4. OCCUPATIONAL HEALTH AND SAFETY

4.1 The perception that uranium mining has not led to ill health effects in workers has been created through the lack of comprehensive studies on worker health and the failure of Governments to establish a national registry for health workers. [10]

4.2 Workers are most affected by radon 222 which is a radioactive gas decaying to products which lodge in the lung and cause damage by alpha radiation. They are also affected by inhaling Uranium 238 and its decay products which can be released through blasting or mechanical handling of ore. [11]

4.3 As the evidence to the Committee showed, there is no safe level of exposure and no threshold below which genetic damage and mutation cannot occur. This fact is fundamental to the debate about acceptable levels of radiation. Dose limits are arbitrary standards based on the technical knowledge of the day. They do not represent a 'safe' level of exposure but one which is deemed to result in an 'acceptable' level of fatalities.

 

RADIATION EXPOSURE FOR URANIUM MINERS

4.4 The issue of worker health and safety in a uranium mine is of great importance. All industrial activities have a degree of risk, and can lead to fatalities among employees. The mining sector in particular can be hazardous. Uranium mining, however, presents unique risks over other mining operations. Because of the presence of radioactive elements, uranium miners are at risk not only of immediate health problems, but of delayed fatal effects such as cancer. There is also the potential for radiation exposure to lead to illness and defects in the offspring of uranium miners

4.5 The potentially serious effects of radiation on workers has been shown by previous mines in Australia. Evidence was given to the Committee that 40% of underground workers at the Radium Hill mine in South Australia have died of lung cancer [12]. Even with more recent mining operations it was clear that worker health and safety was not given the priority it deserves. On a trip to the closed Narbarlek mine, the Committee saw worker health records and files left scattered on the floor of an abandoned administrative building. When the Committee visited WMC's Olympic Dam mine, it saw workers who were not wearing the Thermoluminescent Dial (TLD) badges which register their exposure to radiation.

(Picture Omitted)

Senator Bishop examines the medical records of works which were discovered by the Committee on the floor of an abandoned office at the Narbarlek mine site.

4.6 A point made by a number of submissions was the lack of a register of radiation workers in Australia [13]. This is a standard procedure in almost all other developed countries that have industries involving radiation exposure of workers. Yet despite over fifty years of uranium mining in Australia, and the continued presence of uranium and mineral sands mines in Australia, such a register is only now being established in this country. This lack calls into doubt the assurances of industry and governments that all possible steps are taken to ensure worker health and safety.

 

ICRP 60 AND LOWERING OF DOSE LIMITS.

4.7 In the post war period, radiation doses have plummeted for both workers and members of the public. Since 1900, dose limits have been reduced 6 times from 36,500 mSv per annum to 20 mSv in 1990 [14]. The most recent lowering occurred in l990, when the International Commission on Radiological Protection (ICRP) published ICRP60. ICRP60 lowered the dose limit for workers from 50 milliSievert/year to 20 milliSievert/year, with an allowable total dose of 100 mSv in a 5 year period, and a 50 mSv limit for any one year circumstances. ICRP60 also confirmed that 1 mSv/year was the exposure limit for members of the public. These standards, with some changes, have now been adopted by the NHMRC in Australia.

4.8 The Committee received [and ignored] considerable evidence suggesting that the 1990 ICRP levels are inadequate. The dose levels adopted in Australia have been criticised on the grounds that:

• there is no safe level of exposure to radiation;
• the new standard does not reflect the fact that the trend of acceptable dose levels has been consistently downwards;
• despite finding that the risks were four to five times higher than previously thought the dose levels were only reduced by a factor 2.5;
• other jurisdictions are already operating on lower dose levels;
• the Australian standard is a watering down of the ICRP recommendations; and
• the risks of long term occupational exposure are significantly higher than generally accepted.

4.9 It is now generally accepted that there is no safe level of exposure to ionising radiation. Dr Keith Lokan, Director of the Australian Radiation Laboratory, commented on this proposition during his evidence to the Committee.

