Safeguarding Global Health: Reforming Nuclear Regulation at Global and Canadian Levels
This Essay is authored by IPPNWC Research Intern and Medical Student Leader, Ahmad Butt.
Introduction
Nuclear power has many uses and is a novel source of energy that we have used for less than a century. Its most important impact on human health is through ionizing radiation. Ionizing radiation is a form of energy that removes tightly bound electrons from atoms, causing the atoms to become charged, or ionized. This process, known as ionization, can disrupt the structure of atoms and molecules, leading to chemical changes that damage cells [1]. The indirect effects of radiation — via reactive oxygen species (ROS) formation, e.g., hydroxyl radicals — account for a significant proportion of biological damage [2,3]. These radicals are generated as radiation interacts with water molecules, initiating a cascade of biochemical reactions that lead to DNA damage. While cells have repair mechanisms to address these injuries, these processes are not always efficient or accurate. DNA repair errors can result in permanent mutations, while unrepaired or misrepaired damage can lead to genomic instability, programmed cell death (apoptosis), or cancer formation (carcinogenesis) [2,3].
There are different types of ionizing radiation, X-rays, gamma rays, alpha and beta particles, each of which possess unique characteristics. X-rays are used in medical imaging. Higher energy gamma rays are released in nuclear reactions [4]. Ionizing radiation is emitted by nuclear reactors and nuclear weapons. Background radiation naturally exists but the production of novel radionuclides by the nuclear industry introduces additional risks through exposure to more potent forms of ionizing radiation [5].
The biological effects of ionizing radiation depend on the type and dose of radiation, and duration of exposure [1]. External exposure occurs when radiation penetrates the skin or deeper tissues, typically from environmental sources or medical procedures involving external radiation. In contrast, internal exposure results from the ingestion or inhalation of radioactive particles, which can cause greater and more sustained biological damage due to the retention and decay of radionuclides within the body [6,7]. Lastly, background exposure to radiation, primarily external in nature from sources such as cosmic rays and terrestrial radon gas, provides a baseline level of exposure that informs our understanding of radiation safety and associated health risks [7].
Nuclear medicine procedures, such as bone scans, PET (Positron emission tomography) scans, and Gallium scans, use medical isotopes that continue to emit radiation after use. These procedures primarily expose individuals to radiation externally, but generate radioactive waste that requires careful handling and protection to prevent environmental contamination and accidental internal exposure through ingestion or inhalation [4]. Nuclear reactor meltdowns or nuclear bomb explosions, on the other hand, release large and uncontrolled amounts of radiation, leading to exposure through multiple routes (i.e., internal and external exposures). This leads to exposure to high concentrations of ionizing radiation that are associated with severe health and environmental damage [5].
Historically, the regulation of the nuclear industry has prioritized the safety of its workers. Guidelines for exposures have focused on the ‘Reference man’ model. This has led to inadequate safeguards for vulnerable populations such as children, pregnant women, elderly and Indigenous populations [8]. While regulations aim to protect workers, emerging evidence suggests that these risks have been underestimated. The broader public health impacts, especially those outside the nuclear power plants, continue to be neglected [9]. This disparity emphasizes the need for more comprehensive regulations that protect from the long-term health risks to the broader population, especially to those most vulnerable to radiation.
Scientists and researchers continue to gain important insights by analyzing historical events involving ionizing radiation. Monitoring the long-term health and environmental impacts of radiation from the Chernobyl and Fukushima nuclear disasters, as well as the Hiroshima and Nagasaki atomic bombings during World War II (WWII), has provided valuable data. These events have shed light on the drastic and ongoing complications associated with radiation exposure. In addition to physical health issues, researchers have also highlighted the mental burdens and intergenerational trauma linked to such exposures [8,10].
