How to involve stakeholders, especially citizens, in the revisioning process of ICRP general recommendation: An analysis of ICRP public comments

This study aims to propose measures to promote stakeholder, especially citizens, involvement in the revision process of the General Recommendation (GR). To achieve this, we analysed the public comments for ICRP recommendations. Sixty-one public comments have been conducted by ICRP since 2005; a total of 1613 comments were posted (an average of 26.4 comments/publication draft). The draft of ICRP Publication 146 received 308 comments, followed by ICRP Publication 103 ’s (2007 GR) second and first drafts which received 217 and 195 comments, respectively. We examined the posters’, ‘organisation’, and ‘name’ and classified them as general public (GP) or not (non-GP). Among the 1135 posters, we identified 268 GP and 867 non-GP. ICRP Publication 146 received 251 comments from GP, but the first and second drafts of ICRP Publication 103 received only 33 and 23 comments, respectively, from GP. The largest comment for the draft of ICRP Publication 146 is attributed to the citizen group's briefing, and ICRP accepted Japanese comments. Despite the large number of comments, critical comments from GP were not well reflected in ICRP Publication 146 . In developing ISO 26000: Guidance on social responsibility, the International Organization for Standardization (ISO) involved representatives from (1) industry, (2) government, (3) labour, (4) consumers, (5) NGOs, and (6) service, support, research, and others. The working group included 355 experts and 77 observers from 72 countries. In 2008's public comment, 5200 comments were posted worldwide. On the other hand, the ICRP 2007 GR was developed by 14 main commission members of ICRP or specialists in radiological protection. Accepting comments in multiple languages effectively promotes public engagement with ICRP recommendations. However, a reflection of citizens’ comments was limited in the past ICRP public comments. Involving the general public or a citizen group from the initial stage of the revision process is essential to formulating multi-stakeholder–involved general recommendations.