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Full text of "Report of the Royal Commission on the Health and Safety of Workers in Mines."

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The Law Foundation of Ontario & the Ontario Council of University Libraries 



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Commission on 
the Health and 



in Mines 



-n A u ^ f Government 

Publications 

R H PORT () J I H F: royal. C O M M I S S I O N ON T H E 
HEALTH AND SAFFTY OF W O R K F R S IN MINF:S 



Report of the 

Royal Commission on the 

Health and Safety 

of Workers in Mines 



James M. Ham 
Commissioner 



Frederick R. Hume, QC 
Counsel 



Dr Cameron C. Gray 
Medical Consultant 



Arthur L. Gladstone 
Executive Secretary 



Jean Beaudry 
Labour Adviser 



Edmund A. Perry, P.Eng. R. Peter Riggin 

Engineering Adviser Industrial Adviser 




Ontario 



^'*-i '" " 



Published by the 

Ministry of the Attorney General 

Province of Ontario 

Toronto. Canada 

© 1976 Government of Ontario 
Printed in Canada 




Ontario 



James M Ham 

Commtssionef 

Frederick R Hume Q C 

Counsel 

Arthur L Gladstone 

E«ei Litivf Secrpta'v 



The Royal Commission 
on the 

Health and Safety of 
Workers in Mines 



416/965-9512 



Suite 1320 
2 Carlton Street 
Toronto Ontario 
MSB 1J3 



To Her Honour, 

The Lieutenant Governor of 

The Province of Ontario 



May It Please Your Honour; 



On the 10th day of September, 1974, I was 
appointed Commissioner to investigate matters 
related to the health and safety of workers in 
mines. Having performed the duties as set out in 
the Order-ln-Council, I submit herewith my report. 



30 June 1976. 



J4^tMJL^ 



'James M. Ham, 



Commissioner. 



oc-2340/74 

Copy of an Order-in-Council approved by Her Honour the Lieutenant 
Governor, dated the 10th day of September 1974 

The Committee of Council have had under consideration the report of the 
Honourable the Attorney General, dated September 6, 1974, wherein he 
states that, 

WHEREAS this Government has concern in relation to the health of 
workers in the mines of this Province, and 

WHEREAS some reasonable doubt has been cast on the effectiveness of 
present safety programs, and 

WHEREAS it is thought fit to refer these matters to an Inquiry instituted 
pursuant to the provisions of The Public Inquiries Act, 1971, S.O. 1971, 
Chapter 49. 

The Honourable the Attorney General therefore recommends that pur- 
suant to the provisions of The Public Inquiries Act, 1971, S.O. 1971, 
Chapter 49, a Commission be issued to appoint Dr James Milton Ham, Sc. , 
Dr.:- 

1 . To investigate all matters related to health and safety involved in the 
working conditions and working environment in mines in Ontario; 

2. To identify the relevant data related to silicosis, lung cancer and 
other occupational health hazards of miners in Ontario; 

3. To review the present basis for Workmen's Compensation Board 
awards as they relate to environmental health matters affecting miners; and 

4. To make such recommendations in relation to 1 , 2 and 3 above as are 
by him deemed to be appropriate. 

The Honourable the Attorney General further recommends that all 
Government Ministries, Boards, Agencies and Commissions shall assist 
Dr James Milton Ham to the fullest extent in order that he may carry out his 
duties and functions and that he shall have authority to engage counsel, 
expert technical advisers, investigators and other staff as he deems proper 
at rates of remuneration and reimbursement to be approved by the Man- 
agement Board of Cabinet. 

And the Honourable the Attorney (General further recommends that Part 
HI of the said Act be declared to apply to the aforementioned Inquiry. 

The Committee of Council concur in the recommendations of the 
Honourable the Attorney General and advise that the same be acted on. 

Certified, 

JJ . Young 

Clerk, Executive Council 



Contents 



PREFACE IX 
1 

The issues in health and safety in the mining industry 3 

2 

SiHcosis and dust 18 

3 

Lung cancer and ionizing radiation in the uranium mines 66 

4 

Accidents and injuries 118 

5 

Other environmental hazards at the workplace 182 

6 

Policy for occupational health and safety in the mining industry 249 

APPENDICES 

a: Recommendations 261 

b: Briefs and presentations before the Commission 278 

c: Radiogenic lung cancer in Ontario uranium miners 1955-64 319 

d: Statistical tables 330 

e: Studies conducted for the Commission 349 



Preface 



The report has the following structure. The first chapter identifies the 
agencies of government, industry, and labour concerned with the health 
and safety of workers in mines, illustrates the kinds of injuries and disease 
that produce loss of well-being, and points towards the issues of policy that 
underlie the report. The subsequent chapters on 'Silicosis and dust,' 'Lung 
cancer and ionizing radiation,' 'Accidents and injuries,' and 'Other en- 
vironmental hazards at the workplace' represent case investigations of 
particular problems. The pattern of my recommendations arises out of the 
concrete context of these analyses. The concluding chapter explains the 
implications of these recommendations for provincial policy on occupa- 
tional health and safety and recommends a change in legal and administra- 
tive arrangements for the mining industry. 

The Commission established quarters, acquired staff, and began active 
work in mid-October 1974. Following an initial period of exploratory 
investigations in mines and plants and with agencies of government, indus- 
try and labour, the first period of hearings was initiated in Elliot Lake on 14 
January 1975. These hearings were held in the northern communities of 
Elliot Lake, Red Lake, Thunder Bay, Sault Ste Marie, Sudbury, Timmins, 
and Kirkland Lake, and in Toronto and Ottawa. 

Following the first period of hearings, which was substantially com- 
pleted in mid-February 1975, the Commission extended its investigations 
and initiated research on industrial disease and injuries. The second and 
final period of hearings was held in Toronto from 26 May to 6 June 1975. 
Thomas Conlin acted as court reporter. A list of all briefs presented to the 
Commission together with cross references to the transcript of the hearings 
is given in appendix b. This material has been filed for public reference in 
the Provincial Archives of Ontario. 



X Preface 

The Commission is indebted to a host of persons in the mining com- 
panies, the unions, and ministries of government and to individuals who 
contributed information and understanding in the course of the hearings 
and associated investigations. Not least important has been the rewarding 
personal experience of meeting miners at work. In the Province the Mines 
Accident Prevention Association, the Mines Engineering Branch in the 
Ministry of Natural Resources, the Ministry of Health, the United Steel- 
workers of America, and the Workmen's Compensation Board assisted the 
Commission continuously. The work of the Commission benefited from 
consultations with the staff of the Atomic Energy Control Board and of 
Atomic Energy of Canada Ltd. 

In November 1975 the Commission visited mines, labour unions, and 
government agencies responsible for occupational health and safety in 
Sweden and the United Kingdom, and consulted the International Labour 
Office and the World Health Organization. Dr Cameron C. Gray, medical 
consultant, made visits to specialists in occupational medicine in Germany, 
the United Kingdom, and the usa. 

During the fall of 1975 and the spring of 1976 the research projects were 
completed. Studies conducted for the Commission are listed in appendix e. 
Appendix c interprets the evidence obtained for risk of lung cancer in 
relation to radiation exposure among uranium miners on the Uranium 
Nominal Roll. The related mortality experience of these miners is dis- 
cussed in chapter 3. This project was supervised for the Commission by 
Professor David Hewitt, Department of Preventive Medicine and Bio- 
statistics, University of Toronto, with the personal co-operation and assis- 
tance of John Silins, chief. Vital Statistics Section, Health Branch, Statis- 
tics Canada; the Registrars General of all the provinces; W.C. Wheeler, 
supervisor. Statistical Analysis Section, Workmen's Compensation 
Board; Dr Jan Muller, chief. Environmental Health service, Ministry of 
Health; Dr Charles Stewart, chest disease consultant. Workmen's Com- 
pensation Board; and Peter McCrodan, Director, Mines Engineering 
Branch, Ministry of Natural Resources. I am deeply grateful for the spirit 
of co-operation that made this study possible in the short time available to 
the Commission. It is imperative that this study be extended to gain the full 
benefits of Ontario data. 

Finally, I owe a personal debt of gratitude to each of the persons as- 
sociated directly with me in the work of the Commission. Each has contri- 
buted unstintingly to the objectives and to my understanding. Frederick R. 
Hume QC, the counsel, is a principal in the firm of Hume, Martin, and 
Timmins. Dr Cameron C. Gray, the medical consultant, is executive vice- 



XI Preface 

president of the Ontario Lung Disease Association and associate professor 
in the Department of Medicine, University of Toronto. Jean Beaudry, the 
labour adviser, is a member of the staff of the United Steelworkers of 
America. Edmund A. Perry, the engineering adviser, is a representative for 
the mining branch on the Council of the Association of Professional En- 
gineers of Ontario. R. Peter Riggin, the industrial adviser, is vice-president 
corporate relations, Noranda Mines Ltd. The executive secretary, Arthur 
L. Gladstone, managed the operations of the Commission in an exemplary 
manner and provided stimulating criticism of the formulations of the is- 
sues. Michael Evans and Daniel Pearlman ably served for a time on the 
staff of the Commission. Marilyn Lefolii and Marilyn Flynn meticulously 
prepared the report from handwritten manuscript. I am grateful to Larry 
MacDonald of the University of Toronto Press for carefully editing the 
report. 

Frederic LePlay, a distinguished French sociologist and inspector gen- 
eral of the mines of France in the late nineteenth century, said that the most 
important thing to come out of mines is the miner. I share his conviction 
today. 



RHPORI Oi IHH ROYAL COMMISSION ON I HI 
HFAI/IH AND S A F I{ r Y O I WORKI-RS IN MINIS 



1 

The issues in health and safety 
in the mining industry 



THE NETWORK OF RESPONSIBILITY 

Intense public concern about the effect of human activity on the quality of 
the outer environment of air, land, and water has developed within the past 
decade. There is now a growing concern about the health and safety of 
persons at work in the inner environment of their working places in indus- 
try. The hearings and investigations of the Commission have confirmed 
that this concern, when focused on the health and safety of workers in our 
mines, is well justified. 

In Canada the ownership of mineral resources and the control of their 
extraction, except for uranium, is vested under the British North America 
Act in the provinces. In Ontario the statutory basis for health and safety 
provisions in the mining industry can be found in the Mining Act, and in 
particular in Part ix.^ Part ix of the Mining Act places upon the manage- 
ment of a mine the responsibility to ensure that its provisions are met.^ 
Equivalent legal instruments in many countries do likewise. In the hearings 
before the Commission this managerial prerogative has been challenged. 

Since ores of uranium are mined in Ontario and since the respiratory 
diseases of lung cancer and silicosis among workers in the uranium mines 
have been of special concern in hearings before the Commission, the 
exceptional federal jurisdiction relating to the extraction of uranium is 
important. With the advent of nuclear weapons and of nuclear power, the 
Government of Canada exercised an imputed right, under a general provi- 
sion of the British North America Act regarding 'peace, order and good 
government,' to assume control of the extraction of uranium ores. This it 
did by passing the Atomic Energy Control Act, which is administered by 
the Atomic Energy Control Board. ^ The Board has exercised its authority 



4 The health and safety of workers in mines 

under the Act to issue licences for the operation of uranium mines in 
Ontario, one provision of which invokes provincial regulations concerning 
the health and safety of workers at these mines/ The regulations under the 
Atomic Energy Control Act also include allowable exposures to radiation 
for workers designated as radiation workers. 

The role of the Board in matters of health and safety in uranium mines in 
Ontario will be considered in this report. The special circumstances for 
uranium notwithstanding, the administration of the Mining Act by the 
Ministry of Natural Resources (and formerly the Department of Mines) 
provides the basic structure of regulation and enforcement. Enforcement 
of Part IX of the Mining Act is carried out under Section 610 by an 
inspectorate consisting primarily of professional engineers under the tech- 
nical direction of the director of the Mines Engineering Branch in the 
Ministry of Natural Resources. The role, composition, and performance of 
this inspectorate were strongly criticized in many hearings before the 
Commission. The functioning of this inspectorate will be reviewed. 

When the Commission began its work in October 1974, the role of the 
Ministry of Health in relation to mines and mineral plants was to provide 
assistance to the Ministry of Natural Resources on the basis of requests 
received. Through this administrative practice, the Occupational Health 
Protection Branch of the Ministry of Health and its forerunners have 
played an important but undesirably restricted role in health problems of 
mine workers. The role of an Occupational Health Authority will be 
considered. 

When a person is injured in an accident at work or contracts an industrial 
disease attributable to conditions at the workplace, he receives partial 
wage compensation and related medical and rehabilitative services through 
the Workmen's Compensation Board, which administers the Workmen's 
Compensation Act.^ The Board, which is responsible to the minister of 
labour, receives claims for accidents and diseases associated with the 
conditions and place of work and establishes administrative practice for the 
compensation of diseases and accidents. The adequacy of the basis for 
compensation used by the Board in relation to certain occupational health 
hazards in mines was challenged in the public hearings before the Commis- 
sion, and in accordance with the terms of reference some recommenda- 
tions in this regard will be made. 

Under Section 119 of the Workmen's Compensation Act, 'the em- 
ployers in any of the classes for the time being included in Schedule 1 may, 
with the approval and under the control of the Board, form themselves into 
an association for the purposes of education in accident prevention.' The 



5 The issues in health and safety 

employers under Class 5 of Schedule 1,^ consisting mainly of mines and 
their associated plants, formed in 1930 what is now called the Mines 
Accident Prevention Association of Ontario. Membership in the mapao of 
all employers under Class 5 is obligatory. This association is one of a 
number of organizations formed in a similar fashion in other sectors of 
industry. The operations of the mapao are funded by the Workmen's 
Compensation Board from the levies against employers authorized under 
the Act. 

Closely related to the mapao, and indeed sharing the services of the 
same executive director, is the Ontario Mining Association, a voluntary 
industrial association of corporations operating mines, reduction plants, or 
like businesses. The oma is the older organization, and the mapao was 
formed on its initiative. 

These are the major institutions for the involvement of government, and 
for the collective involvement of industry, in issues related to the health 
and safety of workers in mines. Each of them has been subjected to sharp 
criticism by labour unions, and particularly by the United Steelworkers of 
America. To investigate this criticism the Commission has found it helpful 
to use the concept of a responsibility-system for health and safety encom- 
passing the roles of all parties involved. The scope of this responsibility- 
system is related to five basic factors which, in the Commission's opinion, 
together determine the levels of occupational risks in our mines. Whether 
in the home or the factory, on the highway, or in the mine, there is no 
attainable state of absolute health and safety. There are levels of risk ac- 
cepted or tolerated to a degree by the parties concerned. Mines can only 
exist where economically viable operations can be conducted. Within 
operating mines, the acceptable levels of occupational risk are determined 
by: 1/ the quality and kind of industrial management and supervision: 2/ the 
degree of participation and commitment from employees, individually and 
collectively in labour unions or otherwise; 3/ the state of social expectation 
and concern in mining communities and in the public at large: 4/ the 
measure of political attention as expressed in legislation, in the related 
governmental administrative practices for monitoring compliance, and in 
the provision of compensation; and 5/ the combined effectiveness of the 
above parties in operating as a system. 

Underlying the first four factors is a complex structure of relationships 
between worker, supervisor, management, union, industry, government, 
and the public. The following sections of this report, in attempting to assess 
the many allegations that have been levelled at the current responsibility- 
system, will look in some detail at the sources of specific problems of health 



6 The health and safety ot workers in mines 

and safety now existing in our mines. The object of these studies is to 
clarify the role and future responsibility of the participants. 

The responsibility-system seems to have been lacking in two significant 
ways. First, divided jurisdictions have made it unclear where the initiative 
necessary to deal with problems is to be taken. Second, the worker as an 
individual and workers collectively in labour unions or otherwise have 
been denied effective participation in tackling these problems; thus the 
essential principles of openness and natural justice have not received 
adequate expression. Participation may be understood in terms of the 
following three major elements: 1/ knowledge - having ready access to 
information about actual and expected conditions at the workplace, and 
about the state of the health of the workers; 2/ contributive responsibility - 
to provide individual and collective insight on problems on the basis of 
knowledge and work experience; and 3/ direct responsibility - to make 
operative decisions that influence conditions at work. 

^ The problems of the health and safety of workers in mines discussed in 
this report are probably not peculiar to the mining industry. 

THE INDUSTRY, THE WORKPLACE, 
AND THE HAZARDS OF WORK 

Mining is concerned with discovering and delineating useful bodies of 
materials in the earth's crust, and with removing and processing such 
materials into economically viable primary products. In Ontario the mate- 
rials mined are grouped as metallic, non-metallic, structural, and fuels. "^ 
Metallics include uranium oxide and such metals as nickel, copper, iron 
and gold; non-metallics include gypsum, salt, sulphur, and asbestos; struc- 
tural materials include sand, gravel, clay, and stone; fuels include coal, 
natural gas, and petroleum. Briefs to the Commission associated with 
specific mining operations related entirely to the mining and processing of 
metallic and non-metallic materials. The substance of this report is there- 
fore addressed to the problems of health and safety in these sectors of the 
industry, which currently employ some 38,000 persons.^ 

The geographical distribution of current metallic and non-metallic min- 
ing operations is shown in Figure 1 . This sector of the industry accounts for 
about 85 percent of the gross value of all mineral production, which in 1974 
toalled $2.5 billion and represented 4.5 per cent of the Gross Provincial 
Product. 

Currently, the workers at metallic and non-metallic mines are employed 
by forty companies operating sixty-three underground or open-pit mines 



7 The issues in health and safety 




FIGURE 1 Geographical distribution of current metallic and non-metallic mining 
operations in Ontario. 

and related ore processing and refining plants as grouped in Table 1. The 
contractors are private operators hired by the mines to conduct diamond 
drilling for the delineation of ore bodies and to sink shafts and develop 
headings as part of mine development. 

Well over one-half of the workers are in the nickel-copper mines concen- 



8 The health and safety of workers in mines 



TABLE 1 

Distribution of employees by material mined and by contractor type as of December 1974 



Type of 


Companies 


Mines 


Employees 


Employees 


material 


(N) 


(N) 


(N) 


(%) 


Metallics 










Nickel-Copper 


4 


25 


23,500 


61.8 


Iron 


7 


8 


3,700 


9.7 


Gold 


8 


9 


3,400 


8.9 


Copper-Zinc 


8 


8 


3,200 


8.4 


Uranium Oxide 


2 


2 


1,630 


4.4 


Magnesium 


1 


1 


300 


0.8 


Silver 


2 


2 


150 


0.4 


Total 


32 


55 


35,880 


94.4 


Non-metallics 










Salt 


2 


2 


450 


1.2 


Nepheline Syenite 


2 


2 


200 


0.5 


Asbestos 


2 


2 


170 


0.4 


Quartz 


1 


1 


80 


0.2 


Talc 


1 


1 


40 


0.1 


Total 


8 


8 


940 


2.5 


Contractors 










Sinking and 










development 






780 


2.0 


Diamond drilling 






400 


1.1 


Total 






1,180 


3.1 


Over-all total 


40 


63 


38,000 


100 



note: Employees in Class 5 under the Regulations of the Workmen's Compensation Act, 
excluding prospectors. Numbers of employees are rounded. 

source: Mines Accident Prevention Association of Ontario, Animal Report, Toronto, 1975, 
19-20; and company reports to the Commission. 



trated in the Sudbury basin. Workers in the uranium mines now represent 
just over 4 per cent of all employees, and all of the non-metallic mines 
together employ just over 2 per cent of workers. The gold mines, which 
historically were the major source of the industrial disease silicosis, em- 
ployed some 75 per cent of workers in 1940 but currently employ only 9 per 
cent. 

Table 1 indicates a great variety in the number of employees per com- 
pany. This wide range of scale extends to the number of employees active 
at the different types of workplace within corporate mining operations. The 
employees at a given operation may be divided into five categories of 



9 rhc issues in health aFid safely 

personnel. These are management/supervisory, accounting for 10 per cent 
of the total, clerical (5 per cent), engineering/technical (5 per cent), skilled 
trades (15-45 per cent) and semi-skilled and unskilled (65-35 per cent). The 
lower percentage for skilled trades and the higher percentage for semi- 
skilled and unskilled is attained at operations concentrating on under- 
ground mining. 

Workplaces and their hazards 

The employees of a producing mining property which is developing, for 
example, a metallic mineral body are distributed among the following 
characteristic operations, all of which may not be conducted at a single 
geographical location: 1/ drilling a pattern of holes in the ore; 2/ breaking 
the ore by loading the drilled holes with a blasting agent and firing the 
round; 3/ collecting the broken ore (muck) and transporting it to a primary 
crusher; 4/ transporting the crushed ore to, and passing it through, a 
sequence of secondary crushing and grinding operations to produce a 
mixture of fine particles; 5/ separating the particles of valuable mineral 
from the particles of waste material in the ore by gravitation, flotation, or 
related methods to produce a mineral concentrate; 6/ extracting the valu- 
able fraction of the mineral by pyrometallurgical or hydrometallurgical 
treatment of the concentrate, followed by refining to produce primary 
metal; and 7/ managing and servicing the above operations. 

These operations may be grouped to define four types of workplaces, 
which are characterized by distinctive hazards to health and safety and for 
which accident statistics have been segregated. Operations 1 to 3 inclusive 
are characteristic of mining both in underground mines and open pits; 4 to 6 
inclusive occur in reduction plants usually located on the surface; and 7 
represents, in addition to the administrative centre of the mining operation, 
technical shops, private railways, and related road transportation systems. 

Table 2 gives the approximate current distribution of the workforce in 
the metallic and non-metallic sector of mining by the above types of 
workplace. Within a particular mining operation the percentage distribu- 
tion may vary significantly from the averages shown for the whole sector. 
The high percentage in servicing is indicative of the high measure of 
mechanization in the industry in Ontario. 

The extraction of ore involves the continuous development and exten- 
sion of a network of passages, known as shafts, crosscuts, and drifts, and of 
rooms in the ore body and associated waste rock, known as stopes. The 
pattern of this network in any given mine depends on the orientation, 
shape, and size of the ore body and on the method of mining adopted, such 



10 The health and safety of workers in mines 



TABLE 2 






Distribution of work force 


by class of workplace in 1974 


Workplace 


Workers (n) 


Workers (%) 


Mining 


14,000 


37 


Underground 


12,000 


32 


Open pit 


2,000 


5 


Reduction plants 


7,000 


18 


Total Mining and 






reduction plants 


21,000 


55 


Servicing 


15,800 


42 


Diamond drilling 


400 


1 


Sinking and 






development 


800 


2 


Total 


38,000 


100 



NOTE : Servicing places are those designated Shops and Surface 
by the Mines Accident Prevention Association. As noted in 
relation to Table 3, Diamond drilling and Sinking and develop- 
ment workers are associated with private contractors who 
contract with mines to develop shafts and headings for under- 
ground mines and to provide diamond drilling to delineate ore 
bodies. 

source: Figures derived from the Mines Accident Prevention 
Association of Ontario, Annual Report, Toronto, 1975, 14 

as room-and-pillar, cut-and-fill, and sublevel-caving. The rock surfaces of 
the network have properties peculiar to the geology of the ore and the host 
rock. These properties change from place to place within individual mines 
and between different mines, and so, therefore, do the day-to-day locations 
and surrounding conditions of workplaces. These circumstances make 
work in a mine singularly different from that at fixed and stable places such 
as factories. 

Because underground networks may extend for miles and ore extraction 
is highly mechanized, men are scattered widely, and the supervision of 
work is more difficult than in plants. Furthermore, in most but not all 
underground mines and open pits in Ontario, workers engaged directly in 
extracting and transporting ore are paid on an incentive-contract basis, 
providing a base wage supplemented by a bonus keyed to the production 
achieved on a shift-by-shift basis. Only a few workers in plants are paid this 
way. It has been debated whether or not the bonus system increases the 
likelihood of accidents. 

The potential hazards in the enclosed spaces underground are many. 
There is the threat of rock movement and of the fall of loose rock. The 



1 I The issues in hcallh and safety 

machines used in mining generate intense noise. The inherently destructive 
nature of blasting precludes the use of permanently installed lighting at the 
working face. The regular processes of drilling, blasting, mucking, and 
crushing generate fine respirable mineral dusts which are potential causa- 
tive agents in pneumoconiosis (literally 'lung-dust-disease'). Compressed 
air drills release oil mist; diesel engines emit soot and a complex variety of 
chemical particulates and gases. Development blasting and secondary 
blasting release significant amounts of dust and potentially noxious gases. 
The radioactive gases radon and thoron emanate from rock faces and arise 
from the elements uranium and thorium which are present in many rock 
formations, especially in uranium mines. Also, in the deepest mines, work- 
ing temperatures and humidity may be high. 

Whether or not these risks lead to accidents and industrial disease 
depends on a complex of factors, some of them determined beyond the 
workplace but many others depending intimately on how work is super- 
vised and performed. From the outside, statutory regulations establish 
standards for dust and other aerosols, for radiation, noise, exposure to 
chemicals, and for the safe development and operation of mines, mining 
systems, equipment, and services. Within a mine, the control of rock 
movement depends on mine design and rock-support methods such as roof 
bolting. The reduction of injuries from 'loose'^ depends on work practices 
in scaling the developing rock surfaces. The loading, hauling, and dumping 
of muck is a perennial source of accidents, prevention of which depends on 
skill and care in the use and maintenance of heavy machinery. The level of 
respiratory hazard from the air breathed at the workplace depends on the 
effectiveness of the ventilating system in diluting and sweeping out air- 
borne gases and particulates and upon such work practices as wet drilling, 
blasting at the end of shifts, and wetting down broken rock. Safety boots, 
hard hats, safety glasses, ear plugs, ear muffs, respirators, gloves, and 
special clothing are among the personal items of equipment used in mines 
to provide physical protection to the worker by 'enclosing* him. But not all 
workers are disposed to make meticulous use of such devices when they 
are available. 

In reduction plants the mineral materials being processed with various 
chemical reagents and heat are completely or partially enclosed within 
process equipment having, except for the use of cranes and the like, a fixed 
arrangement. Health and safety hazards distinctive to reduction plants are 
associated with the leaking or splashing of potentially dangerous materials 
into the work area. These materials include molten metals, chemical re- 
agents, and process gases such as sulphur dioxide and nickel carbonyl. 



12 The health and safety of workers in mines 

The reality of the hazards in the mines and plants is in the end deter- 
mined by the record of events. To complete a background for assessing 
how the responsibility-system has dealt with particular hazards, the spec- 
trum of accidents and cases of industrial disease compensated by the 
Workmen's Compensation Board in 1974 will now be reviewed. 

THE SPECTRUM OF ACCIDENTAL INJURIES AND CASES 
OF RECOGNIZED INDUSTRIAL DISEASE IN 1974 

The puipose of surveying industrial diseases at one moment in time is 
threefold. First, it places on public record a list of events in 1974 which 
resulted in a loss of well-being of workers attributable to the workplace in 
mines and plants as judged on the basis of awards made by the Workmen's 
Compensation Board. Second, it illustrates the distribution of such events 



TABLE 3 

Fatal accidents during the year 1974 in Class 5 of 
the Workmen's Compensation Act 



Workplace 


Fatalities 


Mining 




Underground 


15 


Open pit 


1 


Reduction plants 


- 


Servicing (shops and surfaces) 


- 


Contract diamond drilling 


- 


Contract sinking and development 


1 


Prospecting 


3 


Total 


20 


Cause 


Fatalities 


Haulage of material 


6 


Fall of ground 


5 


Fall of person 


3 


Explosives 


2 


Runs of Muck 


1 


Drowning 


1 


Fatigue 


1 


Suffocation 


1 


Total 


20 



source: Mines Accident Prevention Association of 
Ontario, Annual Report, Toronto, 1975, 16 



13 1 he issues in health and safety 



TABLE 4 

Non-fatal compensable accidents during the year 1974 in Class 5 of 
the Workmen's Compensation Act 







Injuries 






per million 






man-hours 




Injuries 


worked 


Workplace 


(N) 


(N) 


Mining 






Underground 


1,950 


90.8 


Open pit 


57 


13.9 


Reduction plants 


1,147 


89.2 


Servicing (shops and surface) 


403 


13.7 


Contract diamond drilling 


94 


85.0 


Contract sinking and development 


48 


27.9 


Prospectors, etc. 


119 


59.5 


Total 


3,818 


53.8 






Proportion 




Injuries 


of total 


Principal cause 


(N) 


(%) 


Slips and falls 


939 


24.6 


Over-exertion (primarily 






back injuries) 


681 


17.8 


Striking, struck by, objects 


651 


17.1 


Caught between objects 


418 


11.0 


Rock falls 


291 


7.5 


Falling objects 


220 


5.7 


Inhalation, contact 






absorption, ingestion" 


163 


4.3 


Extremes of temperature'' 


114 


3.0 


Flying objects 


90 


2.4 


Nails and splinters 


75 


2.0 


Runs of muck 


33 


0.9 


Explosives 


16 


0.4 


Other 


127 


3.3 


Total 


3,818 


100.0 



note: Compensable accidents entail an absence from work for one or more 

days following the date of the accident. 

a Including 107 instances of a foreign body in the eye, 15 instances of a 

caustic substance in the eye, 1 1 instances of inhalation of toxic gases and 

11 cases of contact dermatitis. 
b Including 66 incidents involving hot materials such as steam, liquids 

including molten metals, and 17 incidents with cutting and welding. 
source: Mines Accident Prevention Association of Ontario, Annual Report, 
Toronto, 1975, 14-15; and Commission research on compensable injuries 



14 The health and safety of workers in mines 



TABLE 5 

Recognized cases of industrial disease first compensated during 1974 in Class 5 of the Workmen's Compensation Act 



Cases 



Metal group 
charged 



Underground Reduction 
Unspecified or open pit plants 



Causative agent 



Silicosis Uranium 
Gold 
Other than uranium 

and gold 
Total 

Cancer Uranium 
Nickel 
Gold 
All other 

Subtotals 
Total 



21 
11 

10 

42 



20 

2 



Loss of hear ins; 



Rcspirable dust containing free silica 



UraniiDv: The major contributing caus- 
ative agent peculiar to the workplace is 
considered to be exposure to radiation 
from the disintegration products of radon 
gas called radon daughters. The eight 
cases of kmg cancer arc associated with 
seventeen uranitim mines opened at Ban- 
croft and Elliot Lake in the period 
1955-74. Only two of these mines are 
now operating. 

\ickc/: These cases, seven of which were 
sinus cancer and thirteen lung cancer, 
are associated with calcining, sintering, 
and cupola furnace operations in reduc- 
tion plants in the nickel industry. The 
operation of the processes involved was 
terminated at one location in 1958 and 
at the other in 1963. 
A/I other: The one case of lung cancer 
associated with an open pit was charged 
to an asbestos mine, and the two cases 
of lung cancer in reduction plants are 
currently associated with arsenic in a 
silver and cobalt oxide refinery that 
ceased production in 1961. 

Industrial noise 



note: Compensated cases of hearing loss included first disability awards only. 

sources; For silicosis: Mines Accident Prevention Association of Ontario, Annual Report, Toronto, 1975, 18, as updated to 
show the final figures for the year. For cancer: data provided by the Workmen's Compensation Board. For loss of hear- 
ing: Workmen's Compensation Board, Medical Statistics Unit. 



among workplaces by various causes where these are known. Third, it 
identifies the distinctive issues of policy that must be dealt with by the 
responsibility-system in recognizing and responding to accidents and in- 
dustrial disease. 

Practices in reporting accidents and industrial disease differ notably in 
different jurisdictions. It is important therefore to define clearly the condi- 
tions for the inclusion of an event in this review. Each event is one for 
which the Workmen's Compensation Board authorized payments in 
maintenance of partial wages or for pensions. Accidents involve traumatic 
events such as fractures, sprains, burns, and inhalations that occur at 
specific times at the place of work. Compensable accidents as listed in 



15 The issues in health and safety 

Tables 3 and 4 involve absence from work for one or more days following 
the day of the accident. 

Industrial diseases include respiratory diseases such as certain types of 
lung cancer, silicosis, asbestosis, other forms of pneumoconiosis, and loss 
of hearing. Although each of the cases reported in Table 5 was recognized 
for compensation for the first time in 1974, the elapsed time to recognition 
from initial exposure to the known or suspected causative agent(s) ex- 
tended over a period of years. For example, the average elapsed time to 
recognition from first exposure to respirable dust containing free silica for 
the twenty-one new cases of silicosis among uranium miners was twenty- 
four years. Since workers move from job to job, the exposure to dust of a 
given person may not all have occurred in Ontario, in one type of mine, in 
one particular mine, or at one class of workplace. Industrial disease of the 
types cited is experienced throughout the remaining life of the person and is 
attributed to past working conditions. Personal habits such as smoking 
modify and often greatly increase the likelihood of the onset of industrial 
disease. 

The accident experience for Class 5 under the Workmen's Compensa- 
tion Act for 1974 is summarized for fatal injuries (Table 3) and for non-fatal 
injuries (Table 4). The cases of industrial disease recognized in 1974 are 
listed in Table 5 with brief notes on causative circumstances. Not included 
in Table 5 are medical-aid-only events not entailing loss of a day at work but 
reported to the Board for payment of medical expenses, and that part of 
light-duty work assignments made by the employer which do not involve 
compensation by the Board. These classes of events will be considered in 
chapter 4. 

CONCLUSION 

The following chapters outline how management, labour, and government 
have dealt with, and how the Commission feels they should deal with, the 
ongoing pattern of work-related injury and disease as reviewed in the 
tables. Accidents and industrial diseases pose for the responsibility-system 
distinctive sets of questions of policy concerning principles and practices 
for identification, prevention, and compensation. These sets of questions 
will provide the framework for problem analysis. 

Let us briefly consider accidents. With the exception of symptomatic 
events such as back pain, accidents can be clearly identified as to time and 
place. Recognition for puiposes of compensation is readily effected once 



16 The health and safety of workers in mines 

identification with the place of work is made. The key problems lie in the 
complex human origins of accidents and in the policies adopted to prevent 
them. 

While careful design and effective maintenance of the work environment 
is important, relatively few accidents are the result of technical or physical 
defects that are independent of the personal act of work. The great majority 
of accidents arise out of the act of work itself. Hence the responsibility- 
system must have well-defined policies and practices with respect to the 
following subjects: the organization of work, the design of work practices, 
the performance of work, the supervision of work, the monitoring and 
control of the system of work, and the value system operative at the 
workplace. 

The worker and his immediate supervisor, the shift boss, are centrally 
involved in and share an inescapable measure of direct responsibility for 
working safely. That this is peculiarly true in mining is evidenced by the 
fact that when a shift boss visits a work crew all work stops while the 
situation is discussed. The Commission, having accompanied shift bosses 
through the tortuous drifts of gold mines and through the amphitheatre-like 
stopes of nickel mines to talk with the men, has become convinced that 
participative responsibility in the act of work is, and will remain, a key to 
accident prevention. 

Further, the hearings and investigations of the Commission have sug- 
gested that the basis of confidence for the exercise of this responsibility by 
the worker, the shift crew, and the shift boss is being eroded because the 
roles of the different parties in the responsibility-system as a whole are not 
clearly and mutually understood and accepted. Lack of information and of 
openness to the contributive participation of labour in the responsibility- 
system as a whole, changing attitudes in management, and a changing 
social basis for discipline at the workplace, all further erosion of trust. The 
worker, the shift boss, the union, and management must work together to 
restore a sense of mutual responsibility for working conditions. 

Let us now briefly examine the central questions of policy that are posed 
for the responsibility-system by industrial disease. Whereas accidents 
arise principally out of the personal act of work, industrial disease is related 
primarily to the environment of the workplace, which although influenced 
by work practices is largely beyond the control of the worker. Dust, 
radiation, noise, and noxious gases are intrinsic to mining. And major 
problems exist with respect to the identification, prevention, and com- 
pensation of industrial disease. To deal effectively with these, the 
responsibility-system must have well-defined policies and practices on 



17 The issues in health and safety 

the following operational questions: identifying disease attributable to the 
workplaee, identifying eausative agents and other hazardous substances in 
the environment of the workplaces, setting standards for hazardous sub- 
stances to prevent disease, monitoring concentrations of hazardous sub- 
stances at the workplace, ensuring biological surveillance of the state of 
health of the workers, identifying and diagnosing cases of disease, accept- 
ing cases of disease for compensation, and communicating information on 
these issues to the affected parties. The effectiveness of the responsi- 
bility-system in these matters depends critically on the quality and extent 
of statistical and personal records based on monitoring of environmental 
contaminants at the workplace and on biological surveillance of the 
worker. 

In the hearings of the Commission there were allegations that the 
responsibility-system has failed to develop and to exploit for the protection 
of the worker an adequate set of properly linked records, and further that 
workers have not had reasonable access to the studies that have been 
carried out. In reporting on the problems of silicosis and dust and of lung 
cancer and radiation, this central problem of medical and engineering 
records, access to them and their use, will be addressed. 

All policy recommendations in this Report result from detailed investi- 
gation of particular problems. 

1 Revised Statutes of Ontario (RSO), 1970, The Mining Act, c. 274. as amended to August. 
1972. Parts ix and xi of the Mining Act are, for easy reference, pubHshed in a manual 
entitled Handbook of Requirements Governing the Operations (f Mines (being Part IX 
and Sections 621, 624, 625(l)(a)(h)(c)(2)&(3)and626ofPartXI(fthe Mining Act) 
(Toronto: Queen's Printer, 1971). Henceforth all references to sections in Part ix andxi of 
the Mining Act will be taken from the Handbook. 

2 Mining Act, s. 169(13). 

3 Revised Statutes of Canada (RSC), 1970, Atomic Energy Control Act, 1946, c. .\-19. 
Henceforth cited as Atomic Energy Control Act. 

4 The collective bargaining units representing the workers in Ontario uranium mines have 
been certified under the Canadian Labour Code. All other union locals in mines in Ontario 
are certified under the Ontario Labour Code. 

5 Revised Statutes of Ontario (RSO), 1970, The Workmen's Compensation Act. c. 505, as 
amended to July 1974. Henceforth cited as Workmen's Compensation Act. 

6 Workmen's Compensation Act, Reg. 834, Schedule 1 , Class 5. 

7 Ontario Ministry of Natural Resources, Ontario Mineral Review 1974. 

8 The employees in this group form the major part of those covered by Class 5 of Schedule 1 
under the regulations of the Workmen's Compensation Act. The major subgroup of Class 5 
excluded from the Commission's study are the prospectors, whose numbers fluctuate but 
currently total about two thousand. 

9 Piecesof rock that may fall from the roof, which is known in the mining terminology as the 
'back.' 



Silicosis and dust 



SILICOSIS AS A PNEUMOCONIOSIS 

Silicosis, one of a group of diseases of the lungs termed pneumoconiosis, is 
caused by the inhalation over a period of years of dust containing free 
silica J The latter is the chemical compound silicon dioxide, usually found 
in crystalline form and most commonly in Ontario as quartz. The percen- 
tage by mass of free silica in ore bodies in Ontario ranges from under 10 per 
cent up to about 70 per cent. Ontario ores of nickel in the Sudbury basin, 
and some ores of iron, contain up to 10 per cent free silica. Gold and copper 
ores contain 15 to 35 percent, the uranium ores in the Bancroft area 5 to 15 
per cent and the uranium ores in the Elliot Lake area 60 to 70 per cent. 

The harmful free silica is that present in the dust inhaled by workers. 
While the amount of free silica in the respirable fraction of dust in mining 
operations may vary widely from place to place in a given mine, the 
likelihood of there being a significant percentage is directly related to the 
free silica content of the ore and host rock being broken. Silica dust is but 
one of several particulates commonly found suspended in mine air. These 
particulates generally include dust of the minerals mined and oil mist from 
drills, and may also include dust of rare earth dements, radioactive daugh- 
ters of radon and thoron gas, and the emissions of diesel engines. In the 
sequence of jobs that mark the career of a typical mine worker, different 
aerosols formed from complex combinations of particulates are commonly 
inhaled. The influence on the lungs of a given complex aerosol and of a 
sequence of different aerosols is not fully understood. 

A primary reaction of the lung to extended exposure to silica particles is 
to generate fibrous or scar tissue at dispersed locations initially in the upper 



19 Silicosis aiul dust 

and posterior lung fields. The fibrous tissue gradually develops into a 
pattern of whorled nodules. The developing patterns of fibrous tissue can, 
in an otherwise normal lung, be recognized and classified into various 
radiographic categories. An initial abnormality may be called 'dust effects' 
and in Ontario be categorized as a number 4 on an integer radiological 
scale. ^ As the fibrogenic process in an otherwise normal lung intensifies 
into a system of dispersed nodules a few millimetres in diameter, the 
pattern is recognized as 'radiological silicosis' and assigned the number 5. 

In the absence of complications, the most important of which is tuber- 
culosis, the fibrous nodules of radiological silicosis do not themselves 
significantly reduce the large reserve of respiratory capacity in the human 
lung and therefore produce no disability apparent to the person. However, 
the fibrogenic reaction of the lung progresses both in and out of dust 
exposure and may lead to a gradual reduction in the elasticity of the lung. 
When pulmonary impairment is detected by clinical assessment the person 
is said to have the disease silicosis. If the disease progresses without 
complications, the affected person may first become aware of it through 
unexpected shortness of breath during periods of physical exertion. 

Silicosis has been by far the most serious form of pneumoconiosis 
among workers in Ontario mines. But asbestos, nepheline syenite, and talc 
are other materials mined in Ontario the dusts of which are fibrogenic in 
varying degrees and produce pneumoconiosis in distinctive forms. To the 
end of 1974 no case of asbestosis had been recognized by the Workmen's 
Compensation Board as chargeable to the mining industry. There have 
been some twenty-five cases of pneumoconiosis attributed to nepheline 
syenite and talc operations in the mining industry. "^ 

Dusts which do not produce a fibrogenic reaction in the lungs are called 
inert and include gypsum, limestone, and common salt, all of which are 
mined in Ontario. The property of inertness does not imply that such dusts 
in sufficient quantity are harmless. 

SILICOSIS AND THE MINING INDUSTRY"^ 

Silicosis and its major complication, silicotuberculosis, became compens- 
able under the Workmen's Compensation Act in 1926.*^ When examining 
the development of the disease in the mining industry as a whole since that 
date it is important to note that silicosis and other related pneumoconioses 
are not confined to mining. In the years 1972 to 1974 inclusive, mining 
accounted for slightly more than half of the cases of pneumoconiosis 



20 The health and safety of workers in mines 



Scale 1 Scale 2 
20,000 T 2.000 T 



15.000 -- 1,500 ■- 



-L 



10,000 ■- 1.000 -- 



5,000 ■- 500 



^ — .. 



/ 



/ 



/ 



A / 

\ /' 



y 



Population at risk - scale 1 
/ 



\' 



■* Cumulative no of cases 
of disability -scale 2 




1925 1931 



1937 



1943 



1949 



1955 



1961 



1967 



1973 



FIGURE 2 The development of silicosis in Ontario mines (Source: Workmen's 
Compensation Board, Silicosis Disability Index, November 1975) 

recognized by the Workmen's Compensation Board. The remainder de- 
rived from such industrial activities as foundries and asbestos manufac- 
turing. 

The scope and evolution of the disease among workers in Ontario mines 
can be seen in Figure 2, showing the number of mine workers in dust- 
exposure workplaces since 1925, the cumulative number of new cases of 
silicosis, and the cumulative number of surviving silicotics.^ The graph of 
cumulative new cases shows that some eighteen hundred cases have been 
recognized in Ontario in the fifty years from 1925 to 1975. Because of the 
long average latency period for the development of silicosis and the relative 
continuity of historical dust conditions, the approximately linear form of 
the graph of cumulative new cases cannot be expected to change rapidly in 
the immediate future. Hence a significant number of new cases may be 
expected to appear. 

The graph of the population of surviving recognized silicotics shows that 
this number has been nearly constant. It has averaged 570 over the 25-year 



21 Silicosis and dust 



400 



300 



200 



100 



< 



70- 




^ 


60 ■ 


t 


^ Average age at death 


50 ■ 


• 


— ^_ -*''" Average age at recognition 


40 - 






30 


^^ ^^^^"\ 


20 - 


■ 


v»^No. of surviving silicotics ^"^^■^^ 

^^ with disability rating of 100% 


10 - 


1 — 


1 1 1 1 , 1 1 



1926 1932 1938 1944 1950 1956 1962 

FIGURE 3 Age at recognition and death (Source: see Figure 2) 



1968 



1974 



period from 1950 through 1974. This number has been nearly constant 
because the number of new cases of silicosis recognized per annum has 
been about equal to the number of silicotics dying per year. Over the 
corresponding period the average number of mine workers exposed to dust 
has been 17,500. Hence, the population of surviving silicotics has for some 
years been at the level of 3.3 per cent of the current population of dust- 
exposed workers. This figure provides a gross prevalence factor for the 
disease. 

The experience of silicotics after recognition varies considerably from 
person to person depending upon age, severity of the disease, and other 
coexisting medical conditions. An indication of the impact of the disease on 
life and lifespan is given by the average age of silicotics at death in a given 
year and the average age at recognition of those silicotics who died in a 
given year. These characteristics are shown in Figure 3, along with the 
number of surviving silicotics who have been assigned a disability rating of 
100 per cent for purposes of compensation. 

The average age at first recognized disability of those silicotics who have 
died increased from forty-three years of age in 1926 to fifty-six years in 
1974. For a male person having attained the age of fifty-six years, vital 
statistics of Canada (1960-2) indicate an additional life expectancy of 19.6 
years. "^ The average number of survival years for silicotics who died in 1974 



22 The health and safety of workers in mines 

was sixteen years. Thus, the average lifespan of silicotics in Ontario is 
approaching the average life expectancy of Canadian males who have 
attained the average age at which silicotics who have died were recognized. 

The number of surviving silicotics who have been assigned a disability 
rating of 100 per cent for puiposes of compensation has been decreasing 
since 1960. Because the total population of surviving silicotics has been 
nearly constant since 1950, the proportion with a high disability rating has 
been decreasing, so that in a statistical sense the severity of the disease is 
decreasing. 

Disease conditions other than silicosis are often present in silicotics 
assigned a high disability rating for puiposes of compensation. Tuber- 
culosis is the major disease to interact synergistically with silicosis. Pater- 
son reviewed the status of tuberculosis among miners and the general 
population in a report issued in 1973.^ His statistics, based on the records of 
the Ontario Mining Association and the Ministry of Health, showed that 
tuberculosis was present in seven out of eight deaths of silicotics recorded 
as occurring in 1926. Further, its incidence among persons x-rayed in the 
period 1967-72 was found to be four times as high among dust-exposed 
mine workers as among the general population. Data of the Mclntyre 
Research Foundation show that in the period 1970-4 tuberculosis was 
present in 8 out of 145 deaths, or 5.5 per cent.^ The Commission has 
examined the records of the Ministry of Health for tuberculosis among 
living miners for 1973 and 1974 and has found no evidence of a significant 
change in the incidence of tuberculosis during the annual radiographic 
surveillance from that reported in Table 7 of Dr Paterson's report. Tuber- 
culosis continues to be present among living dust-exposed miners and at 
the death of silicotics at a much higher rate than in the general population. 
The recommendations for continuedyigilance in this regard given byDrJ.F. 
Paterson in 1973 are therefore fully endorsed. 

The encouraging trends noted above are in the severity of the disease 
following its recognition. The circumstances leading up to its first recogni- 
tion are suggested in Figure 4, showing the average age of silicotics recog- 
nized in each year, the average elapsed time to silicosis from first dust 
exposure in Ontario, and the average percentage initial disability for those 
cases in which a percentage was assigned for purposes of compensation. 
The delay or latency in the development of silicosis is illustrated by the 
steady increase in average elapsed time from first dust exposure in Ontario 
to first disability, from fifteen years in 1926 to some thirty-five years about 
1960, with a downward trend since then.'" The corresponding increase in 
years of dust exposure in Ontario was about thirteen to twenty years,' • the 



23 Silicosis and dust 



1926 



90 ■ 
80 - 


r 

\ Average disability at first rating (%) 






70 - 


^ \ ^^^^ 






60 - 
50 ■ 


_^_- --"Average age at first disability (years) 


\ 


k "~ ~--« 


40 ■ 


■ 




\ 


30 ^ 


• — 

, • -"^ 

.•'"^ 

• " 

^ • — 


• 




20 - 


^ • ' 

____,- — • "^ 'Average elapsed time from 
— '"^ first dust exposure in Ontario 
to disability (years) 






10 - 


1 1 1 1 1 




— t 1 » 



1932 



1938 



1956 



1962 



1944 1950 
Calendar year 

FIGURE 4 Some characteristics of silicosis cases (Source: see Figure 2) 



1968 



1974 



latter figure remaining essentially unchanged from the mid-fifties through 
1974. The average age at first disability has risen steadily from about 
forty-three years of age in 1926 to about sixty years of age in the mid-fifties 
and has remained nearly constant since then. 

The failure of case characteristics for elapsed time to silicosis and for age 
at first disability to continue to rise after the mid-fifties can be correlated 
with the changing incidence of the disease. An average delayed incidence 
factor'^ for the new cases recognized in the decade 1935^4 and the 
subsequent decades'^ is given in the last column of Table 6. A representa- 
tive average dust-exposed population to associate with 1935^4 cases was 
calculated by averaging the exposed population in the period 1910-29.''^ 
The average delayed incidence factor declined notably from 1940 to 1960, 
but has not declined significantly since 1960. 

The lower rate of decline in the imputed incidence factor (Table 6) after 
1960, the failure of the graph of age at first disability to rise after the 



24 The health and safety of workers in mines 



TABLE 6 

Average delayed incidence factors by ten- 


■year intervals 




Interval 
of case 
averaging 


Recognized 
cases 

per annum 
in interval 
(average n) 


Workers in dust exposure in 
a preceding period 


Delayed incidence factor 
in cases per 1000 workers 
in dust exposure (average) 


Period 


Workers 
(average n) 


1935-44 
1945-54 
1955-64 
1965-74 


45 
39 
31 
36 


1910-29 
1920-39 
1930-49 
1940-59 


6,400 

8,900 

12,500 

15,700 


7.0 
4.4 

2.5 
2.3 



source: Population figures before 1928 are taken from S. Mcintosh, 'A study of cases of 
silicosis among Ontario miners,' Ontario Mining Association, May 1962. Thereafter, figures 
are from records of the Workmen's Compensation Board. 



mid-fifties (Figure 2), and the failure of the elapsed time from first dust 
exposure in Ontario to first disability to rise after the late fifties, all provide 
evidence that a significant change occurred in the developing pattern of 
silicosis. 

This change was caused by two related factors. The first was the opening 
of the uranium mines in 1955, the effects of which will be examined later in 
detail. Just a few years after the opening of the mines, some workers were 
discovered to be suffering unexpectedly rapid radiological changes in their 
lungs. The first case of silicosis in a uranium miner was recognized in 1962. 
The second factor was a change in the policy of recognizing silicosis for 
purposes of compensation. This policy change is illustrated in Figure 3 in 
the continuing decline in the average percentage disability assigned for 
purposes of compensation from about 50 per cent to about 20 per cent in the 
years from 1955 to 1974. The designation of persons as silicotics at a lower 
average threshold level of clinical impairment than had been customary 
made it possible for the persons involved in the peculiar circumstances in 
the uranium mines to be kept under earlier surveillance by the Advisory 
Committee on Occupational Chest Diseases and enabled the Ministry of 
Health to develop an understanding of the special pattern of pneu- 
moconiosis in the uranium miners. '-'^ 

This change also extended the incentive for persons given early recogni- 
tion to leave dust exposure. This incentive would derive from the fact that 
from 1933 to 1974 silicotics were normally not eligible, under the regula- 
tions of the Workmen's Compensation Board, to receive compensation 
payments until they had left dust exposure. ^^ The change in compensation 



25 Silicosis and dust 

policy, which began before the uranium mines opened, complicates any 
assessment of the historical pattern of the disease. After 1960, it is difficult 
in terms of disease statistics to separate effects due to a changing definition 
of the disease from those due to the intrinsic improvement or deterioration 
in the status of the disease in the industry as a whole. 

SILICOSIS AND IHH URANIUM MINES 

The effect of the uranium mines on the evolving pattern of silicosis in 
Ontario will now be considered in detail. The distribution of silicosis 
among types of mines is not easy to determine because it is rarely possible 
to attribute a case definitely to any one mine. This is because of the mobility 
of workers, induced in part by continuing changes in the level of employ- 
ment in different sectors of the mining industry, as illustrated in Table 7 for 
the period since the uranium mines opened. Nor can any large fraction of 
cases be unequivocally assigned to a single type of mine. Nevertheless, an 
estimate of the contribution of different types of mines to the disease can be 
made, as in Table 8, if it is assumed that the type of mine to which 
compensation is charged is that in which the worker received the dominant 
part of his silica-significant exposure. '^ Because of the decline in employ- 
ment in gold mines and uranium mines and the diffusion of some of these 
workers into the growing 'other' sector, the percentages for gold and 
uranium in Table 8 for the period 1954—74 are considered to be understated 
and those for 'other' to be overstated. 



TABLE 7 

Distribution of workers by mining group since the opening of the uranium mines 









Total 












Employment 


employees 


Total employment by 






Total 


in dust 


in dust 


mining group (%) 






employment 


exposure 


exposure 
















Period 


(all groups) 


(all groups) 


(%) 


Gold 


Uranium Silica 


Other 


1955-59 


42,900 


18,800 


44 


26.2 


13.7 0.04 


60 


1960-64 


41,800 


18,500 


44 


25.8 


9.2 0.02 


65 


1965-69 


41,600 


16,700 


40 


15.7 


3.9 0.01 


80.4 


1970-74 


41,000 


16,300 


40 


9.0 


4.1 0.20 


86.7 



note: 'Other' means all mining other than gold, uranium, and silica groups and includes 
contractors. Silica group means mining and milling of quartz. 

source: Mines Accident Prevention Association and Workmen's Compensation Board: 
Employees in Dust Exposure 



26 The health and safety of workers in mines 



TABLE 8 

Sources of silicosis tiy mining group based on class of mine charged with 
compensation 



Time 
period 




Silicosis 


cases by mine 


group (%) 




Cases (n) 


Gold 


Uranium 


Silica 


Othei 


Before 1954 
Before 1975 
1963-74 


1140 

1812 

396 


91.0 

83.3 
58.8 


5.1 
23.6 


0.4 
1.0 


9.0 
11.2 
16.7 



note: 'Other' includes all Class 5 operations studied other than gold, uranium and 
silica mines; that is, nickel, copper, iron, silver, salt, nepheline syenite, asbestos, 
gypsum, talc, contractors. 1963-74 is the period during which all cases of silicosis 
charged to the uranium mines to the end of 1974 were recognized. 
source: Mclntyre Research Centre, Brief to the Royal Commission on the Health 
and Safety of Workers in Mines, Toronto, 1975, Appendix a, Tables 1-5, updated 
through 1974 at the request of the Commission. 



Thus, as a qualitative judgment relative to historical levels of employ- 
ment, the Commission has concluded that past dust exposure in the gold 
mines has generated a large fraction of the cases of silicosis found in recent 
years. Further, past dust exposure in the uranium mines is generating a 
rapidly increasing fraction of recent cases of silicosis. The growing 'other' 
group has been contributing a relatively small fraction of the recent cases of 
silicosis. The silica group, which represents a tiny fraction of mine em- 
ployment, has produced a disproportionate number of silicotics, however, 
and deserves careful review. 

The growing proportion of cases charged to the uranium mines is evi- 
dence of the central problem related to silica-laden dust in the industry 
today. Of the ninety-four cases of silicosis charged to the uranium mines up 
to the end of 1974, only one is in the Bancroft region, where the amount of 
free silica in the ore is 5 to 15 per cent, in contrast with 60 to 70 per cent 
in the Elliot Lake ores. And that case involves a miner who had nine years 
of dust exposure in a marble and granite quarry before spending two years 
in a Bancroft mine. The problem of silicosis in the uranium mines has there- 
fore been in the Elliot Lake Mines. 

The early cases of pneumoconiosis appearing in the Elliot Lake mines 
had unusual clinical characteristics, described by Cowle et al.'^ The most 
recent cases are similar to classical silicosis, except for the fact that the 
nodules characteristic of silicosis are more widely dispersed through the 
lungs. Other characteristics of the cases of silicosis charged to the uranium 



27 wSilicosis and dust 



Percentage of 
total in 
metal group 



55 
50 

45 
40 
35 

30 
25 
20 
15 

10 
5 















r •— •— •— . 

; 1 




1 
1 






! i 










9 — . . 


1 1 
i 1 

1 • 

1 1 
ii 

1 






• 
• 

... 1 

• 

1 

• 

1 

• 

I 




[ 


— ,_. — 


21^0 


1 31^0 


41-50 ' 


5 


1-60 




61-70 


71- 



Uranium 

Other 

Gold 



Age at first disability 



FIGURE 5 Silicosis: age distribution of cases at first disability by type of mine 
1963-74 (Source: see Figure 2) 



mines have been of concern. Men have been recognized as silicotics in the 
uranium mines at significantly younger ages than in the gold and 'other' 
mines. This fact is indicated in Table 9 and illustrated in greater detail in 
Figure 5. ''^ Indeed, the average age (forty-six years) of the cases of silicosis 
in the uranium mines is the same as the age at recognition of persons in the 
gold mines about 1930. This fact implies a more rapid radiological progres- 
sion of silicosis in the lungs of workers in the uranium mines. 

The rate of progression from dust effects to radiological silicosis can be 
determined from data provided by the Workmen's Compensation Board. 
Plotted in Figure 6 is the percentage of the persons who, having been placed 
in the radiological classification 4 ('dust effects') in a given five-year period, 
progressed to the radiological classification 5 within five years. All persons 
involved in the statistics of Figure 6 have had dust exposure in Ontario 
only. Data are given for three groups according to whether dust exposure 
was in 1/ other than uranium mines (meaning all other than uranium. 



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29 Silicosis and dust 



80 - 


Percentage 










Dust exposure in uranium mines only 










(ten-year interval) 










(4) 


70 - 












60 - 










(25) 
1 


50 - 




- 






1 Dust exposure in 
1 uranium and other 
, mines (five-year 
intervals) 


40 - 












30 - 










(20) 1 
1 ' 


20 - 






Dust exposure in other than 
Uranium mines, including gold 








1 






(D^D) *~ 


(612) 


(five-year intervals) 






10 - 






(339) 




















h 


1 


(209) 


(15) 








a ' 1 






(307) 


f^rlFl ' ■ 





1- 


1 


(255) 
-1 1 ( — 



1935-39 



1940-44 



1945^9 1950-54 1955-59 1960-64 1965-69 

Calendar period 



FIGURE 6 Progression rate of silicosis: percentage of persons rated Radiological 4 
in designated time intervals who were rated Radiological 5 within five years, by type 
of mine (Note: persons with dust exposure in Ontario only; number of initial 4s in 
parentheses, including 4s at first examination. Source: 'Silicosis Report Pro- 
gramme,' Workmen's Compensation Board, November 1975, Table 15.4) 



30 The health and safety of workers in mines 

including gold, nickel, copper, etc.), 2/ uranium mines only, or 3/ uranium 
and other mines. 

For the 'other than' group, -^' Figure 6 shows that the fraction of new 
class 4s identified in five-year intervals that had progressed to class 5s 
within five years has fallen steadily from about 18 per cent in 1935-9 to 7 per 
cent in 1965-9.-' This pattern is consistent with the earlier conclusion 
(based on disease statistics) that the incidence of the disease was declining 
up to about 1960. The decline in the fraction of 4s that have gone on to 5s 
within five years is also believed to be a good biological indicator of the 
improvement in dust conditions prior to the opening of the uranium 
mines.'- 

In sharp contrast to the 'other than' graph in Figure 6 are those for 
'uranium and other' and 'uranium only.' For the 'uranium only' group, 
three out of four miners with dust effects discovered between 1960 and 1969 
progressed to radiological silicosis within five years. For those with 
'uranium and other' exposure, the percentage of 4s progressing to 5s has 
been increasing and is at a very much higher level than for the 'other than 
uranium' group. 

Figure 7 repeats the data of Figure 6, but for miners who had dust 
exposure outside Ontario prior to or in the course of experiencing dust 
exposure in Ontario. The data for the 'other than' group in the two figures is 
comparable, the same startling difference being apparent for the 'uranium 
only' and the 'uranium and other' groups. 

Since the number of 4s being identified among persons with any expo- 
sure in the uranium mines has been rising through the interval 1970^, and 
since the fraction of these progressing to radiological silicosis has been 
rising through the period 1965-9, it is reasonably clear that a significant 
number of new cases of silicosis will appear in future years in the popula- 
tion at risk. Their number cannot be predicted, but they will not all be found 
among current employees of the uranium mines. 

The burst of silicosis in the uranium mines will have died out, relative to 
the historical experience in the 'other than' classification, when the frac- 
tion of new 4s found in future successive five-year periods that progress to 
5s within five years falls to the levels now characteristic of the 'other than' 
classification. 

To the end of 1974 no case of silicosis charged to the uranium mines 
involved a person who first entered dust exposure in Ontario in or after 
1960, that is, in a fifteen-year period before 1974. This fact is encouraging, 
but on the other hand Table 9 shows that the average elapsed time from first 
dust exposure in Ontario to the recognition of silicosis among the cases 



31 Silicosis and Just 



60 -- Percentage 



50 -- 



40 -- 



30 -- 



20 -- 



10 -- 



Uranium only in Ontario 



Uranium and other in Ontario 
r (31 



(19) 
(51) 



(308) 



Other than uranium in Ontario 
(including gold) 



(279) 



:145) 



(190) 




(1241 



1935-39 1940^4 1945^9 1950-54 1955-59 1960-64 1965-69 

Calendar period 

FIGURE 7 Progression rate of silicosis: same as Figure 6 but for persons with dust 
exposure both in and outside Ontario (Note: number of Radiological 4s at each 
interval includes those so categorized at a first examination; number of initial 4s in 
parentheses. Source: 'Silicosis Report Programme,' Workmen's Compensation 
Board, November 1975, Table 15.4.) 



charged to the uranium mines between 1963 and 1974 was eighteen years, 
while that for cases charged to the gold mines was thirty-one years. Not 
until the elapsed time to silicosis for persons whose dominant exposure to 
silica dust has been in the uranium mines has increased to an average of 
thirty-odd years, can there be great confidence in underground mining 
conditions. 

The observed age of the new silicotics in the uranium mines and the 
unusual characteristics of the related pneumoconiosis led the Advisory 
Committee on Occupational Chest Diseases and the Workmen's Compen- 



32 The health and safety of workers in mines 

sation Board to continue to lower the threshold of cHnically assessed 
impairment at which compensation has been allowed. The Commission 
believes this to have been a humane decision, albeit one which complicates 
assessment of the historical pattern of the disease. 

SILICOSIS AND THE RESPONSIBILIIY-SYSTEM 

The total number of employees in the two operating mines at Elliot Lake at 
the end of 1974 was 1 ,634 persons. Somewhat more than half of these were 
in characteristically dust-exposed occupations, yet this group represents a 
small fraction of the total number of persons who at one time or other have 
experienced some dust exposure in the uranium mines. ^^ 

The Ministry of Health in April 1975 published a report on the state of 
the respiratory organs of mine workers in Elliot Lake.^'* This study showed 
that among about one thousand dust-exposed workers employed at Elliot 
Lake in February and March 1974, or who had been employed as of 31 
December 1973, and whose radiological records were subsequently ex- 
amined, thirty-six, or 3.6 per cent of the total, had a radiological 
classification of silicosis and an additional fifty-three, or 5.3 per cent, had a 
radiological classification of 4 (dust effects). ^^ The report on the respira- 
tory system of the workers at Elliot Lake was undertaken by the Ministry 
of Health at the urgent request of the union locals of the United Steel- 
workers of America. Under the Mining Act, basic governmental responsi- 
bility for the health and safety of workers in mines has rested with the 
Ministry of Natural Resources (and formerly with the Department of 
Mines), which has published two studies on silicosis, in 1959 and 1973.^^ 

During the Commission hearings it was repeatedly apparent that the 
workers did not have ready access to reviews of the status of occupational 
diseases. Nor has it been clear within the whole responsibility-system how 
such reviews should be generated and used. The legitimate alarm in the 
Elliot Lake mining community and in other mining communities that suffer 
at first hand the consequences of occupational disease will not be fully 
allayed by this Commission's report or any futher reports. But there is no 
reason for not providing on a regular basis to all the parties concerned, and 
in particular to the workers and their representatives, reviews of occupa- 
tional diseases. The Commission therefore recommends: 

That the Occupational Health and Safety Branch of the province con- 
duct or have conducted and publish on a regular cycle not exceeding five 
years status reports on the evolution of occupational diseases among 
miners. 



33 Silicosis and dust 

If we are to meet occupational hazards with a sensible balance between 
the acceptable risks and the desired economic benefits, the nature and 
extent of the risks manifested in the lives of working persons must be 
understood more openly. Workers who bear the risks, and their represen- 
tatives, have in natural justice a right to know, as do the public at large. 
Clear independent initiative in this regard must be assigned to one author- 
ity, and that should be the Occupational Health and Safety Authority. ^"^ By 
legislative jurisdiction and administrative practice, this agency, in its pres- 
ent form as the Occupational Health Protection Branch in the Ministry of 
Health, has been denied the opportunity and resources freely to perform 
the above task and many related ones. Because the burst of silicosis related 
to the Elliot Lake uranium mines is in the early stages of its evolution, the 
Commission further recommends: 

That the radiological status of silicosis in the dust-exposed population 
currently employed in the Elliot Lake uranium mines and all other uranium 
mines be reviewed by the Occupational Health and Safety Branch on a 
biennial basis for a period of at least ten years, 

That the radiological status of silicosis among the persons on record on the 
Uranium Nominal Roll be reviewed on a biennial basis for a period of at 
least ten years. 

Recommendations on work adjustment and workmen's compensation 
pertaining to workers currently employed in the uranium mines and to 
persons on the Uranium Nominal Roll are presented later in this chapter. 

THE ROOTS OF THE PROBLEMS OF THE 
ELLIOT LAKE URANIUM MINERS 

The burst of silicosis associated with the Elliot Lake uranium mines was 
partly caused by the precipitate manner in which these mines in highly 
siliceous ores were developed (and shut down) and by the work environ- 
ments that resulted. The effectiveness of the responsibility-system in deal- 
ing with the problem of dust in these and other mines will be examined in 
the following sections of this report. 

Because of the long latency factor in silicosis it is important at this point 
to have a picture of the historical development of the situation in the 
uranium mines. Between 1954 and 1958 twelve mines came into regular 
operation in the Elliot Lake region and four in the Bancroft region. Total 
employment at Elliot Lake rose from about five hundred at the end of 1954 



34 The health and safety of workers in mines 



o 



60 - 



40 -- 



J 



10,000 - 



o 

Q. 



