CHAIR —Do you wish to make an opening statement?

Dr Lokan —Yes, Mr Chairman; I would like to. I would not bother to go through our submission; however, I would like to read a brief statement entitled `Changes to international and Australian radiation protection recommendations'. What stimulated me to do this is that one of the other submissions which I have seen gave a somewhat distorted view of the way in which we have developed Australia's radiation protection standards and I would like to correct that. It is about a page and a half and I have provided a copy to the secretary.

Towards the end of the 1980s it became apparent, following from the study of Japanese A-bomb survivors, that the risk of delayed effects, usually cancer, from radiation exposure were greater than had been thought previously. This came about for two reasons. Firstly, a careful and thorough re-evaluation of the radiation exposures indicated that they had been overestimated by about a factor of two. In addition, with the addition of further years of medical data as the exposed population aged, the emerging number of cancers exceeded earlier projections by about 50 per cent. Taken together, these factors implied that the risk for a given dose is about three times greater than had been previously assessed.

The International Commission on Radiological Protection accordingly developed revised recommendations which were circulated for comment in draft form in 1989, modified accordingly, and published in 1991 as document ICRP 60. The Radiation Health Committee of the National Health and Medical Research Council then undertook the development of revised Australian recommendations based on ICRP 60, culminating in a document that was the seventh draft to have been issued for public comment during 1994. The final version, which took into account public comment, was adopted by the National Occupational Health and Safety Commission and NHMRC, respectively, in April and June 1995.

In parallel, ARL--that is, our laboratory--was active in WHO, ILO and IAEA committees which, using ICRP 60, developed the basic safety standards, casting ICRP doctrine into a form that was more directly applicable in a regulatory environment. Australia's recommendations are consistent with the basic safety standards and in almost all areas reflect the spirit and intent of ICRP.

With respect to dose limits, ICRP recommended a limit of 20 millisievert per year, averaged over any five years, for occupational exposure and not more than 50 millisievert in any one year; this was down from their previous value of 50 millisievert per year. The notion of averaging over time was in recognition of the fact that, at these low doses and dose rates, the health impact depended only on the total dose and not on the way in which it is distributed in time. The period of five years entered the picture because this was considered a reasonable time to require employers to maintain accurate and complete records of employee exposure.

An important departure in ICRP philosophy was the identification that the limit of 20 millisievert per year represented a threshold of intolerability. At this level the risk of detriment in the future, per year of exposure, after a working lifetime, averages out at about one chance in 1,300--a level which would not generally be tolerated by our society if it were exceeded. Previously ICRP in 1977 had argued that their lower risk factor at that time, and a requirement to keep doses as low as reasonably achievable, meant that in practice occupational radiation risks were about one in 10,000 per year and comparable with other safe industries. That was very much a watershed shift in philosophical position.

The points of difference between our recommendations and ICRP are: firstly, a more realistic recommendation regarding exposure of the foetus, once a woman employee notifies her employer that she is pregnant. Rather than a limit of two millisievert at the surface of the abdomen, which ICRP proposed, we have used more general words saying that the foetus should be afforded the same protection as members of the public. This allows the regulator to assess the importance of internal exposures from radioactive materials rather than only external exposure.

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.

In recent years--that is, since ICRP 60--the ICRP has adopted a new psychologically based lung model and revised metabolic models which have resulted in changes to dose conversion factors for internal contamination. In a series of publications, ICRP has given new factors for occupational exposure and age dependent factors for exposure to members of the public. These have been incorporated in the BSS--that is, the basic safety standards. Recommendations and guidelines of the Radiation Health Committee and nuclear codes will incorporate these new factors as they are revised.

CHAIR —Thank you very much for that statement and the additional information you have provided. It is probably opportune to pick up from that reference to a number of the submissions that have been put to the committee expressing the opinion that there is no really safe level of radiation. I am wondering what ARL's view is on that proposition.

Dr Lokan —We would share the opinion of ICRP and the international agencies that that 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'.

CHAIR —In effect, some are safer than others? Is that what you are saying?

