Draft Carriage of Dangerous Goods (Amendment) Regulations 2019

Alan Brown Excerpts

Monday 28th January 2019 General Committees

[Alan Brown (Kilmarnock and Loudoun) (SNP)]

It is a pleasure to serve under your chairmanship, Mr Bailey. I have a few brief questions. Paragraph 11.1 of the explanatory notes to the draft instrument says that the Office for Nuclear Regulation will publish guidance, following an informal consultation in 2019. Why will there be such a lag until it publishes that guidance, and why is it only guidance, not statutory guidance?

The following questions are probably more basic or high level and touch on what the shadow Minister outlined. Paragraph 7.3 of the explanatory notes tells of the national reference level of exposure being 100 mSv over one year. How was that exposure level defined? Why do the notes say that that is a cumulative exposure level over one year, yet the reference to one year is not included in paragraph 9 of the schedule?

How does the Minister see emergency plans working if there is a spike towards the end of that one year, taking workers over the 100 mSv exposure level? What guidance needs to be given or action taken if there are several spikes? For example, it is one thing to set the level at 100 mSv over a year, but what if there are a series of spikes of 30 mSv each at one time? That seems to me to be a more dangerous exposure than a 100 mSv exposure over one year. What cognisance has been taken of routine, year-on-year exposure to 100 mSv? It seems to me that a long-term, cumulative effect must increase the cancer risk associated with radiation.

As the shadow Minister touched on, why will emergency workers be allowed to be exposed to that massive spike of 500 mSv? Workers at Chernobyl were relocated at 350 mSv, so why are we saying that our emergency workers can be exposed to an even greater level than what happened at Chernobyl?