100 - 5.000 -- 



80 - 



20 -- 1.000 -- 



Employment. 
Elliot Lake Mines 




54 



56 




Cumulative 
number of 
silicosis cases 
charged to 
uranium mines 



Employment 

Bancroft 

Mines 



Calendar year 



FIGURE 8 Employment in uranium mines and cumulative number of cases of 
silicosis charged to these mines (Source: Records of the Ontario Mining Associa- 
tion and the Mclntyre Research Foundation) 



to ten thousand at the end of 1958. Four years later it had fallen to under 
three thousand; by 1973 only two uranium mines were operating, with a 
total employment of some sixteen hundred persons. These trends are 
illustrated in Figure 8, which also presents the cumulative number of 
silicosis cases charged against these mines. The mines at Elliot Lake now 
anticipate a period of substantial growth. New uranium mines are opening 
at Agnew Lake and mines in the Bancroft area will reopen shortly. ^^ Cause 
for concern about environmental conditions remains. 

In May 1958. following representations from the United Steel workers, 
the Department of Mines established a Special Committee to study the 
accident situation and mining practices in the Elliot Lake District. ^"^ Its 
report provides a statistical, pictorial, and interpretive account of the early 
phases of development of these mines. The following quotation from that 



35 Silicosis and dust 

report, together with the graphs in Figure 8, will serve as a commentary 
upon the early Hlliot Lake development: 

A Crown company. Kldorado Mining and Refining Limited, then the sole purchaser 
of uranium oxide and other nuclear materials in Canada, entered into contracts, at 
stated prices, with those companies showing a production potential for the pur- 
chase of uranium oxide, aggregating over $ LOGO. ()()(). ()()() in value. 

The contracts are valid until 1962 and in some cases into 1963. They permitted 
the financing and equipping of the mines for rates of production that would meet 
their contracted quotas. They also gave the companies an assured income for the 
lives of the contracts but left the future beyond 1962-63 very uncertain. 

The stocks of uranium oxide at the disposal of the western world and for annual 
requirements are, of necessity, classified information. Those responsible for such 
matters have contracted for the above supplies from the Elliot Lake mines. Under 
the circumstances, this was one of the few ways in which the responsibility for such 
a gigantic procurement, together with the complex problems and risks involved, 
could be passed from government to private enterprise with which the general 
public could be associated. In doing so, however, government has protected itself 
to the extent that the contracts not only call for the total commitments by 1962-63 
but further call for deliveries to commence on specified dates. 

Thus, if a company had failed to meet the delivery requirement, there was a risk 
of having the contract cancelled. Also, the financing arrangements of many of the 
companies were such that operating revenues were necessary to meet the interest 
charges on borrowed capital. Both of these factors introduced a time incentive from 
which, in the early stages at least, a pressure on production inevitably followed.''" 

Of the problems of health and safety that have emerged out of the Elliot 
Lake situation, dust and radiation are two that are central to this report. 
The problem of dust will now be examined in the context of the industry as 
a whole. 

DUST 

The labour unions have vehemently made many allegations about dust 
conditions and about the practices for monitoring them. To analyse the 
problem it is useful to set down the following questions: Who determines 
what levels of exposure at the workplace are acceptable? What are these 
levels? How are they determined? Who monitors actual dust conditions, 
when and how? Who has the responsibility to audit measurements and to 
inspect conditions? What is the record of compliance? 

When viewed in terms of these questions, the allegations of the unions, 
particularly those regarding Elliot Lake, constitute a charge that the agen- 



36 The health and safety of workers in mines 

cies possessing authority to control dust conditions have failed to exercise 
their responsibilities in an effective, open, and accountable manner. It is 
central to the remainder of this report to understand why such a charge 
might be made. 

Under Part ix"*' of the Mining Act, on health and safety in mines and 
plants, primary responsibility for compliance is placed upon the owner: 

169( i) The owner or agent of an operating mine or plant shall appoint a manager 
who is responsible for the control, management and direction of the mine or plant. 
(2) The owner or agent shall provide the manager of a mine or plant with the 
necessary means and shall afford him every facility for complying with this Part ... 
(6) Except as to any provisions that the chief engineer has directed are not applica- 
ble thereto, the manager of the mine or plant shall take all necessary and reasonable 
measures to enforce the provisions of this Part and to ensure that they are observed 
by every employee of the mine or plant, and every supervisor shall take all 
necessary and reasonable measures to enforce the requirements of all such provi- 
sions as are applicable to the work over which he has supervision and to ensure that 
they are observed by the persons under his charge and direction. 

Representative requirements concerning dust are as follows: 

213(1) The ventilation in every mine shall be such that the air in all of its workings 
which are in use shall be free from dangerous amounts of noxious impurities and 
shall contain sufficient oxygen to obviate danger to the health of anyone employed 
in the mine. 

213( 10) Every place in a mine where drilling, blasting, or other operations produce 
dust in dangerous quantities shall be adequately supplied at all times with clean 
water under pressure or other approved appliance for laying, removing or control- 
ling dust. 

2I3( 12a) A fresh air supply independent of the air supplied to any machine or drill 
used therein shall be provided ... in every raise ... 

214(1) There shall be provided a positive supply of fresh air into, and provision for 
the removal of vitiated air from, a plant building that is sufficient to keep the air 
reasonably pure and to render harmless so far as is reasonably practicable, all 
gases, vapours, dusts or other impurities that are likely to endanger the safety of 
any person therein. 

214(4) There shall be provided and used, where a process is carried on that 
produces a gas, vapour, dust or other impurity that is likely to be inhaled to an 
injurious extent by persons in the plant building, such mechanical means satisfac- 
tory to an engineer, as are capable of (a) preventing, as far as is reasonably 
practicable such inhalation; (/?) effectively carrying off and disposing such gases, 
vapours or dusts: and (r) preventing, as far as is reasonably practicable, the 
recirculation and re-entry of air containing such impurities. 



37 Silicosis and diisl 

This legislation gives to the owner-manager the freedom to achieve the 
required ends to the degree and by the means judged by him to be suitable. 
This Judgment is subject to review by the engineers (mining inspectors) of 
the Mines Engineering Branch of the Ministry of Natural Resources, 
who are assigned the following broad powers and duties: 

6i()( 1) It is the duty of the engineer and he has power: (^/) to make such examination 
and inquiry as he deems necessary to ascertain whether this Act is complied with, 
and to give notice in writing to the owner, agent or manager of any particulars in 
which he considers the mine or plant or any part thereof, or any matter, thing or 
practice to be dangerous or defective or contrary to this Act. and to require the 
same to be remedied within the time named in the notice: (h) to enter, inspect and 
examine any mine or plant or any part thereof at any reasonable time by day or 
night, but so as not to unnecessarily impede or obstruct the working of the mine or 
plant: (c) to order the immediate cessation of work in and the departure of all 
persons from any mine or plant or part thereof that he considers unsafe, or to allow 
persons to continue to work therein on such precautions being taken as he deems 
necessary: and iJ) to exercise such other powers as he deems necessary for 
ensuring the health and safety of miners and all other persons employed in or about 
mines, plants, pits, quarries or other works. 

As a body of law the Mining Act is unusual in that there is no associated 
set of regulations on health and safety passed by order in council. An item 
that would be a regulation under, for example, the Industrial Safety Act is 
made part of the Mining Act and passed in detail by the legislature. 
However, the chief engineer of the Mines Engineering Branch has from 
time to time issued 'codes of requirements' on such areas as the measure- 
ment of dust and radiation, allowable radiation levels, and ventilation for 
diesel engines underground. These codes have been arrived at after consul- 
tation with the industry and, as deemed appropriate, with the Ministry of 
Health and other agencies. They constitute an interpretation of general 
requirements of the Mining Act in the form of specific practices acceptable 
to the chief engineer and to the industry. 

The legal framework for health and safety in the mines as sketched 
above has resulted in strong reliance being placed by the government on the 
self-regulatory initiatives of industry through individual companies and 
collectively through the educational activities and moral suasion of the 
Mines Accident Prevention Association. "^^ The Mines Engineering Branch 
has fulfilled the dual role of inspecting mines and plants in accordance with 
the provisions of the Mining Act and through consultation establishing 
technical standards and codes of requirements for the industry. Such 
consultation between this branch and the industry has come to be seen by 



38 The health and safety of workers in mines 

the unions as. at best, accommodation of interests^^ and, at worst, collu- 
sion. 

The Mines Engineering Branch and the industry itself are the agencies 
responsible under existing law for health and safety conditions in mines and 
in particular for dust conditions. The response of the labour unions, espe- 
cially to the problems at Elliot Lake, becomes fully understandable when it 
is realized that there has been no code of requirements specifying allowable 
dust levels, that until January 1975 workers and their representatives have 
not been informed on an industry-wide basis about dust conditions, and 
that the public annual reports of the Mines Engineering Branch and of the 
Mines Accident Prevention Association have not provided critical reviews 
of dust conditions. The unions have perceived the responsibility-system to 
be closed and not accountable. 

How effective, therefore, has this system, with its strong self-regulatory 
nature, been in controlling dust conditions? 

Dust and its measurement 

Dust is measured for two basic reasons: 1/ to determine the levels that 
result from mining procedures, work practices, and the conditions of 
ventilation at the workplace, the objective being to achieve engineering 
control of the generation and dispersal of dust; 2/ to obtain quantitative 
data on human exposure that will permit epidemiological study of the 
relation of human response to dose, with the goal of providing a quantita- 
tive basis for the setting of health preserving dust standards. 

The hazard of dust is related to particle size, surface area, mass, and 
chemical composition, and to particle concentration. Mineral dust is a 
major constituent of mine aerosols, but the latter may also contain oil mist 
from drills, particulates from diesel exhausts, and radioactive particles 
deriving from radon gas emanating from rock faces and broken rock. The 
hazard to the lungs is produced by inhalation of particles from about 10 
microns in size to less than 1 micron in diameter.^'* The larger particles are 
trapped in the nasal passages and trachea; the mid-range of particles may 
be deposited in the bronchioles and alveolar sacs of the lungs; the smallest 
particles may be breathed in and out.^^ Respirable dust in the size range of 
microns is invisible in ordinary light and remains suspended in air for long 
periods. ^^ Respirably hazardous dust therefore tends to build up in the air 
at any dust-generating process such as drilling, slushing, mucking, dump- 
ing, and crushing. 

There are many different instruments for measuring dust.^"^ The instru- 
ment in use on an industry-wide basis in Ontario^^ is the konimeter. 



39 Silicosis and dust 

adapted from wSoiith African practice of the 192()s. This instrument sucks in 
through a small orifice a five-cubic-centimetre volume of dust laden air. 
This process occurs in one-fifth of a second, so that the instrument takes a 
'snap' sample. The dust in the sample of air is deposited on an adhesive, 
layer on a glass plate. After a heating and acid treatment the residue of dust 
particles on the glass plate is counted visually under a microscope^*^ and 
expressed as a number of particles per cubic centimetre (ppcc ). The treat- 
ment procedure removes combustibles such as diesel soot and acid soluble 
minerals such as carbonates. Free silica and various silicates are among the 
residue of particles counted. An electronic optical scanner'*" was de- 
veloped by the Mines Accident Prevention Association in the 1960s and 
made available to the industry for standardized reading of glass slides at its 
North Bay field station in 1969. 

A standard procedure has been developed for dust measurement at the 
workplace."^' This calls for three snap samples to be taken in the breathing 
zone of the worker down wind from a mining operation, such as drilling, 
which is to be taking place. A single snap sample of the air entering and 
leaving the workplace is also taken. 

The konimeter is a 'spot' sampler in both place and time. Information 
presented to the Commission'*^ reveals that if a konimeter measurement is 
made at half-hour intervals during a working shift at a given workplace with 
operations starting and stopping, variations on the order of 5 : 1 in the 
readings are encountered. The instrument and the standard procedures of 
sampling used with it are therefore unsuitable for determing the total 
exposure to dust to which a worker may be subjected over a working shift. 
But the konimeter is useful for engineering control as an indicator of 
comparative dust levels being encountered. For this purpose it is necessary 
to average sets of readings taken at similar workplaces near such opera- 
tions as drilling, mucking, and crushing. When konimeter spot samples are 
averaged over a class of workplaces in a mine, over a whole mine, and 
across groups of mines of a given type, qualitatively comparative dust 
records are obtained. 

The representatives of workers expressed before the Commission deep 
concern about the accuracy and adequacy of the dust-sampling procedures 
used. Before January 1975, workers were not informed on an industry-wide 
basis what the readings were, what the accepted procedures of measure- 
ment were, or what purpose the readings served. This fact reflected a 
general lack of communication from management to workers on matters 
that are of legitimate concern to workers. The paternalistic attitudes of the 
past which appear to remain in parts of the industry are not, in the 



40 The health and safety of workers in mines 

Commission's view, acceptable. It is therefore recommended: 

That the functional purpose, measuring procedures, and measured results 
relating to all environmental monitoring at the workplace he made known 
in understandahle language to all affected workers and their representa- 
tives hy the employer and as appropriate by the Mine Inspection Branch. 

Subsequent recommendations will deal in more detail with how the 
workers and their representatives may participate in achieving a wider 
understanding of environmental conditions, and of their inescapable in- 
volvement in influencing these conditions through their own work prac- 
tices. 

DUST AND IHE RESPONSIBILITY-SYSTEM 

There were no systematic industry-wide measurements of dust before the 
opening of the uranium mines. From the mid-twenties the konimeter was 
used in gold mines for engineering control purposes to recognize excep- 
tional dust conditions. After the Mines Accident Prevention Association 
was established in 1930, concerted efforts to deal with dust conditions 
began, and by 1954, when the uranium mines opened, initial dust guidelines 
had been formulated by the Association: 'Through the years we have come 
to appreciate that, in our case, konimeter counts of the order of 100 to 300 
particles per cubic centimetre are good; those of the order of 500 to 700 or 
800 are fair, only; while those in excess of 1000 ppcc are poor.'"^^ The 
selection of these levels was based on 'best practice' in Ontario gold mines, 
on a knowledge of then current South African practice, and on the Ontario 
Mining Association's study of the developing record of silicosis. These 
guidelines, with the implication that they were suitable for percentages of 
quartz encountered in gold mines, were in use by the mapao when the 
uranium mines opened. 

The guidelines and their subsequent variations to date had, and have, no 
legal validity as dust standards. Under the Mining Act no statutory stan- 
dards for dust have been issued. It is therefore important to understand that 
there has been no question of legal compliance with stipulated standards. 
On a collective basis, the industry has had guidelines, which were tacitly 
accepted by the Department of Mines as a basis for guiding the Mines 
Engineering Branch in its interventions with management. 

In matters of health and safety in the mines, an important principle of the 
Ontario Mining Association, as reflected in the work of the Mines Accident 



41 Silicosis and dust 

Prevention Association, has been that self-regulation is preferable to inter- 
vention by government. The Commission believes the principle of self- 
regulation is sound, but the associated issue of accountability of both 
industry and government must be made clear. 

It has been noted that no systematic industry-wide dust measurements 
were made prior to the opening of the uranium mines in the mid-fifties. 
However, concern about potential radiation and related dust hazards in the 
developing uranium mines led the then Department of Mines and the 
Ontario Mining Association to an agreement'^'* for an initial survey'^'' of 
conditions to be undertaken by the Mines Accident Prevention Associa- 
tion. The issue of accountability for the validity of the measurements was 
raised by a spokesman for the industry who 'asked the question that in the 
event a question is later raised in the House or in another manner, to the 
Department, as to the actual situation existing, is the Department going to 
be satisfied with the results and be able to back up the work even though it is 
carried out by the Association."^^ The spokesman for the Department 
'stated that his Department would have full confidence in the work of the 
Association and would do its best to support the work in public. '"^"^ 

In March 1957, undoubtedly in response to the evidence of the first 
survey of conditions, the chief engineer of the Mines Engineering Branch 
issued a code of requirements for the measurement of radiation and dust 
levels on a quarterly basis in the uranium mines. "^^ No dust or radiation 
standards were included. In December 1957 the Department of Mines 
commissioned Dr J.F. Paterson to study the problem of silicosis in the 
mining industry and his report was submitted in June 1959."^^ 

In response to these initiatives by the government, the directors of the 
Ontario Mining Association recommended to its members in the Mines 
Accident Prevention Association the adoption of a voluntary code-^^ of dust 
sampling on a semi-annual basis for all mines other than uranium, salt, and 
asbestos.-''^ The Mines Engineering Branch welcomed this initiative. While 
not all mines immediately participated in this voluntary system, it came 
into being and remains in regular operation. The results of these voluntary 
surveys and of the surveys required in the uranium mines constitute the 
system-wide record of dust conditions in the industry. These will shortly be 
reviewed. 

Underlying the foregoing sequence of events are the important issues of 
accountability and openness, which were revealed by a senior spokesman 
for the labour unions when he stated before the Commission: 'We believe if 
there were any independent data on dusts and other hazards in mines it 
would prove that the mapao has not been an effective force for safety and 



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43 Silicosis and dust 

that all the statistics based on mapao guidelines that its members compiled 
are worthless/''" The Commission has no evidence to cast doubt on the 
general validity of the measurements of dust compiled by the industry, as 
required by the code for the uranium mines, and for other mines voluntar- 
ily. But as a matter of principle it is recommended: 

That the Mines Inspection Branch within the Occupational Health and 
Safety Authority conduct annually, or have conducted hy an independent 
agency, sample measurements at representative workplaces of all en- 
vironmental quantities whose values are audited hy the Authority in carry- 
ing out its role; 

That the Occupational Health and Safety Authority publish at least bien- 
nially a critical review of its appraisal of environmental conditions at the 
workplaces in the mines and mineral plants. 

Self-regulation is a valuable and desirable principle, but to be properly 
effective there must be more open accountability on the record. There has 
not been publicly available a record of dust conditions in the mines. 

The record of dust conditions 

The dust conditions observed during the early development of representa- 
tive uranium mines at Bancroft and Elliot Lake are summarized in Table 
10. It will be recalled that whereas the free silica in the ores at Bancroft is in 
the range 5 to 15 per cent, in the ores at Elliot Lake it is 60 to 70 per cent. 

The historical evolution of underground mine average dust levels by 
class of mine in the industry as a whole is shown in Figure 9.^^ This figure 
shows that over the historical period of system- wide observation, dust 
levels have decreased in each class of mine by a factor of about two, the 
major decrease having occurred in the period 1958 to 1965. In reflecting 
upon these data it is important to relate them to the guidelines of the Mines 
Accident Prevention Association then current. In the early period, until 
about 1960, the initial guidelines developed from experience with gold 
mines prevailed. Nickel mines, with their low percentage of free silica in 
the ore, were not considered to present a major silicosis hazard. However, 
the uranium mines were a problem, and the guideline for 'good' dust 
conditions of 100 to 300 ppcc was considered by the engineering staff of the 
Mines Accident Prevention Association to be applicable.^'* In the period 
1960 to 1969, the early 'gold' guideline was elaborated to provide dust 
guidelines based on the percentage of quartz (or free silica) in total dust.'' 
These guidelines were first published in 1969. ''^ 



44 The health and safety of workers in mines 




FIGURE 9 Average underground dust conditions for gold, nickel, and uranium 
mines 1958-75 (Note: the uranium mines were surveyed four times a year between 
1959 and 1961 and three times a year between 1962 and 1964. The first and third 
surveys of these sets have been used for this comparison. Source: mapao 
semi-annual surveys of dust conditions) 



Table 1 1 reviews average dust conditions in the nickel, gold and uranium 
mines in terms of the guidelines of the Mines Accident Prevention Associa- 
tion current as of April 1975. Tables d.2 through d.4 provide a basis for 
judging conditions at particular classes of workplaces as contrasted with 
mine averages. For mine averages it is apparent that the nickel mines are 



45 Silicosis and dust 



TABLE 11 

Some characteristics of underground dust conditions in Ontario 


mines 


Average dust 
level" in ppcc 


Quartz in 
total dust 

(average %)" 


MAPAO guideline (1969) 
in PPCC by percentage 
of quartz in 
total dust^ 


Type of 1st half 1st half 
mine 1960 1975 


Nickel 680 310 
Gold 400 250 
Uranium 400 220 


UptolO'' 
15to35 
60 to 70*^ 


500 (up to 10% quartz) 
300 (10 to 30% quartz) 
200 (over 30% quartz) 



source: Mines Accident Prevention Association of Ontario, Semi-Annual Surveys of Dust 

Conditions, 1958-1975 

a From Figure 9 (rounded to nearest 10) 

b Log of Analysis of Aerial Dusts from Ontario Mines, mapao (1935-1975) and First 

Surveys of the Uranium Mines. 
c MAPAO, Airborne Contaminants, Mining, Milling, Smelting and Refining, 1st ed., 1969 
d Sudbury Basin 
e Elliot Lake Mines 



well below the current guidelines, the gold mines are below the guideline, 
and the uranium mines continue to be above the guideline. 

When the guidelines are applied to classes of workplaces as listed in 
Tables D. 2 through d. 4 for the period 1973-5 the nickel mines are observed 
to meet the guideline at all recorded types of workplace, the gold mines 
substantially meet the guidelines in all but one category, and the uranium 
mines are above in eight out of nine categories. In these circumstances 
anything less than the most rigorous attention to the reduction of dust in the 
uranium mines must be deemed unacceptable, and recommendations fol- 
low on this matter. Further, it is important that guidelines not be under- 
stood to be limits which become by precedent the tolerated average levels. 
The objective must be the lowest practicable levels of dust. 

The response of the industry to self-regulation and to the actions of 
government is reflected in the foregoing record of dust conditions and dust 
guidelines. The Commission has studied records of the work of the Ontario 
Mining Association, the Mines Accident Prevention Association, and the 
Mines Engineering Branch through the period 1955 to 1975. Since these 
institutions have been the subject of shaip criticism by the labour unions, 
some assessment of their actions in relation to dust control is important. 



46 The health and safety of workers in mines 

The record shows that it was the poHcy of the Ontario Mining Associa- 
tion to have the technical staff of the Mines Accident Prevention Associa- 
tion work assiduously to educate and to guide companies in the control of 
dust by auditing company operations and providing technical information. 
Critical annual reviews of dust conditions within the industry have been 
circulated to member companies. '^^ Within the context of its dependence 
on the Ontario Mining Association for policy direction and its legal charter 
under the Workmen's Compensation Act, the Mines Accident Prevention 
Association has attempted to exercise moral suasion based on collective 
industrial self-interest. It has been clearly perceived by the industry that 
want of self-regulation would lead to greater intervention by government. 

The self-regulatory approach to problems of health and safety for work- 
ers, whatever the quality of its general performance, has a fundamental 
weakness or incompleteness. Not all management in Ontario mines have 
seen, or are likely to see, collective interest as corresponding to self- 
interest. A well-informed Mines Inspection Authority is necessary on 
several grounds, but in particular to discern and to deal bluntly with this 
situation. 

Since self-regulation is important, but a greater measure of openness is 
necessary to justify public confidence in this process, it is recommended: 

That the legal framework for the health and safety of workers in mines 
continue to recognize the importance of a significant component of collec- 
tive self-regulation by industry as a whole achieved through a Mines 
Health and Safety Association.^^ 

The Mines Engineering Branch has had the responsibility of determining 
whether the management of mines has complied with the provisions in the 
Mining Act concerning dust and the health of workers. It has been indi- 
cated that the provisions of the Act related to dust are general and not 
susceptible of precise legal interpretation. The Mines Engineering Branch 
has issued no code of requirements for dust levels; for underground condi- 
tions it has relied on the dust guidelines of the Mines Accident Prevention 
Association. 

Within this limited framework, the record shows that inspectors were 
not negligent in auditing dust records, inspecting mines, and issuing letters 
of instruction to the managers of uranium mines and of other mines under 
Section 6I0(l)(a) of the Mining Act. Yet two factors have limited the 
effectiveness of work in the field. The Mines Engineering Branch has not 



47 Silicosis and dust 

had adequate resources to fulfil the responsibilities assigned to it. It has 
lacked adequate staff and independent expertise in dust control and venti- 
lation. Further, in the absence o\' statutory standards for dust a mines 
inspectorate is limited in the effectiveness with which it can demand 
compliance with qualitatively defined environmental requirements charac- 
teristic of the Mining Act. Its effectiveness depends strongly on the clarity 
with which the responsible ministry makes known its expectations of 
industry. When that ministry has the role both of promoting the develop- 
ment of the industry and of protecting the health and safety of workers, 
failure to act is inevitably seen as accommodation of interests. In the 
Commission's view there has been on more than one occasion unjustified 
complacency at the policy-making level both in government and the in- 
dustry. 

On the basis of the foregoing review it is apparent that collective indus- 
trial self-regulation and mines inspection as these then existed were not 
strong enough to meet the challenge presented by the explosive initial 
development of the uranium deposits. Attention to industrial development 
and to corporate economic risks dominated concern for the health of 
workers. The existing responsibility-system has gradually succeeded in 
bringing the average dust conditions in the industry close to or below the 
guidelines in use. Because of the general improvement in dust conditions 
the rate of appearance of silicosis in the groups other than the uranium 
mines may be expected to continue to decline. But for a decade or more the 
consequences of the early conditions in the uranium mines will continue to 
be evident in the distinctive burst of silicosis that has been identified. 
Current conditions among persons on the Uranium Nominal Roll deserve 
further discussion. 

The ongoing control of dust 

There are two steps that I believe should be taken with the intent of 
ensuring the continued improvement of dust conditions where these are 
unsatisfactory. These are the issuance of codes of practice on ventilation 
and on work practices; and the establishment of statutory standards for the 
exposure of workers to dust. 

The industry has long been aware of the methods available to prevent 
fine dust from becoming airborne, to confine and collect dust that does 
become airborne, and to dilute and sweep out the residual dust by main and 
auxiliary ventilation. I have no doubt that good practice is followed at many 
workplaces. However, the following quotations from a recent survey of 



48 The health and safety of workers in mines 

underground air conditions by the Mines Accident Prevention Association 
is symptomatic of the fact that what is known is not always practised.'^*' The 
investigations of the Commission have confirmed that the situations re- 
ferred to are of long standing and are not peculiar to the uranium mines. 

Drillifii^ 

Air-water blasts are mandatory under the Mining Act in headings and raises, the use 
of this device is recommended in stopes as well, yet there is a large number 
reporting that it is not used ... The air-water blast is a first line defense in control of 
dust concentration, and is of utmost importance in conditioning broken rock to 
reduce ventilation volumes required to dilute dust and gas concentrations. 

The removal of handvalves in water lines at machines equipped with automatic 
backheads eliminates the temptation to collar dry. While many of the drill machines 
having hand valves in the water lines are stopers, almost one half of the mines report 
that handvalves have been retained at all machines ... 

HcuuUing Muck 

There is a continuing need for more effective applications of water to condition the 
muck prior to handling. The number of mines reporting on the use of intermittent 
sprays is disappointingly small, those using the preferred continuous sprays even 
more so . . . 

Ventilation 

Auxiliary ventilation continues to be used extensively in working places lacking 
through airflow. The number of headings and stopes ventilated by auxiliary means 
decreased slightly over that of a year ago, which probably accounts for the number 
of these locations that report airflows too slow to measure. It is gratifying to note 
that the number of raises ventilated has increased ... 

The foregoing review includes the following statement: 

Reduction of dust concentration to acceptable levels requires constant and com- 
plete cooperation of all concerned. Proper conditioning of broken rock (with 
water), adequate dilution volumes of fresh air, adequate enclosures with sufficient 
exhaust volumes are all necessary to provide a clean healthy work environment. 
The effectiveness of any system is a function of how closely actual operating 
conditions meet design considerations. Supervisors and ventilation personnel must 
be prepared to explain the basic principles involved to operating personnel if 
maximum benefits are to obtain from existing installations ... 

Getting the muck out involves continual judgment by all those engaged 
as to what constitutes effective work practices. Any natural or induced 
propensity of the worker to neglect good work practices must be met by 



49 Silicosis and dust 

effective training and supervision. In turn the shift boss and related ventila- 
tion staff must be working under clear policy direction from senior man- 
agement. Production with safety and health poses a continuous challenge 
at every level. The Commission believes that codes of practice^" should be 
prepared to guide all parties and therefore recommends: 

That the Mines Inspection Branch within the Occupational Health and 
Safety Authority, in consultation with industry and the representatives of 
workers, prepare, under clearly defined statutory authority, Codes of 
Practice applicable to all mines relating to: I / the prevention and 
confinement of dust at each distinctive class of workplace; 2 / the provision 
of ventilation in the breathing zone of workers that is effective for purposes 
of protecting health at each distinctive class of workplace (including vehi- 
cles); 

That the management of each mining operation or appropriate part thereof 
be required under clearly defined statutory authority to prepare and keep 
updated a Scheme of Practice for implementing the foregoing codes;^^ 

That the management be required to appoint a competent person to super- 
vise the over-all operation of the scheme. 

The documentary basis for such schemes is implicitly present in the 
policies and procedures of each mining operation. It is being recommended 
that these be compiled into a local manual of practice explicitly concerned 
with the interplay between production, safety, and health, and it is essen- 
tial that responsibility for carrying out the scheme should be clearly as- 
signed. In underground mining it is singularly important that the shift boss 
be conversant with the scheme of practice as it applies to day-to-day work 
and with his responsibilities under it. Such a plan is intended to provide a 
manual for the guidance of workers and supervision, a point of reference 
for the auditing of operations by mine inspectors and for the promotion of 
understanding of underlying problems between management and the rep- 
resentatives of workers. 

DUST STANDARDS 

Industry-wide dust control in Ontario mines continues to be based on the 
konimeter. Such measurements, however, are not indicative of an 
individual's personal exposure to dust over a working shift and are thus 
inadequate. 



50 The health and safety of workers in mines 

The industry has expressed confidence that adherence to its dust 
guidehnes will lead to the continuing decline of silicosis as a disease. The 
radiological progression data presented support this view for mines other 
than the Elliot Lake uranium mines. The historical growth of the propor- 
tion of the dust-exposed population working with ores having lower free- 
silica content than those of gold and uranium is a significant circumstantial 
factor in favour of a decline of the disease in the industry as a whole. 
However, individual workers have the right to reasonable assurance that 
their dust exposure at work is within standards designed to protect their 
health. A low incidence of disease in the whole population of dust-exposed 
persons may correspond to a much higher incidence among workers en- 
gaged in 'worst case' jobs. The Commission therefore recommends: 

That the Occupational Health and Safety Authority establish hy regulation 
a dust standard for personal exposure to free silica in mine and plant 
aerosols based on a time-weighted average of respirable dust intensity 
over a working shift and a stipulated lifetime period, of exposure. 

That the dust standard for time-weighted average exposure be established 
on a statutory basis. 

The extent of personal exposure to dust during a working shift can be 
indicated by an instrument that continuously draws dust-laden air through 
a porous membrane on which the dust collects. By the nature of its design, 
the instrument can select the respirable range of particle sizes. With re- 
spect to silicosis the most commonly accepted measure of the pulmonary 
hazard of dust-laden air is the mass of respirable free silica, often expressed 
in milligrams per cubic metre of air. 

The introduction of a statutory dust standard must be undertaken with 
meticulous care.^^ The promulgation of a numerical standard alone is 
pointless. Before a standard can become effective for the protection of 
health all of the following points must be dealtwith, some of them involving 
codes of practice and others requiring regulations: 

1 the choice of the property of respirable dust to be used as an indicator of 
exposure and the specification of the means for measuring it; 

2 the specification of the selection characteristic for aerosol particles of 
different size (to establish the definition of respirable dust); 

3 the adoption of a commercially available instrument technology^^ capa- 
ble of collecting dust over a working shift with the necessary accuracy and 
reliability under field conditions; 

4 an approved and readily accessible service for the accurate assessment 



51 Silicosis and dust 

of instrument readings and for the regular calibration of instruments; 

5 a code of practice for the use and maintenance of instruments; 

6 regulations identifying the persons considered to be in dust exposure; 

7 regulations governing the frequency and conditions of regular sampling; 

8 regulations governing the keeping and reporting of dust and related 
occupational records of individuals; 

9 regulations defining how 7 and 8 are to be extended when the current 
samples at a given workplace or class of workplace are not in compliance 
with the standard; 

10 operative understanding of, and confidence in, the purposes of the 
monitoring program on the part of all affected parties. 

Over a period of years the Mines Accident Prevention Association in 
co-operation with the Canada Centre for Mineral and Energy Technology 
and with the assistance of the Mclntyre Research Foundation has been 
conducting experimental studies on the measurement of respirable dust on 
a full-shift basis in representative Ontario mines. ^'^ Experimental results of 
recent gravimetric measurements are summarized in Table 12. The Com- 
mission believes that this work, using the x-ray method of measuring the 
mass of free silica in the total mass of dust collected over a full shift, 
establishes the feasibility of introducing a personal dust standard in Ontario 
mines. There are practical problems of achieving all of the conditions for 
effectiveness that have been listed, but the existence of these problems is 
not an excuse for delay in resolving them. 

It is proposed that a statutory standard for dust exposure be attained in 
two stages. Therefore, it is first recommended; 

That the Occupational Health and Safety Authority immediately establish 
by regulation an interim threshold limit value (TLV) for the mass of 
respirable free silica in milligrams per cubic metre. 

That the interim TLV have the status accorded by the Occupational Health 
and Safety Authority to threshold limit values as issued by the American 
Conference of Governmental Industrial Hygienists. ^^ 

That the Occupational Health and Safety Branch prepare a code of re- 
quirements for the gravimetric measurement of dust in all mines suited to 
determining personal exposure to dust. 

That all steps necessary to render effective a gravimetric standard of dust 
measurement including those listed herein be implemented immediately. 

It is suggested that the initial code of requirements for gravimetric 



52 The health and safety of workers in mines 



TABLE 12 








Experimental gravimetric dust 


measurements 




underground in four Ontario mines 










Average 


Samples 






mg/m^ of 


over 


Type of Samples 




free 


0.1 mg/m^ 


mine (n) 




silica 


(N) 


Nickel 151 




0.03 


4 


Gold 








Mine A 231 




0.06 


45 


Mine B 119 




0.13 


53 


Uranium 165 




0.11 


71 



source: Mines Accident Prevention Association of Ontario, Gravi- 
metric Sampling in Metal Mines, May 1 975. Airflow 2. 1 litres/minute ; 
size selection characteristic according to United Kingdom practice in 
accordance with the recommendations of the Johannesburg Confer- 
ence of 1959. 



measurements place emphasis on classes of workplace known to be dusty 
and on those which have consistently not met the dust guidelines of the 
Mines Accident Prevention Association. 

The TLV for the respirable mass of free silica as introduced by the 
American Conference of Governmental Industrial Hygienists in 1968 is 
effectively 0. 1 mg/m^ under a specified size-selection characteristic.^^ This 
standard has a mandatory status under federal jurisdiction in us metallic 
and non-metallic mines. ^"^ Sweden is currently adopting a dust index based 
on the size-selection characteristic recommended at the Johannesburg 
International Conference on Pneumoconiosis in 1959.^^ This index for free 
silica is unity at a mass level of 0. 1 mg/m\^^ A recent study of the us 
National Institute for Occupational Health and Safety proposes a tlv of 
0.05 mg/m\^^ This proposed standard is based on epidemiological data for 
workers in the Vermont granite sheds where the amount of quartz in total 
dust is 25 to 35 per cent."^^ The original studies.were based on the use of the 
impinger instrument, which counts particles of total dust. Later studies 
have inferred a mass equivalent of respirable dust for impinger counts of 
total dust. The niosh criteria document states: Tt is recommended that 
the studies in the granite industry be confirmed and that similar studies be 
undertaken in other industries to determine more precisely the significance 
of free silica in those industries so that alternate recommendations can be 
made, should they be indicated. '"^^ 

To establish a statutory dust standard it is essential to conduct 



53 Silicosis and dust 

epidemiological research that will relate silicosis to the conditions of dust 
exposure as measured by a standardized instrument at the workplaces 
where the standard is to apply. It has been previously noted that while free 
silica is a known hazard, mine and plant aerosols are complex and may 
contain, in addition to compounds of the metal mined, compounds of many 
other metals and of the rare earths, along with oil globules, radioactive 
particles and diesel particulates."^^ It is therefore recommended: 

That to provide a basis for establishing a statutory standard or standards 
for time-weighted average respirable dust exposure in Ontario mines and 
plants, the Occupational Health and Safety Branch commission 
epidemiological research on the relation (f incidence of silicosis and of 
other pulmonary effects to the structure and quantity of aerosols respired 
in Ontario mines. 

That where more than one recognized toxic component is present in the 
aerosols the standaid specify how an effective combined exposure limit is 
to be determined. 

The determination of statutory standards in the end involves a decision 
on what constitutes an acceptable human risk in the face of desired 
economic benefit, available technology and economic cost. Hatch has 
carefully reviewed practices in setting standards in the usa as contrasted 
with those in the ussR.^"* The Threshold Limit Value used by the American 
Conference of Governmental Industrial Hygienists implies an accepted 
risk after extended exposure for a small number of susceptible persons. "^^ 
In practice the crucial evidence is that of human response to the levels 
actually achieved at the workplace. Environmental standards for the 
workplace that are not complied with are a fiction. 

Until the gravimetric method of measurement is in effective operating 
practice and the appropriate statutory standard or standards are invoked, it 
is imperative that the current dust-measuring practice based on the 
konimeter be continued as a means of controlling dust levels. It is therefore 
recommended: 

That the existing code of requirements for dust measurement in the 
uranium mines as issued by the chief engineer of the Mines Engineering 
Branch remain in force. 

That the system of measurement and reporting being conducted by the 
Mines Accident Prevention Association continue in operation and be 
subject to independent monitoring as recommended. 



54 The health and safety of workers in mines 

The current broad guideHnes of the mapao have been developed on the 
basis of the percentage of free silica in total dust. There appears to be no 
logical ground for altering the basis of these guidelines to the percentage 
free silica in respirable dust, which is a highly variable quantity. 

The effect of the foregoing recommendations is to retain the present 
system, of dust measurement while gravimetric methods are being intro- 
duced and proven. When the statutory standard for time-weighted expo- 
sure to dust averaged over a working shift is invoked for all mines, the 
industry should be free to continue or discontinue current konimeter prac- 
tice. To terminate this practice before a personal dust standard is effec- 
tively in place would remove a useful, if imperfect, control of the work 
environment in the mines. 

WORK ADJUSTMENT AND WORKMEN'S COMPENSATION 

The terms of reference of the Commission directed it to review the present 
basis for workmen's compensation as this relates to environmental health 
matters affecting miners. Compensation under the Workmen's Compensa- 
tion Act for silicosis and other industrial diseases is not directed to the 
impairment as such, but is rather to prevent, in part, loss of wages as a 
consequence of the person being unable to continue in his regular employ- 
ment. 

The process by which a claim is accepted for silicosis is as follows. Each 
new claim is examined by the medical staff of the Board, which reviews the 
occupational history of the claimant and the radiographic and other rec- 
ords, and seeks a recommendation from the Advisory Committee on 
Occupational Chest Diseases of the Ministry of Health. ^^ That committee 
conducts a clinical assessment of each referred claimant to determine if 
there is silicosis and observable impairment. When impairment is present, 
the Advisory Committee recommends to the Board a percentage disability 
to be assigned for purposes of compensation. The Board then decides 
whether to accept the claim and the amount of the award. The Commission 
believes this administrative practice to be just and equitable. 

The problem of silicosis in the Elliot Lake uranium mines presents new 
and pressing problems with regard to compensation policy and practice. 
The Commission believes that extended rehabilitative provisions should 
be made for persons who have worked in the uranium mines, and that these 
should be provided to persons who experience exceptional conditions of 
exposure to other occupational health hazards. 

The principle underlying the recommendations is one of work 



55 Silicosis and dust 

adjustnicnl. that is, of providing, to workers likely to be impaired by 
continued exposure to environmental health hazards in their current work, 
assistance in transferring to work involving what may reasonably be im- 
puted to be less exposure. The Workmen's Compensation Board, man- 
agement, and unions each have an important role to play. The Board can 
assure that such services are available when initiative by management and 
supported by unions is insufficient. 

In framing the recommendations, the Commission has found it essential 
to review the central tenets of compensation under the Workmen's Com- 
pensation Act, which are rooted in the landmark report of Chief Justice 
Meredith. ^^ The essence of workmen's compensation is that risks of work 
manifested in accidents and disease attributable to work should be com- 
pensated out of the wealth generated by the industry employing the 
worker. In every case of industrial injury or disease that impairs a worker's 
ability to do his or her work (or results in death) partial compensation for 
lost income is made Vv'ithout regard to fault. ^^ In accepting this system of 
compensation the worker and the employer give up the legal right to action 
for negligence under common law.^^ Rights to damages for pain and suffer- 
ing and for the inconvenience, discomfort, and anguish associated with 
being maimed or disfigured are part of the rights under common law given 
up by the worker in obtaining the advantages of compensation without 
regard to fault. One provision under Section 42(6) allows for a lump-sum 
payment in compensation for serious facial disfigurement.^^ 

The Workmen's Compensation Board provides payment for loss of 
income. In addition, it provides medical, hospital, and rehabilitative ser- 
vices, including retraining programmes designed to minimize the effect of 
injury and disease on the person and on his or her capacity to maintain 
income. 

The funds to compensate mine workers derive from levies made by the 
Board on employers in Class 5 of Schedule 1 of the Act.^' These assess- 
ments include the costs of administration of the Board and of the Mines 
Accident Prevention Association. Currently, the costs paid out of these 
assessments, when averaged over the employers in Class 5, amount to 
about 6 per cent of the gross annual payroll of the employees covered. The 
Act now treats industrial disease in the same manner as an accidental 
injury. ^^ That is, a workman recognized as suffering from a compensable 
industrial disease is eligible for awards under the Act as from the date of 
recognition, and there is no longer.the requirement that the worker remove 
himself from the industrial exposure deemed to be contributive to the 
disease. 



56 The health and safety of workers in mines 



TABLE 13 

Comparative exposure times in years from first dust exposure 
Ontario to dust effects in lungs (Radiographic 4) 


in 


Period found 


exposed in 1960-4 1965-9 


1970-4 


Uranium only 3.2 7.5 
Uranium and other 13.2 15.1 
Other than uranium 15.0 16.6 


11.3 
18.7 
20.6 



note: Dust exposure in Ontario only. 

source: Workmen's Compensation Board, 'Silicosis Report Pro- 
gramme,' November 1975, Table 2.4 



Silicosis is a disease that, unlike lung cancer, is clearly attributable to an 
identifiable cause, namely, silica-laden dust at the workplace. In addition 
radiography of the lungs yields clear precursor indicators that precede the 
disease. The disease involves a lessened capacity for work. Thus the 
sequence of pulmonary events for a person who has become a silicotic is a 
radiographic category 4 (dust effects), followed by a radiographic category 
5 (radiological silicosis), followed by the disease silicosis. By no means all 
mine workers whose lungs come to exhibit dust effects actually progress to 
become silicotics. Nevertheless, in a probabilistic sense dependent on the 
intensity of continuing exposure to dust, a radiographic 4 may be presumed 
to be evidence of the likelihood of progression to a state of disease, even 
though there is at this stage no clinical evidence of lung impairment. 

It is but common sense that younger workers especially should be given 
the opportunity and assistance to get out of current dust exposure if there 
is strong statistical evidence or a basis for clinical judgment that they are 
likely to progress to impairment or increased impairment unusually rapidly 
by continuing in their current work. This is the principle of work adjust- 
ment, which the Commission believes should be invoked in exceptional 
exposure situations such as those in the Elliot Lake Mines. Table 13 
provides comparative statistical data on dust exposures required to pro- 
duce dust effects in the lungs of mine workers. ^^ This table shows that 
miners who have worked only in Ontario and only in uranium mines and 
who came to exhibit dust effects in their lungs in the period 1970-4, reached 
that state in approximately half the time of persons who have worked in 
other than uranium mines. It is therefore recommended: 

That the current employees in the Elliot Lake uranium mines who are 



57 vSilicosis and dust 

silicotics or exhibit dust effects irudioi^idpliic 4) in tiicir lun^s he elif^ihle 
for a voluntary proi^ranune of work (ic/Justnient; that this proi^rcnnme he 
supported hy management and unions; and that the Workmen's Compen- 
sation Board provide rehabilitative compensation and supportive coun- 
selling services to assist the persons involved. ^"^ 

The Board's entitlement to provide rehabilitative compensation is 
defined in Section 53, which reads: 'To aid in getting injured employees 
back to work and to assist in lessening or removing any handicap resulting 
from their injuries, the Board may take such measures and make such 
expenditures as it may deem necessary or expedient, and the expense 
thereof shall be borne, in Schedule 1 cases, out of the accident fund and, in 
Schedule 2 cases, by the employer individually, and may be collected in the 
same manner as compensation or expenses of administration ...' 

This section refers to injured workmen. While silicotics are clearly 
injured persons and eligible for rehabilitative compensation designed to 
sustain income and to lessen further impairment, it is not clear that persons 
with dust effects and no clinically observable impairment are injured in the 
sense of the above section. ^'^ It is therefore recommended: 

That Section 53 of the Workmen's Compensation Act be amended as 
necessary to provide clear entitlement for rehabilitative compensation 
based on the principle of work adjustment for persons subject to excep- 
tional exposure to environmental hazards at work. 

Invoking a principle of work adjustment must not be permitted to lessen 
the commitment of management, labour, and government to reduce the 
exposure of workers to all known hazardous substances to levels of ac- 
ceptable risk. If one worker, on grounds of personal protection, is assisted 
to move from one workplace to another, entailing less intense exposure to a 
given substance, it is reasonable to infer that another worker will take his or 
her place. In a direct sense, then, work adjustment leads to the exposures 
associated with a given level of industrial production being spread over a 
larger set of persons. ^^ In this regard it is recommended: 

That any employer who rotates job assignments for workmen with the 
intent of limiting the occupational exposure of any persons to any hazard- 
ous environmental condition be required to obtain the formal approval of 
the Occupational Health and Safety Branch and to maintain permanent 
occupational records which clearly define the persons, tasks, locations, 
hazardous conditions, and time intervals involved. 



58 The health and safety of workers in mines 

Workmen's compensation exists to deal as fairly as possible with the 
fact that accidents and industrial disease do, and inevitably will occur. The 
principle of work adjustment represents a significant extension of the 
concept of compensation made with the intent of lessening the likelihood of 
initial impairment or of further impairment in those special situations of 
susceptibility and exceptional exposures that can be clearly identified. At 
the same time, it is the palpable hazards of the workplace that are at issue, 
and workmen's compensation is not a suitable vehicle for dealing with 
broad questions of social disability. 

A work-adjustment programme for a person should contain assisted 
opportunity for one or more of the following elements: 1/ transfer to 
equivalent or new work within the mine or plant of current employment; 2/ 
transfer to comparable or new work in a mine, plant or other industry at 
another location in Ontario; 3/ retraining for the new work if required; and 
4/ planning and carrying out the relocation of the family and home where 
that is indicated. 

Further, in effecting work adjustment for a person it is essential that his 
or her current income be sustained. It is therefore recommended: 

That during' a programme of personal rehabilitation through work adjust- 
ment, and for a minimum period of two years thereafter, the ineome of the 
worker he maintained in accordance with the provisions of the Workmen s 
Compensation Act for full compensation which allow the board to pay in 
non-taxable compensation 75 per cent of the difference between the cur- 
rent rate of pay and the rate of pay applicable at the date of entry into the 
programme; 

That in addition to wage maintenance, the worker in a work-adjustment 
programme be eligible for rehabilitation training allowances as provided 
for in the Workmen s Compensation Act; 

That, further, the worker be entitled to reasonable costs for medical and 
personal counselling beyond that provided by the Workmen's Compensa- 
tion Board, and to reasonable moving, travelling, and related relocation 
costs when these are applicable. 

The Commission's impression is that mine workers by and large are 
committed to mining. It is therefore essential that there be no hindrance to 
their mobility for purposes of work adjustment resulting from the adminis- 
trative practices of the Board in levying charges for disability pensions 



59 Silicosis and dust 

against employers. The practice has been to charge the employer ol^ a 
silicotic, at the time of his recognition, the full disability pension costs for 
the lifetime of the person, even though the person may have come to this 
employer with dust effects in his lungs. ^^ If the present policy of assessing 
companies is continued, it is recommended: 

That when the hin^s of a worker exhibit dust effects and the worker seeks 
the opportunity throui^h work adjustment to take emph)yment with a new 
empU)yer, the new employer not he held liable for any disability pension or 
other costs for silicosis or disease conditions related thereto that may be 
levied as a consequence of the person becoming a silicotic at a future date. 

This problem, under current administrative practice, does not exist for 
silicotics. 

A work adjustment programme offers no panacea for the employee and 
his family. It involves a decision whether the expected benefits of personal 
well-being that may or may not accrue from moving out of one form of 
environmental exposure into another place of work will outweigh the 
economic, personal, and family costs of uprooting and change. When 
counselled to do so, younger persons should, in the Commission's view, be 
encouraged, and if necessary required, to undertake work adjustment. The 
programme provides no special assistance if the worker elects to remain in 
his current employment. With regard to work adjustment and so-called 
pre-silicotic effects, it is essential that all evidence be marshalled that can 
assist the making of decisions. It is therefore recommended in particular: 

That the Occupational Health and Safety Branch commission research on 
the radiographic records related to miner's certificates to assess the rela- 
tive rate of progression of persons in and out of dust. 

The foregoing analysis has made reference primarily to the current work 
force at Elliot Lake. The Commission's intention is that it should be 
applicable as far as is feasible to the Uranium Nominal Roll of all persons 
who have worked in the uranium mines and to other less obvious subpopu- 
lations of exceptional exposure. 

Of the some fifteen thousand persons having one or more months of 
exposure in the uranium mines to the end of 1974, the great majority have, 
since about 1962, dispersed widely from these mines. There is no feasible 
way of tracing the majority, but it is reasonable to suppose that many will 
not now be in dust exposure. However, the Commission recommends: 



60 The health and safety of workers in mines 

Tliat persons on the Uranium Nominal Roll who exhibit dust effects 
(radiographic 4) within twenty years of entry into Ontario dust exposure, 
and who have been employed in dust exposure in the uranium mines for a 
cunudative interval of five or more years from 1954 to 1975 inclusive, be 
eliiiible for rehabilitation assistance under a programme of work adjust- 
ment. 

Finally, since the principle of work adjustment is a basic one, it is recom- 
mended: 

That where there is evidence that the exposure of any person to silica-laden 
dust has been substantially in excess of established dust guidelines or 
standards and the person has exhibited dust effects in his or her lungs 
within twenty years of first exposure to dust in Ontario, the person be 
eligible for work adjustment rehabilitation assistance. 

This recommendation has two purposes. The first is to assist younger 
persons for whom there may be some benefit. The second is to ensure that 
management, labour, and government address themselves to exceptional 
conditions of exposure as well as to average conditions. 

Having examined the details of the policy of work adjustment and 
rehabilitation assistance that the Workmen's Compensation Board has 
initiated for the current population of workers at Elliot Lake, the Commis- 
sion believes this policy, as it concerns silicotics and persons with dust 
effects, effectively addresses the principles that have been stated. 

An effective programme of work adjustment calls for the co-operation of 
management and labour. Managements can facilitate work adjustment 
within the range of workplaces that characterize their operations. It is here 
that work adjustment is likely to be most meaningful. They must act 
generously. The distinctive unity of the industry gives it special opportun- 
ity to facilitate an over-all programme of work adjustment. While unions 
may properly argue that the problem is not of their making, they can 
improve local work adjustment opportunities by making special provision 
for such persons not to be subject to conventional seniority rules. The 
latest collective bargaining agreements at the Elliot Lake Mines make such 
provision. ^^ Both unions and management deserve commendation for 
these arrangements. 

In all of these matters it is imperative that the privacy of the worker be 
protected and that initial counselling be undertaken privately between the 
worker, his attending physician, and the staff of the Workmen's Compen- 



61 Silicosis and dust 

sation Board. Once the person elects to undertake work adjustment, his 
special status will of necessity be known by his actual and potential em- 
ployers. 

For reasons elaborated in chapter 3 the Commission's endorsement of a 
work adjustment policy for silicotics and pre-silicotics in the uranium 
mines is based on evidence that the risk of silicosis is substantially higher 
than the risk of attributable lung cancer. 



1 Free silica, as distinct from bound silica, in such compounds as silicates 

2 The Ontario classification scale for x-rays was adapted from South African practice and 
has been used in its current form since 1937. It is distinctly different from the current 
international classification system adopted by the International I.abour Organization in 
1971 (ILO International Classification of Radioi>raphs of the Pneumoconioses, 1971 , 
Occupational Safety and Health Series No. 22. Geneva, 1972). Five on the Ontario scale 
corresponds approximately to one on the ilo scale. 

3 These are associated with old surface milling operations. 

4 There have been many reviews of radiological and disease data relating to silicosis in the 
mining industry. These include two studies by J.F. Paterson commissioned by the gov- 
ernment (J.F. Paterson, .S/7/(7^s/.s in Hardrock Miners in Ontario. Toronto: Department of 
Mines, Bulletin 155, 1959; and Silicosis in Hardrock Miners in Ontario: A Farther Study, 
Toronto: Ministry of Natural Resources, Bulletin 173, 1973). reports and papers of the 
Ontario Mining Association, reports of the Mclntyre Research Foundation and of the 
Workmen's Compensation Board. The majority of these sources are documented in Dr 
Paterson's first report and in the briefs to the Commission from the Mclntyre Research 
Foundation and the Mines Accident Prevention Association. The most comprehensive 
report to date was issued by the Workmen's Compensation Board in March 1976 (W.C. 
Wheeler, Statistics on Silicosis Amoni> Miners in Ontario, Workmen's Compensation 
Board, March 1976). The historical use of aluminum powder as a prophylactic agent for 
silicosis is reviewed in Brief 99, and assessments of its use are given in the reports of 
Paterson and in J.F. Cowle, 'Health hazards of dust inhalation (pneumoconiosis),' 
Canadian Mining Journal, Oct. 1970, 64. Its use is not favoured in Germany or South 
Africa. 

5 An historical review of the development of the Board's policies in compensating silicosis is 
given in its brief to the Commission (transcript 4702-25). Under the current Workmen's 
Compensation Act, S. 1(2), ' "silicosis" meansafibrotic condition of the lungs sufficient to 
produce a lessened capacity for work caused by the inhalation of silica dust.' Under S. 

1 18( 10) an employee is entitled to compensation only after dust exposure in Ontario for 
periods amounting to at least two years. 

6 The data used in Figures 2 and 3 derive from the Silicosis Disability Index issued in 
November 1975 by W.C. Wheeler, chief of Statistical Services of the Workmen's Com- 
pensation Board as part of the Medical Statistics Program established by the Board in 
co-operation with the Mines Accident Prevention Association in 1950. 

7 Dominion Bureau of Statistics, Canadian Life Tables, 1960-1962, Ottawa: Queen's 
Printer, Catalogue Number 84-5 16, 1964 

8 Paterson , Silicosis [ 1 973 1 , 7-8 and 13-14 

9 Mclntyre Research Foundation, fi/vV/V^^ the Royal Commission , Table mrf6, .Appendix a 
updated through 1974 at the request of the Commission. 

10 Since many workers move from job to job within, between, and outside mines, they may 
move into and out of dust exposure during their careers. Further, some cases of silicosis 



62 The health and safety of workers in mines 

are found years after workers have left the mining industry. Hence, elapsed time is always 
greater than or equal to years of dust exposure. 

1 1 Pate rson . .V ///( o.si.s |i 973 ] . 33 

1 2 Accurate man-years-at-risk were not available to permit a proper epidemiological calcula- 
tion. The factors determined are qualitatively correct. The period of averaging of popula- 
tion was chosen in relation to the observed elapsed time from first dust exposure to 
silicosis. 

13 The recognized cases derive from the retired as well as the working population. 

14 Tests of other reasonable averaging periods did not lead to any significant change in the 
pattern of incidence factors by time period. 

15 J.F:. Cowle. H. Mastromatteo. A.C. Ritchie. 'An unusual pneumoconiosis in the Ontario 
mining industry/ Transactions ofthc'34tli Annual Meeting of the American Conference of 
Governmental Industrial Hyf^'ienists. May 1972, 126-35. It hasbeen suggested that irradia- 
tion of the lungs in uranium miners enhances the fibrotic effects of silica dust. See for 
example E. Trapp et al., 'Cardiopulmonary function in uranium miners.' American 
Review of Respiratory Disease, 101, 1970. 27-43. 

16 As of 1 January 1974 all industrial disease recognized under the Workmen's Compensation 
Act was treated as industrial accidents are and became eligible for receipt of compensation 
at the date of recognition. This policy change is likely to have a significant effect on the 
future statistical pattern of recognized silicosis and indeed of other compensable condi- 
tions such as hearing loss. 

17 The policy of the Workmen's Compensation Board is to charge all costs of compensation 
for silicosis to the company in whose employment a person is at the time he is recognized, 
regardless of his occupational history. 

18 'An unusual pneumoconiosis.' The first case of silicosis was charged to a uranium mine in 
1963. All cases charged to uranium mines to the end of 1974 experienced first dust 
exposure in Ontario in 1930 or later. 

19 The cases considered were all those for which the first disability rating was less than 100 
per cent. The average disability rating among the groups was consistent at about 25 per 
cent. 

20 These radiological classifications are different from the classifications by 'mine group 
charged' as used with reference to Table 8. 

21 Sufficient time has not yet elapsed for any later five-year data. 

22 Of all the persons who at some time exhibit dust effects in their lungs many of course do not 
progress to become silicotics. 

23 The Workmen's Compensation Board, in co-operation with the Ontario Mining Associa- 
tion, has developed a Nominal Roll of persons who have experienced one month or more 
of exposure in the uranium mines including those in the Bancroft area. To the end of 1974 
this roll had some fifteen thousand names. 

24 Ontario Ministry of Health, Survey of Certain Conditions of The Respiratoiy Organs 
Among Persons Employed Underground and in Surface Crushers and Mills of Two 
Operating Uranium Mines at Elliot Take, Ontario, Toronto, April 1975, 49; for silicosis 
refer to 9-1 3 , 37-4 1 , 45 , 48-9 

25 To the end of 1974, some 347 radiological ratings of 4 and 140 ratings of 5 had been found 
among persons on the Nominal Roll. Continuing radiological records for some of the 
persons on the Nominal Roll are not available because they have moved out of Ontario or 
out of the industry. The current dust-exposed population at Elliot Lake represents about 7 
percent of the total number of persons on the Nominal Roll. 

26 Pate rson.. S/7/Vm/,s 11 959 and 1973] 

27 The full relation which I believe this authority should have with mine workers is spelled 
out in chapter 6. 

28 A new mine at Agnew Lake near Espanola opened in the spring of 1976. 

29 Ontario, Special Committee on Mining Practices at Elliot Lake, Report: Fart I .Accidents 



63 Silicosis and dust 

(ind Ri'liitcd Rcprcscntntions: l\ii( 2. Mininf^ /*r<i( ticc.s . Toronto: OnUnio I)cp;iilmcnt of 
Mines, Bulletin 155. 1959. 

30 Special C\>mmiltee on Mining Practices at l.lliol Lake, Appendix i), 1-2 

3 1 Mining Act, Part ix, S. 169( 1 ). (2). and (6) and S. 213 ( 1 ), ( 10), and (12a). and S. 214 ( hand 
(4) 

32 it has been noted that the provision for this Association is made under the Workmen's 
Compensation Act, S. 119(1). 

33 For a commentary on the politics of mineral development see H.V. Nelles. The I'olitK s of 
Development, Toronio, 1974. chap. II. 

34 1 micron = 10 ^ metres. 

35 T.F. Hatch, P. Gross, Fiihnondry Deposition and Retention of Inluded Pcutides. New 
York. 1964 

36 Settling velocity may be on the order of centimetres per hour. 

37 International Labour Office. Dust Sampling in Mines, Geneva: ilo Occupational Safety 
and Health Series. No. 9. 1972 

38 G.H.C. Norman, 'Methods of sampling and dust determination in the mines of Ontario," 
American Institute of Mining and Metallurgical Engineers, November 1937. 1-20 

39 Magnification 150 times in a dark field 

40 Mines Accident Prevention Association, i5r// Annual Report, May 1969. 8 

41 Mines Accident Prevention Association, Semi-Annual Dust Survey Procedure. 1974 

42 Exhibit No. 8- Figures 1-5 of brief submitted by Denison Mines 

43 C.S. Gibson, 'Limiting factors in dust control and ventilation." a paper presented at the 
Sixth Conference of Mclntyre Research Foundation on Silicosis held in Toronto. Ontario 
1-3 February 1954 [Gibson was safety director and chief engineer and secretary. Commit- 
tee on Silicosis, Mines Accident Prevention Association.] 

44 Exhibit No. 130- Memorandum: 'Dust control in uranium mines, 25 May 1955," included 
in the Ontario Mining Association's presentation to the Commission 

45 Mines Accident Prevention Association of Ontario. First Report Dust Control, Ventila- 
tion and Radioactivity at Bicroft Uranium Mines Limited -Subject: Suney of Under- 
ground Operations , January 1956. Similar surveys by the same Association were reported 
on: Faraday Uranium Mines Limited (All Operations), January 1956; Pronto Uranium 
Mines Limited (All Operations), March 1956; Quirke Mine, Algom Uranium Mines 
Limited (All Operations), June 1956; Nordic Mine, Algom Uranium Mines Limited (All 
Operations), ianuary 1957. 

46 Exhibit No. 130- Memorandum: 'Dust control in uranium mines. 25 May 1955," included 
in the Ontario Mining Association's presentation to the Commission 

47 Ibid. 

48 Exhibit No. 135 - included in the presentation by the Ministry of Natural Resources to the 
Commission as Resource Document No. 2 to its brief. 

49 FatQrson, Silicosis [1959] 

50 Ontario Mining Association, Minutes of Annual Meeting, 15 June 1959 

51 Asbestos mines have been surveyed by the Ministry of Health at the request of the 
Ministry of Natural Resources. 

52 Brief presented to the Commission by L. Williams on behalf of United Steelworkers of 
America. District 6. (transcript 341 1) 

53 In Figure 9 the graph for uranium mines includes all uranium mines. After 1964 the only 
operating uranium mines were in the Elliot Lake area. The early dust levels in the Bancroft 
area mines were comparable to those in the Elliot Lake Mines. The historical pattern 
shown in Figure 9 is not significantly changed by their inclusion from 1958 to 1964. 
Workplace-averages by class of mine corresponding to the underground mine-average 
data of Figure 9 are given in Appendix d. Tables d.2 to d.4. These tables also provide the 
gross ventilation flow rate in cubic feet per minute per ton of ore hoisted per day. 

54 Ministry of Natural Resources, Mines Engineering Branch, letter from W. Bawden to 



64 The health and safety of workers in mines 

engineers. 6 July 1959. The current practice of the engineers was confirmed in interviews 
with senior ministry staff and field staff. 

55 'Rafter' dust as settled out from the air at the workplace 

56 Mines Accident Prevention Association, /l/V/?o/7?(' Contaminants, Minhiii. Milling, Snwlt- 
ini> and Ri'Jinini>, 1st ed.. Toronto, 1969 

57 Exhibit No. 2 - Mines Accident Prevention Association, Comments on Results of Surveys 
of Air Conditions in Ontario Mines for the period endins^' March 3 L 1974 

58 In chapter 6 the relation of the labour unions to the self-regulatory organizations of 
industry is discussed. 

59 Mines Accident Prevention Association, Comments on Results of Surveys of Air Condi- 
tions in Ontario Mines for the period ending March 31 , 1974 

60 Under the existing Mining Act there is no legal recognition of codes of practice, but the 
chief engineer of the Mines Rngineering Branch has issued such codes under the powers 
conveyed by Section 610. The Commission believes this procedure has been a sound one 
but intends that such codes should have the significance defined in the Health and Safety 
At Work Act. 1974. United Kingdom, underSections 15, 16. and 17. Recommendations for 
revision in the legal framework of the Mining Act are made in chapter 6. 

61 This concept is adopted from Part iv of the Coal Mines (Respirable Dust) Regulations 
1975. Statutory Instrument No. 1433. 1975, Health and Safety Executive, United 
Kingdom 

62 After a long period of epidemiological and instrument research, the United Kingdom 
, adopted its first statutory standard for dust in coal mines in September 1975. 

Recent reports of experience with gravimetric sampling in us coal mines provide 
insight into some of the difficulties. The problem of measuring coal dust is simpler than that 
of measuring the mass of free-silica in the dusts of the ores of metals: us National Bureau of 
Standards, An Evahiation of the Accuracy of the Coal Mine Dust Sampling Program 
Administered by the Department of the Interior -a Final Report to the Senate Committee 
on Labour and Public Welfare, np, December 1975; us Comptroller General. 
Improvements Still Needed in Coal Mine Dust Sampling Program and Penalty Assess- 
ments and Collections -Report to the Congress by the Comptroller General of the United 
States. Washington: us General Accounting Office, rfd-76-56. January 1976. 

63 Different types of instruments measure distinctly different characteristics of aerosols, so 
that their readings can only be compared on the basis of statistical correlation, preferably 
in standardized dust clouds. Much of the concern attending the release of the document 
entitled 'Survey of dust-radiation-diesel exhaust in uranium mines and mills at Elliot Lake, 
Ontario,' by the Occupational Health Protection Branch, Ontario Ministry of Health, in 
November 1974, was, in the Commission's view, related to attempts to compare non- 
equivalent measures of dust deriving from the midget impinger. the konimeter, and 
gravimetric instruments. 

64 G. Knight. T.E. Newkirk.G.R. Yourt. 'Full shiflassessment of respirable dust exposure,' 
Canadian Mining and Metallurgical Bulletin, April 1974. 61-72; 

P. Chmara. H. McLean, 'Gravimetric sampling in metal mines.' paper presented before 
the Mines Accident Prevention Association. May 1975 

The brief submitted to the Commission by the Canada Centre for Mineral and Energy 
Technology, Federal Ministry of Energy, Mines and Resources, Canada, reviews Cana- 
dian and related research on the measurement of dust (transcript 4143-213). 

65 American Conference of Governmental Industrial Hygienists, Threshold Limit Values for 
Chemical Substances and Physical Agents in the Workroom Environment with intended 
changes for 1975, Cincinnati, 1975 (henceforth cited as Ti v) 

66 American Conference of Governmental Industrial Hygienists, Transactions of the Thir- 
tieth Annual Meeting, May 1968; 1 1 v 33, 35 

67 us Mining Enforcement and Safety Administration, Metal and Non-metal Mine Health 



65 Silicosis and dust 

ami Sdjcfy StuniUinls and l<e^nl(itions , l*iihlic l.iiw H9-577 , Icilcrol Metal and Son- 
metallii Mine Safety Act, S. 57-5. 1 

68 F.J. Ovcns\c\n.(n\. J^r()(ecdiri}>s oj the I'neiinioconiosis Conference. Johannesburg. 1959. 
619-20 

69 Communication to the Commission during its visit to Sweden 

70 us Department ot" Health, Education and Welfare, niosh. Criteria for a l<e( onunended 
Standard ... Occupational lixpo.sure to Cry.stalline Silica, Washington: us Department of 
Health. Hducation and Welfare Publication No. 75-120, 121. This document provides an 
extensive review of international practices. 

