Professor William Reville:

I thank the Chairman for inviting us here to talk about this Bill.

I am the chairman of the board of the Radiological Protection Institute of Ireland, RPII. I am accompanied by my fellow board member, Mr. James Fitzmaurice. I thank the committee for inviting us here to talk about the Radiological Protection (Miscellaneous Provisions) Bill 2014, which provides for the merger of the RPII and the Environmental Protection Agency, EPA. I find it heartening to participate in an exercise that involves the rational examination of legislation. If the arguments we present are deemed to be of merit, I hope the Oireachtas will agree to make some amendments to the Bill.

The board of the RPII is deeply puzzled about why the Government is insisting on a merger. When this idea was first mooted several years ago, the possible advantages of it were considered in detail. The board of the RPII could identify few, if any, advantages of such a merger. It was able to identify many disadvantages, however. For that reason, it recommended to the Minister in 2011 that a merger of this nature should not happen. The matter was further considered in 2012 when a critical review of the potential of the amalgamation of the two bodies was produced by the Department of the Environment, Community and Local Government. The review identified few, if any, advantages but many disadvantages and recommended that the merger should not take place. We all thought that was the end of the matter until the Department of Public Expenditure announced out of the blue that the merger should happen quickly. This was not expected by us. We can identify no real advantages of this proposal. Instead, we suggest that many disadvantages, dangers and hazards are associated with this merger. Perhaps we can elaborate on them during the question and answer session.

While this is commonly referred to as a merger, that is not an accurate description of what is happening. In fact, the RPII is being taken over by the EPA. The RPII is to be dissolved and all of its functions are to be incorporated into the EPA. We understand that many people would naturally think that a marriage between two organisations that are involved in dealing with the environment could be a good thing. That is a misunderstanding of what is happening here. While both organisations deal with environmental matters, the actual roles and functions of the RPII and the EPA are quite different. By and large, the RPII is involved in protecting people against radiation hazards in their environment, whereas the EPA is involved in protecting the environment from being damaged by human activities. As these two types of work are different, they require different approaches. They are viewed in a different light by the stakeholders involved with the RPII and the EPA, respectively. The ideal situation is actually the situation we have now, in which these two environmental functions are separated into two distinct national bodies. This situation obtains in many, if not most, European countries. It is a disadvantage, rather than an advantage, to merge the two organisations. The situation as we have it works well. The RPII works well and I assume the EPA works well. I have heard no criticism of the EPA. The merger of the two organisations offends the basic principle of common sense that "if it ain't broke don't fix it". There is nothing broken about the situation as it is. It is actually the optimum situation.

Having said all of that, of course the board of the RPII recognises the prerogative of the Government to organise these matters as it deems fit. We have many misgivings about the merger - we do not think it is a good idea for radiological protection - but if it is to happen, the only consideration of the RPII board will be to ensure it is arranged in a way that will allow radiological protection to continue to be administered at the high level of quality that obtains at present. I have to admit the Department was not deaf to the representations we made as the Bill was being drafted. Some of the provisions in the Bill were included on foot of the board's encouragement or prompting. Unfortunately, we failed to persuade the Department that some matters we consider very important - the name of the new organisation and the basis on which the arm of the new organisation that will deal with radiation will be established - should be incorporated into the Bill.

The proposed name for the merged organisation is the "Environmental Protection Agency". We think the decision not to include a reference to "radiation" in the name is a bad thing. At the moment, an independent institute - the RPII - deals on a national basis with the organisation of radiological protection. It is known and respected internationally. Of course the people of Ireland and our stakeholders know all about it. That is to disappear. It is proposed that there will be no reference at all to "radiation" in the name of the new organisation. If this proposal is implemented, radiation advice and regulations, etc., will issue from the EPA. I appreciate that it is proposed to set up a new office - the office of radiological protection - within the EPA. When Michael Murphy or someone else is reading out the news about a matter of national importance - for example, the public might badly need to hear some advice about a radiation cloud that is overhead - the announcement will begin with a phrase like "the EPA this morning declared".

The loss of the existing branding in the name of the merged institution will be bad for the profile of radiological protection, which is currently very healthy. It was never stronger than it is now, having been built up patiently by the RPII over 25 years. It is well known internationally. I do not doubt that if this branding is wiped out, it will have a bad effect on the profile of radiological protection in this country. If this area is covered one day by a national institute with its own name - the RPII - but that institute ceases to exist the next day, it is common sense to suggest that this will be perceived as a diminution in the importance accorded to radiological protection. If this merger is to proceed, we would like the name of the proposed new institute to be amended to include a reference to "radiation". This could be done very simply. The name "Environmental Protection Agency" could be changed to "Environmental and Radiological Protection Agency" or some equivalent name.

The Bill proposes that radiological protection in the new body will be administered by a new office to be created within the EPA and to be called the office of radiological protection. If this merger happens, it will be a huge change for the RPII. It will be part of a body that has a completely different culture and an executive board. Our board is non-executive. It will be a shock to the RPII to be part of the new body. It will take a number of years for it to settle down.

The culture of the EPA is that its individual offices are quite flexible. Under the eye of the CEO of the EPA, functions assigned to different offices can change. I have heard noises already that what will be established as the office of radiological protection could change after a year or so. It will take several years for the Radiological Protection Institute of Ireland to bed down properly and it is important that there would be no chopping and changing during that period. To ensure that is the case, we would like the office of radiological protection to be established in legislation. That does not mean it could never be changed but it would not be changed quickly. A good period should be allowed to elapse before any chopping and changing would occur within the EPA.

Those are two amendments the board would like to see if the merger is going ahead, in order to give a good chance that radiological protection will proceed into the future with the same level of efficiency and expertise that it has at present.