Comment (3) of Michael Dennis on FR Doc # 2011-21900 (New International Commission on Radiological Protection; Recommendations on the Annual Dose Limit to the Lens of the Eye)

Document ID: NRC-2009-0279-0051
Document Type: Public Submission
Agency: Nuclear Regulatory Commission
Received Date: September 06 2011, at 12:00 AM Eastern Daylight Time
Date Posted: September 20 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: August 30 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: October 31 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f11f41
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This is comment on Notice

New International Commission on Radiological Protection; Recommendations on the Annual Dose Limit to the Lens of the Eye

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Recommend caution on change. Uncertain of any safety/biological benefit to reduction. Primary medical eye exposure is in interventional fluoroscopic procedures. Eye dose estimated by external dosimeter and generally does not account for any additional eye shielding. It is rare to get exposures above this limit, however it does happen in busy labs, and results in ALARA followup. A 2 rem limit would initiate an ALARA followup on many individuals and dilute the intent and effectiveness of ALARA. Would not recommend any change under 5 rem.