7! Ibid., 75-7 

72 Ibid., 77 

73 D.S. Robertson, Thorium and Rare Earths in the Huronian Rocks of Elliot Eake and the 
surrounding region. New York, ny: Paper No. a68-3. The Metallurgical Society of aime, 
February 1968. 

Radioactive particles are discussed in chap. 3 and diesel emissions in chap. 5 ot the 
present report. It has been suggested that irradiation of the lungs of uranium miners 
enhances the fibrotic effects of silica. See, for example, E. Trappetal., 'Cardiopulmonary 
function in uranium mines.' 

74 T.F. Hatch, 'Permissible levels of exposure to hazardous agents in industry,' Journal of 
Occupational Medicine . 14, 1972, 134-7. Methods Used in the U.S.S.R. for Establishing 
Biologically Safe Levels of'To.xic Substances, Geneva, 1975. 

75 TLV, 1 

76 Brief presented to the Commission by the Workmen's Compensation Board (transcript. 
4702-35) 

77 Chief Justice Meredith, Report of the Royal Commission on Workmen's Compensation. 
Ontario: Sessional Papers, 46, 1914 

78 Current regulations provide for up to 75 per cent of the lesser of the current rate of 
earnings or a rate of $15, 000 per annum. Such payments are not subject to federal or 
provincial income tax. 

79 With minor exceptions explained in the Act. 

80 Mr Justice McGillivary , /?('po/7 of the Royal Commission in the Matter of the Workmen's 
Compensation Act, Toronio, 1967, 18-20 

81 Workmen's Compensation Act, Regulation 834 

82 Ibid., Section 118(1) 

83 See also Figures 5 and 6 for comparative evidence of current rates of progression from 
radiographic 4 to radiographic 5. 

84 Such a programme is now being invoked for current employees at the Elliot Lake mines at 
the initiative of the Board, unions, and managements. Over the years many silicotics have 
been provided with work-adjustment opportunities by their employers on an ad hoc basis. 

85 Nor is it clear that a person is injured in the sense of Section 53 who has accumulated a 
specified exposure to radiation or to any other hazardous substance. 

86 This result is somewhat analogous to using smoke stacks to lower the danger from 
concentrated effluents by a process of dilution in a larger volume of the atmosphere. 
Further, if a younger person replaces an older person he may be subject to higher risk of 
accident than the person replaced. 

87 When a mine ceases operation the continuing liability for silicotics is shifted to the mines of 
the same type remaining in operation. 

88 Collective Agreement Between Local 5762 United Steehvorkers of America and Denison 
Mines Limited, 1976, Articles 16 and, especially 16.01; Collective Agreement Between 
Local 5417 United Steelworkers of America and Rio Algom Limited. 1976. Articles 14 and 
17.01 



Lung cancer and ionizing radiation 
in the uranium mines 



INIRODUCTION 

Lung cancer, unlike silicosis, occurs in the general population, and is 
occurring with increasing frequency as shown in Table 14. The disease 
appears in response to such known cancer-inducing agents as cigarette 
smoke, ionizing radiation in uranium mines, asbestos fibres, and nickel and 
arsenic compounds,' as well as without recognized cause. Cases of lung 
cancer attributed to ionizing radiation experienced in uranium mines have 
been found to appear five or more years after the first exposure to 
radiation.-^ 

While the oat-cell type of cancer has been shown to occur more fre- 
quently among uranium miners exposed to ionizing radiation than among 
unexposed populations,^ all kinds of cancer are usually indistinguishable in 
form from those observed in persons who have not been so exposed. 
Consequently there is no definitive pathological basis for inferring that a 
particular lesion was induced by ionizing radiation. The relationship of 
lung cancer to the exposure of uranium miners has been established on a 
statistical basis by observing that it occurs more frequently among these 
persons than would be expected in a comparable population of persons not 
exposed to more than the normal ionizing radiation.'* Even when a statisti- 
cally significant excess of observed over expected cases is established, a 
decision to ascribe a specific case to conditions at the workplace still 
depends on a judgment of how the person's record of exposure compares 
with the exposure experienced by other workers. At best there may be 
epidemiology providing a dose-response relation to support the 
attribution."^ The work of Archer et al.^ shows that uranium miners who 
smoke cigarettes are much more likely to experience lung cancer than 



67 Lung cancer and ionizing radiation 



TABLE 14 

Male death rate per 100,000 of population from 
cancer of the trachea, bronchus, and lung 



All Under 
Period ages 15 15-24 25-34 34-44 45-54 55-64 65-74 75 + 



1950-4 


19.83 


0.03 


- 


0.37 


4.70 


31.28 


83.74 


112.17 


91.64 


1955-9 


25.08 


- 


0.05 


0.59 


4.97 


36.78 


112.03 


162.36 


128.96 


1960-4 


30.79 


- 


0.14 


0.54 


6.64 


39.52 


134.98 


218.70 


181.84 


1965-9 


37.36 


- 


0.10 


0.66 


8.46 


42.85 


145.94 


297.45 


252.21 


1970-4 


45.87 


0.02 


0.11 


0.68 


10.23 


48.69 


167.71 


346.89 


382.20 



note: Deaths categorized according to the International Classification of Diseases, a51, 

8th Revision 

source: Ministry of Health, Ontario 

non-smoking miners. In such a situation there is no single assignable cause 
for an individual case of cancer. 

There is epidemiological evidence that the risk of the development of 
lung cancer in silicotics is not greater than in the general population. On the 
other hand it has been suggested that irradiation of the lungs in uranium 
miners may modify and possibly enhance the fibrotic effect of silica.^ 

IONIZING RADIATION IN THE URANIUM MINES 

The ionizing radiation in mines arises from the spontaneous radioactive 
disintegrations associated with the decay chains of the naturally occurring 
isotopes of the elements uranium and thorium.^ There is a stage in each of 
these chains at which a gas is produced. The hazard of radiation in air 
breathed into the lungs arises mainly from the emanation into mine air from 
rock faces, broken rock, and mine water of the radioactive gas radon; 
thoron and actinon are radioactive gases of relatively lower hazard. 

Throughout the rock in the Canadian Shield, uranium is present in about 
3 parts per million and thorium in about 9 parts per million. These elements 
are more concentrated in many mineral deposits, especially in uraniferous 
ores . Wherever they are present in significant quantities there is a potential 
hazard from ionizing radiation in mine air if ventilation is not adequate. 
There is evidence from several countries, including Canada, of hazard 
from ionizing radiation in mines other than uranium mines. '^ The conditions 
in non-uranium mines in Ontario will be reviewed. 

The uraniferous ores under development in Ontario, as noted in Table 
15, have similar uranium grades and are therefore subject to comparable 



68 The health and safety of workers in mines 



TABLE 15 

Some comparative characteristics of uranium ores 
(approximate average values) 




Lbs/Ton 




Percentage 
of free 
silica 


Location 


U3O8 


Rare 
ThO, earths 


Agnew Lake 
Elliot Lake" 
Bancroft" 


2.5 
2.5 
2.5 


4 13 
1 6 
1 <1 


65 
65 

5^-15 



a North geological branch, which includes current operating mines 
b Madawaska Mine (formerly Faraday Mine) 

source: D.S. Robertson, Thorium and rare earths in the Huronian 
rocks of Elliot Lake and surrounding region,' TMS-AIME mectinf^. New 
York Feb., 1968; D.S. Robertson, Thorium and uranium variations in 
Blind River ores,' Economic Geology, 57, Dec. 1962, 1 175-84 



ionizing radiation from the uranium chains which lead to radon and acti- 
non. The Agnew Lake ore has a distinctly high thorium content, the 
element that sends thoron gas into mine air. The Agnew Lake ores are also 
rich in rare earths.'^ 

Practical control of ionizing radiation in mines has been based on mea- 
surements of dust and of radon and its daughters, which derive from the 
abundant uranium isotope U^^^ and cause most of the radioactivity in mine 
air." However, since ore of higher than usual thorium content'^ is to be 
mined at Agnew Lake, the Commission recommends as a matter of precau- 
tion: 

That the Atomic Energy Control Board confirm the extent to which thoron 
^His and its daui^hter products contribute to the irradiation of the respira- 
tory system and other organs of workers in Ontario uranium mines. 

THE MEASUREMENT OF IONIZING RADIATION 

The analysis which follows will deal for the most part with the effects of 
radon and its daughter products. Radon gas in mine air is transformed by 
spontaneous nuclear disintegrations into a sequence of distinctive particles 
called radon daughters. The chain of disintegrations, which terminates in a 
stable form of lead, is shown in Table 16. When disintegrations occur in 
mine air, a fraction of the resultant particles remain free in the form of 



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70 The health and safety of workers in mines 

unattached ions, while most particles become adsorbed to water droplets 
and particles of mineral dust, diesel soot, and so on. The combination of 
radon gas and these complex particulates forms the aerosol inhaled by 
miners and deposited in part on the surfaces of the respiratory pathways. 

At each characteristic nuclear decay there is released radiation in the 
form of beta rays, gamma rays, or alpha particles.'^ The damage to living 
cells, with the complex biological consequences that may lead to cancer, 
occurs when these particles and rays produce ionization along their paths 
of impact on the human body. Beta and gamma rays contribute primarily to 
external whole-body irradiation, alpha particles to internal irradiation. 

In the uranium mines, both external and internal irradiation of workers 
have been measured. For external irradiation a personal dosimeter, in the 
form of a film badge or semiconductor detector calibrated for gamma and 
beta rays, has been used over a working shift or series of shifts."* The 
personal dosimeter is read in Rems.'"^ There has been no code of require- 
ments for measurement of whole-body irradiation, but mines from time to 
time have taken spot measurements. 

The maximum permissible dose to the whole body of persons designated 
as Atomic Radiation Workers'^ is stipulated by Schedule ii of the Atomic 
Energy Control Regulations to be five Rems per annum, which is equiva- 
lent to 2.5 millirems per hour for a working year of two thousand hours. 
Table 17 gives representative current measurements in an Elliot Lake 
Mine. An ore grade of 6 lbs of UjO^ per ton in Elliot Lake mines is 
exceptionally high. This grade leads to a dose rate slightly over one-half the 
maximum permissible dose. Measurements in United States mines with 
ores of comparable grade reveal a pattern of values similar to that in Table 
17.'^ 

Despite the fact that current records show external whole body irradia- 
tion from gamma and beta rays to be within the existing standard as 
specified by Atomic Energy Control Regulations, for two reasons the 
Commission believes that some sampling by personal dosimeter using 
solid-state detector technology should be carried out. The industry is 
expanding, and ore grades vary. It is essential that there be assurance that 
whole-body dose is kept as low as practicable. Further, such measure- 
ments have value in providing a data base for epidemiological research on 
the long-term effects of whole-body irradiation at these levels.'^ Therefore 
it will be recommended that the Atomic Flnergy Control Board issue a code 
of guidance for the measurement of external irradiation and the mainte- 
nance of related occupational records. 

It is the alpha particles associated with nuclear decay of radon. Radium a 



7 1 Lung cancel and ioni/ing radiation 



TABLH 17 

Gamma radiation by film badge in an Elliot Lake mine 





Ore grade 














in lbs 


Number 


Average 


Work 






Personnel 


of ViOs 


of 


total 


exposure 


Millirem/ 


Equivalent 


task 


per ton 


badges 


millirem 


hours 


hour 


Rems/year 


Shift boss 


- 


6 


16 


64 


0.25 


0.5 


Miners 


2.8 


5 


42 


72 


0.60 


1.2 




6.0 


3 


103 


72 


1.40 


2.8 



note: Maximum permissible dose is five Rems/year under Schedule n, Atomic Energy 

Control Regulations 

source: Rio Algom Mines Ltd, 1975 



and Radium c' in the aerosol breathed by miners, that are considered to 
contribute the major internal irradiation of the bronchial and bronchiolar 
epithelium of the lungs. ''^ Of this internal dose to the lungs, by far the 
greater proportion is delivered by the daughters of radon. ^" 

In Ontario uranium mines the internal irradiation of workers' lungs by 
radon and its daughters has been measured indirectly in terms of the level 
of radioactivity present in the mine air. The current measure is the Working 
Level (wl) and the Working Level Month (wlm).^' 

Measurements of radon-daughter radioactivity have been taken by in- 
dustry at representative workplaces since the issuance by the Mines En- 
gineering Branch of a code of requirements in March 1957.^^ Exploratory 
measurements had been made in 1955-6 under circumstances described in 
chapter 2. Historical mine average values of radiation intensity expressed 
in Working Level Months per annum have been compiled by the Mines 
Engineering Branch and are given in Table 18. Table 19 shows the corre- 
sponding cumulative Working Level Months that a person would expe- 
rience were he to have worked continuously in one mine under mine 
average exposure conditions. The development of a radiation standard for 
the uranium mines will be examined in detail later in this chapter. For the 
present it is noted that prior to 1968 there was no required limit to radiation 
stated in the code of requirement for measurements. From 1955 to the end 
of 1967 the guideline accepted by the Mines Accident Prevention Associa- 
tion and the Mines Engineering Branch appears to have been 12 wlm per 
annum or its equivalent. -"^ At the end of 1967 the code on radiation expo- 
sure was revised to include a limit of 12 wlm per annum. -^ In 1972 a further 
revision reduced the limit of exposure from 12 to 8 wlm per annum for 1973 





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76 The health and safety of workers in mines 

and from 8 to 6 wlm per annum for 1974.^*^ A final revision of the code in 
1974 reduced the allowed limit of exposure to 4 wlm per annum for 1975.'^ 
The extent to which this sequence of guideline values and stipulated 
limits was complied with may be judged from Table 18, where the guideline 
value or code limit is entered for each year at the top of the table. Regular 
measurements of radiation were not conducted in all mines and hence were 
not available for audit by the mines inspectorate until 1958. In Tables 18 
and 19 there are notable differences in radiation levels and cumulative 
radiation exposure among the mines. The radiation levels in the mines of 
the Bancroft area were initially substantially higher than those in Elliot 
Lake. Although silicosis has not been a problem in relation to the Bancroft 
mines, the same cannot be said of lung cancer. 

RADIATION AND THE R E S P O N S I B I L I T Y - S Y S T E M 

Recognition of the problem of lung cancer 

From the beginning of the development of the uranium mines, the Mines 
Engineering Branch of the then Department of Mines, the Ontario Mining 
Association, and the Mines Accident Prevention Association were aware 
that they posed unusual potential hazards to health because of the highly 
siliceous ores at Elliot Lake and because of radiation at both Bancroft and 
Elliot Lake. The Ontario Mining Association established an internal Ad- 
visory Committee on Uranium Mines in 1956 which met regularly until 
1964, examined United States and South African practice, and, through the 
work of the Mines Accident Prevention Association, was made aware of 
the environmental conditions existing in the uranium mines. The Ministry 
of Health and Atomic Energy of Canada Ltd provided competent advice 
whenever it was requested and assisted in particular with problems of 
radiation measurement. The code of requirements for the measurement of 
radiation and dust beginning in 1957 is evidence that the need for radiation 
records was recognized. Until 1968 these measurements were in represen- 
tative mine locations and not related to individuals. However, the revised 
code for the mines issued in December 1967 called for the maintenance by 
the mines after that date of personal radiation exposure records. ^^ 

In Ontario the recognition by the responsibility-system of a suspected 
problem of lung cancer among uranium miners gradually came about, 
notably through deliberations of the Advisory Committee on Occupational 
Health of the Ontario Mining Association, whose forerunner was the 
Committee on Silicosis of that organization. In this committee, persons 
from the staff of the Ontario Mining Association, the Mines Accident 



i 



77 Lung cancer and ionizing radiation 

Prevention Association, the industry, the Mines Hngineering Branch, the 
Ministry of Heahh, and the Workmen's Compensation Board met, at the 
invitation of the Mining Association, to share understanding of problems ni 
heahh and safety in the mining industry. ^*^ A major concern in this commit- 
tee from the early sixties was the setting up of occupational records suitable 
for 'making an assessment of the present and future lung cancer risk in 
uranium miners. '-'^ The development of records proceeded slowly. But 
gradually, through the co-operation of the mines, the Department of Mines, 
the Ontario Mining Association, the Workmen's Compensation Board, and 
the Ministry of Health, a Nominal Roll of Uranium Miners was developed 
by the Medical Statistics Unit of the Board."*" While this Roll was being 
developed, the persons on the Committee from the Ministry of Health and 
the Board conducted exploratory searches for deaths and causes of death 
of uranium miners in Ontario records of vital statistics. 

As the Nominal Roll was improved and updated, estimates of mortality 
by cause of death were made in the Ministry of Health,^' and a written 
report based on incomplete data for deaths in the period 1955-70 was 
prepared for the Advisory Committee. ^^ This report was updated in 1974 to 
include deaths for the period 1971-2.^^ In essence, this report estimated 
that, from a total of forty-one lung cancer deaths observed in Ontario in a 
population of about eight-thousand miners in the years 1955-72, there was 
an excess of twenty-eight over the thirteen lung cancer deaths to have been 
expected by reference to all contemporary deaths of Ontario males. The 
substance of this report was presented at an international conference in 
September 1974.^"^ 

At Commission hearings in Elliot Lake, union leaders alleged that the 
workers whose lives have been and are at risk have not been kept informed 
about the developing situation in Ontario. The following words convey the 
intensity of feeling: 'We have been led to believe through the years that the 
working environment in these mines was safe for us to work in. We have 
been deceived. '^-^ 

The Commission has examined in depth the events briefly described 
above. During this period Mines Inspectors issued many letters of instruc- 
tion to the mines to improve conditions, and, as Table 18 shows, levels of 
radiation were reduced. But neither the workers nor their representatives 
were advised about the emerging status of the problem of lung cancer. The 
consequence was, and is, that men and their families have been living in 
fear of the circumstances of their work. The Commission sees no excuse 
for not telling working people the truth, however difficult and imperfect 
that may be. Nor is it tolerable that there should be no forum in which 



78 The health and safety of workers in mines 

representatives of workers can engage other parties in the responsibility- 
system in frank deliberation over the risks to health involved in work."^^ 

The central public responsibility for initiative in ensuring that the prob- 
lems of the work environment in the uranium mines were dealt with 
expeditiously and thoroughly then rested with the Department of Mines 
and now rests with the Ministry of Natural Resources. In the period 1972 to 
1974, the allowed radiation exposure limit was lowered from 12 wlm per 
annum to 4 wlm per annum. But the delineation of the underlying problem 
has been slow and remains incomplete. Indeed at times it has not been clear 
whether initiative was considered to rest with industry or the responsible 
ministry. Staff in the Ministry of Health and the Workmen's Compensation 
Board have worked, and continue to work, with inadequate resources to 
assist in illuminating problems outside theirjurisdiction. In this sense there 
is compelling need for new clarity in roles within the responsibility-system, 
especially when there is growing awareness of an evident threat to the lives 
of \yorkers. The Commission therefore recommends: 

That the Occupational Health and Safety Authority he given by statute the 
authority and responsibility to conduct a full and expeditious review of any 
emergent situation in which the health and safety of workers in mines are 
believed to be at unexpected risk. 

If adequate occupational health records are maintained and subjected to 
regular review there will be less of the crisis atmosphere that currently 
pervades problems of occupational health. Ad hoc reviews are less than 
satisfactory, but in the absence of resources for, and a planned commit- 
ment to, occupational health they are necessary. 

MORTALITY EXPERIENCE OF URANIUM 
MINERS IN ONTARIO 

In the circumstances of the uranium mines the Commission has been called 
upon 'to identify relevant data related to lung cancer.' The following 
assessment is based on a study conducted with the full co-operation of the 
Workmen's Compensation Board, the Ministry of Health, and the Ministry 
of Natural Resources. The limited statistical study conducted by the 
Commission had two purposes: 1/ to seek verification of the extent of the 
excess of lung cancer predicted in the earlier studies: 2/ to determine if, 
within the circumstances of the Ontario Uranium Nominal Roll, there is 
statistical evidence of a risk of cancer dependent on radiation exposure at 
the levels experienced. 



79 Lung cancer and ioni/ing radiation 

TABLE 20 

Distribution of deaths by province of residence 









Lung cancer 








deaths 


Residence at 


Deaths 


from 


(included in 


time of death 


all causes 


all causes) 


Maritimes 


24 




4 


Quebec 


100 




9 


Ontario 


692 




63 


Prairies 


56 




5 


British Columbia 


75 




3 


Outside Canada 


2 




1 


Total 


956 




81 



source: Commission Project: 'Mortality experience of uranium 
miners in Ontario' 



The study has been based on the Ontario Uranium Nominal Roll as of 3 1 
December 1974 prepared by the Workmen's Compensation Board. ^^ This 
Roll contains data on 15,094 persons who worked one or more months in 
dust exposure at the uranium mines in the period 1955 to 1974 inclusive. 
The very great majority of these persons at some time had worked under- 
ground in both dust and radiation exposure. A few had exposure limited to 
dust on the surface. In June 1975, the Commission arranged with Statistics 
Canada to conduct, in co-operation with the Registrars-General of the 
provinces, a search of all national vital statistical records for deaths of 
persons on the Nominal Roll. In parallel wi:h this work the Statistical 
Services Unit of the Workmen's Compensation Board, at the request of the 
Commission, began manual extraction of data from its files based on 
Miners Certificates to permit estimation of the man-years at risk and to 
provide radiation histories for a random sample of persons on the Nominal 
Roll.^^ The radiation history of each lung cancer death was also deter- 
mined. 

The death search yielded 956 acceptable matches to the Nominal Roll, of 
which 81 were certified as caused by cancer of the lung."^*^ The distribution 
of the deaths by province of residence is shown in Table 20. 

The expected numbers of deaths to be compared with the actual deaths 
were determined from vital statistics for the male population of Ontario as a 
whole. "^^ To determine whether or not actual deaths from lung cancer are in 
significant excess of those expected, the comparison in Table 21 was 
prepared. As of the end of 1974, lung cancer deaths were in significant 



80 The health and safety of workers m mines 



TABLE 21 

Comparison of actual and expected deaths by calendar period 



Deaths from all causes 



Lung Cancer deaths 
(included in all causes) 











Excess ( + ) 


or 








Excess ( + ) 


or 


Period 


Actual 


Expected 


deficiency (- 


-) 


Actual 


Ex 


pected 


deficiency (- 


-) 


1955-9 


57 


59, 


,43 


-2, 


.43 




1 


1 


.21 


-0.21 




1960 4 


223 


177, 


.14 


45. 


.86 




12 


5 


.54 


6.46 




1965-9 


280 


261, 


.77 


18, 


.23 




18 


12 


.49 


5.51 




1970-4 


396 


396. 


.20 


-0 


.20 




50 


25 


.84 


24.16 




Total 


956 


894 


.54 


61 


.46 




81 


45 


.08 


35.92 





note: a deficiency means that fewer persons on the Nominal Roll died than would be 

expected on the basis of Ontario male mortality experience 

source: Commission Project: 'Mortality experience of uranium miners in Ontario' 



excess by a total of 36 cases, or 80 per cent of the expected deaths/' The 
excess first becomes apparent for the period 1960-4. 

New employees in the uranium mines are added to the Nominal Roll each 
year, and it is reduced in number only through death. Hence the accumulat- 
ing expected number and actual number of deaths will increase as years 
pass, particularly because the major population growth in the Roll, as 
suggested in Figure 8, occurred about 1960. This population is now aging 
and faces rising death rates from natural causes. It is not possible on the 
basis of the Commission's study to predict how Table 2 1 will evolve as time 
elapses."*^ It is imperative that the mortality experience of the uranium 
mines be followed up. The Commission therefore recommends: 

That the Occupational Health and Safety Branch commission a review of 
the mortality experience of persons on the Ontario Uranium Nominal Roll 
on a biennial basis for at least ten years. 

To place the current excess cancer deaths in proper perspective it is 
necessary to examine the actual and expected deaths under major causes as 
presented in Table 22. Several distinctive features of the mortality experi- 
ence of uranium miners in Ontario now emerge. The over-all net excess of 
62 deaths derives from a gross excess of 188 deaths from violent causes and 
a major deficiency of 126 deaths from natural causes within which lung 
cancer is in excess. The large excess of deaths from violent causes derives 
mainly from those other than motor vehicle accidents and suicides. The 



81 Lung cancer and ionizing radiation 



TABLE 22 

Actual, expected and excess deaths by major causes 



Violent causes 
400 : 212.38 : 187.62 



All causes 

956 : 894.54 : 61.46 



'Natural' causes 

556 : 682. 16 :(-I26.16) 



Motor vehicle accidents 

93 : 77.48 : 15.52 
Suicide 

47 : 48 . 50 : ( - 1 . 50) 
Remainder 

260 : 86.40 : 173.60 

Cancer of lung 

81 : 45.08 : 35.92 
Cancer of stomach 

11 : 12.70 :(-1.70) 
Tuberculosis 

: 2.47 :(-2.47) 
Miscellaneous respiratory 
(including silicosis) 

28 : 32.20 :(-4.2) 
Arteriosclerotic heart disease 

195 : 287.69 : (-92.69) 
Hypertension, etc. 

6 :6.03 :(-0.03) 
Remainder 

223 : 293.99 : (-70.99) 



note: An excess is positive, a deficiency negative. The numbers in each sequence are actual 

expected : excess (deficiency) deaths. 

source: Commission Project: 'Mortality Experience of Uranium Miners in Ontario' 



remaining deaths from violent causes arise largely from accidents in the 
mines or in other industrial employment. In chapter 4 a detailed analysis of 
deaths of this type will be given. Here it should be noted that the related 
excess of 173 violent industrial deaths is almost five times the excess due to 
lung cancer. 

In the class of causes designated as natural there is no significant excess 
or deficiency for cancer of the stomach, tuberculosis, hypertension, and 
miscellaneous respiratory diseases, which include silicosis. The excess for 
lung cancer is the more striking when it is noted that there is a major 
deficiency of 93 for arteriosclerotic heart disease and a deficiency of 71 for 
all other causes. "^"^ The latter deficiencies may be attributable to the natural 
physical selection entailed in the recruitment of persons to an occupation 
requiring strenuous work. However, all of the population has not remained 
in mining. 

The impact of the foregoing pattern of excess deaths on the lives of 
uranium miners can be further illustrated with Table 23.'*'^ In terms of the 



82 The health and safety of workers in mines 



TABLE 23 

Actual deaths 
excess deaths 


; (ascertained ; 
for all causes 


and estimated), 
l">y age group 


expected deaths and 




Age at 
death 


Actual deaths 




Expected 
deaths 


Excess ( + ) or 
deficiency ( — ) 
based on estimated 
actual deaths (%) 


Ascertained 




Estimated 


15-39 
40-49 
50-59 
60 + 

Total 


328 
285 
240 
103 

956 




376 
293 
268 
135 

1,072 


229.06 

275.18 
261.56 
128.73 

894.53 


+ 64 
+ 6 

+ 2 
+ 5 

+ 19.8 



note: For estimated actual deaths, see n. 39 

source: Commission Project: 'Mortality experience of uranium miners in Ontario' 

total excess of deaths resulting from all causes, it is the youngest age group 
that suffers by far the most conspicuous excess, and deaths primarily 
through industrial accidents are the largest contributor. A study of loss of 
potential life years based on Canadian male life tables for 1960-2 has shown 
that each 'extra' fatal accident in the population of the Nominal Roll took 
nearly thirty-five years of future lifetime, compared to an average of 
twenty-two years for each 'extra' death from lung cancer. In aggregate the 
deprivation of life years by excessive fatal accidents was eif^^/u times that 
resulting from the excess of lung cancer deaths. This fact has important 
implications for policy on work adjustment discussed below. 

EXPOSURE TO IONIZING RADIATION AND THE 
RISK OF CANCER - ONTARIO EVIDENCE 



An excess in the occurrence of lung cancer in an occupational group does 
not in itself establish the identity of a causative agent in the working 
environment. However, since the link between lung cancer and exposure 
to ionizing radiation has been well established in other populations,^*^ the 
Commission has sought evidence that there is such a link in the particular 
circumstances experienced by the population on the Ontario Nominal Roll. 
With respect to uranium miners, the major epidemiological studies in the 
usa"^^ have involved populations that have experienced average radiation 
exposures higher by a factor often or more than the persons on the Ontario 
Uranium Nominal Roll, and efforts to relate us experience to lower levels 
of exposure are based on extrapolation. The Commission has been able to 



S3 Lung cancer and ioni/ing radiation 



TABLE 24 

Comparative characteristics of cancer cases having the highest and 
lowest radiation exposures experienced in Ontario 



Case characteristic 



Highest 

exposure group 
(average of 
20 cases) 



Lowest 

exposure group 
(average of 
20 cases) 



Radiation exposure 195 wlm s 

Years of exposure 7.2 years 

Exposure per annum 33 wlm s 

Elapsed time, entry to death 13.8 years 

Age at entry 37.7 years 

Year of entry 1956 



5.8 WLM s 

0.6 years 

16 WLM s 

11.8 years 
41 .5 years 
1958 



discover no epidemiological data on excess lung cancer among uranium 
miners, based on radiation records of the completeness of those available 
in Ontario, at the radiation levels encountered here, in a population as large 
as that on the Uranium Nominal Roll. The Ontario body of data is believed 
to be of major significance for the delineation of the risks of lung cancer 
among uranium miners and the full exploitation of these data is essential. 
Except in the search for deaths, the Commission has conducted analysis 
based on samples of these data. 

Table c. 4 contains available case characteristics for the lung cancer 
deaths identified by the Commission. "^^ The cases are listed in sequence by 
cumulated exposure to radiation. The highest radiation exposure received 
in the uranium mines of Ontario prior to death from lung cancer was 375 
WLM and the lowest zero; the mean value was 75 wlm. Table 24 compares 
some characteristics of the quarter of the cases with highest exposure with 
those of the quarter with lowest exposure. 

To determine if there is statistical evidence that the risk of lung cancer 
among the persons on the Uranium Nominal Roll is dependent on the 
cumulative radiation exposure experienced in Ontario uranium mines, the 
series of eighty-one cancer deaths was related to a comparison series of 
eighty-one survivors drawn from a set of names randomly selected from the 
Nominal Roll."*^ The comparison series is taken to be representative of all 
those persons who entered the mines in the period 1955-74 and survived to 
the end of 1974. 

Several statistical tests were conducted using the recorded ages, expo- 
sures to radiation, and places of occupation for the cancer deaths and the 
randomly selected comparison series. These tests are described in appen- 



84 The health and safety of workers in mines 

(Jix c . The hypotheses included: 1/ that the risk of lung cancer is unrelated 
to radiation exposure incurred in Ontario mines; 2/ that the risk of lung 
cancer is unrelated to the region of employment (Bancroft or Elliot Lake); 
3/ that the risk o\^ lung cancer is independent of the period of entry into 
uranium mining. 

Hypothesis I was tested using several configurations of the data, and in 
each case was rejected/*^ The Commission concludes that under the condi- 
tions oi exposure to radiation in Ontario uranium mines in the period 
1955-1974, there is statistical evidence that the persons on the Uranium 
Nominal Roll have experienced a risk of lung cancer that is related to 
radiation exposure received in Ontario. The tests, based on sample 
analysis, indicate that risk increases with exposure and that a linear depen- 
dence on cumulative wlm is consistent with the sample data. Therefore, 
on the basis of the data on excess mortality from lung cancer and the sample 
evidence on risk as related to cumulative wlm, the Commission will 
recommend that the standard for exposure to ionizing radiation be re- 
viewed. 

Because the Bancroft area mines have been shut down, there has been a 
strong tendency in the hearings of the Commission to relate lung cancer 
primarily to the Elliot Lake Mines. For this reason hypothesis 2 was tested. 
There is statistical evidence based on samples that for persons who ever 
worked in the Bancroft area mines the risk of lung cancer has been 2.2 times 
that for persons who never worked at Bancroft (see Table c. 2). Further, 
there is very proper concern about the continuing risk of lung cancer 
relative to those that pertained in the early period of the mines. A test of 
hypothesis 3 was conducted for the period before 1958 as against the period 
thereafter. There is statistical evidence that the risk of lung cancer for a 
person who entered the mines before 1958 was 2.5 times that for a person 
who entered after that date (see Table c. 3). The outcome of the latter two 
tests of location and time of entry are consistent in character with the 
radiation data in Tables 18 and 19. 

I H E E V O I U 1 I O N OF THE C U R R E N 1 S 1 A N D A R D 
FOR R A D I A I ION EXPOSURE 

Since the labour unions have properly expressed deep concern over condi- 
tions in the mines it is essential to examine how the current radiation 
exposure limit of 4 wlm per annum for internal irradiation was arrived at, 
and to consider by whom it should be reviewed. The Commission con- 



85 l.iing cancer and ionizing radiation 

dudes that the review should be effected by the Atomic Energy Control 
Board, whose historical role is now examined. 

THE P R O B I I: M () I J U R I S I) 1 C r I O N 

When the uranium mines opened, they were contractors to Eldorado 
Mining and Refining Ltd, a federal crown company. The Atomic Energy 
Control Board issued operating licences to the mines under which provin- 
cial regulations for safety and health were invoked subject to any regula- 
tions made under the Atomic Energy Control Act.^*^ Substantive regula- 
tions relating to health and safety were first issued in 1960, and apply to 
persons defined as atomic radiation workers.''' At the time of writing the 
Atomic Energy Control Board had not formally declared uranium miners to 
be such workers. Hence the governing standards with respect to the 
exposure of uranium miners to ionizing radiation have been those invoked 
by the Atomic Energy Control Board under provincial regulations. Provin- 
cial regulations have been set by the Department of Mines (now Ministry of 
Natural Resources) with advice from the Ministry of Health, the industry, 
and special consultants. 

Although the Atomic Energy Control Board from time to time exercised 
a review role by meeting with provincial authorities and mine manage- 
ments, it did not do so on a regular basis and received no regular reports 
from provincial authorities. It became especially concerned about condi- 
tions in the uranium mines following the release in 1967ofamajor us report 
on lung cancer among uranium miners. *^^ 

The intervention of federal authority in the uranium mines through the 
Atomic Energy Control Act and the concomitant intervening jurisdiction of 
the Canadian Labour Code'''^ has not rested easily with either the industry 
or the provincial authorities. Indeed the validity of the federal jurisdiction 
has been tested in the courts.'^'* In the matter of legal liability for workmen's 
compensation the Commission has been advised that miners are not 'em- 
ployees' under the Government Employee's Compensation Act^^ and are 
not therefore eligible to make claims against the federal government, even 
though an injury might be imputed to want of adequate inspection. 

The historical record of conditions in the uranium mines clearly reveals 
that the current arrangement of undelegated federal jurisdiction and in- 
voked provincial regulation is unsatisfactory. Workers in uranium mines 
should no longer suffer for want of the commitment of resources by all 
parties and the effective concertation of authority and talent. The Commis- 



86 The health and safety of wt^rkers in mines 

sion believes it to be essential for the public good that the Atomic Energy 
Control Board fully exercise its fundamental regulatory responsibility over 
the whole of the nuclear fuel cycle from the mining of ore to the operation of 
reactors. 

To clarify jurisdictional responsibilities in these matters, it is therefore 
recommended: 

Jfuit the Atomic Enc^ry Control Board review the basis for and issue 
explicit regulations establishing the maximum permissible annual expo- 
sure to ionizing radiation for workers in uranium and thorium mines and 
mills; 

That the regulations for maximum permissible exposure delineate how all 
significant components of external and internal irradiation are to be ac- 
counted for and indicate how total exposure and related dose is to be 
evaluated; 

That the regulations for maximum permissible exposure and related dose 
be interpreted in units that can be monitored by practical means in uranium 
and thorium mines and mills. 

Further, as a matter of fundamental principle the Board as a public regula- 
tory agency should in issuing its regulations make publicly available a 
summary of the grounds on which it bases its judgment. 

To fulfil its responsibility of interpreting radiation standards for the 
mining and milling of uranium and thorium ores, the Atomic Energy Con- 
trol Board should take certain initiatives in research. In particular it is of 
the highest importance that a reliable personal dosimeter for alpha radia- 
tion be developed for use in the mines and that a reliable 'instant' working 
level meter be developed to facilitate engineering monitoring of mine 
environments. Prototype technology is already available. The Commission 
therefore recommends: 

That the A tomic Energy Control Board 

1 1 have research conducted relevant to current circumstances 'dl on means 
for measuring all components of ionizing radiation effective in contribut- 
ing significantly to the irradiation of the lungs, other organs, and tissues of 
workers in Ontario uranium and thorium mines and mills; and b/ on the 
spatial and temporal distribution (f ionizing radiation and related particu- 
lates in these mines and mills; 



87 Lung cancer and ionizing radiation 

2/ issue codes of i^iiidiuicc 'dl for the frequency and location of sampling 
required to deter/nine both the radiation exposure of individual workers in 
Ontario mines and mills and the general state of the mine and mill envi- 
ronment; bl for the selection, use, maintenance, and calibration of instru- 
ments for measuring ionizing radiation both for the determination of 
individual exposures and for the monitoring of the general mine and mill 
environment; cj for the identification of persons for whom records of 
radiation exposure shoidd be kept; and dj for the form, preservation, and 
use of occupational records for exposure to all si^^niftcant components of 
ionizing radiation; and 

31 facilitate, with the assistance of the federal Department of Health and 
Welfare, epidemiological research on a national basis. 

If the Board exercises the foregoing initiative clearly and in open consul- 
tation with industry, labour, and provincial authority there should be 
benefit to all concerned. The public and the workers should expect nothing 
less than the full co-operation of all parties. The Board's position in these 
matters has been positively stated in its brief to the Commission. -^ In this 
regard it may be noted that exceptional efforts are made to monitor and to 
control the radiation exposure of workers at the high-technology end of the 
nuclear fuel cycle at nuclear reactors. More extensive attention should be 
given to those who work in mines where the day-to-day exposures to 
ionizing radiation may be orders of magnitude larger than those received by 
workers around reactors. 

To clarify provincial responsibility, the Commission recommends: 

That the Province of Ontario, through the Occupational Health andSaftey 
Authority, establish by statute a standard for maximum permissible annual 
exposure to ionizing radiation for workers in uranium and thorium mines 
and mills, and that this standard be in conformity with the regulatory 
standards of the Atomic Energy Control Board; 

That the Occupational Health and Safety Branch be assigned by provincial 
statute the responsibility to direct: 

11 the establishment and review of occupational health records for workers 
in uranium and thorium mines and mills, for regulatory and epidemiologi- 
cal purposes; 

2/ the preparation of a code of practice for the sampling and measurement 
of ionizing radiation in a manner suited to the determination of the expo- 
sures of individual workers in uranium and thorium mines and mills and 



88 The health and safety of workers in mines 

t/uit this code of practice he in conformity with the code of guidance issued 
by the Atomic Energy Control Board. 

The Commission believes that mines should be required to comply with 
standards of individual exposure to ionizing radiation and with com- 
plementary engineering standards indicative of over-all environmental 
control of radiation. It therefore recommends: 

That the Mines Inspection Branch prepare regulations defining the kinds 
and frequencies of measurements of ventilation and radiation necessary to 
enable it to audit the engineering operational characteristics of uranium 
and thorium mines and mills; 

That these regulations be in conformity with the related code of guidance 
established by the Atomic Energy Control Board; 

That the Occupational Health and Safety Authority specify 

If a level of radiation in mine or mill air measured at any time in any 

occupied workplace which, if exceeded, requires that corrective action be 

taken immediately; and 

21 a level of radiation in mine or mill air measured at any time in any 

occupied workplace which, if exceeded, requires closure of the related 

workplace until the level of radiation is reduced below that specified in I. 

The puipose of the last recommendation is to ensure that radiation in the 
working environment is kept as low as possible through procedures of 
engineering monitoring. This form of control is complemented by the 
requirement that personal exposures to radiation not exceed the statutory 
limit. 

THE ORIGIN OF THE CURRENT ONTARIO 
SIANDARD FOR RADIATION EXPOSURE 

Let us now review the basis for the current limit of exposure to radiation of 
4 WLM, which relates to the internal irradiation of the lung by alpha 
particles. The standard for radiation exposure in Ontario uranium mines 
has been influenced by two major sources - the recommendations of the 
International Commission on Radiological Protection and us practices and 
legislation.^' When mines began production in 1955 the International 
Commission on Radiological Protection had issued a new recommendation 



89 Lung cancer and ionizing radiation 

that the maximum permissible concentration of radon and its daughters in 
air be 100 picociirics per htre. I'his level was accepted as the basis Ibi the 
early Ontario guideline when the 1957 code of requirement for radiation 
measurement was implemented during 1958.^^ This guideline was for prac- 
tical purposes equivalent to the Working Level recommended for adoption 
in us mines by the us Public Health Service in the same period (see n. 11). 
Thus a radiation guideline equivalent to internationally recommended 
levels was accepted in Ontario from 1958. However, since the guideline 
had no statutory significance the question oi'^ legal compliance was not 
initially at issue. Table 18 and the empidemiological evidence provide 
verification that the worst radiation conditions in most, but not all, mines 
existed in the period 1955 to 1958, before auditing of conditions by the 
Mines Engineering Branch was taking place with assistance from the 
Ministry of Health. 

In 1959 the International Commission on Radiological Protection issued a 
revised recommendation of 30 picocuries/litre as a maximum permissible 
concentration of radon for a forty-hour week.'^'^ This recommendation was 
interpreted in Ontario as a reduction by a factor of three in the maximum 
permissible concentration and led in 1960 to a major review of the situation 
by the Departments of Mines and Health assisted by outstanding Canadian 
and us specialists. ^° There was an informal consensus that it was desirable 
to shift to the lower guideline over a period of five years. ^' 

In the meantime, radioactivity in the air in us mines continued at levels 
substantially above those in Canadian mines, and a variety of us authorities 
confirmed the then prevailing 12 wlm per annum guideline.^- In Ontario 
the guideline continued at the equivalent of 12 wlm per annum until the end 
of 1967, when the code of requirement stating this level was issued by the 
Mines Engineering Branch. ^"^ 

At this time definitive evidence of an excess risk of lung cancer among us 
uranium miners began to appear (see nn. 1, 52), and internal Ontario 
evidence of a similar risk was beginning to emerge (see nn. 30. 32). The 
Ontario code of requirement for exposure to radiation was reduced to 8 
WLM per annum effective 1 January 1973 and to 6 wlm per annum effective 
1 January 1974. As of 1 January 1973 smoking underground in uranium 
mines was forbidden. The current level of 4 wlm per annum was made 
effective as of 1 January 1975 (See nn. 24-6). 

From this brief review it will be apparent that the setting of guidelines for 
exposure to radiation in Ontario mines began in accord with the best 
available national and international understanding of the problem. The 
initial intent to follow the revised recommendations of the International 



90 The health and safety of workers in mines 

Commission on Radiation Protection (1959) over a period of five years 
appears to have been set aside in favour of us practices. However, in the 
USA the limit of 4 wlm per annum was adopted under federal legislation in 
1971, albeit with variances allowed.^'* 

The Commission has recommended that the Atomic Energy Control 
Board review the basis for the current standard and confirm a maximum 
permissible annual exposure to ionizing radiation for uranium miners. In 
the hearings before the Commission the current level of 4 wlm months has 
been stated to incorporate a factor of safety of five, to be safe, and to be 
high by a factor of ten.^'^ Each of these judgments has been based on 
different data or interpretations. The following notes outline some of what 
the Commission considers to be relevant data at this time. 

THE BASIS FOR A STANDARD 

A recent extensive review of the history of the development of radiation 
standards has stated that 'there is now no longer any real question of 
recommending a level of exposure to ionizing radiation that in the light of 
present knowledge can be considered absolutely safe. The ''safety" of an 
exposure in particular circumstances must be determined by the risk 
deemed acceptable in that circumstance. This philosophy of exposure 
requires as a pre-requisite an assessment of risk associated with the 
circumstance.'^^ This review is in accord with the positions of the Interna- 
tional Commission on Radiological Protections^ and of the Ministry of 
Health. s^ Further, a recent major review of lung cancer among uranium 
miners in the usa states: 

the possible potentiation of radiation effects by cigarette smoking, diesel fumes and 
other agents in mine atmospheres is not really pertinent to the setting of permissible 
levels for radon daiighleis at this time. As such agents are identified, attempts 
should be made to reduce the risk tYom their presence; but until that risk is 
substantially reduced, the permissible level foi radt)n daughters should be based on 
e\ idence collected in the environment in which miners continue to live.^*^ 

The mortality study of the Commission indicates that in the circum- 
stances experienced by persons on the Uranium Nominal Roll in the years 
1955-74 there has been a significant excess risk of lung cancer. The sample 
analysis undertaken indicates that the excess risk is related to exposure to 
radiation. The number of excess cases of lung cancer, conservatively 
estimated to be thirty-six for the period 1955-74, is based on a comparison 
with the experience of the Ontario male population as a whole. For pur- 
poses of public health the Commission regards this as the appropriate 



91 I. ling cancel' and ioni/ing ratlialion 

reference population, but for epidemiological undei standing ofdilTeicnlial 
risks in uranium and other types of mines a study using matched popula- 
tions of non-uranium miners and non-miners is important. It is therefore 
recommended: 

That the Occupational Health and Safety Branch commission a study of 
the mortality experience of the Ontario Uranium Nominal Roll relative to 
appropriately matched sample populations of non-uranium miners and 
non-miners in Ontario. 

THE NAIURE OF THE DATA AVAILABLE FOR 
SETTING A RADIATION EXPOSURE STANDARD 

There is no direct way of measuring ///.s//// within the respiratory pathways 
the energy in Rads of ionizing irradiation delivered to the bronchi and lungs 
by radioactive particles in the aerosol breathed by uranium miners. The 
Working Level is a measure of the radioactivity of radon daughters in mine 
air before it is breathed. The Working Level Month is a measure of average 
exposure over a period of one month. As the number of wlms per annum 
increases it is inferred that the human dose of ionizing irradiation increases 
in proportion. Other measures of radioactivity in mine air, such as of radon 
gas alone, are used and may be preferable as indirect indicators of dose. ^^ 

Whatever measure of radioactivity in mine air is used, there is a funda- 
mental problem in relating it to the actual dose of ionizing irradiation in the 
lungs and to the biological consequences. Using mathematical models of 
the human lung extensive research has been conducted on the relation 
between the wlm unit of exposure and the energy dose of irradiation in 
Rads.^' The estimates of dose derived by these methods vary by at least a 
factor of ten. ^-^ Further, in the absence of definitive knowledge of how the 
incident energy of irradiation is distributed over the surface of the respira- 
tory pathways and lungs, there is no general agreement on the number of 
Rems of biologically effective irradiation corresponding to the energy of 
alpha irradiation in Rads.^"^ It is not surprising therefore to find a variety of 
interpretations of the biological significance of exposure to a particular 
mine environment (see nn. 1 and 57). Thus a representative of the Atomic 
Energy Control Board stated before the Commission that exposures of 4 
WLM per annum and 12 wlm per annum could both be consistent with the 
maximum permissible biological dose of 15 Rems per annum to the lungs as 
allowed by the regulations under the Atomic Energy Control Act for atomic 
radiation workers.^"* 

For these reasons, direct epidemiological evidence in the circumstances 



92 The health and safety of workers in mines 

of exposure of the particular working population is considered to provide 
the best basis upon which to review the standard for exposure to radiation. 
The epidemiological evidence accessible to the Commission on the exis- 
tence of lung cancer among miners may be divided into two parts - one in 
which the average exposure to radiation has been very much higher than in 
Ontario uranium mines, and another in which the estimated exposures 
have been comparable to those in Ontario uranium mines. The first group 
involves experience in the United States."^ The most recent major study 
indicates that there is an excess risk of lung cancer at exposures down to 
and including the range 120-359 wlm.^^ This report concludes in part that 
'these evaluations have failed to find any plausible alternative to the 
hypothesis that radon daughter exposure is causally related to the excess 
lung cancer risk in the 120-359 wlm category '"^^ and that 'other 
epidemiological studies of situations where human lungs were irradiated 
were not only consistent with the observations of lung cancer in uranium 
miners, but indicate that excess lung cancer occurs at lower radiation levels 
than could be adequately studied among [us] uranium miners. '"^^ The 
statistical data derived by the Commission on the basis of analysis of 
samples are consistent with the foregoing conclusions. But the 
Commission's statistics are inconsistent with certain analyses of us data 
that suggest that a definite exposure-dependent increase in cancer risk will 
not occur unless some 600 wlm s of exposure have been accumulated.^*^ 

Let us now consider evidence on exposures estimated to be comparable 
to those in Ontario. In Swedish underground iron mines in the period 1950 
to 1970 a significant excess of lung cancer has been experienced in the 
presence of radioactivity due to radon and its daughters at exposures 
estimated to have been in the neighbourhood of 120 wlm with an annual 
exposure rate of about 4 wlm.^*^ It has been reported that in South African 
gold/uranium mines exposures at the level of about 4 wlm per annum give 
rise to no significant excess of lung cancer (see n. 9, Basson et al.). In both 
the South African and Swedish studies the exposures of miners were 
roughly estimated because no regular radiation measurements were taken 
during the years of exposure. '^' For French uranium mines, where radiation 
exposure records extend back to 1958 and average exposure has been 
about 4 WLM per annum, it has been stated that there is as yet insufficient 
basis for a clear epidemiological analysis. ^-^ 

From the foregoing evidence for Sweden, South Africa, and France, no 
clear understanding emerges. At the reported levels of exposure, the data 
necessary for a clear statistical delineation of the relative risks are careful 
radiation measurements, a large number of person years at risk, and a 



93 LAing cancer and ionizing radiation 

significant ninnber of cancer cases. It is here that the Ontario records of 
extensive radiation measurements over a period of twenty years, and a 
Nominal Roll of over fifteen thousand persons at risk constitute, in the 
Commission's view, epidemiological evidence of singular importance. 

With respect to Ontario records it is important to note that cumulative 
exposures until 1968 have been determined from mine average radioactiv- 
ity based on measured levels in headings, raises, and stopes, adjusted for 
the travel time of workers to and from their workplace through the travel- 
ways. The use of mine averages for individuals may lead tooverestimation 
or underestimation of exposure by a factor of perhaps two. For statistical 
purposes there is nothing superior to the mine average data, which is based 
on large numbers of measurements. No corrections have been made for 
vacations or variations in work week, which in the early developmental 
period undoubtedly involved varying amounts of overtime. 

There is a question whether persons on the Nominal Roll have experi- 
enced significant exposure to radiation prior to or possibly after working in 
the Ontario uranium mines. ^^ For the cancer deaths, the available occupa- 
tional records of the Workmen's Compensation Board were checked and 
five of the eighty-one cancer deaths were confirmed as having had some 
employment in uranium mines outside Ontario in a mixture of occupations 
prior to working in Ontario. These cases, identified in Table c-4, are 
scattered through the eighty-one cases. Since radon is now known to have 
been present in many non-uranium mines, it is important to have some 
estimate of average cumulative exposure to radioactivity that may have 
occurred among the population on the Ontario Nominal Roll before 
uranium mining began in Ontario. 

The Mines Accident Prevention Association conducted a radiation sur- 
vey of non-uranium mines in 1961 , and further measurements were made in 
the period 1970-5.^'^ The average reading in the 1961 survey of gold mines, 
where a significant fraction of the readings were taken in dead ends, was 
0.07 WL or 0.8 wlm per annum. In the 1970-5 surveys, the readings were 
still lower, and with rare exceptions no measurable levels were found in the 
nickel mines. Levels of radon and associated daughters are strongly 
influenced by the level of ventilation in mines. A plausible estimate of 
average pre-uranium mining exposure for a person who worked in other 
Ontario mines prior to entering the uranium mines in 1954 may be taken as 1 
WLM per annum. A study of the occupational histories of the eighty-one 
cancer cases indicates that these persons had an average of eleven years of 
work in mines other than Ontario uranium mines and that eight of these 
years were in other Ontario mines. Not all of these exposures occurred 



94 The health and safety of workers in mines 

before the persons worked in the uranium mines. No occupational records 
are readily available to determine if there has been exposure in uranium 
mines outside Ontario among persons who left the Ontario uranium mines. 

The unions have raised the question of the accuracy of the company 
records of radiation measurements because no spot-checking of these was 
undertaken by the Mines Engineering Branch. In the early period, isolated 
instances of improper or inconsistent operation of instruments occurred. 
The Ministry of Health provided calibration services for instruments until 
1969, when, at the suggestion of the Atomic Energy Control Board, the 
Elliot Lake Laboratory of the Canada Centre for Mineral and Energy 
Technology began to provide this service to the industry. In March 1974, 
tests, including the calibration of instruments, were conducted by the 
Environmental Health Directorate of the federal Department of Health and 
Welfare at the request of the Ontario Ministry of Natural Resources. ^-"^ The 
measurements by the mines provided a slight overestimation of the radia- 
tion levels measured by the Directorate. A further extensive series of 
independent measurements including radon daughters were made in the 
uranium mines in the period May to October 1974 by the Ministry of 
Health. ^^ The measurements made by the mines were found to be consis- 
tent with those taken by the Ministry. 

The Commission believes that the Ontario records, which are based on a 
very extensive set of measurements, are generally valid and that the 
estimated cumulative exposures of persons based on Ontario uranium 
mining experience are acceptable for statistical purposes. 

THE CANCER RISK SITUATION 

The Commission has estimated that to the end of 1974 the excess lung 
cancer deaths in the population of the Nominal Roll are approximately 
equal in number to the expected cancer deaths, forty-five in rounded 
numbers. This is surely an unacceptable risk from occupational exposure. 

The means available to limit the risk both -for those remaining in and 
entering the uranium mines are twofold: first, to lower the annual incre- 
ment of exposure to ionizing radiation for the whole population; second, to 
lower or eliminate exposure to known conjoint factors such as cigarette 
smoking. ^^ A third and more questionable means of limiting risk, one based 
on work adjustment, will be discussed later. 

In regard to lowering radiation exposure the Commission has recom- 
mended that the Atomic Energy Control Board review the standard of 
maximum permissible annual exposure to ionizing radiation for uranium 



95 Lung cancc! and ioni/ing i atliation 

miners. wSince the Commission's study of data based on the Ontario 
Uranium Nominal Roll provides no evidence supporting the hypothesis of 
a threshold of exposure below which there is not significant excess risk, the 
concept of a maximum safe exposure is not tenable on the basis of these 
data. Further, for the range of exposures experienced in Ontario the 
Commission has found no evidence based on data of comparable scope that 
clearly confirms the existence of a threshold. Therefore, until contrary 
evidence is presented, the Commission considers the issue to be that of 
setting the standard at as low a level as is practically and economically 
feasible, having regard to the human risks that are acceptable in return for 
the benefits of nuclear power. ^*^ If there is no level of exposure to ionizing 
radiation significantly higher than background exposure that can in the light 
of present knowledge be considered absolutely safe, then the judgment of 
an acceptable level of risk in uranium mining should, in the Commission's 
view, be based on the combined risks of respiratory disease and disabling 
accidents. 

The Commission has identified the levels of risk as expressed in current 
experience. Since everyone accepts voluntary and involuntary risks daily, 
and since susceptibility to disease in the human population varies, finite 
risks, including those of accidents, lung cancer, and silicosis in uranium 
mines must be accepted. It has been noted that the number of potential life 
years lost from fatal accidents of mainly industrial origin among the popula- 
tion on the Ontario Uranium Nominal Roll outnumber those lost from lung 
cancer by a factor of about eight times. It is desirable that the total risks be 
reduced. But the operative level of risk of industrial disease and injury is 
not settled simply by setting environmental standards. It is determined by 
individual, legislative, and social judgments as expressed in work practices 
and their supervision, in regulatory standards and processes of enforce- 
ment, and in practices of compensation. All these matters are pertinent and 
should not be considered in isolation. One reality is that current gross risks 
for uranium miners greatly exceed those for workers at nuclear reactors. 

With respect to risk of cancer mortality attributable to ionizing radia- 
tion, current us evidence is that the risk among persons having exposures 
to alpha radiation at the level of 120-359 wlm is not influenced by the 
annual rate of exposure. ^^ If that is the case in Ontario, the total exposure 
to radiation over the historical period of exposure is the dominant factor in 
the excess risk of lung cancer. 

For future revisions in the exposure standard it is important to deter- 
mine, if possible, how a current period of exposure contributes to the risk 
of lung cancer in the future. Such knowledge may confirm whether or not 



96 The health and safety of workers in mines 

the effects of exposure are simply additive or have some reduced or 
enhanced equivalent value as time passes in association with underlying 
effects of aging. ^" To that end the Commission recommends: 

That the Occupationcil Health and Safety Authority of the province, in 
collaboration with the Atomic Energy Control Board, have conducted 
further epidemiological research based on the exposure to ionizing radia- 
tion among Ontario uranium miners; 

That the epidemiological research include a study of 1 1 the amount and 
type of exposure effective in raising cancer mortality, 21 the pathology of 
lung cancer in miners, and 31 the effects of cigarette smoking and of other 
conjoint occupational factors . 

It is recommended that this research employ extended sampling methods 
such as those used by the Commission. 

The Commission has already recommended that the extent of the excess 
cancer mortality be reviewed on a biennial basis for at least ten years; this 
review will provide a calibration of the ongoing circumstances for the 
population on the Nominal Roll. 

With respect to means of reducing conjoint factors contributing to risk of 
respiratory cancer the Commission now fervently recommends: 

That persons who work in exposure to ionizing radiation in uranium mines 
cease smoking both at home and at work for their own sakes and in 
consideration of their families. 

The risks of lung cancer related to smoking are voluntary risks, while 
those related to radiation exposure are largely involuntary. The conjoint 
risks are real and inescapable for miners who smoke. The industry is of 
course free to declare that no person who smokes will be eligible for 
employment in the uranium mines. It may choose to do so, but the Com- 
mission believes that such a rule should not be legislated. 

The lessening of risks need not and must not wait upon the confirmation 
of new standards for environmental conditions and such related factors as 
training and work practices. The dollar costs of improvements are properly 
passed on to those who benefit from nuclear power. Thus, the evidence of 
the Commission that an excess risk of lung cancer in the period 1955 to 1974 
is related to total Ontario exposures indicates that there must be sustained 
and meticulous concern to reduce levels of dust and radiation to the lowest 



97 Lung cancer and ionizing radiation 

practicable levels. In this regard current conditions in the mines are of the 
utmost importance both for those who are now entering and for those who 
already have experienced substantial exposure. 

CURRENT CONDinONS IN THE MINES 
AND THEIR IMPROVEMENT 

Two uranium mines are currently in full operation: Denison Mines Ltd and 
Rio Algom Mines Ltd. The details of current exposure conditions in these 
mines will be reviewed. A new mine at Agnew Lake is coming into opera- 
tion and at least one Bancroft area mine, Madawaska Mines Ltd (the old 
Faraday Mine), is being reopened. The developmental lessons of the past 
should be sufficient to alert management, labour, and government to the 
realization that full and effective compliance with dust and radiation stan- 
dards must be achieved in developing new mines and reopening old ones. 
The technical means are available for meeting current standards at reason- 
able costs. Operations that do not comply should be closed. 

The distribution of annual exposures to radiation among persons pos- 
sessing a Miner's Certificate for the years 1974 and 1975 in the two produc- 
ing mines is shown in Table 25. The mines are now expanding production, 
and the population of workers is growing. The average annual exposure in 
the Denison population decreased from L7wLMin 1974 to L2wLMin 1975 
when a major new ventilation raise, the Roman Island raise, first came into 
use. The corresponding average figures for Rio Algom workers were 1.2 
and 1.0 WLM. 

In Table 26 the numbers of persons receiving annually in excess of 1 , 2, 
and 3 wlm identify the part of the total population that would be at excess 
annual exposure if the allowable maximum annual exposure were set at any 
one of these values. In the two mines together in 1975, some 204, or 1 1 per 
cent, of the workers received more than 3 wlm, with an average of 3.7 
WLM. The majority of these persons are undoubtedly involved in under- 
ground development. 

The means to reduce exposure to alpha radiation underground include: 
1/ sealing off, where possible, emanations of radon gas; 2/ provision and 
efficient use of high volumes of ventilation air; 3/ rigorous adherence to 
sound work practices; 4/ the use in special circumstances of personal 
protective equipment; and 5/ the application of a policy of job rotation 
and/or job replacement (work adjustment). 

The disintegration of radioactive elements cannot be prevented, so that 
the generation of radon gas and subsequent alpha emissions cannot be 













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102 The health and safety of workers in mines 

suppressed. Whereas dust arises only from mining operations, radon gas 
continuously emanates from seepage water and rock faces and disinte- 
grates into radon daughter products. The emanating surfaces include 
worked-out areas of a mine and travelways driven in ore. Emanation of 
radon into the work area from currently broken ore at the workplace is 
unavoidable and must be swept out by main and auxiliary ventilation 
systems that are meticulously maintained. Emanation into occupied areas 
from worked-out areas can be prevented by carefully sealing off such 
regions with barriers and maintaining them under a negative exhaust pres- 
sure through good ventilation design. Experimental technology for coating 
rock surface with a sealant to retard radon emanation exists,^' and serious 
exploration of its use in selected passages should be undertaken in Ontario 
mines. 

Fundamental to the reduction of radiation levels is the effectiveness with 
which the masses of air pumped into the mine by the main ventilation 
system are directed in a fresh state to the zones in which persons work.^^ 
The effectiveness of a regional ventilation system in a mine can be seri- 
ously decreased by failure to maintain fans, baffles, and damper doors in 
optimum configurations. Such failure may arise from carelessness, from 
inadvertent blast damage, and from equipment failure. One uranium mine 
has planned a central monitoring system to ensure that the state of the main 
ventilating network can be continuously monitored. ^^ Believing this to be 
an essential step as the network of mine passages becomes more complex, 
the Commission therefore recommends: 

That each uranium mine install a central monitoring' system for its ventila- 
tion network to monitor air flow and air quality as indicated by dust, 
radiation, and other contaminants; 

That the Mines Inspection Branch audit the engineering records of per- 
formance of mine ventilation systems. 

In chapter 2 a statutory requirement was recommended for Codes and 
Schemes of Practice concerning the control of dust and other environmen- 
tal contaminants. The Commission intends that these should apply fully to 
radiation and should be the means for governing accepted standards of 
work practices in whose implementation the worker fully participates. 
Substandard work practices that increase present dust and radiation levels 
cannot be tolerated in the name of production or bonus pay at the expense 
of the worker's health some years in the future. The shift boss and the men 



1 



103 Lung cancer and ionizing radiation 

should be clearly instructed on this matter through established Schemes of 
Practice. The basic operative responsibility rests with the shift boss, who 
must be given full support by higher levels of supervision. 

Some subsidiary methods are available for piotecting persons in special 
circumstances while at the workplace. Substantial progress is being made 
in the design of compact visored helmets which flush the face with air 
obtained from the work environment and filtered by means of a small fan 
driven by a cap-lamp battery. '^'^ Such powered devices may prove accepta- 
ble for limiting exposure in special tasks. Ordinary respirators are not 
acceptable devices except for sharply limited periods in exceptional condi- 
tions of exposure. '^'^ 

WORK ADJUSTMENT AND JOB ROTATION 

The control of radiation exposure by withdrawing a person from his regular 
workplace deserves special discussion. 

Lung cancer is a much more complex disease than silicosis. Silicosis is 
not expected to occur in the general population, has an identified cause of 
occupational origin, and often gives precursor radiographic evidence 
which may forewarn of the onset of the disease, thus permitting the process 
to be slowed or stopped at a stage that involves very limited disability. 
These circumstances combine to make a work adjustment programme as 
recommended in chapter 2 feasible. Lung cancer, however, occurs in the 
absence of recognized carcinogens and in response to several known 
carcinogens of which ionizing radiation is one. By the time a lesion is 
detectable by radiographic methods the likelihood of survival is not great. 
Recent research on sputum cytological methods has shown that in many 
persons who have developed bronchial carcinoma there is a distinctive 
series of five stages of cellular change exhibited in sputum which precede 
invasive carcinoma. ^^ A person who exhibits sputum identified with a 
given cellular stage does not invariably progress to lung cancer. The 
Commission is advised that the methodology itself is not at present suited 
to mass screening in the manner in which radiographic methods have been 
used.^^ It has recently been used by the Ministry of Health in experimental 
surveillance of a group of uranium miners at high risk at Elliot Lake who 
entered these mines before 1962.^^ Until potentially predictive medical 
tests such as sputum cytology are more fully developed, any policy of work 
adjustment, as distinct from removal for medical treatment following selec- 
tive medical surveillance, should be based primarily on records of radiation 
exposure. 



104 The health and safety of workers in mines 

There are clearly two possible types of work adjustment: one based on 
job rotation and designed to limit annual exposure, the other based on job 
replacement and designed to limit career exposure. 

In the absence of evidence of a threshold below which it may be pre- 
sumed that there is no risk, it is prudent to assume that the risk of excess 
cancer of the lung increases with ionizing radiation from zero exposure. 
Linearity of response to cumulative exposure is accepted by the Interna- 
tional Commission on Radiological Protection as a conservative relation 
for estimating risks. Linearity is consistent with the estimated risk derived 
by sample analysis in Figure c. 1 for the population on the Ontario Uranium 
Roll. In Figure c. 1 the estimated risk at any cumulative exposure is plotted 
in terms of the estimated proportion of Ontario uranium miners (born 
before 1933) who had died of lung cancer by the end of 1974. Under these 
circumstances, the statistical excess of lung cancer derives from the whole 
range of exposures. In any one specified range of cumulative exposure, the 
number of excess lung cancers is proportional to the risk and to the number 
of persons having experienced exposure in that range. Hence, on the 
premise of linear response to ionizing radiation, it is wrong to attribute the 
excess of lung cancers to the cases in Table c-1 possessing simply the 
highest exposures to radiation. In statistical terms, and these are the only 
terms in which excess lung cancer can be identified, excess cases may arise 
from cumulative exposure at 0-50 wlm, 50-100 wlm, 100-150 wlm, and 
so on. And because the risk, although increasing with exposure, is a small 
number, substantial numbers of persons in all exposure ranges will survive 
without experiencing carcinoma of the lungs. A particular miner may or 
may not experience lung cancer at any level of exposure. Medical science is 
not currently able to determine which individual regardless of exposure to 
ionizing radiation is destined to develop carcinoma of the lung. 