The Hiroshima and Nagasaki bombings that occurred towards the end of WWII in 1945 resulted in ~70,000 immediate deaths, with an additional 70,000 deaths by the end of 1945 due to injuries and radiation poisoning [11]. Additionally, longitudinal studies examining the health and long-term impacts on survivors revealed a 42% increase in cancer incidence among those exposed to 1 Gy of radiation through the bombings, while life expectancy decreased by about one year for those highly exposed [10]. Research has highlighted that the most notable health problems associated with radiation exposure include cancer, cardiovascular disease, and an increased risk of genetic mutations [1]. Children and pregnant women are also particularly vulnerable to the harmful effects of radiation [8]. However, it is important to note that permissible doses of radiation in our current society are not necessarily safe doses, as current regulations are still based on the outdated ‘Reference Man’ model, which does not account for the variability in radiation sensitivity across different populations, gender, and age groups [12]. Collectively, these points highlight strong reasons to foster more comprehensive and transparent regulations as well as open discussions on nuclear development and energy, which would ultimately promote a safer and healthier society.
Existing Regulatory Bodies: International Atomic Energy Agency (IAEA) and Canadian Nuclear Safety Commission (CNSC)
What is the IAEA?
The International Atomic Energy Agency (IAEA) is an international organization with the goal of promoting the peaceful use of nuclear energy while establishing safety and security standards on a global scale [13]. However, the IAEA faces a conflict of interest in its dual role of promoting nuclear technology while downplaying the negative impacts on public health and the environment. Additionally, the agency's ability to regulate is limited, as it can propose safety standards, but lacks the power to enforce them. Importantly, it does not have authority over nuclear weapons and does not have access to all countries using nuclear technology [14].
This lack of enforcement capability creates significant problems when countries fail to observe the proposed standards. For example, during Russia's invasion of Ukraine in 2022, there was blatant disregard for IAEA protocols at the Zaporizhzhia Nuclear Power Plant, including disruption of power supplies, forceful occupation, and violation of safety protocols [15]. Furthermore, the absence of a rapid deployment force with the technical, security, and public health capacity to manage nuclear power plant disasters that overwhelm local capabilities exacerbates these vulnerabilities. Without such a mechanism, the IAEA is ill-equipped to respond to nuclear emergencies in an effective manner. These gaps in the IAEA's regulatory framework and enforcement capacity have certainly undermined public trust and pose serious risks to global public health and environmental safety
What is the CNSC?
The Canadian Nuclear Safety Commission (CNSC) is the Canadian regulator responsible for overseeing the use of nuclear energy and materials, operating under the authority of the Nuclear Safety and Control Act (NSCA) [16]. The NSCA was enacted in 2000 and provides the legal framework for CNSC’s responsibilities, which include “regulat[ing] the development, production, and use of nuclear energy and the production, possession and use of nuclear substances…[and] disseminating objective scientific, technical and regulatory information to the public” [17].
While the CNSC shares many of the same objectives as IAEA, it is specifically tasked with ensuring local Canadian safety and protecting public health and the environment. However, the CNSC has been critiqued for inadequate and vague safety standards, notably in regulating tritium emissions into drinking water. Although the exact health impacts of tritium are not fully understood, there is growing concern due to its tendency to concentrate in fetuses, raising alarms about potential long-term health risks, especially in vulnerable populations such as those in remote and Indigenous communities [18].
A major concern regarding the CNSC is the absence of independent public health assessments in its evaluation of nuclear technologies. Unlike other regulatory bodies that incorporate public health expertise into decision-making processes, the CNSC has specifically been noted for lack of health professionals on its board [19]; the recent appointment of Mr. Pierre Tremblay, whose background includes extensive experience directly in the nuclear industry, as CNSC President has underscored concerns that the Commission prioritizes industry ties over public health representation. This creates a potential conflict of interest, with public health risks being underrepresented in decision-making processes regarding nuclear safety [19]. This dual gap — the absence of a legally mandated independent public health review and insufficient safeguards for vulnerable populations — highlights the need for structural reform within the CNSC to ensure public health considerations are adequately integrated into Canada’s nuclear safety framework.
Limitations in current regulatory oversight
Conflict of interest: As the IAEA both promotes and regulates nuclear energy, it faces evident conflicts of interest. Its regulatory power is especially weakened in politically unstable regions, as seen in Ukraine, where local forces involved in the war disregarded the IAEA’s safety mandates at a nuclear powerplant [15].
