Abstract
Abstract
The principle of optimisation of protection is a cornerstone of the system of radiological protection (RP). The practical implementation and interpretation of optimisation, particularly at low doses and dose rates, is a long-recognised challenge and has often been subject to robust and spirited debate. At present, we seem to have unprecedented interest and momentum for reflection on RP recommendations and standards, and with it the opportunity to collaboratively develop creative solutions to such challenges in support of a sustainable future. Potential solutions should be informed by science as well as a wide range of social and economic factors and be thoroughly and critically evaluated accordingly. In the United States (US), Executive Orders have led to relevant proposed rule changes from the US Nuclear Regulatory Commission (NRC), including one entitled ‘Reforming and Modernizing the NRC’s Radiation Protection Framework’. This paper argues that the proposal is rushed, imprecise and insufficient by highlighting a few illustrative examples of how the proposed rule change as written is inconsistent with international (e.g. International Commission on Radiological Protection) and national (e.g. US National Council on Radiation Protection and Measurements) recommendations and guidance. For example, the proposal claims that adherence to regulatory dose limits provides a sufficient level of protection and that beyond prescribed actions at certain thresholds, there is no need for further incorporation of the prevailing circumstances (i.e. no need to optimise protection) below these dose limits. National authorities of course have the purview to decide what is most appropriate and effective from a regulatory standpoint, but diverging from the broader consensus requires a clear, thoughtful, thorough and transparent argument that is missing from the current proposal.