The Commission therefore concludes that there is no ground, based on 
the health of the population of uranium miners, to justify a policy of work 
adjustment through removal of a miner from exposure and his placement in 
another job after he has experienced some designated total exposure to 
ionizing radiation. If the mines are in a stable state of production, or 
expanding, the removal of one man will imply his replacement by another, 
who begins to experience exposure to radiation and to incur risk of lung 
cancer that may not be expressed until a period of latency elapses. Mean- 
while the man he has replaced may die of lung cancer in any event. Hence, 
the statistical expectation of excess lung cancer can be definitely reduced 
only by reducing the collective exposure of the working population by 



105 Lung cancer and ionizing radiation 

lowering the general level of exposure to radiation, decreasing the number 
of persons experiencing given levels of exposure, or by decreasing expo- 
sure to conjoint factors such as cigarette smoke. Further, when persons 
change jobs there may be augmented risks of accidents related to age and to 
training. Younger persons replacing older persons may be at significantly 
higher risk of loss of life years through disabling accidents. Table 23 
provides convincing evidence of differential risks that are age-dependent. 
The study of accidents and injuries in chapter 4 will elaborate on these 
risks. Non-smokers replacing smokers would partially compensate for 
these subsidiary risks. Hence, work adjustment through job replacement to 
limit career exposures is not an acceptable substitute for the reduction of 
levels of radiation and of associated factors such as cigarette smoke. The 
Commission therefore does not recommend a policy of work adjustment 
through job replacement for uranium miners based on exposure to ionizing 
radiation. Nor can it endorse the provisions in recent collective bargaining 
agreements at Elliot Lake for the exercise of special seniority among 
persons who have experienced specific levels of exposure. If the risk of 
cancer mortality increases with exposure, such policies cannot in the 
Commission's view be justified on the basis of serving the health of the 
population of uranium miners. Indeed the converse effect may occur. The 
Commission has considered no other grounds. It interprets the decision of 
the Workmen's Compensation Board to introduce such a policy for work- 
ers in Elliot Lake to have been based on the existence of a threshold of 
exposure at or about 120 wlm below which no significant excess risk of 
cancer mortality is presumed to exist. ^^ The data analysed by the Commis- 
sion does not support that basis. 

Finally, the Commission recommends: 

That job rotation within mines conducted to meet the standard for max- 
imum permissible annual exposure to ionizing radiation be permitted only 
in exceptional circumstances with the explicit approval on a case-by-case 
basis of the Occupational Health and Safety Branch and with the know- 
ledge of the representatives of the workers. 

To the Commission's knowledge, the uranium mines have not engaged 
in this practice on any significant scale. While work adjustment in relation 
to ionizing radiation cannot be commended, medical surveillance is of 
special importance. 



106 The health and safety of workers in mines 

MEDICAL SURVEILLANCE IN RELAIION 
TO DUST AND IONIZING RADIATION 

Medical surveillance of miners in relation to known health hazards has the 
following major puiposes when coupled to environmental monitoring: 

- to provide epidemiological data required to permit standards of exposure 
to be reviewed and revised; 

- to provide epidemiological data required to permit the definition of the 
effects of conjoint factors in occupational risks (such as cigarette smoking 
anddiesel fumes); 

- to provide, through early detection of health impairment, '^^ individual 
evidence that may be used to assist a person through treatment or work 
adjustment; 

- to guide the making and administration of new policy on workmen's 
compensation, on work adjustment, and on medical surveillance itself. 

, The cornerstone of medical surveillance for persons who work in dust 
exposure in Ontario mines has been the medical examinations required for 
the issuance of a Miner's Certificate. '^' An initial certificate is issued on the 
basis that 'if the medical officer finds upon examination that the applicant is 
free from disease of the respiratory organs and otherwise fit for employ- 
ment in a dust exposure occupation, he shall issue to the applicant an initial 
certificate.''^^ The holder of an initial certificate is required to present 
himself for re-examination after eleven months in dust exposure. If the 
person is then free from disease of the respiratory organs his certificate is 
endorsed. Finally, if after a further period of eleven months in dust expos- 
ure the person is free from tuberculosis of the respiratory organs he is 
issued a Miner's Certificate, which retains its validity if at an annual 
examination the holder is found to be free of tuberculosis of the respiratory 
organs. '^^ 

The medical examinations referred to have been conducted at Chest 
Examining Stations set up in the mining districts by the Workmen's Com- 
pensation Board. They are now administered and staffed by the Ministry of 
Health. The radiographic and related occupational records collected 
through these stations have been filed centrally by the Workmen's Com- 
pensation Board, which has gradually developed a Mining Master File of 
which the Ontario Uranium Nominal Roll is now a part. This massive file 
contains the core of case data used by the Commission. Unfortunately, 
important related occupational data, such as the exposure of each miner to 
ionizing radiation as kept since 1968 by the mines, have not been keyed to 
the records of the Board. The Commission therefore recommends: 



107 Lung cancer and ioni/ing radiation 

That records ofpersoiuil exposure to ionizing radiation maintained h\ the 
mines he keyed to Miner's Certificate niimhers in sequence and to so( iid 
insurance numhers in sequence and arranged in a format that facilitates 
linking to the Mining Master File. 

There is no subject more important to the protection of workers than the 
adoption of simple means of keying company and governmental records so 
that they can readily be linked for manual or computer data analysis. '^^"^ 

The system of annual radiographic examinations for renewal of Miner's 
Certificates was introduced in a period when tuberculosis and silicotuber- 
culosis were a scourge among miners. These conditions no longer exist, 
and it is no longer necessary to collect radiographic data on every dust- 
exposed miner every year. Such evidence has been of primary use in 
administering workmen's compensation for silicosis. A less frequent rec- 
ord of a miner's lung condition can be made equally effective by backdating 
any compensation award to the date of the immediately preceding exami- 
nation. When silicosis is effectively suppressed it may be time to abandon 
the Miner's Certificate as an instrument of regulatory control, but such a 
step is still considered premature. Therefore, the Commission recom- 
mends: 

That the frequency of regular radiographic examination of dust-exposed 
mine workers be reduced to once every two years unless a radiographic 
change was apparent at the last examination. 

The staff at the examining centres should be encouraged to participate in 
epidemiological studies conducted by or through the Occupational Health 
and Safety Branch for the purposes of reviewing standards and for the 
detailed study of health conditions among selected samples of mine work- 
ers such as presilicotics and persons at high risk from ionizing radiation. 
Such sample studies are desirable in developing policies of compensation 
and work adjustment. They are all too rarely used. Such examining stations 
should be equipped to perform lung function tests, audiometry, and other 
tests as determined by the Occupational Health and Safety Branch. 

It is understood that the examining physicians currently advise the 
attending physician of each worker in writing about any respiratory ab- 
normalities that deserve attention either for treatment or for possible 
compensation. The question of specialized surveillance of persons with 
exceptional exposure to ionizing radiation deserves particular comment. 

It has been noted that sputum cytology is not at present suited to massive 



108 The health and safety of workers in mines 

application in occupational medicine. However, sampling methods are 
feasible. It is therefore recommended: 

That tests using sputum cytology he conducted every two years on all 
persons who have worked in radiation exposure at the uranium mines for 
five or more years. 

Further aspects of medical surveillance will be discussed in Chapters 5 
and 6. 

LUNG CANCER AND WORKMEN'S COMPENSATION 

The Commission has confirmed that an excess of lung cancer, conserva- 
tively ascertained to be thirty-six cases, has occurred in the population of 
15,094 persons on the Ontario Uranium Nominal Roll for the period 1955 
through 1974. On the basis of the estimated under-ascertainment as- 
sociated with the procedures of the death search as previously described 
(see appendix c), it is believed that the number of excess cancer cases to the 
end of 1974 may be about forty-five, which is the same as the expected 
number of cases of lung cancer. Further, sample analysis has shown 
statistical evidence that the risk of lung cancer among the population on the 
Ontario Uranium Nominal Roll in the period 1955 through 1974 is related to 
exposure to ionizing radiation received in Ontario. If there are additional 
factors specific to the uranium mines contributing to an excess of lung 
cancer, they are as yet unknown. It is imperative that compensation be 
provided to victims of lung cancer that can reasonably be attributed to 
working in the uranium mines. 

The Workmen's Compensation Board first allowed compensation for 
lung cancer among uranium miners in 1970. As shown in Table 5, eight out 
of thirty-one cancer cases charged to the mining industry in 1974 were 
uranium miners. The cases of lung cancer among uranium miners allowed 
compensation to the end of 1975 total twenty. The compensation almost 
invariably has been as a pension to the widow and family. 

The difficulties inherent in deciding which cases are entitled to compen- 
sation have been outlined in the subsection on Work Adjustment. There is, 
on the basis of medical evidence, no clear way to identify the subset of 
persons within the total number of cancer deaths whose deaths represent 
the statistical excess over that number which would be expected in the 
absence of exposure. Exposure alone is not a definitive determinant. The 
act of granting compensation is a human decision and not susceptible to 



109 Lung cancer and ionizing radiation 

sharp quantitative prescription. In effect the Board is placed in the unenvi- 
able position of judging which persons may be considered to have been at 
exceptional risk. There is an inescapable dilemma here. On the one hand 
most of the persons on the Uranium Nominal Roll who have died of lung 
cancer have experienced some additional risk by exposure to radiation in 
the mines. On the other hand it is statistically clear that half of these 
persons would have experienced lung cancer in any event. There are 
certain guiding principles to be recommended beyond which, the Commis- 
sion believes, the Board should give every reasonable benefit of doubt to 
the man and his family. First, it is recommended: 

That the Workmen's Compensation Board of Ontario, in collaboration 
with other provincial boards as provided for in interprovincial agreements, 
seek out and advise the families of all ascertained deaths due to lung 
cancer on the Nominal Roll that a claim for compensation should be 
entered. 

The Board should review all claims for compensation using the follow- 
ing as evaluative factors in the adjudication: 1/ the duration of the period of 
exposure to dust and ionizing radiation, 2/ the record of cumulative expo- 
sure to ionizing radiation and the limits of variability anticipated in this 
record, 3/ the elapsed time from entry to illness or death, 4/ the environ- 
mental record at the mines worked at and the jobs undertaken. 5/ the 
calendar years spanning the interval of exposure, 6/ the age at entry, 7/ the 
pathology of the primary tumour, 8/ the available analysis of the mortality 
experience of the Ontario Uranium Nominal Roll, 9/ the available esti- 
mates of risk of lung cancer for the Ontario Uranium Nominal Roll, and 10/ 
the record of factors of risk known to be conjoint with ionizing radiation, 
and the related evidence on the role of radiation. 

With regard to item 10 it has been noted that had no uranium miners 
smoked cigarettes the number of observed cancer deaths expected would 
have been very much smaller. This fact may be used to argue that the 
excess of lung cancer is in some sense due largely to cigarette smoking and 
therefore that the number of persons compensated should be reduced ac- 
cordingly or charged to the Consolidated Revenue Fund rather than to the 
uranium mines. The manner in which radiation exposure combines with 
cigarette smoking to produce a resultant risk of cancer is not clearly 
understood at the levels of exposure experienced in Ontario mines. In the 
matter of compensation, the Commission's view, which is not based on 
scientific premises, is that uranium miners should be compensated without 



1 10 The health and safety of workers in mines 

regard to their smoking habits, because they experience a greater risk than 
the smoking non-miner. 

Should evidence be obtained that there is a threshold of exposure to 
ionizing radiation below which there is no risk of lung cancer from this 
cause, the evaluative criteria of the Board ought to be altered accordingly. 
However, the argument for such a threshold must be demonstrated to be 
consistent with data obtained from the Ontario uranium mines and their 
workers. Whether or not there is such a threshold or some unknown 
carcinogen, there is excess lung cancer, for which compensation must be 
provided on a generous basis of interpretation. The costs of nuclear power 
for public use are so vast that the costs of being publicly responsible to 
uranium miners and their families are by comparison negligible. 



1 The Effects on Populations of Exposure to Low Levels of Ionizing Radiation: Report of the 
Advisory Committee on the Biological Effects of Ionizing Radiation. Division of Medical 
Sciences, National Academy of Sciences and National Research Council, Washington 

' DC, November 1972, chap. 7 and appendix 7, f Lung; Henceforth cited as be\r Report . 
Frank E. Lundinjr, Joseph K. Wagner, and Victor E. Archer, Radon Daughter Exposure 
and Respiraton- Cancer Quantitative and Temporal Aspects: National Institute for Occu- 
pational Safety and Health, National Institute of Environmental Health, Joint Mono- 
graph No. /, Washington DC, June 1971, chap. 3; henceforth cited as Lundinetal.,/?«£/o/7 
Daughter Exposure 

2 Lundin et al. , Radon Daughter Exposure, 97 

3 Victor E. Archer, Geno Saccomano, and James H. Jones, 'Frequency of different his- 
tologic types of bronchogenic carcinoma as related to radiation exposure,' Cancer, 34, 
1974, 2056-60 

4 Extensive statistical analysis of the occurrence of lung cancer among uranium miners in 
the United States is available and developed in the following institutional sources: 
Lundin et al. , Radon Daughter Exposure; Advisory Committee from the Division of 
Medical Sciences: National Academy of Sciences, National Research Council, National 
Academy of Engineering, Radiation Exposure of Uranium Miners. Washington dc: 
Federal Radiation Council, August 1968; Federal Radiation Council, Guidance for the 
Control of Radiation Hazards in Uranium Mining, Washington dc: f.r.c. Report No. 8 
(Revised), September 1967 

5 Lundin et al. , Radon Daughter Exposure, Tables 4, 5 

6 Victor E. Archer, Joseph K. Wagoner, and Frank E. Lundin, jr, 'Uranium mining and 
cigarette smoking effects on man,' Journal of Occupational Medicine, 15, 1973, 204-1 1 ; 
Victor E. Archer, Dean J. Gillam, and Lynn A. James, 'Respiratory disease mortality 
among uranium miners as related to height, radiation, smoking, latent period,' to appear in 
the forthcoming Proceedings of the Third International Symposium on the Detection and 
Prevention of Cancer, ed. H.E. Nieburgs, md. New York, 1976 

7 P. Gross and R.T.P. de Treville, 'The pneumoconioses,' The Industrial Hygiene Founda- 
tion of America, Bulletin No. 12, 1967; I. Webster, 'Bronchogenic carcinoma in South 
African gold miners,' Pneumoconiosis, Proceedings of the International Conference, 
Johannesburg, 1969, 572-4; E. Trapp et al., 'Cardiopulmonary function in uranium 
miners.' American Review of Respiratory Disease, 101 . 1970, 27-43; J. Chameaud et al., 
■Risques et nuisances des mines d'uranium prevention mcdicale,' Colloque International 
de Radioprotection dans l' Extraction et Le Traitement de L' Uranium et du Ihorium, 



1 1 1 Lung cancer and ionizing radiation 

Bordeaux, Fiance, 9-1 1 septembre 1974: see also n 6. Archer ct al.. 'Respiratory disease 
mortality'. 

8 There are three major chains for which the parent isotopes are U^"*, U^''' and Ih^'^ Of all 
the uranium, 99.3 percent is U-"* and 0.7 percent U^^^ F-"or details of the chains see. for 
example, G. Friedlander and J.W. Kennedy, Nuclear and Radiochcmistry , New York, 
1955, chapter I, sec. c. 

9 A.J. Villiersand J. P. Windish, 'Lung cancer in a fluorspar mining community- I radiation, 
dust and mortality experience,' Brilish Journal of Medicine, 21 , 1964. 94-108; Newfound- 
land, Royal Commission Respecting Radiation, Compensation and Safety in the Fluorspar 
Mines, St Lawrence, Nfld, Report, Newfoundland: Queen's Printer, 1969: J.K. Wagoner 
et al., 'Unusual cancer mortality among a group of underground metal miners,' New- 
England Journal of Medicine, 269. 1963, 284-9 (Radiation levels are estimated to have 
been between 6 and 24 wlm per annum.); J. O. Snihs, 'The approach to radon problems in 
non-uranium mines in Sweden,' Proceedings of the Third Conference of the International 
Radiation Protection Association, Washington DC. September 1973; H.S. Jorgensen. 'A 
study of mortality from lung cancer among miners in Kiruna 1950-1970,' Work Environ- 
mental Health, 10, 1973, 126-33; Karl Goran St Clair Renard, 'Respiratory cancer mortal- 
ity in an iron mine in Northern Sweden,' Amhio, 3, 1974, 67-9; M.J. Duggan et al., 'The 
exposure of United Kingdom miners to radon,' British Journal of Industrial Medicine, 17, 
1970, 106-9; J. C. Strong, A.J. Laidlaw, and M.C. 0'K\ov&dr\, Radon and Its Daughters in 
Various British Mines, London: National Radiological Protection Board, Report 39, 
HMSO, 1975; J.K. Basson et al., 'Lung cancer and exposure to radon daughters in South 
African gold/uranium mines,' 4th International Canference on the Peaceful Uses of 
Atomic Energy, Geneva, 1971 

10 The biological significance of rare earths in mine aerosols is not clear, but the distinctive 
variations noted deserve attention in research related to the proposed statutory standard 
for dust. Yttrium and cerium metallic compounds are common. The significance of free 
silica has been discussed in chapter 2. 

1 1 United States Public Health Service, Control of Radon and Radon Daughters in Uranium 
Mines and Calculations of Biologic Effects, Washington Dc: us Department of Health. 
Education and Welfare, Public Health Service Publication No. 494, 1957 (henceforth cited 
as us Public Health Service Publication 494); Duncan A. Holaday. Evaluation and Control 
of Radon Daughter Hazards in Uranium Mines, Washington DC: us Department of 
Health, Education and Welfare, No. [niosh] 75- 1 17, November 1974 

Only 0.7 percent of uranium atoms are of the isotope U^-^\ and the half-life of the gas 
actinon, which appears in its radioactive chain, is 3.92 seconds, as compared to 3.83 days 
for radon. Thus there is very little actinon, compared to the amount of radon, and only a 
relatively small fraction of that becomes airborne. 

In Ontario uranium ores, the number of atoms of thorium Th-^- which give rise to the 
gas thoron is comparable to the number of atoms of uranium. However, the half-life of 
thorium is about three times that of uranium U^^** and the half-life of thoron gas is about 
1/6000 of that of radon gas. Both of these factors diminish significantly the amount of 
thoron that becomes airborne in mine air relative to the amount of radon. Further, the 
relatively long half-life of the daughter Thorium b facilitates it being swept out by ventila- 
tion. Foracomparativeanalysisof the effects of radon and thoron at agivenacli\ily level 
in relation to a lung model see for example, W. Jacobi, 'Relations between the inhaled 
potential a - energy of Rn^'^ - and Rn^^° - daughters and the absorbed a - energy in the 
bronchial and pulmonary region,' Health Physics, 23, July 1972, 3-1 1 . For related sampl- 
ing analysis, see for example R.L. Rock, Sampling Mine Atmospheres for Potential Alpha 
Energy Due to the Presence of Radon -220 (Thoron) Daughters, Denver: Mining En- 
forcement and Safety Administration. Information Report iR-1015. 1975. M.J. Duggan, 
'Some aspects of the hazard from airborne thoron and its daughter products.' Health 
Physics, 24, March 1973, 301-10; J.C. Strong and M.J. Duggan, 'The effects of the 



1 12 The health and safety of workers in mines 

presence of thoron daughters on the measurement of radon daughter concentrations,' 
Health Physics. 25. September 1973. 299-300 

12 A few measurements of thoron daughters were made in the Rio Aigom Nordic Mine by the 
Ministry of Health in August 1967. 

13 Beta rays are high speed electrons, gamma rays are similar to x-rays, and alpha particles 
are energetic nuclei of helium atoms. Alpha particles penetrate at most a few surface layers 
of human cells; beta and gamma rays are more penetrating, and the latter in particular 
contribute to whole-body irradiation. 

14 The gamma and beta irradiation is in part from uranium and thorium in the faces of the 
unbroken and broken rock and in part from the daughters of radon and thoron in the mine 
air. 

15 The radiation dose in Rems (Roentgen Equivalent Man) is equal to the absorbed energy 
dose in Rads times the rbe (Relative Biological Effectiveness) factor for the type of 
radiation being absorbed. The Rad is a measure of the energy of irradiation absorbed by a 
unit mass of human cells and is 0.01 joules per kilogram. The rbe factor is relative to the 
biological effect of one Rad of 250 kv x-rays {ee\r Report). 

16 At the time of writing the Atomic Energy Control Board had not formally designated 
uranium miners as Atomic Radiation Workers under the Atomic Energy Control Act, but 
Schedule ii. which is based on the recommendations of the International Commission on 
Radiation Protection (icrp). has been used by the mines as a guide. 

17 A.J. Breslin, A.C.George, and M.S. WQinslem, Investif^'ation of the Radiological Charac- 
teristics of Uranium Mine Atmospheres, New York: Health and Safety Laboratory, us 
Atomic Energy Commission, hasl-200, December 1969, 24 (henceforth cited as Breslin et 
al.. Investigation) 

18 The natural background irradiation plus medical diagnostic irradiation of the general 
population in the usa average about 0. 170 Rems per year. be\r Report, Table 1 , 50 

19 us Public Health Service Publication 494, 15-20 

20 The special role of radon daughters was first identified by W.F. Bales in 1951 in an 
unpublished memorandum of the us Atomic Energy Commission, entitled 'Hazards 
associated with radon and thoron.' 

Radon gas breathed into the lungs contributes also to a body burden of radioactive 
substances by diffusing through the alveolar membrane into the blood from which it 
deposits preferentially in fatty tissues. Further, mine dust contains radioactive uranium 
and thorium products deriving from the stages of the decay chains which precede the noble 
gases and follow the basic daughters. A maximum permissible limit on this component of 
radiation is in use in the French uranium mines, together with limits on external radiation 
and internal radiation from radon and its daughters. Y. Francois, J. Pradel et P. Zettwoog, 
Tncidence des normes de radioprotection sur le marche de Turanium,' in Radon in 
Uranium Mining, Vienna: International Atomic Energy Agency. 1975 

21 The level of radioactivity in mine air is one 'Working Level' when the complete decay to 
Radium d of whatever combination of short-lived daughters of radon Rn'— is present in 
one litre of air would yield a total Alpha energy of 1.3 x 10'' mhv. A 'Working Level Month' 
is exposure for 170 hours to mine air in which the radioactivity averages one Working 
Level over that period. 

22 Code of Requirements for the Survey of Dust, Ventilation and Radioactivity at Uranium 
Mines in Ontario, Department of Mines, Ontario. 1 March 1957; Mines Accident Preven- 
tion Association of Ontario. Radon Daughter Sampling Procedure 

23 Mines Accident Prevention Association et seq.. First Report -Dust Control, Ventilation 
and Radioactivity at Faraday Uranium Mines Limited, January 1956. The accepted 
standard of radioactivity in mine air was equivalent to 100 picocuries per litre of each of the 
radon daughters Radium a. b. and c in equilibrium. One picocurie is equal to 2.22 nuclear 
disintegrations per minute. W.F^. Bawden, 'Proposed legislation on radioactivity by De- 
partment of National Health and Welfare of Ottawa,' Memorandum to Dr C.G. Cunning- 
ham. Division of Industrial Hygiene, Department of Health. 5 Aug. 1959. Toronto 



1 13 lAing cancer and ionizing radiation 

24 Rdcliation Iluzunls in Ontario Mines. Department of Mines. 4 Dec. 1967 

25 Riuliation Exposure in Ontario Mines, Ministry ofNatmal Resources, Mines Division, 
Hngineering Branch, 9 Nov. 1972 

26 Radiation Exposure in Ontario Mines, Ministry of Natural Resources. Division of Mines, 
Mines Kngineering Branch, I July 1974 

27 Unfortunately, as so often happens with occupational health records, there was no 
requirement that these new records be readily linkable with the massive existing radio- 
graphic records maintained by the Workmen's Compensation Board. 

28 For representative membership, see Ontario Mining Association, Annual Report, 1973. 

29 For example, W.C. Wheeler, 'Progress report on the preparation of a nominal roll of 
Uranium miners,' presented at Advisory Committee on Occupational Health of the 
Ontario Mining Association, 23 Nov. 1972 

30 The origin and stagesofdevelopment of the initial Nominal Roll are described in J. Muller 
and W.C. Wheeler, 'Causes of death in Ontario uranium mines (Second report). May 1974. 
revised July 1974 (hereafter cited as Muller and Wheeler, 1974). 

31 These estimates were based on proportional mortality ratios. The form of the Nominal 
Roll was not, and is not, sufficiently complete to permit ready calculation of either man 
years at risk or of personal radiation exposure, and the death search was for Ontario 
records only. 

32 Jan Muller, 'Causes of death in Ontario uranium mines' (Preliminary Report), January 
1973. Prior to this report, reference had been made to the identification of twenty cases of 
lung cancer among uranium miners. See Ministry of Health, Occupational Health in 
Ontario, 22, December 1970, 5. 

33 Muller and Wheeler, 1974 

34 J. Muller, W.C. Wheeler, 'Causes ofdeath in Ontario uranium miners,' /'/-or£'^£/m^5c»///ie 
International Symposium on Radiation Protection in Mining and Milling of Uranium and 
Thorium, Bordeaux, France, 9-1 1 September 1974 

35 Transcript of hearings, 566 

36 In response to an internal review of the field of occupational and environmental health 
conducted by the government in 1975, an Advisory Committee on Occupational and 
Environmental Health comprising representatives of industry, labour, and government 
and advisory to the Ministry of Health, has been established. 

37 D. Hewitt, 'Radiogenic lung cancer in Ontario uranium mines, 1955-1974,' Commission 
Project Document, May 1976. Data not reviewed in the report are included in appendix c. 

38 Man-years at risk were estimated from a 10 per cent random sample of the Nominal Roll. 
The sample was determined by selecting persons whose Miner's Certificate numbers 
ended in the digit 4. The random sample of cumulative exposure to radiation was con- 
ducted for 1 per cent of the Nominal Roll and yielded 158 persons, of whom 147 were 
survivors to the end of 1974. The sample was determined by selecting persons whose 
Miner's Certificate numbers ended in the digits 34. 

39 There is no assured manner in which to determine whether or not all deaths have been 
found. An analysis of the yield of data from the previous Ontario searches and from the 
computer-based search of Statistics Canada leads to an estimate that about 1 15 deaths may 
not yet have been found, including proportionately more deaths at ages over fifty years 
than among the 956 successfully 'ascertained' deaths. Such a possible deficit in observed 
deaths would not alter the conclusions of this study. If the deficit is of the size and type 
suggested, the total number of deaths to the end of 1974 would be about 1070 (see Table 
23), and lung cancer deaths would be about ninety-three rather than eighty-one. It is 
further assumed that no incorrect matches have been made. The assessment herein then is 
given as if 956 and 81 represent all deaths. 

40 Another choice for comparison is the population of Northern Ontario. The Commission 
has examined the relation of the actual death-experience of males in Northern Ontario to 
expected deaths among all Ontario males. The comparison is shown in Table D.9. This 
table is for all ages, whereas ages over 65 are largely unrepresented at present in the 



1 14 The health and safety of workers in mines 

Nominal Roll. A further comparison population worth considering is an age-matched 
group of non-uranium miners. The comparison with all Ontario males as used by the 
Commission serves to illuminate the public health risks of uranium mining. 

41 Expected deaths are based on the man-years at risk in the entire Nominal Roll, which 
includes many persons w ith very short working exposures. The actual deaths are based on 
the best achievable search. Since some deaths may be missed, the figures for actual deaths 
are conservative. Thus, while the ascertained excess of cancer deaths is thirty-six. an 
estimate based on the effectiveness of the search leads to the number forty-eight. The 
expected number at 45.08 is statistically complete within a sampling error on man-years at 
risk. 

42 Epidemiological research on the risk of cancer at a future time produced by a present 
exposure to radiation may permit the course of the excess of lung cancer to be estimated. 
See Eundin et al.. Radon Daitt^lucr Exposure, chap. 4. 

43 The mortality experience of us uranium miners reveals some distinctive differences from 
that ofthe Ontario Uranium Nominal Roll. See Victor E. Archer and Joseph K. Wagoner, 
'Lung cancer among uranium miners in the United States.' Health Pliysies. 25, October 
1973, 351-71 and Table 1 (hereafter cited as Archer and Wagoner, 1973). 

44 In Table 23 the comparison is between expected and estimated actual deaths (rather than 
ascertained deaths). See n. 39. 

45 BE\R Report. 

46 See n. 4 and CD. Stewart and S.D. Simpson. 'The hazards of inhaling Radon-222 and its 
short-lived daughters: considerations of proposed maximum permissible concentrations 
in air,' in Radiolo^ieal Health and Safety in Minini> and Milling ofNuelear Materials, 
Vienna: International Atomic Energy Agency. 1964. 333-57 

47 Forcomparableuscasedatasee Archer and Wagoner. 1973. Table 5. The mean exposure 
of 1 15 cases of cancer in us uranium mines was 2,000 wlm. 

48 The control group of eighty-one randomly selected survivors was determined from the 1 
percent sample (see n. 38) by deleting deaths and ensuring that the date of birth was such 
as to enable the person to have been employed in the mines in 1954-5 and later. 

49 See appendix c, D. Hewitt. 'Radiogenic cancer in Ontario uranium mines. 1955-1974.' 
Table c. I and Figure c. 1 refer to tests of dependence on cumulative exposure. Table c. 2 to 
tests related to region of employment and period of entry, and Table c.3 to a test for 
dependence of radiation effects on age. 

50 The Atomic Energy Control Act ofthe federal government was passed in 1946 and first 
revised in 1954. 

51 Atomie Energy Control Regulations P. C. 1960-348, 94 (Canada Gazette, Part II, SOR 
601119, April 13, 1960). The most recent revision was in 1974 under PC 1974-1195, 108 
(Canada Gazette, Part 11, SORjDORS 74-334, June 26, 1974). 

The 1960 Regulations were reviewed with provincial authorities before enactment. 
Under these Regulations certain members of the staff of the Mines Engineering Branch 
were designated radiation inspection officers by the federal Department of Health and 
Welfare on behalf of the Atomic Energy Control Board. The practice continues and the 
Board offers a Uranium Mine Inspector Training course. 

The AECA Regulations stipulate maximum permissible doses of ionizing radiation in 
Rems per annum. However, no interpretation of internal alpha irradiation in terms of 
equivalent values of practical units such as the Working Level Month has formally been 
given by the Board. In the hearings ofthe Commission, the aecb contended that the limit 
of 15 Rems per annum to the lung may be considered to have been met by the provincial 
standards ranging from 12 to 4 wlm (Transcript, 5449). 

52 Federal Radiation Council, Guidance for the Control of Radiation Hazards in Uranium 
Mining, Washington dc: f.r.c. Report No. 8 (Revised), 1967. The Board's response is 
described in the Transcript 5406 ff. 

53 Revised Statutes of Canada, 1970, First Supplement, c. 22. 



1 1 5 Lung cancer and ionizing radiation 

54 Pronto Uraniiint Mines l.iniilal (itul Ali^om Uroniiim Mines Limited v The Ontario 
Labour Relations Board et aL, Ontario Reports ( 1956), 862. Denison Mines Limited v I lie 
Attorney General of Canada, Dominion Law Reports ( 1972), 419 

55 Revised Statutes ofCanada. 1970. c. (,H 

56 Transcript, 5402, 541 1. Foi difticiilties with provincial aulhoiitics see 5424-5. 

57 See nn. 58, 59, and F.T. Cross et al., 'Evaluation of methods for setting occupational 
health standards for uranium miners,' Report FB-237 774 ^ np: Battelle-F^icific Northwest 
Laboratories, March 1974; Available from Nils, us Department of Commerce. 

58 'Recommendations of the International Commission on Radiological Protection (Revised 
December 1954),' British Journal oj Radiology, Supplement No. 6, London, 1955. The 
ICRP recommendation of 100 picocuries per litre of radon and its daughters for a 168-hour 
week came to be interpreted in Ontario as 100 picocuries per litre of each of the daughters 
RaA, RaB, and RaCfora 40-50 hour week. Under equilibrium conditions, 100 picocuries 
per litre of each of the latter daughters is equivalent to 1 Working Level. An instrument 
based on a scintillation counter to detect alpha disintegrations was designed with the 
assistance of Atomic Energy of Canada Ltd and manufactured in Canada. Over a period of 
a few minutes this instrument sucks several litres of mine air through a filter on which 
radioactive particles accumulate for subsequent reading of the rate of nuclear disintegra- 
tion. The method of measurement adopted was that due to Kusnetz in H.L. Kusnetz. 
'Radon daughters in mine atmospheres - a field method for determining concentrations,' 
American Industrial Hy^^iene Quarterly. 17, March 1956. Until 1967, readings were 
recorded in equivalent equilibrium picocuries/litre rather than in Working Levels. See also 
n. 23 and A.J. Cipriani, 'Radiation hazards in uranium mines,' Proceedings of Technical 
Sessions of the 24th Annual Meeting (f'the Mines Accident Prevention Association of 
Ontario, May 1955; and G.R. Yourt, 'Sampling for radioactivity in uranium mines,' 
Proceedings of Technical Sessions of the 24th Annual Meeting of the Mines Accident 
Prevention Association of Ontario, May 1955. 

59 International Commission on Radiological PvotQcUon,Report of Committee II on Permis- 
sible Dose for Internal Radiation ( 1959), London: icrp Publication No. 2, 1960 

60 'Radiation hazards in uranium mines, with particular attention to the icrpii ( 1959) revision 
of the guide level for radon and radon daughters,' Minutes of a Conference, Department of 
Mines, Department of Health, Toronto, 3 Nov. 1960. The Atomic Energy Control Board 
was not represented at this meeting. 

61 The 30-picocurie per litre standard for a 40-hour week or 3.6 Working Level Months 
(rounded to 4 wlm) did not become effective under a code of requirement issued by the 
Mines Engineering Branch until January 1975. 

62 For example, the following sources affirmed the 12 wlm per annum standard; 'Radiation 
protection in uranium mines and mills,' USA Standards Institute Document USAS 

N7. 1-1960, 3 Oct. 1960; us Public Health Service, Governors' Conference, Health 
Hazards in Uranium Mines, Washington Dc; Department of Health. Education and 
Welfare, us Public Health Service Publication No. 843, 1961 (An increased lung cancer 
risk among us uranium miners was first documented at this conference.); 'Radiation 
protection guide for federal agencies,' Federal Radiation Council, usa, in the Federal 
Register, 32, No. 7, Tuesday, 1 Aug. 1967; us Department of Interior. 'Regulations 
pursuant to the Federal Metal and Nonmetallic Safety Act,' Federal Register, 34, No. 1 1, 
Thursday , 16 Jan . 1969. For further detail of us practices see n.57 , Cross et al . In the usa , 
issues related to federal and state jurisdictions have been more complex than the corre- 
sponding federal and provincial question in Ontario. Provisions for variances from stated 
standards have been common. A Congressional examination of conditions in us mines is 
reported in Radiation Exposure of Uranium Miners: Hearings Before the Subcommittee 
on Research, Development and Radiation of the Joint Committee on Atomic Energy, 
Congress of the United States, Washington. 1967. 

63 This revision was in response to concern expressed by the Atomic Energy Control Board 



1 16 The health and safety of workers in mines 

(sec n.52). It included a new leqiiiremenl foi the maintenance of individual exposure 
records. After endorsement by the industry through the Ontario Mining Association it was 
issued as a code by the Chief Engineer of the Mines Hngineering Branch (see n.24). 

64 Metal and Non-Metal Mine Health and Safety Standards and Regulations. Public Law 
H9-571 .Federal M chil and !^ on- M ctaUic Mine Safety Act. Section 57.5-38, as superseded 
effective July L 1971. under a ruling of the Environmental Protection Agency, Mining 
Enforcement and Safety Administration, Washington, October 1974 

65 Transcript. 4234-5. 5567. and 4622. respectively 

66 C.G. Stewart. 'A history of the development of radiation protection,' unpublished manu- 
script communicated to the Commission in July 1975 (cited hereafter as Stewart. 1975) 

67 International Commission on Radiological Protection. Recommendations. London: icrp 
Publication No. 9, 1966 

68 J. Muller. 'Criteria for radon daughter concentrations in uranium mines,' Ontario, Minis- 
try of Health, May 1975 (cited herafter as Muller. 1975) 

69 Lundin et 'd\.. Radon Daughter Exposure. 89 

70 See n.20. Fran^^ois et al. 

71 See for example A. C. Chamberlain and E.D. Dyson. 'Thedose to the trachea and bronchi 
from the decay of products of radon and thoron.' British Journal ofRadioh)gy, 29, June 
1956. 317-25. See also n.l I, Jacobi. 1972. and H. Parker. 'The dilemma of lung dosimetry,' 
Health Physics. 16, 1969,553. 

72 See n.57. Cross etal.. Table 2.2. 

73 Representative conversion factors as used in the be\r Report and in Lundin et al.. Radon 
Dau^^hter Exposure, are 1 wlm = 2 Rads = 5-6 Rems. 

74 Transcript. 5449 

75 See n.4. For a compilation of related sources see n.57. Cross et al. 

76 Lundin et 2^., Radon Daughter Exposure, Tables 4-7. 

77 Ibid., Chapter V sect, h, 112. See also the conclusions in the works cited in nn.6 and 43. 

78 Ibid., sect. 1. 112 

79 C.G. Stewart and S.D. Simpson, 'On an (MPc)aforthe short-lived daughters of Rn222- 
1969," Pneumoconiosis, Proceedings of the International Conference. Johannesburg, 
1969 

80 See n.9, Jorgensen, 127, 132, and Snihs. 

81 See n.9, Basson et al., 9. The epidemiological data as published are incomplete; see also 
ibid., Jorgensen, 132. 

82 See n.7. Chameaud et al., 5-6. The number of underground workers increased to 1000 in 
1958 and was 600 in 1974. Some 450 have more than fifteen years experience underground, 
and, of these, 300 have more than eighteen years, and 100 have more than twenty years. 
Eleven cases of lung cancer have been found, of which two had exposures of about 300 
WLM, three of between 150 and 100 wi.m, and the remaining six of between 10and50wi m. 

83 There are no occupational records available for persons on the Nominal Roll after they 
cease to report in Ontario for the annual examination required to maintain a valid Miner's 
Certificate. 

84 G.R. Yourt. Radiation in Ontario Non-Uranium Minesy np: Mines Accident Prevention 
Association of Ontario, 1 1 Dec. 1961: a survey of five gold mines. Peter Chmara, Suryeys 
of Radioactivity in Non-Uranium Mines. Toronto: Mines Accident Prevention Associa- 
tion of Ontario, 3 Dec. 1975: surveys of sample workplaces throughout the industry. 

85 Department of National Health and Welfare, Environmental Health Directorate, Health 
Protection Branch, Radon Daughters and Dust Measurement Practices in Elliot Lake 
Uranium Mines: A Report to the Division of Mines. Ontario Ministry of Natural 
Resources, Ottawa, March 1974. 

86 Ontario Ministry of Health. Survey of Dust, Radiation and Diesel Exhaust In Uranium 
Mines and Mills at Elliot Lake, Ontario. Toronto, 29 Nov. 1974. 

87 See n.6for United States data on the effects of smoking. A recent survey of uranium 



1 1 7 I Aing cancel and ionizing radiation 

miners at Iilliot I .akc foiincl that some 60 per cent ofthem smoke and 24 per cent are former 
smokers. Smoking was torbidden underground under a code of the Mines Engineering 
Branch as of I Jan. 1973. (see chap. 2, n. 24). 
8S C.Starr, 'Social benelit versus technological risk. Wr/fv/rr, 165, 1969. l232-H:k.H. Mole. 
'Ionizing radiation as a carcinogen: practical questions and academic pursuits," British 
Journal of R(uliolo}^\\4i^, March 1975, 157-69 

89 Lundin et al.. Radon Dan^'hter Exposure. Conclusion M ( 113) states in part that 'there is, 
therefore, no scientific reason to suspect that dose-rate has influenced the respiratory 
cancer risk among miners exposed in the 120 to 360 wlm range.' 

90 Ibid., chap. 4; see Table c.2for a related statistical test conducted as part of the sample 
analysis by the Commission. 

91 us Bureau o\ Mines, Information Report /RS036 { 1975). Control of radon emanations and 
related matters are extensively discussed in Radiation Protection in Uranium and Other 
Mines, Report of the International Commission on Radiological Protection (to be pub- 
lished). 

92 The uranium mines currently are pumping on the order of 160,000 cubic feet per minute of 
ventilation air per ton of ore hoisted per day. This figure is about twice that in use in the 
gold mines (see Tables d.2 and D.3). 

93 R.D. Lord and P.P. Pullen, 'A proposal for monitoring mine ventilation air volumes,' 
Canadian Institute of Mining,' Transactions, 74, 1971 , 229-36. Such systems have been 
designed in Finland. 

94 See, for example, G.K. Greenough, 'The dust helmet- protection for head, eyes and 
lungs,' Underi^round Services 2, London. 1974 and Safety in Mines Research Establish- 
ment, 'Respirable Dust- 3,' Z)/>£^.s7, 1974 (Sheffield) 

95 Safety Guide For Respiratory Protection Against Radon Daughters. American National 
Standard, New York: ansi z288. 1 - 1969. 1969. 

96 GenoSaccamannoetal., 'Developmentof carcinoma of the lung as reflected in exfoliated 
cells.' Cancer, 33, Jan. 1974. 256-69 

97 W. Clark Cooper and Michael D. Utidjian. 'The role of sputum cytology in occupational 
medicine.' Proceedini^s of XVII Congress on Occupational Health, Buenos Aires. Sept. 
1972; W. Clark Cooper, The Role of Sputum Cytology in Occupational Medicine: Sup- 
plementary Report, np: NiosH HSM-099-71-51, March 1975. 

98 Elliot Lake Sputum Cytology Programme; Sputum Cytology Programmes. 1973 and 1974. 
Ministry of Health (Ontario). Exhibit Number 139 before the Commission. No confirmed 
case of malignancy was discovered in the population of some two hundred persons 
screened at Elliot Lake. 

99 The Mines Engineering Branch has examined the cumulative radiation exposures of 464 
persons who were employees in the Elliot Lake Mines in 1974 and had entered these mines 
prior to 1968. the year in which personal exposure records were initiated. Of these 
persons. 159 had exposures in excess of 120 wlm and 61 had exposures in excess of 240 
WLM. The highest exposure of one person was in the range 301-21 wlm. 

100 Early Detection of Health Impairment in Occupational Exposure to Health Hazards, 
Geneva: who. Technical Report Series 571 , 1975; Environmental and Health Monitoring 
in Occupational Health, Geneva: who. Technical Report Series 535, 1973 

101 Mining Act, Part ix. Section 167 

102 Ibid., Subsection 1 (c), and Department of Mines and Northern Affairs. Memorandum 
Re Surface Dust Exposure Occupations, Mines Inspection Branch. 15 Dec. 1967; Mining 
Act. Part IX. Section 167. Subsection 6 

103 It is worthy of note that a miner may retain a Miner's Certificate while displaying any 
respiratory abnormalities other than tuberculosis and. in particular, silicosis. 

104 H .B. Newcombe, A Method of Monitoring Nationally For Possible Delayed Effects of 
Various Occupational Environments , Chalk River: National Research Council, Associate 
Committee on Scientific Criteria for Environmental Quality. 1974 



Accidents and injuries 



INTRODUCTION 

Accidents are unexpected and individually unpredictable events whose 
origins involve a complex set of factors, human and technical. ^ They occur 
when unrecognized adverse conditions, present at the workplace or 
created by the manner in which work is organized, supervised, or carried 
out, lead to undesired consequences in the form of injuries to persons, 
damage to equipment, and loss of production. 

Accidents at mines and plants arise in relation to 1/ the movement of 
persons and materials to and from the workplace, 2/ the nature of the 
workplace, 3/ the materials, tools, machines, and processes associated 
with the workplace, and 4/ work methods and the performing of work. An 
example of each type of accident is as follows: 1/ being struck by an 
ore-haulage train, 2/ a fall of rock from the roof of a development heading, 
3/ the tipping over of a load-haul-dump machine while ore is being moved, 
and 4/ the fall of a miner down an open mill hole. 

Each of these accidents may be associated with one or more anomalous 
conditions which may lead to a variety of consequences. A haulage train 
may move unexpectedly (for the injured workman) when there is unclear 
communication between the operator and persons in the vicinity of the 
train. Operating procedures as well as signalling devices may be faulty. An 
unintended fall of ground may be a massive structural movement of rock 
associated with variations in local geology and the design of the mine 
openings being driven; or it may occur on a smaller scale, for example 
when production commences before adequate standards of protective 
scaling, bolting, and screening have been applied. A load-haul-dump 
machine may be used in an unintended manner or may be defective for 



1 19 Accidents and injuries 

want of regular maintenance in some operational characteristic such as 
steering. A miner may fall down an ore pass through failing to notice the 
hazard when alone or while activity is in progress around him. In each of 
the foregoing accidents the human consequences may range from nil to 
fatality. 

In the hearings before the Commission there were two particular points 
of emphasis in relation to accidents, unsafe conditions and unsafe acts. 
Some workers' representatives emphasized the former, and some man- 
agement representatives the latter. Unsafe conditions may have their 
origin in unclearly defined and communicated management objectives. 
They may arise through defects of plant and mine design, through methods 
of work inadequate in themselves or inadequately supervised, and through 
tools, equipment, and processes inadequately maintained. Unsafe acts of 
any person may originate in want of vigilance, training, skill, physical 
strength, or judgment when all conditions of work are otherwise within 
standards. In many respects the details of Part ix of the Mining Act 
represent the lessons of historical experience in the form of regulatory 
standards intended to eliminate the roots of many unsafe conditions and 
unsafe acts. 

The Commission believes that emphasis on unsafe conditions and un- 
safe acts falsely dichotomizes and greatly oversimplifies the organic cir- 
cumstances out of which accidents arise. Thus, the major prospect for 
reducing the adverse human consequences of accidents may lie in increas- 
ing the commitment and capacity of all persons in the organization to detect 
and to correct anomalies of operation that contribute to accidents. The 
basis for such action lies in effective training and supervision and in 
co-operative understanding of the complementary processes of what will 
be called internal and external 'auditing.' This chapter studies the pattern 
of injuries arising from accidents in Ontario mines, and examines the roles 
of the various parties in detecting and dealing with the functional anomalies 
of operation that cause accidents.^ 

THE CLASSES OF INJURIES ARISING FROM 
ACCIDENTS 

Injuries arising from accidents in the mining industry are categorized as 
first-aid, medical-aid, light-duty, non-fatal compensable, and fatal. In this 
chapter statistical data on non-fatal compensable injuries and on fatal 
injuries will be reported, but it is important to understand their relation to 
events of lesser or related human consequences. First-aid injuries involve 



120 The health and safety of workers in mines 

minor cuts, bruises, and so on that can be dealt with at a first-aid station at 
the mine or plant and entail no loss of time at work. But such accidents may 
be as indicative of anomalies in operations as those involving more serious 
injuries. Medical-aid injuries are those requiring the services of an attend- 
ing physician commonly outside the premises of the mine. However, they 
do not involve loss of time at work other than on the day of the accident. 
(The characteristics of medical-aid injuries involving accidents with chem- 
ical substances are reviewed in chapter 5.) Medical-aid injuries are re- 
ported to the Workmen's Compensation Board for payment of medical 
fees. The Mines Accident Prevention Association maintains no statistical 
record of these events. 

Light-duty and non-fatal compensable injuries possess in common the 
fact that the person injured does not return to his or her regular place of 
work for at least one day following the date of the accident. Under current 
procedures of record-keeping in the industry an injury becomes non-fatal 
compensable when the eligible worker receives from the Workmen's Com- 
pensation Board the whole or part of his current wages for at least one day 
following the date of the related accident. Statistics on this class of accident 
and on fatal accidents are maintained by the Mines Accident Prevention 
Association from records of the Workmen's Compensation Board. A sim- 
ple compensable injury causes the workman to remain away from work 
until he is able to return to his regular job. Under these circumstances he 
receives from the Workmen's Compensation Board 75 per cent of his 
regular wage rate provided it does not exceed a rate of $ 15,000 per annum. 

A light-duty injury is so defined when a company assigns an injured 
workman, with the concurrence of an attending physician, to other work 
for some period before he returns to his regular job. If the rate of pay for the 
newly assigned work is identical with the person's regular rate of pay no 
compensation from the Workmen's Compensation Board is involved and 
no record of the injury enters the statistics maintained by the Mines 
Accident Prevention Association through information supplied to the 
Board. If the company pays its regular rate for the type of work undertaken 
by a person on light-duty assignment, and this rate is less than the person's 
regular wages, the Workmen's Compensation Board pays 75 per cent of the 
difference, the injury being classed as compensable and entering the statis- 
tics of the Mines Accident Prevention Association.^ 

During the hearings of the Commission two disturbing facets of light- 
duty work assignments became apparent: the possibility of non-uniform 
standards in the recording of injury statistics within the industry"* and the 



121 Accidents iind injuries 

objection of some union representatives to the piinciple ot" rehabilitation 
that underhes such assignments.^ lo ensure consistency in statistical 
records and to ensure that the workman's basis for eligibility for subse- 
quent compensation is protected by the establishment of an appiopriate 
record, the Commission recommends: 

That the Workincii\s Conipensatioii Board require and niiike provision for 
the inelusion in non-fatal injury statisties of all non-fatal injuries in whieli 
the injured person fails to return to his or her regular job on the day 
following' the date of the aceident i^'ivin^ rise to the injury. 

The principle of rehabilitation, that is, of assisting an injured worker to 
return as soon as possible to regular work, has been basic to the 
Workmen's Compensation Board and is surely a desirable objective. It is 
disturbing therefore to find union representatives alleging that light-duty 
may be used by companies to conceal injuries that would otherwise be 
entered as compensable and implying that a person's recovery might by 
engaging in such work be delayed beyond what it would be if the person 
simply remained away from work. This is one of several areas of tension 
between some unions and management that can be removed by openness. 
It has already been recommended that the issue of consistency of records 
be clarified; the Commission further recommends, as one area for co- 
operation between workers and management on Health and Safety Com- 
mittees: 

That management inform the Joint Health and Safety Committee about its 
polieies on rehabilitative work assignment and in the eontext of indepen- 
dent medieal eonsultation seek the adviee of the Committee in giving wise 
effeet to its polieies. 

Since both parties desire the good of the individual worker, confrontation 
can and must be set aside with respect both to accidents and to health- 
impairing environmental exposures. The best interests of a workman may 
be served by rehabilitative work adjustment on a temporary basis. 

The statistical record of fatal injuries and of non-fatal compensable 
injuries in the industry will now be examined and placed in perspective with 
experience in other jurisdictions. A summary of Ontario records for 1974 
has been given in Tables 3 and 4. 



122 The health and safety of we^rkers in mines 



TABLE 27 

Fatal injuries in metal and non-metal mining companies in Ontario 1965-75 













Fatalities 


Fatalities 




Man-hours 








per 


10,000 


per million 


Calendar 


worked" 


Man-years 




man 


-years 


man-hours 


year 


(millions) 


at risk" 


(N) 


Fatalities'^ (n) 


at risk (n) 


worked (n) 


1965 


80.2 


40,100 




24 


6.0 




0.30 


1966 


75.0 


37,500 




29 


7.7 




0.39 


1967 


82.5 


41,250 




21 


5.1 




0.25 


1968 


85.0 


42,500 




30 


7.1 




0.35 


1969 


66.9 


33,450 




22 


6.6 




0.33 


1970 


86.5 


43,250 




24 


5.5 




0.28 


1971 


82.6 


41,300 




22 


5.3 




0.27 


1972 


71.4 


35,700 




14 


3.9 




0.20 


1973 


66.8 


33,400 




11 


3.3 




0.16 


1974 


69.6 


34,800 




16 


4.6 




0.23 


Tenryear 
















totals 


766.5 


383,250 




213 


5.6 




0.28 


1975 


69.5 


34,750 




9 


2.6 




0.13 



note: The data include the types of operations listed in Table 1 

a From monthly work sheets of Mines Accident Prevention Association of Ontario 
(excluding prospectors) 

b The number of man-years at risk is estimated by dividing millions of man-hours by 
2000 

c From records of Mines Engineering Branch, for fatalities occurring in metal and non- 
metal operations, as defined in Table 1 



OVER-ALL INJURY EXPERIENCE IN ONTARIO MINES 



Fatalities 

The over-all fatality record of the metal and non-metal sector of the 
industry as studied by the Commission is tabulated in Table 27 for the 
decade 1965-74 and plotted in Figure 10. The decade has seen a significant 
decrease in the frequency of fatalities, by 45 per cent (on the regression 
line), which is not wholly accounted for by the changes during this period in 
the distribution of man-hours worked between underground, open pit, 
reduction plants, and shops and surface workplaces. As shown in Tables 27 
and 28, there has been a significant reduction, from 0.40 to 0.30, in the 
proportion of the work force employed underground, where the fatality 
risk of mine workers will be shown to be significantly higher than the risk 
for the total population. Further, as measured in tons of ore hoisted per 
man-hour of labour based on all employees, productivity in the metal mines 



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124 The health and safety of workers in mines 



TABLE 28 














Comparative 


fata 


ity rates for 


underground mine 


workers in 






Ontario and Sweden 














Man-hours 


worked 


Fatalities 


pe 








(millions) 




million man- 


hours (n) 


Calendar 














year 




Ontario 


Sweden 


Ontario 




Sweden 


1965 




32.5 


10.9 


0.43 




0.55 


1966 




29.6 


10.4 


0.68 




1.15 


1967 




30.5 


9.8 


0.39 




0.51 


1968 




30.2 


9.8 


0.60 




1.12 


1969 




23.1 


9.6 


0.48 




0.94 


1970 




28.6 


8.9 


0.60 




0.67 


1971 




26.7 


9.1 


0.49 




1.09 


1972 




22.4 


8.8 


0.44 




0.56 


1973 




22.0 


8.9 


0.32 




0.55 


1974 




21.0 


9.0 


0.70 




0.33 



source: Ontario: Mines Accident Prevention Association of Ontario, Annual 
Reports J 966-1975; Sweden: Svenska Gruvforeningen, Yrkcsskadestatistik vid 
Svenska Malmgnaor Mr 1974, Uppsala, 1975, Figure 7 and other related data 



has increased over the decade 1965-74 by an average of about 35 per cent. 
These changes in employment and productivity reflect in part advances in 
mechanization and in part changes in the level of operations, for example a 
notable decline in the gold group. 

To place the Ontario experience in perspective, comparisons have been 
sought with other Canadian and foreign mineral industries. To compare 
fatality rates between mining industries is reasonable when there are com- 
parable distributions of man-hours worked by types of workplace in mines 
similarly distributed between metal and non-metal types. Tables 1 and 2 
provide representative structural data for Ontario mines. In Figure 1 1 the 
fatality rates for the metal and non-metal mines of British Columbia, 
Manitoba, Ontario, and Quebec are plotted for a ten-year period ending in 
1974. These graphs show that experience in four major mining provinces 
has been comparable in recent years, with Ontario experience comparing 
favourably. The numberof man-hours worked in British Columbia mines is 
about 25 per cent of that in Ontario, in Manitoba about 20 per cent, and in 
Quebec about 60 per cent. 

Table 28 provides a comparison between Swedish fatality experience 
and Ontario fatality experience in the underground category, which reflects 



125 Accidents and injuries 



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FIGURE 1 1 Comparative fatality frequencies of selected provincial metal and 
non-metal mining companies (Source: British Columbia, Ministry of Mines and 
Petroleum Resources; Quebec, Department of Natural Resources; Ontario. Table 
28; Mines Accident Prevention Association of Manitoba, Annual Reports, Win- 
nipeg, 1968, 1970, 1974). 



126 The health and safety of workers in mines 



TABLE 29 
















Non-fatal compensable inj 


uries in metal and 


non-metal 


min 


ng companies in 




Ontario 1970 


-5 
























Injuries 


Injuries 




Man-hours 








per 


100 


per million 


Calendar 


worked" 


Man-years 






man 


-years 


man-hours 


year 


(millions) 


at risk" (n) 


Injuries'" 


(N) 


at n 


sk (n) 


worked (n) 


1970 


86.5 


43,250 


3,575 




8.2 




41.3 


1971 


82.6 


41,300 


3,318 




8.0 




40.1 


1972 


71.4 


35,750 


2,909 




8.1 




40.7 


1973 


66.8 


33,400 


3,220 




9.6 




48.2 


1974 


69.6 


34,800 


3,747 




10.8 




53.7 


Five-year 
















totals 


376.9 


188,500 


16,789 




8.9 




44.5 


1975 


69.5 


34,750 


4,246 




12.2 




61.0 



note: The data include the types of operations listed in Table 1. 

a From monthly work sheets of Mines Accident Prevention Association of Ontario (ex- 
cluding prospectors) 

b The number of persons at risk are estimated by dividing the man-hours worked by 2000 

c From annual reports of Mines Accident Prevention Association of Ontario (excluding 
prospectors) 



the highest rates. ^ Over the decade, Ontario compares favourably to Swe- 
den, although the many small mines in the Swedish industry give it a 
different structure. 

The foregoing data, as well as reviews of us and other sources where the 
basis for comparison is less clear, ^ led the Commission to conclude that 
fatality experience in the metal and non-metal sectors of the Ontario mining 
industry compares favourably with that in other jurisdictions, though not 
notably so. Ontario mining fatalities will be compared with those in other 
sectors of Ontario industry subsequently when the distribution of fatalities 
among the basic classes of workplace is examined. 



Non-fatal compensable injuries 

Non-fatal compensable injuries cover an immense range of human conse- 
quences, from a lacerated finger to a serious burn to broken limbs. Degrees 
of disability range from temporary partial to permanent partial disability. 
Whereas the over-all fatality experience in Ontario mines has been improv- 
ing, the frequency of non-fatal injuries has been rising, as indicated in Table 



127 Accidents and injuries 

72 -I 



64 



56 



45 - 



40 -' 



32 - 



24 



16 - 



1970 



1971 



1972 



1973 



1974 



1975 



Calendar year 

FIGURE 12 Non-fatal compensable injuries at metal and non-metal mines 1970-5 
(Source: Table 29. The data were obtained from mapao monthly work sheets.) 



29.^ These data, plotted in Figure 12, show that a significant rise in the 
number of injuries per million man-hours occurred in the years 1973 and 
1974 and has continued in 1975. Subsequent analysis of industry experi- 
ence by metal sector for the five-year period 1970-4 will show that the 
increase has come largely in nickel mining and is in contrast with favoura- 
ble fatality experience in that sector. 

The difficulties of making fair comparisons of fatalities between differ- 
ent jurisdictions have been noted. The problem of comparing experience 
with non-fatal compensable injuries is much greater because of the 
ill-defined nature of a compensable injury in different social situations 
under different legislation. The Commission is not confident enough of the 
equivalence of data to offer quantitative statistical comparisons. However, 
it has examined non-fatal injury statistics for the underground employees 
of us and Swedish metal and non-metal mines. ^ These data show that the 



128 The health and safety of workers in mines 

Ontario experience has been superior to, and is now comparable with, that 
in the usa and Sweden. 

Comparative analysis underscores the prevalence of generic risks of 
fatal and non-fatal injuries in metal and non-metal mines. If the record of 
injuries is to be improved, it is important to understand how they are 
distributed on the macro scale of metal group and class of workplace and on 
the micro human scale of factors such as age, experience, shift, and 
working alone. These structural reviews will be undertaken first on the 
macro scale and then on the micro scale, both for fatalities and for non-fatal 
compensable injuries. 

FATALITIES AND THE MACRO STRUCTURE OF THE 
I N D U S 1 R Y 

Using data provided to the Commission by the companies operating 
throughout 1974, the detailed fatality experience of the different metal 
groups in the industry for the five-year period 1970-4 has been examined. 
The essential data are presented in Table 30. The relative scale of each 
metal group is suggested by the 1974 employment figures for total opera- 
tions, underground, open pit, reduction plants, and shops and surface, as 
given in columns 1, 3, 5, 7, and 9. Within a given type of operation there is 
significant variation in fatality frequencies between different metal groups, 
as shown in columns 2, 4, 6, 8, and 10. For the industry as a whole the risks 
of fatality in the various operations vary by a factor of about ten, as shown 
in Table 3 1 . Reduction plants and shops and surface units have much lower 
risks than underground operations, as would be expected. Open-pit opera- 
tions are distinctly less hazardous than underground operations. Within the 
underground segment of operations, as in others, there is a remarkable 
range of variation in fatality experience among the metal groups. A test for 
correlation with the scale of operations in the underground segment, shown 
in Table 32 reveals that fatality frequency is distinctly higher in small 
operations than in large ones. This fact deserves careful examination both 
by the companies conducting the smaller operations and by the Mines 
Inspection Authority. The Commission therefore recommends: 

That the Mines Inspection Branch base its patterns of audits in part on 
studies of the relative risks involved in different segments of mining opera- 
tions and on the related man-years at risk. 

While the industry, through the work of the Mines Accident Prevention 



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130 The health and safety of workers in mines 



TABLE 31 

Average fatality frequency per million man-hours 
for all mining companies 

Segment of 

operation Fatalities per million man-hours 

Reduction plants 0.045' 

Shops and surface 0.066' 

Open pit 0.160^ All operations 0.217 

Underground 0.446/ average 

source: Table 30. Frequencies are for the five-year period 1970-4 



TABLE 32 

Fatality frequencies by scale of 
operations underground 

Scale of operation 

indicated by number Fatalities per 

of employees million man-hours 

0-200 0.944 

201-1000 0.411 : 

1000+ 0.312 I 

Over-all frequency 0.446 



source: Table d.5. Frequencies are for the five-year 
period 1970-4 



Association, is aware of the variability of fatality experience, the Commis- 
sion has found no evidence that research is undertaken to probe the origins 
of the observed patterns of risk. The Mines Inspection Branch has a 
responsibility to the workers, the industry, and the public to do so and to 
report on its findings.'" It is therefore recommended: 

That the Occupational Health and Safety Branch publish biennially a 
critical review of factors that influence risks of accident and injury at 
workplaces in the mines and mineral plants. 

Sampling methods as used in this report are one way of exploring particular 
facets of concern. 

Interest was expressed during the Commission hearings about the risks 
of fatality in the mines relative to those in other sectors of industry. Table 



131 Accidents and injuries 



TABLE 33 

Comparative fatality frequencies for sectors of 
Ontario industry 

Fatalities per 
Sector million man-hours" 

Manufacturing'' 0.033 

Mining'" - reduction plant operations 0.045 

Mining - shops and surface operations 0.066 

Construction" 0.148 

Mining - open pit operations 0. 160 

Mining - all operations 0.217 

Mining - underground operations 0.446 

Logging, sawmilling, and veneer milling^ 0.786 

a Average for five years 1970-4 

b Provided by the Industrial Accident Prevention Association. 
Companies represented include a wide spectrum of activities from 
retailing to the production and fabrication of textiles, steel, 
chemicals, automobiles, food, etc. 
c Based on data from companies operating in 1974 
d Provided by the Construction Safety Association of Ontario 
e Based on data provided by the Forest Products Accident Preven- 
tion Association 



33 provides comparative data for mines, logging, construction, and man- 
ufacturing, which show that risks in different segments of mining opera- 
tions are interspersed with those in manufacturing, construction, and log- 
ging. Within mining, underground operations stand out as exceptionally 
risky, and it is here that the work of accident prevention continues to 
deserve special attention. The following analysis of the human impact of 
fatalities in terms of factors such as age, experience, shift, and working 
alone will underscore this point. 

THE HUMAN IMPACT OF FATAL INJURIES 

The following analysis is based on a study of 213 fatalities occurring in the 
decade 1965-74. The fatality reports of the Mines Engineering Branch were 
used as the primary source of data. The Commission obtained from iNCO 
Ltd, which represents in its operations approximately half of the employ- 
ment in the industry, estimates of the distribution of workers by years of 
experience and by working shift. The estimated distribution of workers by 
age was obtained from the Canadian Census (1971).^' 



Proportion of 


Observed proportion 


employees" 


of fatalities" 


0.35-0.65 




0.45-0.15 


0.05 


0.10 


lis «•- 


0.05 


Nil 


0.05 


Nil 



132 The health and safety of workers in mines 

TABLE 34 

Distribution of fatalities by category of personnel 



Personnel 

Unskilled/semi-skilled ( 
Group leader ) 

Skilled trades 
Supervision / 
Management ) 
Engineering/technical 
Clerical 

a Table d.6 

b Total number of fatalities: 213 for the decade 1965-74 



The relation of fatalities to age, experience, working shift, and working 
alone will be examined by comparing observed fatalities to those that 
would be expected if the occurrence of fatalities were independent of each 
of these factors. It will be shown that an hypothesis of independence is 
sustained for age, but not for experience, time of working shift, or working 
alone. It will be inferred that the training of workers and the role of first-line 
supervision are important issues for the industry. ^^ 

Table 34 shows how fatalities are distributed by category of personnel 
and reveals that 0.88 of all fatalities occur among unskilled persons, semi- 
skilled persons, and group leaders, while the proportion of such persons in 
the work force ranges from 0.35 to 0.65. First-line supervisors experience 
risks comparable to those expected, while the skilled trades and other 
categories experience much lower risks. These data confirm that the major 
source of fatalities is in work undertaken by unskilled and semi-skilled 
persons for whom training and supervision are crucial issues. 

Table 35 provides statistical evidence that fatalities are not occurring 
with significantly higher frequency at one age than at another. This result 
has been interpreted as arising from the fact that younger persons assign a 
high subjective risk to work situations in mines and that this subjectively 
assigned risk declines with age as experience grows. '^ In contrast with this 
result, the data in Table 36 show that the observed number of fatalities for 
persons with less than five years of experience at the mine of last employ- 
ment is substantially greater than the number expected on the basis that 
experience is not a factor. Thus 0.62 of all fatalities occurred among 
persons with less than five years of experience, while only 0.26 of all 



133 Accidents and injuries 



TABLE 35 








Age as a 


factor 


in fatalities 










Observed 


Expected 








fatalities" 


fatalities'" 


DifTerence'^ 


Age 




(N) 


(N) 


(Observed-Expected) 


<20 




5 


8.3 


-3.3 


20-24 




40 


38.1 


1.9 


25-29 




24 


28.1 


-4.1 


30-34 




23 


24.9 


-1.9 


35-39 




27 


23.6 


3.4 


40-44 




25 


23.0 


2.0 


45-49 




29 


20.9 


8.1 


50-54 




11 


18.7 


-7.7 


55-59 




18 


15.5 


2.5 


>60 




11 


11.7 


-0.7 


Total 




213 


213 


0.00 



a For the decade 1965-75 

b The expected number is based on the age distribution given in Table 
D.6 on the hypothesis that fatalities are independent of age 

c For this table, x^(9) = 9.6, which is consistent with the null hypothe- 
sis (0.25 < P < 0.50). 

source: Commission study 



fatalities would be expected in this group if experience were not a factor. 
There is clearly increased risk of fatal injury for persons with less than five 
years' experience at the company of last employment. The data of Table 37 
show that this risk is further elevated for unskilled and semi-skilled per- 
sons. Whereas 0.67 of all fatalities among persons classified as unskilled 
and semi-skilled occur among those with less than five years' experience in 
the company of last employment, only 0.38 of all fatalities among other 
categories of personnel occur among persons with less than five years' 
experience. 