Transparency and engagement issues: The CNSC has faced criticism for its lack of transparency and insufficient public engagement, particularly with relevant stakeholders, on nuclear safety matters, such as in communities disproportionately affected by its regulations, including remote and Indigenous populations [18]. While the CNSC plays a key role in regulating nuclear safety domestically, it also does not actively engage in international cooperation and discussions, which can lead to gaps in global regulatory efforts. In addition, although the IAEA conducts routine checks on civilian nuclear power plants, including those in Canada, the CNSC’s focus is strictly domestic and does not extend to international nuclear safety oversight [20]. In particular, there does not seem to be adequate concern about the possibility of plutonium reprocessing and the production of fissile materials that could contribute to nuclear weapons proliferation.
Proposed solutions & stakeholders:
Overall, addressing the current gaps in nuclear regulation is not merely a technical challenge—it is a critical moral responsibility. Implementing transparent, inclusive, and evidence-based reforms is vital to safeguarding global health, protecting vulnerable populations, and ensuring the responsible and safe use of nuclear energy. Therefore, we propose the following actionable steps towards achieving these goals:
Improved national policies: While the IAEA provides international guidance on nuclear safety protocols, it has identified deficiencies in Canada’s nuclear waste management policies, urging updates. This has led to public consultations where various stakeholders have called for stronger policies — particularly concerning plutonium extraction. However, these alternative policy recommendations have largely been ignored by the Canadian government [21]. To ensure a more inclusive and transparent policy development process, it is essential that stakeholders involved in decision-making include regulatory bodies like the CNSC and health experts, physicians, and community advocates such as Indigenous leaders. This would ensure that the potential health impacts on vulnerable communities are considered and that public welfare remains a priority [22].
Crisis response teams: Independent crisis response teams with expertise in radiation control, public health, and safety could be organized to be rapidly deployed to nuclear facilities during emergencies to appropriately safeguard and prioritize community health and safety. These teams should operate under the guidance of the United Nations but remain independent from the conflicting parties involved in the crisis. Including experienced healthcare professionals, such as physicians and nuclear physicists, would ensure a rapid and accurate assessment of radiation exposure risks, immediate health concerns, and necessary mitigation strategies based on the level of exposure. This approach would ensure a tailored, impartial response that prioritizes the health and safety of affected populations.
Stronger legal accountability: While an international legal framework already exists, with the IAEA setting safety standards, the challenge lies in poor enforcement mechanisms and limited access to facilities in certain countries [14]. A more robust framework is needed to ensure compliance with these standards, even in countries where the IAEA has restricted access or limited oversight. This framework should strengthen cooperation between the IAEA and national organizations, such as the CNSC, and mandate greater transparency and accountability for safety violations. In addition, regulatory bodies must incorporate public health expertise, involving both healthcare providers and local environmental advocates as key stakeholders in decision-making. Independent public health reviews, with direct involvement from these communities, should be required to minimize conflicts of interest in nuclear regulation, a recurring concern with both the IAEA and the CNSC [23].
Updating permissible levels of radioactive materials: As explained above, the current safety standards for permissible levels of radioactive materials in many societies, including Canada and the United States, are still based on the outdated 'Reference Man' model, which assumes the radiation sensitivity of a 20–30-year-old Caucasian male. This model, however, fails to account for the significant gender, ethnic, and age-related differences in radiation sensitivity, with research indicating that women and children are at higher risk of radiation-related health impacts [12, 24], highlighting an urgent need to update these standards to reflect these gendered and age-related differences in radiation risk [24]. Without these updates, regulatory bodies continue to underestimate the risks posed to large segments of the population, particularly women, children, and ethnic minorities.
Strengthened oversight from Health Canada: A critical issue in Canadian nuclear regulation is Health Canada's limited involvement in regulating toxic radioactive materials. Instead, it defers responsibility to the CNSC [25], which has faced criticism for its lack of transparency and inadequate safety measures, particularly in Indigenous and remote communities. Strengthening Health Canada's role in monitoring and regulating radioactive materials, especially to prioritize public health protection, is crucial in addressing the gaps in current regulatory frameworks.
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This Essay is authored by IPPNWC Research Intern and Medical Student Leader, Ahmad Butt.
Ahmad Butt is a second-year medical student at the University of British Columbia with experience and interest in radiology, cell biology, public health, and the intersection of health, society, and policy.