Do We Want or Need Tougher Regulation?

[Chris Davey <chris.davey@cancerboard.ab.ca>]

Hello all:

I believe the members of RadSafe might be interested in the situation here
in Canada.

The current regulations (under the Atomic Energy Control Board) have
resulted in a very safe Canada, from a radioactive perspective.  There
is no real problem, and the AECB has admitted this in writing.

Despite this, the AECB is in the process of reinventing itself as the
Canadian Nuclear Safety Commission, and in the process, going to ICRP
60 limits, and increasing the regulatory burden from thirty or forty
pages to hundreds of pages of incredibly confusing, complex,
over-the-top, over-killing, unnecessary regs.  The new, proposed
regulations are more than six times as voluminous, much more complex
and confusing, and will add a huge burden of extra work to all in
fields where radioactive materials and or nuclear facilities are used,
diverting funds from areas where real benefits could (and presently
are) realized.

I have been writing in comments/complaints for the past three years,
since these new regs were first proposed, and have just discovered
that, despite claims from the AECB that all comments have been
addressed in their response document, 26 of my 46 comments were
ignored.  When I phoned in to express my concern about this (in a
previous life I was an AECB inspector, and know many of the AECB staff
quite well) the response was surprise.  I indicated I would re-submit
my 'lost' comments, but I can't help wonder how many other comments
were 'lost' in the system.  If any of you sent in comments, please
take the time to check the AECB Response document to see if your
comments were missed, or misunderstood.

My solution (which I have already suggested to the AECB, and had
rejected!) is to dump the new regulations and continue as we are.  

If such a thing were to happen, and Canada turned away from the
implementation of ICRP 60, it would certainly be an object lesson for
the world...

The AECB web site is: 

http://www.aecb-ccea.gc.ca/menu_e.htm

You can find the proposed regulations, the Response document, and lots
of other relevant documents there.

Regards,

Chris Davey

-- 
RSO / LSO Cross Cancer Institute 11560 University Avenue
Edmonton Alberta Canada T6G 1Z2
(780) 432-8616 fax 432-8615
email: cdavey@med.phys.ualberta.ca     chris.davey@cancerboard.ab.ca
pager number 005, just call (780) 432-8771 and ask for that pager
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