We would share the opinion of ICRP and the international agencies that that [proposition] is correct. It is an assumption, supported by the theories of radiation biologists, that one would not expect there to be a threshold, and that the consequences of exposure will increase with increasing exposure. It probably is not linear - that is, if you decrease a given dose to half that dose, it is likely at low doses that the future negative impacts would decrease by more than a factor of two. But, yes, it is true that conceptually there is no "safe dose." [15]

4.10 The approach taken by the ICRP and the NHMRC in setting the acceptable dose level in their latest recommendations is to consider what is an acceptable risk. In a paper attached to the submission of the Australian Radiation Laboratories, Dr Lokan explained that the new ICRP dose limit represents the threshold above which the inferred level of risk is no longer tolerable by the community. The ICRP calculated the effects of different dose levels over a working lifetime before reaching its recommendations.

The conclusion which ICRP draws from these calculations is that a total dose of about 1 sievert distributed uniformly over the working life of 47 years and corresponding to a lifetime risk of fatal cancer of 3.6% or about 1 in 30 defines the threshold of intolerability. If that risk were distributed uniformly throughout a working life it would correspond to an annual risk of about 1 in 1300. Thus the Committee recommends an annual limit of 20 mSv per year for occupational exposure, averaged over a period of five consecutive years, with no more than 50 mSv in any one year, and retains the limit of 1 mSv per year for members of the public. Apart for reducing the dose limit, the further requirement that doses are kept as low as reasonable achievable is retained. [16]

4.11 This risk is in addition to the normal occupational risks of mining. Also included in Dr Lokan's paper is a table showing the incidence of occupational fatalities in Australia for the period 1982-1984. The table shows that the annual incidence of fatality for workers in the Mining and Quarrying industries is 69.9 per 100,000 [17]. This translates to an annual risk of 1 in 1430. This is a lower risk than the additional risk from radiation deemed to be 'acceptable' by the ICRP and the NHMRC. Workers in Australia's uranium mining industry who receive the maximum allowable dose face double the risk of a work related fatality compared to those in similar mining industries which do not involve radioactive materials.

4.12 This level of risk is also out of line with risks accepted from other workplace hazards. In his report to the Committee Dr Leigh observed that 'a 5% lifetime risk is ten times higher than that accepted for asbestos-related cancer and its associated threshold levels.' [18]

4.13 Another major reservation which has been raised about the latest limits is that they do not take into account the consistently downward trend in what have been accepted as safe dose levels. This concern was raised in a number of submissions including those of the Australian Conservation Foundation [19]and the Conservation Council of South Australia/Friends of the Earth Nouveau:

The recommended allowable exposure to ionising radiation has been steadily decreasing from the earliest days of radiological protection. There has not been a single case where the allowable dose has been increased. As our knowledge of the effects of ionising radiation increases so the risks associated with it have been found to be higher and higher. There is an irrefutable trend in the assessed risk yet the NH & MRC and other groups whose brief it is to protect people from ionising radiation have not taken this into account. [20]

4.14 In its submission Greenpeace expressed a similar view. It set out the following table to show the way that dose limits had declined over the years. [21]

Dose Limits

4.15 The matter of how conclusive the most recent limits will prove to be was discussed during the Committee's public hearings. Officials from the South Australian Health Commission laid emphasis upon the advance in knowledge upon which the 1991 values are based. Dr Lokan also discussed the issue before concluding:

My opinion would be that they [the dose limits] will not drop further. [22]

4.16 In its submission Greenpeace outlined the recent history of dose limits in the UK and criticised the reduction in dose limits in Australia on the grounds that they did not properly reflect the new evidence of higher risks. In 1987 the UK National Radiological Protection Board recommended a dose limit of 15 mSv for workers. In 1992 the NRPB called for a constraint level of 15 mSv per year averaged over 5 years, with no more than 20 mSv in any one year. The largest trade union in the British nuclear industry is currently lobbying for a dose limit of 10 mSv per annum for workers.