Dr Lokan —I guess it is fair to say that nearly all human activities carry some degree of adverse impact. For example, using motor transport is one such thing. It is a function of our society that we have to set rules, set speed limits and work out ways in which we can take advantage of the use of transport. In much the same way, we have to set rules which limit the risk of radiation to socially acceptable levels.

CHAIR —Given that maximum permissible levels have been dropping throughout the postwar period, is there any reason to expect that the most recent limits that have been established will not drop further?

Dr Lokan —My opinion would be that they will not drop further. At the present time the natural environment delivers annually to all of us about two millisievert per year. We also on average in our population receive about one more millisievert per year from our use of radiation for diagnostic purposes in medicine. The public exposure limit is currently one millisievert per year, and the occupational exposure limit is already at 20 millisievert per year, with the added concept that it is not sufficient for an operation to merely meet that limit. For as long as it is economically sensible in terms of saving future adverse effects, the operator is obligated to invest further to reduce exposures to as low as is reasonable, taking into account the economic and social factors.

CHAIR —Greenpeace has claimed in its submission that Australian regulators did not respond in a timely or proper fashion to the ICRP recommendations of 1990. What processes were involved in Australia's adoption of the ICRP recommended levels, who was involved and why did it take five years?

Dr Lokan —Yes, I was tempted to add another paragraph. You need to understand that in our federation processes like this, the development of new standards, can only proceed at a pace in which they can be developed in a consensual way by all the players. In this case, we produced a first draft document after the publication by ICRP of its recommendations. We circulated that draft amongst all of the aficionados. We went through seven drafts at various times exposing it to interested parties and, ultimately, issuing it for public comment in year four.

By the time we received the public comment, absorbed the public comment, changed it accordingly and took it back to the Radiation Health Committee, we had covered 4 1/2 years. Then it took another half a year for it to go through the formal processes of adoption by the Occupational Health and Safety Commission and the National Health and Medical Research Council.

If not the first, we are among the first countries in the world to have adopted the new recommendations. As a matter of interest, the European Community succeeded in getting through their more complicated system--after all, they have 13 autonomous states that have to be guided towards some sort of consensus. They have produced something which is really much more restricted than ICRP 60, which they achieved in May of last year. We completed ours one year earlier.

Most countries now are contemplating the adoption of new standards, and more than likely many will take advantage of the basic safety standards produced jointly by the International Atomic Energy Agency, International Labour Organisation, World Health Organisation and Food and Agriculture Organisation because they are tailor-made for adoption as regulatory instruments.

CHAIR —So to some degree the time frame was due to the extent of the consultations undertaken?

Dr Lokan —Yes. Also, in our view it was quite important to be players in the international game because we wanted to make our input and we wanted to ensure that we were synchronised with the way that the rest of the world was going. That in fact did not cause a delay, though the basic safety standards emerged in final form a year after we had promulgated our standard. But we had a very good idea of what was going to be in there a year earlier.

CHAIR —It could well be reasonable to conclude that those who criticised you for the time taken would also have been critical had not the consultation been undertaken?

Dr Lokan —Yes.

CHAIR —Were mining companies involved in the lead-up to the adoption of those new standards, and if so in what way?

Dr Lokan —Very much so. The conduit in that case was a reference committee, appointed by the National Occupational Health and Safety Commission, made up of union and mining representatives. Everything that was done as the drafts progressed was formally passed to that reference committee through the National Occupational Health and Safety Commission. In addition, it is fair to say that most of the potential players received informally those drafts directly from our committee.

CHAIR —Page 13, part B, of the Greenpeace submission says that it is particularly worrisome that the NHMRC is so prepared to subvert the ICRP recommendations. Can you comment on this claim?

Dr Lokan —I think I had explained that in my opening statement. It was considered in the Australian context by all of the regulators--and remember that the regulators are in every case state radiation control branches in health departments or territory regulators in the ACT and the Northern Territory--and they were fairly firm in the view that there needed to remain an element of flexibility in the system to allow them the judgment to take into account extraordinary circumstances. That is why we included that clause. Incidentally, the basic safety standards picked that up from us and included it in the international doctrine, for the same reason of it being desirable to have some degree of judgmental flexibility left to the regulators.

