1. South Australia’s Environment Protection Authority
Regulating radiation at levels where
no harmful effect is observed
Keith Baldry
Director Regulation and Compliance
October 2010

2. The standard regulatory approach
DosesCompliance
Good
Poor
Optimised
Not optimised

3. Risks and models
risk
dose
risk
dose
risk
dose

4. Risks and models
UNSCEAR 2008, Sources and effects of ionizing radiation
Monitored Workers Average Effective dose (mSv)
Mining 12000 1.9
Milling 3000 1.1
Enrichment 18000 0.1
Fuel Fabrication 20000 1.6
Reactor Operation 437000 1.0
Reprocessing 76000 0.9
Research 90000 0.4
Aircrew 900 3.0
Nuclear Fuel Cycle 660 1.0
Medical Uses 7440 0.5
Industrial Uses 869 0.3
Military Activity 331 0.1
Natural Radiation 13050 2.9
Average 0.8

5. Risks and models
risk
dose
risk
dose
risk
dose
Low dose = Low risk
and this is where we mostly regulate

6. What do we get in practice?
Risk
Low
High
Business
impact
Burdened
Public
concern
Reassured
Outraged
Supported

7. Regulatory burden
• UNSCEAR data shows that in all sectors in almost all countries the
majority of occupational exposures are less than 1 millisievert
• How many non‐radiological hazards have entire branches devoted
to regulating them?
• Every regulatory clause and guidance note written and then read
by thousands; every report written and read; every dosemeter
issued to every individual with an annual dose of less than a
millisievert: someone pays for these things.
• A nuclear power plant costs a bazillion dollars to build*
* $8bn rather than $2bn [Brook, Switkowski 18/10/10]

9. What’s wrong with being conservative?
Letter to the Editor

10. Community outrage

11. ‘No-one can tell you that this is safe’
‘Sir William Stewart, head of
the NRPB and the Health
Protection Agency,
recommends “a precautionary
approach to the use of mobile
phone technologies be
adopted…” ’

12. Community outrage
• Attitudes can take a generation
to change
• If we do not change public
attitudes now, we will be in the
same place in a generation

13. Government confidence
• It doesn’t matter how
technically correct the
solution is
• Government decisions
depend on confidence
• Railing against the
government for indecision
is of no value

14. It’s ALARA’s fault
• We are fixated on the three principles
• It is an excuse to avoid prioritisation of risks
• It drives the wrong behaviour
• It sends the wrong messages
• Nobody (except us) understands it or values it

15. OK, so what
• International standards are not going to change in any
way that will help in the short to medium term
• However: we can use LNT effectively now, by properly
appreciating that a low dose = a low risk
• With that appreciation, we can look around and see what
might be more worthwhile

16. Identifying value
• In any given situation, regulating ALARA is probably not
the most valuable thing
• Value is not determined by the seller, it is determined by
the buyer
• The questions are: what are the more important things,
and how does this change the regulatory approach
• Also: what do we do with the unintended by‐products of
dose optimisation?

17. Identifying value
Stakeholder Value
Public
Workers
Patients
Licensee
Government
Science community

18. Turning values into a purpose
Science
Influential
Ignored
Workers
Trusting
Distrust
Public
Reassured
Outraged
Government
Confident
Nervous
mSv
Low
High
Patients
Well
Sick
Business
Supported
Burdened

19. Turning public outrage into reassurance

• Reduce doses
• More compliance

• Increase transparency
• Be honest
• Demonstrate control, be authoritative
• If it’s safe, say so*
• Address the community directly (may
require expertise in being able to talk
to people)
* Using the word ‘safe’

20. Turning business burden into support

• Fit in with existing systems
• If the dose is below regulatory interest, don’t be interested*
• Use the right tools
• Aim for outcome based regulation
• Mandate the minimum and encourage best practice
• National uniformity
*Really, don’t be interested

21. 
• Sound policy work
• Iconic achievements
• Public reassurance = government confidence
Gaining government confidence

22. Making the
science influential

• Advocacy
• Relationships

• Transparency
– e.g. a national dose database
Gaining workers’
trust

23. Reducing the radiation risk

• Prioritise the significant risks
• You can have a regulatory de facto threshold, even if you
don’t have a risk threshold
• Get in at the front end

24. Outcome based regulation
• At ARPS 2006, I proposed that the outcome we sought was:
maximum millisieverts measured and saved
• A question that always bothered me was: if you’ve spent a
lifetime regulating and saving millisieverts, what if you then
found out that it’s not bad for you?
• The answer is: we need outcomes, just more important ones

25. Measuring outcomes
• Assurance
• Reassurance
• Confidence
• Advice
• Business certainty
• Fairness
• Relationships
• Dose optimisation

26. Capabilities required for effective
regulation
• Policy
• Communication
• Community engagement
• Political networking
• Understanding of regulatory best practice
• Effective tools
• …and some radiation protection

27. A purpose in life
In regulating low doses, where there is a benefit, there are
often many things that are more important than a
theoretical, relative risk reduction so small it can never be
detected.
People‐related things are more important, the things that
affect people and concern them much more than
compliance or radiation doses.
The regulator should find out what these things are. This
gives the regulator a purpose in life.