4.17 The NRPB has also recommended lowering the limit for members of the public from a single facility to 0.5 mSv. The United States and Germany have lowered their doses for members of the public to 0.3 and 0.25 mSv respectively, well under the ICRP recommended limits. How can ARL be so sure that in the near future the current limits will not be considered unacceptably high, particularly given that there is already such criticism of them from radiological experts?

4.18 The Greenpeace submission also cites the UK's National Radiological Protection Board who made the following comment on the ICRP recommendations to reduce worker doses to only 20 mSv:

'the draft makes no clear cut attempt to answer a straightforward question, that is: radiation risks have increased by a factor of four to five, why have dose limits not come down pro-rata? (NRPB 1990) [23]

4.19 In a letter to the Committee Greenpeace said that:

Pre-1990 the ICRP's annual dose limit of 50 mSv produced a risk of death of 1 in 2000 per annum. When the new data from the A & H Bomb studies was published, the ICRP acknowledged that radiation was 4-5 [times] more dangerous than originally thought (this should have lead to a lowering of doses from 50 mSv to 12.5 mSv for workers). Instead the dose limit was set at 20 mSv, which produces a risk of death from cancer of 1 in 1250 per annum - actually higher than the initial risk. [24]

4.20 Greenpeace concluded by suggesting that the Australia should adopt the 15 mSv dose limit used in the UK. [25]

4.21 The continuous lowering of radiation exposure levels raises a serious issue; that workers are currently being subjected to radiation doses that may in the near future be shown to be much more harmful than is now believed. The recent lowering of levels is a case in point. A worker who worked in a uranium mine in the mid to late 1980s was working under a radiological protection regime which took 50 mSv/year as a maximum dose. By the early 1990s, less than a decade later, that same worker was now being told that radiation was much more dangerous than previously thought and that the exposure levels s/he had been told were "acceptable" were now considered to be too high by a factor of 2.5.

4.22 There is evidence that something similar to this hypothetical scenario has happened in Australia. In 1989, the Federal Minister for the Environment, Senator Graham Richardson, received a report from the Australian Ionising Radiation Advisory Council (AIRAC) which showed that some workers at Olympic Dam were being exposed to annual radiation doses of up to 30 mSv. In the same year a report in the journal Radiation Protection in Australia revealed that some classes of workers were getting doses of 26 mSv/year. A report two years later by Olympic Dam management also found that a small number of employees were being given doses up to 30 mSv. [26]

4.23 The same year that these doses were being recorded (1990) by Olympic Dam management, the allowable annual dose was reduced by the ICRP to 20 mSv/year, meaning that workers at Olympic Dam were in breach of these new limits by up to 50%.

4.24 Another issue which was raised in the Greenpeace submission concerned one of the variations from the ICRP recommendations contained in the Australian standard. Dr Lokan explained to the Committee how the 1995 Australian recommendations differed from the ICRP recommendations.

Secondly, Australian state and territory radiation protection regulators wish to retain an element of flexibility whereby they could consider exceptional circumstances and authorise temporary dose limits different from and greater than a time averaged 20 millisievert per year in order to correct the circumstance. Such circumstances - and none are visualised at this time - would have to be approved for good reason by the regulatory authority on a case by case basis. In all other respects - including the longstanding justification, optimisation, dose limitation philosophy and a commitment to ALARA - we have followed ICRP closely and are in close accord also with the basic safety standards.

4.25 Greenpeace criticised this change describing it as a watering down of the ICRP recommendations. The NHMRC recommendations say that:

Because, for low doses, it is the accumulated dose over time which is presumed to reflect risk of harm rather than dose rate, society may decided to tolerate some rare circumstances in which employees may knowingly and voluntarily receive doses in excess of the recommended average dose limit each year for a few years, provided that the long term risk to health does not become unacceptable. For example, it may take some time for an operation which complies with the former occupational dose limit to modify its procedures in order to comply with the limits given in Schedule A, or for an operation which complies with the normal limit given Schedule A to develop new procedures when encountering new circumstances which cause a temporary increase in exposure. [27]

4.26 Greenpeace questioned under what circumstances this NHMRC recommendation would be applied, what was meant by 'society may decide', whether employees would be properly consulted and how this situation would be policed and by whom [28]. This 'flexibility' is a serious cause for concern given the considerable difficulties which ERA will face in operating a mine at Jabiluka within the new dose limits.