CHAIR —What is the structure and size of ARL and how many professional staff do you employ?

Dr Lokan —That number has just changed downwards somewhat. At the present time we have a staff of 73. I have not got exact numbers, but I guess it is 30 professionals, 30 technicians and a dozen or so infrastructure support--storemen, cleaners, personnel, general administration. That is our size. Our charter is, in general, to oversee from a federal government perspective the way in which radiation is deployed--both ionising radiation and non-ionising radiation, uranium mining and every other activity involving radiation--and to ensure that Australians are well protected.

CHAIR —In monetary terms, what is the size of your budget and what are your sources of revenue? How much comes from the federal government budget? How much do you raise from fees or charges?

Dr Lokan —The cost of our building is about three-quarters of a million dollars per year rent to finance. But, from our perspective, they give us a cheque and we dole it back to them in monthly instalments. Beyond that, our budget is about $5.3 million a year--$3.3 million of which is salaries and the remainder is operating expenses. Our earnings in fact are the $2 million for operating expenses.

We earn income from a variety of sources. The biggest single source is the provision of a national personal radiation monitoring service which generates perhaps three-quarters of it. The remainder comes from a lot of other smaller consultancies, advice, environmental measurements both in ionising and non-ionising areas. Currently we are spending a lot of time around the country measuring radiation fields around cellular telephone transmitting towers, for example. I guess that covers it in general.

CHAIR —Do you contract out any research work?

Dr Lokan —No. In fact our research work, if anything, has been fairly sharply attenuated in the last several years by virtue of the fact that there is more and more public awareness of radiation issues. One has to address them and, in times of constraint, the first thing that suffers is the resources available for other things which are not so time driven as responding to public concerns.

CHAIR —Does that diminution of research effort in any way threaten our capacity to maintain proper standards?

Dr Lokan —In the long run it could. At present, I would say that we are living on the legacy of the last 15 years of competent research with a large enough corporate collective memory to use our previous experience. But it is certainly true that it is becoming tougher.

Senator MARGETTS —I read with interest the comments by the Australian Radiation Laboratory on the draft environmental impact statement in relation to Jabiluka. In that statement it indicated that ERA's predictions of radiation doses to workers at the proposed Jabiluka mine may underestimate doses by a factor of two and that, as a result, some workers may be exposed to doses in excess of agreed international limits. The Minister for the Environment indicated that the problems with the environmental impact statement are methodological. Would you agree that the problems are simply methodological?

Dr Lokan —Yes. The position we took in our submission was that in the long run we do not really believe that there will be difficulties in operating that Jabiluka mine in terms of Australian radiation protection standards. It may be and probably will be more complicated and more difficult than Olympic Dam. The problem we faced was that the submission from the company did not provide enough detail for us to independently assess properly whether or not that was the case. We believe it will be the case, and there are many mines of similar or higher ore grade which are functioning perfectly satisfactorily in various parts of the world. It is just that, in our judgment, they had not really demonstrated to us, and perhaps to other commentators, that that was the case. There may be more that they will need to do.

Senator MARGETTS —In similar situations in other parts of the world where there is an underground source of a similar ore grade--that is, the intensity of radiation--what methods have they implemented to reduce the levels of radon so that it is well within the limits rather than battering at the limits?

Dr Lokan —Radon is normally readily controllable through the right sort of adequate ventilation. I think that is well understood. It seemed from the Jabiluka draft EIS as though radon was seen to be a not particularly significant problem. However, we felt that, particularly given the experience at Olympic Dam, if one recognised the contribution of radon to the problems at Olympic Dam, the scaling of ore grades from Olympic Dam to Jabiluka suggested that there would be a corresponding increase in the radon problem because of the increase in ore grade.

We could not find the arguments which allowed them to argue that the main problem was an external exposure problem. We would want to see more information from them on that and on other aspects as well--on other pathways of radiation exposure. The problem is the detail is not in their submission. Without that detail, one cannot really check it. The instinct we have is that the problems ought to scale, more or less, with ore grade.

