4. OCCUPATIONAL HEALTH AND SAFETY

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:

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.

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.

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:

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

Workers

Public

1900 100 mSv per day No limit set until 1952
1925 5 200 mSv p.a.  
1934 3 600 mSv p.a.  
1950 150 mSv p.a.  
1952   15 mSv p.a.
1957 50 mSv p.a.  
1959   5 mSv p.a.
1987   1mSv p.a.
1990 20 mSv p.a.  

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:

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:

4.19 In a letter to the Committee Greenpeace said that:

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.

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

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.

4.28 A more recent paper on these issues concluded that:

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.

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:

4.31 The paper later said that:

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:

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:

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:

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

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:

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.

 

Recommendations:

1. Comprehensive longitudinal studies on the effects of radiation on workers and the public from uranium mining should be undertaken in Australia.

 

2. The current Australian dose limits for occupational exposure should be reviewed with a view to reducing both the maximum allowable dose level in any one year and the average across 5 years.

 

3. As an interim measure Australia should adopt the dose limits accepted in the United Kingdom and refuse to approve new projects where workers might be expected to be exposed on a regular basis to the maximum dose.

 

4. Independent assessment of worker dose levels, including the use of urine and blood tests, should be mandatory on current and future uranium mining projects.

 

5. The Olympic Dam indenture agreement should be amended or repealed to ensure that the public has access to all dose records in a form which does not allow individual identification (except individual records which remain the property of the individual).

 

6. Individual workers should be given ready access to the information on their exposure levels contained in the national register.

 

7. The ALATA principle (as low as technically achievable) for radiation exposure should be adopted at all mine sites to replace the ALARA principle (as low as reasonably achievable).


Footnotes:

[10] Friends of the Earth. Submission 40: Greenpeace Australia. Submission 73: Medical Association for the Prevention of War. Submission 79.

[11] Medical Association for the Prevention of War. Submission 79.

[12] Friends of the Earth. Submission 40.

[13] Australian Liquor, Hospitality and Miscellaneous Workers Union, Friends of the Earth, Greenpeace, Australian Conservation Foundation.

[14] Greenpeace Australia. Submission 73.

[15] Dr K Lokan. Australian Radiation Laboratories. Committee Hansard. p1073.

[16] Australian Radiation Laboratories. Submission80, Attachment A.: Dr K Lokan. Australian Radiation Laboratories. Committee Hansard. p1072.

[17] Australian Radiation Laboratories. Submission80, Attachment A.

[18] Occupational Health and Safety in Uranium Mining and Milling - Comments on Submissions in Regard to Occupational Health and Safety. Dr J Leigh. p4.

[19] Australian Conservation Foundation. Submission 81, p13; citing Les Dalton. Radiation Exposures. 1991. p205.

[20] Conservation Council of South Australia/Friends of the Earth Nouvea. Submission 92. p23.

[21] Greenpeace. Submission 73a. p4.

[22] Dr K Lokan. Australian Radiation Laboratories. Committee Hansard. p1073.

[23] Greenpeace. Submission 73 Part B. p5.

[24] Jean McSoreley, Letter to the Committee, 1 May 1997.

[25] Jean McSoreley, Letter to the Committee, 1 May 1997.

[26] Friends of the Earth. Submission 40. p77.

[27] National Health and Medical Research Council. 1995.

[28] Greenpeace. Submission 73 Part B. p11.

[29] Health Consequences of Exposures to Ionizing Radiation from External and Internal sources: Challenges to Radiation Protection Standards and Biomedical Research. Rudi H Nussbaum and Wolfgang Kohnlein, Medicine & Global Survival, December 1995. Vol 2 No 4, p198; Direct Estimates of Low-Level Radiation Risks of Lung Cancer at Two NRC-Compliant Nuclear Instalations: Why Are the New Risk Estimates 20 to 200 Times the Old Official Estimates?. Irwin D J Bross and Deborah L Driscoll. The Yale Journal of Biology and Medicine 54(1981), p317-328.

[30] Direct Estimates of Low-Level Radiation Risks of Lung Cancer at Two NRC-Compliant Nuclear Instalations: Why Are the New Risk Estimates 20 to 200 Times the Old Official Estimates?. Irwin D J Bross and Deborah L Driscoll. The Yale Journal of Biology and Medicine 54(1981), p317.

[31] Direct Estimates of Low-Level Radiation Risks of Lung Cancer at Two NRC-Compliant Nuclear Instalations: Why Are the New Risk Estimates 20 to 200 Times the Old Official Estimates?. Irwin D J Bross and Deborah L Driscoll. The Yale Journal of Biology and Medicine 54(1981), p324.

[32] Health Consequences of Exposures to Ionizing Radiation from External and Internal sources: Challenges to Radiation Protection Standards and Biomedical Research. Rudi H Nussbaum and Wolfgang Kohnlein, Medicine & Global Survival, December 1995. Vol 2 No 4, p211.

[33] Direct Estimates of Low-Level Radiation Risks of Lung Cancer at Two NRC-Compliant Nuclear Instalations: Why Are the New Risk Estimates 20 to 200 Times the Old Official Estimates?. Irwin D J Bross and Deborah L Driscoll. The Yale Journal of Biology and Medicine 54(1981), p324.

[34] Reduced radio-Biological Effectiveness at Low-Rate, Low-Dose Exposures [DREF]: An Unwarranted Conjecture. W Kohlein & R Nussbaum. p6.

[35] Reduced radio-Biological Effectiveness at Low-Rate, Low-Dose Exposures [DREF]: An Unwarranted Conjecture. W Kohlein & R Nussbaum. p9.

[36] Reduced radio-Biological Effectiveness at Low-Rate, Low-Dose Exposures [DREF]: An Unwarranted Conjecture. W Kohlein & R Nussbaum. p10.

[37] Australian Peace Committee, Submission 7. p1.

[38] Australian Radiation Laboratories. Submission80, p2.

[39]

[40] Australian Radiation Laboratories. Response to Jabiluka EIS. 1997.

[41] Dr K Lokan. Australian Radiation Laboratories. Committee Hansard. p1076.

[42] Australian Liquor, Hospitality and Miscellaneous Workers Union. Submission 82. Appendix.

[43] Australian Liquor, Hospitality and Miscellaneous Workers Union. Submission 82. Appendix.

[44] Dr K Lokan. Australian Radiation Laboratories. Committee Hansard. p1078.

[45] Occupational Health and Safety in Uranium Mining and Milling - Comments on Submissions in Regard to Occupational Health and Safety. Dr J Leigh. p6.

[46] Greenpeace. Submission 73a. p10.

[47] A Career Dose Limit for Underground Uranium Miners. R M Fry & M W Carter, attached to Australian Liquor, Hospitality and Miscellaneous Workers Union. Submission 82.

[48] Australian Liquor, Hospitality and Miscellaneous Workers Union. Submission 82. p2-3.

 

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