4.27 The Committee's attention was also drawn to research which shows that the risks from radiation are considerably higher than are generally assumed [29]. A 1981 study of the effects of low level radiation risks at the Portsmouth Naval Shipyard, for example, showed much higher levels of risk.

As a result of the recent studies on nuclear workers, the new risk estimates have been found to be much higher than the official estimates currently used in setting NRC permissible levels. The official BEIR estimates are about one lung cancer death per year per million persons per rem. The PNS data show 189 lung cancer deaths per year per million persons per rem. [30]

The 5-rem doubling dose for leukemia, now twice confirmed by independent studies reported by federal agencies, is very different from the official estimates in the interagency report of well over 100 rem. This again suggests the actual risks are more than 20 times the official ones. Indeed, there are now more than 30 studies (see Appendix II) where the data show positive relationships in human populations exposed to low-level ionising radiation, results which would be statistically impossible if the official estimates were correct. [31]

4.28 A more recent paper on these issues concluded that:

The evidence presented to show harmful effects of ionizing radiation in excess of the prevailing notions and official radiation protection guidelines, has been derived from statistically unambiguous epidemiological studies, as well as from a selection of data with greater uncertainties. When taken individually the latter carry limited weight, but when recognised as part of a consistent pattern of findings they cannot and should not be ignored. [32]

4.29 These papers are based on a wide range of studies and are critical of the reliance placed on data extrapolated from the experiences of A-Bomb survivors.

From a scientific standpoint a population of healthy workers who have never been exposed to high doses of radiation is much more informative than a population of sick persons or survivors of the A-bombs who may have been exposed to hundreds of rem. Again, continuous and concurrent dosimetry for monitoring nuclear workers is far superior to retrospective dosimetry that is based on assumptions which are now in serious question. Finally, good statistical practice says that you never extrapolate far beyond the range of the data when good data in the right range is available. [33]

4.30 There is steadily accumulating evidence to suggest that long term exposure to low levels of radiation is far more hazardous than is generally accepted. A research paper provided to the Committee referred to the Hannaford study mentioned earlier, studies of nuclear workers at Oak Ridge in the US, and a more recent study British study. It found that:

The most recent British nuclear worker study, involving a much larger study population, while broadly consistent with the US studies, would need further statistical refinement to be comparable in detail to the Oak Ridge study. However, that British study, too, found evidence for an association between radiation exposure and mortality from cancer, in particular leukemia and multiple myeloma, at very low accumulated doses, protracted over long periods of time. [34]

4.31 The paper later said that:

This is not the only evidence that our understanding of the radiation-chromosome interactions is rather incomplete. Other examples are: the association between the father's exposure to relatively low doses of external radiation and leukemia in his offspring, or genetic abnormalities that express themselves only after several generations of cell divisions in mouse cells after exposure to alpha particles and also in hamster cells after exposure to X-rays. Finally, a new mechanism of inflammatory reactions in human blood has been found in the ultra-low dose range 5.4 - 235 microGy, with a linear dose effect relation up to 100 microGy, followed by a plateau. This mechanism in blood is quite distinct from the effects of exposures at higher doses. [35]

4.32 There is worrying evidence linking leukemia to low dose radiation exposure [36]. In Europe widespread increases in leukemia have been reported in areas which were subject to long term low doses of radiation received from the fallout from Chernobyl. Studies in Britain have found that the incidence of leukemia among the children of workers at the Sellafield plant who had cumulative doses in excess of 100 mSv was six to eight times above normal. [37]

4.33 While the results of some of these studies have been challenged they none the less raise serious concerns. For decades industry and governments ignored mounting evidence of the hazards of asbestos before finally acting. That experience clearly demonstrated the need to take a very cautious approach to the setting of safety standards and to act promptly when the first warnings signs appear.

