ALARA and de minimis concepts in regulation of personnel exposure

It is suggested that the ALARA process should not be limited by a de minimis level on either collective or individual dose. Instead it should be limited or defined by: (a) an acceptable discount-rate on future costs and effects, and (b) a monetary value for detriment (e.g. $10,000 to $20,000/person-Sv; $100 to $200/person-rem) to be used in cost-effectiveness or cost benefit calculations at dose levels well below the regulatory limits. This approach would provide the desired benefit of simplifying the decision process and thereby making it more cost effective and would avoid the inconsistencies of limits on only one of the four parameters of importance in the optimization process. These are: average individual effective dose equivalent rate, number of individuals to be included in the summation, years of exposure, and costs, which include costs of analysis to reduce the exposure. This is not to claim that individual doses of 10 to 100 μsv/yr (1 to 10 mrem/yr) are not trivial, but rather to emphasize that these doses to an individual may not be considered trivial by society when given to a very large population, especially if they could easily be avoided. The latter factor, in particular, is often overlooked in discussions of the de minimis concept