Senator MARGETTS —What problems at Olympic Dam are you referring to?

Dr Lokan —I do not believe there are problems at Olympic Dam.

Senator MARGETTS —Sorry, I am just using your words. You said because of the `problems at Olympic Dam'.

Dr Lokan —At Olympic Dam it is around about equal contributions from external exposure--that is, gamma rays coming into the body--and inhalation of dust and inhalation of aerosols to which radon daughters are attached. They each contribute about an equal component.

It is easy to understand why the external exposure in Jabiluka would be a good deal higher, because the ore grade is higher. It is not so easy to understand, because they have not told us, what they are doing which will not mean that the other components will increase in a similar sort of way.

Senator MARGETTS —Would you envisage making the ALARA principle involve the use of robotics or rotation of workers if they were to address the problem of radon?

Dr Lokan —It remains to be seen whether radon really is a problem. Often radon is controlled just by adequately managed ventilation. I would not necessarily accept your point that radon is the main problem. I am sorry, I forgot your question.

Senator MARGETTS —Would you envisage some of the solutions involving the use of robotics or rotation of workers?

Dr Lokan —Possibly not. It may involve the use of better shielding on underground mechanised equipment to shield the workers. 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. It is better to find a properly engineered solution.

Senator MARGETTS —Do you have any understanding of what increased costs might be involved with improved ventilation and the engineering of such a thing?

Dr Lokan —No, I do not. I do not see that as being a problem. One has to do what one has to do to achieve good practice.

Senator MARGETTS —You have indicated that you do not think the radiation dose limits for members of the public and workers will come out any further in coming years. I guess that, if we were to ask people 20 years ago, they might have said a similar thing?

Dr Lokan —Yes, but, as I indicated, the irreducible background and medical uses are already not trivial compared with occupational exposures.

Senator MARGETTS —Perhaps the argument might be that we are discriminating by saying in a particular instance that the levels are unacceptable for the public up to a certain level but for workers to a considerably higher level by a factor of 20. There does not seem to be any logic in saying that someone can take a risk 20 times higher if we pay them than if we do not pay them.

Dr Lokan —I guess there is not an argument in there which says, `We'll be paying you to take risks.' For example, in regular hard rock mining the risk of fatalities is not very different from the calculated risk from radiation exposure at the occupational exposure limit of the order of one in 1,300 per year. No-one is arguing that conventional hard rock miners are simply being paid to take risks; they are paid to do a job, and it is incumbent upon employers and society to do the best we can to minimise that risk.

Senator MARGETTS —I have asked Western Mining Corporation why, even for designated workers, the use of TLD badges is optional. Do you have any insight as to why that might be the case?

Dr Lokan —It an acceptable thing to do where the exposures of the workers are securely predictable and wearing a badge does not really contribute to one's knowledge of the exposure that those workers are going to get. Provided that one has a good regime for measuring environmental exposure levels to demonstrate that these exposures are quite stable, then that is philosophically and practically an acceptable proposition.

I can give you another example in another area. The exposures of air crew who spend, say, 1,500 hours per year flying at altitude over Australia is such that they receive approximately three millisievert per year of occupational exposure. We do not need to put badges on them to work out what those exposures are. We can calculate it. In fact, we have confirmed with badges the calculation that they will get their three millisievert if they are working their 1,500 hours, just from a knowledge of the time spent in the air and the known dose rates at the altitudes at which they fly. That would be a case where a badge would add no information beyond what one could establish through other measurements.

Senator MARGETTS —I would hasten to suggest that the potential anomalies with any uranium mine might be greater than within an aircraft.

Dr Lokan —I took that as an extreme example of a good case where one would not bother with a badge. For people who are working underground and moving around with changing tasks and in changing radiation fields, the badge is by far the best way of assessing it.

Senator MARGETTS —That gives them some sort of individual record, does it not, of their own exposure levels?

Dr Lokan —There is still an obligation to provide an individual assessment, whether it is done through occupancy and a knowledge of the dose rate or done by wearing a badge.