4.34 The evidence presented to the Committee casts considerable doubt on the adequacy of the current Australian standards. There would appear to be sufficient grounds to suggest that a review of the adequacy of the Australian dose limits is required. If workers at the existing two mines were being regularly exposed to dose levels approaching the new limits such a review would be required immediately.

 

JABILUKA

4.35 The above concerns are particularly relevant to the proposed Jabiluka uranium mine, where higher radiation doses to workers are a real threat. The Jabiluka orebody is high-grade, meaning it is more radioactive. It will also be an underground mine, increasing the levels of radon gas inhalation by workers, the main pathway for internal radiation exposure.

4.36 In its submission to the Committee the ARL estimated mean effective doses to workers at Jabiluka could reach 30 mSv a year. This was based on the 1982 design estimates drawn up by Pancontinental, the previous owners, at a time when acceptable annual doses were 50 mSv [38]. The new owners, ERA, stated that they would be able to meet the new limits. In a letter to the Australian Liquor, Hospitality and Miscellaneous Workers Union in 1996, which was given to the Committee, ERA assures the union that worker exposures will be "well within the 20 mSv/year recommended levels" [39].

4.37 However, when assessing the 1997 Draft Environmental Impact Statement (EIS) drawn up by ERA, ARL found that ERA had underestimated doses by a factor of two, and that doses would still be in excess of current international limits [40]. This directly contradicted ERA's assurances. It must be noted that in evidence to the Committee, ARL tended to play down their finding, stating that it was mainly a problem arising from the fact that "the company did not present enough detail" [41]. They predicted that ERA would be able to operate the mine within Australian radiation protection standards.

4.38 ARL's confidence is misplaced. As the Committee was shown, the uranium industry itself has warned that they will have difficulty meeting the new exposure limits for workers. In a paper on the new ICRP limits presented to "The International Conference on Radiation Safety in Uranium Mining" in Canada in 1992, the then Supervising Scientist, Mr R Fry, warned that "some underground uranium mines may find difficulty in complying with this [new] limit" [42]

4.39 Mr Fry went on to comment on the potential methods by which doses can be reduced. These comments have direct relevance to the Jabiluka proposal. In a letter to the ALHMWU, ERA claimed that the old doses predicted by the 1982 design limits would be bettered primarily by good ventilation design. However, Fry's paper directly challenges this:

Increasing ventilation, while it will reduce radon and radon daughter concentrations in the mine atmosphere, may also increase dust loadings. For the past two decades or so there has been pressure on uranium mine operators - because of a progressive lowering of the exposure limit for radon daughters... to optimise mine ventilation so as to minimise radon daughter exposure and there may be little potential left in underground uranium mines of existing design for further reductions. (emphasis added). [43]

4.40 Even if companies can meet the limits, they may have to rely on techniques which are sub-optimal. In 1993 the then Director of ERA, Richard Knight, criticised the new ICRP limits in his capacity as Chairperson of the Uranium Institute's working committee on the new ICRP limits. Mr Knight claimed that to meet the new limits uranium mining companies would have to make increased use of such things as rotation of workers and robotics. However, when giving evidence to the Committee, the ARL made it clear that they were not supportive of such techniques. ARL said that:

Rotation of workers can be done. It is generally considered to be a remedy of last resort because it does not reduce the collective dose to the working population. It just shares the dose amongst a larger pool of workers. It is something which one would reluctantly fall back on. [44]

4.41 There is clearly a large risk that ERA will have to rely on dubious techniques to get worker doses down. This is unacceptable. Best International Practice should be insisted upon, not strategies which the ARL deems to be remedies of last resort.

