Antinuclear

 Medical Assocation for the Prevention of War (MAPW)  SUBMISSION ON FEDERAL REGULATION OF URANIUM MINING, by Dr Margaret Beavis April 2013 “…..With regard to non-human species, the 2010 ARPANSA Technical Report No. 154 entitled

“Environmental protection: Development of an Australian approach for assessing effects of  ionising radiation on non-human species” made the following statements:

“It is now generally accepted that under certain circumstances, there is a need to demonstrate, rather than assume, that non-human species living in natural habitats are  protected against ionising radiation risks from radionuclides released to the environment by

human actions.

In an Australian context, there is a recognised need for specific national guidance on protection of non-human species, for which the uranium mining industry provides the major  backdrop; it is Australian Government policy that uranium mining should be based on world

best practice standards for assessing environmental impacts.

It is timely that Australia now consider the development of guidance in order to provide clear  and nationally consistent advice to operators and regulators on protection of non-human  species, including advice on specific assessment methods and models and how these might

be applied in an Australian context.

This report reviews the ICRP and ERICA internaational frameworks for assessment and  protection of non-human species and the applicability to the Australian context.

The general conclusions to be drawn from this report include:

• At the international level, the International Commission on Radiological Protection  has established a framework for radiological assessment and protection of nonhuman species based on a reference animal and plant approach;

• In an Australian context, there is a need for specific national guidance on protection  of non-human species, identified through the National Directory for Radiation  Protection, and realised by the need of the uranium mining industry to integrate world  best practice standards for assessing environmental impacts;Without federal oversight and reporting this is highly unlikely to happen in any consistent,

coherent or comparable manner. So inclusion in the EPBC Act is essential……http://www.mapw.org.au/files/downloads/2013-04-Productivity-Commission-uranium-submission.pdf