Senator MARGETTS —Yes, but people can probably have more confidence in that measurement if it is taken from their individual reading.

Dr Lokan —Maybe, but there is no need for them to have more confidence if the other method is satisfactory.

Senator MARGETTS —If it is, yes. You have had some disagreement with the operators of Olympic Dam in relation to radiation. Could you detail what the basis of that disagreement has been?

Dr Lokan —I am not aware of what you are referring to.

Senator MARGETTS —It was indicated to us that there has been a disagreement in relation to the measurement--how you relate one level of radiation to another.

Dr Lokan —It is not a disagreement with Western Mining Corporation. It is something which we have indicated in our submission. In fact, I have brought a copy of a fairly recent paper in which staff from the laboratory have published a result. The issue comes down to how one converts radon daughter exposures to radiation doses.

Historically, it has always been the view of ICRP, based on theoretical modelling, that one working level month is equivalent to 10 millisievert of exposure. In recent times, ICRP has homed in on the anomaly that, when one looks at the epidemiological data--that is, the lung cancer incidence--in historical mines, the actual number of cancers observed is smaller than would be indicated by using that conversion factor. So they have suggested that it is probably more correct to use the epidemiological answer, based on human experience, which leads to five millisievert per working level month.

We have been addressing the difference between modern mines, like Roxby Downs, and mines in the past--classical uranium mines that did not enjoy the same sort of ventilation control, dust management, aerosol management and so on. Therefore, in modern mines, in a sense, the air is cleaner. If the air is cleaner, it turns out that there are more of the radon daughters which do not attach themselves to aerosols and which, therefore, produce a bigger dose per atom, which is inhaled.

So the anomaly is that, by having a cleaner environment, the dose per unit of intake per exposure may be higher. Whereas all of the epidemiological data is based on old-fashioned mines, the modern mines might need a number more like eight millisievert per working level month, rather than the five--which is based on old epidemiological data. Doses therefore may be underestimated, if one uses that five millisievert per working level month.

We have drawn attention to that in our submission. That is also one of the things we pointed out in our Jabiluka comments--that possibility requiring a more subtle sort of measurement of the properties of the radon daughters in the working environment than traditionally is done.

Senator MARGETTS —So that may be one means by which doses perhaps are being underestimated?

Dr Lokan —I am not certain. But until fairly recently at least, Western Mining Corporation were using 10 millisievert per working level month, not the reduced figure. It is true, however, that the Jabiluka draft EIS does use that lower does per working level month. We have proposed that they should address that.

Senator REYNOLDS —I am sorry I missed your opening comments, but I am also in another hearing next door. How does Australia compare with other OECD countries in regard to monitoring occupational health and safety issues related to radiation?

Dr Lokan —I cannot speak for general occupational health and safety issues. But I would assert fairly confidently that our degree of regulatory control and oversight of uranium mining and the mineral sands industry would match that of any other country that I am aware of and be better than most.

I do not know how I can defend that in quantitative terms or by reference. But certainly I am aware of the structures we have in place to develop radiation protection codes of practice. They are the administrative structures with state regulatory control and this method where, through the Environment Protection (Nuclear Codes) Act, we develop quite extensive national guidance. Unquestionably, that is practised throughout the uranium mining and mineral sands industries in this country.

Senator REYNOLDS —But how do we know it is actually practised, because the Commonwealth really has no specific regulatory power?

Dr Lokan —We have very good networks with the state regulators, however, and we do see data.

Senator REYNOLDS —Networks, but nothing specific. How does that compare with other OECD countries?

Dr Lokan —Frankly, I do not believe that would make much difference. There are plenty of regulators in Australia. In fact, there is only a limited number of states where uranium mining or mineral sands industries exist. We have pretty good connections with those regulators and we have been party to the development of the codes of practice which govern their regulations.

Senator REYNOLDS —Would you not agree that it is one thing to have a code of practice--and it is better to have that than nothing--but, when we are reliant on state governments, and perhaps you have more faith in state governments than I have, where there is not that national oversight and quite specific monitoring process and a specific regulatory authority on the part of the Commonwealth, it is a much more ad hoc approach?

