To The Globe and Mail, The Ottawa Citizen, and The North Renfrew Times:

1998 March 19

To the Editor:

The Environmental Assessment Panel reviewing AECL's plan to bury nuclear waste deep in the Canadian Shield has just released its report, and it is setting a very dangerous precedent. The report concludes that, "while the safety of the AECL concept has been adequately demonstrated from a technical perspective, from a social perspective, it has not". It then recommends against acceptance at this time and calls for the establishment of an independent agency to oversee all activities related to the nuclear waste issue, with full public participation. (The report is available on-line at: http://www.ceaa.gc.ca/panels/nuclear/reports/report_e.htm).

This priority given to public acceptability is not a bad idea; what is a bad idea is the inclusion of this acceptability, by the panel, within the definition of "safety". The report states that "safety must be viewed from two complementary perspectives: social and technical". This is an absurd notion. Safety is the "freedom from harm or danger", which is distinct from the perception of safety, or the perception of risk. While these latter considerations are important in the assessment of a technology's psycho-social impact, they have no place in the assessment of safety. The effect on human and environmental health, now and into the future, is a matter of scientific determination. How we may feel about those findings is equally important, but another chapter altogether.

The precedent is dangerous. Already, anti-nuclear activist groups are assembling behind the banner "Panel Declares Waste Disposal Unsafe", which is a falsehood. Word-processors are busy typing "I told you so" rhetoric in fund-raising literature. The position of the EA Panel is no fluke: For years the more astute anti-nuclear activists, having recognized the low risk of nuclear power's operations, have strategically stressed the social factor. The more legally-minded have invoked our Charter of Human Rights, claiming that radiation dose, no matter how insignificant, and regardless of the direct benefits (e.g. clean electricity, cancer therapy), should be banned if an individual chooses not to be exposed to it, as a matter of personal rights.

This is an engaging debate, and one that leads straight to the question of "personal choice" versus "societal benefit". However, nowhere does it impinge on the question of safety. The EA Panel, by redefining the word, has undermined the credibility of those working to improve safety, and has made Public Opinion the last word on the success or failure of their efforts.

The EA report is well-intentioned, but poorly executed. It will be misinterpreted and misused for years to come, and other technologies will suffer, completely regardless of the societal benefit and risk they represent.

Jeremy Whitlock

[Response from Norm Rubin of Energy Probe]

[My response to Norm Rubin]