The combination of data in Tables 36 and 37 gives clear indication that 
unskilled and semi-skilled persons with less than five years' experience at 
the company of last employment are at much higher risk of suffering a fatal 
injury than are other workers. These risks are generic to mining, and 
Ontario experience is not inferior to that in comparable jurisdictions. 
Nevertheless, this evidence raises the question whether or not training for, 
and supervision of, underground work in the mines is adequate in the light 
of what society is now prepared to accept as risks of work. The following 



134 The health and safety of workers in mines 



TABLE 36 

Fatalities related to years of experience 
at the company of last employment 


Years of 
experience 
(v\here known) 




Observed fatalities" 


Expected fatalities" 


Difference" 
(Observed- 
Expected) 

(N) 


Number 


Proportion 


Number 


Proportion 


<1 
1-5 
>5 

Total 




54 
65 
73 

192 


0.28 
0.34 
0.38 

1.00 


22.8 

27.1 

142.1 

192.0 


0.12 
0.14 
0.74 

1.00 


31.2 

37.9 

-69.1 

00.0 



a For the five-year period 1970-4 

b Based on the reference population defined in Table d.6 

c The null hypothesis that fatalities are not related to experience was tested. For this 

table, x^,2) = 1 29.3, which is significant at the 0.005 level, thus providing strong evidence 

against the null hypothesis. 
source: Commission study 



TABLE 37 

Fatalities by category of personnel 
and years of experience 1965-74 






Observed 
experience 


proportion with indicated years of 
with company of last employment 




Personnel 


<1 


1-5 


<5 


>5 


All 


Unskilled/semi-skilled 
Other 




0.32 
0.12 


0.35 
0.26 


0.67 
0.38 


0.33 
0.62 


1.0 
1.0 



source: Commission study 



data support the view that there are identifiable circumstances on which to 
work to reduce fatality frequencies. 

The distribution of fatalities with respect to shift worked, shown in 
Table 38, provides statistically significant evidence that the risk is greater 
on the night shift from 1 1:00 pm to 7:00 am. A specific examination of the 
distribution of fatalities by age and shift has shown that 0.30 of all fatalities 
among persons in the age group 20 to 24 years occur on the eleven-to-seven 
shift, whereas the expected proportion of fatalities in this age group on this 
shift isO. 13, under the assumption that the distribution of ages on the three 



135 Accidents and injuiics 



TABLE 38 

Fatalities by shift worked 1965-74 



Hours of 
shift 


Observed 
fatalities (n) 


Expected 
fatalities" (n) 


Difference'' 
(Observed-Expected) 


7-3 
3-11 
11-7 

Total 


118 
57 
38 

213 




125.46 
60.49 
27.05 

213.00 


-7.46 

-3.49 

10.95 

00.00 



a Based on reference population data given in Table d.6, the null hypothesis that 

fatalities are independent of shift was tested 
b For this table, x^d) = 5.08, which is significant at the 0.10 level, thus providing 

some evidence against the null hypothesis 
source: Commission study 



TABLE 39 

Fatalities by shift 1965-74: proportion with less 
than five years of experience with company of 
last employment 

Shift Proportion Expected 

7-3 0.60 0.26 

3-11 0.54 0.26 

11-7 0.81 0.26 

note: Expected based on the reference population 
data given in Table d.6 and assuming the distribu- 
tion of experience among workers on all shifts is 
the same 



shifts follows that in Table d.6. Thus, younger persons working on the 
night shift are indicated to be at substantially excess risk. This evidence is 
not inconsistent with the earlier observation that fatalities as a whole are 
distributed over all age groups in proportion to the population in each age 
group. The above risk may be combined with that related to experience, 
shown in Table 39, where it is shown that the proportion of all fatalities 
occurring on the night shift among persons with less than five years' 
experience at the company of last employment is 0.81, whereas the ex- 
pected proportion is 0.26. ^'^ Again, these data raise the questions of training 
and supervision, which are further emphasized by the following observa- 
tions on fatalities while working alone. 

During the hearings of the Commission the representatives of labour 



136 The health and safety of workers in mines 



TABLE 40 

Fatalities by shift occurring among persons working alone 1965-74 





of 


Work 


ng 


alone 


Not alone 






Hours 
Shift 


Number 


Proportion 
by shift 


Number 


Proportion 
by shift 


Total 


7-3 
3-11 
11-7 

All shifts 


27 
10 
11 

48 




0.23 
0.18 
0.29 

0.23 


91 

47 
27 

165 


0.77 
0.82 
0.71 

0.77 


118 

57 
38 

213 



TABLE 41 

Fatalities by shift among persons working alone 1965-74 



Hours of 
shift 



Proportion 

working 

alone 



Proportion 
not working 
alone 



Expected 
proportions 



7-3 


0.56 


0.55 


0.59 


3-11 


0.21 


0.28 


0.28 


11-7 


0.23 


0.17 


0.13 


All shifts 


1.00 


1.00 


1.00 



NOTE : The expected proportion is taken to be the proportion of workers 
on a given shift as listed in Table d.6, the assumption being that this 
distribution applies to the subpopulations working alone and not 
working alone. 



unions time and again expressed concern that working alone underground 
in mines entails exceptional risks that should be reduced by improved 
supervision. Table 40 shows the number and proportion of the working- 
alone fatalities occurring by shift; the proportion that working-alone 
fatalities are of all fatalities is 0.23. Table 41 shows that a significantly larger 
proportion than expected of working-alone fatalities occur on the night 
shift, but not on the other shifts. This would suggest that the supervision of 
work on the night shift may be at issue. The data of Tables 42 and 43 
indicate that for both those working alone and those not working alone 
fatalities occur significantly more often than expected for persons having 
less than one year's and less than five years' experience at the company of 
last employment."'' 



137 Accidents and injuries 



TABLE 42 

Fatalities by experience and working alone 1965-74 



Fatalities by years of experience (n) 



Conditions of work 


Less than i 


1 year 


1 to 5 


years 


More 


than 


5 


years 


Total 


Alone 


16 




14 




17 








47 


Not alone 


35 




51 




56 








145 


Total 


54 




65 




73 








192 


Total as proportion 


0.28 




0.34 




0.38 








1.00 



Less than 1 


0.34 


0.26 


1 to 5 


0.30 


0.35 


More than 5 


0.36 


0.38 



NOTE : Years of experience with mine of last employment, where known 



TABLE 43 

Fatalities: proportion of total by experience and working alone 1965-74 

Years experience 

with mine of Expected 

last employment Working alone Not working alone proportion 

0.12 
0.14 
0.74 

Total 1.00 1.00 1.00 

note: See note to Table 41 



In the light of the foregoing analysis, the Commission concludes that the 
basis for training and supervision of the persons classified as unskilled and 
semi-skilled and in particular those employed in underground work merits 
review by the industry as a whole. The current basis for, and status of, 
training in the mines will be discussed and recommendations made after 
completing this review of fatalities and non-fatal compensable injuries. 

It has been noted that injuries arise as particular consequences of acci- 
dents, the roots of which in turn depend on training, supervision, work 
standards, personal behaviour, and many other factors. The particular 
kinds of accidents associated with fatalities are intrinsic to mining and 
appear to be relatively invariant between jurisdictions. Table 44 provides 
some insight into the generic situations in which fatalities occur in Ontario 
mining operations in the metal and non-metal mines. 



138 The health and safety of workers in mines 

TABLE 44 

Fatalities by kind of accident 1965-74 







Proportion ( 


Df fatalities associated 






with a given 


1 kind of accident 






Less than 


Less than 






Proportion of 


5 years 


1 year 


Working 


Type of accident 


all fatalities" 


experience'' 


experience'' 


alone** 


Fall of ground 


0.249 


0.55 


0.24 


0.17 


Fall of person 


0.216 


0.64 


0.39 


0.33 


Haulage 


0.202 


0.74 


0.37 


0.28 


Fall of object 


0.131 


0.73 


0.23 


0.07 


Run of muck 


0.066 


0.50 


0.14 


0.07 


Explosives 


0.052 


0.64 


0.27 


0.18 


Drowning 


0.023 








Burns 


0.023 








Suffocation 


0.023 








Electrocution 


0.010 








Fatigue 


0.005 








Total 


1.000 









a The total number is 213 for the decade 1965-74 

b Proportion occurring among persons having less than five years of experience at 
the company of last employment. The expected proportion is 0.26 on the assump- 
tion that the subpopulation of workers with less than five years of experience 
encounter each accident situation with the same frequency. See Table d.6 

c Proportion occurring among persons having less than 1 year of experience at the 
company of last employment. The expected proportion is 0.12 

d The proportion of workers working alone is not known. 



NON-FATAL COMPENSABLE INJURIES AND THE 
MACRO STRUCTURE OF THE INDUSTRY 



The frequencies of occurrence of non-fatal compensable injuries in a given 
segment of operations vary among the metal groups by a factor of about 
five, as shown in Table 45 in columns 2, 4, 6, 8, and 10. This degree of 
variability within a common type of operation indicates that a substantial 
reduction in frequency of injuries could be achieved if the record of the best 
group was emulated by others. For the industry as a whole, the frequencies 
vary between types of operations by a factor of about four, as summarized 
in Table 46. This degree of variation is lower than that for fatalities shown 
in Table 31. Although the highest risk for all types of injuries is in under- 



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140 The health and safety of workers in mines 



TABLE 46 

Non-fatal compensable injuries: average frequency for all 
mining companies 1970-4 

Segment of 

operations Frequency per million man-hours 



Average 

all operations 



note: Compare with Table 31 for fatality frequencies 
source: Table 45 



ground operations, the ordering of risks for fatalities and non-fatal injuries 
differs in the other segments of mining operations. 

A distinctive fact emerging from Table 45, in which metal groups are 
ranked by order of increasing over-all fatality frequency, is that the rank 
order for over-all non-fatal compensable frequency is quite different. It 
might be expected that a metal group's experience with non-fatal compen- 
sable injuries would be correlated to its experience with fatal injuries, but 
the five-year sample of data studied by the Commission reveals no 
significant direct correlation. 

In Figure 12 it was noted that the frequency of non-fatal compensable 
injuries has risen significantly since 1972. Figure 13 shows that this increase 
has been occurring primarily in underground operations and reduction 
plants. A further division of reduction plants into concentrators and other 
plants including smelters has shown that the increase has been occurring 
primarily in smelters and related reduction plants rather than in concen- 
trators. Further, the recent increase in frequency is concentrated in large 
operations located in the nickel group. Analysis conducted over the indus- 
try as a whole with the intent of testing the null hypothesis that non-fatal 
injury frequency is unrelated to scale of operations as measured by the 
numbers of employees led to no significant evidence to the contrary. 
However, there are distinctly anomalous individual operations, which may 
be identified in Table d.7. 

Part of the total increase in the frequency of non-fatal compensable 
injuries is understood to result from a decision by certain companies to 
cease offering light-duty employment to workers who are temporarily 
partially disabled, so that the associated injuries formerly classed as light- 
duty now are classified as compensable. There is also some likelihood that 



141 Accidents and injuries 

96 ^ 

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24 - 



16 - 



1970 



Underground 




Reduction Plants^ 



en Pit 



Shops & Surface 



1971 



1972 



Calendar year 



1973 



1974 



FIGURE 13 Non-fatal injury experience 1970-4, by segment of operations (Note: 
Figure 12 provides data for all operations together; Reduction plants include 
concentrators, smelters, and other metallurgical plants. Source: Company data 
provided to the Commission). 



the circumstances of injury under which a worker, in consultation with an 
attending physician, elects to remain absent for one or more days following 
the date of an accident are becoming more diverse. Nevertheless there is 
ground for concern about the rising rate of non-fatal compensable injuries, 
especially in the light of the following analysis of their relation to age, 
experience and shift. 



142 The health and safety of workers in mines 



TABLE 47 










Non-fatal compensable injuries 


by age 






Age 


Observed 


Expected 


Difference" 


(where known) 


injuries" 


(N) 


injuries'* (n) 


(Observed-Expected) 


<20 


119 




53.94 


65.06 


20-4 


329 




247 . 56 


86.44 


25-9 


231 




182.56 


48.44 


30-4 


195 




161.81 


33.19 


35-9 


114 




153.51 


-39.51 


40-4 


134 




149.36 


-15.36 


45-9 


118 




135.53 


-17.53 


50-4 


65 




121.70 


-56.70 


55-9 


52 




100.96 


-48.96 


60 + 


26 




76.06 


-50.06 


Total 


1,383 




1,383.00 


00.00 



a From records of Workmen's Compensation Board October 1975 through January 

1976 for Class 5 
b Based on reference population data given in Table d.6 
c These data were tested for the null hypothesis that age has no effect on the frequency 

of accidents. For these data, x^(9) = 226.06, which is significant at the 0.005 level 

thus providing strong evidence against the null hypothesis 
source: Commission study 



THE HUMAN IMPACT OF NON-FATAL COMPENSABLE 
INJURIES 

To obtain some insight into the effects of age, experience, and shift on the 
incidence of non-fatal compensable injuries the Commission analysed in 
detail the records of the Workmen's Compensation Board for a sample of 
1388 non-fatal compensable injuries occurring in Class 5 for the period 
October 1975 through January 1976forwhich the records were complete or 
nearly complete. Injuries to prospectors were excluded. All of the follow- 
ing results are based on this sample and on the expected distributions of 
persons by age, shift, and experience given in Table d.6. 

Whereas there is evidence, given in Table 35, that fatal injuries are not 
age-dependent (although they are strongly experience-dependent), the 
evidence of Table 47 is that non-fatal compensable injuries are age- 
dependent. There is an excess of injuries among persons under thirty years 
of age, and the relative excess is greatest in the youngest age groups. 

With respect to the relation of non-fatal injuries to working experience at 



143 Accidents and injuries 



TABLE 48 

Non-fatal compensable injuries 
company of last employment 


by experience at 


the 






Years of 
experience 
(where known) 


Observed 


injuries" 


Expected 


injuries'" 


Difference'' 
(Observed- 
Expected) 

(N) 


Number 


Proportion 


Number 


Proportion 


less than 1 
1 to 5 
more than 5 

Total 


306 
398 
650 

1,354 


0.23 
0.29 
0.48 

1.00 


161.13 

190.91 

1,001.96 

1,354.00 


0.12 
0.14 
0.74 

1.00 


144.87 

207 . 09 

-351.96 

000.00 



a Records of Workmen's Compensation Board, October 1975 through January 1976, for 

Class 5, with prospectors excluded 
b Based on reference population defined in Table D.6 
c These data were tested for the null hypothesis that experience has no effect on frequency 

of accidents. For these data, x^a) = 478.53, which is significant at the 0.005 level, thus 

providing strong evidence against the null hypothesis. 
source: Commission study 



TABLE 49 

Non-fatal compensable injuries by age 

and experience at company of last employment 





Proportion 


of all fatalities 








Age 


<1 


1-5 


<5 


>5 


All experience 


<30 
>30 


0.36 
0.10 


0.44 
0.15 


0.80 
0.25 


0.20 
0.75 


1.00 
1.00 



source: Commission study 



the company of last employment, Table 48 shows that there is a significant 
excess of observed over expected accidents for persons with less than five 
years' experience. It will be noted that for persons with less than one year's 
and less than five years' experience, the observed proportion of injuries 
exceeds the expected proportion by a factor of two. A similar excess of 
fatal injuries has been noted in Table 36. 

The interrelation of non-fatal injuries with both age and experience is 
shown in Table 49. Whereas 80 per cent of all injuries to persons less than 
thirty years of age occur among persons with less than five years' experi- 
ence, only 25 per cent of all injuries to persons over thirty occur in this 
experience group. Such data add strong evidence that non-fatal injuries, in 



144 The health and safety of workers in mines 



TABLE 50 

Non-fatal compensable 


injuries by shift 










Observed injuries'' 


Expected 


injuries'' 


Difference'' 
(Observed- 
Expected) 

(N) 


Shift 


Number 


Proportion 


Number 


Proportion 


7-3 
3-11 
11-7 

Total 


725 
509 
154 

1,388 


0.52 
0.37 
0.11 

1.00 


817.53 
394.19 
176.28 

1,388.00 


0.59 
0.28 
0.13 

1.00 


-92.53 

114.81 

-22.28 

00.00 



a Sample of Workmen's Compensation Board records for October 1975 through 
January 1976 

h Based on reference population defined in Table D.6 

c The data were tested for the null hypothesis that non-fatal injuries are indepen- 
dent of shift. For this table, x^(2) = 46.73, and is significant at the 0.005 level, 
giving strong evidence against the null hypothesis. 

source: Commission study 



addition to fatal ones, are incident to an exceptional degree upon younger, 
inexperienced persons. 

As a final test the Commission examined in a manner similar to that of 
the foregoing tables the relation of non-fatal compensable injuries to the 
shift of work. On each shift the proportion of the total injuries occurring in 
persons having less than five years' experience at the company of last 
employment is about twice that expected under the assumption that in- 
juries are independent of experience. Further, there is statistical evi- 
dence that the total number of injuries occurring on different shifts is not 
independent of the shift. The relevant data are given in Table 50, where an 
excess of injuries is apparent on the three-to-eleven o'clock shift. A sepa- 
rate test of the proportion of the total number of non-fatal injuries to 
persons under thirty years occurring on each of the shifts revealed that a 
larger than expected proportion occurred on the three-to-eleven shift (0.42 
observed versus 0.28 expected). It will be recalled from Table 36 that fatal 
injuries are in excess on the eleven-to-seven shift. This combination of 
evidence that injuries may be in excess on other than the main working shift 
must add to concern for training and supervision. 

The generic accident situations in which non-fatal injuries occur are 
given by proportion in Table d.8 and the characteristic seats of injury on 
the body are given in the same table. The consequences of non-fatal 
injuries vary in a wide spectrum from temporary partial disability of minor 



145 Accidents and injuries 

duration to permanent partial disability not only of suffering but also of 
lessened capacity to earn wages. Fatalities are in a tragic sense self- 
classifying. The important issue is that all of the parties that need to know 
be advised of injuries in a manner that facilitates the use of the information 
for the well-being of workers. Forms designed to facilitate the administra- 
tion of compensation may lack information that is crucial for accident 
research. The Mining Act already requires the reporting of all fatal and 
non-fatal compensable accidents and in addition certain dangerous 
occurrences.^^ These arrangements are commendable and have been the 
source of key information for use by the Commission. What is disturbing is 
how difficult it is to render the masses of data pertinent to basic questions in 
accident studies. To improve the basis for audit and research, the Commis- 
sion recommends: 

That the Occupational Health and Safety Authority , in consultation with 
the Workmen's Compensation Board, industry, and labour, review the 
procedures for the reporting of injuries and accidents with a view to 
establishing links to occupational records and thereby facilitating accident 
research by sample methods. 

SUMMARY OF THE RECORD OF INJURIES, FATAL 
AND NON-FATAL 

The over-all Ontario fatality record of the metal and non-metal mines has 
been improving and is comparable with, if not superior to, that in other 
Canadian and foreign jurisdictions. Within the Ontario industry, small 
companies as a group have distinctly poorer records than large companies 
as a group. The generic risks in the different segments of operations of the 
industry as a whole differ by a factor often, with underground operations 
exhibiting much the highest risk. 

In contrast with the fatality record, the over-all record of non-fatal 
compensable injuries, while apparently comparable in level with that in 
similar jurisdictions, has been deteriorating, mainly in large operations. 
Redefinition in some companies of light-duty injuries as compensable 
injuries and a socially motivated liberalization of the circumstances in 
which absence from work for at least a day following an injury is recom- 
mended by the attending physician, expected by the worker and his union, 
and accepted by the company are, in the Commission's view, contributing 
to the rise. The rectification of statistical records should cause only a 
temporary disturbance in the trend of reported injuries. Unexpectedly, 



146 The health and safety of workers in mines 

there is little correlation between fatality experience and non-fatal injury 
experience. For example, in inco Ltd, whose employment is about half 
that of the industry, the non-fatal injury frequency has been rising 
significantly while fatalities are below average for the industry. 

There is clear statistical evidence, arising from both fatal and non-fatal 
injuries for the whole industry, that the generic risks of mining are falling in 
disturbingly excess proportion on young persons of limited experience and 
skill. However, it should be recognized as inevitable that excess risks will 
be experienced by younger and less experienced persons; what is at issue is 
the extent to which this excess can be reduced. The potential years of life 
lost and the lost years of full enjoyment of normal physical capability 
arising from accidental injuries far exceed those from industrial disease. If 
the frequency of accidents is to be reduced significantly, the question of 
training and supervision for the worker is central, as is the question how in 
a given company anomalous departures from accepted standards of techni- 
cal operations and human performance are detected and corrected. Every 
party bears some responsibility. 

ACCIDENTS AND THE PERFORMANCE OF WORK 
WITHIN A MINING OPERATION 

The following sketch of the responsibility-system for the performance of 
work is intended to generate a framework within which to identify roles and 
to derive corresponding recommendations. 

The legal framework governing the operation of mines is set out in Part 
IX and Sections 621, 624, 625, and 626 of Part xi of the Mining Act of 
Ontario. In a practical sense these parts of the Act may be viewed as a form 
of contract between the public, represented by government, and a mine 
owner, whereby the management of a mine is assigned certain generic 
duties and specific responsibilities, together with wide power to make 
decisions required to fulfil these responsibilities. The conduct of manage- 
ment in meeting these requirements under the'Act is currently audited by 
the staff of mine inspectors of the Mines Engineering Branch in the Minis- 
try of Natural Resources. 

Beyond the legal framework of the Mining Act, the employee has the 
legitimate right, under the principle of natural justice, to appraise the 
conditions under which he works and to express his views of their ade- 
quacy. Thus, the voluntary nature of a worker's decision to accept em- 
ployment does not imply acceptance of the adequacy of working conditions 



147 Accidents and injuries 

as found or the diminution ofthe obligation of the owner to fulfil the duties 
and responsibihties as defined in the Act. 

The requirements governing the operation o\' mines under the Mining 
Act place the onus on management to ensure that 1/ the conditions of work 
meet well-defined standards and 2/ the tools and equipment are suitable for 
the work and maintained in proper condition. The Commission would add a 
third obligation which is not made as clear as it should be in the Act, 
namely, to ensure that 3/ the employees are adequately prepared through 
training and experience to engage safely in productive work under normal 
conditions and to recognize and report anomalous conditions of work. 

Once the foregoing obligations are met by management the onus is on 
worker and supervisor to ensure that 1/ standard work procedures are 
followed, 2/ standard conditions of work are maintained, and 3/ tools, 
equipment and processes are properly used. 

It is a premise of this study that properly performed work will preclude 
accidents. In mining the conditions under which work is performed are 
subject to continual change both physically at the workplace and generi- 
cally in technology and methods. The proper performance of work must 
therefore depend not only on the effectiveness of a system of work ad- 
ministration through which human effort is co-ordinated but also on the 
effectiveness of the means whereby this system monitors its own perfor- 
mance and adapts to changing conditions. The Commission believes that 
the fundamental basis for accident prevention lies in the ability of each 
person to perform his duties in a self-determined manner within clearly 
defined boundaries of authority and responsibility. In this context, and 
from the evidence of briefs, hearings, expert opinions, and intensive visits 
to mining operations, the Commission concludes that there is a need for 
greater clarity and openness with respect to such simple questions as 1/ 
who is responsible for detecting departures from standards of work per- 
formance, 2/ who carries the responsibility to make the decision whether or 
not action is to be taken, and 3/ who is then responsible for seeing that the 
anomaly is corrected. 

It was observed that anomalous conditions may arise from plant and 
process design and layout, from the care and maintenance of tools and 
equipment, from work practices in the use of equipment and in the opera- 
tion of processes, from the manner of performing tasks, and from personal 
and group behaviour. Instances of anomalous conditions or departures 
from standards have been adduced in all ofthe previous chapters, and there 
is no reason to believe that any one type of anomaly is dominant as the root 



148 The health and safety of workers in mines 

of accidents. If there is argument that the dominant cause lies in unsafe 
acts, this report provides strong indications that the extent of training of 
both workers and supervisors and the effectiveness of management and 
supervision are also at issue. Anomalous conditions pertain to production, 
to health, and to safety and are inextricably related. 

The question of the prerogative of managerial responsibility in matters 
of health and safety was debated at length in the Commission hearings. In 
the Mining Act the authority to define policies that govern the response to 
anomalous conditions and the power to provide physical and human re- 
sources to correct them rests in the hands of management. This same base 
of managerial authority would exist in any form of revised industrial 
democracy involving worker participation in management.'*^ The locus of 
ultimate accountability has been well stated by the United Steelworkers of 
America as follows: 'the employer must accept the full legal and moral 
responsibility to provide a safe and healthy workplace, protective equip- 
ment, safety and health training, and safe work procedures.''^ 

It is critically important that the managerial system for the performance 
of work be effective. Table 5 1 was prepared as a model to demonstrate how 
the duties of all persons in an organization can be interrelated to achieve 
integration of the responsibilities essential to the effective performance of 
work. This table will be referred to as 'the internal responsibility-system 
for the performance of work.' 

Let us examine the roles within the internal responsibility-system de- 
picted in Table 51. For each of the levels of occupation extending from 
workman to president the elements of responsibility related to the job are 
identified succinctly in vertical columns. The elements of the rows define 
the tasks to be performed by the collective hierarchy in organizing the 
performance of work. When these organizational tasks are correctly inte- 
grated there is a unity of responsibilities. The progressive change in the 
character of the elements from the purposes of organization at the top 
management level to the operational detail at the workplace reflects the 
devolution of duties for each occupational level in the organization. Crucial 
to the capacity of the system to recognize and respond to departures from 
standard conditions is its own performance in defining the basis for stan- 
dard conditions at every level of the organization through 1/ providing 
detailed job descriptions, 2/ specifying the personal prerequisites neces- 
sary to carry out the work characteristic of the job, and 3/ the definition of 
the responsibilities entailed in the job. The responsibilities associated with 
the performance of the duties as defined in the columns of Table 5 1 must be 



149 Accidents and injuries 

adequately understood and prepared for if the person is to be able to 
perform the role effectively and to be held accountable for the identification 
and correction of the departures from standard conditions. It is man- 
agement's underlying responsibility to see that this internal respon- 
sibility-system is effectively in place and in particular that there is open 
understanding among all parties of their duties and responsibilities in the 
performance of work. In particular it is essential that the processes of 
communication at the interfaces between levels of responsibility be well 
defined and operative. In view of the scale and technology of mining 
operations, a significant part of the variability of injury experience, both 
fatal and non-fatal, identified within metal groups can be attributed, the 
Commision believes, to the degree of effectiveness of internal respon- 
sibility-systems. 

The responsibility for internal accounting with respect to anomalous 
conditions is defined in the bottom row of Table 51. The preceding two 
rows define responsibilities for sustaining standard conditions at the work- 
place and for facilities and equipment used. The hearings and investiga- 
tions of the Commission support the view of the labour unions that in some 
mining operations departures from standard conditions are recognized by 
workers and first-line supervisors but are not regularly acted upon with 
reasonable promptitude by the internal responsibility-system. There are at 
least two consequences of such a situation. The first and most important is 
that the worker's and supervisor's commitment to the importance of cor- 
recting anomalous conditions may be undermined. The second conse- 
quence is that the existence of such situations may only be revealed by the 
external audit system through the attention of mine inspectors and, before 
detection, may lead to preventable accidents. It is a misuse of the role of 
mines inspection for any management to rely on this external process of 
audit as a primary means of detecting departures from standard conditions. 

In the complex developmental character of hard rock mining, it is 
unreasonable to expect unvarying perfection of quality in tools, machines, 
and working conditions; nor is it reasonable to expect the performance of 
work to be free of human error and misjudgment. However, there ought to 
exist, and to be understood by all who need to know, clearly defined and 
supervised standards of performance including concern for the safety and 
health of workers. The essence of this understanding is the capacity to 
recognize and to correct departures from standards even in such simple 
things as housekeeping. Lax standards become not only accepted stan- 
dards but expected standards. The Commission therefore recommends: 



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152 The health and safety of workers in mines 

That the senior management of each mining operation review the perfor- 
mance of its internal responsibility-system, placing special emphasis on 
the delineation of II responsibility to detect and to report departures from 
standard conditions at every level of operations, 21 location of responsibil- 
ity for ensuring that identified departures are dealt with, 31 procedures for 
committing the resources to correct anomalies, and 4/ procedures for 
checking the action already taken and still to be taken. 

The apparently common view that the great majority of accidents are the 
direct result of nothing more than unsafe acts or unsafe conditions is, in the 
Commission's opinion, too restricted a view of the human problem of 
accidental injuries. Workmen and their supervisors at every level may act 
unwisely, but they do so within a system for the performance of work 
whose responsibility it is to set clear and supervised standards of what is 
expected. Within such a system workers have a clear obligation to perform 
work by standard procedures, and supervision has the responsibility to see 
that standard conditions of work, tools, and equipment are maintained. At 
times, accidents in themselves may distract attention when in fact the 
responsibility-system for the performance of work deserves to be the focus 
of concern. 

Any internal system of direct responsibility will be imperfect and re- 
quires audit, not because of any inherent defect in form but because it is a 
human organization in which conditions of work and concern for the 
well-being of persons create grounds for tension. The major element of 
external auditing currently in use is that of mines inspection under the 
Mining Act. To this process of inspection the Commission will propose that 
there be added worker-auditors drawn from the ranks of employees and a 
well-defined role for joint labour-management health and safety commit- 
tees. Each of these three elements, namely, mines inspection, worker- 
auditors, and joint health and safety committees play a distinctive role 
supplementary to and in an important sense external to the basic processes 
of accountability that are internal to the employee-employer relationships 
in the system for direct responsibility depicted in Table 5 1 . 

External audit can keep the basic internal system alert and responsive, 
but it cannot substitute for basic internal integrity which rests on the 
knowledge, training, experience, and commitment of management, super- 
visor, and worker. All parties are under an obligation to seek to eliminate 
anomalous conditions organizational, technical, and human. No party can 
claim that the beam is always in the other's eye. 



153 Accidents and injuries 

THE W O R K r R - A LI D I T O R 

Studies by the Commission indicate that workers as a group with more than 
five years' experience at a company have a significantly lower frequency of 
injury than would be expected if experience were not a factor. This fact 
leads to the conclusion that the knowledge and judgment of this group, as 
individuals, has a major influence on their abilities to perform their tasks 
safely at the workplace. While each worker can contribute personally on 
matters concerning the performance of his specific work through the inter- 
nal system of direct responsibility discussed in relation to Table 5 1 . there is 
no established means by which workers can assess conditions of work as a 
whole, and through which the insight derived from their collective know- 
ledge and experience can be utilized to assist in preventing accidents in 
mines. 

In the hearings before the Commission the labour unions argued for the 
extension of the mining inspectorate to include a significant fraction of 
experienced workers in addition to the professional engineers who cur- 
rently constitute the core of the inspection staff. The Ministry of Natural 
Resources in its brief proposed that workers should have the option to 
select and employ worker-inspectors. 

The Commission visited the United Kingdom and Sweden, where it 
investigated the worker-oriented inspection systems cited in the hearings. 
By statute, mines in the United Kingdom have workmen's inspectors and 
mines in Sweden have safety delegates whose responsibilities are compar- 
able but not identical.'^ In the United Kingdom, workmen's inspectors are 
appointed and employed by the labour unions, where such exist. In Swe- 
den the safety delegates are appointed by the labour unions, where such 
exist, and are paid by the company while performing their duties. Their 
general function is to monitor and report on conditions of work as these 
pertain to health and safety. 

Believing that provision should be made in Ontario for the review of 
conditions of work by means of worker-auditors, the Commission recom- 
mends: 

That statutory provision he made for the appointment in each mine and 
plant of worker-auditors having the authority and responsibility to examine 
and report upon conditions of work pertaining to the health and safety of 
workers at sets of workplaces designated by management in such a way as 
to encompass all workplaces in underground, open pit, reduction plant, 
and shop and surface operations. 



154 The health and safety of workers in mines 

The basic function of such worker-auditors is to contribute to manage- 
ment and subsequently to the mining inspectorate the judgments of experi- 
enced workers on conditions of work pertaining to health and safety in the 
operations designated for such workers' review. The intended role is an 
advisory one. Thus in the manner of the workmen's inspectors in the coal 
mines of the United Kingdom^" the Commission proposes that the 
worker-auditor conduct an examination of an area of work, prepare a brief 
report thereon, and submit this to the mine manager for his written com- 
ment. One copy of the completed form containing both the worker- 
auditor's report and the manager's comments is to be sent to the mining 
inspectorate and another copy posted for the information of the workers 
concerned. The intention is to provide management with an additional 
form of audit of operations while informing the mining inspectorate of the 
details of the review. 

Intending the worker-auditor to be neither the formal agent of the union 
nor a member of the mines inspectorate, the Commission recommends: 

That worker-auditors be given released time with regular wages while 
performing their duties; 

That the Workmen's Compensation Act he amended to make provision for 
the assessment of the costs of worker-auditors upon employers in Class 5. 

The latter recommendation is intended to provide a means of including the 
costs to employers of worker-auditors within the assessments of the Board 
and hence of accounting on an industry-wide basis for the costs incident 
upon employers. 

The Commission proposes that worker-auditors devote an appropriate 
part of one shift per month to the task of reviewing work conditions. If such 
a system of worker-audit is to function constructively its purpose as part of 
the whole system for the co-ordination of the performance of work must be 
clearly understood. The process must be conducted openly, with the 
worker-auditor scheduling the time of review on a regular basis by ar- 
rangement with the manager and being accompanied, as the mining inspec- 
tor is, by the manager or his designate. The Commission believes it to be 
important that worker-auditors be accompanied by supervision of the most 
senior responsibility that is feasible. The worker-auditor is not an instru- 
ment of investigation for the collective bargaining unit as such. Through 
statutory provision he or she undertakes a publicly affirmed obligation to 
review conditions at designated places of work and to make a report to 



155 Accidents and injuries 

management. It is suggested that there be one worker-auditor for every 
twenty-five workers, more or less, ^' and that the designation of workplaces 
for review be made by management in consultation with the Joint Health 
and Safety Committee and the Mines Inspection Branch. Further, the 
Commission recommends: 

That worker-auditors he appointed from among qualified candidates for a 
period of three years by the collective bargaining unit, where such exists, 
or be elected by the workers. 

To qualify for the role of worker-auditor, a person should 1/ have a 
minimum of five years of experience in work closely related to one or more 
of the types of work undertaken at the workplaces designated for audit; 2/ 
have a minimum of three years' seniority; and 3/ have received adequate 
instruction arranged and funded by the Occupational Health and Safety 
Authority in co-operation with the industry and the representatives of the 
workers. ^^ The instructional programme in modular form should deal with 
issues of health and safety under conditions of work pertinent to mines and 
under the governing legislation. Worker-auditors should have the right of 
access to all statutory records for environmental conditions and equipment 
operation and should understand the function and significance of these and 
related schemes, codes, and standards for environmental conditions and 
work practices. He or she should have the right to take, or to request the 
taking of, environmental measurements at particular places during, or as 
soon as feasible following, an audit, and to have the results appended to the 
report. 

A system of worker-auditors, by providing a clear basis for experienced 
workers to contribute to the review of work conditions in a capacity other 
than in the process of work itself, could, in the Commission's view, 
strengthen the effectiveness of the internal system of direct responsibility 
which is at the core of accident prevention. A statutory provision for such 
audit would be, not an unwarranted interference in the management of 
enterprise, but rather an affirmation of a public desire that workers have a 
formal right and the means to review the conditions of the work into which 
they have entered voluntarily as employees. Such auditing is symbolic not 
only of the right to review conditions of work with reference to standards 
but also of the obligation of all parties to adhere to standards. Anomalies 
affecting health and safety arise on both human and technical grounds. The 
role of worker-auditor implies the exercise of judgment in recognizing and 
reporting anomalies of all kinds without engaging in personal identification. 



156 The health and safety of workers in mines 

At the Commission hearings the labour unions stated their conviction 
that a representative of the workers should be present at the investigation 
of fatalities and serious injuries. Under British law the workmen's inspec- 
tor has this right. The worker-auditor in whose area an event occurs is the 
appropriate person to join the mines inspector and others as are now 
provided for or customary in such events. ^^ The Commission therefore 
recommends: 

That there he statutory provision for the appropriate worker-auditor to 
participate in the investigation of fatal accidents and serious injuries; 

That the designated worker-auditor have the privilege of cross-examining 
witnesses at an inquest into any fatal accident whose circumstances he has 
participated in investigating. 

JOINT L A B OU R- M AN AG E M E NT HEALTH AND SAFETY 
COMMITTEES 

Labour unions have for many years sought the right to be consulted about 
and to participate in accident prevention at the workplace. ^"^ Various royal 
commissions in Ontario have made recommendations for the voluntary or 
mandatory formation of joint committees of management and employees 
for purposes of accident prevention. ^"^ The Workmen's Compensation Act 
contains provision for the Board to invoke the formation of safety commit- 
tees for accident prevention in companies with adverse injury experience, 
although to the Commission's knowledge the Board has not exercised this 
right. ^^ 

Joint labour-management health and safety committees currently exist in 
over 90 per cent of the industry. The Commission's concern is therefore 
not so much with their formation as with their role. The operational 
procedures and jurisdiction of existing committees have been negotiated 
by collective bargaining. The hearings before the Commission have indi- 
cated that a number of these committees have become effective instru- 
ments for constructive and co-operative consultation on conditions of 
work related to safety and health. On the other hand, among these commit- 
tees are also some that meet sporadically with no clear sense of their role 
and others that meet more often in an atmosphere of frustration, in which 
the labour members are convinced that undesirable conditions are not 
being corrected and management members believe that the substance of 
many complaints is not central to health or safety. In spite of the varied 



157 Accidents and injuries 

experiences of such committees in Ontario, the Commission has found no 
evidence to suggest that at this time 1/ injury experience in Ontario is 
inferior to that in jurisdictions such as Sweden where union participation is 
more extensive or 2/ unionized mines have accident records superior to 
those of non-unionized mines. 

If the internal system of direct responsibility depicted in Table 51, 
checked by mines inspection and examined by worker auditing, is effective 
in dealing with the bulk of the anomalous conditions that give rise to 
accidents, a joint labour-management health and safety committee, the 
Commission believes, can also play an effective role in sustaining the 
alertness and responsiveness of the whole system. However, if the internal 
system of direct responsibility functions below some reasonable level of 
effectiveness it may mean that the capacity of the organization is too 
limited to make use of the information provided by the committee. Fur- 
thermore, without a co-operative will to understand the complex issues of 
health and safety in the industry it is unlikely that such committees can 
better the conditions of work. The Commission is strongly convinced that 
there is emphatically no place for the adversary system of collective 
bargaining in dealing with matters of health and safety. 

The Commission has argued for clear recognition by all parties that the 
integrity of the internal system of direct responsibility is the key to what 
actually happens in matters of health and safety. And it has recommended 
that this system be kept operationally alert by adding to the mines inspec- 
tion function a provision for the review of conditions of work by worker- 
auditors. Within this framework the Commission sees an important consul- 
tative and advisory role for a joint labour-management health and safety 
committee that can help to sustain responsiveness to changing conditions. 
Both labour and the industry, through the Ontario Mining Association, 
have recommended that the establishment of such committees be manda- 
tory. It is thus recommended: 

That there be statiitoiy provision for the establishment of a Joint La- 
bour-Management Health and Safety Committee at each mine and plant: 

That the membership of the Committee consist of equal numbers of per- 
sons appointed by management and appointed by members of the collec- 
tive bargaining unit(s), where such exist, and otherwise elected by the 
workers collectively, subject to the constraint that at least two of the 
persons selected be worker-auditors; 

That the Joint Committee conduct its work as far as feasible during regular 



158 The health and safety of workers in mines 

hours of work and that its members receive their regular wages while 
engaged on committee work; 

That the Joint Committee meet regularly at least four times per year and 
tu)t nu)re often than once nionthly. 

The variations in scale in the industry make it impracticable to define the 
optimum size of such a committee or to define the extent to which there can 
fruitfully be subsidiary committees for segments of operations, for example 
in smelters, mills, underground, and so on. In one large corporation, inco 
Ltd, which has some twenty thousand employees, a new system of one 
general committee, fifteen area committees, and forty operations' commit- 
tees has recently been negotiated with the labour union. ^"^ The question of 
infrastructure should evolve out of a reaffirmed role for the central commit- 
tees that now exist in most of the industry, and where mutually agreed 
practices currently exist the Commission makes no suggestion that these 
be altered. 

FUNCTIONS OF THE CENTRAL JOINT COMMITTEE 

So diverse are mining operations that a detailed basis of operations for joint 
committees should properly be evolved by those engaged in them.^^ How- 
ever, the Commission believes that certain principles should guide the 
work of these committees and their subsidiary parts. 

In the whole responsibility-system for occupational health and safety, 
which involves workers, companies, and government agencies, the essen- 
tial principles of openness and of natural justice have not received adequate 
expression. This issue is not peculiar to the mining industry. Participation, 
it has been noted, can be understood in terms of three modes: knowledge 
(having ready access to information), contributive responsibility (provid- 
ing individual and collective insight, advice, and judgment), and direct 
responsibility (making operational decisions). The worker, the supervisor, 
management, and the mine inspector participate in all three modes. The 
worker-auditor, as defined above, participates in the first two, and the 
Commission believes the proper basis for the participation of the joint 
health and safety committee is also in the first two modes. 

The Commission considers the essential role of the joint committee to be 
that of providing a consultative forum for constructive and critical review 
of the status of the health and safety of workers as reflected in the perfor- 
mance of the responsibility-system both internal and external to the local 



159 Accidents and injuries 

operations. It is a forum of consultation between those with the ability to 
contribute and those accountable for deciding what is to be done. Someone 
accountable for making a decision does not impair his decision-making role 
by consulting those who can contribute to it. Such consultation is indeed 
very likely to improve both the quality and the acceptability of the decision. 
The Commission was presented with little evidence that the contributive 
ability of workers is being tapped extensively by mine management. If it is 
to be tapped in the deliberations and activities of a joint committee, there 
must be an atmosphere conducive to the development of a mutual under- 
standing of objectives rather than an atmosphere of confrontation for the 
purpose of maintaining institutional rights of either party. 

Openness, in the sense of establishing a clear basis of knowledge, should 
encourage co-operation. Workers have not, in the Commission's view, had 
appropriate access to information concerning environmental conditions at 
the workplace, to data on the hazards of materials and processes, to reports 
on injury experience, to reviews of the status of occupational disease, or to 
schemes, codes, and standards of practice for work and work conditions 
where such exist. All such data, as well as reports of the worker-auditor 
and information that management may be expected to table on policy and 
operations, are relevant to the work of a joint committee. 

The Commission suggests that joint committees give attention to 
policies, system performance, operations, and conditions. These will be 
discussed in reverse order. While it may be practicable in small-scale 
operations to discuss all of these elements in a single committee, it will not 
be so in large mines. The minutes of representative committees currently 
in operation reveal a tendency to dwell on the disposition of specific 
anomalies to the exclusion of all else. Workers naturally wish to see 
particular adverse conditions dealt with, and it is important that a commit- 
tee should demonstrate its capability at this pragmatic level. However, as 
the training of persons for such committees improves and as practices of 
openness become better developed, it is essential for them to reach beyond 
individual conditions to the generic context in which they occur. Thus, if a 
joint committee is to undertake tours of operations, which the Commission 
considers appropriate, such tours should be designed to consider policy in 
such generic problem areas as the following: 1/ environmental standards, 
codes, and schemes of practice; 2/ standard work procedures for existing 
and new methods of work and equipment; 3/ modification and extension of 
plant; 4/ education and training for health and safety; 5/ the design and use 
of protective equipment; 6/ the maintenance of tools, equipment, and 
processes; 7/ the efficient use of ventilation; 8/ the hazards related to 



160 The health and safety of workers in mines 

haulage and hoisting: 9/ the use of hazardous chemicals; 10/ housekeeping; 
and 1 1/ underground fire procedures. 

The internal system for direct responsibility alerted by worker audit and 
mine inspection has the task of identifying and reporting specific problems. 
While a tour by a joint committee may unearth such instances its major role 
should be to understand classes of anomalies. This task may be facilitated 
by engaging, prior to a tour, in an analysis of the accidents related to the 
generic problem area under review. It is important that a joint committee 
have a program for reviewing problems and for advising on policy. Both 
parties have a responsibility to share in constructing such a programme; 
simply talking about health and safety is not enough. 

The joint committee should have an understanding of how the internal 
system of direct responsibility is organized to deal with anomalous condi- 
tions affecting health and safety and how it functions in introducing 
changes in methods and technologies. In this regard, if both parties under- 
stand the framework in which they meet together, the joint committee can 
be a constructive vehicle for communicating management intentions and 
for management in turn to benefit from the insight of workers. The Com- 
mission recommends: 

That each mining company provide its employees with a written statement 
outlining its policy for health and safety and the organizational arrange- 
ments and responsibilities for giving effect to it. 

In the operation of a joint committee it is hoped that opportunity would 
be taken to benefit on occasion from a visit by an attending physician, an 
industrial hygienist, and other resource persons who can add perspective 
to its long-range work. Joint labour-management health and safety commit- 
tees can be instruments of co-operation for the sustaining of an effective 
and responsive internal system of direct responsibility and for assisting in 
the development of policy both within the mining operation and within the 
whole provincial system for occupational health. There is an opportunity 
for leadership. 

However, if the parties in the committee insist upon emphasizing the 
dichotomy between unsafe conditions and unsafe acts to the exclusion of a 
balanced judgment of the risks and benefits in the complex human and 
technical organism that is a mining operation, both parties will inevitably 
be disappointed. The greatest bone of contention will probably be whether 
or not a given condition constitutes an anomaly that may contribute to the 
occurrence of an incident likely to cause injury. It is essential for differ- 
ences of opinion on this matter to be frankly stated and recorded, and for 



I 



161 Accidents and injuries 

management to indicate when considerations involving feasibility, costs, 
and so on are determining factors in its response to situations. The mines 
inspectorate should receive a copy of the minutes of the committee for 
review, and as necessary the inspector should adjudicate matters referred 
to him for resolution. In this regard the Commission states its strong 
conviction that anomalous conditions should as far as possible be dealt 
with by the persons immediately involved. It would be inexcusable for 
problems to be presented either to a joint health and safety committee or to 
the mines inspectorate before the internal system of direct responsibility 
had been given the opportunity to act. Some aspects of the role of the 
mining inspectorate in accident prevention will now be reviewed. 

THE ROLE OF THE MINES INSPECTORATE IN 
ACCIDENT PREVENTION 

The powers and duties of the mines inspectors as specified in Sections 610 
to 612 of the Mining Act were reviewed in chapter 2. The mines inspecto- 
rate, as represented by the Mines Engineering Branch of the Ministry of 
Natural Resources, has interpreted its role in accident prevention as having 
two distinct parts: 1/ to determine by sample inspection the state of com- 
pliance of mining operations with the extensive technical provisions of the 
Mining Act and to issue written instructions for improving the state of 
compliance; 2/ to assess the characteristics of existing and proposed min- 
ing methods and technology with the intent of establishing codes of prac- 
tice and subsequent modifications to the Mining Act designed to minimize 
the risks of their use. 

The modus operandi of the inspectorate has been described in the 
following words: 

We work through periodic inspections. We require mines to provide us with data 
about their operations. And we receive information from workers and union 
officials. 

When one of our Engineers finds out about a problem or a failure to meet a 
standard he informs management that they are required to correct it. Normally this 
order will include a date by which the work must be completed. 

Only in cases where the offense is flagrant, or where our written orders are 
disregarded would charges under the Mining Act normally be laid. 

In some cases, it is [not] possible for problems to be corrected or standards met 
immediately. In those cases, our Engineers work with management to find solu- 
tions, and to expedite those solutions. 

Our job, in short is to make sure the self-regulatory system is working.-^ 

The Commission fully endorses the last statement when the self- 



162 The health and safety of workers in mines 

regulatory system is understood to be the system of direct internal respon- 
sibility based on the worker, supervisor, and management, as modelled in 
Table 5 1 . In order to appraise the process of self-regulation in this context it 
is essential for every mine inspector to develop a sense of the effectiveness 
of the internal responsibility-system in each mining operation he inspects. 
The minutes of the joint labour-management health and safety committee 
and copies of the reports of the worker-auditors should provide some 
insight on this matter. It has previously been recommended that the alloca- 
tion of the work of inspection be based in part on the analysis of the relative 
frequencies of injuries in different mining operations. The mine inspector 
may need to consult with worker-auditors in the general course of mine 
inspection. Since it has been recommended that the reports of the worker- 
auditors be copied to the mine inspector after completion by management, 
consultation between the mine inspector and the worker-auditor is a 
natural step. 

The mines inspectorate has been staffed by mining, electrical, and 
mechanical engineers with professional qualifications. The mining en- 
gineers inspect primarily underground and open pit operations, while the 
electrical and mechanical engineers inspect machines, equipment systems, 
and processes. Unlike mining inspectorates in the United Kingdom and 
Sweden, the Mines Engineering Branch has inspected metallurgical plants 
other than mills, that is to say, smelters and refineries. It does not appear to 
have the expertise in extractive metallurgical processes it will need if it is to 
continue to have this responsibility. 

There are standard inspection forms which enumerate the many techni- 
cal elements dealt with in the Mining Act. The inspectors generally visit 
mining operations two to four times a year, spending one or more days 
during a visit. The actual inspection can at best be a sampling process 
designed to test management's compliance and to alert it to its respon- 
sibilities under the Act. The mines inspectorate in effect acts to monitor, as 
intensively as its resources permit, the state of mining operations as these 
pertain to the health and safety of workers. It is not feasible for the 
inspectorate to police exhaustively the technical detail of the Mining Act. It 
is the responsibility of the internal responsibility-system continuously to 
detect and to remove anomalous conditions throughout the operations. 
The Commission endorses this balance of responsibilities. But the inspec- 
torate has, in the Commission's view, been understaffed and inadequately 
funded for its role both in accident prevention and in the protection of the 
health of workers and no doubt these circumstances have affected its 
morale. 



163 Accidents and injuries 

The mines inspectorate should have not only the professional capacity 
to comprehend the full range of mining operations but also the standing to 
influence the commitment of senior management to the effectiveness of the 
internal responsibility-system. The Commission therefore recommends: 

That the core of the staff of the Mines Inspection Branch continue to he 
based on persons (f exceptional professional experience in mining*, and 
related fields of engineering, supplemented by special training in occupa- 
tional health and safety and in the principles of the administration of work. 

This same professional capacity is essential to the role of assessing and 
advising on technological change in mining. In the hearings before the 
Commission the Mines Engineering Branch was subject to severe criticism 
from the labour unions on several grounds. Some of these have been dealt 
with in the preceding chapters. In assessing technological change in mining 
methods, the Branch seems to have met its responsibilities effectively. 
Indeed, the work of the Mines Engineering Branch in the development with 
mines and manufacturers of codes of practice for friction hoists, in situ 
testing of hoist cables, raise climbers, hydraulic backfill, and so on repre- 
sents in the Commission's view an admirable record. ^° The practice of 
working closely with mine management on issues of technological change 
has led to the union allegation of accommodation of interests. While 
technical expertise is an ''mportant ingredient in these matters, so also are 
practical points of application in mines. The Ministry of Natural Resources 
has been tardy in establishing policy for consultation between the Mines 
Engineering Branch and experienced workers. To affirm further the con- 
tributive basis for worker input into questions of technological change, the 
Commission recommends as a matter of principle: 

That task groups set up by the Occupational Health and Safety Authority 
to advise on codes of practice and statutory regulations relating to tech- 
nological change in mining include representatives of labour. 

Through the power conferred by legislation the mines inspectorate must 
be, and be seen to be, the agent of the public in exercising responsibility to 
preserve the health and safety of workers involved in mineral develop- 
ment. One manifestation of this public responsibility, namely, a critical 
annual or biennial report, has been seriously neglected. In the fulfilment of 
this responsibility it is essential that the mines inspectorate have clear 
access to and utilize the understanding of both management and workers. 
To date the contributive capability of workers has been too little called for. 



164 The health and safety of workers in mines 

THE TRAINING OF MINERS 

For accident prevention by the worker himself, nothing is more important 
than the extent and quality of training, experience, and supervision. This 
subject, together with the issue of working alone, will now be considered. 

The studies reported in this chapter show that injuries arising from 
accidents fall disproportionately upon unskilled and semi-skilled personnel 
with limited experience. If unsafe acts are the major cause of injuries, as 
asserted by management,^ ^ it must be asked whether or not workers 
receive training and supervision of adequate extent and quality. In the light 
of the fact that fatal and non-fatal compensable injuries cause many times 
greater loss of potential life years and of life years enjoyed at full physical 
capability than does industrial disease, no question deserves more careful 
attention by the mining industry than that of training. In fact the risks in 
mining are exceptional, and persons do indulge in unsafe acts. 

With respect to the preservation of the health of workers it has been 
pointed out that the Mining Act contains general stipulations calling for the 
suppression of dust, the removal of noxious gases, and the provision of 
adequate ventilation. Likewise, with respect to accident prevention, the 
Act requires that persons engaging in work shall be adequately trained, 
experienced, qualified, approved, authorized, and so on. The employer 
possesses the sole authority to determine the qualifications of employees 
under Section 169 (3), which states that 'subject to the requirements of the 
Act and except as otherwise provided by the Act, responsibility for the 
authorization and decision as to the qualifications of employees rests with 
the employer or his agent.' General conditions for the exercise of this 
responsibility are specified in a variety of sections of the Act, examples of 
which are as follows: 

Section 169 (14) ... Every Manager shall ensure that no person works without 
supervision at any machine unless the person, {a) has received adequate training 
and instruction in the operation of the machine and any dangers connected there- 
with; (h) has received adequate supervision by a person having thorough knowl- 
edge and experience with the machine; (c) is capable of safely operating the 
machine without supervision. 

Section 165 ( 1) No person under the age of 21 years and no person who has not had 
adequate experience on a reversing hoist shall be authorized to operate a hoist by 
which persons are handled in a shaft or winze at a mine. 

Section 396 (3) No person, unless he is authorized so to do, shall operate any 
equipment for controlling the movement of the hoist or interfere with the 
equipment." 



165 Accidents and injuries 

Section 249(2) No person under the age of 18 years and no person who has not had 

adequate experience on a crane shall be authorized to operate a crane in a mine or 

plant. 

Section 431 (I) Wheie electrical equipment is used at a mine or plant, il shall be m 

the charge of an authorized person who shall be qualified by experience to handle 

such equipment. 

Section 43! (2) Hvery person operating or having charge of electrical equipment 

shall have been instructed in his duty and shall be competent to perform the work he 

is set to do. 

Section 431 (3) Repairs, extensions and changes to existing installations shall be 

made only by qualified persons. 

Section 169(5) It is the duty of every manager, supervisor or other person in charge 

of workmen and every hoistman, deckman, conveyance attendant or person who 

handles explosives or blasting agents or who operates, installs or maintains any 

equipment, machinery or electrical apparatus in or about a mine or plant, to know 

the requirements of this Part that apply to the work under his charge and direction 

or in which he is engaged. 

In relation to personnel, the Mining Act does not define clearly the meaning 
of 'adequate experience/ 'qualified/ 'approved/ or 'authorized.' Judg- 
ment on these central issues, which is crucial to the health and safety of 
workers, is the responsibility of the manager. Further, in Section 169(14) 
the Act refers to adequacy of training and supervision for the operation of a 
machine but does not directly require adequacy of training and supervision 
for the over-all performance of work. The labour unions have been sharply 
critical of the quality of training provided to underground miners. 

On the basis of its hearings and investigations and the evidence provided 
by the study of accidents, the Commission believes that the level of training 
of many miners should be improved and that as a matter of principle there 
should be improved means of verifying that management ensures the 
adequacy of training and qualification for all new and upgraded employees. 

Before the basic issue of training for work is considered, certain impor- 
tant arrangements for training miners to deal with accidents deserve com- 
mendation. Fire is one of the terrible hazards of mining. Since 1929, under 
the provisions of the Mining Act and under the direction of a Mines Rescue 
Superintendent attached to the Mines Engineering Branch, "^"^ a system of 
Mines Rescue Stations has been maintained throughout the province. 
These stations provide to some miners, who volunteer and are paid regular 
wages plus a bonus by their companies, expert training and practice in 
working in simulated fire situations; about six hundred miners and two 
hundred supervisors currently participate. These mine rescue crews are 



166 The health and safety of workers in mines 

organized to converge on a mine where there is a fire.'^'* The training has 
been so standardized that mine rescue crews can work without loss of 
effectiveness with crews of other companies, in other districts, and at other 
mines. They compete annually for a trophy and maintain a splendid level of 
competence and morale. In the past thirty-eight years since the Mine 
Rescue Stations were set up, only one life has been lost because of fire in an 
Ontario mine. Many mine companies require their first-line supervisors to 
hold a St John's Ambulance First Aid Certificate, and in some mines a 
significant number of workers hold certificates. The Commission strongly 
commends this programme. 

The following discussion of training for work focuses on the novice 
underground miner, who the Commission study shows, encounters the 
highest risk of accident, but it applies with like force to other categories of 
workers. The Commission is concerned with principle, rather than detail, 
the latter being beyond its competence. The training of employees in mines 
and plants has been and remains largely an on-the-job proposition whereby 
new employees are introduced to the work environment and are shown the 
methods of work by their supervisors and fellow employees. This proce- 
dure, while suited to the varied and immediate needs of the company, 
has resulted in great variation in content and emphasis on training and has 
led to difficulties in establishing consistent records of evaluation for 
defining the qualifications of persons ostensibly doing the same kind of 
work who move about not only within a given mining operation but also 
within the industry. These problems are not new to industrial training,^-'' 
but they are emphasized by the diversity of mines and of mining methods. 
Parts of the industry, particularly in Northwestern Ontario, have also been 
facing severe problems of labour turnover. "^^ 

The following excerpts from company training procedures for novice 
miners, the majority of whom have left formal schooling before Grade 9 or 
10,^"^ illustrate the distinctive types of training. 

Short-term induction, followed by training on the job 
The procedures of one company are intended to 

provide each new employee with the basic knowledge and skills needed to perform 
his job safely including the Company's philosophy of safety, good housekeeping, 
fundamentals of safe work procedures, requirements of the Mining Act, safety 
equipment and its uses, first aid, reporting of injuries and many others. Basic work 
methods are demonstrated in the field allowing the new employee to become 
familiar with his job. At the end of this one-week training period he is required to 
pass a qualification test before joining the regular work force. ■^'^ 



167 Accidents and injuries 

Ihis piocediire is designed to intiodiice a person to a basic job. If and 
when a worker changes jobs, further training is provided. Training pei iods 
are commonly interspersed between periods of experience. I he units of 
training are delivered by a variety of persons to standards determined by 
those within the company who deliver it. 

Phased Staines of training a development miner 
The procedures of one company are as follows: 

Phase I (2 to 4 weeks) 

The novice is assigned to the conveyor belt clean-up crew under a full-time 
supervisor. He is constantly supervised from the time he reports ... in this phase the 
primary job is conveyor clean-up. However, the crew is moved all over the mine on 
general clean-up work. During this period of from 2 to 4 weeks, the man becomes 
acquainted with the underground surroundings, the terminology used on the job, 
procedures in safety, fire, etc. ... The trainee attends a weekly safety and instruc- 
tion meeting ... 

Phase II (4 to 6 weeks) 

At this point he becomes more oriented to the job. as he assists in pipefitting. supply 
distribution, general housekeeping, and occasionally helps a miner in the stopes. In 
these ways he obtains an indication of what a miner's job consists of. At Phase ii, 
the trainee is supervised by a production shift-boss. He is more or less on his own, 
and is given jobs as required on the beat ... 

Phase in (8 to 12 weeks) 

This is the focal point of the whole program, the beginning for a production miner . . . 
The candidate is put into a school stope with two other trainees, working under the 
constant and direct supervision of a Training Stope Instructor. Here the trainee is 
given instruction for a minimum number of hours in the various elements of 
practical and safe mining ... 

A. Work Area Preparation and Maintenance 

B. Drilling 

C. Use of Explosives and Blasting Accessories 

D. Ore Removal 

The Director of training reviews the trainee's performance with him once a week ... 

Phase IV (2 to 4 weeks) - Advanced Stope 

At this point the trainee leaves the instructor. He is on his own with a partner and is 
put into a stope to practise the skills which have not yet become second natiue. 
The work is lined up by the Training Shift Boss who is around constantly. Here he 
begins to feel the demands of production, and starts to appreciate w hat he can do for 
himself... When it appears, usually after two to four weeks, that the trainee's safety 



168 The health and safety of workers in mines 

performance and his initiative would not adversely affect the incentive earnings of 
other qualified men, he is given a written test. If he achieves the required marks a 
certificate is presented to him at one ot his safety meetings. He is then transferred to 
a regular production beat, classified as a general miner and receives a miner's rate. 
A further period of time will evolve before the trainee-miner can be considered to be 
an all-around miner. ^^ 

The significant structural elements here are staged training delivered in a 
coherent sequence with regular evaluation by a director of training, fol- 
lowed by a form of certification. The content of training remains wholly 
company-determined. 

Modular or block training 

This form of training for novice miners was introduced into the mining 
industry by one company in 1974 and is in use in related forms in other 
companies. "^^ The system for novice miners is carried on in co-operation 
with the Industrial Training Branch, Ministry of Colleges and Universities, 
and has been described as follows: 

Each job is broken down into its essential tasks or elements of work. By combining 
these tasks into various combinations, complete job profiles are made up in any 
pattern or combination required. Each module contains a performance and safety 
standard. This system of training provides for the accreditation of each employee 
who has completed a training course in each module or block. Testing is done by a 
show-and-tell basis and no written exams are required. Accreditation certificates 
are issued by the Industrial Training Branch, Ministry of Colleges and Universities 

A new employee ... upon entering the mine is required to go through a Basic 
Program. This takes 40 man-hours or 1 week's training. After successful comple- 
tion he is then put into a mine beginner's job or a labourer's job, or he can go straight 
into the Drill School for a further 2 week's training, of 80 man-hours and receive the 
further 4 modules of drilling.'*' Upon successful completion of the drilling section, 
he will then go into the School Stope No. I and receive training in a further 10 
modules, which takes about 2 weeks, or 80 man-hours. After successful completion 
of this section he is now qualified to function as a stope driller ... Putting a person 
through a 1 , 2 or 5 week training program does not necessarily mean that he is fully 
qualified as there is still the factor of experience to be considered. 

The distinctive feature of the modular form of training described above 
is the introduction of standard definitions and descriptions of elements of 
work which are established as printed standards, maintained in a central 
registry, and accredited by an agency other than the company itself. This 



169 Accidents and injuries 

system therefore provides a basis for standardization of training and of 
transferability and recognition of training. The Commission believes that 
the modular system of training for miners and other workers in the mines 
and plants should be vigorously developed through tripartite co-operation 
of the industry, labour, and government and therefore recommends: 

That the industry, government, and labour give high priority to the de- 
velopment, standardization, and accreditation of modular training and 
qualification for workers in mines and plants. 

A tripartite committee convened by the Ministry of Colleges and Univer- 
sities began meeting in September 1975 to study the development of modu- 
lar training. 

In the development of the elements of the modular system the expertise 
of the colleges of applied arts and technology and the universities should be 
provided as necessary. There is a singular opportunity here for the post- 
secondary educational system to serve the many workers who by the 
nature of their work have not needed formal access to the system but 
deserve the full benefit of its interpretive knowledge on all matters related 
to the interplay of technology, human behaviour, health, and safety at 
work. 

There are certain structural principles that the Commission commends 
for consideration in the development of modular training pertaining to the 
health and safety of miners. The following subjects are considered relevant 
for training by modules: 1/ standards for personal protective equipment 
and for conditions at the workplace, including statutory regulations relat- 
ing to health and safety; 2/ practical technical knowledge and skill in the 
selection, use and maintenance of tools, machines, processes, and prac- 
tices; 3/ standard work procedures; 4/ the organization of work generally; 
5/ the supervision of work; 6/ the system for the performance of work in a 
particular mine or plant. 

A simple model of the functional elements for training and qualification 
is shown in Table 52. In this sketch the responsibility of the first-line 
supervisor spans all elements. In the design of sequences of modules to 
implement the scheme in Table 52 for particular types of jobs it is recom- 
mended that four levels of work responsibility be clearly distinguished. 
These are 1/ working dependently as a helper under direction of an experi- 
enced worker, 2/ working as a qualified miner independently and possibly 
alone, 3/ working as a crew leader with one helper, and 4/ working as a lead 
hand directing team work. Further, it is recommended that accreditation of 



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1 7 1 Accidents and injuries 

the modular system of industrial training be at two levels, namely, training 
and minimum qualification, through satisfactory completion of one or more 
modules of training and accumulation of a specified minimum of satisfac- 
tory experience in the use of a module. Thus, the Commission envisages a 
certificate of completion of one module, or of groups of modules, being 
endorsed at the completion of training and further endorsed after the 
accumulation of the qualifying extent of satisfactory experience. The 
worker must be assured that his personal record is meticulously maintained 
and available to him as required and on separation. 

The viability of an extended modular system of training in which there is 
some basis for quality control by an accrediting agency external to the 
company will depend on the co-operation of the parties in defining subsets, 
or sets of core modules, whose significance in contributing to the 
qualification of a worker can be agreed upon and widely recognized.'*^ 
Qualification objectives should be developed for key classes of jobs. 
Guideline sequences of modules expressing these objectives should be 
prepared by the industry and made known to the Occupational Health and 
Safety Authority. It is important that the mining inspectorate be able, as a 
matter of principle, to check the qualifications of persons according to the 
Mining Act. The accreditation of modules by the outside agency is to 
promote uniformity of training as a primary factor in the qualification of 
workers. The process of accreditation must not pre-empt the responsibility 
of the manager under the Mining Act to ensure that workers are adequately 
qualified. 

The labour unions have argued for a statutory provision for certification 
of a journeyman miner, such as was recently adopted in Manitoba,"*^ 
whereas the industry has opposed statutory certification. "^"^ It is beyond the 
terms of reference of the Commission to consider this matter. But the 
Commission observes that the improvement of the training of mine work- 
ers can and must be continued while this basic provincial question of a 
policy for industrial training is being resolved. All parties agree that an 
improved system for the training and personal development of workers is a 
desirable and feasible objective, and the Commission believes that our 
society will rightly demand it. 

