Why? Is the question to ask of governments and the "Radiation Health authorities" within the various State and Federal Health departments.

I am not aware of any significant "incident" pertaining to the storage, shipping or use of uranyl acetate here or anywhere. The Queensland legislation pertaining to this substance was brought in without any consultation, without knowledge of commercial realties, and with no idea of the importance of small quantities of UA to over a hundred sizeable laboratories serving many thousands of researchers annually.

Safety and health issues in regard to a "dangerous substance" are not necessarily satisfied by the application of onerous regulatory requirements and fees. Regulations and fees can encourage hording or dumping of the regulated substances and actually just increases cost and decrease safety. Over regulation may give the appearance that a public servant has discharged a duty, when there never was a safety or health issue and the appearance of "good regulatory control" is deceptive because the measures do not improve safety or health, but they are just another burden on science in Australia. To put it bluntly: science in Australia has been pummelled into dysfunction not only by years of budget cuts, but also by an incredible array of shipping and quarantine regulations. The legislation and fees affecting UA are only the latest example of inept legislation.

What is uranyl acetate? UA is a water soluble uranium compound made from depleted uranium. Depleted uranium has small fractions of the U235 isotope removed, which could be used to make an atom bomb. For radiation health purposes, there is little difference between depleted and non-depleted uranium. UA's use in electron microscopy is as a "stain" - actually it increases electron scattering and thereby greatly increases the contrast and visibility of specimens. Users usually float prepared specimen discs on a single drop of solution. Electron scattering is atomic number dependent and since uranium is the highest naturally occurring element, it has been proven most suited. Other elements above lead are also radioactive and lead is in fact commonly used as a double stain with UA. Effectively, electron microscopy of biological specimens cannot do without UA.

In recent times we have imported about 14 jars of UA annually (usually two at a time). We probably supplied almost all UA used in Australia and much of New Zealand's too. Each jar contains 25g of powder. The compound contains about 13g of uranium per jar. A jar of UA costs just over A$100 in the USA. Our last price, which included shipping in and out and also a $45 per jar permit tax, was $173. To conform with the new Queensland legislation and the Federal permit requirements, we would need to charge at least $400 per jar and this would include very little towards the additional administration. The high price would muddy our name and so we have reluctantly decided that we can no longer import, export and distribute UA. We will however, drop-ship as indicated above - until some time in the future, when we will have politicians who don't accept the advice and drafted legislation presented by thoughtless public servants.

What does the new legislation require? The Radiation Safety Act 1999 deems a quantity of uranium 238 (depleted U consists mostly of that isotope) as radioactive if:

1. the concentration of the uranium is equal to, or more than, 10 Bq/g; and
2. the activity of the radionuclide is equal to, or more than, 10 kBq.

Note that 1g of UA just exceeds that definition.

To conform with the Act, we, as a mere supplier would need to:

1. Apply for a licence to possess uranium for the purpose of storage.

Note this licence costs $340 and is valid for three years.

2. Develop a Radiation Safety and Protection Plan.

Note: The guidelines for developing this "plan" are 14 pages of mostly highly irrelevant material.

3. Apply for the appointment of a Radiation Safety Officer.

Note: This normally requires a course to be undertaken and the application form consists of another five pages of mostly completely irrelevant material. (See relative dangers below)

4. Submit an Application for Approval to Acquire an Unsealed Radioactive Substance. This is a two-page form and can be valid for the period of the licence to possess.
5. Apply for Approval to Relocate a Radiation Source outside Queensland for every sale to an interstate address. This is a two-page form.

6. Obtain a Certification of Premises Compliance for our uranyl acetate store and a listing of staff that may have access to the UA.

Relative Dangers: Basic requirements, such as water, oxygen, nitrogen and carbon can be dangerous to life. Similarly, radiation can be adverse and beneficial, but radiation especially has to be evaluated in terms of relative risk. UA radiation is not beneficial, but it has to be seen in context and relative to other dangers. Queensland's in particular, but also the Australian legislation uses a very low radiation level as the definition of a radioactive substance and then treats 13 gram and 1000 ton shipments identically.

