Vani Ranganathan, MSc, DRP, CRPA (R)

HSO, Registered & Designated Radiation Safety Officer

Environmental Health and Safety
Division of the Vice-President, Research & Innovation
 

University of Toronto

The compounds that appear in the Group 1A list based on REGDOC 2.13.1, were never regulated in the last few decades when they were procured. These compounds of Uranium and Thorium were used for their non-nuclear properties in the past and continue to be used at present as well. The procedure is referred to as negative staining and is applied in the Electron Microscopy procedures.  

The purchase of these compounds has been completed without requiring internal approval, until recently. The vendor or supplier has been releasing the compounds for purchase without requiring any approval, or without requesting a copy of the import license, there is no verification step in place for vendors.

The compliance for ensuring Cradle to Grave policy by the regulator must be reconsidered/rewritten to include the vendor and suppliers as well and not just the purchasing LOF alone. (The vendors and suppliers do not appear along with manufacturers in Appendix A of REGDOC 2.13.1)

• In terms of the timeline, the “cradle” must be placed even before the vendor websites offer the safeguard items listed as products available.  We would like to see the Cradle to Grave policy apply to vendors and suppliers from anywhere within or outside Canada. We request that control be established right from where these compounds are shipped out to the receiving LOFs. (The current impact is: It is not Cradle to Grave anymore but begins at “Once it enters the LOF to Grave”.)
• The language/terminology used in Appendix C seems ambiguous.  We as a research and academic institution have inferred and reasoned that the sentence in appendix C of REGDOC 2.13.1 “natural uranium, depleted uranium or thorium used as a colourant, pigment, stain or glaze” as being referred to the negative staining procedures used in the Electron Microscopy facilities. This ambiguity is also seen in the section outlining the criteria for exemption.

We and other research institutions across Canada request clarity on the descriptions used in Appendix C. A terminology with numbers (limits) similar to SOR/2000-210 section A.1.2 source material is more comprehensive, to prevent the misconception between negative staining as a scientific procedure and staining at a contaminant level as implied in Appendix C.

Anticipated Impact for the comment

The anticipated impact is If the Cradle to Grave is applied consistently across the board, starting from the vendors, and suppliers (of the Safeguards material), at the international and national levels, the academic and research institutions will be better placed and supported to ensure compliance with the Safeguards program. To draw a comparison, the internal radioisotope requisition review and order approval process requires, that all purchases of radioactive material at the University be approved by the Radiation Protection Services prior to ordering or receipt of the material. The vendors and suppliers insist on the approval and a copy of the license before releasing the purchase order. Compliance is therefore achieved because both the institution and the vendor are engaged.

A more comprehensive and clear language for Appendix C of REGDOC 2.13.1 with explanatory notes or guidance documents will help licensees break down and communicate technical issues that are complex in nature to all stakeholders within the academic and research institution in a meaningful way and manage obligations as a licensee.

I recall going to the Pickering Nuclear Plant to see fireworks and coming across guards with machine guns. It was incredibly disturbing. Security guards are not trained to act calmly around neurodivergent people like myself. I feel really uncomfortable around armed guards. Please do not heavily arm the guards, and have properly trained security staff who are not armed. Police are armed but at least have some training and feel more normal. grew up near a nuclear dump and nuclear power plant, near Pickering. I never felt safe there, especially with that loud false alarm in January 2020. I was so glad to move. There is no safe disposal of nuclear waste or safe use of nuclear.

I am quite concerned with mandates for testing “fish tissue and other receptor species tests for exposure uptake”. As Canada is moving away from animal testing, this seems counterintuitive to include animal testing in a document to modernize practices, especially when there is no mention of phasing out and replacing the practice. Mining is harmful to all life, and to the planet. Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated. Canada is phasing out toxicity testing on animals. Please switch to animal free methods of testing effluent and other substances. For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. 
Mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc. Please do not use animal testing for pollution monitoring.

There are cruelty free modern alternatives to animal testing, including acute lethality testing. Cell cultures can determine effect of pollution for instance. Please reach out to antivivisection organizations regarding these tests, and lobby to change these outdated laws.

Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species. These tests involve pumping effluents into fish tanks about once a month, and if more than half the fish die, the experiments are repeated. There are animal free ways to test for pollution. Any guardians of companion fish will test their tank using paper strips and test tubes. They do not deliberately expose the fish to effluents to see what happens. Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows and rainbow trout, and stop cutting up fish to test their livers for mercury. Please lobby the government to put an end to mandatory toxicity testing under the Fisheries Act and go cruelty free. Please only use non lethal sampling of wild fish, or take tissue samples from fish who were already caught for human consumption. Please do not kill or harm any animals for research.

Many mining companies also kill animals as “pests”. Please only use non lethal methods of wildlife coexistence.

Please only use humane non lethal methods to manage beavers and other wildlife. Killing beavers only leaves room for more animals to move in. And the traps kill many other animals. London Ontario and many other places manage beavers without killing.