The British Columbia
Medical Association


(477 pages)




E.R. YOUNG, B.Sc., M.D.




Telephone (604) 736-5551

Brief Summary of Major Points:
Verbatim Excerpts from the 477 page report:

Clarification from the BCMA President



Delay of hazard recognition and consequent worker non-protection is an unfortunate but recurring theme in the Canadian regulatory and uranium industry history:


Uranium tailings will remain radioactive for hundreds of thousands of years, and will require such expensive long-term surveillance and maintenance by government and the local citizenry as to make statements about uranium mining providing revenue very misleading:

  • Misuse of uranium tailings has led to internal lung doses calculated to be 100 rems per year to the public.

  • Conservative calculations show that the public near uranium tailings will receive a 25 percent increase in lifetime radon daughter radiation.

  • Uranium tailings will have appreciable radioactivity for more than 100,000 years.

  • In Canada we now have approximately 100 million tons of radioactive tailings; this will eventually increase to about one billion tons by the year 2000.

  • There have been many uranium tailings disasters in Australia, Canada and the United States. even with the most modern ''state of the art'' tailings dams.

  • The present average allowable exposure to the public  [ of 0.02 WL of radon exposure ]  could result in 200-300 extra cases of lung cancer per 10,000 people per lifetime. In light of current knowledge, this might be considered tantamount to allowing an industrially induced and publicly sanctioned epidemic of cancer.

  • This present guideline of 0.02 WL must be immediately withdrawn and replaced with ''no exposure (above ambient levels) of any carcinogen permitted to the local public''.

  • Radon contamination of ground water may be a health risk in pincushion drilling typical of advanced exploration, yet under present AECB regulations, a couple of hundred drill holes can be made without obtaining a license. AECB admitted to having no scientific data to show this is safe; the regulation was based on an arbitrary administrative decision.

  • Radium-226  [ released from uranium tailings ]  is a superb producer of osteosarcoma  [ bone cancer ] .

  • In 1959 the ICRP recommended a maximum exposure of 3 picocuries per liter (pCi/l) of  [ dissolved ]  radium-226 to the public.

  • In 1968 Canada allowed a maximum permissible concentration of 100 picocuries per liter, with an objective of 10 picocuries per liter  [ of dissolved radium-226 ] .

  • Ontario has retained a maximum permissible concentration of 3 picocuries per liter  [ of dissolved radium-226 ] .

  • New ''recalculations'' of the ICRP recommend relaxing the radium-226 standard to 27 picocuries per liter (9 times the Ontario limit of 3 picocuries per liter).

    [ NOTE: Canada has since authorized this increase in permissible radium levels in drinking water.  ] 

  • Certain uranium mining companies in Ontario are discharging radium-contaminated effluents which exceed the standard of 3 picocuries per liter. With the relaxation of the standard to 27 this will no longer be  [ considered as ]  a technical or regulatory problem.

  • American standards are as usual more stringent than Canada's; in the U.S.A.,  [ dissolved ]  radium-226 plus radium-228 cannot exceed 5 picocuries per liter.

  • A U.S. Public Health Service study shows increased bone cancer in communities with 4.2 picocuries per liter of  [ dissolved ]  radium-226 in drinking water, as compared with communities having only 1 picocurie per liter.

  • The concept that a radium-226 limit for the public can be set ten times too high because the usual radium-226 levels will only be one-tenth of that, is as inane as setting a speed limit of 200 kilometers per hour in a school zone because most caring people will only drive at 20 km/hr anyway.

  • There are no standards for total radium-226 (dissolved and particulate); one wonders if that is because total radium-226 effluents range as high as 168 picocuries per liter.


The BCMA calls for an Emergency Task Force into tightening the present radiation standards. Review by the AECB or by its Committees is unacceptable; the Task Force should be under the Advisory Council on Occupational Health and Safety or the Science Council of Canada:

  • Industry and regulatory officials are overly eager to select conversion factors for dose calculations that are at the lower end of the spectrum of values proposed. This consequently leads to lower risk estimates of radiation effects. The fact that the calculations are subject to ''large unquantifiable uncertainty'' leaves one with little confidence in the conclusions of health risks made by nuclear physicists and former employees of Atomic Energy of Canada Limited, now associated with the Atomic Energy Control Board.

  • Canadian regulations lag far behind countries which are more conscious and concerned about occupational and public health and safety.

  • Canadians cannot continue to allow vested interest Ministries and regulatory bodies to promulgate maximum permissible exposure levels  [ of radiation ] .

  • The BCMA is on record as calling for a national enquiry into nuclear energy in Canada,  [ including ]  a total reassessment of the structure and function of the AECB; this resolution arose out of our investigations of nuclear waste management and uranium mining.

  • That the AECB consistently and seriously neglected its statutory responsibility for the regulation of uranium mines is obvious to the most casual observer.

  • We believe that the continued use of the ALARA principle,  [ unenforced ]  guidelines, and the encouragement of industrial self-regulation is a combination of objectives that will  [ continue to ]  compromise the effectiveness of the AECB as a regulator of uranium mining.