Dr Lokan —Let me just remind you that the Northern Territory administration has adopted the national code of practice for radiation protection in mining and milling as regulations. The South Australian government have modelled their regulations on the same code of practice, and so too has Western Australia. I cannot be so clear about Queensland. Their position is that they have not formally adopted that code of practice, but they operate within its spirit and similar schedules for radiation exposure. I should admit that it will be 1998, I think, when we will have taken on board, in the uranium mining industry, the revised radiation protection standards. It will be a two-year task from now.

Senator REYNOLDS —But if you look at a submission from the Nuclear Safety Bureau, you will see that in their appendix A they actually detail legislation for mining and milling radioactive ores in OECD countries covering mining legislation, radiation protection and waste management. When you look at, just at random, Belgium, you see that they have three basic acts covering radiation protection. These cover compliance powers within the acts, the protection of public and workers, and safety at work. Australia, as a nation, hasn't anything of that kind.

Dr Lokan —I might argue that it has eight acts.

Senator REYNOLDS —Do you think there is adequate monitoring? You would argue that there is adequate monitoring to ensure compliance with the National Health and Medical Research Council and Worksafe Australia recommended occupational dose limits? You would say that the code of practice is adequate?

Dr Lokan —And our knowledge of the way in which each state operates it. We do see reports which are delivered to each state regulator by operators and we are aware of the degree of inspection which is exercised by state and territory regulatory organisations.

Senator REYNOLDS —Do you understand why the industry would not be prepared to support a register of uranium workers?

Dr Lokan —I have never heard that. No-one has ever said it to us.

Senator REYNOLDS —It is contained in a submission on behalf of a union that represents workers. Do you think it is a good idea to have a register of workers?

Dr Lokan —Yes.

Senator REYNOLDS —It has been claimed that any further expansion of the uranium industry should be accompanied by the researching of adequate monitoring of occupational health and safety issues. Do you think we need more research or do you have more faith in the codes of practice regime than some of us have?

Dr Lokan —I am not quite certain that I know what you mean by `research'. Do you mean scientific research--

Senator REYNOLDS —Yes.

Dr Lokan —Or research in the way in which other administrations do it?

Senator REYNOLDS —The concern of this committee at the moment is the health and occupational safety of workers in the uranium industry. I mean research about anything that is of concern relating to workers' health and safety.

Dr Lokan —At least radiation health and safety is all that I am competent to comment on. I think you will find in our submission a fairly substantial list of research studies we have undertaken which underpin Australian recommendations. In fact, the discussion that I just had with Senator Margetts about five millisieverts or 10 millisieverts--or where in between--per working level month comes straight out of a piece of scientific experimental research, carried out, by the way, at Olympic Dam in collaboration with the company.

Senator REYNOLDS —Would you not agree that it would be more efficient to have a national authority charged with ensuring compliance with limits and the control of exposure instead of relying on eight individual states and territories?

Dr Lokan —You are making a comment on Australian federalism, but yes, I would agree.

Senator REYNOLDS —In a perfect world?

Dr Lokan —I think it is even possible to contemplate doing it in this imperfect world.

Senator REYNOLDS —Thank you very much.

Senator BISHOP —Turning to your submission, at page 5 you make reference to the National Radiation Dose Registry. Do you advocate the extension of that registry to what might be described as clerical and administration workers who work at or around mine sites but who are not immediately part of the mining or milling process? Should the maintenance of that registry be compulsory for all workers employed at relevant mine sites or milling sites?

Dr Lokan —It is quite a complex question, isn't it?

Senator BISHOP —Yes, it is.

Dr Lokan —Clearly anyone who is likely to be a designated worker and, therefore, potentially exposed to varying and substantial levels needs to be monitored and ideally their lifetime accumulation of dose needs to be maintained. The question of whether it needs to go down to workers who are not radiation workers but who happen to be working on the property--

Senator BISHOP —In particular at Ranger, where they drew a distinction between the mining and milling workers and those involved in a clerical capacity some hundreds of yards away--

Dr Lokan —It depends, I would think, almost entirely on the potential for the latter group to receive any exposure. Do you want to comment on that, Peter?

