Antinuclear

Submission to AUKUS Public Inquiry – Radiation protection for workers and members of the public under AUKUS – Dr Tony Webb

No. 204 -Summary

Summary of key issues covered in this submission
The key issues I wish to raise for consideration as part of this Inquiry into the AUKUS
submarine program are:
 That there is a potential risk to health of workers and the public from routine as well
as unpanned/accidental exposures to ionising radiation from many aspects of this
AUKUS program including: submarine construction, operation, maintenance,
decommissioning, and long-term management of radioactive waste materials.

 It has long been an established principle for radiation protection that there is no
threshold or safe level of exposure – that even small doses may result in stochastic
health effects where probability of effect rises with the level of exposure rather than
disease outcomes being determined by dose. As a result, it is expected that all
exposures need to be justified against some expected social benefit, be kept as low
as reasonably achievable (ALARA) and be kept below strict annual worker and public
exposure limits.

 These established principles are currently being challenged in the USA as a result of a
2025 Presidential directive that instructs the US Nuclear Regulatory Commission to
abandon the no threshold and ALARA principles and revise occupational and
exposure limits to reflect deterministic rather than stochastic health effects – changes
that, if implemented would significantly increase permissible exposures.

It is unclear how such changes might be applied to nuclear submarine operations
under AUKUS particularly where US or Australian-US co-owned/operated boats use
Australian facilities. Pressure from the US to operate within US standards can be
anticipated. It should be noted that Australia has already established a Naval
Nuclear Protection Standards Regulator (ANNPSR) – separate from the current
Radiation Protection and Nuclear Safety Agency (ARPANSA) – that will regulate all
aspects of safety for the AUKUS program.

 The changes to US standards – already weaker than those applied under international
recommendations by most other countries, come at a time when scientific evidence
from large scale epidemiological health studies on workers employed in, and
communities living close to, nuclear facilities indicates that the estimates used in
setting current standards underestimate the risks to health and need to be
significantly tightened.

Details and evidence relating to these issues are outlined below. I will be happy to provide
further information and be questioned on matters arising if this would assist the Inquiry.

Impending changes to radiation protection standards
Changes for worse or better protection for workers and the public is on the international and
national political agenda in a number of countries. Trade Union, environment and public
health groups around the world are concerned that the USA is considering proposals that
would weaken radiation protection standards at a time when the scientific evidence
suggests these need to be significantly tightened. These need to be resisted with pressure
to provide better not worse protection for workers and the public.
In May 2025 US President Donald Trump issued a Directive (EO 14300) i

requiring the US Nuclear Regulatory Commission (NRC) to review nuclear safety regulations with particular
reference to radiation protection of workers and the public. The Directive instructs the NRC
to abandon fundamental principles that have formed the basis for radiation protection for
much of the past century. These include: the internationally accepted position that there is
no threshold or safe level of exposure to ionising radiation; that, as a consequence, all
exposures should be kept as low as reasonably achievable (ALARA); and that exposures to
workers and the public be kept below strict annual limits in line with the best evidence of
radiation-induced health risks.

Evidence for increased health risk from radiation exposure
The evidence used to set current standards is drawn mainly from the studies of cancer rates
among the Japanese A-bomb survivors who were exposed to relatively high doses over short
time periods. Since then, studies of workers in nuclear power facilities exposed to lower
doses over long time periods show higher rates of cancer than predicted by the Japanese
studies. Rather than indicating any threshold these studies suggest that at low doses the
cancer rates are proportionately higher than expected from the Linear No-Threshold (LNT)

model used to set current standards.ii Worker studies also show elevated rates of cardio-
vascular diseases, and increased rates of dementiai. In addition, studies on populations around nuclear power plants are now showing higher cancer rates affecting the population
generallyand particularly childrenvi and the elderly with level of health damage correlated
with how close they lived to these facilities……………………

US pressure on global standards
If they go through there will also likely be pressure on international and national standards
agencies to align with changes in the USA. There is already some push-back. In June 2025
the heads of European standards agencies issued a statement supporting the LNT and
ALARA principles and insisting that exposure standards be set on the basis of the scientific
evidence without undue influence. ix In May 2026 the World Health Organisation urged
national and international bodies to continue collaboration to “harmonise standards, share
data and strengthen coordination on radiation and health.”

The AUKUS connection
In Australia there are a number of joint ventures in uranium and radioactive rare earths and
mineral sands mining and the government has already established a separate Naval Nuclear
Power Safety Regulator (ANNPSR) to oversee all aspects of construction, operation,
maintenance, decommissioning and nuclear waste management under the Australia-UK-US
(AUKUS) nuclear submarine program. While these nuclear submarine standards are
expected to be consistent with those of the current Australian Radiation and Nuclear Safety
Agency (ARPANSA) it is unclear whether US or Australian standards will apply to US military
or joint US Australian assets operating from Australian facilities. Pressure for change is
inevitable. Hopefully the outcome of politically independent science-based pressure will be
not merely opposition to changes prompted by the US President’s directive but for
significantly better standards to protect health.

What the AUKUS investigation might recommend
First: that Australian radiation protection should continue to be based on the established
principles that: there is no safe level of exposure to ionising radiation; that all exposures in
the workplace, and in community from whatever source need to be justified against some
recognizable benefit and where justified be kept as low as reasonably achievable and in any
case below strict exposure limits that are set on the basis of the best available evidence for
the level of risk of health damage.

Second: that all radiation protection safety standards operated under the AUKUS program
and regulated by the ANNPSR be consistent with those developed by ARPSANSA for
occupational and public exposures generally and that these apply to construction,
maintenance, decommissioning and waste management for all nuclear-powered submarines
whether these are owned by Australia or another country – Australian standards rather than
those of another country should apply in Australia.

Third: that ARPANSA be asked to provide a clear and unequivocal statement that Radiation
Protection standards in Australia will not be changed in line with the US Presidential
Directive
Fourth: that ARPANSA be asked to undertake a systematic review of the evidence suggesting
that the current occupational and public exposure limits need to be revised – and tightened
so as to lower permissible exposure limits.
References and Further Reading………………………….

October 11, 2026 - Posted by Christina Macpherson | politics