Earthlife Africa
This presentation will cover the following topics :
• Introduction and General Comments
• National Nuclear Regulator Bill
• Nuclear Energy Bill
• Recommendations & Conclusions
• Questions

Introduction and General Comments
Earthlife Africa believes that the nuclear industry has for a great deal of time been governed by secrecy. The Bills facilitate adherence to this secrecy and support the expansion of the nuclear industry and do not support nuclear non-proliferation and scaling down of the industry. Earthlife believes these Bills should not be passed

• Nuclear industry with little accountability to citizens
- secrecy of the industry in the past
- industry has monitored itself - no public confidence
- no accountability & penalisation for transgressions and license violations

• Exposure of workers & citizens to radiation - lack of sufficient protection
- little or no monitoring that is made available to public

• Proliferation of the industry
- supports the continued investment in nuclear technology & energy, against international advice & trends

• Transformation of AEC away from nuclear to renewable energy not supported
- capital intensive investment promoted - resultant job loss

Introduction and General Comments
Earthlife Africa is concerned with specific provisions of, and omissions in the two Bills which supports our reasons calling for the Bills to be withdrawn:

• The exclusion of the mining sector from these Bills
- concern that these Bills make way for the relaxing of safety standards in the mining industry
- lack of public participation

• Secrecy - No provisions for protection of "whistleblowers"
- Bills support punitive action against whistleblowers
- Does not support openness and accountability - entrenches secrecy established under previous government
- Does not give public the confidence that transgressions will be uncovered

• Standards
- must have national standards and these are not apparent
- Bills appear to be way to settle dispute between CNS & MWH&S Inspectorate

National Nuclear Regulator Bill
• Application of the Act again does not include the mines
• Functions of the Regulator
- governance does not include participation of civil society at highest levels of corporate governance
• Minutes of meetings
- no facility for public access to minutes - entrenches secrecy
• Financial Security/ liability damage
- methods for calculating "acceptable risk" and financial risk provisions must be made publicly available - no provision for this
• Records or nuclear installations
- no provision for access to records for public scrutiny
• Regulators powers & Disclosure of information
- punishes whistleblowers
- entrenches secrecy - lack of transparency & accountability

Nuclear Energy Bill
• Main function
- no public debate and participation in determining the role of this institution or the future of the nuclear industry
- limits public & interest group access to the corporation activities

• Board minutes
- no explicit provision for public/interest group access to minutes - secrecy

• Provisions for security & disclosure of information
- entrenches the secrecy of the organisation and its operations
- penalises and restricts members of the public and staff for making public information which may well jeapordise public safety & health
- no protection of whistleblowers

• Nuclear Non-Proliferation
- clauses enshrine the secrecy of the corporation and facilitate a climate for proliferation rather than combat proliferation

Conclusions & Recommendations
Based on our decision to call for the withdrawal of these Bills, Earthlife Africa believes:

• Nuclear Summit must be called to allow for proper and full participation of all affected stakeholders - Portfolio Committee best placed to drive this summit based on successes with the Asbestos Summit

• Standards should be applied uniformly across all industries - applicable to the mining industry NB!

• Enshrine protection of whistleblowers - current Bills punish whistleblowers

• Bill should not make provision for the proliferation of the nuclear industry but rather show a commitment to scaling down and closure of the industry in favour of renewable energy - in line with overseas trends

• Apparent lack of government co-ordination in these issues should be addressed through the calling of the nuclear summit (e.g. radioactive waste management)