Mr Burns —It is just that at the moment the National Radiation Dose Registry's focus is on external dose, which is much easier to keep a register of than the assessment of internal dose. The maintenance of those in a register is a much more difficult task, but it should be done as a complete record of doses for uranium miners in that most of their dose is coming from these sources.

You should not divide the work force and say, `These people are not getting very much dose so we will not keep their lifetime records,' because they might move to another occupation where they do get more dose. So you are really interested in anybody who is working in radiation to keep a lifetime record of their true doses so that their accumulative dose over their 30, 40 or 50 years of working time is recorded.

Dr Lokan —In a way, it is more important in the mining industry than elsewhere because miners do work in one mine and then go to another mine. That other mine may be in a different jurisdiction and it is then not easy to ensure a transfer of radiation exposure records from one employer to the next. It is, therefore, quite important that there should be a centralised registry which is keeping those accumulative totals.

Senator BISHOP —I understand that. On page 7 of your submission you advocate a review of the codes of practice in respect of the management of radioactive waste and the radiation protection code. They have not been done for 14 and nine years respectively. Are they out of date or behind international best practice? What is their area of deficiency that warrants their review, apart from the passage of time?

Dr Lokan —It is the fact that we have had since 1995 a new set of radiation exposure limits and the present code of practice--the radiation protection code, for instance--is out of date to the extent that it is still using pre-1990 dose limits. There is the fact, too, that we now have substantial real operating experience, which we did not have in 1980 when the first radiation protection code was developed. The 1987 one took into account the practicalities of uranium mining and the way it was really done, and therefore it was a better code. But it was still based on the current radiation protection standards.

The milling code--the management of radioactive waste--in some measure is a longer term problem and has not really governed activities in the mining and milling so much because the mill waste is still being accumulated. In the end it has to be managed satisfactorily, but it has not been a pressing and urgent problem--aspects of it have been, but in the main it is a continuing long-term issue which at the end there has to be a solution to.

Senator BISHOP —If the industry were to expand into a large number of mines around this country, the management of tailings would become a more pressing problem as those mines are exhausted, would it not?

Dr Lokan —Yes. The problem ultimately is the reliable, safe disposal of the tailings that have accumulated during the life of the mill. We recognise that the present waste management code, which takes the view that it has to establish principles and then at each location details are worked out on a case by case basis, is not actually all that useful and we will have to develop a lot more doctrine. The transport code, by the way, is in pretty good shape.

Mr Westall —With regard to the transport code of practice promulgated under the nuclear codes act, the Nuclear Safety Bureau has the Australian delegate to the IEA Transac Committee, which is the international committee for developing the IEA transport regulations. They are adopted throughout the world. They are in the process of being revised and are perhaps very close to being issued as revised regulations. Australia, it would be expected, would adopt those revised regulations, as it has adopted the previous regulations of the IEA, and they would be adopted as a code of practice under the nuclear codes act. So one of the activities of the nuclear codes committee, the Commonwealth-state consultative committee which is reviewing the nuclear codes, will be to adopt those revised transport codes.

Senator BISHOP —At page 10, point No. 6, in your recommendations you say:

The assessment of external radiation dose by use of an external radiation monitoring device is a well proven technique and should provide reliable estimates . . .

Why do you use the verb `should' and not `will'? Is there a doubt about its accuracy?

Dr Lokan —There is no doubt about the radiation that is measured by a badge. The doubts creep in--of course, in an ideal society it does not happen--when the person responsible for radiation safety does not ensure that the badge is being worn by the employee. You cannot guarantee--as an organisation you are issuing a badge with the worker's name on it so that it is easy to put it into a dose registry and you know who wears it--the process that the badge that Jim Smith is supposed to be wearing has not been put onto Joe Blow. There are little deficiencies like that. So it is really just a caution--and nothing is perfect.