1. Legislation controlling a substance with severe protocols and ensuing cost is justifiable only if it can be shown that there is a reasonable danger to individuals and the public, which is likely to be averted through such controls. Obviously, chances are low that a danger will be averted because, to the best of the writer's knowledge, there has never been an "incident". I have managed three electron microscope laboratories over a period of 28 years and have been in EM commerce full time for an additional 8 years. Over 26 years ago I wrote the first scientific publication drawing attention to the dangers of UA (mostly as a kidney poison (chemical toxin) and not nearly so much radiologically).
2. It only makes sense to tightly control a substance if this is more dangerous than other non-controlled substances. It is difficult to compare radiation dangers with chemical toxicity, however, it should be noted that IATA regulations allow UA to be shipped as normal airfreight and also as postal articles - not as Dangerous Goods. Why have State and Federal Radiation Authorities decided to better IATA regulations? Why can an item be shipped as freight without further packing restrictions, when a legitimate business is effectively barred from handling it? Why control the commerce of a substance like UA. In our business a jar or two of UA would sit on a shelf (packed so it could be THROWN on the floor. Sitting on a shelf is not a danger, if there is a danger, then it would be in transit, where for instance a truck could back over a parcel. Because Queensland's Radiation Health Unit cannot control worldwide shipping, they have, disingenuously, targeted storage which patently is the safest link in the chain from mining to end-use.

The points raised under "A" mean that there has probably never been an incident with UA anywhere when used in electron microscopy. Any serious incident would have been written up in EM Journals and thoroughly discussed on the Microscopy Listserver, which has over 3000 subscribers.

Furthermore, if there had been an "incident", the question should be asked, would controlling the substance under the Queensland legislation have prevented its occurrence? There is nothing in the legislation that would prevent people from doing stupid things, but more stupid things can be achieved with diesel fuel and ammonium nitrate fertilizer for considerably less money. However, a trader is not going to throw out valuable stock (there is no expiry date) or remove it from the packaging and break the little jar. With no improvement in safety likely to be achieved through this legislation and with no history of a single incident, the control of such a marginal radiation hazard has no useful purpose. The legislation seems to have been invented to produce jobs - for the "Radiation Health Unit".

Question: Who else had input into producing this legislation?

Point "B" is concerned with relative risks or dangers. A few physical factors: Our UA is packed into a small jar, which is sealed in a heavy aluminium envelope. Gamma rays able to pass through the glass would generate various X-rays. The Al envelope would ensure that almost all X and gamma rays are turned into Al X-rays. So K-alpha X-rays of Al would be the most powerful of these, but they are much weaker than the original gamma rays and cannot penetrate the outer packing, which is a tightly closed metal can. The reality is that our smoke detector emits more, and more powerful, radiation than the can containing 13g of uranium 238. Those detectors typically emit 1 mcurie of Americium 241, but they are not shielded like our UA is. In radiation terms, it's like 2 grams of UA lying on a bench without shielding. Frequently, a supermarket will have a dozen smoke detectors lying on a shelf, which is rather worse than 50g of UA without shielding. Worse still, if sufficient Americium from smoke detectors was collected this could be used to build a nuclear device.

Question: Why are smoke detectors not controlled Radiation sources?

Since UA is well packed and almost no radiation is emitted, then arguably the item should therefore not be controlled. If the packing of UA is seen as irrelevant, then any granite outcrop contains more uranium. In fact the legal definition of a radioactive substance is so low, that a collection of just a few uranium-rich rocks would need to be controlled. Since radiation is used as a scare word, we should compare the amount of uranium in a jar of UA with other quantities handled in Australia. Seawater contains 0.00015g U per ton. So a square km of ocean, to a depth of just one meter, contains more than 150g of Uranium or the equivalent uranium as is contained in 12 jars of UA. There is considerable irony that Australia, the world's second largest exporter of uranium, is making the importation of trifling, but urgently required quantities of a uranium compound all but impossible.