THE ROLE OF THE FIRST-LINE SUPERVISOR 

No position is more important to safe production than that of the first-line 
supervisor - the shift boss or foreman. It is a position of stress and 
responsibility. The underground shift boss, having received from his 



172 The health and safety of workers in mines 

supervisors a work plan for current operations, then has the responsibility 
to 1/ assign workers to work places; 2/ ensure that necessary services, 
materials, tools, and machines are available; 3/ instruct upon and supervise 
the conduct of the work; 4/ ensure that departures from standard condi- 
tions are corrected; 5/ prepare time records of the workers; 6/ report on 
operations; and 7/ assist in developing the capabilities of the persons he 
supervises. The men under his supervision may be scattered over a large 
area of one or more levels of the mine. In the course of a shift he will visit 
each crew at least once to discuss with them procedures and problems, to 
check on conditions of work, and to review some element of safety at work. 
In assigning men to workplaces he must recognize pertinent provisions of 
any collective bargaining agreement. He must appraise the conditions of 
the ground not only out of concern for safe working but also to advise on the 
adjustment in incentive contracts for time allowances for scaling, drilling, 
and so on. He must keep in touch with the ventilation department to ensure 
that local conditions of ventilation are standard, and he must respond to 
and investigate accidents. 

From the foregoing sketch of his duties it is apparent that the first-line 
supervisor should 1/ understand the organization and administration of the 
internal responsibility system for co-ordinating the performance of work of 
which he is a significant part; 2/ understand the work standards and condi- 
tions applicable in his area, without necessarily being expert therein; 3/ 
understand the hazards to health and safety associated with anomalous 
working conditions; 4/ be able to make a decision that action be taken; 5/ 
have the authority to ensure that a decision is carried out; 6/ have the 
freedom to exercise his authority and hence to be free from unwarranted 
encroachment on, or intervention in, his role; and 7/ have capacity for 
leadership. 

These elements suggest on the one hand the nature of various modules or 
blocks of knowledge in which a first-line supervisor should be trained, and 
on the other hand certain critical aspects of his relationships both with 
workers and with senior supervision. The Commission strongly believes 
that the competence, morale, and leadership of the first-line supervisor is 
crucial to the effectiveness of the internal system of direct responsibility for 
the performance of work which is the foundation for accident prevention. 
Leadership throughout this internal system is the force that binds it to- 
gether. It takes form through the delegation of responsibility, the confer- 
ring of complementary authority, and the exercise of these elements. 
Through its hearings and investigations the Commission is concerned to 



173 Accidents and injuries 

have noted that the morale of shift bosses may be undermined by senior 
supervisors, both through their unresponsiveness to reported anomalous 
conditions and through downgrading his authority by their intervening in 
his area of responsibihty. Such indications lead the Commission to place 
singular emphasis on the need in mining operations for clear communica- 
tion and understanding within the internal system of direct responsibility 
for work. 

THE TRAINING OF SUPERVISORS 

Not all the companies submitting briefs to the Commission addressed the 
question of training of supervisors. Of those that did comment on the 
subject, attention was directed to the expansion of the working knowledge 
of the supervisor in specific aspects of the company operations, personnel 
policies, identification of hazards, development of personal skills, and so 
forth. Reference was also made to the use of programs offered by the 
MAPAO and directed chiefly to the fundamentals of environmental controls 
and of accident prevention. Some companies incorporate courses de- 
veloped by the American Management Association dealing with principles 
of work administration, supervisory techniques, and personal skills. 

From the Commission's limited study of supervisory training it is appar- 
ent that there are great differences between companies in what is being 
done. Supervisors questioned on the subject indicated both strongly 
favourable and unfavourable feelings about the effectiveness of their train- 
ing. This situation means that supervisory training may suffer from such 
limitations as the following: 1/ lack of relevance to the organization struc- 
ture as it is understood by the first-line supervision; 2/ inconsistency with 
attitudes of management and senior supervision as these appear to the 
first-line supervisor; 3/ obscurity in the manner or means whereby the 
chain of responsibilities is integrated; 4/ incompatibility between the 
theory of supervision and experience in practice. 

A programme of supervisory development will have much more mean- 
ing if it emanates from the top of the organization in clear statements of 
policy and philosophy for the conduct of operations, and if the training 
aspects include active involvement by management and senior supervision 
as the sources of insight into the functions of occupations and the duties of 
office, such as those outlined above and in Table 51. In this way the 
objectives of management would be identified and the desired means for 
attainment would be made evident in explanations of procedure by senior 
management and in demonstration by example. 



174 The health and safety of workers in mines 

WORKING ALONE 

In the hearings of the Commission the labour unions expressed concern 
about the risks undertaken by persons working alone while relatively 
remote from co-workers in underground operations. There are situations 
for which the Mining Act requires that the work be conducted by more than 
one person. These include blasting and work in enclosed tanks in plants. "^^ 
Working and undertaking risks while alone is a common human experi- 
ence. Farming and logging are two activities in which many persons work 
alone. The latter has higher fatality risks than underground mining. After 
studying the evidence available for our mines the Commission cannot 
recommend that working alone be proscribed. However it is concerned to 
ensure that management's inherent responsibility to assign properly 
qualified workers to work alone is meticulously exercised. 

Under current standards of supervision, persons working alone may be 
visited not more than once every four hours, or once per shift other than at 
the start of the shift. The record of fatalities for the past decade among 
persons working alone has been reviewed in Tables 40-4. There is sample 
evidence in Table 43 that a disproportionate number of all fatalities, 
namely, those working alone and not alone, occur among persons with less 
than one year of experience in the company of last employment. The 
Commission therefore recommends: 

That persons assigned to work alone he required to have specified 
qualifications for independent work at the job to which they are assigned. 

By 'specified qualifications for independent work' is meant the second 
category in the system outlined in Table 52 with significant practice in 
performing safely the work assigned. 

A further question is the extent of supervision and of communication 
intended to confirm the well-being of the miner. It is recommended: 

That on all shifts persons working alone he visited at the place of work at 
least three times (other than at the start of a shift) by a first-line supervisor; 

but 

That such visits may be reduced to once per shift (other than at the start of a 
shift) if 1 1 work conditions are standard; and 21 means of communication 
are provided and a record of use thereof is kept so that the person working 



175 Accidents and injuries 

alone reports his status to a point of supervision or to a designated fellow 
worker not less often than onee every two hours. 

Fuilher, the Commission recommends: 

That where the loeation of work is suffieiently remote to warrant the use of 
technical means of communication and where no illumination other than 
that of the miner's cap lamp is normally available, an auxiliary source of 
illumination powered by means other than the miner's lamp battery be 
provided at the workplace; 

That all fatalities and serious injuries to persons working alone underground 
be the subject of biennial review by the Occupational Health and Safety 
Branch. 



THE RIGHT TO REFUSE TO WORK UNDER UNSAFE 
CONDITIONS 

The labour unions have contended that a mine worker should have the right 
to refuse to perform work or to operate a machine when he believes the 
situation or the machine to be unsafe (see n. 18). The word 'unsafe' applies 
both to conditions associated with accidents and to environmental condi- 
tions affecting health. 

This report has emphasized the importance of the capacity of a well- 
audited internal responsibility-system to detect and to correct departures 
from standards in machines, in work procedures, and in conditions at the 
workplace, including environmental conditions. Workers and supervisors 
have a right and a need to know what these standards are, to be trained to 
recognize significant departures from standards, and, in so far as their 
responsibilities extend, to deal with them. It is unconscionable to suppose 
that workers are required to perform work in situations that their super- 
visors suspect to be unsafe beyond the unpredictable characteristics of 
mines, machines, and men. The first responsibility of all persons in per- 
forming work is to maintain prescribed standards, since it is within this 
framework that the bounds of regularly encountered risks are controlled. 
The worker-auditor, the joint health and safety committee, and the mining 
inspectorate exist to keep this system of responsibility alert and responsive 
to departures from standards for the performance of work. 

Within this internal system the one situation requiring further study is 



176 The health and safety of workers in mines 

that of the individual worker or small group of workers active at a work- 
place where an exceptional risk or unsafe condition is deemed to have 
arisen at a particular time during a shift, so that it is believed that work 
cannot safely be performed in a standard manner. The exceptional risk or 
unsafe condition may be related to the workplace and its environment or to 
the machines and devices being used. With respect to machines and de- 
vices the Mining Act makes the following specific provisions under Sec- 
tions 169 (15) and (16): 

( 15) No manager, supervisor or his agent who has reasonable cause to believe that 
any machine or device in or about a mine or plant is unsafe or in contravention of 
this Act shall cause or permit it to be used or operated. 

(16) No person who has reasonable cause to believe that any machine or device, 
which has been assigned to him for use in or about a mine or plant, is unsafe or in 
contravention of this Act shall use the machine or device until he has: (a) reported 
the defect to his supervisor; and (b) obtained specific instructions in writing from his 
supervisor to use or operate the machine or device. 

The need for Section 169 (16) stems from the possibility that a machine or 
device may be unsafe or in contravention of the Mining Act without the 
knowledge of management and supervision. The Commission understands 
that, in application. Section 169(16) may lead to the following outcomes: 1/ 
the judgment of the supervisor is in support of the worker's belief and the 
machine or device is withdrawn from service for repair; 2/ the judgment of 
the supervisor is contrary to that of the worker, the worker is given verbal 
reassurance or written instructions to use or operate the machine or device, 
and he proceeds with one of these forms of reassurance to operate the 
machine or device; 3/ the judgment of the supervisor is contrary to that of 
the worker first assigned to the machine or device, but a second worker is 
assigned to and operates the machine or device and no written instructions 
are given to either the first worker or the second. The Commission, con- 
cerned that under outcome (3) a record of the worker's judgment is not 
recorded, and having argued for improved means by which the judgment of 
workers can more effectively contribute to the operation of the internal 
responsibility-system, therefore recommends a clarification: 

That Section 169(16) (h) he amended (and he inchided in a revised Act, to 
he recommended) to require the supervisor to make a written report which: 
II states the nature of the condition of the machine or device which in 
the worker' s belief renders it unsafe for use; 21 ^ives the supervisor's 
comments at the time; and 31 gives the supervisor's confirmation or other- 
wise that Section 169( 15) is, in the supervisor's view, satisfied; 



177 Accidents and injuries 

That the worker who refers a machine or device to his supervisor under 
Section 169(16) (h) as amended si^n and receive a copy of the supervisor'. s 
report. 

The Commission emphasizes that the invoking of Section 169 (16) (b) as 
amended should be expected to be a relatively infrequent event, but the 
judgments of the worker and of the supervisor, both deemed to be acting 
responsibly, should be reported to the internal responsibility-system as 
information to improve its operations in maintaining machines and devices. 

The provisions of Sections 169 ( 15) and ( 16) apply only to machines and 
devices. There remains the situation in which some other condition at the 
workplace is deemed by a worker to prevent the performance of work in a 
standard manner without the undertaking of unreasonable risk. 

Since the inherent risks in underground mining are higher than in any 
other sector of mining operations, it will be the context of this discussion. 
The shift boss assigns work at the beginning of a shift and subsequently 
visits the men at least once per shift. It is the practice in underground 
mining for all work to stop and consultation to take place about the current 
conditions of work whenever the shift boss visits the workplace. If, when 
the shift boss is not available, a miner judges that conditions, for example of 
ground, have become such that the work assigned cannot be performed in a 
standard manner without undertaking unreasonable risks, it is expected 
that he and his immediate co-workers will await or seek the further guidance 
of supervision and if necessary while awaiting guidance withdraw from any 
place judged to present imminent danger to life or limb. Just as it is possible 
for there to be differences in judgment between a worker and his supervisor 
about the condition of a particular machine or device, it is clearly possible 
for such differences of judgment to exist with respect to the risks of 
performing work under the conditions at a particular workplace, even after 
the normal processes of consultation intrinsic to mining have taken place. 
Nevertheless, it is the responsibility of the shift boss to assign work and to 
decide if the conditions for that work meet standards for its performance. 
In a more open and better audited internal responsibility system the exer- 
cise of the responsibility will continue to be a heavy one. There is, in the 
Commission's view, no substitute for the exercise of this responsibility 
supported by first class training and experience. 

The Commission would expect a substantive difference in judgment 
between a worker and his shift boss about a condition of work to be a 
relatively infrequent event, but since both parties would be deemed to be 
acting responsibly, the work should be visited and judged by a senior level 
of supervision. It is therefore recommended: 



178 The health and safety of wt^rkers in mines 

Tluif where (I worker, after clue eoiisultutioii with his immediate supervisor, 
believes that the work then assii^ned eaiuiot he performed by standard 
proeediires without eneounterinii personal risks deemed by him to be 
unreasonable, there be a statutory requirement that the work situation be 
examined and jndi^ed by a member of senior supervision in the presenee of 
a worker-auditor aetin^ as an observer and that a report of the eircum- 
stanees be made to the mines inspeetorate by the manager. 

The situations in which the foregoing recommendation would be in- 
voked would by their nature be ones of great tension between the workman 
and his supervisor. The worker has a right in natural justice to be assured 
that a well-considered disagreement in judgment between himself and his 
immediate supervisor about the risks of work can be fairly examined and 
that he will suffer no discrimination for having stood by his convictions. 



1 Jean Surrey. An Annotated Bihlioi^raphyfor Industrial A evident Researeh and Related 
Fields. Labour Safety Council of Ontario, Toronto: Ministry of Labour. April 1969; 
International Labour Office. ///////<^/// Factors and Safety. Geneva: International Occupa- 
tional Safety and Health Information Centre, cis No. 15, 1967; International Labour 
Office, Fncyelopaedia oj Occupational Health and Safety. 2 vols, Geneva, 1971; W.T. 
Singleton, Introduction to Ergonomics. Geneva: World Health Organization, 1972; D.F. 
Jones, Human Factors -Occupational Safety, Toronto: Labour Safety Council of On- 
tario, Ministry of Labour, 1973 

2 J. A. Fletcher and H.M. Douglas, Total Environmental Control, Toronto. 1970 

3 Workmen's Compensation Act, Ontario, Sections 39, 40, 41 

4 Transcript, 1068. 1187-8, 1762 

5 Transcript, 1 125-6 

6 The available Swedish data on the mining industry as a whole does not include all 
reduction plants and therefore cannot be compared to the over-all Ontario figures. 

7 The following sample of us data for underground operations of metal and non-metal mines 
was obtained: 

Number of 
Millions of fatalities 

Calendar man-hours per million 

year worked man-hours 

1973 65.0 0.75 

1974 70.3 0.68 

These figures are about twice Ontario figures for the same years. Source: mesa Safety 
Reviews, Metal and Non-metal Mine Injuries Fourth Quarter and Summary 1974. 
Washington dc: us Department of the Interior, Mining Enforcement Safety Administra- 
tion, March 1975 

Over-all comparative data for mining fatalities in Japan, Canada, Sweden, and the usa 
were tabled before the Commission by the United Steel Workers of America (Exhibit 99) 
and modified by the insertion of Ontario data by the Ontario Mining Association (Exhibit 
125). The pattern of these data is consistent with the more specific review undertaken by 
the Commission. 



179 Accidents and injuries 

S The delinition of a compensable accident was changed by the Workmen's Compensation 
Board in 1969 from a three-day to a one-day basis. Thus, in 1969 and subsequently , a 
non-fatal accident became compensable when a worker was absent for one or more days, 
rather than three or more days following the day of the accident. The precise definition has 
been given in the text. 

9 For us data on disabling injuries see mhsa Safety Reviews. Metal and Non-metal Mine 
Injuries. A disabling injury is defined as one such that the worker does not return to his 
regular place of work on the day following the accident leading to the injury. For Swedish 
data see Svenska Giuvforeningen. Yrkesskadestatistik Vid Svenska M(dfnf^'ni\(>rAr 1974 , 
Meddelande nr 137, Volym 9, Uppsala, 1975. The definition of a non-fatal injury as used by 
the Swedish Mining Association is formally the same as that used by the Workmen's 
Compensation Board in Ontario. 

10 The annual reports of Her Majesty's chief inspector of mines and quarries in the United 
Kingdom provide an example of what is done in other jurisdictions. 

1 1 See Table d.5 for reference distributions used in comparing observed with expected 
numbers of fatalities. 

12 The analysis to be given for the industry as a whole is based on samples as defined and is 
subject to sampling error. Inferences are drawn only where there is clear statistical 
significance. 

13 Transcript. 1071-2 

14 It is possible that, because older persons with greater seniority prefer not to work at night, 
younger persons are being assigned to the eleven-to-seven shift in numbers larger than 
would be expected on the assumption that the age distribution in the reference population 
is independent of the shift worked. 

15 There are other interesting features of data related to working alone. Thus, while Table 35 
indicates that the frequency of all fatalities is independent of age, the following data 
indicate that the fraction that occur when working alone may be age-dependent. It is not 
possible, however, with the data available to the Commission to determine appropriate 
expected proportions. 

Proportion of fatalities at a given 

Age age occurring while working alone 

<20 0.20 

20-24 0.25 

25-29 0.17 

30-34 0.17 

35-39 0.15 

40-44 0. 16 

45-49 0.33 

50-54 0.18 

55-59 0.38 , 

>60 0.36 

16 Mining Act, Part ix. Sections 605, 606 

17 Paul Malles, The Institutions of Industrial Relations in Continental Europe, Ottawa: 
Information Canada, 1973 

18 United Steelworkers of America, Summary of Proceedings, Canadian Policy Conference, 
Vancouver, May 1974, 18 (Exhibit 84) 

19 United Kingdom, Mines and Quarries Act, Section 123 (l)-(4) as extended by the Health 
and Safety at Work etc. Act 1974, hmso, London, 1975, Sections 2 (4), 2 (5); Sweden. 
Workers' Protection Act and Workers' Protection Ordinance. Ministry of Labour. Stock- 
holm, September 1974, Section 40 

20 Form 216, 'Report of Inspection on Behalf of Workmen,' Under the Mines and Quarries 
Act, HMSO, London 

21 The number twenty-five is intended as a guide and may be adjusted as circumstances 
suggest. A simple calculation will indicate that the direct cost to the company in wages of a 



180 The health and safety of workers in mines 



worker-auditor system is about one-quarter of 1 per cent of payroll. The current direct 
assessment for compensable injuries and industrial disease by the Workmen's Compensa- 
tion Board on Class 5, the bulk of which is represented by the metal and non-metal mines, 
is at an average level of 6 per cent of gross payroll. The budget of the Mines Engineering 
Branch of the Ministry of Natural Resources, which provides mine inspection, currently 
represents less than 0.5 per cent of gross payroll for Class 5. 

22 The Tripartite Committee on Training in Mining set up by the Manpower Training Branch 
of the Ministry of Colleges and Universities in September 1975 is a suitable vehicle for 
initiating a task group w hose responsibility it would be to devise a training programme for 
worker-auditors. The Commission proposes that the training programme be funded and 
administered by the Occupational Health and Safety Authority, whose functions are 
defined in chapter 6. This task group should have membership from the Occupational 
Health and Safety Authority, the Mines Inspection Branch, the industry, and labour. The 
assistance of colleges of applied arts and technology and of the universities should be 
sought. The programme should be available to persons such as safety stewards designated 
by labour unions on a fee-paying basis to be agreed on. 

23 The Mining Act, Sections 604 and 605 

24 A representative review of one major union's experience is given in A Histoiy of Steel- 
workers' Action for Occupational Health in Ontario Minin^^, United Steelworkers of 
America, District 6, January 1976 

25 Mr Justice Roach , Report of the Royal Commission on the Workmen's Compensation Act, 
Toronto, 1950; His Honour Judge P.J. McAndrew, Report of the Royal Commission on 
Industrial Safety, Toronto, 1961 ; Mr Justice McGillivray, Report of the Royal Commis- 
sion in the Matter of the Workmen's Compensation Act. Toronto, 1967 

26 Workmen's Compensation Act, Toronto, Section 86 (7) 

27 Collective Barf>ainin^ Agreement Between International Nickel and the United Steel- 
workers of America, ]u\y 1975; this agreement provides for such innovative features as an 
Occupational Health Research Study Group funded by the company. 

28 The following references provide examples of current codes of practice and working 
experience in other jurisdictions: Occupational Health Committees Code of Practice. 
Occupational Health and Safety Division, Saskatchewan Department of Labour, 
November 1973; Works Safety Committees in Practice -Some Case Studies, Ministry of 
Labour, United Kingdon, hmso, 1968 

29 Brief 139,23d 

30 Brief 139, Section f 

31 Transcript. 1067-71 , 1 102; International Labour Office, 5(^(/V/y Training for Underground 
Mineworkers, Geneva: ilo Occupational Safety and Health Series. 1968, chap, iv. Metal 
and Non-Metal Mines 

32 The Mines Engineering Branch prepares annual summary reports on hoisting accidents. 
The following table summarizes a sample of data from these reports: 





Total 

number of 
accidents 


Proportion of total 
attributed by cause 








Calendar 

year 


Improper 
functioning 
of equipment" 


Error of 
hoistman 


Other 

human 

error 


Unknown 


1971 
1972 
1973 


77 
56 
43 


0.57 
0.57 
0.23 


0.34 
0.10 
0.26 


0.09 
0.25 
0.51 


0.08 



o Including poor maintenance and improper procedures 



181 Accidents and injuries 



33 Mining Act, Section 163; I/andhook oJ'Trdininii in Mine Rescue (ind Rciovcrx Operations 
1973 , Ministry of Natural Resources, Hth eel. 

34 In the twenty-six years from 1947 to 1973 there were 4()1 underground fires and 279 fires on 
surface. Rescue crews and/or their specialized apparatus worked underground in 96 of 
these. One lile was lost due to asphyxiation. 

35 Task Force on Industrial Training, 1 raininf^ for Ontario's future. Toronto: Ministry of 
Colleges and Universities, Manpower Training Branch, 1972. This report provides an 
historical review of the role of the provincial government in industrial training and makes 
extensive recommendations, reference to which will be made below. 

36 Transcript, 1163, 1322, 1415, 1482, 1512, 1658,2706,3098 

37 Census of Canada, 797/, Catalogue 94-731, vol. iii, Pt 3, Bulletin 3.3-4, June 1975 

38 Brief 5 1,21 

39 Brief 17, appendix F, 8-12. This system, introduced in 1965, appears to have stimulated the 
interest of the then Department of Labour (Ontario) in miner-training programs through its 
Industrial Training Branch. wSee also Brief 9, I. and Brief 67, 20-1. 

40 Bnef 52, 14-21 and appendix 8. See also n. 36 and General Advisory Committee on 
Industrial Training, Report Toronto: Department of Labour, 1968. 

41 The Ministry of Colleges and Universities, Manpower Training Branch, maintains a 
master file of the new training modules for mining and for other industrial fields. Typical 
titles related to drilling are: 



Module number 
06-08-003-3 



06-08-008-1 



03-02-006-3 



Title 
Drill rock 

Operate dril 
(Jackleg) 



Fasten rockbelts 
and anchors 



Performance objective 

To be able to collar 
and drill holes in rock 

To be able to assemble 
and operate jackleg 
drill, and to mount 
steel 

To be able to fasten 
rockbolts and anchors 
safety and securely 



42 The adoption of the modular system of accredited training in the smaller and particularly 
isolated mining operations poses serious difficulties. Innovation through district co- 
operation and the provision of itinerant instructors are possibilities. The Commission 
emphasizes that the classroom is not a substitute for the mine for the great majority of 
training. 

43 Brief 105 and Exhibit 102 

44 Brief 132 and Exhibit 129, 4, para. 5 

45 Mining Act, Sections 305 (7), 218 (6) 



Other environmental hazards at the 
workplace 



In the preceding chapters studies of silicosis and dust, of lung cancer and 
ionizing radiation, and of accidents at work have been undertaken in some 
detail. The purpose of this chapter is to survey briefly the status of health 
problems arising from chemical agents and from the physical agent noise^ 
and to examine how the responsibility-system has dealt with these prob- 
lems. 

There is no simple basis for classifying the immense range of biological 
effects of chemical agents. However, some of their acute and chronic 
effects may be distinguished. Acute effects result from sudden or short- 
term intense exposure to agents encountered under accidental circum- 
stances. Chronic disease may result from sustained exposure to levels far 
below those which produce acute effects. Depending on the particular 
agent, acute or chronic effects may be fatal. 

Conditions underground have been discussed at some length in other 
parts of this report, but little has been said about the nature of hazards in 
concentrators, hydrometallurgical plants, smelters, and refineries.^ Fig- 
ures 14 to 18 provide simplified flowsheets for the processes that are 
characteristic of the reduction of ore after it is hoisted. "^ In each diagram, 
representative sources of chemical and physical hazards are listed. Present 
metallurgical plants in Ontario must be operated, and new plants must be 
designed, to enable products to compete in international markets. The 
Commission has been advised that representative new metallurgical plants 
in Scandinavia, the United States, and Japan are achieving major im- 
provements in occupational conditions. There is no reason to believe that 
comparable plants in Ontario are inferior to their counterparts, although 
conditions in older plants are inferior to those in newer ones. 



83 Other environmental hazards 



mine ore 



COARSE 
CRUSHER IC^'* 



VIBRATING 



SCREEN 




CRUSHING 



VIBRATING 
SCREEN 
unde 
size 

FINE 
ORE 

BINS 




water 



BALL 
MILL 



I GRINDING 
CLASSIFIER 



reagents 



under 
size 



FLOTATION CELLS 




concentrates- 
FILTER 



CONCENTRATION 



tail ings 
to disposal 




concentrates 
to smelter 



POTENTIAL SOURCE OF HAZARDS 

Moving equipment, conveyor 
belts present particular 
hazards, falling rock, heavy 
equipment to be handled, 
noise, flying chips, dust and 
large particles can cause 
tripping hazards and radiation 
from uranium ores. 



Dusting, slides of material, 
moving equipment, slippery 
spillage, noise. 



Slippage on floors, chemicals 
in solution, noise, dusting, 
reagent handling and pre- 
paration prior to addition, 
slow moving equipment 



FIGURE 14 Crushing, grinding, and concentration 



184 The health and safety of workers in mines 



concentrate 



DUST 
COLLECTOR 



or limestone 



DUST 
COLLECTOR 




CHARGE 
PREPARATION 



PRIMARY 
SMELTING 



POTENTIAL SOURCE OF HAZARDS 

Hot equipment surfaces, 
fuel and oxygen risks, hot 
and noxious gases, dusting, 
noise, pressure vessels, 
such as waste heat boilers, 
and hot calcine. 



Temperatures increase, 
example - 2000OF (IIOQOC) 
or higher, molten products, 
danger of breakouts and 



slag to disposal 



DUST 
COLLECTOR 



Smelting Furnace) water explosions, oxygen 
used at various pressures, 
high strength off gas. 



CONVERTER 
rude metal 



matte 




reducing 
agents 



FIRE 
REFINING 



-=3iti: 



STATIC MOLDS or CASTING WHEEL 
I 



I 



SECONDARY 

SMELTING 

(Converter) 



CASTING 



Transfer of molten materials, 
gas leakages, spray and 
spills of molten materials. 



Splash or spills of molten 
materials, movement of 
heavy casting, slow moving 
machinery, water hazards. 



solid metal or matte 
to refining 



FIGURE 15 Smelting of concentrate 



185 Other environmental hazards 



concentrate 

I binder 




PELLETIZING 




+3/8" green 
pellets 



DRYING 
HARDENING 
& 
COOLING 



INDURATING 

SYSTEM & 

COOLER 



fired pellet 



^exhaust gases 
to atmosphere 



PRODUCT 
BINS 



PRODUCT 
HANDLING 



^c^ 4 >^ 



'product to steel mills 



POTENTIAL SOURCE OF HAZARDS 



Dusting and fumes due 
to draft created by 
pelletizer, slippage 
on floors. 



Temperatures increase 
to 2400OF (13150c), 
slow moving equipment 
is deceptive and dusting, 



Product is still hot 
350OF (1800C), water 
cooling produces steam, 
spillage endangers 
footing and dust. 



FIGURE 16 Agglomerationof iron ore concentrate 



186 The health and safety of workers in mines 



off gas. 



DUST 
COLLECTOR V 



reagent 



commonly 
sulphuric acid 



water 




concentrate 

U 



ROASTER 



CHARGE 
PREPARATION 



LEACH 
TANKS 
4 heat 



LEACHING 



solution 




as: 



solids to 
disposal 



reagents 



i iresidues PURIFICATION 

i PURIFICATION :- ► AND RECOVERY 

! I to recovery aitu klluvlm 

I iof by-products 



. 



reagents or 



electric power 
— I 

i 



RECOVERY 



I 



I 



POTENTIAL SOURCE OF HAZARDS 



Hot equipment surfaces, 
fuel and oxygen risks, hot 
and noxious gases, dusting, 
noise, pressure vessels, 
such as waste heat boilers, 
and hot calcine. 



Strong chemicals in large 
volumes, such as sulphuric 
acid, ammonia, etc. ; 
solution spills can cause 
hazardous floor conditions 
and contaminate the atmos- 
phere, fumes resulting 
from leaks, and foaming. 



Same as listed for leaching 
with added hazard that 
dangerous gases may be 
generated, example, arsine, 
hydrogen, etc., residues 
can contain significant 
concentrations of potentialy 
hazardous elements such as 
arsenic and cadmium. 



final product 



FIGURE 17 Hydrometallurgical treatment of concentrate 



187 Other environmental hazards 



starting 
anodes sheets 



electrolyte 



r 



ELECTROLYTIC 
CELLS 



anode 
si imes 



cathodes 



steam, reagent 
electric power 



i. 



lELECTROLYTIC 
iPURIFICATION 






REFINING 



L.- 



T 



by products & 
waste impurities 



jPRECIOUS METAL, 
jRECOVERY plant! 

i i 



r 



PRECIOUS METALS 
RECOVERY. 

(where applicable^ 



precious metals 
to market 



^Q 



MELTING 
FURNACE 



al loying 

metals 

& reagents 

r 



fuel or 
electric power 



CASTING 



water 
L._— JJ cooling 

I— ...- 



CASTING OF 
REFINED METAL 



^^^^^ 



1^ 



I I 

cathodes final shapes 

To Market 



POTENTIAL SOURCE OF HAZARDS 

Handling heavy anodes and 
cathodes, hot corrosive 
solutions and electric 
arcing. 

Toxic reagents and poisonous 
gases from electrolyte 
purification. 



Heat, fumes, corrosive 
solution, some of which 
are relatively exotic. 



Noise, high temperatures, 
molten metal splash, and 
slow moving equipment. 

Toxic fumes such as carbon 
monoxide, lead, arsenic, 
etc. , dust, explosions 
from water or moisture. 

Handling of loads from 
4000 lbs. (1800 kg) up 
in weight. 



FIGURE 18 Electrolytic refining of metals 



188 The health and safety of workers in mines 

THE RECORD OF CHEMICAL AGENTS AS TOXIC 
SUBSTANCES 

Chemical agents acting as toxic substances form a subclass of all hazardous 
materials, which include flammable, explosive, corrosive, and radioactive 
materials. Toxic substances occur in the form of dusts, fumes, mists, 
liquids, vapours, and gases. In normal operations they are encountered 
underground as blasting fumes and in the exhausts of drills and diesel 
engines. In reduction or metallurgical plants they occur as process dusts, 
fumes, and gases such as nickel oxide, sulphuric acid, and sulphur dioxide 
and as liquids and vapours associated with hydrometallurgical flotation 
agents and process solvents. In addition, many different chemicals are 
handled in the course of supplying reagents to processes and in servicing 
equipment through lubrication, cleaning, repairing, painting, and so on. A 
complex variety of toxic substances may be generated as chemical reaction 
products when different materials are welded. If chemicals are spilled at or 
leak into workplaces they may react in unintended ways with other materi- 
als, especially at high temperatures. Explosions and fire generate unex- 
pected toxic products. 

Toxic substances may be absorbed into the body through the skin, by 
ingestion into the gastrointestinal tract, and by inhalation into the respira- 
tory system. The majority of these substances are eventually excreted from 
the body in a chemically different form, but some do accumulate. Toxic 
substances produce a great variety of biological effects, ranging from 
reversible tissue damage to severe systemic effects which interfere with 
normal body functions and may be fatal. Because many toxic substances 
are inherent to industrial activity, including mining, there have been exten- 
sive efforts made to determine permissible levels of human exposure, 
expressed for example as Threshold Limit Values (tlvs)."* In Table 53 are 
listed TLVs for representative gases and vapours and for dusts, fumes, and 
mists. A substantial number of these are the causative agents currently 
involved in injuries from the inhalation of a toxic material, from contact 
dermatitis, and from contact burns. The occurrences of such injuries will 
be considered. 

To establish the status of such effects in the population of mine workers 
the Commission first reviewed all fatalities for the decade 1965-74, and the 
records of the Workmen's Compensation Board for all non-fatal medical 
aid and lost-time compensable injuries attributed to acute inhalations and 
contact dermatitis for the three-year period 1972-4. Of the 213 fatalities in 
mines for the decade 1965-74, five, or about 1/40 of the total, were caused 



189 Other environmental hazards 

by toxic effects. Three were cases of asphyxiation in underground opera- 
tions, of which one was caused by carbon monoxide and lack of oxygen in a 
highly localized fire and two were caused by oxygen deficiency in poorly 
ventilated locations. Of the remaining two, one was caused by acid burns 
and the other by flash burns from magnesium. 

The substances involved in non-fatal inhalation of toxic materials are 
listed in Table 54 in order of most frequent occurrence together with 
representative circumstances of encounter. Although the locations of the 
incidents within the different sectors of operations are varied, the largest 
number of events occurs in reduction plants including concentrators where 
toxic substances are inherent to the operation of processes as depicted in 
Figures 14 to 18. Yet it is a matter of concern that the inhalation of blasting 
fumes accounts for nearly one-third of all events.*^ Blasting practices are 
clearly at issue. Further, it is surprising to note in the brief from the Canada 
Centre for Mineral and Energy Technology that adequate funds have not 
been available to permit research to be actively pursued on the generation 
of fumes from explosives so that quantitative requirements for ventilation 
to remove blasting fumes could be accurately established. Table 54 shows 
that many toxic substances besides blasting fumes contribute to inhalation 
injuries. In round figures the average number of compensable inhalation 
injuries over the three years 1972-4 was 11 per annum and the number of 
medical aid cases was 26 per annum. The compensable injuries are thus 
about one-third of the total of compensable and medical aid injuries. The 
compensable injuries involved a total lost time of 159 days per annum and 
the average duration of lost time for these injuries was 14.5 days. 

Contact dermatitis denotes inflammatory reaction of the skin to some 
external agent acting either as a primary irritant or as an allergic sensitizer. 
The manifestations of occupational dermatitis in mining have been re- 
viewed by Rogan.^ In Table 55 is a list of the substances involved in contact 
dermatitis, ranked in order of the number of events, together with rep- 
resentative circumstances of encounter. Caustics and acids, nickel, 
cyanide, and arsenic are the major agents associated with dermatitis. 
Substances producing dermatitis may either wet the skin directly or be 
airborne. In round figures, the average number of compensable cases of 
contact dermatitis has been 7 per annum, and these have accounted for 198 
days of lost time per annum or 28 days per case. The number of medical aid 
cases averaged 12. Thus, as with inhalations, the number of compensable 
injuries is about one-third of the total of compensable and medical aid 
cases. 

The Commission has also examined the records of the Mines Accident 



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197 Other environmental hazards 



TABLE 57 

Non-fatal compensable injuries: proportion resulting from acute encounters 
with toxic chemicals 





Non-Fatal Compensable Injuries Per 
Million Man-Hours 




Sector of 
operations 


Injuries from 
toxic chemica 
(1) 


Is" 


All compensable 
injuries'' 

(2) 


Ratio (l)/(2) 


Underground 
Shops md surface 
Reduction plants 

All 


0.5 
0.2 
1.9 

0.7 






66.9 
16.5 

41.2 

44.9 


1/134 

1/83 

1/22 

1/64 



a Data from Table 56 with one man-year being two thousand hours 
b Data from Table 42, where 'alP includes open pits as well as the categories 
shown in this table 



Prevention Association for compensable injuries produced by acute en- 
counters in which toxic chemicals are ingested, enter the eyes, or produce 
chemical burns of the skin.^ The average number of events per annum 
during 1972^ for each of these problems is noted in Table 56. The greatest 
frequency is in eye injuries caused by chemicals in reduction plants. 
Greater attention ought to be paid to the meticulous use of eye protection in 
all operations.^ 

The occurrence of all non-fatal compensable events attributed to toxic 
substances by location is summarized in Tables 56 and 57. For all locations 
the average number of such events per year is 46.2. The total of non-fatal 
compensable injuries and medical aid cases per annum is expected to be 
about 150, or three times the number of compensable cases. Table 57 
shows that 1 in 134 injuries underground is related to toxic chemicals. In 
shops and surface units the number is 1 in 83 injuries, and in reduction 
plants it is 1 in 22 injuries. All the cases reported were clearly ascribable to 
the categories used. But because of inherent difficulties in classifying 
injuries there may be some underascertainment of injuries that should be 
classified here as being caused by toxic substances. The Commission 
believes that the round figures 1 in 120 for underground, 1 in 75 for shops 
and surface, and 1 in 20 for reduction plants are reasonable indicators of the 
direct involvement of toxic chemicals in lost-time injuries arising from 
acute encounters at the workplace. There is some evidence that medical 



198 The health and safety of workers in mines 

aid cases occur approximately twice as often as do compensable injuries. 
There are undoubtedly many other incidents with chemicals that involve 
temporary discomfort, irritation, or annoyance which do not require the 
services of an attending physician or involve loss of time at work on a day 
following the incident and hence are not included in the records of the 
Workmen's Compensation Board. 

An examination of the circumstances of encounter in Tables 54 and 55 
will suggest that the kind of subpopulation of workers at risk is substan- 
tially less than the total number of workers. The risk of a given type of 
injurious acute encounter with toxic substances cannot readily be esti- 
mated without an accurate knowledge of patterns of v/ork. These tables 
also show that the variety of chemicals involved is large, and in view of the 
many different effects they may have on a person it is not surprising that 
workers have expressed concern about the possibility of damage to health, 
about the care with which they are identified and handled, and about the 
adequacy of information about the hazards involved in their use.^ 

THE CONTROL OF TOXIC SUBSTANCES 

Chemical agents are inherent in the production and refining of metals. They 
occur as normal products of chemical reactions, as reagents added to 
processes, and as substances used in the construction, servicing, and 
repair of equipment and processes. They become most dangerous during 
unanticipated leaks and spills, when additional products of unexpected 
chemical reactions may appear as a result of fire, explosion, and so on. 

About both potential risks and actual events it is desirable to have 
knowledge of 

- the kinds and amounts of substances that can be expected to be present 
at a given place of work under normal and upset conditions; 

- the hazards to human health of each substance and as far as possible all 
toxic combinations thereof, including Threshold Limit Values or their 
equivalent; 

- the available means and standard practices for limiting the presence of 
toxic substances; 

- the kinds, amounts and concentrations of substances that are actually 
present at the workplace at any time; 

- the persons who are likely to encounter the substances at work; 

- the frequency and duration of intervals at which these persons may be 
expected to be at risk; 

- the exposures actually experienced by persons at risk; 



199 Other environmental hazards 

- the medical procedures for assisting a person who experiences an acute 
encounter; 

- the occupational history of persons subject to acute exposures; and 

- the developing state of health of exposed persons. 

The mining industry lacks complete information on all these points. The 
provisions of the Mining Act'^ are general and incomplete, and to the 
Commission's knowledge no relevant codes of practice have been issued 
by the Mines Engineering Branch to guide the inspectorate, the industry, 
and the workers on these matters. Major reliance has been placed on the 
self-regulatory character of the internal responsibility-system. 

The metallurgical plants present the greatest ongoing risks from chemi- 
cal agents and so deserve particular attention. The issues to be considered 
are the development of metallurgical audits, codes, and schemes of prac- 
tices and the training of workers. 

METALLURGICAL AUDIT 

It is essential to know the quantity of known hazardous substances present 
in a mining operation at any given time and to know how the substances 
enter the operations and how they leave it. Knowledge of this kind consti- 
tutes an audit of material which is usually on the basis of mass. It is 
standard practice in the operation of metallurgical plants (reduction plants) 
to conduct by careful sampling and analysis an audit of the origin, holdup, 
and destination of the major chemical elements and compounds involved in 
valuable products. The Commission has been advised that a metallurgical 
audit is increasingly important with respect to minor elements that may be 
injurious to the health of workers. Metallurgical plants have as inputs 
crushed and ground ores, water, heat, and reagents as shown in Figures 14 
to 18. As the processes operate, substances leave the system as metal 
products containing impurities, tailings from processes, and the washdown 
of spills. They leave fixed in slags or in various bleed streams vented to the 
external environment through ventilation stacks, louvres, and chimneys. 
These bleed streams may contain dusts, fumes, gases, steam, and so on. 

In addition to the major elements, the internal metallurgical system will 
contain at any given time a holdup mass of minor elements such as lead, 
arsenic, selenium, tellurium, cadmium, and antimony. The levels of these 
toxic elements depends on the bleed and effluent streams in use. As 
external environmental standards of air pollution have been made more 
rigorous and recovery objectives for valuable products have been raised, 
traditional bleed streams have increasingly been recirculated to the internal 



200 The health and safety of workers in mines 

metallurgical processes. As a consequence the relative amounts of differ- 
ent toxic minor elements may increase or decrease significantly at different 
locations in the system because of buildup or unexpected losses. The 
potential risks from leakage and spills from process units into locations of 
work may therefore change significantly, and the changing risks may not be 
recognized if a metallurgical audit of minor elements is not carried out. The 
Commission therefore recommends: 

That there be a statutory requirement for a metallurgical audit of origin, 
holdup, and destination of potentially dangerous compounds of minor 
elements such as lead, mercury, arsenic, selenium, tellurium, cadmium, 
and antimony to he conducted quarterly in all reduction plants on the basis 
of extended standard monthly sampling and analytical procedures and 
that a copy of this audit be sent to the Occupational Health and Safety 
Authority. 

The purpose of such an audit is to alert management to any significant 
changes in the distributions of minor elements that require further investi- 
gation. In addition to this audit it is recommended: 

That there be a statutory requirement for an annual audit of use by mass of 
toxic and hazardous reagents and that a copy be sent to the Occupational 
Health and Safety Authority. 

The intent of such an audit is to identify significant changes in the scale of 
use of reagents. For example, the use of solvent extraction methods has led 
to the presence of large masses of flammable substances. While the poten- 
tial hazards are clearly recognized, there should be a record of their 
changing presence. 

When new metallurgical plants are being designed using pilot plants it is 
desirable that the conventional programme be expanded to measure factors 
which may have an impact on the working environment. The character and 
content of fumes, dusts, and intermediate products should be analysed 
with particular emphasis on minor elements. The resulting information 
may be used for designing ventilation systems and establishing preliminary 
operating procedures and safety standards for a commercial-scale plant 
whose development may take from three to eight years. The Commission 
therefore recommends as a practice of occupational health assessment for 
new plants: 

That pilot plant studies used to develop processes and preliminary operat- 



201 Other environmental hazards 

//?,i,' procedures he extended to include the niecisurenient of ju( tors likelx to 
have an impact on the health and safety of the environment for work. 

The Ministry of Health in its brief to the Commission has indicated its 
intent to conduct occupational health assessment studies for new plants 
and major revisions to existing plants in co-operation with industry and 
related ministries." The Commission strongly endorses this policy and 
believes that it should be given a statutory basis in the manner described in 
chapter 6. 

CONTROL OF THE USE OF REAGENTS AND 
SERVICING CHEMICALS 

For these substances there are questions of labelling, storing, procedures 
for use and cleanup, and treatment in the event of acute encounter. The 
Mining Act contains the following general provisions: 

199 Any dangerous, flammable or explosive material or substance in a solid, liquid 
or gaseous state or any combination of them, other than manufactured explosives 
and blasting agents, that is kept, stored or handled, in a plant, 

(a) shall be kept in a container that is suitable having regard to the nature and state 
of the material or substance; and 

(b) shall be kept apart or insulated from any reasonably foreseeable source of 
ignition or from temperatures likely to cause combustion; 

and where the material or substance is kept, stored or handled for a purpose other 
than immediate use, it shall be kept, stored or handled. 

(c) outside any building; 

(d) in a building not used for any other purpose; or 

(e) in a fire-resistive compartment satisfactory to the district mining engineer as to 
location and construction. 

222(1) At every plant where poisonous or dangerous compounds, solutions or 
gases are used or produced, there shall be kept in a conspicuous place, as near the 
compounds, solutions or gases as is practicable, a sufficient supply of satisfactory 
antidotes and washes, and there shall be installed eye wash fountains and. where 
necessary, safety showers, for treating injuries received from such compounds, 
solutions or gases. 

(2) Such antidotes and washes shall be properly labelled and explicit directions for 
their use affixed to the boxes containing them. 

223( 1) Where an acid or poisonous compound or any other material that is likely to 
endanger the health of an employee is produced, transferred, used or stored in a 
plant, due provision shall be made to reduce to a minimum the hazard of handling or 
storing such material. 



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203 Other enviionnicntal ha/ards 

(2) Where the provisions taken under subsection I do not lemove the hazard, 
personal protective equipment shall be worn by the person exposed to the hazard. 

(3) Where such material is piesent, there shall be posted in a conspicuous place, 
when so required by the chiefengineei", notices stating the dangers involved and the 
precautions to be taken. 

(4) Where required, the employer shall provide the chief engineer with accurate 
information regarding the percentage of any harmful ingredient in such material. 

(5) Any person who, foi use in a plant, manufactures, distributes or purchases any 
material that contains benzol, carbon tetrachloride, lead or other ingredient that is 
deemed dangerous to health by the chief engineer, shall indicate the presence of 
such ingredient by a label lettered in legible type, distinctly visible and affixed to 
each package or container thereof. 

(6) The chief engineer on the advice of the director of the Environmental Health 
Branch of the Department of Health, may require at specified intervals by qualified 
physicians and at the expense of the employer a physical examination of any person 
employed in a plant having a process that the chief engineer considers is likely to 
endanger such person's safety, and the physician shall forthwith send or cause to be 
sent to such director a report of the examination in a form suitable to the chief 
engineer. 

(7) The examination required under subsection 6 shall be prescribed by such 
director and may include an x-ray examination and blood or other tests. 

These sections deal in a general manner with storage, antidotes, wash 
facilities, handling, posting of information about dangers and precautions, 
provision of information by the employer to the Mines Inspectorate, label- 
ling, and medical surveillance. The Mines Engineering Branch has issued 
no codes of practice in these matters. 

The MAPAO first issued in 1969 a brochure listing properties of airborne 
contaminants in reduction plants and began issuing standard forms for 
recording information about hazardous substances in 1974. The introduc- 
tion of formalized programmes of control of hazardous substances in the 
industry appears to have been relatively recent.'^ An example of an infor- 
mation sheet for a toxic substance as prepared for hazardous material 
control is given in Table 58. Some companies have issued booklets on 
reagents and chemical hazards to all employees at particular plants.'-^ 
Further, the Ministry of Health has recently commissioned tripartite task 
groups to prepare guidelines for the labelling and handling of the 
chemicals.^"* Their reports identify the basic elements of these problems. 

The variety and amount of substances in use as servicing chemicals is 
growing rapidly. Believing it is important for each company to maintain a 
register of such chemicals currently in use, showing both trade name and 
chemical formula, the commission recommends: 



204 The health and safety of workers in mines 

That there he ci statutory requirement for each mining company to main- 
tain a re^i^ister of servicing' chemicals involved in any personal encounter 
associated with a medical aid or compensable injury; that the register 
specify both trade name and chemical composition and identify all known 
toxic chemical constituents; that the register include an audit by mass of 
annual use; and that a copy of this register be provided to the Occupational 
Health and Safety Authority; 

and further 

That there be a statutory requirement for each mining company to give the 
Occupational Health and Safety Authority notice of intent to introduce any 
new reagent or servicing chemical whose toxic characteristics are not 
known. 

. The Occupational Heahh and Safety Authority should have the statu- 
tory power to require the analysis of any chemical substance in use and 
biological testing for toxicity. 

CODES AND SCHEMES OF PRACTICE 

For the control of chemical agents the Commission believes that schemes 
of practice, as referred to in chapter 2, are very important. '-*^ Knowledge of 
these should be included as part of the training of all who operate and 
maintain metallurgical processes. A review of Tables 54 and 55 will confirm 
that maintenance workers are commonly involved in injuries from toxic 
substances. Maintenance workers employed on diverse process units 
should have a clear understanding of the hazards of each operation in which 
they are assigned to intercede and therefore should have access to and 
knowledge of codes and schemes of practice. Worker-auditors, members 
of the Joint Health and Safety Committee and of the Mines Inspectorate, 
and the workers directly involved should all have access to the appropriate 
schemes of practice. The Commission thus recommends: 

That with respect to codes of practice and schemes of practice the princi- 
ples of recommendations 8, 9, and 10 [as listed in appendix a] be extended 
J I to the maintenance and operation of mills and metallurgical plants as 
these activities relate to the leaking and spilling of toxic substances and hot 
materials into workplaces; 21 to the handling and use of reagents and 
servicing chemicals and to the consequences of their leaks and spills. 



205 Other environmental hazards 

Schemes of practice should provide relevant information about the risks 
of acute encounter with toxic substances. They should outline standard 
practices for avoiding and controlling leaks and spills and for cleaning up 
when they occur. Further they should give explicit instructions on how to 
assist any person who experiences an acute encounter likely to cause 
injury. 

EDUCATION AND F RAINING FOR THE DESIGN AND 
OPERATION OF METALLURGICAL PLANTS 

The Commission believes there is need in the education of metallurgical 
engineers and related disciplines to strengthen concern for, and control 
over, the impact of processes on persons at work. In a survey of engineer- 
ing schools in the province the Commission found no instance of an 
established active interplay between engineers and occupational health 
specialists in faculties of medicine, although recent initiatives are evident 
at McMaster and Toronto. It is recommended: 

That engineering schools review and redefine their responsibility to the 
profession to ensure that graduates are more keenly aware of and respon- 
sive to the impact of technological design upon the occupational health 
and safety of workers; 

That resources for joint research and teaching by specialists in occupa- 
tional and environmental health in faculties of medicine and engineering 
be given high priority by both the universities and government. 

The broad issue of training and supervision of workers has been ad- 
dressed in chapter 4; the principles of co-ordination for the performance of 
work outlined there apply specifically in the operation of metallurgical 
plants. 

Because of the dynamic complexity of metallurgical plants there is 
special need for a high degree of co-operation, communication, and techni- 
cal understanding between employees, supervisors, managers, and techni- 
cal staff if the systems are to operate efficiently and safely. There is a much 
larger measure of dynamic interdependence than in the sequentially separ- 
able operations of underground mining. On the basis of its hearings and 
investigations, the Commission is of the view that the authority and re- 
sponsibility of the first-line supervisor is not always sufficiently well 
defined to enable him clearly to exercise his duty to identify and to ensure 



206 The health and safety of workers in mines 

the correction of anomalous working conditions. This point has been 
discussed in chapter 4. 

In the handling of interactive metallurgical processes all employee 
groups need to have training in both theoretical and practical aspects of the 
operations for which they are responsible. Such training is necessary to 
create capacity to 1/ inteipret operating and test data correctly; 2/ recog- 
nize hazards in abnormal conditions arising out of the interactive charac- 
teristics of the processes; 3/ cope with unusual conditions that arise. 

Existing training programmes vary from employer to employer, tending 
to restrict themselves to very specific functions and not to cover the 
broader interactive aspects of the processes; nor do they supply a great 
deal of the theoretical background required to interpret data and to cope 
with abnormal situations. The worker thus may not have the knowledge to 
reach beyond day-to-day occurrences on the job. To improve the circum- 
stances of training the Commission strongly endorses the modular schemes 
of training being operated in certain metallurgical plants'^ and, emphasiz- 
ing the recommendations in chapter 4, encourages the development of 
provincially accredited systems of modules. The Commission believes 
there is a need to develop a set of modules based on the hazards of specific 
toxic substances, a set that can be combined to match the sequence of risk 
situations that a maintenance worker may be expected to encounter. The 
Commission therefore recommends: 

That profiles of risk-encounter for toxic substances he developed by ex- 
amining the work patterns of maintenance workers, and that modular 
training be adapted to such profiles. 

MONITORING AND MEDICAL SURVEILLANCE FOR 
ACUTE ENCOUNTERS WITH TOXIC SUBSTANCES 

So far the problems of toxic substances have been treated in terms of acute 
encounter. Acute encounters and chronic exposures call for complemen- 
tary processes of monitoring and medical surveillance. The special re- 
quirements for chronic exposures will be discussed at the end of this 
chapter. Although accidental acute encounters cannot by their nature be 
monitored, the Commission recommends: 

That at any location of regular work where acute encounters with toxic 
substances repeatedly occur as a result (f leaking, recirculating, or spilling 
from metallurgical and milling processes, there be a statutory requirement 



207 Other environmental hazards 

for the installation and use of equipment for the continuous tnonitorint^ of 
the substances involved: 

That a record of the substances and human effects of acute encounters 
with toxic substances leading to medical aid and compensable injuries he 
maintained in the occupational health records of each worker at the 
company level; 

That at five-year intervals the Occupational Health and Safety Branch 
commission a review of the status of the health of samples of persons who 
are at high risk from acute encounters with toxic substances, including as 
necessary intensive medical surveillance. 

The need and responsibility for central occupational health records 
necessary for epidemiological studies for both acute and chronic exposures 
to toxic substances will be discussed after the following review of evidence 
of chronic effects. 

THE EFFECT OF CHRONIC EXPOSURE TO TOXIC 
SUBSTANCES 

The chronic effects of a few substances, such as free silica and lead, are 
relatively well known, but for the great majority of chemical agents used at 
the workplace today there is scant data available upon which to establish 
accurately the range of their long-term effects on humans. Documentation 
for Threshold Limit Values is based on experiments with animals, on 
evidence of acute effects observed in the exposure of persons at work, and 
on long-term studies. Studies of the latter type based on reliable measure- 
ments of toxic substances, clearly delineating the effects of a specific agent, 
and in particular separating the effects of smoking are relatively few in 
number. This area of study is a major frontier in environmental and occupa- 
tional health. The Commission believes that the issues related to the 
recognition, prevention, and compensation of chronically induced indus- 
trial disease are becoming centrally important in occupational health. At 
the same time it is to be emphasized that, in mining, disabling and fatal 
accidents cause far greater loss in immediate human well-being than do the 
industrial diseases currently recognized for compensation. 

It has been noted that the air breathed at workplaces in mines and plants 
typically contains combinations of such toxic substances as mineral dusts 
and sulphur dioxide or mineral dusts and diesel fumes, and the majority of 



208 The health and safety of workers in mines 

workers smoke cigarettes. Moreover, diseases such as lung cancer and 
chronic bronchitis, some cases of which are believed to be attributable to 
industrial exposure, occur commonly in persons not exposed in mines and 
mineral plants. Hence, even with well-founded data collected at the work- 
place there is substantial difficulty in discerning the influence of a particular 
agent on the population at risk and extreme difficulty in identifying the 
cases resulting from work exposure. The complex problems of ascribing 
disease to industrial workplaces at which combinations of contaminants 
occur can be placed in some perspective by reviewing briefly the investiga- 
tions conducted by the Ministry of Health in identifying industrially in- 
duced diseases and the record of compensation provided by the 
Workmen's Compensation Board. 

The Workmen's Compensation Act defines industrial disease as fol- 
lows: "industrial disease" means any of the diseases mentioned in 
Schedule 3 and any other disease peculiar to or characteristic of a particular 
industrial process, trade or occupation.''^ The Board's authority to com- 
pensate derives from the following sections of the Act. 

1 18(8) If the employee at or immediately before the date of the disablement was 
employed in any process mentioned in the second column of Schedule 3 and the 
disease contracted is the disease in the first column of the Schedule set opposite to 
the description of the process, the disease shall be deemed to have been due to the 
nature of that employment unless the contrary is proved, but, except where the 
Board is satisfied that the disease is not due to any other cause than his employment 
in Ontario, no compensation is payable under this section unless the employee has 
been a resident of Ontario for the three years next preceding his first disablement. 

Under this section, a defined schedule'^ of disease conditions related to 
specified substances and processes is accepted automatically as constitut- 
ing industrial disease. Silicosis caused by silica dust is covered by Schedule 
3; diseases such as chronic bronchitis and emphysema are not. 

118(1) Where an employee suffers from an industrial disease and is thereby dis- 
abled or his death is caused by an industrial disease and the disease is due to the 
nature of any employment in which he was engaged, whether under one or more 
employments, the employee is or his dependents are entitled to compensation as if 
the disease was a personal injury by accident and the disablement was the happen- 
ing of the accident, subject to the modifications hereinafter mentioned or contained 
in the regulations, unless at the time of entering into the employment he has wilfully 
and falsely represented himself in writing as not havingpreviously suffered from the 
disease. 



209 Other environmental hazards 

Under this section the Board is free to render interpretive judgments on 
what is to be recognized as an industrial disease. To assist it in performing 
this role, the Board has an advisory medical staff which maintains close 
liaison with occupational health and industrial hygiene specialists in the 
Ministry of Health, with the Ministry of Natural Resources, and with 
industry. 

In the following analysis the record of the performance of the 
responsibility-system in responding to problems of identifying and attribut- 
ing diseases caused by chronic exposures and in dealing with the concomi- 
tant issues of records and research in occupational health is critically 
important. 

CANCER OF THE RESPIRATORY SYSTEM 

In Table 59 is a record of the cases of cancer among workers in mines that 
were compensated by the Workmen's Compensation Board up to 
November 1975. Of 178 cases, eighteen were cases of lung cancer attri- 
buted to uranium mines. In chapter 3 it was estimated that in these mines to 
the end of 1974 there has been an excess of observed over expected cases of 
lung cancer of about forty-five. ^^ A further twenty-two cases of lung cancer 
were attributed to a silver and cobalt-oxide refinery in which arsenic 
trioxide was one of the by-products. Epidemiological evidence for an 
excess of lung cancer in the operations of this refinery was provided by the 
then Department of Health in 1958.^^ The refinery ceased operations in 
1961. Because of the distribution of latent periods associated with lung 
cancer, compensable cases continue to appear in the population at risk. 
Two cases were compensated in 1974. In 1974, the first case of lung cancer 
attributed to an asbestos mine was compensated.-^' The person involved 
had had exposure in the asbestos mining industry in Quebec prior to 
working in Ontario. 

By far the largest number of cases of lung cancer have been attributed to 
processes in nickel reduction plants. There have been ninety-eight of 
these, and a further thirty-nine cancers of the nasal cavities. Of the total of 
137 cases, thirteen were compensated in 1974, and, among these, seven 
were cases of cancer of the nasal cavities. Compensation for the foregoing 
cases of cancer was initiated in response to epidemiological evidence 
reported by the staff of the Department of Health in 1958,- 1967,-' and 
1969.^"^ All of the metallurgical processes to which the cases have been 
attributed were phased out of the operation in the period 1958 to 1962. 
Compensable cases, as indicated above, continue to appear in the popula- 



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2 1 1 Other environmental hazards 

tion of workers at risk. A recent major review of the medical and biological 
effects of nickel and its compounds contains a section on nickel car- 
cinogenesis among workers in Wales, Canada, Norway, and Russia. ^^ I his 
section contains a concise summary of experience in Ontario. With respect 
to reduction plant operations in the Sudbury area it states: 

at the same smelter | referring to reference n.241 in Copper ClitT. dining the years 
1950-67, there was no excess mortality from respiratory cancer among workers in 
nickel-converter operations who were exposed to intermittent high concentrations 
of metallic dusts and sulfur dioxide. At two additional sintering plants in the 
Sudbury region, which are engaged in processing nickel sulfide ore, there have been 
no cases of cancer of the nasal cavities and only a few cases of lung cancer. At these 
two plants, sintering is performed at a lower temperature, and the product contains 
18-22% sulfur. 

Therefore it appears that the identified causes of cancer from nickel opera- 
tions have been removed. 

Of the operational sources of cancer identified to date in the mining 
industry, continuing risks, other than those generated by past exposures in 
operations now closed, certainly exist in the uranium mines and the asbes- 
tos mines. The problem in the uranium mines has been dealt with in chapter 
3, and recommendations will be made for surveillance of workers in asbes- 
tos mines. However, it is natural that workers should be concerned that 
there may be as yet undetected consequences of past chronic and acute 
exposures in the industry. 

The epidemiological studies by the Ministry of Health have contributed 
essential evidence for the protection and compensation of mine workers. It 
is regrettable that it has not been government policy to release these studies 
in full or in summary form upon their completion. Workers have an intrin- 
sic right of access to information about the risks inherent in work. If society 
is not made aware of the consequence of risks at work, the government 
itself cannot render wise judgment on the acceptability of current risks. 
There have been too few epidemiological studies of workers in mines 
because resources for occupational health in the Ministry of Health have 
been woefully inadequate within a health-care system which spends mas- 
sive sums on curative services but little on prevention. The Commission 
believes that resources for occupational health deserve a far higher priority 
than they have been given, and a basis for such a higher priority will be 
recommended in chapter 6. It is essential that significant health hazards be 
anticipated as well as responded to. The Commission here recommends: 



212 The health and safety of workers in mines 

That epidemiological reviews of selected populations subject to chronic 
exposure to toxic substances in reduction plants and mines matched to 
suitable control groups be conducted on a five-year cycle by or under the 
guidance of the Occupational Health and Safety Branch and that the 
essential results of such studies be summarized and published upon com- 
pletion. 

Certain suggestions for the subject of such studies are subsequently made. 
The Ministry of Health in its brief has outlined a number of important areas 
for work. 

The Commission understands that the Ministry of Health has been 
receiving from the nickel-producing companies reports on deaths occur- 
ring among employees and pensioners and that these records are reviewed 
periodically. The Commission commends these procedures and will make 
a recommendation for the incorporation of such data on a selective basis in 
a central system of occupational health records. Further, the Commission 
notes that inco Ltd and the United Steelworkers of America have recently 
entered into an agreement to establish under company funding a Joint 
Occupational Health Study Program, 'for the purpose of developing a 
better understanding of the working environment ... through independent 
industrial health surveys and research in connection with potential occupa- 
tional illness and disease. ^^ The Commission commends this new evidence 
of constructive co-operation between labour and management. 

Among the toxic substances occurring in reduction plants, nickel car- 
bonyl has attracted the particular concern of workers because of its ex- 
treme toxicity. ^^ Reference has already been made to acute encounters 
with it. The concern here is with the possibility of it inducing cancer. There 
is some evidence that the inhalation of nickel carbonyl can produce cancer 
in rats^^ but the conclusiveness of this evidence has been questioned. ^^ The 
Commission has found no conclusive epidemiological evidence in the 
literature that nickel carbonyl is or is not a carcinogen under the current 
conditions of human exposure. Sufficient time has not elapsed for there to 
be any epidemiological evidence from the new nickel refinery at Copper 
Cliff. 

The following circumstantial evidence has been cited concerning cancer 
of the respiratory system in nickel refining in Wales. ^^ In Wales, where 
nickel carbonyl has been a process product since 1902, an excess of cancer 
of the lung and nasal cavities was confirmed in epidemiological studies 
conducted in 1939, 1958, and 1970. The studies of 1958 and 1970 provided 
some evidence of the stages of the process to which the excess of cancer 



213 Othci environmental hazards 

could be attributed. The latest study states as follows: 'The epidemiologi- 
cal evidence in their reports (Morgan, 1958; i3oll, 1958) strongly suggested 
that the risk was associated with the preliminary steps of the process 
preceding the formation oi' nickel carbonyl and that the risk has been 
eliminated from the industry by process changes in Britain by 1925/-*' A 
further appreciation has been given in a recent report of the International 
Centre for Cancer Research at Lyon: 

Although the exact natuie of the carcinogenic agent in nickel refining is iinknoun. 
the cancer hazard has been associated with the earliest stage of refining uhich 
involves heavy exposure to dust from relatively crude ore (Doll, et a!.. 1970). Ihe 
view that nickel carbonyl is alone responsible has been discounted due to the 
disappearance of cancer risk despite continued use of the carbonyl process after 
1925 in South Wales and due to the detection of an excess risk of respiratory cancer 
in refineries using the electrolytic and not the carbonyl process in Canada (Mas- 
tromatteo, 1967) and other countries.^- 

In the light of this evidence and as a means of ensuring the earliest 
possible detection of any health risks from nickel carbonyl, the Commis- 
sion recommends: 

That a nominal roll of workers at risk of exposure to nickel carbonyl in 
reduction plants and pilot plants he estahlished hy the Occupational 
Health and Safety Authority in co-operation with the industry and that the 
morbidity and the mortality experience of this nominal roll be reviewed at 
least every five years. 

OTHER RESPIRATORY DISEASES 

Asbestosis 

Asbestos, which is distinctive by being separable into filaments, is both 
fibrogenic and carcinogenic when inhaled as dust in human populations. ^"^ 
A recent review by Health and Welfare Canada states that 'no concentra- 
tion of asbestos can be specified at this time that affords no carcinogenic 
risk.'^'* As with ionizing radiation, the issue of standards is one of risk 
acceptance. Its fibrogenic effects are reflected in asbestosis, a form of lung 
disease characterized by a slowly progressive, pulmonary fibrosis whose 
stages can be identified by the radiographic methods used for detecting 
silicosis. The latent period for the development of asbestosis may be 
twenty or more years. Asbestos dust may also induce lung cancer and 
mesothelioma, a form of malignant tumour of the membrane that enfolds 



214 The health and safety of workers in mines 

the lungs or the abdominal cavity. The latent period for the development of 
mesothelioma may be over twenty-five years. The risks of cancer for 
asbestos workers who smoke cigarettes are many times greater than those 
for non-smokers. ^'^ 

The asbestos mined in Ontario is of the chrysotile type. The mining 
operations have accounted for about 2 per cent of Canadian production of 
asbestos and about 0.4 per cent of employment in the mines in Ontario. The 
operations involve open pit extraction accompanied by mills. The first case 
of lung cancer to be charged to an Ontario asbestos mine was compensated 
in 1974 (see n.21). The first case of asbestosis to be charged to an Ontario 
asbestos mine was compensated in 1975.'*^ There has been some produc- 
tion of asbestos in Ontario for over thirty years; the total employment in 
these operations was 225 in 1950, 254 in 1960, and 200 in 1970. Because of 
fluctuations in operations and short-term labour turnover it is difficult to 
know how many persons have been subject to exposure. 

The Mines Engineering Branch has not issued any code of requirements 
for dust measurement in the asbestos mines, although written instructions 
have been issued from time to time by the engineers of the Branch. The 
Ministry of Health, at the request of the Mines Engineering Branch has 
periodically taken dust surveys. The voluntary system of dust measure- 
ment introduced by the Mines Accident Prevention Association in 1959 
was not, and has not been, applicable to the asbestos mines (or to the salt 
mines). 