Mr Burns —There are cases from time to time of people deliberately exposing badges, either as practical jokes on their workmates or on their own behalf, to record significant radiation doses.

Dr Lokan —Or to test the system.

Mr Burns —All sorts of things happen.

Dr Lokan —There was one individual at Roxby Downs, at the Olympic Dam mine, who was summarily fired because he tampered with his badge. He opened his badge and put a little note in there that came back to us. The note actually identified him. We reported it to the company and that was the end of him. It is perhaps not my place to say, but I have considerable respect for the quality of the Olympic Dam operations in the way in which they have managed radiation safety over the years. They are quite dedicated. They take it seriously. It is not something that they go through because they have to. They genuinely believe in it and do it quite well.

Senator BISHOP —Are we doing questions on nuclear safety?

CHAIR —No.

Senator BISHOP —On page 4 of the Nuclear Safety Bureau submission there is a reference to FINAS and the reporting of accidents, et cetera. Is that applicable to mine sites such as Olympic Dam and Ranger or is it only further down the chain?

Mr Diamond —No, it covers the whole of the fuel cycle. It is trying to copy what happens in the nuclear power industry where they have an incident reporting system. The incident reporting system for the nuclear power industry is accepted worldwide and they share information between plants through the combined NEA and IAEA. FINAS is something that the OECD has been trying to get up for the past four years. To date, it has not been that successful.

The last time we looked at it only about 63 incidents had been reported. Most of them came from the UK, France or Japan, and there was not one associated with uranium mining and milling. The only one that was vaguely associated was with the transport of new fuel which was an accident in the US--a fire. The industry would support the possibility that FINAS be adopted because it would help share information about incidents that occur around the world at other mines.

Senator BISHOP —Would you argue the same for tailings depots as opposed to--

Mr Diamond —Yes.

Senator BISHOP —Mine sites as well?

Mr Diamond —Yes.

Senator BISHOP —There is a reference in your document to Canada where it is illegal to abandon uranium mine sites. Do you recommend such a course of action in this country?

Mr Diamond —We believe that a mine should not be abandoned until the design criteria associated with the mine have been satisfied. There are design criteria set out in the nuclear codes at the moment. We would anticipate that until those design criteria are satisfied then the regulators should ensure that it is not abandoned.

Senator BISHOP —Do the design criteria encompass complete rehabilitation?

Mr Diamond —Yes.

Senator BISHOP —So as long as mine operators comply with the design criteria that would obviate the problem of mine abandonment?

Mr Diamond —Yes.

Senator BISHOP —And that has application currently in Australia?

Mr Diamond —I understand that the codes of practice for mining and milling set out guides on the final deposition of the wastes, the waste management practices and the long term is considered to commence when a path to the site is fully stabilised and it is rehabilitated to the design criteria.

CHAIR —I think further questions should be put on notice.

Senator MARGETTS —I have a question for the NSB, which can be taken on notice. In more than one submission we have had an indication of at least one incident that occurred at Olympic Dam in relation to a fairly serious anomaly with workers which involved substantial increases in radiation doses. When the workers were exposed, they lost their masks and were covered in yellowcake. My question is: firstly, is the Nuclear Safety Bureau advised in a timely fashion of any such anomalies; and, secondly, could you give us a report back of any particular anomalies of which you have been advised and what your response has been?

Mr Diamond —I think we can answer that question straightaway. The NSB has got no involvement in the mining industry whatsoever, so we would not be informed of any situation that occurred at Olympic Dam. Our legislation restricts us to the operation of ANSTO's reactors and other areas which the minister might define. We certainly have got no involvement in mining as such.

Dr Lokan —The most direct answer to that question would come from the South Australian Health Commission.

CHAIR —If there are no further questions, I thank each of you for appearing before the committee. In continuing our deliberations, if any issues arise, we would perhaps seek a response in writing. Is it the wish of the committee that submission Nos. 80 and 15 be incorporated in the transcript of evidence? There being no objection, it is so ordered.

[8.07 p.m.]

The documents read as follows--

[DOCUMENT OMITTED FROM DATABASE, SEE HARD COPY PAGES 1087-1225]