Question: How did our annual quantities of imported UA compare with the quantities "accidentally" released into the World Heritage listed Kakadu; one thousandth or one millionth?

IATA regulations allow "unlimited quantities" of UA to be shipped in an "excepted package", provided that:

the packaging bears the marking "RADIOACTIVE" on an internal surface in such a manner that a warning of the presence of radioactive material is visible on opening the package.

Note: Categorization, Labelling and Shippers Declaration are NOT required.

IATA is not concerned about UA in terms of radiation since radiation from the sun at high altitudes is an infinitely greater concern to frequent travellers than a cargo hold filled with packed UA. What if there was a crash? Again IATA should have great concerns about the uranium carried in jumbo jets. The designers found uranium metal the most useful (and cheapest) heavy metal and so incorporated 370kg into the tail fin. That is the equivalent of 24,666 jars of uranyl acetate! There is no basis of comparison between the laboratory use and the commercial distribution of UA and the use of depleted uranium in projectiles by several armed forces; the consequences of using uranium weapons on soldiers and civilians are mind numbing.

The danger from water insoluble uranium and its compounds is not so much from radiation but from tiny uranium particles, which may be lodged in the lung. These produce the heavy gas, Radon, as a decay product, which causes lung cancer. Radon is the killer of underground miners (thousands died from mining in the 40th and 50th in Ontario alone), or even inhabitants of granite cottages. Happily UA is fully water soluble, so it does not lodge in the lung and is very unlikely to cause these cancers. Also, UA is not a cumulative toxin, so it is not concentrated in the food chain nor would it cause pathological conditions due to increased levels from ongoing minor exposures.

Question: Why is the Radiation Health, Environmental Health Unit not impounding those jumbos at the airport? Imagine a crash at take-off or landing with 370 kg of uranium ground to dust or turned into smoke particles by fire in an urban area. Why is the legislation not protecting the public from this unlikely, but very real and catastrophic danger? Why are they wasting our time fiddling with bits of paper concerning grams of a soluble uranium compounds?

Considering the quantities of UA we have handled, the perfect safety record, the effective packaging, the mature judgement of IATA and foreign Governments, we must wonder why the Queensland Government has introduced these fancy and expensive requirements and the Federal Government collects those greedy fees?

Contrast our few jars of UA with the abundance of uranium in nature. Think of the comparative dangers involved in handling and trucking thousands of 200kg drums of uranium oxide "yellow-cake" (which has similar radiological and physical properties as does UA) across Australia. Then think of the uranium-carrying jumbos and its obvious that the current Federal and State legislation pertaining to UA in small quantities is high farce.

Unfortunately, it is also an impediment to research in Australia, but facilitating research has not been a consideration in Australia for many years now; only lip service to developing "Hi-tech or smart technologies" is paid, but government actions create nothing but impediments. Governments have found it convenient to collect taxes under the guise of fees and permits. "User Pays" is nonsensical when there is no demonstrable utility for a particular service. Not truly required, but demanded "services" are an impediment to employment, industry and commerce. They are one of many reasons why Australia is becoming less competitive despite the ever decreasing value of the A$. It is a common failure of all Australian Governments that "civil servants" can freely invent "requirements" and charge usurious fees for any such "services".

I have already wasted weeks of my time on this issue, but all Australian EM labs will need to forthwith waste much more time and money as well. If you think that I am wrong, then please show me the evidence to justify the now current legislation, the rules and permit requirements. I have invited the Federal and Queensland Radiation Authorities to supply a rebuttal, which I would be happy to publish here.

Jim Darley
(Proprietor) ProSciTech

No reason or a rationalization to justify the Federal or the State legislation has been received from the "responsible" agencies. The Queensland Radiation Health Unit was specifically advised of this posting, but has never responded. Through the Microscopy Listserver, I have asked to be advised of any radiation "incident" anywhere, which involved UA. There has been no response.

I also asked to be advised of any permit system anywhere involving UA; apparently they do not exist.

At last we have found something where Australia is leading the world: permits, rules and fees, not required to solve a problem, but to satisfy a bureaucracy's urge.