After the Ministry of Natural Resources adopted the standard of 2 fibres 
per cubic centimetre of airborne dust in 1975, one mine closed down. A new 
mine whose mill began operating in 1976 was closed on an order of the 
Ministry of Natural Resources because of dust conditions in the mill; this 
operation is currently coming back into production. 

The director of the Mines Engineering Branch has stated that workers in 
dust-exposed occupations in asbestos mines have not been exempted from 
the requirement for a Miner's Certificate under the Mining Act, so that 
standard radiographic chest records of the working population comparable 
to those for miners exposed to silica-laden dusts have been accumulated at 
the chest-examining stations of the Workmen's Compensation Board (and 
Ministry of Health). 

The Commission believes that the small Ontario asbestos mining opera- 
tions have not been subject to adequate review and recommends as follows 
with the intent of invoking the principles of recommendations already 
made with respect to silicosis and to lung cancer in the uranium mines: 



215 Other cnvironnicnlal ha/aids 

r/uil the (ippropridlc suhstamc or intent of rcconinK'/uldlions S. 9, 10, J9 
(2), 40, 42, and 46 \(i.s listed in (ippendi.x \| he nuide (ipf)li( ahle to dshestos 
Diines (ind pUuits. 

These recoFiimcnclations call tor the application ol'codes otpractice and 
schemes of piactice for ventilation and dust control, for the engineering 
monitoring of dust and ventilation, for the specification of dust levels at 
which, first, corrective action must be taken and. second, closure o\' a 
workplace is required, for the sample monitoring of personal exposures 
and for smoking to cease among exposed workers. 

To ensure the assessment of all available evidence of health impairment 
among the population that has been and is at risk, the Commission recom- 
mends: 

That the Occupational Health and Safety Authority establish, with the 
co-operation of the Workmen's Compensation Board and the minini^ in- 
dustry, a nominal roll of all persons who have worked one or more months 
in exposure to asbestos dust in the asbestos mines and plants; 

That the Occupational Health and Safety Branch commission a review of 
the radiographic record and of the mortality experience for the asbestos 
nominal roll on a five-year cycle. 

Since there is no clear evidence that a threshold level of asbestos dust 
exists below which there is no risk of cancer, the Commission does not, for 
the reasons cited in chapter 3 on lung cancer and ionizing radiation, 
recommend work adjustment procedures that would lead to an increase in 
the total population at risk. However, if the risks of disabling asbestosis 
arising from the fibrogenic property of asbestos dust in mining populations 
can be shown to be very much greater than the risk of malignant tumours, 
then a work adjustment policy similar to that outlined for silicotics in 
recommendations 21, 24, 25, 26, 27, and 30 may be worthy of considera- 
tion. The Commission's endorsement of a work adjustment policy for 
silicotics in uranium mines is based on the evidence that the risk of silicosis 
is much higher than the risk of attributable lung cancer. With asbestos dust, 
as with ionizing radiation, the essential need is to minimize exposure by the 
rigorous control of the carcinogen. 

The evidence through 1975, namely, one case of lung cancer and one 
case of asbestosis, both compensated in persons at or past retirement age. 



216 The health and safety of workers in mines 

one of whom had a significant part of his exposure to asbestos outside the 
province, is too slim to be indicative of the future development of cases in 
the mines in Ontario. 

Ch ronic hroiu h it is 

Of the lower respiratory tract diseases, none affects more workers than 
chronic bronchitis, an inflammatory condition of the bronchi which in a 
chronic state may be defined as the presence of a cough productive of 
phlegm on most days for a period of one year or longer (see n.46). Em- 
physema, which may be associated with chronic bronchitis, involves an 
anatomical change in the lungs characterized by enlargement of the air 
spaces beyond the small bronchioles with destruction of the air sac walls 
and by shortness of breath." The labour unions have stated their concern 
that much of the prevalence of chronic bronchitis and related obstructive 
lung disease may be attributable to exposure to airborne contaminants. 

Chronic bronchitis is not recognized by the Workmen's Compensation 
Board as being an industrial disease under the definition of the Act. The 
Commission's understanding of the Board's policy is as follows: if a person 
has an industrial disease such as silicosis or asbestosis and the condition is 
aggravated by the presence of other disease conditions such as chronic 
bronchitis, the Board may increase the level of disability assigned for 
purposes of determining the amount of wage compensation. Further, if 
there is clear evidence that chronic bronchitis or emphysema existed prior 
to employment in work involving prolonged exposure to irritants such as 
welding fumes, sulphur dioxide, acid fumes, and so on, and the work has 
induced periodic aggravation of the pre-existing condition, the Board may 
consider a claim on the basis of aggravation. Finally, if the onset of chronic 
bronchitis can be traced to a single acute exposure to a respiratory irritant 
the Board may allow a claim. The Board does not allow claims based 
simply on extended encounter at work with airborne toxic substances 
where there is no specific ground for attributing to such exposure the 
condition of chronic bronchitis on which the claim is based. As with lung 
cancer in the uranium mines, the Board might allow a larger number of 
claims if there were sound epidemiological evidence for an excess of the 
disease over that which is to be expected in appropriate comparison popu- 
lations. 

The epidemiological evidence related to the exposure of Ontario mine 
workers to sulphur dioxide and metal dust and fumes, and to mineral dusts 
and diesel fumes, will now be briefly reviewed. The levels of dust exposure 
underground were reviewed in chapter 2. Table 60 provides representative 



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218 The health and safety of workers in mines 

average dust measurements by konimeter in surface reduction plants. The 
higher dust levels are in iron plants and nickel plants."*^ 

Following the identification of an excess of lung and nasal cancer in a 
CopperCliff sinter plant in 1969. the then Ontario Department of Health, in 
co-operation with the nickel producer, conducted a comparative study of 
the morbidity and mortality experience of samples of workers in a mine and 
in three distinctive sections of operations in a reduction plant located at 
Copper Cliff. This study indicated that 

for lower Respiratory Diseases there was a statistically significant increase in 
reported absences [from work] among the Converter men ... Most of the excess 
occurred in men with 25 years or more of service ... The average duration of Lower 
Respiratory Disease absences in the Converter men was essentially equivalent to 
that expected. The findings suggest that employment for 20 years or more in the 
Converter department is associated with an increase in the frequency of lower 
respiratory diseases, but without any increase in severity. ^'^ 

From the four types of work locations studied the converter area was 
selected to entail distinctive exposure to sulphur dioxide, metal fume and 
dust. A follow-up report by the Ministry of Health has recently been 
completed. ^^' In this report the prevalence of chronic bronchitis, as deter- 
mined subjectively through a standard questionnaire, is indicated to be 1 in 
4.4 among 310 converter workers and 1 in 12.8 among the 64 refinery 
workers used as a comparison group. The prevalence of chronic bronchitis 
among Ottawa males in the ages 25 to 64 is about 1 in 12."*' The foregoing 
difference between the prevalence for converter workers and that for 
refinery workers is stated to be statistically significant. Lung function tests 
(see explanation in n. 40) also revealed statistically significant differences 
between converter workers and refinery workers. For both, the symptoms 
of chronic bronchitis occurred almost entirely among smokers and former 
smokers. Measurements at fixed locations for total dust and for sulphur 
dioxide, averaged over a shift and the locations, indicated a mean value of 
about 2.4 milligrams per cubic metre of total dust and about 2.5 parts per 
million of sulphur dioxide. The current tlv for sulphur dioxide is 5 parts 
per million. The appropriate tlv for the dust depends on the chemical 
analysis. A value of 7. 5 mg/m^ has been set for another smelter. These data 
for Ontario are comparable to recent results for workers in a us copper 
smelter."*^ There is contrary evidence for the effects of a combination of 
sulphur dioxide and dust when studied among workers in all departments in 
two British steel works. "^^ 

Evidence of this kind raises questions about the adequacy of control of 



219 Other environmental hazards 

exposure to toxic substances, the appropriateness of cui rent ii vs/'* and 
the legitimacy o( compensation. Regarding the latter the Commission 
recommends: 

Tluit workers in reduction pUints who have been exposed for twenty years 
or longer to sulphur dioxide at levels approaching^ the current threshold 
Limit Value and to associated dust and fames, and who exhibit the clinii dl 
diagnosis of chronic bronchitis and impaired pulmonary function as 
identified by objective tests, be considered for compensation at up to a 
maximum of 20 per cent disability. 

The Commission recognizes that, to use the words of Gilson. in the 
individual it is very rarely possible to apportion, even approximately, the 
contribution of each of the many factors responsible for the severity of 
occupational bronchitis or the altered lungfunction/"^*^ As with lung cancer 
among uranium miners, this fact begs the question of how compensation 
might be made. 

When there is obtained in Ontario statistically significant evidence of an 
excess of chronic bronchitis in a particular subpopulation of Ontario mine 
workers compared to an appropriate control group of Ontario mine work- 
ers, the Commission believes the Board should consider the compensation 
in keeping with the nature of the evidence as it becomes available and is 
altered by planned epidemiological reviews. In the absence of knowledge 
that would allow the clear attribution of individual cases, it is necessary to 
establish an arbitrary basis for compensation the motivation of which is to 
render to the workers as a whole a measure of rough justice. The recom- 
mendation made is of this character and the limit of 20 per cent disability is 
related to the character of the disease. The toxic substances encountered at 
the workplace may be considered to be the ultimate involuntary aggravat- 
ing factor in the disease. Individual compensation in such circumstances is 
not based on scientific knowledge other than epidemiology but on public 
policy. The alternative of a 'hazard' increment in wages for the group at 
excess risk is in the Commission's view less defensible. The essential need 
is to reduce the exposure of the workers to the aggravating contaminants. 

Concerning a possible relation between chronic bronchitis and mineral 
dust (with diesel fumes as an added factor for some subpopulations) there is 
some evidence from the Elliot Lake uranium mines. The study of under- 
ground and surface workers conducted by the Ministry of Health in 1974 
revealed the following.'*^ In the study population of 707 persons who 
worked underground, one in 7.6 reported symptoms of chronic bronchitis. 



220 The health and safety of workers in mines 

while the prevalence among the remaining population of 266 who worked in 
dusty surface and mixed surface dust and underground exposure was one 
in 9.2. The prevalence for all workers as a group was one in 8.3. The 
differences between these groups is not large and is not notably higher than 
the prevalence of chronic bronchitis among Ottawa males in the age group 
25 to 64. Statistical analysis of both chronic bronchitis and of lung function 
parameters indicated that the occupational environment plays some role."*"^ 
The dominant factor was smoking. Over a wide range of ages the preval- 
ence among smokers was about three times that among non-smokers. The 
prevalence in both groups increased with age by several times. There is 
strong evidence, therefore, that the prevalence of chronic bronchitis 
among all mine workers could be reduced by a large factor if cigarette 
smoking ceased. The Commission's recommendation to uranium miners to 
cease smoking to lower risks of lung cancer applies with equal force to all 
workers to lower risks of chronic bronchitis. 

Although the separate effects of mine contaminants, smoking, city air 
pollution, and socioeconomic factors on the prevalence of chronic bron- 
chitis among hard rock miners are not clearly established, there is persis- 
tent evidence from other jurisdictions that miners exposed to dusts have 
more respiratory disability than the comparison groups used and that the 
effects are related to dose. The differences are about twofold. "^^ 

There is need for more extensive epidemiological research on the prev- 
alence of chronic bronchitis in Ontario mines and plants. It is suggested 
that a major study of dust-exposed underground workers, dust-exposed 
surface workers, and non-dust-exposed surface workers be undertaken 
and that smokers and non-smokers be examined in each group. The Elliot 
Lake review did not permit a clear separation of these groups. Further, the 
prevalence of chronic bronchitis among subpopulations of workers in the 
iron reduction plants and other nickel smelters should be compared with 
that in suitably matched control groups. In the event that such epidemiolog- 
ical studies, suitably matched between comparative populations of under- 
ground, reduction plant, and surface workers, reveal a statistically 
significant excess of chronic bronchitis in Ontario mines and plants, the 
Commission would recommend that the provisions of the recommendation 
relating to sulphur dioxide, metal fumes, and dust be extended to the 
workers among whom the excess occurs. Underground mine workers in 
South Africa are currently compensated for obstructive lung disease in the 
absence of silicosis."*^ 

Diesel fumes are one of the possible factors in the induction of chronic 
respiratory disease whose role requires elucidation. The recent study of 



221 Othci environmental hazards 

respiratory conditions among workers in the uranium miners where some 
are exposed to diesel fumes and some are not observes: 

The total number of persons with chronie bronchitis was not large in relation to the 
number oi men in the study | i 18 out of 973]. Moreover, on dividing these into 
subgroups the small numbers make valid judgements difficult. Despite these con- 
siderations and after having made allowance for age and smoking habits, there was 
no evidence from the available data to indicate that the use of diesel powered 
equipment at Denison Mine has an identifiable adverse effect. ''" 

The Commission is aware of little epidemiological evidence dealing 
directly with the effects of diesel fumes on the mortality of miners.^' One 
recent us study of mortality experience among mine and mill workers in 
eight potash mines, two of which have used diesel engines as the major 
energy source for underground transportation,^^ gives the following ap- 
preciation: 

To explore the possibility of effects of exposure to diesel exhaust on mortality, the 
underground potash cohort was subdivided on the basis of which men had worked 
(and when) in these two mines and the life table method was again used to determine 
expected deaths. There were 31 deaths in 6733 person years. Except for violent 
deaths, no major cause of death exceeded expectation among men who worked in 
the diesel mines. No causes of death were significantly different between miners 
who worked in dieselized mines and those who worked in other mines. It may be 
noteworthy that the 'other respiratory disease' category which was high among 
underground workers was not different between diesel and non-diesel workers. 
However, there may have been insufficient elapsed time since the start of diesel 
usage for chronic or long latent period diseases, such as emphysema and lung 
cancer, to be manifested as excess deaths in the relatively small exposed group. 

There is a need for further epidemiological review of possible effects 
from the use of diesel engines, which came into use in Ontario about 1950 
and are now widely used. The Commission urges that such a study be 
included among the epidemiological reviews that the Occupational Health 
and Safety Branch conduct or have conducted.''^ 

Under Section 213(9) of the Mining Act, internal combustion engines 
may not be used underground without permission in writing from the chief 
engineer of the Mines Engineering Branch. Gasoline-burning engines have 
never been permitted, but equipment driven by diesel engines has been 
approved on a unit-by-unit basis, provided that each unit and the condi- 
tions surrounding its use satisfy a Code of Requirement the current version 
of which was issued in 1973.'^'* This code specifies the maximum permis- 



222 The health and safety of workers in mines 

sible levels of aldehydes, carbon dioxide, carbon monoxide, and nitrogen 
dioxide in the atmosphere adjacent to the engine. It also specifies the 
minimum amount of ventilating air required and the maximum sulphur 
content of the fuel oil and sets out certain general requirements related to 
fuelling, exhaust scrubbing, operating, maintenance, and record-keeping. 

Complaints from the labour unions have centred on alleged defects of 
maintenance both of the diesel engines themselves and of the equipment 
driven by them and upon alleged excesses of diesel fume contaminants in 
air breathed in the presence of the equipment. 

While diesel equipment has been introduced with considered care into 
Ontario mines, the Commission believes that there are instances in which 
maintenance is inadequate and in which more equipment than is proper 
becomes concentrated in particular work locations. Diesel control maps 
which clearly specify zones of operation should be well understood by 
supervisors, operators, workers, and worker-auditors. To ensure strong 
emphasis on the basic problems of the use of diesel engines, the Commis- 
sion recommends: 

T/uit the Occupational Health and Safety Authority, in co-operation with 
the industry and labour, prepare a code of requirements for diesel emis- 
sions; 

That the Mines Inspection Branch prepare a code of practice for the 
provision of ventilation andfor the fuelling, operation, and maintenance of 
diesel engines; 

That each mine using diesel equipment he required to file with the Mines 
Inspection Branch a scheme of practice for the short-term and long-term 
maintenance of its diesel engines. 

The first two recommendations in effect split the existing diesel code 
into two parts each of which the Commission believes requires elaboration. 
The final recommendation is for a Scheme of Practice, which should set out 
the practices for staging, carrying out, and verifying the state of mainte- 
nance of diesel engines. There has been a substantial co-operative Cana- 
dian research programme related to the latter problem.*'^ 

Diesel exhausts contain an extremely complex combination of gases, 
vapours, and particulates the toxic effects of all components of which are 
not fully understood. "^^ While the Commission has found no epidemiologi- 
cal evidence that diesel fumes are contributing to chronic disease in mine 



223 Othci cnvironmcntul ha/ards 

workers, there has been httle research directed to finding out. The Com- 
mission has recommended that such research be conducted by the Occupa- 
tional Heahh and Safety Branch, and further urges that animal experi- 
ments be conducted to determine the toxic effects of diesci particulates. 
The following toxicological assessment of diesel exhausts has been given: 

Toxicologic evaluation of the numerous components of dicsci exhausts and Ihcir 
probable interactions points to oxides of nitrogen and the oxides of carbon as 
substances posing the greatest threat to health. Smoke, with its adsorbed, partly 
oxidized, and nitrated hydrocarbons, chiefly aldehydes and nitroparaffins. al- 
though constituting an initation and odor problem, actually can contribute to health 
effects by carrying the irritants to the deeper, more sensitive recesses of the lung, 
where they can act to initiate, promote, or accelerate emphysematous, fibrotic. or 
carcinogenic processes. Smoke-adsorbed oxides of nitrogen would be particularly 
notable in this respect. 

Serious major gaps in analytic information still have to be filled before a firm 
toxicologic appraisal can be made, however. Information is needed, among other 
things, on the types and amounts of aldehydes, particularly unsaturated aldehydes, 
whether smoke-adsorbed or free, and whether, and under what conditions polycyc- 
lic aromatic hydrocarbons of the carcinogenic type are smoke-adsorbed. 

From the toxicologic viewpoint, two things can be said with assurance: (I) 
poorly maintained diesel engines will enhance to such proportions all of those 
constituents most hazardous to health and comfort as to require uneconomic 
amounts of ventilation to reduce their levels to acceptable concentrations, and (2) 
underground mine temperatures must be maintained below 80°F if greatly enhanced 
toxicity from unburned hydrocarbons is to be pre vented. "^"^ 

There is a widely held view in the industry that under current conditions 
of operation of diesel engines in underground mines in Ontario the toxic 
substances other than those for which standards have been set are not 
present in sufficient quantities to constitute a significant risk to health. 

HEARING LOSS AND INDUSTRIAL NOISE 

Noise as unwanted sound is familiar to everyone who enjoys the normal 
sense of hearing. Noise-induced hearing loss results from exposure to high 
levels of noise over a prolonged period of time."^^ The onset is slow, 
affecting both ears, and the person is usually unaware of its progression 
until the point is reached where it interferes with conversation. It results 
from irreversible physical damage to the tiny hair cells located in the inner 
ear produced by intense acoustical pressure waves in the ear canal. The 
evidence for this form of sensorineural deafness among mine workers will 



224 The health and safety of workers in mines 



TABLE 61 

Permanent disability awards 
in the mining industry to 31 


at latest settlement for 
December 1974 


hearing loss 


First permanent 
disability award 
in period 


Awards 




Mean Percentage 
of permanent 
disability at 
latest settlement 


N 




% 


1950-4 
1955-9 
1960-4 
1965-9 
1970-4 

Total 

Standard deviation 


1 

4 

7 

69 

540" 

621 




0.2 
0.6 

1.1 
11.1 

87.0 

100.0 


10.0 
5.1 
6.2 
8.4 
8.3 

8.3 

5.9 



NOTE : The 621 cases of permanent disability settled as of 3 1 December 1974 

are distributed by the calendar period in which a permanent disability 

award was first made to each of the persons involved. 

a Of these awards, 213 were first made in 1974 

source: Claims for Industrial Noise Deafness, Mining Industry of Ontario, 

31 December 1974, W.C. Wheeler, Workmen's Compensation Board, 

5 April 1976 



be examined/^ It is a wholly preventable but incurable disease the conse- 
quences of which among persons such as metal smiths, weavers, and 
boilermakers have been recognized for centuries. 

A worker who becomes partially deaf from noise attributable to work or 
other causes may suffer several handicaps. For example, he may be re- 
fused promotion to a job as a cage tender or a hoistman who is required to 
respond accurately to auditory signals. His ability to converse at work and 
at home may be impaired. High noise levels may affect him psychologically 
by causing irritability, mental fatigue, and lessened attention and alertness, 
which may lead to accidents. Society is much less sensitive to a deaf person 
than to a blind person. 

THE RECORD OF HEARING LOSS 



Industrial noise deafness was first recognized as a compensable injury as 
the result of a court decision in New York State in 1944. In Ontario it 
became compensable on 31 March 1947, when the definition of industrial 
disease in the Workmen's Compensation Act was generalized as in Section 



225 Other environmental hazards 

More than one third of all claims for hearing loss received by the Board 
in the decade 1965-74 were from the mining industry.^" Table 6 1 shows the 
burst of permanent disability awards in the past decade. Almost 90 per cent 
of all permanent disability awards settled to the end of 1974 were awarded 
in the five-year period l97()-4. The cumulative direct costs to the end of 
1974 for all permanent disability payments to the 62 1 persons involved has 
been about $3 million, or about $5,000 per disability. These costs include 
capitalization for pensions. Associated with the 621 permanent disability 
settlements in Table 61 , there were 338 medical aid cases and 168 rejected 
claims among all the claims that had been adjudicated and settled to the end 
of 1974. Medical aid cases are now those in which the Board pays for the 
worker the authorized costs of specialized medical consultations about his 
hearing. 

The evidence is clear that cases of hearing loss in the mining industry are 
now being recognized in massive proportions. For reasons related to 
changes in administrative practice for compensation, which will subse- 
quently be explained, a significant number of these cases can be regarded 
as a backlog of pre-existing injury. This fact does not alter the reality that 
men in large numbers have experienced significant loss of hearing in the 
mines. Continuing evidence of this fact can be expected until current 
hearing conservation programmes prove their effectiveness. The percen- 
tage permanent disability figure in Table 61 is the percentage of eligible 
earnings provided to the worker as a pension. The eligible earnings at 
present are 75 per cent of current wages up to a maximum rate of $15,000 
per annum. ^* The disability currently allowed for the complete loss of 
hearing in both ears is 30 per cent.^^ 

To determine how the cases of hearing loss are related to the populations 
in the various classes of mines the distribution of adjudicated claims was 
examined. Table 62 reveals two major anomalies. The first is that hearing- 
loss claims in the iron mines, which are largely open pit, are very much less 
than expected on the basis of the proportion of the mining population 
involved. This evidence suggests that the cumulative noise exposure in 
such operations has been much lower on the average than in underground 
mines. The second is that claims among shaft sinkers are very much higher 
than expected. The latter evidence has been checked by consulting com- 
pany records of the Workmen's Compensation Board. The estimate is, if 
anything, conservative, and is a sad commentary on past conditions of ear 
protection among such workers where the higher levels of noise due to 
drilling are persistent (see Table 63). 

An examination of the occupational histories of a 10 per cent sample of 



226 The health and safety of workers in mines 



TABLE 62 

Distribution of adjudicated claims for hearing loss 
in the mining industry by type of operation 

Claims Claims 

Type of operation observed C^,) expected" (%) 



Diamond Drill 


ing 


1.1 


1.8 


Gold 




29.8 


26.0 


Iron 




1.1 


5.4 


Nickel-Copper 




48.0 


49.0 


Shaft Sinking 




5.6 


1.8 


Uranium 




5.3" 


11.5 


All Other 




7.8'- 


4.5 



a Expected on the basis of the employment in the designated 
type of operation averaged over the decade 1955-64. This 
choice is based on evidence that the majority of allowed 
claims are associated with persons with fifteen years or 
more of employment in Ontario up to the year in which 
their claim is first allowed. 

b The very rapid diffusion of the uranium mining population 
after 1960 probably contributes to an under-ascertain- 
ment of claims attributable to exposure in these mines 
because the compensation is prorated between the mine 
of last employment and the pooled second injury fund 
(see Brief 136, 89). 

c These are mainly the smaller mines for asbestos, mag- 
nesium, nepheline syenite, quartz, silver, and talc. 

source: See Table 61 



all the foregoing cases for which miner's certificate numbers are known 
was conducted for the Commission by the Board. This study showed that 
for approximately 90 per cent the principal employment was underground 
and that about 90 per cent had mine employment in Ontario for fifteen or 
more years at the time of the first allowance of a claim. Figure 19 shows the 
age distribution of the 760 claims first allowed in the period 1970-4.^^ The 
mean of the distribution is 56 years, but a significant number of persons 
experience compensable hearing loss between the ages of 40 and 50 and 
therefore carry a hearing disability as many as 25 years of their working life. 
A person entering mining at 25 years of age would be 40 after an elapsed 
time of fifteen years, which is a sample estimate of the average duration of 
mine employment in Ontario for persons with hearing loss. 

NOISE AND THE R E S P O N S I B I L 1 T Y - S Y S T E M 

For centuries men in certain occupations and their communities have 



227 Other environmental ha/aids 



TABLt: 63 












Typical high noise levels 


in 


mines and 


plants 


near types of equi 


ipnient de: 


signi 


I ted 














Noise level 


Location 










in dB(A) 


Underground 












Crusher 










no 


Fans 










107-110" 


Drills 










115-125 


Scraper 










115 


Open pit 












Drills 










100 


Tractor (in cab) 










108 


Truck (in cab) 










95 


Surface 












Ball Mills 










103 


Cone Crushers 










103 


Copper Refinery, 


Vertica 


[\ Furnace 


102-110" 


Pellet Rolls 










102 


Rod Mills 










96 



a See us Department of the Interior, Hearing Con- 
servation for the Mineral Industry, Bureau of 
Mines Information Circular ic 8564, 13. 
b Ministry of Health survey of furnace operation 
source: mapao surveys except as noted 



simply accepted the fact that some persons became prematurely deaf. 
Despite the fact that industrial deafness became a compensable injury in 
Ontario in 1947, it was not recognized as a real problem in the mining 
industry until after 1960. The following quotations from mine managers at 
the hearings of the Commission indicate the nature of the situation from 
which current deafness injuries have arisen: Trior to 1956 no serious 
attempts were made to design noise out of mining, or to protect employees 
from existing noise ... some workmen, particularly drillers, used a shred- 
ded cotton waste, absorbent cotton or toilet tissue as a makeshift ear 
stopple.'^'* T am talking about '60, '61 and '62 when nobody worried about 
noise, it was just part of the job, the fact that your ears rang when you came 
off the shift was part of the job.'^^ The period during which the mining 
industry became alerted to noise as a problem corresponded to that during 
which a quantitative understanding of damage-risk criteria was being 
clearly established.^^ It has been a slow process to reach the state of 
concern, knowledge, and practice that exists now as the injuries to hearing 
induced in the past are being recognized in disturbing numbers. Among the 



228 The health and safety ot workers in mines 

40 



T3 


$ 

O 

To 

•*- 
o 

Q). 
U) 

(a 

♦^ 
c 

<D 
O 

^. 


Q. 



30 - 



20 



10 - 



Mean 
56 years 



20 



30 



40 



50 



60 



70 and over 



Age 



FIGURE 19 Age distribution of claims for hearing loss first allowed in the period 
1970-4 (Note: total number of claims was 760, consisting of medical aid and 
permanent disability; Source: Table 61) 



causes of injury to workers, noise is unusual in that it can be readily 
measured and the effects it produces on hearing can, in the absence of 
complicating disease and traumatic injury, be measured with some 
accuracy. ^^ The first exploratory noise survey was taken in the mining 
industry by a large company about 1955. Formal noise surveys began in this 
company in 1966. The mapao conducted initial noise surveys and prepared 
noise report forms in 1968. It published a booklet on survey procedures'*^ in 
1973 and has carried out noise surveys for many mines. '^ At the present 
time, 'noise maps' are available in most of the operations in the mining 
industry so that noise conditions have now become reasonably well 
defined. 

What have been the acceptable levels of noise and what levels actually 



229 Othci environmental hazards 

occur? While the Mining Act has provided for management to designate 
areas for the wearing oi"^ approved hearing protective equipment,^" no 
codes of practice regarding the use of such equipment have been issued. A 
code of requirement with respect to allowable levels of exposure to noise 
was first issued in July 1974."^' For a duration per day of eight hours the 
maximum allowable noise level at the ears is 90 decibels ldB(A)| and no 
exposure in excess of 1 15 decibels is permitted (see n.67 for a definition of 
dB(A)). In a noise level of 90 decibels it is difficult to sustain communica- 
tion with another person by shouting from a distance of about one foot 
(mouth to ear).^^ The current (1975) tlv of the American Conference of 
Governmental Industrial Hygienists is 85 decibels for eight hours. The 
MAPAO currently recommends that all areas having an 85-decibel noise 
level or higher be mapped as a hazardous zone. 

Noise levels near operating stationary equipment such as fans and drills 
in mines or crushers and rod mills in plants are relatively stable. Moving 
equipment such as load-haul-dump machines or trucks alter local noise 
levels, and persons riding on vehicles experience a varied noise environ- 
ment usually dominated by the machine they operate. Typical high noise 
levels in mines and plants measured at operator positions or near the 
equipment when in full operation are listed in Table 63."^^ The evidence is 
unequivocal that existing noise levels in mining operations can induce 
serious loss of hearing among workers. As the technological scale of mining 
operations has grown so has the potential noise hazard. Noise is therefore a 
continuing serious hazard to the well-being of mine workers demanding 
hearing conservation programmes of high effectiveness. Such programmes 
involve four elements: 1/ the assessment of noise levels and profiles of 
encounter with noise, 2/ the control of noise sources and of noise exposure, 
3/ the monitoring of noise exposure and the screening of the hearing of 
workers, and 4/ the provision of workmen's compensation and work ad- 
justment. The pui-pose of each of these elements needs to be made clear. 

With respect to the assessment of noise levels and profiles of noise 
encounter it is essential that mining operations maintain noise maps and 
develop fuller knowledge of profiles of noise encounter. The Commission 
recommends: 

That each mining operation maintain noise maps based on full-scale 
conditions of operation which delineate all areas of work at which the noise 
level is 85 dB(A) or higher. 

Many companies are now doing this. Workers, worker-auditors, and the 
joint health and safety committee should have access to these maps. 



230 The health and safety of workers in mines 

Instrument technology exists to determine cumulative effective noise ex- 
posure over a working shift. The Commission recommends: 

Unit the niiiiinii industry, in co-operation with labour and the Occupa- 
tional Health and Safety Authority, have conducted research to determine 
shift-profiles of noise encounter for representative occupations in mines 
and plants both in the absence and in the presence of actual and best- 
available hearini^ protection, that such profiles be codified and published, 
and that a code be assigned to each worker who regularly encounters areas 
of work in which noise levels of 85 dB(A) or higher exist. 

Codification of characteristic profiles of noise encounter can provide a 
basis for specifying the nature of a worker's exposure to noise and provide 
an important element in audiometric records. 

Exposure to noise can be decreased by reducing its generation and 
propagation through the air, and by providing isolation of the ears from the 
onslaught of incident sound waves. Drills are the source of the worst noise, 
and substantial research has been directed at reducing it.^"^ However there 
has been little evidence of a concerted effort on the part of the mining 
industry to establish, in co-operation with equipment manufacturers, 
labour, and government , expected standards of noise generation for mining 
equipment as a whole. ^^ A manager of one of the smaller mines made the 
following observation to the Commission: 'Even though we want mufflers 
on our machines there is very little we can do about it ... We are at the 
mercy of the manufacturers to a large extent. '^^ 

The Commission, believing that the basic responsibility for equipment 
standards rests with the industry and manufacturers, recommends: 

That the mining industry and equipment manufacturers, with the Canadian 
Standards Association, expedite the development of standards for the 
assessment of noise from mining equipment, and for the performance of 
personal safety equipment and cab enclosures in attenuating noise, and 
that such standards be invoked by the industry in specifying noise perfor- 
mance requirements for new equipment. 

The industry is aware that feasible technology is available to reduce noise 
from many kinds of machines not only in primary design but also in 
installation through the use of isolation. Mufflers are specified by many 
companies where they are available. Underground fans, for example, can 
be effectively silenced: the Commission visited a mine in Sweden where all 
fans had been silenced. Need for ready access for maintenance may pose 



23 1 Other environmental hazards 

difficulties in noise reduction. The maf'ao has an important role to play in 
compiling design criteria and case-study illustrations ofgood practice. I he 
Commission understands that this is being done and recommends that such 
information be available to joint health and safety committees, in any 
event, it is unreasonable to expect the worker to bear the full burden of 
excess noise by being compelled unnecessarily to wear ear plugs and muffs 
which may be uncomfortable and irritating. "^^ Ear plugs and muffs add to 
the total kit of personal 'enclosure/ a kit which in its current form leads 
more than a few workers to avoid its meticulous use. The following frank 
statement by a mine manager defines what needs to be done in the design of 
personal equipment: 

You will notice in the last safety report that I leceivcd from the safety supervisor. I 
think of the 12 work crews he saw 8 were not wearing eye protection but were 
wearing ear muffs. When I was Chairman of the Safety Siib-Commitlee of the 
MAPAO we actively tried to get manufacturers to develop a helmet that would 
incorporate hearing protection, head protection and eye protection, all in one unit 
...I believe that the present hard hat, with the add-ons (ear muffs and glasses), it is 
not proper protection and I believe the problem here, we are at the mercy of 
suppliers who say, well if you put out $50,000.00 on the table we will turn around 
and do some research and development.^** 

The recently formed Mining Industry Research Organization of Canada 
has indicated that research on a protective helmet represents one of its 
priorities. The Commission simply observes that the record of eye. ear, 
and head injuries provides an absolute minimum index for determining the 
investment that is justified to achieve improved environmental protection 
of workers through personal equipment and zonal enclosures, such as 
rugged, ventilated, and sound-proofed cabs, which deserve wide applica- 
tion for heavy equipment. However, until technology is available that will 
properly replace or avoid the need for effective ear plugs and muffs, it is 
crucial that management provide them and that workers meticulously wear 
them to preserve their hearing. One of the important issues to be consi- 
dered in the wearing of protective devices is the worker's ability to dis- 
criminate warning signals from noise. The Commission recommends: 

That the Occupational Health and Safety Authority issue a code of prac- 
tice for the selection and use of personal ear protection and for com- 
municating in the presence of noise. 

The Commission urges labour and management to co-operate in achieving 
a thorough discipline in this matter and urges the Joint Health and Safety 



232 The health and safety of workers in mines 

Committees to review the underlying issues of policy and achievement. 

Of all the elements of an effective hearing conservation programme, 
none is more important than the screening of the state of hearing of the 
workers. Among the questions requiring a clear answer are the following. 
What are the goals of screening and who is to be responsible for it? Both the 
MAPAO and the unions have expressed a desire that audiometric screening 
be undertaken at the chest examining stations that provide the x-ray 
examinations required under the Mining Act for the validation of a miner's 
Certificate. The Commission has expressed the view that these stations 
should be capable of carrying out lung function and audiometric testing in 
support of research based on sample populations to be undertaken by or 
under the auspices of the Occupational Health and Safety Authority. 
However the Commission does not believe that these stations should be 
responsible for maintaining massive audiometric records of large popula- 
tions of workers. The Commission recommends: 

That, by statute, each mining company he made responsible for maintain- 
ing effective audiometric records for each employee \vho in the absence of 
hearing protection encounters noise at levels of 85 dB(A) or higher and that 
such audiometric records be required to be keyed H to social insurance 
numbers, 21 to Miner's Certificate numbers where such have been as- 
signed, and 31 to a code number of noise-profile-encounter as previously 
recommended. 

It is important that the audiometric record for an employee as maintained 
by a Company be complete and include data acquired by specialist review 
as well as by regular audiometric testing and that these records be pre- 
served after an employee leaves employment. Further, the Commission 
recommends: 

That the Occupational Health and Safety Branch commission on a 
five-year cycle statistical assessments of the state of hearing among sam- 
ple populations of workers in mines, and that the first review be of produc- 
tion crews in underground operations , including diesel operators. 

The Commission also suggests that research be conducted to determine if 
the accident experience of workers with loss of hearing differs significantly 
from that of other workers. 

Audiometric records should be effective in detecting abnormalities of 
hearing for the purposes of 1/ referral for medical review to confirm the 
nature of any hearing handicap and to provide counsel on conditions of 



233 Other environmental hazards 

continuing employment, 2/ providing evidence related to any claim for 
compensation, 3/ checking the effectiveness of the company's hearing 
conservation programme and the participation of the employee in that 
programme, and 4/ providing data for a statistical perspective on the state 
of hearing among populations of workers. The technical requirements for 
an occupational audiometric testing programme have recently been 
outlined. "^^ The Commission endorses these general requirements and 
recommends in addition: 

That the Occupational Health and Safety Branch regularly inspect all 
audiometric testing facilities not under the supervision of a designated 
medical specialist, and that any designated medical specialist be required 
to certify biennially in writing that the facilities under his supervision 
conform to the minimum standards of the Ministry of Health as then 
current. 

Smaller companies may wish to band together as in Sweden to establish or 
gain access to an authorized and supervised audiometric testing facility. 

The Ministry of Health guidelines call for screening at the time of 
employment, at least annually thereafter for persons who work in areas 
where noise levels are in excess of 100 decibels, and every three years for 
those in areas where noise levels are less than 90 decibels. The foregoing 
guidelines also call for the referral to a physician of any employee with 
hearing loss in both ears who exhibits an increase in hearing threshold^^ in 
the better ear averaging 26 decibels or over at pure tone frequencies of 500, 
1000, 2000, and 3000 cycles per second. At this level an employee is entitled 
to reimbursement by the Workmen's Compensation Board for the cost of a 
specialist's consultation fee. Under current administrative practice of the 
Board, an employee whose average increase in hearing threshold at the 
foregoing frequencies is 35 decibels or more in the better ear is entitled to a 
permanent disability award if the changes can be verified as having an 
occupational cause and he is under sixty years of age. ^' The Commission 
sees no reason why a worker should not be shown his audiometric test 
record; it represents, after all, measurements on his person. 

Compensation for hearing loss, although related to complex technical 
and medical characteristics of the auditory sense, is in the end based on 
social judgment rather than definitive scientific knowledge. Social judg- 
ment of what constitutes fair compensation has changed remarkably since 
1947. The Commission understands that when hearing loss was first com- 
pensated in Ontario a person was not eligible for a pension until six months 
after retirement. Until the end of 1973, a person could not receive a pension 



234 The health and safety of workers in mines 

for which his state of hearing made him ehgible until he removed himself 
from work in noise exposure, and no special programme of rehabilitation 
was offered to assist him. As of 1 January 1974 the Workmen's Compensa- 
tion Act was modified to make administrative practice for industrial disease 
the same as that for an injury due to an accident. Persons with hearing loss 
became eligible on that date for disability awards while continuing to work 
in noise exposure. This fact has contributed to the recent burst of disability 
awards, because there was a backlog of persons with hearing loss who had 
not elected to leave their work with its noise exposure as a precondition for 
the receipt of a disability award. Further, the onus has been on the worker 
to see that a claim for compensation is initiated. While the workmen clearly 
must participate in the act of making a claim, the Commission believes that 
a fundamental professional responsibility rests on all those who generate 
and review audiometric records to advise and assist a workman to make a 
claim the compensability of which must be judged by the Workmen's 
Compensation Board. 

" The Commission asks why a person who loses the sight of both eyes is 
compensated at 100 per cent of eligible earnings while a person who suffers 
complete sensorineural deafness in both ears from industrial noise is com- 
pensated at only 30 per cent. Deafness isolates a person far more from 
social intercourse than does blindness, although in our technological soci- 
ety a deaf person can work at tasks unsuited to a blind person. Workmen's 
compensation is designed to sustain remuneration and does not attempt to 
measure the intangibles of social deprivation in conversation, unrealized 
advancement in job status, and many other facets of life. The Board has 
supported research on the assessment of the human impact of loss of 
hearing, and the Commission believes such work should include a study of 
job accessibility for persons with industrial noise deafness within and 
between companies, so that the effective economic impact can be more 
fully assessed. It is the Commission's understanding that since the last 
employer is charged only a prorated amount of the disability payments for 
the hearing loss of a current employee, there is no intrinsic economic 
impediment to the mobility of a worker with hearing loss. This point should 
be verified. It has been proposed that the Occupational Health and Safety 
Branch conduct research on the relationships, if any, between hearing loss 
and accidents among mine workers. Should a significant connection be 
established, the Board should consider a work adjustment policy for per- 
sons with hearing loss. 

Loss of hearing from industrial noise is wholly preventable and incura- 
ble. Its incidence can in time be reduced to a small fraction of its current 
level if all parties, and not least workers, follow good practices with 



1 



235 Other environmental hazards 

diligence and care. Progress in eradicating industrial noise deafness will 
depend strongly on the keeping and analysis of effective occupational 
records. Questions of standards of exposure, medical surveillance, and 
occupational records have recurred through this report. Specific recom- 
mendations have been made concerning medical surveillance. The follow- 
ing notes are intended to summarize the issues related to standards and 
occupational health records. 

ENVIRONMENTAL SIANDARDS, HEALTH RECORDS, 
AND RESEARCH 

The Commission has noted that with respect to toxic substances and 
physical agents such as noise, there are two kinds of standards for which 
monitoring is necessary: engineering standards governing technical condi- 
tions of operations in mines and plants, and standards for exposure of 
persons, such as tlvs. It has been recommended that a statutory standard 
for personal exposure to silica-laden dust and to ionizing radiation in the 
uranium mines be established on a basis that includes evidence from 
Ontario conditions. It is essential that there be guidelines for a large range 
of other toxic substances and physical agents and that all parties under- 
stand what these are. The Commission recommends: 

That the Occupational Health and Safety Authority be assigned by statute 
the responsibility to establish standards or guidelines for personal expo- 
sure to all toxic substances and hazardous physical agents and that, 
subject to any statutory standards and in consultation with industry and 
labour, the Authority issue a code of practice for the application in mines 
and plants of the Threshold Limit Values of the American Conference of 
Governmental Industrial Hygienists. 

This recommendation is made with the clear understanding that tlvs as 
defined by the acgih (see n.4) are guidelines and not statutory standards. 
The Commission has further recommended that with respect to both 
ionizing radiation and asbestos dust the Mines Inspection Branch estab- 
lish a sequence of two ceiling values based on averaging over a time interval 
that is a small fraction of a shift (perhaps fifteen minutes). When the first 
ceiling level is exceeded, corrective action must be initiated immediately, 
and when the second ceiling level is exceeded, regular workers must be 
withdrawn from the offending locations until conditions are corrected. 
Such a regulation does not preclude the protection of regular workers by 
the wearing of respirators for limited periods in a small number of desig- 
nated work locations. 



236 The health and safety of workers in mines 

The procedure of defining 'ceiling' short-term operational levels de- 
serves to be extended as a means of ensuring that 'worst case' exposure 
conditions are dealt with as part of the over-all problem of limiting time- 
weighted average exposures over working shifts. Recommendations have 
been made for the establishment of codes of practice for engineering 
monitoring. Common sense suggests that environmental samples be taken 
when well-informed workers consider a work situation to be unusually 
hazardous. 

With respect to individual encounter, there are very great difficulties in 
determining both acute and chronic exposures. Acute encounters are for 
the most part accidental, and instrumentation of an appropriate form to 
assess the circumstances is unlikely to be present. The Commission has 
recommended mandatory continuous monitoring at locations where acute 
exposures recur. With acute events it is essential to document the circum- 
stances in personal health records and to conduct selective medical surveil- 
lance, as has been recommended. For chronic exposure the Commission 
has placed emphasis on the importance of determining cumulative expo- 
sures corresponding to profiles of encounter characteristic of distinctive 
classes of jobs. Such profiles can be obtained for samples of workers by 
using portable-instrument technology capable of integrating specific ex- 
posures over several shifts. The exposure status of classes of workers, 
codified through samples and updated from time to time, can play an 
important role in establishing occupational records for epidemiological 
research and workmen's compensation. The Commission considers it to be 
the responsibility of each mining company to develop exposure records for 
its workers under the guidance of codes of practice issued by the Occupa- 
tional Health and Safety Authority. 

The companies also have the responsibility of maintaining environmen- 
tal records of over-all operations under codes of requirement, issued and 
audited by the Mines Inspection Branch. 

A key issue is the development, custody, and use of personal occupa- 
tional health records, which should include records of accidental injuries. 
X-ray records as prescribed by the Mining Act for persons with a Miner's 
Certificate are maintained by the Chest Examining Stations now operated 
by the Ministry of Health. The Commission has recommended that respon- 
sibility for maintaining audiometric records and records of acute and 
chronic encounter with toxic substances rest with the mining companies. 
It has proposed that representative cumulative exposures associated with 
characteristic profiles of encounter with toxic substances and noise be 
established for sample populations of workers in distinctive classes of jobs, 
and that these representative exposures be codified and included in per- 



237 Other environmental hazards 

sonal occupational health records as estimates of exposure and risk. The 
importance of linking personal health and safety records to the system of 
social insurance numbers and Miner's Certificate numbers (where issued) 
has been emphasized. It is desirable that as far as feasible there be a 
complete file of all occupationally related personal health and injury data 
for a particular person placed under local medical supervision. These 
records should be designed to serve the immediate well-being of the worker 
and to provide basic data for studies of the health of groups of workers. To 
ensure proper confidentiality and use they should be under the responsible 
medical supervision of a company medical director or a superintending 
consulting physician. The Commission believes that the mining industry as 
a whole has not been providing the level of occupational health supervision 
workers are entitled to and endorses the substance of the recommendations 
of the Ministry of Health in this regard. ^^ In a major Swedish mining 
company visited by the Commission the medical director is responsible for 
supervisory surveillance of both the health and safety of the workers. In 
another area smaller mines are grouping to establish a collective service. 
The Commission recommends: 

That the mining industry establish/or its employees, where such is not now 
provided, occupational health surveillance by a supervising medical direc- 
tor or consultant experienced in occupational medicine. 

The realization of such a service will be difficult because few medical 
graduates of Canadian medical schools are oriented toward the challenges 
of preventive medicine in occupational health. This fact reflects the em- 
phasis in the health-care system on disease as contrasted with prevention. 

Personal occupational health records should be confidential to the per- 
son and to the supervising physician and their release as individually 
identifiable records to other persons within or outside the company should 
be subject to the informed consent of the worker. In this regard the medical 
supervisor of the occupational health of workers is faced with basic ethical 
issues which need to be understood by the worker as well as by 
management. ^^ The Commission further recommends: 

That the labour unions individually or in consort appoint to their staff a 
consulting specialist in occupational medicine. 

The intent of this recommendation is to ensure that the unions have the 
continuing advice of a person who is able actively to participate in the 
network of professional relations in occupational medicine. 



238 The health and safety of workers in mines 

Statistical studies of the health status of groups of workers, for example 
through the methods of epidemiology as used by the Ministry of Health and 
the Commission and cited in the report, are necessary to identify existing 
and emerging health problems. For such puiposes it is essential that there 
be agreed protocols whereby research groups can gain access to and use 
records for statistical puiposes while preserving the confidentiality of 
individuals and, as appropriate, employers. The Commission strongly be- 
lieves that the Occupational Health and Safety Authority should be given 
a carefully defined statutory right of access to all personal occupational 
health records. Further, it is proposed that protocols for research on such 
records by government, university, or other agencies be approved by the 
Authority on the recommendation of a protocol review committee consist- 
ing of widely representative lay and professional persons, except in those 
instances where the protocol has already been subject to review by a 
human experimentation committee as is customary in university-based 
research. The purpose of a protocol review committee, at the Authority 
level would be to approve the ethical aspects of the research but not to 
judge the scientific merit of the work. Such judgment is properly rendered 
by the agency funding the study. The Commission suggests that the Occu- 
pational Health Protection Authority convene a seminar of interested 
parties to discuss the conduct of epidemiological studies in occupational 
health, including needs for computer-based files at company and provincial 
levels. 

In the foregoing review the Commission has emphasized the need for 
linking occupational health records through common code identification 
provided by social insurance numbers and Miner's Certificate numbers 
(see n. 104 in chap. 3). For some kinds of research there is likely to be need 
for a central depository of records. The Commission suggests that the 
Workmen's Compensation Board be designated for that purpose. The 
Board has stated that it does not consider that it bears direct responsibility 
for epidemiological assessment of emerging problems of health and safety 
among workers.^'* Indeed, this responsibility should ultimately rest with 
the Occupational Health and Safety Authority. At the same time the 
Board's statistical records on compensation are of prime importance to any 
general review of the status of the health and safety of mine workers, and 
the Board has assisted the Ministry of Health by setting up such special 
programmes as the Uranium Nominal Roll. The Commission's intent is 
that the Board should have the resources to provide statistical support to 
perform research in occupational health and to act as the official central 
depository for confidential records where such is needed. To fulfil this role 
it will be important for the Board, in co-operation with the research com- 



239 Other environmental hazards 

munity , to devise file structures and data bases suited to the investigation of 
sample populations selected in accordance with the topic of research. 

The subject ofoccupational health records is a major one for which there 
are no simple solutions. The proper roots lie in well-maintained personal 
occupational health records under effective medical supervision. These 
root elements should be linked by common codes, and central deposition 
should be directed primarily to problems of research. 

The Commission considers there to have been far too little research on 
the health and safety of workers in mines in Ontario. The excellent 
epidemiological studies by the Ministry of Health have been conducted in 
response to major emergent problems. The Occupational Health Protec- 
tion Branch has not had the resources to carry out exploratory research 
designed to assess the likelihood of there being problems. Research on the 
statistics of accidents, such as that conducted by the Commission, has been 
non-existent. It is imperative that this situation change. The Commission 
proposes that the government fund research at an annual level of 1.5 per 
cent of the direct annual costs of workmen's compensation for accidents 
and industrial disease in the mining industry. The direct costs of such 
compensation are currently about 6 per cent of gross wages, which total 
about $400 million. Thus compensation costs are about $25 million per 
annum, and 1.5 per cent of this sum is $375,000 dollars. 

In addition to a general commitment by government to research on 
health and safety in mines it is important that the joint health and safety 
committees have a direct means of initiating studies of common pragmatic 
concern. The Commission conceives of the joint health and safety commit- 
tees of one or a number of companies proposing in consultation with 
competent researchers the conduct of particular studies. The Commission 
believes that the policy recently adopted in Sweden^'' of levying a fixed 
percentage of the wages of workers provides an equitable means of estab- 
lishing a fund for this purpose. The Commissions recommends: 

That under the Workmen s Compensation Act provision he made for the 
levying on all employers in class 5 an amount of 0.03 per cent of wages 
currently subject to levy under the Act to create a fund for research on 
occupational health and safety by the joint labour-nuinagement health and 
safety committees. 

The foregoing fund would be about $ 125,000 or about 1 /200th of the current 
direct costs of compensation for accidents and industrial disease in the 
mining industry. The Commission proposes that both of the foregoing 
funds totalling together about 2 per cent of the direct annual costs of 
workmen's compensation, that is, about $500,000 per annum, be adminis- 



240 The health and safety of workers in mines 

tered by the Occupational Health and Safety Authority, with the guidance 
of a peer review Committee on Research. 

1 Health Hazards of the Human Environment, World Health Organization, Geneva, 1972 

2 Airborne Contaminants Mining, Milling, Smelting and Refining, 3d ed.. Mines Accident 
Prevention Association of Ontario, 1973; E. Mastromatteo, 'Noxious gases in mining 
operations,' Canadian Mining Journal, October 1967, 75-7 

3 Jan H. Reimers and Associates Ltd, Study of Health and Safety in Ontario Extractive 
Metallurgical Plants, 7 November 1975. This report was prepared by consultants in 
extractive metallurgy as a Commission resource document. The Engineering and Labour 
Advisors to the Commission subsequently visited metallurgical plants and the related 
labour unions with the Commissioner and the consultants. 

4 A part of the definition of Threshold Limit Values for chemical contaminants as used in the 
USA is as follows: 

Threshold limit values refer to airborne concentrations of substances and represent 
conditions under which it is believed that nearly all workers may be repeatedly exposed 
day after day without adverse effect. Because of wide variation in individual susceptibil- 
ity, however, a small percentage of workers may experience discomfort from some 
substances at concentrations at or below the threshold limit; a smaller percentage may be 
affected more seriously by aggravation of a pre-existing condition or by development of an 
occupational illness . . . Threshold limit values refer to time-weighted concentrations for a 
7- or 8-hour workday and 40-hour workweek ... Time-weighted averages permit excur- 
sions above the limit provided they are compensated by equivalent excursions below the 
limit during the workday . . . Although the time-weighted average concentration provides 
the most satisfactory, practical way of monitoring airborne agents for compliance with the 
limits, there are certain substances for which it is inappropriate. In the latter group are 
substances which are predominantly fast-acting and whose threshold limit is more appro- 
priately based on this particular response. Substances with this type of response are best 
controlled by a ceiling 'c' limit that should not be exceeded ... They should be used as 
guides in the control of health hazards and should not be used as fine lines between safe and 
dangerous concentrations ... These limits are intended for use in the practice of industrial 
hygiene and should be interpreted and applied only by a person trained in this discipline . . . 
They are not intended for use, or for modification for use (i) as a relative index of hazard or 
toxicity ... In spite of the fact that serious injury is not believed likely as a result of 
exposure to the threshold limit concentrations, the best practice is to maintain concentra- 
tions of all atmospheric contaminants as low as is practical. ( Preface, 'Chemical contamin- 
ants,* T'/j/i'i/io/J Limit Values for Chemical Substances and Physical Agents in the Work- 
room Environment With Intended Changes for 1975, American Conference of Govern- 
mental Industrial Hygienists, Cincinnati, Ohio, 1975) 

The documentary basis for tlvs is published in Documentation of the Threshold Limit 
Values for Substances in Workroom Air, 3d ed., American Conference of Governmental 
Industrial Hygienists, Cincinnati. Ohio. 1971 . For related concepts see chap. 2, n. 74, and 
Permissible Levels of Occupational Exposure to Airborne Toxic Substances, World 
Health Organization, Technical Report Series No. 415, Geneva, 1969. 

5 The following are representative page references in the transcripts to union concern about 
blasting fumes and practices: 1 1 16, 1689-91 . 2 182. 2234. 2243-5. 2588, 2594-5, 2760, 3008, 
4168-70. In the decade 1965-75. 1 1 out of 213 fatalities were caused by explosives. 

6 J.M. Rogan, Medicine in the Mining Industries, London, 1972, chap. 1 1 

7 Non-fatal chemical burns to the skin at 12.9 per annum represent a small part of accidents 
leading to burns of the skin. Of these the five occurring underground were mainly from 



241 Other environmental hazards 

cement used in backfill. In the three-year period 1972-4 an average of seventy non-fatal 
compensable burn injuries per annum were caused by agents other than chemicals. The 
agents involved were molten metal (35), other hot materials including steam and hot liquids 
(24.4), fires (8.3) and electricity (2.3). This total of seventy compensable burn injuries per 
annum were distributed as follows: reduction plants (52.7), underground (6.7), shops and 
surface (7.6). As would be expected, the great majority of these burn injuries occur in 
reduction plants, where process temperatures are highest. With respect to electrical burns 
it is noted that in the decade 1965-74, twoof 213 fatal injuries were by electrocution. 

In the period 1972-74 one non-fatal compensable injury was caused by ingestion. A 
driller attempting to siphon diesel fuel from a barrel into a scooptram used his mouth and 
swallowed some fuel. 

8 Compensable injuries per annum from chemical absorption, at 15.6, are a small fraction of 
all eye injuries. Compensable injuries to eyes, resulting from a 'foreign body' in the eye. 
for the three-year period 1972-4 averaged 90.3 injuries per annum distributed as follows: 
53 underground, 31.7 in reduction units and 15.6 in shop and surface units. In addition to 
these injuries there were three per annum from flash burns of radiation from welding arcs. 
These figures total 108.9. About half of these injuries occur underground. There is strong 
evidence, particularly for certain companies, that eye protection is not meticulously used. 
The foregoing figures exclude injuries caused by being struck forcibly on or in the eye by 
agents that would break or displace eye protection. 

9 The following are representative page references in the transcripts to union concern about 
chemicals other than blasting fumes: 1023-4, 1357, 1424, 1438-9, 1724-32, 1846-62. 
1869-80, 1928, 1961-2, 21 16-20, 2168-9, 2183, 2204-5, 2335, 2515-31, 2870, 2972, 3001, 
3406, 3422, 3561, 3564-75, 3582, 3680, 3692-3704, 3900-5, 4036-8, 4661-2, 4879-80, 
4896-9. 

10 Mining Act, Sections 214( 1), (4), (6) 

11 Brief 142, 28, 32 

12 Seefor example Brief 51, 34 

13 For example. Reagents and Chemical Hazards, Electrowinning Department, Copper 
Refinery, inco Ltd, Aug. 1974 

14 Guidelines for Labelling of Toxic Chemicals for Use in Ontario Industries, Occupational 
Health Protection Branch, Ministry of Health, Ontario, 1975; Guidelines for the Safe 
Handling of Toxic Chemicals for Use in Ontario Industries, Occupational Health Protec- 
tion Branch, Ministry of Health, Ontario, 1975 

15 See for example Exhibit 55. 

16 For example, in the Copper Cliff Nickel Refinery of inco Ltd and in Falconbridge Nickel 
Mines Ltd 

17 Workmen's Compensation Act (wca). Section 1(/) 

18 WCA, Regulation 834, Schedule 3 

19 Until the publication of this report this number was not known to the Board. An earlier 
estimate, cited in chap. 3, was an excess of 26 cases. 

20 The epidemiological identification of the excess of lung cancer in the silver and cobalt 
oxide plant is to be found in R.B. Sutherland, 'Respiratory cancer mortality in a smelting 
and refining company in Ontario 1928-1952,' Thesis, Diploma in Industrial Hygiene, 
University of Toronto, 30 April 1958, and in 'Follow-up report on pulmonary cancer 
mortality 1930-1963 Deloro Smelting and Refining Company Ltd,' Department of Health, 
Ontario, unpublished. Arsenic was present in the ores and packed by hand in barrels as a 
by-product in the form arsenic trioxide. 

2 1 The compensation was for a person who had worked sixteen years is asbestos mines in the 
province of Quebec before working a further twenty-one years in Ontario asbestos mines 
in the period 1950-70. Some thirty-four cases of cancer among workers in asbestos 
manufacturing plants have been compensated. Of these, twenty-two cases were lung 
cancer and twelve were cases of mesothelioma. 



242 The health and safety of workers in mines 

22 R.B. Sutherland. "Report on respiratory cancer: the International Nickel Company of 
Canada. Ltd. Port Colboine Refinery (among men employed during the period 1930 to 1957 
inclusive)." Department of Health. Ontario, 1959. unpublished. The operations considered 
to be contributing high risks were cupola and sintering furnaces. Employment solely at 
calcining or anode finnaces was not associated with increased risk of cancer of the lungs or 
nasal cavities. The Workmen's Compensation Board initialed compensation early in 1961 
on the basis of the evidence in Dr Sutherland's report. For all cases of lung, nasal, or sinus 
cancer in the population continuing at risk, the current practice of the Workmen's Com- 
pensation Board is that one year of exposure is necessary to establish a claim 
(Transcript. 4725-7). 

23 E. Mastromatteo. 'Nickel: a review of its occupational health aspects." Journal of Occu- 
pational Medicine. 9 March. 1967. 127-36. This review contains data updating ibid, to 

1965. 

24 R.B. Sutherland. "Mortality among sinter plant workers: International Nickel Co. of 
Canada. Ltd. Copper Cliff Smelter," Department of Health, Ontario. 1969. unpublished. 
The operation considered to be contributing the high risk was sintering furnaces in which 
the sinter produced contained less than 1 percent sulphur. The Workmen's Compensation 
Board initiated compensation in 1969 in response to Dr Sutherland's report. The current 
practices of the Board are that one year of exposure is necessary to establish a claim except 
for exposures arising before 1952, in which case six months of exposure is necessary to 
establish a claim (Transcript, 4725-7). 

. The Ministry of Health, with the assistance of the company and the United Steel- 
workers of America, has developed a nominal roll of some 724 persons for whom there is 
documented evidence of exposure. The Ministry is conducting biannual medical surveil- 
lance based on chest x-rays and sputum cytology for the population at risk living in the 
Sudbury area, and chest x-rays are arranged for those who have moved away. On sputum 
cytology see Joan C. McEwan, 'Cytological monitoring of nickel workers,' Annals of the 
New York Academy of Sciences, forthcoming, paper presented at the Conference on 
Occupational Carcinogenesis, New York. March 1975. 

25 Nickel: Medical and Biological Effects of Environmental Pollutants, National Academy 
of Sciences, Washington DC . 1975: for nickel carcinogenesis see chap. 6 and for Ontario 
experience 152-6. 

26 Collective Bargaining Agreement Between Inco Ltd and United Steelworkers of America. 
19 July \915. Letter of Agreement. 10 July 1975, appended to Article 17 

27 Nickel carbonyl Ni(CO)4 is a mobile colourless liquid with a high vapour pressure. It boils 
at 43°c at atmospheric pressure and begins to decompose at 60°c . producing finely divided 
nickel and carbon monoxide. There are established industrial uses for nickel carbonyl. It is 
also generated and released into the atmospliere as a product of combustion of fossil fuels 
and may be present in cigarette smoke. See Evaluation of Carcinogenic Risk of Chemicals 
in Man Some Inorganic and Organometallic Compounds, Volume 2. International 
Agency for Research on Cancer, World Health Organization, Lyon, 1973, 129-32. It 
occurs as a process product in pressured vessels in the refining of nickel in the new Copper 
Cliff Nickel Refinery of inco Ltd which began operating in March 1973. In the period April 
1959 to 1970. preceding the opening of this nickel refinery, a pilot plant was operated at a 
carbonyl research station at Port Colborne where thirty-five persons were employed. The 
current TLV for nickel carbonyl , cited in Table 54, is 0.00 1 parts per million , with a notice of 
intended change to 0.0.50 parts per million. The nature and treatment of acute effects of 
nickel carbonyl are reviewed in Mastromatteo. "Nickel." 128. The company maintains a 
special clinic at the refinery and has well-defined standard procedures of response for any 
worker who may have suffered an acute inhalation. 

28 F.W. Sunderman jr. "The current status of nickel carcinogenesis,' Annals of Clinical 
Laboratory Science. 3 1975. 156-80: nickel carbonyl is treated in Table 8 and on 165-6. 

29 Evaluation of Carcinogenic Risk, 134-5 



243 Other environmental hazards 

30 A concise review of experience in Wales is given in Ni( kcl: Mcd'u al and liiolo^^ic (tl 
I'lfjccts, 144-52 

31 R. Doll, L.G. Morgan, and F.K. Spei/.er, 'Cancers of the lung anil nasal sinuses in nickel 
workers,' British Journal ofCanccr. 24. 1970, 624 

32 Evdluation oj Cdrcinoiicnii Risk. 144 

33 us Department of National Health and Welfare, niosh. Criteria for a Recommended 
Standard ... Occupational Exposure to Asbestos. Publication hsm 72-10267. 1972. This 
document provides an extensive review of the literature ou asbestos to 1971 and docu- 
ments the elements for a standard based on a time-weighted average exposure of 2.0 fibres 
per cubic centimetre greater than 5 microns in length averaged over an eight-hour day and 
with a maximum allowable concentration over a fifteen-minute averaging period of 10 
fibres/cc. The 2.0 fibre standard was adopted by the Ministry of Health in 1975 and is now 
used as a guideline by the Ministry of Natural Resources for Ontario asbestos mines. The 
Occupational Safety and Health Administration, which sets standards in the usa for in- 
dustry other than mining, has now proposed a revised standard of 0.5 fibres/cc: see "Occu- 
pational exposure to asbestos - Notice of proposed rulemaking.' Federal Rej^ister. De- 
partment of Labour, 40, no. 197, 9 Oct. 1975. In the United States federal regulations for 
mines are set by the Mining Enforcement and Safety Administration, which has published 
a standard of 5 fibres/cc greater than 5 microns in length and a maximum allowable con- 
centration of 10 fibres/cc. Federal Register. 39, no. 127, 1 July 1974: I.J. Selikoff, E.C. 
Hammond, and J. Churg, 'Asbestos exposure, smoking and neoplasia,' Journal of the 
American Medical Association, 204 1968, 196; J.C. McDonald et al., 'Mortality in the 
chrysotile asbestos mines and mills of Quebec,' Archives of Fnvironmentid Health. 22. 
1971,677: Health and Welfare Canada, Environmental Health D\vQQXovd\Q. Report of the 

Asbestos Working Group. Feb. 1976. This document provides a review of the asbestos 
mining industry in Canada, giving the locations of mines, milling capacities, types of fibre, 
major product uses, and product manufacturers. It documents the number of known cases 
of asbestosis and of mesothelioma by province and makes recommendations to the 
provincial and federal governments, including a recommendation for a dust standard of 2 
fibres per cubic centimetre and another that non-smoking be a condition of employment in 
exposure to asbestos. The problems of health in the asbestos industry of Quebec are 
currently being studied by a committee which has issued a preliminary report, the results 
of which should be highly relevant to Ontario asbestos mines: Rene Beaudry et al. . 
Rapport Preliminaire Comite d' etude sur la salubrite dans I' Industrie de I'amiante, 
Quebec, April 1976. 

34 Health and Welfare Canada, Report of the Asbestos Working Group. 8 

35 Selikoff et al.. 'Asbestos exposure' 

36 The person had worked intermittently in gold mines and silica mines from 1928 to 1956 in 
Quebec and Ontario. He worked at an Ontario asbestos mine from 1956 to 1975 and was 
compensated for mild asbestosis in the year of his retirement. In Ontario industry as a 
whole in the five years 1970-4, 82 cases of asbestosis were compensated, and among these 
were eight cases of mesothelioma (see Health and Welfare Canada. Report of the Asbestos 
Working Group, 24, 26). 

37 Introduction to Lung Diseases. American Lung Association, usa, 1973, 14. 69 

38 While measurements with the konimeter using acid and heat treatment of the slides are 
suitable for isolating free silica, they are not well suited for determining the levels of 
airborne toxic substances not related to silicosis. Total dust measurements by mass are 
now common in reduction plants and an ad hoc standard of 7.5 milligrams per cubic metre 
has been stated to have been set for one smelter complex by the Mines Engineering Branch 
on the recommendation of the Ministry of Health. See Brief 139. 12d. 13d: Brief 52. 27-9 
and Appendix 14. 

