As part of my interest in the Chalk River-medical isotope-NRU situation that currently exists, I thought I would send an e-mail to a scientist who is an international expert in risk management.

I was pleasantly surprised, if not overwhelmed, to get a full essay from him in response. He’s agreed to allow me to post it here as a guest post. It provides a perspective far more informed on the topic than I am, but one that reinforces much of what I’ve been thinking (as a sideline, improving my self-esteem).

Here’s the bio of Dr. William Leiss from his site:

William Leiss is a Fellow and Past-President (1999-2001) of the Royal Society of Canada and an Officer in the Order of Canada. From 1999 to 2004 he held the NSERC/SSHRC Research Chair in Risk Communication and Public Policy in the Haskayne School of Business, University of Calgary. This five-year chair program, with total funding of $1.25 million, was part of the MOTC (Management of Technological Change) strategic grants program; a consortium of Alberta-based industrial sponsors from the chemicals and petroleum sectors, led by Nexen Inc., provided one-half of the chair funding. From 1994 to 1999 he held the Eco-Research Chair in Environmental Policy at Queen’s University, Kingston, Ontario. The five-year Eco-Research Chair program was funded at a total of $1.3 million by the Tri-Council Secretariat (using funds from Environment Canada) and Imperial Oil Ltd. His earlier academic positions were in political science (Regina, York), sociology (Toronto), environmental studies (York), and communication (Simon Fraser). At Simon Fraser he was also Vice President, Research.

And here is his essay, in its entirety. I have added hyperlinks where appropriate.

Grandstanding about Risks:
What Lessons can we learn from the Isotope Mess?

William Leiss

December 13, 2007

Apparently the bill mandating the re-starting of the nuclear reactor at Chalk River was the first use of the Government of Canada’s emergency powers since World War II—or at least since the use of the War Measures Act in 1970.

The combination of high parliamentary drama, overheated partisan rhetoric, and thousands of critically-ill patients going without essential diagnostic tests will be hard to match in future. Of course, things never should have come to such a pass. This was a tragedy waiting to happen, like so many others (the discovery of BSE in the Canadian herd is another recent example).

We have all the tools we need already in hand to avoid such needless crises. But when it comes to risk management, all bets are off: Politicians simply do not want to deal with bad things that might occur but haven’t happened quite yet. Once they do happen, they’re quite comfortable in writing large cheques against the public purse to clean up the mess, and then finding someone else to take the blame.

As Ian Macleod explained in a superb background article on the front page of yesterday’s Ottawa Citizen, the isotope mess had been in preparation for a very long time. Canada’s MDS Nordion has developed a very useful and profitable business selling nuclear isotopes for medical diagnostics and radiotherapeutics under an agreement with AECL, and as of now Canada is responsible for half the world’s supply of these vital substances.

AECL’s aging Chalk River installation was supposed to have been replaced ages ago with a new generation of reactors, the so-called “Maple” models. The new models are eight years behind schedule and hundreds of millions of dollars over budget. An ugly legal battle between MDS Nordion and AECL over who was going to pay for the enormous cost overruns was settled only last year. But, as Macleod explained, there may be a serious design flaw in the reactor, and Canada’s nuclear safety regulator is still not at all happy with AECL’s present plans for bringing them into service.

The current facility in Chalk River is over fifty years old. The dispute between AECL and the regulator, the Canadian Nuclear Safety Commission [CNSC], over whether or not the facility is in compliance with current safety standards, has been going on for about two years. Natural Resources Canada is the government department with lead responsibility for these agencies and the legislation under which they operate. Health Canada has regulatory responsibilities for the use of radioactive substances in diagnostics and patient care.

All of the senior administrators for all of the above parties live in the same city. Didn’t anyone see the train wreck coming? Laying the blame at the feet of the CNSC alone is a crude and unconvincing way of trying to disguise the fact that all of the parties named above, including two federal ministers, were asleep at the switch.

What can be said about the substance of the matter? When the crisis broke, what patients, the medical community, citizens of eastern Ontario and western Quebec, and governments faced was in fact a risk/risk tradeoff situation. Two types of risks, equally compelling in nature, are present: (1) patient risks from delays in diagnosis and treatment, on a very large scale, and (2) unsafe operation of a nuclear facility, with potentially catastrophic consequences for the region around Chalk River and perhaps elsewhere.

The first set of risks is immediate, widespread, potentially catastrophic for many sick individuals, and obvious to the rest of us. The second set of risks is a hypothetical one, based on a complicated process of estimating the likelihood and consequences of a reactor failure and the unavailability of some or all of the backup safety equipment at the facility. I hasten to add: Just because it’s a hypothetical risk doesn’t mean it’s not “real”! The Prime Minister may honestly believe that “there will be no nuclear accident” as a result of restarting the reactor, but such a statement is illogical on its face.

However: Almost certainly a reasonable, fair and considered judgment—on the competing “balance of probabilities” for adverse outcomes—would conclude that, in this case, the first set of risks trumps the second, and that the current facility should continue to operate. So why didn’t the CNSC make the call in this way?

Because it has no legal, regulatory, or moral authority to do so. CNSC’s mandate is to ensure that nuclear installations in Canada are operating according to approved standards of performance and acceptable risk. That is its only mandate. It has no authority whatsoever to “balance” the safety of nuclear reactors against the needs of Canadians and others to have reliable access to nuclear isotopes. Just imagine the hypothetical counter-case: The reactor is restarted, it fails, and a catastrophic accident ensues as a result of the lack of adequate emergency backup systems—a situation of low or very low likelihood, that is, improbable, but not impossible. Then what would we all be in a position to say to the CNSC?

So whom should we hold responsible for getting us into this mess—and, hopefully, for getting us out of it again? My candidates are the ministers of natural resources and health in the Government of Canada, and the officials who report to them. For who else should have noticed, sometime in the past two years at least, while AECL and CNSC were battling, that potentially tens of thousands of patients around the world were at serious risk of a disruption in the supply of nuclear isotopes?

Where was the contingency plan, devised in advance? Where was the directive given to AECL in 2006 to respond immediately and completely to the CNSC’s requirements regarding its operating license? And, knowing how important Canada’s role is in supplying nuclear isotopes for medical purposes to the world, why has the Government of Canada been sitting on its hands for so long while AECL was embarrassing itself with its Maple reactors fiasco?

Risk management means that you look ahead, for the risks that are known to you, and try to devise ways of minimizing the adverse consequences that have a good chance of coming down on our heads. This is also called “the precautionary approach,” which was adopted some time ago as an official policy of the Government of Canada. These are very good tools, by now developed at a high level of sophistication. But at the political level, the mantra always is, “Please, dear God, don’t let this happen in my term of office.”

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Thanks, Dr. Leiss.

Ciao,
Bob.

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