Dr. Wagoner well described the discovery of the relationship between lung cancer and radon daughters:

Hollywood, in his article on "The Epidemiology of Lung Cancer Among Workers Exposed to Radon and Radon Daughters" in May, 1979, noted:

Studies in the U.S. were undertaken in the 1950's on uranium miners in the Colorado Plateau area. These results began to appear in the early 60's, and they showed an increase in lung cancer with an increase in exposure to radon daughters. Dr. Wagoner noted that these studies had to be extended and refined to rule out any possible other agent:

[As noted by Dr. Wagoner, referring to the Colorado data]  , observed versus expected carcinoma of the lung cases in 1978 was 205 versus 40, with an attributable risk of 164 men

With the long latent period of carcinoma induction by low level radiation, these numbers will increase further over the next 20 years.

The submission of Dr. Wigle relating to the St. Lawrence (Newfoundland) fluorspar miners who were exposed to elevated levels of radon daughters demonstrated an observed incidence of lung cancer of 65 versus an expected 6.41, with an average ratio of observed to expected of 10.1 . Dr. Radford noted that the ongoing studies, such as the one of the Newfoundland fluorspar miners,

The collection of the Canadian   [uranium mining]   data began in 1974. The Royal Commission on Health and Safety in Mines in Ontario   [the Ham Commission]   commissioned an epidemiological study of the uranium miners in the Elliot Lake area; this was conducted from 1975 to 1976. Dr. Muller noted that

The Ham Commission analyzed the data   [81 observed lung cancer deaths versus 45.08 expected]   in order to determine whether radon daughters were the agent:

In his analysis of the Ontario data, Ellett stated:

According to the United Steelworkers of America, the number of lung cancer cases should now read well in excess of 100 at Elliot Lake and are "climbing steadily".


Dr. Axelson, in his submission on Swedish Miner Lung Carcinoma, stated:

Wagoner noted that

The most detailed and conclusive evidence showing the carcinogenic effect of radon daughters has been done by Dr. Lafuma of the Radiation Protection Department of the Atomic Energy Commission of France:

Dr. Lafuma's research indicates a higher risk   [per unit of exposure]   at lower cumulative working level months (WLM).

It seems that the controversy over low level radiation which is now taking place is following a similar pattern to that of the health hazards of cigarettes that began 30 years ago when epidemiological studies were met with flat denials that cigarettes could possibly cause cancer of the lung.

One of the serious consequences of down-playing the effects of low-level radiation will be to deny those who have developed various carcinomas adequate compensation which may be their due. With the abundant information on the effects of low-level ionizing radiation, the humane course of action would be to give the worker, or in most cases the deceased worker's family, the benefit of the doubt as to whether his or her particular carcinoma was a product of radiation, and compensate accordingly.

Society and industry must be willing to shoulder this burden if we wish to continue with the production of nuclear power and nuclear weapons.


Mr. Bush, Manager of the Radiation Protection Division of the AECB, described mining as an industry with high risk:

According to Mr. Bush,

When asked whether the mining industry in Canada was an industry with a high standard of safety, Mr. Bush replied: "No".   [In particular]   he knew of no industry that exceeds the combined risk of uranium mining.

According to the AECB,

Mr. Bush re-iterated this in cross-examination:

Of course, what he clearly means is that the risk   [from uranium mining]   is no greater than adding the occupational risk of a safer industry on top of the occupational risk of an industry   [mining]   which does not have a high standard of safety.

[In any event]  , the risk of accidental death in a "safe industry" can be approximated at 100 deaths per million workers per year. Several authors have produced estimates of lung cancer cases per million people exposed to one working level month (WLM). According to Mr. Bush,

Sevc, in his calculations of the   [Czechoslovakian]   data in 1970, found

As can be seen, even using the Nuclear Energy Agency's calculations, the   [ cancer ]   risk to miners would be four times as great at present radiation standards   [4 WLM per year]   than the accident risk in safe industries.

Using Sevc's calculations,   [the cancer risk]   would be 9.2 times as great -- approximately 10 times as great -- which would then be in a category of industries with a high degree of risk   [one accidental death per thousand workers per year]  .

Moreover, there is a very important flaw in the AECB's comparison of accidental risks per year with lung carcinomas, which makes direct comparison meaningless:

[Indeed]   Archer & Linden in 1967 concluded that an exposure of 120 WLM

Summary of doubling dose estimates
for lung cancer in uranium miners:
Archer (1967)..........................120 WLM Hewitt (1980) - Ontario............40-5O WLM - Newfoundland.........5O WLM Sevc (1976)..........................~50 WLM US EPA (1980)..........................~40 WLM Ellett (1980)...........................40 WLM BEIR-II (1972)...........................34 WLM BCMA (1980) - NIOSH & Sevc.......19-20 WLM BEIR-III (198O).........................12-17 WLM Axelson (1980)............................2 WLM

The lifetime incidence of lung cancer in males can be calculated to equal 52.5 per thousand, equivalent to approximately a five percent lifetime risk for lung cancer development in males. It would appear that the doubling dose from exposure to radon daughters would be 40 WLM or less, in the exposure ranges experienced by today's miners.