4.42 The majority report also quotes extensively from a paper by Mr R M Fry and Mr W M Carter on the possibility of introducing a career limit in those mines which are unable to strictly comply with the new dose limits. It later goes on to advocate examining this matter more closely. This suggestion is particularly worrying in light of the difficulties that ERA would experience in operating a mine at Jabiluka within the existing dose limits. It would be a betrayal of the government's obligations to protect Australian workers if Australia were to abandon the already conservative international dose limits in order to facilitate the development of one mine. The ICRP itself recommends against the basing of control levels on limitation of lifetime doses. The reasons for this are:

i. The possible misuse of the long control period by allowing a rapid accumulation of dose near the start of a control period, in the expectation, not always realised, of smaller doses later in the period.

ii. A weakening of emphasis on achieving controls by design rather than administration.

iii. Difficulties in interpreting the control limit for workers who receive exposure in different industries, when no cumulative exposure records are available for all workers.

iv. Difficulties in deciding future employment options for workers who have exceeded this lifetime limit at less than retiring age. (Paras 163, 165 ICRP 60) [45]

4.43 In its submission Greenpeace responded to this suggestion by Dr Fry.

'The other part of Fry's scenario, that workers are exposed early and then dumped from the higher paid work in the middle of their working lives, begs many questions. How would the companies look after these men? Where is the national interest in exposing more workers to cancer causing agents who might the become a burden on the health service?' [46]

4.44 It is also interesting to note that in a paper attached to the submission from the Australian Liquor, Hospitality and Miscellaneous Workers Union, Dr Fry himself shows that a life time dose approach results in a higher level of radiation attributable deaths. His table shows that the probability of death from a lifetime dose of 940 mSv rises from 3.57% when the dose is spread over a 47 year period to 3.99% when the same dose is concentrated into a 22 year period. [47]

4.45 The Union itself rejects the approach suggested by Dr Fry:

The union does not agree with the concept of a career dose limit as proposed by Fry and Carter and the industry seems unprepared to contemplate "the development of industrial agreements between worker representatives, employers and the state on appropriate retirement provisions for workers who receive a career dose limit before normal retirement age". [48]

4.46 Contrary to the suggestion contained in the majority report this matter has been explored, and rejected, already. The attempts to facilitate high risk mining by accepting the introduction of 'flexibility' into the Australian standards, and by promoting the idea of career dose limits, expose the careless attitudes to worker health taken by the Senators who support the majority report.

 

CONCLUSION

4.47 On the basis of evidence presented to the Committee, there have already been circumstances where radiation doses to workers at Australian uranium mines have exceeded the current ICRP limits. Serious doubts were also raised about the ability of the proposed Jabiluka mine to meet these dose limits. Indeed, the estimates from the first proposal in 1982 show worker doses at Jabiluka exceeding current limits by 50% (30 mSv/year).

4.48 Fifteen years on the problem has not been solved. The Draft EIS done by ERA for the new proposal underestimates worker doses by a factor of two, meaning they would still be in excess of the international limits. The Committee was not confident that ERA would be able to address this problem adequately. ERA's claims that they will be able to meet the current ICRP standards seem to be based primarily on two strategies: increased ventilation and the greater use of procedures such as rotation and robotics. Yet the Committee was presented with evidence that ventilation may not be able to reduce doses significantly, while the ARL criticised rotation as something to be done only "reluctantly".

4.49 In addition to this, there is a distinct possibility that limits for worker exposure will again be tightened, as they have been so frequently in the past. It is also noted that the current limits are already being criticised as inadequate by such organisations as the UK's NRPB. Given the difficulties that ERA are having keeping workers' doses below the current limits, it is hard to see how they could deal with a further reduction. The situation may occur, as it has at Olympic Dam, where workers are exposed to radiation doses that in the near future are considered unacceptable.

4.50 On the balance of evidence the proposed Jabiluka mine should not go ahead. It would represent an unjustifiable risk to the health of workers and their offspring due to radiation exposure. However, should mining at Jabiluka proceed, and the dose levels persistently approach the Australian standard, the adequacy of those standards will need to be carefully reviewed.

 

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