differences between occupational/medical and public situations? Occupational/medical: - key aspects of the ALARA process are very strongly aligned with the key attributes of a (radiation) safety culture, with additional emphasis to higher exposures Public situations: - often ‘high stress’ situations and differences in perceptions - more emphasis on process and seeking common understanding

35. Paris (continued) • Some situations have resulted in minimisation, not optimisation • Recognised need to look at Value for Money for society • Cost Benefit Analysis has proved to be limited • So how to do it??? • Is there a regulatory role??? • Next steps : • This remains a key issue of concern for IRPA • We will join with international colleagues and then review further action • ICRP [Tolerability and Reasonableness] and NEA Workshop on Reasonableness

36. Practical Protection Issues -The Graded Approach The Graded Approach is a regulatory principle – to apply increasing levels of stringency as the level of risk increases • a proportionate approach • best use of regulatory resources, and society’s resources But is not consistency applied in practice • Eg in regulating NORM (natural radioactivity, for example in mining) • Material above 1Bq/g is classed as ‘radioactive’ – but it should not need the full weight of stringent regulation!

37. NORM and Mining - Some Thoughts 1Bq/g is……… • The cut off that defines a material as being radioactive, and • In theory is therefore the starting point for regulatory consideration • BUT in practice has become a de-facto “limit”

38. NORM in mining - Consequences • Once defined as radioactive, the label is difficult to remove • Usually a graded approach collapses to pure compliance – with virtually zero safety benefit • $100’s million to reduce product from 2Bq/g to 1Bq/g - If not, material considered to be inferior (loses value) • Ultimately, it all just costs more • Companies forging ahead and spending the money - considered to be the price of compliance But is this good value for society, and does it drive the right behaviours?

39. Typical NORM Regulation Its like using a cannon to kill a mosquito

40. Typical NORM Regulation Its like using a cannon to kill a mosquito It usually misses the target, but there sure is a lot of collateral !

41. Public Understanding: Things that are important (from the consultation) • Does the use of a ‘banded’ approach help communication? Brings together all exposure situations.

42. Public Understanding: IRPA is moving towards Guiding Principles for Communicating with the Public 1. Introduction – why we need to communicate 2. Objective of this guidance (and what it is not) 3. Key issues from radiation science 4. Key issues from communication science 5. Key common factors across all communications 6. Specific situations – key issues and approaches 7. Communication tools 8. Roles, responsibilities and capabilities: RP Societies Individual RP professionals 9. Conclusions

43. The context of natural background exposure Every person receives at least 2mSv/a (and many receive significantly higher doses) - Everything else is an addition to this Personal lifestyle decisions add a ‘Delta’ to this: • Whether to change house • Where to holiday • Whether to fly • Etc This Delta could easily be ± 0.5 mSv or more Such decisions are made daily, with no concern or interest (and usually no knowledge) of radiation risk. Rightly so!

44. The context of natural background exposure So why do we put so much emphasis and effort into controlling doses down to well within the Delta? Almost all real RP decisions we make have no material impact on the total dose received by an individual • 95% of all exposure decisions do not change the ‘few mSv/a’ picture for any individual How does (should!) this play under Tolerability of Risk?

45. The classic example Clearance – the 10 µSv/a criterion Actually its nearer 0.1µSv/a because of conservatisms! Doses to a very few individuals! - up from 2mSv/a to 2.0001mSv/a It costs many tens/hundreds $M Cornwall holiday in the UK Tens of thousands of holidaymakers each year Each person gets several tenths mSv additional dose No-one is remotely concerned or interested Is this giving value for money (best use of resources) to society? Does it align with Common Sense?

46. IRPA Issues Key issue How to take decisions at ‘a few mSv/a and lower’ - when we don’t really know the risk, other than ‘if there is a risk, its very small’

47. Key Issues for the Future • Focus on the larger doses which make a difference to a person’s total exposure • Don’t ignore the smaller doses, but : • Integrate into ‘normal life’, alongside other safety issues • Be proportionate • It’s just a part of wider safety culture and wider life • Don’t seek to drive out every last µSvat great expense to society • And communicate like never before!

48. The Nightmare ‘Thought Experiment’ In the light of new scientific evidence at high to medium doses, radiation risk is reviewed Assuming LNT, the risk factor is doubled Which of the following are the consequences? • Occupational and public dose limits are reduced • Clearance levels are reduced • Regulatory pressure to review exposures • High radon areas are evacuated • Air travel is restricted

49. See you all in Seoul 15th International Congress of the International Radiation Protection Association 11 – 15 May 2020 |COEX, Seoul, Korea