Thus, at a lifetime dose of 40 WLM, a miner would have approximately a 10 percent rather than a 5 percent risk of developing carcinoma of the lung; that is a risk of 1250 lung cancer cases per million workers per WLM. The risk   [per million workers]   would be four times as high at today's maximum permissible exposure of 4 WLM per year. Compare this value with the risk of accidental death in safe industries of 100 accidental deaths per million workers per year!

Because of the long latent period of lung cancer, and its variability with age and smoking, Archer has calculated the attributable cancer for lifetime per million   [workers]   per WLM, which is certainly the value most significant to the mining population. Using the exposure rates present in today's mines and mills, the attributable cancer per lifetime per WLM is approximately 1000   [per million workers]  .


The AECB   [Atomic Energy Control Board]   policy regarding a lifetime exposure limit for uranium miners   [February 1978]   is based on one study   [published in 1969]  , which is not only 11 years out of date, but which has been revised several times by the authors. The AECB notes in passing that in Ontario,

Ignoring this and using the 1969 study (which seems to be the extent of their literature review as no other references are cited) AECB states:

Such a policy statement, based on antiquated data and inadequate literature review, would be irresponsible coming from the nuclear industry, let alone the regulatory agency of that industry. However, as will become clear, it is difficult to ascertain where one ends and the other begins.

The Manager of the Radiation Protection Division of the AECB is Mr. Bush, who has a degree in Chemical Engineering (1955). He worked for Atomic Energy of Canada Limited (AECL) in Chalk River from 1957 to 1969, and subsequently with the AECB from 1969 to the present. One notes that Mr. Bush is responsible for developing radiation protection guidelines and regulations. Mr. Bush admitted,

(This is evident as well from the Board's paltry data analysis upon which their statements of risk are made.) The AECB

Mr. Bush pointed out the difficulty the U.S. Nuclear Regulatory Commission may have in adopting these new ICRP higher dose limits:

The Chairman of the new Advisory Committee, Dr. G. C. Butler, listed members of this Committee.

Dr. Butler agreed that his Committee had not asked any independent bodies, such as the Canadian Medical Association, the Royal College of Physicians and Surgeons, or the Royal Society, to place a member of its own choice on the Committee.

The ''independence'' of this Committee must be seriously questioned. This lack of ''independence'' is characteristic of the AECB.

As Dr. Bates   [David Bates, M.D., Chairman of the B.C. Royal Commission on Uranium Mining]   noted about the previous   [AECB]   Standing Committee on Safety,


The Atomic Energy Control Board has announced adoption of radiation criteria for use in the investigation and cleanup of communities contaminated by radiation.

The Government of British Columbia has adopted the AECB exposure limits   [for public exposure to radon daughters] :

[Outdoor]   levels higher than 0.02 WL may be produced locally by uranium mines. Higher outdoor concentrations would obviously produce higher indoor concentrations of radon.   [According to Dr. Wagoner:]  

In light of the present state of knowledge, one could well view the allowable exposure to the public from nuclear facilities as tantamount to allowing an industrially-induced epidemic of cancer.

Dr. Radford in his submission to the Commission stated that

Dr. Archer observed that

In 1971, the joint monograph by NIOSH   [U.S. National Institute for Occupational Safety and Health]   and NIEHS   [U.S. National Institute for Environmental Health Studies]   also noted:

Nevertheless, the AECB assumes that this   [linear hypothesis]  


British Columbia Medical Association

13 January 1984


As there appears to be some confusion among representatives of industry and government with respect to the British Columbia Medical Association's efforts as a major participant in the British Columbia Royal Commission of Inquiry, Health and Environmental Protection Uranium Mining, we wish to make the following comments:

  1. Dr Eric R Young and Dr Robert F Woollard participated as interveners at the Inquiry as representatives of this Association.

  2. Dr Young is presently the chairman of the environmental health committee of the BCMA and Dr Woollard is past-chairman.

  3. During the Inquiry the BCMA was privileged to present statements of evidence of internationally-recognized authorities on various aspects of this issue.

  4. The report entitled "The Health Dangers of Uranium Mining and Jurisdictional Questions" authored by Drs Young and Woollard is the summary argument of the BCMA presented in 1980 to the Royal Commission in response to its call for final arguments from participants in the inquiry. As such it has been supported by the BCMA Executive and Board of Directors.

  5. This report has had significant peer review and there has been ample opportunity for public comment.

  6. The substance of the report is reflective of BCMA policies in the area of environmental health as established over several years by consideration and debate at the general assembly and Board of Directors and, as confirmation of this, the BCMA holds copyright on both printings of this BCMA publication.

Extensive feedback has confirmed the report's value as an aid in promoting public participation in this important area of environmental health and has vindicated the medical association's expressed interest to raise the level of debate on this issue.

Yours sincerely

G D McPherson, MD
BCMA President

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