39 Morbidity and Mortality in Selective Occupations at The International i\ickel Co. of 
Canada Ltd., Copper Cliff, Ontario 1950-67 . Health Studies Service. Environmental 



244 The health and safety of workers in mines 

Health Services Branch. Ontario LX^partment of Health. 1 13. This undated study is based 
on a sample population of 83 1 persons divided for comparison purposes into persons 
working in a smelter-converter area, in a mill and separation area, in parts of a copper 
refining operation, including the tank house area, mechanical department, and yard and 
transpoil areas, and in an imdcrground mine. The morbidity study was based on a work 
history, including records of absences and diagnoses of the attending physician. 

40 Chronic Obstructive Liin^> Disease Amon^^ Persons Employed for Ten Years and More in 
the Converter Plant of the International Nickel Company of Canada, Ltd. Copper Cliff, 
Ontario. Aug. /Sept. 1973. Ministry of Health. March 1976. This study examines evidence 
of chronic bronchitis and pulmonary function changes among a population of 3 10 conver- 
ter workers and a comparison population of 64 refinery workers. Each person at the time of 
the survey had ten years or more experience in the designated areas. The study is based on 
personal contact with the workers to obtain a medical history through a standard question- 
naire related to chronic bronchitis, determine smoking habits, and conduct lung function 
tests. 

Lung function tests involve mechanical measurements of a person's capacity to inhale 
and exhale. Two of these are fvc (Forced Vital Capacity): the total volume of air, ex- 
pressed in litres, which is expelled from the lungs on maximum effort following a deep 
inspiration: and fev, (Forced Expiratory Volume. One Second): the volume of air ex- 
pelled from the lungs within one second. 

41 L.C. Neri et al.. 'Chronic obstructive pulmonary disease in two cities of contrasting air 
quality,' CMA Journal. 1 13. Dec. 1975. 1043-6: the cities compared were Sudbury and 
Ottawa. 

42 Victor E. Archer, Thomas J. Smith, and J. Dean Gillam. 'Chronic sulfur dioxide exposure 
in a smelter: i indices of chest disease.' paper submitted to the Journal of Occupational 
Medicine: Thomas J. Smith, William L. Wagner, and David E. Moore, 'Chronic SO2 
exposure in a smelter: 11 exposure to SO2 and dust 1940-74,' paper submitted to the 
Journal of Occupational Medicine: Thomas J. Smith et al., 'Pulmonary impairment from 
chronic exposure to SO^,' paper submitted to the New England Journal of Medicine. 

43 See Lowe et al. in J.C. Gilson, 'Occupational bronchitis?' Proceedings of the Royal 
Society of Medicine. 63 . 1970, 863 . 

44 Documentation of the Threshold Limit Values for Substances in Workroom Air, American 
Conference of Governmental Industrial Hygienists, Cincinnati, Ohio, 1971, 238-9; this 
document refers toaxLV of 5 ppm. us Department of National Health and Welfare, niosh. 
Criteria for a Recommended Standard ... Occupational Exposure to Sulphur Dio.xide, 
1974: this report documents a recommendation for a tlv of 2 ppm. 

45 Gilson, 'Occupational bronchitis?' 

46 Survey of Certain Conditions of the Respiratory Organs Among Persons Employed 
Underground And In Surface Crushers and Mills of Two Operating Mines at Elliot Lake, 
Ontario, Eebruary I7-March30, 1974, Ministry of Health, Ontario, 28 April 1975, 25-9 

47 See ibid.. Tables 11, 12. Close quantitative comparisons of prevalence of chronic bron- 
chitis between different sample populations, such as th^ converter and refinery workers, 
the uranium mine workers, and the Ottawa male population, are not justified unless the 
samples are matched for age distribution, smoking habits, and durations of exposure 
where applicable. For the sources cited such matching has not been made. 

48 Gilson, 'Occupational bronchitis?' Table 6: G.K. Sluis-Cremer, L.G. Walters, and H.S. 
Sichel, 'Chronic bronchitis in miners and non-miners: an epidemiological survey of a 
community in the gold area of Transvaal, ^////.v/; Journal of Industrial Medicine, 24, 1967, 
1; F.J. Wiles et al., 'Chronic bronchitis in miners,' National Research Institute for 
Occupational Diseases of the South African Medical Research Council, 1972, 28-38; 
W.K.C. Morgan and N.L. Lapp, 'State of the art, respiratory disease in coal miners,' 
American Review of Respiratory Disease, 113, 1976, 531-59 (industrial bronchitis is 
reviewed on 554-5); Commission of the European Communities, Research on Chronic 



245 Other environmental hazards 

Rcspifdtorx Diseases, Industrial Health and Medicine Series No. \H, l.iixemboutg. 1976. 
chap. 3, ^l^pideniic)K)gical investigation,' 76-1 13; J.C. McDonald et al.. Respiratory 
symptoms in chrysotile asbestos mines and mill workers of Quebec/ Archives of En- 
vironmental Health. 24, 1972,358. 

49 Personal communication from the director. Medical Bureau for Occupational Diseases, 
Department of Mines, Republic of South Africa, to the Commission's medical consultant, 
Oct. 1975. See also Republic of South Africa, Occupational Diseases in Mines and Works 
Act, 1973, Sections i(xiv)(d)(e) and 44( l)(b)(c) and 2(c)(d). 

50 Survey of Certain Conditions, 28 

51 E. Mastromatteo, loxic Effects of Diesel Engines and their Threshold Limit Values , Sem- 
inar on Underground Diesel Operations, Sudbury, April 197 1 (this paper discusses the use 
of TLVs for the multiple components of diesel exhausts); H.E. Stokinger, Toxicology of 
Diesel Emissions, us Bureau of Mines Information Circular, ic 8666, 1975, 147-58; J. A. 
Kibelstis, Medical Effects of Diesels Underground, us Bureau of Mines, Information 
Circular 8666, 1975 159-67 (this paper reviews the short-term influences of diesel fumes on 
workers); for technical characteristics related to mining as based on substantial co-oper- 
ative Canadian research see Brief 127, 10-14. 

52 Richard J. Waxweiler, Joseph K. Wagoner, Victor E. Archer, 'Mortality of potash 
workers,' Journal of Occupational Medicine, 15, June 1973, 489. One of the eight mines 
studied began using diesel engines underground in 1949, another in 1957. 

53 Dr Victor E. Archer informed the Commission that the National Institute of Occupational 
Safety and Health in the United States is mounting such a study with the Mine Enforce- 
ment and Safety Administration. 

54 Underground Diesel Engine Code 1973, Ministry of Natural Resources, Ontario. Section 3 
of this code, which is currently being revised, states: 

The volume of ventilating air shall be sufficient to ensure that at no place in a mine using 
diesel engines, will there be a concentration of noxious gases exceeding the safe limits 
required by the following and no engine shall operate if: (a) The carbon monoxide content 
ofthe undiluted exhaust after the scrubber exceeds 1500parts per million or 0. 15 percent. 
(b) The carbon monoxide content ofthe atmosphere adjacent to the engine exceeds 50 
parts per million or 0.005 per cent, (c) The carbon monoxide content in the air ofthe 
general atmosphere in the haulageway exceeds 20 parts per million or 0.002 per cent, (d) 
The nitrogen dioxide content ofthe atmosphere adjacent to the engine exceeds 5 parts per 
million or 0.0005 per cent, (e) The aldehyde content ofthe atmosphere adjacent to the 
engine exceeds 2 parts per million or 0.0002 per cent (measured as formaldehyde). (J) The 
carbon dioxide content of the atmosphere adjacent to the engine exceeds 5000 parts per 
million or 0.50 per cent. 

This code sets down no limit for particulates in the exhaust or for oxides of sulphur, but the 
current revision ofthe code is expected to do so. With respect to ventilation the Code 
states: 'in general, for design purpose, 75 cfm of ventilating air supply per rated brake 
horsepower of the engine is required in all areas of operation." 

55 See Brief 127. 

56 See Stokinger, Toxicology of Diesel Emissions. The toxic substances for w hich limits are 
currently set in the diesel code are listed in n. 54, and their immediate effects are discussed 
by Kibelstis, Medical Effects of Diesels Underground. 

57 Stokinger, Toxicology of Diesel Emissions, 156 

58 William Burns, Noise and Man, 2d ed., London, 1973; W. Burns and D.W. Robinson, 
Hearing and Noise in Industry, London: hmso, 1970 

59 There are many other effects of intense noise on man the occupational significance of 
which have not clearly been established. The Worken's Compensation Board has received 
no claims for injury from noise other than for hearing loss. See for example. Bums, Noise 



246 The health and safety of workers in mines 

and Man. chap. 8; K.D. Kryter, The Effects of Noise on Man. New York, 1970. 491-516; 
Thomas Cummings. 'Effects of noise on hearing: two group studies,' ms Thesis. Depart- 
ment of Preventive Medicine and Biostatistics, University of Toronto, 1976. The Com- 
mission has not been concerned with infective diseases or with drugs that induce deafness, 
nor with traumatic deafness induced by explosion or by physical objects entering the ears 
or striking the head. 

60 P.W. Alberti. P.P. Morgan, and J. C. LeBlanc. 'Occupational hearing loss -an otologist's 
view of a long-term study," The Laryni^oscope. 84, Oct. 1974, 1822-34; this paper reports 
characteristics of 719 consecutive patients referred by the Workmen's Compensation 
Board of Ontario for adjudication of hearing loss of presumed occupational cause. Of this 
group 49.5 percent were miners. See alsoCummings, 'Effects of noise on hearing,' 6, 7. 

61 Lump-sum payments may be made in lieu of a pension for the smaller levels of compensa- 
tion. 

62 Permanent Disability Rating Schedule. 'Workmen sCompens'dUon Board, 15 Feb. 1972 

63 Because a person's hearing may deteriorate with time, he may submit to the Board a 
sequence of claims with the object of having a previous award adjusted. Thus in due course 
medical aid cases may receive permanent disability awards of increasing percentages. The 
terminology 'first allowed' and 'latest settlement' pertain to this matter. 

64 Transcript, 1110 

65 Transcript. 2745 

66 See Burns, Noise and Man. chap. 1 1 . 

67 For a concise review of the problems of occupational noise and the means to deal with it 
see: Occupational Noise. Project Team Report, Ontario Ministry of Health 4 Dec. 1974. 
Procedures for conducting audiometric tests on the ears of workers are given in Occu- 
pational A udiometric Testing Programmes. Recommended Standard and Guidelines . 
Ontario Ministry of Health, 1974; this document contains a sample of typical audiometric 
records. For a more elaborate exposition of the basis for a noise standard see us 
Department of Health, Education and Welfare, Occupational Exposure to Noise, Criteria 

for a Recommended Standard, niosh Report hsm 73-11001, Washington, 1972. 

Continuous noise consists of a jumble of sound waves of many different frequencies 
spanning the audible range. The frequencies of special concern are those in the range of 
human speech, from about five hundred cycles per second to about three thousand. A 
noise at a particular location has a definite distribution of frequencies and intensities of 
atmospheric pressure variations. A weighted mean of these intensities at all frequencies 
relative to a chosen reference level of pressure can be measured by a sound level meter 
whose reading corresponds to the formula 

dB(A) = 201og,o^, 

where dB( A) means decibels using the A weighting scale, P is the root mean square 
pressure level of the source of noise as measured with the A weighting scale, and Po is the 
root mean square reference level, which is 20 micronewtons per square metre. This level is 
about the threshold of audible sound at the frequency of greatest sensitivity in young 
persons with clinically normal ears. The ear is not equally sensitive at all frequencies, and 
the A weighting scale is chosen to approximate to the relative sensitivity of the normal 
human ear at different frequencies. The loudness of sounds as perceived by the ear varies 
approximately as the logarithm of the sound pressure level. Because of the logarithmic 
function used, the number of decibels increases by the number 6 (almost) when the sound 
pressure P doubles, and decreases by 6 when it halves. Thus a noise with a dB( A) rating of 
96dB(A) has twice the pressure level of a noise of 90dB( A) and a noise of 102dB( A) has a 
pressure level four times that of a noise of 90 dB(A). The decibel levels of independent 
noise sources do not add directly. To obtain the resultant dB( A) level it is necessary to 



247 Other environmental hazards 

determine the separate mean square sound pressure levels, add these, and then determine 
the decibels. 

68 Noise Survey rrocecliire . Mines Accident Prevention Association ofOntario. 197.^ 

69 For example. Noise Survey Report of the Cciiuphell Red Lake Mine. lidlnierfown, On- 
tario, Siiljjeet: Sereeninii Survey of Surf nee und IJtuteri^round Operations . Mines Acci- 
dent Prevention Association ofOntario, May 1974 

70 Mining Act. Section 173(2)4. (3). (9) 

71 Noise Control and Hearing Protection Code. Division of Mines. Mines Engineering 
Branch, Ontario Ministry of Natural Resources ( 1 July 1974). The allowed noise levels are 
the same as those in the Industrial Safety Act. Section 111, under Ontario Reg. 259/72. 
s. 1 1 1 . A formula is provided for determining the effective exposure of a person who ex- 
periences different levels of noise during a shift. 

72 us Environmental Protection Agency. Pulilie Healtli and Welfare Criteria for Noise. 
Publication No. 55019-73-002, 27 July 1973. M 

73 United States Department of the Interior. A/ (y//7/?,i,' Conservation for ttie Mineral Industry . 
Bureau of Mines Information Circular ic 8564 ( 1972): Also see us Department of Health. 
Education and Welfare. Occupational E.xposure to Noise, niosh. Table 7. A skimobile 
operating at full speed may produce a noise level of 105-1 15 dB(A) at the driver's head (see 
Cummings, 'Effects of noise on hearing," Table 10). Isolated impact noise from rifles and 
shotguns and high level sound from loudspeakers are sources of hazard for some persons. 
Typcial lower noise levels are as follows: business office 55, conversational speech 65, 
street corner traffic 75. 

74 M Savich and J. Wylie. Noise Attenuation in Rock Drills. Canadian Mining Research 
Centre. Energy. Mines and Resources Canada. April 1975: this document provides a 
review of the state of the art. Exhaust mufflers on conventional hand-operated com- 
pressed-air drills have succeeded in lowering resultant noise levels by about 6dB(A). but 
the percussive noise of steel on rock remains. (See Table 63.) For the viewpoint of an 
organization of manufacturers see Brief 1 16 and the related transcript. 

75 A new organization called the Mining Industry Research Organization of Canada has been 
established by a group of six large Canadian mining companies (News release. 7 April 
1976). MiROC has indicated that improvement in underground lighting is a priority. The 
Commission strongly endorses this choice. 

76 Transcript, 1121 

77 Well-designed ear plugs properly fitted and kept adjusted can produce attenuation of noise 
of over 20dB(A) at frequencies above five hundred cycles per second. Well-fitted ear 
muffs worn without glasses can produce attenuation of over 30 dB( A) and combined plugs 
and muffs about 40dB(A). (See us Department of the Interior, Hearinii Conservation for 
tlie Mineral Industry . Figure 8 et. seq.) The mapao makes the following recommendations 
concerning the use ofear plugs and muffs: 'Properly fitted insert type of hearing protectors 
should provide adequate protection to all empoyees working in locations where noise 
levels are below 105 dB(A). For noise levels in the 105-1 18 dB(A) range, ear muffs are 
recommended. Over 1 1 8 dB(A) plugs and muffs are recommended." (Noise Survey Report 
oftlie Camplyell Red Lake Mine) 

78 Transcript, 1113 

79 Occupational Audiometric Testini,' Proi>rammes. Ontario Ministry of Health 

80 When a person with normal hearing is presented with a pure tone of a given frequency 
there is a certain minimum sound level at which it will just be audible. As that person"s 
hearing deteriorates it takes a more intense sound at this frequency to evoke hearing. The 
change can be measured in decibel units, and the amount is called the increase in threshold 
at the test frequency. 

81 For persons over sixty years of age 0.5 decibels per year in excess of sixty years is 
subtracted from the observed increase in threshold at each frequency as an allowance for 
the natural deterioration of human hearing with age. This effect is called presbycusis. 



248 The health and safety of workers in mines 

Decibel measurements are in the scale of the International Organization for 
Standardization. 

82 Brief 142.8-10 

83 Robert Murray, 'Ethics in occupational health practice,' chap. 21 in R.S.F. Schilling, ed.. 
Occupational Health Practice, London, 1973; 'The occupational physician," editorial. 
Journal of the Society for Occupational Medicine 25, 1975. 37; Irving R. Tabershaw, 
'Whose "agent" is the occupational physician?' Archives of Environmental Health 39, 
Aug. 1975, 412-16; Robert R.J. Hilker, 'In-plant medical services,' Archives of Environ- 
mental Health 30, Aug. 1975, 409-1 1. 

84 Transcript 4712, 4785-6 

85 Arhetarskydds Fondens Verksamhet, 1974, Stockholm. The amount first levied on wages 
was 0.03 per cent in 1971 , raised to 0.075 per cent in 1973. 



Policy for occupational health and safety in 
the mining industry 



In responding to its broad terms of reference the Commission has been 
guided by the evidence and opinions presented to it in the pubhc hearings. 
Industry and labour have expressed deep concern not only about the facts 
of industrial disease and injuries from accidents but also about the effec- 
tiveness of the institutional arrangements between government, industry, 
and the workers for dealing with the hazards at work and about governmen- 
tal policy for occupational health and safety that such arrangements reflect. 
The Commission has conducted studies and investigations of the problems 
of silicosis and dust, of lung cancer and ionizing radiation, of accidents and 
injuries, and of other hazards to health and safety, including hearing loss 
and noise. These studies and investigations have revealed what the Com- 
mission deems to be defects in the institutional arrangements and proce- 
dures for dealing with the hazards to health and safety in the mining 
industry. While the recommendations in the report have intentionally been 
derived out of the concrete circumstances revealed by the case studies and 
investigations, an overriding concern throughout has been to establish a 
more coherent basis for government, industry, and the workforce to deal 
with the problems of industrial disease and accidents according to their 
skills and in accordance with well-defined duties and responsibilities. The 
problems that underlie the issues of health and safety in the mines are first 
and foremost those of policy and of the performance of the responsibility- 
system that such policy gives rise to at both the company and the provincial 
level. 

There has been a serious lack of openness on matters of the health and 
safety of workers in mines. The majority of the information presented in 
this report has been inaccessible to workers and the public. Workers have a 
right in natural justice to know about the risks and consequences of the 



250 The health and safety of workers in mines 

risks that they undertake at work. Recommendations of the Commission 
have been designed to ensure that workers and the pubhc, together with 
industry and the government, share a common framework of understand- 
ing of the risks of work and of their consequences in injury and disease. 
Without such a framework there can be no proper social and poUtical 
judgment of what constitutes acceptable risks. The Commission believes 
the lack of such a framework is one manifestation of the absence of an 
adequate provincial policy on occupational health and safety. The Com- 
mission has emphasized that not only the special risks of work but also the 
voluntary risks of life-style' require the open critical attention of society. 
These classes of risks are not readily separable, and there is as a conse- 
quence much misunderstanding of the problems of workmen's compensa- 
tion, particularly for uranium miners. 

Within the internal responsibility-system at the company level, which is 
, the key to the quality of the over-all control of occupational hazards, there 
\ has been in many companies an inadequate opportunity for workers to 
\^ contribute their insight to the assessment of work conditions and to the 
basis on which management makes decisions on issues of health and safety. 
The adamantly confrontational character of Canadian labour-management 
relations has deterred the creation of sensible arrangements for worker 
participation. Questions of health and safety are not suitable issues for 
collective bargaining. The Commission has carefully defined a framework 
for the operation of joint labour-management health and safety committees 
as bodies contributive to the formulation and review of sound managerial 
policies and practices. In addition the Commission has recommended the 
introduction of a system of worker-auditors to provide to management and 
to the mines inspectorate a new dimension in the auditing of work condi- 
tions based on the insight of experienced workers. It is based on, but not 
identical to, long-established practices in the United Kingdom and Swe- 
den. Within a context whereby workers, other than in the personal act of 
work, can fulfil a proper responsibility to contribute to the resolution of 
problems of health and safety, the Commission earnestly hopes that a new 
measure of labour-management co-operation can emerge. The Commis- 
sion believes that a part of the wide variation in accident frequencies among 
different companies is related to the quality of human relations that exist 
within them, relations in which both management and the collective bar- 
gaining unit (where such exists) play crucial roles. A well-founded internal 
responsibility-system in which labour and management co-operate to con- 
trol occupational hazards ought to exhibit a high measure of self-regulation 
for which mines inspection and openly reported environmental and 
epidemiological reviews can provide the necessary external evaluation. 



25 1 Policy for occupational health and safety 

There has also been, in the Commission's view, an absence of clearly 
defined roles as a basis for initiative and accountability in institutional 
arrangements at the provincial level. This characteristic has led, under the 
stress oi' burgeoning problems oi' health and safety at Hlliot Lake and 
elsewhere, to the erosion of trust between unions, industry, and govern- 
ment agencies at the provincial level and therefore at the company level. 
The seat of this problem of roles and initiatives lies in divided jurisdictions. 
The law has not facilitated the co-ordination of roles and the implementa- 
tion of programmes to serve the well-being oi' workers in the mining 
industry; it has not kept pace with the rapidly changing social perception oi' 
the importance of occupational health and safety. 

The split jurisdiction between the Atomic Energy Control Board o\' 
Canada and the Ministry of Natural Resources of Ontario, and the related 
indefiniteness of initiatives at the provincial level, have been explored and 
recommendations made in the light of the Commission's research on the 
Uranium Nominal Roll. The health and safety problems of the uranium 
miners (and not just those at Elliot Lake) provide strong evidence that the 
historic problem of divided jurisdiction and responsibility between the 
Ministry of Natural Resources (formerly the Department of Mines) and the 
Ministry of Health must be resolved. To place this problem in final perspec- 
tive, it will be useful to review briefly the locus of legal responsibilities for 
the health and safety of all workers. 

Within the province responsibility for the health and safety of workers is 
divided between the Mining Act, the Industrial Safety Act,-^ the Construc- 
tion Safety Act,"^ and certain other pieces of legislation. In each of the 
foregoing major Acts responsibility for compliance is placed upon the 
employer, whose operations are subject to inspection by government in- 
spectors. The administration of the Mining Act (Part ix) by the Ministry of 
Natural Resources and the Mines Engineering Branch has been dealt with 
in detail in the report. The Ministry of Labour administers the Industrial 
Safety Act and the Construction Safety Act. There are distinctive jurisdic- 
tional boundaries between the work of the inspectors under these three 
acts."* The qualifications of the inspectorates are centred in engineering and 
technology. Supportive services in industrial hygiene and occupational 
health have been provided to these inspectorates by the Occupational 
Health Protection Branch of the Ministry of Health either on an ad hoc basis 
following requests or through interministerial agreements or accords.-^ 
Outside the general provisions on nuisance in the Public Health Act,^ 
which in practice are superseded by the more specific clauses of the Mining 
and other Acts, the Occupational Health Protection Branch does not have a 
defined access under the Mining Act to workplaces in mines and therefore 



252 The health and safety of workers in mines 

has no basis for taking independent initiative on problems of health and 
safety arising there. It has not been part of the role of this branch to conduct 
research on problems of the safety of workers.^ The Mines Engineering 
Branch has done excellent work in developing technical standards for 
safety, for example in mine hoisting, and provisions in Ontario for mine 
rescue have been exemplary. The Mines Accident Prevention Association 
of Ontario conducts programmes of education for the industry in accident 
prevention and some aspects of industrial hygiene. But accidents appear to 
be regarded largely as issues oi unsafe acts and unsafe conditions to be 
dealt with solely by safety regulations, inspections, and such standards of 
trainingand job assignment as are the choice of the industry. Research on 
the relation of accidental injuries to the nature and timing of work assign- 
ments, to training, to the design and operation of machines, to protective 
equipment, and to environmental factors such as noise and illumination has 
been neglected. 

Such studies into the safety aspects of the human ecology of men and 
machines are equivalent to the toxicological and epidemiological studies 
that form the basis for understanding the environmental impact of toxic 
substances on the health of workers. Is it not. for example, important to 
know whether or not a miner with a hearing defect is at greater risk of 
accidental injury than others, so that, if he is, a work adjustment policy can 
be developed to limit the risks to himself and to his co-workers? There are 
questions of stress in work which are coupled both to safety and to health. 
The separation of health from safety for workers is another false dichotomy 
sustained by policy and the institutional arrangements this policy reflects. 

The Commission believes that existing policy on occupational health 
has unduly limited the initiative of the Occupational Health Protection 
Branch and that the lack of a complementary investigative capability 
related to safety has not properly served the well-being of workers in 
mines. A major group of recommendations of the Commission has there- 
fore been designed to delineate the responsibilities of a new administrative 
entity called the Occupational Health and Safety Authority. Within this 
Authority, which will shortly be described, there would be an Occupational 
Health and Safety Branch having capabilities extended from those of the 
existing Occupational Health Branch. 

In the Commission's view the existing Occupational Health Protection 
Branch in the Ministry of Health has conducted critically important studies 
with inadequate resources and has been forced to work in a crisis-to-crisis 
atmosphere which is not conducive to the development of public under- 
standing of the complexities of occupational health and safety. The Com- 



253 Policy for occupational health and safety 

mission believes that the priority given this branch reflects the absence of a 
legal mandate and as well the massive preoccupation of the provincial 
health-care system with disease and diagnosis, as contrasted with preven- 
tive services. A further manifestation of the latter situation is the absence 
of a significant emphasis on occupational medicine, industrial hygiene, and 
ergonomics in medical and engineering education. Few mining companies 
provide their workers with the services of a resident or consulting physi- 
cian experienced in occupational medicine, and in the industry there are 
few active specialists in industrial hygiene. 

The Commission has made recommendations to deal with many of these 
questions but emphasizes that two elements are essential to the institu- 
tional arrangements of government for the safety and health of workers in 
mines. The first has been mentioned, namely, a new administrative struc- 
ture designated the Occupational Health and Safety Authority; the second 
requirement is more flexible legislation served by a strengthened inspecto- 
rate. 

The Commission has reviewed many facets of Part ix of the Mining Act, 
which, with certain sections of Part xi, establishes the legal framework for 
the health and safety of workers in mines, the most recent revision of 
which was proclaimed on 1 January 1971. Part ix of the Mining Act is 
unusual in that all technical details are incorporated in the legislation, and 
there is no provision for the making of extensive regulations by the 
Lieutenant Governor In Council. It has been suggested that the incorpora- 
tion of all technical detail into the Mining Act provides a degree of stability 
of legislative rules that allows the mining industry to plan its operations 
with the knowledge that the rules will not be changed suddenly. An alterna- 
tive view is that to protect the well-being of workers in an industry subject 
to rapid technological change this procedure is unnecessarily rigid. The 
Commission endorses the latter view. 

To reach beyond the rigidity of Part ix of the Mining Act the chief 
engineer of the Mines Engineering Branch has issued, under the general 
powers conveyed by s. 6 10(d), various codes establishing guidelines for the 
measurement of dust, for the operations and emissions of diesel engines, 
and for the exposure of workers to ionizing radiation and to noise. The 
Commission has examined the conditions surrounding the issuance of 
these codes. There have been no codes establishing guidelines for expo- 
sure to dust or to toxic chemicals. Since there is no provision in Part ix to 
incorporate these codes as part of the legislation, the codes are merely 
interpretive guidelines of the chief engineer and do not have the force of 
law. The Commission does not believe that this method of issuing codes 



254 The health and safety of workers in mines 

provides a satisfactory means for achieving the flexibility and clarity that it 
considers to be desirable for legislation governing the health and safety of 
workers in mines. 

To provide a legal and administrative structure within which to imple- 
ment the policy on health and safety for workers in mines reflected in its 
detailed recommendations, the Commission recommends: 

That a Health and Safety in Mines and Plants Act, separate from the 
Minini^ Act, he prepared to replace part IX and the relevant sections of 
part XI of the Mining Act and he administered within an Occupational 
Health and Safety Authority established in the Ministry of Labour; 

That the Health and Safety in Mines and Plants Act consist of a core of 
general provisions supplemented by regulations the issuance of which is 
authorized by the A ct: 

That the general provisions of the Health and Safety in Mines and Plants 
Act identify the duties and responsibilities of the Mines Engineering and 
Inspection Branch and the Occupational Health and Safety Branch; 

That an Occupational Health and Safety Authority, encompassing the 
Mines Engineering and Inspection Branch, the corresponding branches 
under the Industrial Safety Act and the Construction Safety Act, and the 
Occupational Health and Safety Branch, be established in the Ministry of 
Labour under an assistant deputy minister. 

The structure of the proposed Health and Safety in Mines and Plants Act 
will be considered first. Many of the general provisions and regulations of a 
new Act clearly could be adapted from Part ix of the existing Mining Act, 
which is well-elaborated in many respects. These would include the duties 
of employers, the safety of equipment, the control of hazards, and so on. 
But there is need for important additions. The general provisions in the 
core Act should include, in addition to authority for regulations and the 
definition of the duties and responsibilities of the Mines Engineering and 
Inspection Branch and Occupational Health and Safety Branch, the follow- 
ing subjects: 

- recognition of codes and schemes of practice as administrative instru- 
ments; 

- definition of joint worker-management health and safety committees; 

- definition of worker-auditors; 



255 Policy for occupational health and safety 

- definition of qualifications for supervisors and workers; 

- duties ofemployees; 

- definition of medical surveillance and services and the keeping: of occu- 
pational health and safety records; 

- procedures for enforcement of the Act and its regulations through im- 
provement notices and prohibition notices*^; 

- the basis for defining general terms such as 'approved,' 'satisfactory/ 
'adequate'; 

- a schedule of subject matter for health and safety regulations to include 
the setting of engineering and exposure standards and guidelines, and the 
conduct of research (see Health and Safety at Work etc. Act [n.8J, 
Schedule 3). 

The central function of the Health and Safety in Mines and Plants Act is 
to establish a legal basis for a policy for occupational health and safety 
which has four basic indispensable elements. The first is the setting of a 
framework of definitions and regulations within which the internal 
responsibility-system at the company level is required to function in order 
to limit to acceptable levels the risks to workers in mines and plants. The 
second is to audit the state of compliance with this framework through 
inspection. The third is to monitor the introduction of technological change 
into the industry to the extent such change impinges on the health and 
safety of workers. The fourth is to evaluate, through epidemiological 
review, related statistical studies and other research on the machines, 
materials, and risks of work, the extent and nature of the problems of injury 
and disease which are the human basis for the legislation. The recommen- 
dations throughout the report document the many points where initiative in 
epidemiological and related research is needed. 

The foregoing elements lend themselves readily to the identification of 
the duties and responsibilities of the Mines Engineering and Inspection 
Branch and of the Occupational Health and Safety Branch within the 
proposed Health and Safety in Mines and Plants Act and the associated 
Authority. The duties of each have two facets, namely, standard setting 
and auditing, monitoring, and evaluating. The Mines Engineering and 
Inspection Branch should have the primary responsibility for auditing, 
monitoring, and evaluating the operations of mines and plants. This it 
would do by inspecting operations to determine the state of compliance 
with the existing framework of regulations and by monitoring the introduc- 
tion of technological change so that regulations can be altered as required 
to adapt to such changes. In a complementary manner the Occupational 
Health and Safety Branch takes initiative to review and assess the risks 



256 The health and safety of workers in mines 

being encountered by the persons engaged in the operations of mines and 
plants and in so doing develops a basis of evaluation for the framework of 
standards which complements that of the Mines Engineering and Inspec- 
tion Branch. Further, its work is highly relevant to the responsibilities of 
the Workmen's Compensation Board for establishing and reviewing the 
basis for compensation of industrial disease and accidents. The Commis- 
sion believes that its studies demonstrate that to combine the duties and 
responsibilities described in an Occupational Health and Safety Authority 
is natural and desirable. To enable this combining of roles in the interests of 
the health and safety of workers in mines the Commission recommends 
that the jurisdiction over the proposed new Health and Safety in Mines and 
Plants Act be moved from the Ministry of Natural Resources to the Minis- 
try of Labour. The duties of the Mines Engineering and Inspection Branch 
and of the Occupational Health and Safety Branch require that their central 
staffs be located together, where they can interact personally and exercise 
their distinctive initiatives in concert. 

The proposed Occupational Health and Safety Branch can be estab- 
lished by transfer and extension of the resources and capabilities of the 
Occupational Health Protection Branch in the Ministry of Health. In pro- 
posing the transfer to the Ministry of Labour of an existing health-centred 
unit and of a mining-centred unit, the Commission is conscious of an 
important problem of professional identity for the persons involved. Our 
society is becoming more sensitive to the problems of occupational health 
and safety, but it has yet to give the public recognition merited by those 
who devote their professional lives to this field. Government policy and 
medical and engineering education attest to this fact. Thus engineers 
associated with mine inspection, whether it be in the United Kingdom or in 
Ontario, appear to derive professional identity largely from the ethos of the 
industry, as distinct from their work in controlling the risks to life and limb 
of workers. The same may be true for medical professionals. The Commis- 
sion deeply believes that occupational health and safety as an endeavour 
must be given high public recognition. 

Throughout its studies the Commission has emphasized the distinctive- 
ness of the problems of health and safety in mines and reduction plants and 
believes that a high calibre of engineering and related expertise is necessary 
in the Mines Engineering and Inspection Branch. The Commission be- 
lieves that a greater measure of openness and accountability with respect to 
the risks of work will contribute to the needed public recognition of the 
worth of careers in the field. 



257 Policy for occupational health and safety 

The Occupational Health and wSafety Authority that has been proposed 
would, under an assistant deputy minister as its executive head, be the 
administrative expression of the conjoint legal requirements expressed in 
the Health and Safety in Mines and Plants Act, the industrial Safety Act, 
and the Construction Safety Act. Its operational elements would be the 
Mines Engineering and Inspection Branch, the related branches under the 
other acts, the Occupational Health and Safety Branch, and such addi- 
tional executive staff as would be necessary for general administration, for 
the development and formulation of regulations, and for the commissioning 
of research. The directors of the branches should be members of an 
executive committee. Since the Workmen's Compensation Board is now 
under the Ministry of Labour the many important relations with that Board 
would be facilitated. The Commission observes that the scale of operations 
of the Occupational Health and Safety Authority, measured in terms of 
personnel, would be in the order of four hundred persons, that is, it would 
have critical mass yet not be unwieldy. The Commission believes that the 
administration of the branches of the Authority should be based on line 
authority from each director to the field. While the combining of the 
branches under the Occupational Health and Safety Authority should 
permit some concertation of work, it should not be an instrument for 
ill-considered homogenization. If the distinctiveness of the problems of 
health and safety in the different fields of work are respected, the replace- 
ment of the several Acts by a single health and safety at work Act would be 
a logical step in the evolution of legislative policy.^ 

To provide the Minister of Labour with advice on matters of occupa- 
tional health and safety the Commission proposes that the Labour Safety 
Council, which has a Subcommittee on Mines, be replaced by a Council on 
Occupational Health and Safety, which would reflect the unitary respon- 
sibilities of the Occupational Health and Safety Authority and be com- 
posed of representatives from industry, labour, education, and the lay 
public and government. The Council should assist the assistant deputy 
minister, the executive head of the Authority, to constitute task groups 
suited to providing advice on new regulations and standards and to advising 
on the important role of the Authority in education for health and safety 
(see chap. 4, n.22). 

It has been suggested that the mapao be transformed in structure by the 
addition of representatives of labour. Such a proposal reflects in the 
Commission's view a misconstruction of the potentialities of such an 
organization. The mapao, as one of the accident prevention associations 



258 The health and safety of workers in mines 

under the Workmen's Compensation Act, reflects the interests and 
capacities of the mining industry to engage in self-education in matters 
related to health and safety. This is a clear, limited, and, in the 
Commission's view, useful role within the whole responsibility-system. 
The labour unions in the mining industry have an opportunity for a com- 
parable role in self-education. The Minister's Council related to the Occu- 
pational Health and Safety Authority should provide a focus for input from 
industry, labour, education, and the public. 

The risks to health and safety in mining, illustrated by the sad experi- 
ence in the uranium mines and the perennial list of accidents and injuries, 
are higher than in most sectors of industry. In underground mining espe- 
cially the risks are intrinsic to the nature of the endeavour. With respect to 
fatalities in underground mining the recent record of the industry has been 
favourable compared to that in several comparable jurisdictions, but the 
experience of different companies here and in other aspects of injury and 
disease is quite varied. The Commission considers that the training of 
workers deserves special attention throughout the industry and that the 
internal responsibility-system for the performance of work in each com- 
pany deserves review in the light of the over-all findings of the Commis- 
sion. 

The acceptable levels of risks at work and in life-style are being 
redefined by society. It is essential that this process be marked by a higher 
measure of openness than has hitherto characterized government and 
industrial policy. Openness, contributive participation by workers, and 
thorough accountability can re-establish the self-regulatory character of 
the internal responsibility-system at the company level as the key to the 
control of risks at work in a technologically complex future. The regulatory 
and auditing functions of the Occupational Health and Safety Authority 
should be designed to keep the internal system at the company level alert 
and responsive and to deal bluntly with the true offender. 

The Commission believes that the objective of a sound balance between 
self-regulation and legal compulsion based on the constructive co- 
operation of all parties cannot be achieved within current government 
policy and traditional industrial practices. It has formulated its recommen- 
dations to promote the change it considers necessary for the future well 
being of the workers in the mines and plants. 



I Marc l.alonde,/^ New Perspective on the Health ofCanddiitiis. Ministry of National 
Health and Welfare. Canada. Ottawa. April 1974 



259 Policy for occupational health and safety 

2 The hii/iiMridl Safely Act. /^7/. Stiitiitesof Onlario. 1<)7I . ('h;ip. 43. iis Jimendcd b> 1972. 
Chap. 122. and Oiitaiii) Kcgiilatioii 259/72. 

3 The Construction Siifcty A(t. /VZJ. .Statutes ol" Ontario, 1973. Chap. 47. and Ontario 
Regulation 419/73. 

4 While the inspectors under the Construction .Safety Act in the Ministry of Labour inspect 
major construction sites throughout the province, they are precluded (sec ( sa, s. 3(b). 6) 
from inspecting construction on property owned by mines, which includes all the normal 
surface structures of mines and plants. In steel plants the inspectors under the Mining Act 
are responsible for inspecting operations extending from the ore unloading docks up to the 
pouring of pig iron from blast furnaces. The inspectors under the industrial Safety Act 
inspect the remainder (see Memorandum Re^ardinf> Jurisdiction of the Department of 
Labour and Department of Mines, 13 Nov. 1964). The mining inspectorate has. to the 
Commission's knowledge, had no professional staff of its own specializing in construction 
and metallurgical processes. 

5 Relations between the Industrial Safety Branch of the Ministry of Labour and the Occupa- 
tional Health Protection Branch of the Ministry of Health has in the past been guided by a 
Memorandum ofAi^reement { I March 1971). A similar Memorandum of Agreement 
between the then Environmental Health Services Branch of the Ontario Department of 
Health and the Mines Inspection Branch of the Ontario Department of Mines was drafted 
in 1969 but never endorsed. A broader interministerial accord between the Ministries of 
Labour, Natural Resources, Environment and Health on the subject of roles in occupa- 
tional and environmental health was prepared and endorsed in 1975. This internal accord 
defines the intended roles of the ministries as regards standards, inspection, environmen- 
tal monitoring, medical surveillance, records, and research in relation to occupational and 
environmental health as distinct from safety. This accord does not as such provide a legal 
mandate for an Occupational Health and Safety Protection Authority. It attempts to deal 
with the problems of jurisdictions in the operations of ministries by administrative means. 

6 The Public Health Act, Revised Statutes of Ontario, 1970, Chapter 377 as amended 1971, 
Chapter 95 (February, 1972), Sections 4 (d), 5 (2), (3), 85, 86 (g), (1). 

7 There is a Labour Safety Council consisting of persons representing labour, the accident 
prevention associations under the Workmen's Compensation Act. and government. The 
Council advises the minister of labour on changes it deems desirable in the provisions of 
safety legislation under the jurisdiction of the Ministry. It has commissioned reviews of 
literature on accidents and published reports and papers (see chap. 4.n. 1). However, it is 
basically a consultative and advisory body. The new Advisory Committee on Occupa- 
tional and Environmental Health, which advises the minister of health, is complementary 
to the Labour Safety Council. Representatives of labour sit on both councils. The Occupa- 
tional Health Protection Branch in the Ministry of Health as a branch with operational 
resources has no 'safety' counteipart in the Ministry of Labour. 

8 Health and Safety at Work etc. Act 1974, Chap. 37, London: hmso, 1975, s. 21 , 22 

9 See ibid, and Safety and Health at Work, Report of the Committee 1970-72, Chairman 
Lord Robens, London: hmso, 1972. The law in England is based on the Robens report, 
which examined the problems of fragmentation of jurisdictions in occupational health and 
safety in the United Kingdon. The chairman. Lord Robens, brought to the study 
extensive experience in mining, and the resulting Act reflects this fact. 

Worker's Protection Act and Worker's Protection Ordinance, Ministrv of Labour, Stock- 
holm, Sept. 1974 

An Act for the Promotion and Protection of the Health and Safet\ of Persons Engaged in 
Occupations, The Occupational Health Act, 1972. Saskatchewan 



APPENDIX A: RECOMMENDATIONS 



CHAPTER 2: SILICOSIS AND DUST 

1 That the Occupational Health and Safety Branch of the province con- 
duct or have conducted and publish on a regular cycle not exceeding 
five years status reports on the evolution of occupational diseases 
among miners (p. 32) 

2 That the radiological status of silicosis in the dust-exposed population 
currently employed in the Elliot Lake uranium mines and all other 
uranium mines be reviewed by the Occupational Health and Safety 
Branch on a biennial basis for a period of at least ten years (p. 33) 

3 That the radiological status of silicosis among the persons on record on 
the Uranium Nominal Roll be reviewed on a biennial basis for a period 
of at least ten years (p. 33) 

4 That the functional purpose, measuring procedures, and measured 
results relating to all environmental monitoring at the workplace be 
made known in understandable language to all affected workers and 
their representatives by the employer and as appropriate by the Mine 
Inspection Branch (p. 40) 

5 That the Mines Inspection Branch within the Occupational Health and 
Safety Authority conduct annually, or have conducted by an indepen- 
dent agency, sample measurements at representative workplaces of all 



262 Appendix a 

environmental quantities whose values are audited by the branch in 
carrying out its role (p. 43) 

6 That the Occupational Health and Safety Authority publish at least 
biennially a critical review of its appraisal of environmental conditions 
at the workplaces in the mines and mineral plants (p. 43) 

7 That the legal framework for the health and safety of workers in mines 
continue to recognize the importance of a significant component of 
collective self-regulation by industry as a whole achieved through a 
Mines Health and Safety Association (p. 46) 

8 That the Mines Inspection Branch within the Occupational Health and 
Safety Authority, in consultation with industry and the representatives 
of workers, prepare, under clearly defined statutory authority, codes 
OF PRACTICE applicable to all mines relating to: 1/ the prevention and 
confinement of dust at each distinctive class of workplace; 2/ the 
provision of ventilation in the breathing zone of workers that is effective 
for puiposes of protecting health at each distinctive class of workplace 
(including vehicles) (p. 49) 

9 That the management of each mining operation or appropriate part 
thereof be required under clearly defined statutory authority to prepare 
and keep updated a scheme of practice for implementing the fore- 
going codes (p. 49) 

10 That the management be required to appoint a competent person to 
supervise the over-all operation of the scheme (p. 49) 

1 1 That the Occupational Health and Safety Authority establish by regula- 
tion a dust standard for personal exposure to free silica in mine and 
plant aerosols based on a time-weighted average of respirable dust 
intensity over a working shift and a stipulated lifetime period of expo- 
sure (p. 50) 

12 That the dust standard for time-weighted average exposure be estab- 
lished on a statutory basis (p. 50) 

1 3 That the Occupational Health and Safety Authority immediately estab- 



263 Recommendations 

lish by legulation an interim ihieshokl limit value ( 1 1 v) foi- the mass o\' 
respirahle IVee silica in milligiams per cubic metre (p. 51) 

14 That the interim 1 1 v have the status accorded by the Occupational 
Health and Safety Authority to threshold limit values as issued by the 
American Conference ofGovernmental Industrial Hygienists (p. 51) 

15 That the Occupational Health and Safety Branch prepare a code of 
requirements for the gravimetric measurement of dust in all mines 
suited to determining personal exposure to dust (p. 5 1 ) 

16 That all steps necessary to render effective a gravimetric standard of 
dust measurement, including those listed herein, be implemented im- 
mediately (p. 51) 

17 That to provide a basis for establishing a statutory standard or stan- 
dards for time-weighted average respirable dust exposure in Ontario 
mines and plants, the Occupational Health and Safety Branch commis- 
sion epidemiological research on the relation of the incidence of 
silicosis and of other pulmonary effects to the structure and quantity of 
aerosols respired in Ontario mines (p. 53) 

18 That where more than one recognized toxic component is present in the 
aerosols the standard specify how an effective combined exposure limit 
is to be determined (p. 53) 

19 That the existing code of requirements for dust measurement in the 
uranium mines as issued by the chief engineer of the Mines Engineering 
Branch remain in force (p. 53) 

20 That the system of measurement and reporting being conducted by the 
Mines Accident Prevention Association continue in operation and be 
subject to independent monitoring as recommended (p. 54) 

21 That the current employees in the Elliot Lake uranium mines who are 
silicotics or exhibit dust effects (radiographic 4) in their lungs be eligible 
for a voluntary programme of work adjustment; that this programme be 
supported by management and unions; and that the Workmen's Com- 
pensation Board provide rehabilitative compensation and supportive 
counselling services to assist the persons involved (p. 57) 



264 Appendix a 

22 That Section 53 of the Workmen's Compensation Act be amended as 
necessary to provide clear entitlement tor rehabilitative compensation 
based on the principle ot work adjustment for persons subject to excep- 
tional exposure to environmental hazards at work (p. 57) 

23 That any employer who rotates job assignments for workmen with the 
intent of limiting the occupational exposure of any persons to any 
hazardous environmental condition be required to obtain the formal 
approval of the Occupational Health and Safety Branch and to maintain 
permanent occupational records which clearly define the persons, 
tasks, locations, hazardous conditions, and time intervals involved 
(p. 57) 

24 That during a programme of personal rehabilitation through work ad- 
justment, and for a minimum period of two years thereafter, the income 
of the worker be maintained in accordance with the provisions of the 

' Workmen's Compensation Act for full compensation which allow the 
Board to pay in non-taxable compensation 75 per cent of the difference 
between the current rate of pay and the rate of pay applicable at the date 
of entry into the programme (p. 58) 

25 That in addition to wage maintenance, the worker in a work adjustment 
programme be eligible for rehabilitation training allowances as pro- 
vided for in the Workmen's Compensation Act (p. 58) 

26 That , further, the worker be entitled to reasonable costs for medical and 
personal counselling beyond that provided by the Workmen's Compen- 
sation Board, and to reasonable moving, travelling, and related reloca- 
tion costs when these are applicable (p. 58) 

27 That when the lungs of a worker exhibit dust effects and the worker 
seeks the opportunity through work adjustment to take employment 
with a new employer, the new employer not be held liable for any 
disability pension or other costs for silicosis or disease conditions 
related thereto that may be levied as a consequence of the person 
becoming a silicotic at a future date (p. 59) 

28 That the Occupational Health and Safety Branch commission research 
on the radiographic records related to Miner's Certificates to assess the 
relative rate of progression of persons in and out of dust (p. 59) 



265 Recommendations 

29 That persons on the Uranium Nominal Roll who exhibit dust effects 
(radiographic 4) within twenty years of entry into Ontario dust expo- 
sure, and who have been employed in dust exposure in the uranium 
mines for a cumulative interval of five or more years from 1954 to 1975 
inclusive, be eligible for rehabilitation assistance under a programme of 
work adjustment (p. 60) 

30 That where there is evidence that the exposure of any person to silica- 
laden dust has been substantially in excess of established dust guide- 
lines or standards and the person has exhibited dust effects in his or her 
lungs within twenty years of first exposure to dust in Ontario, the 
person be eligible for work adjustment rehabilitation assistance (p. 60) 



CHAPTER 3: LUNG CANCER AND IONIZING 
RADIATION IN THE URANIUM MINES 

31 That the Atomic Energy Control Board confirm the extent to which 
thoron gas and its daughter products contribute to the irradiation of the 
respiratory system and other organs of workers in Ontario uranium 
mines (p. 68) 

32 That the Occupational Health and Safety Authority be given by statute 
the authority and responsibility to conduct a full and expeditious review 
of any emergent situation in which the health and safety of workers in 
mines are believed to be at unexpected risk (p. 78) 

33 That the Occupational Health and Safety Branch commission a review 
of the mortality experience of persons on the Ontario Uranium Nominal 
Roll on a biennial basis for at least ten years (p. 80) 

34 That the Atomic Energy Control Board review the basis for and issue 
explicit regulations establishing the maximum permissible annual ex- 
posure to ionizing radiation for workers in uranium and thorium mines 
and mills (p. 86) 

35 That the regulations for maximum permissible exposure delineate how 
all significant components of external and internal irradiation are to be 
accounted for and indicate how total exposure and related dose is to be 
evaluated (p. 86) 



266 Appendix a 

36 That the regulations for maximum permissible exposure and related 
dose be interpreted in units that can be monitored by practical means in 
uranium and thorium mines and mills (p. 86) 

37 That the Atomic Energy Control Board 

1/ have research conducted relevant to current circumstances al on 
means for measuring all components of ionizing radiation effective in 
contributing significantly to the irradiation of the lungs, other organs, 
and tissues of workers in Ontario uranium and thorium mines and mills; 
and hi on the spatial and temporal distribution of ionizing radiation and 
related particulates in these mines and mills; 

2/ issue codes of guidance al for the frequency and location of sampling 
required to determine both the radiation exposure of individual workers 
in Ontario mines and mills and the general state of the mine and mill 
environment; /7/for the selection, use, maintenance, and calibration of 
instruments for measuring ionizing radiation both for the determination 
of individual exposures and for the monitoring of the general mine and 
mill environment; c/ for the identification of persons for whom records 
of radiation exposure should be kept; and dl for the form, preservation, 
and use of occupational records for exposure to all significant compo- 
nents of ionizing radiation; 

3/ facilitate, with the assistance of the federal Department of Health and 
Welfare, epidemiological research on a national basis (p. 86) 

38 That the Province of Ontario, through the Occupational Health and 
Safety Authority, establish by statute a standard for maximum permis- 
sible annual exposure to ionizing radiation for workers in uranium and 
thorium mines and mills, and that this standard be in conformity with 
the regulatory standards of the Atomic Energy Control Board (p. 87) 

39 That the Occupational Health and Safety Branch be assigned by pro- 
vincial statute the responsibility to direct; 

1/ the establishment and review of occupational health records for 
workers in uranium and thorium mines and mills, for regulatory and 
epidemiological purposes; 

2/ the preparation of a code of practice for the sampling and measure- 
ment of ionizing radiation in a manner suited to the determination of the 
exposures of individual workers in uranium and thorium mines and 
mills and that this code of practice be in conformity with the code of 
guidance issued by the Atomic Energy Control Board (p. 87) 



267 Recommendations 

40 That the Mines Inspection Branch prepare regulations defining the 
kinds and tVeqiiencies of measmements of ventilation, dust and radia- 
tion necessary to enable it to audit the engineering operational charac- 
teristics of uranium and thorium mines and mills (p. 88) 

41 That these regulations be in conformity with the related code of guid- 
ance established by the Atomic Energy Control Board (p. 88) 

42 That the Occupational Health and Safety Authority specify 

1/ a level of radiation in mine or mill air measured at any time in any 
occupied workplace which, if exceeded, requires that corrective action 
be taken immediately 

2/ a level of radiation in mine or mill air measured at any time in any 
occupied workplace which, if exceeded, requires closure of the related 
workplace until the level of radiation is reduced below that specified in 1 
(p. 88) 

43 That the Occupational Health and Safety Branch commission a study of 
the mortality experience of the Ontario Uranium Nominal Roll relative 
to appropriately matched sample populations of non-uranium miners 
and non-miners in Ontario (p. 91) 

44 That the Occupational Health and Safety Authority of the province, in 
collaboration with the Atomic Energy Control Board, have conducted 
further epidemiological research based on the exposure to ionizing 
radiation among Ontario uranium miners (p. 96) 

45 That the epidemiological research include a study of 1/ the amount and 
type of exposure effective in raising cancer mortality, 2/ the pathology 
of lung cancer in miners, and 3/ the effects of cigarette smoking and of 
other conjoint occupational factors (p. 96) 

46 That persons who work in exposure to ionizing radiation in uranium 
mines cease smoking both at home and at work for their own sakes and 
in consideration of their families (p. 96) 

47 That each uranium mine install a central monitoring system for its 
ventilation network to monitor air flow and air quality as indicated by 
dust, radiation, and other contaminants (p. 102) 



268 Appendix a 

48 That the Mines Inspection Branch audit the engineering records of 
performance of mine ventilation systems (p. 102) 

49 That job rotation within mines conducted to meet the standard for 
maximum permissible annual exposure to ionizing radiation be permit- 
ted only in exceptional circumstances with the explicit approval on a 
case-by-case basis of the Occupational Health and Safety Branch and 
with the knowledge of the representatives of the workers (p. 105) 

50 That records of personal exposure to ionizing radiation maintained by 
the mines be keyed to Miner's Certificate numbers in sequence and to 
social insurance numbers in sequence and arranged in a format that 
facilitates linking to the Mining Master File (p. 107) 

51 That the frequency of regular radiographic examination of dust- 
exposed mine workers be reduced to once every two years unless a 
radiographic change was apparent at the last examination (p. 107) 

52 That tests using sputum cytology be conducted every two years on all 
persons who have worked in radiation exposure at the uranium mines 
for five or more years (p. 108) 

53 That the Workmen's Compensation Board of Ontario, in collaboration 
with other provincial boards as provided for in interprovincial agree- 
ments, seek out and advise the families of all ascertained deaths due to 
lung cancer on the Nominal Roll that a claim for compensation should 
be entered (p. 109) 



CHAPTER 4: ACCIDENTS AND INJURIES 

54 That the Workmen's Compensation Board require and make provision 
for the inclusion in non-fatal injury statistics of all non-fatal injuries in 
which the injured person fails to return to his or her regular job on the 
day following the date of the accident giving rise to the injury (p. 121) 

55 That management inform the Joint Health and Safety Committee about 
its policies on rehabilitative work assignment and in the context of 
independent medical consultation seek the advice of the Committee in 
giving wise effect to its policies (p. 121) 



269 Recommendalions 

56 That the Mines Inspection Branch base its patterns ofaiidits in part on 
studies of the relative risks involved in different segments of mining 
operations and on the related man-years at risk (p. 128) 

57 That the Occupational Health and Safety Branch publish biennially a 
critical review of factors that influence risks of accident and injury at 
workplaces in the mines and mineral plants (p. 130) 

58 That the Occupational Health and Safety Authority, in consulation with 
the Workmen's Compensation Board, industry, and labour, review the 
procedures for the reporting of injuries and accidents with a view to 
establishing links to occupational records and thereby facilitating acci- 
dent research by sample methods (p. 145) 

59 That the senior management of each mining operation review the per- 
formance of its internal responsibility-system, placing special emphasis 
on the delineation of 1/ responsibility to detect and to report departures 
from standard conditions at every level of operations, 2/ location of 
responsibility for ensuring that identified departures are dealt with, 3/ 
procedures for committing the resources to correct anomalies, and 4/ 
procedures for checking the action already taken and still to be taken 
(p. 152) 

60 That statutory provision be made for the appointment in each mine and 
plant of worker-auditors having the authority and responsibility to 
examine and report upon conditions of work pertaining to the health 
and safety of workers at sets of workplaces designated by management 
in such a way as to encompass all workplaces in underground , open pit, 
reduction plant, and shop and surface operations (p. 153) 

61 That worker-auditors be given released time with regular wages while 
performing their duties (p. 154) 

62 That the Workmen's Compensation Act be amended to make provision 
for the assessment of the costs of worker-auditors upon employers in 
class 5 (p. 154) 

63 That worker-auditors be appointed from among qualified candidates for 
a period of three years through the collective bargaining unit, where 
such exists, or be elected by the workers (p. 155) 



270 Appendix a 

64 That there be statutory provision for the appropriate worker-auditor to 
participate in the investigation of fatal accidents and serious injuries 
(p. 156) 

65 That the designated worker-auditor have the privilege of cross- 
examining witnesses at an inquest into any fatal accident whose cir- 
cumstances he has participated in investigating (p. 156) 

66 That there be statutory provision for the establishment of a Joint 
Labour-Management Health and Safety Committee at each mine and 
plant (p. 157) 

67 That the membership of the Committee consist of equal numbers of 
persons appointed by management and appointed by members of the 
collective bargaining unit(s), where such exist, and otherwise elected 
by the workers collectively , subject to the constraint that at least two of 
the persons selected be worker-auditors (p. 157) 

68 That the Joint Committee conduct its work as far as feasible during 
regular hours of work and that its members receive their regular wages 
while engaged on committee work (p. 157) 

69 That the Joint Committee meet regularly at least four times per year and 
not more often than once monthly (p. 158) 

70 That each mining company provide its employees with a written state- 
ment outlining its policy for health and safety and the organizational 
arrangements and responsibilities for giving effect to it (p. 160) 

7 1 That the core of the staff of the Mines Inspection Branch continue to be 
based on persons of exceptional professional experience in mining, and 
related fields of engineering, supplemented by special training in occu- 
pational health and safety and in the principles of the administration of 
work (p. 163) 

72 That task groups set up by the Occupational Health and Safety Author- 
ity to advise on codes of practice and statutory regulations relating to 
technological change in mining include representatives of labour 

(p. 163) 



271 Recommendations 

73 That the industry, government, and labour give high priority to the 
development, standardization, and accreditation of modular training 
and qualification for woikers in mines and plants (p. 169) 

74 That persons assigned to work alone be required to have specified 
qualifications for independent work at the job to which they are as- 
signed (p. 174) 

75 That on all shifts persons working alone be visited at the place of work 
at least three times (other than at the start of a shift) by a first-line 
supervisor (p. 174) 

76 That such visits may be reduced to once per shift (other than at the start 
of a shift) if 1/ work conditions are standard, and 2/ means of communi- 
cation are provided and a record of use thereof is kept so that the person 
working alone reports his status to a point of supervision or to a 
designated fellow worker not less often than once every two hours 

(p. 174) 

77 That where the location of work is sufficiently remote to warrant the use 
of technical means of communication and where no illumination other 
than that of the miner's cap lamp is normally available, an auxiliary 
source of illumination powered by means other than the miner's lamp 
battery be provided at the workplace (p. 175) 

78 That all fatalities and serious injuries to persons working alone under- 
ground be the subject of biennial review by the Occupational Health 
and Safety Branch (p. 175) 

79 That section 169( 16)(b) be amended (and be included in a revised Act. to 
be recommended) to require the supervisor to make a written report 
which: 1/ states the nature of the condition of the machine or device 
which in the worker's belief renders it unsafe for use; 2/ gives the 
supervisor's comments at the time; and 3/ gives the supervisor's 
confirmation or otherwise that section 169( 15) is, in the supervisor's 
view, satisfied (p. 176) 

80 That the worker who refers a machine or device to his supervisor under 
section 169( 16)(b) as amended sign and receive a copy of the 
supervisor's report (p. 177) 



272 Appendix a 

8 1 That where a worker after due consultation with his immediate super- 
visor, beheves that the work then assigned cannot be performed by 
standard procedures without encountering personal risks deemed by 
him to be unreasonable, there be a statutory requirement that the work 
situation be examined and judged by a member of senior supervision in 
the presence of a worker-auditor acting as an observer and that a report 
of the circumstances be made to the mines inspectorate by the manager 
(p. 178) 



CHAPTER 5: OTHER ENVIRONMENTAL HAZARDS AT 
THE WORKPLACE 

82 That there be a statutory requirement for a metallurgical audit of origin, 
holdup, and destination of potentially dangerous minor elements such 
as lead, mercury , arsenic, selenium, tellurium, cadmium, and antimony 
to be conducted quarterly in all reduction plants on the basis of ex- 
tended standard monthly sampling and analytical procedures, and that 
a copy of this audit be sent to the Occupational Health and Safety 
Authority (p. 200) 

83 That there be a statutory requirement for an annual audit of use by mass 
of toxic and hazardous reagents and that a copy be sent to the Occupa- 
tional Health and Safety Authority (p. 200) 

84 That pilot plant studies used to develop processes and preliminary 
operating procedures be extended to include the measurement of fac- 
tors likely to have an impact on the health and safety of the environment 
for work (p. 200) 

85 That there be a statutory requirement for each mining company to 
maintain a register of servicing chemicals involved in any personal 
encounter associated with a medical aid or compensable injury ; that the 
register specify both trade name and chemical composition and identify 
all known toxic chemical constituents; that the register include an audit 
by mass of annual use; and that a copy of this register be provided to the 
Occupational Health and Safety Authority (p. 204) 

86 That there be a statutory requirement for each mining company to give 
the Occupational Health and Safely Authority notice of intent to intro- 



273 Recommendations 

duceany new reagent or servicing chemical whose toxic characteristics 
are not known (p. 204) 

87 That with respect to codes of practice and schemes of practice the 
principles of recommendations 8, 9, and 10 be extended 1/ to the 
maintenance and operation of mills and metallurgical plants as these 
activities relate to the leaking and spilling of toxic substances and hot 
materials into workplaces; 2/ to the handling and use of reagents and 
servicing chemicals and to the consequences of their leaks and spills 
(p. 204) 

88 That engineering schools review and redefine their responsibility to the 
profession to ensure that graduates are more keenly aware of and 
responsive to the impact of technological design upon the occupational 
health and safety of workers (p. 205) 

89 That resources for joint research and teaching by specialists in occupa- 
tional health and safety in faculties of medicine and engineering be 
given high priority by both the universities and government (p. 205) 

90 That profiles of risk-encounter for toxic substances be developed by 
examining the work patterns of maintenance workers, and that modular 
training be adapted to such profiles (p. 206) 

9 1 That at any location of regular work where acute encounters with toxic 
substances repeatedly occur as a result of leaking, recirculating, or 
spilling from metallurgical and milling processes, there be a statutory 
requirement for the installation and use of equipment for the continuous 
monitoring of the substances involved (p. 206) 

92 That a record of the substances and human effects of acute encounters 
with toxic substances leading to medical aid and compensable injuries 
be maintained in the occupational health records of each worker at the 
company level (p. 207) 

93 That at five-year intervals the Occupational Health and Safety Branch 
commission a review of the status of the health of samples of persons 
who are at high risk from acute encounters with toxic substances, 
including as necessary intensive medical surveillance (p. 207) 



274 Appendix a 

94 That epidemiological reviews of selected populations subject to chronic 
exposure to toxic substances in reduction plants and mines matched to 
suitable control groups be conducted on a five-year cycle by or under 
the guidance of the Occupational Health and Safety Branch and that the 
essential results of such studies be summarized and published upon 
completion (p. 212) 

95 That a nominal roll of workers at risk of exposure to nickel carbonyl in 
reduction plants and pilot plants be established by the Occupational 
Health and Safety Authority, in co-operation with the industry and that 
the morbidity and the mortality experience of this nominal roll be 
reviewed at least every five years (p. 213) 

96 That the appropriate substance or intent of recommendations 8, 9, 10, 
39(2), 40, 42, and 46 be made applicable to asbestos mines and plants 
(p. 215) 

97 That the Occupational Health and Safety Authority establish, with the 
co-operation of the Workmen's Compensation Board and the mining 
industry, a nominal roll of all persons who have worked one or more 
months in exposure to asbestos dust in asbestos mines and plants 

(p. 215) 

98 That the Occupational Health and Safety Branch commission a review 
of the radiographic record and of the mortality experience for the 
asbestos nominal roll on a five-year cycle (p. 215) 

99 That workers in reduction plants who have been exposed for twenty 
years or longer to sulphur dioxide at levels approaching the current 
Threshold Limit Value and to associated dust and fumes, and who 
exhibit the clinical diagnosis of chronic bronchitis and impaired pulmo- 
nary function as identified by objective tests, be considered for com- 
pensation at up to a maximum of 20 per cent disability (p. 219) 

100 That the Occupational Health and Safety Authority, in co-operation 
with the industry and labour, prepare a code of requirements fordiesel 
emissions (p. 222) 

101 That the Mines Inspection Branch prepare a code of practice for the 
provision of ventilation and for the fuelling, operation, and mainte- 
nance of diesel engines (p. 222) 



275 Recommendations 

102 That each mine using diesel equipment be required to file with the 
Mines Inspection Branch a scheme of practice tor the short-term and 
long-term maintenance of its diesel engines (p. 222) 

103 That each mining operation maintain noise maps based on full-scale 
conditions of operation which delineate all areas of work at which the 
noise level is 85 dB(A) or higher (p. 229) 

104 That the mining industry, in co-operation with labour and the Occupa- 
tional Health and Safety Authority, have conducted research to deter- 
mine shift-profiles of noise encounter for representative occupations in 
mines and plants both in the absence and in the presence of actual and 
best-available hearing protection, that such profiles be codified and 
published, and that a code be assigned to each worker who regularly 
encounters areas of work in which noise levels of 85 dB(A) or higher 
exist (p. 230) 

105 That the mining industry and equipment manufacturers, with the 
Canadian Standards Association, expedite the development of stan- 
dards for the assessment of noise from mining equipment, and for the 
performance of personal safety equipment and cab enclosures in at- 
tenuating noise, and that such standards be invoked by the industry in 
specifying noise performance requirements for new equipment (p. 230) 

106 That the Occupational Health and Safety Authority issue a code of 
practice for the selection and use of personal hearing protection and for 
communicating in the presence of noise (p. 231) 

107 That, by statute, each mining company be made responsible for main- 
taining effective audiometric records for each employee who in the 
absence of hearing protection regularly encounters noise at levels of 
85 dB(A) or higher, and that such audiometric records be required to be 
keyed 1/ to social insurance numbers, 2/ to Miner's Certificate numbers 
where such have been assigned, and 3/ to a code number of 
noise-profile-encounter as previously recommended (p. 232) 

108 That the Occupational Health and Safety Branch commission on a 
five-year cycle statistical assessments of the state of hearing among 
sample populations of workers in mines, and that the first review be of 
production crews in underground operations, including diesel 
operators (p. 232) 



276 Appendix a 

109 That the Occupational Health and Safety Branch regularly inspect all 
audiometric testing facilities not under the supervision of a designated 
medical specialist, and that any designated medical specialist be re- 
quired to certify biennially in writing that the facilities under his super- 
vision conform to the minimum standards of the Branch as then 
current (p. 233) 

1 10 That the Occupational Health and Safety Authority be assigned by 
statute the responsibility to establish standards or guidelines for per- 
sonal exposure to all toxic substances and hazardous physical agents 
and that, subject to any statutory standards and in consultation with 
industry and labour, the Authority issue a code of practice for the 
application in mines and plants of the Threshold Limit Values of the 
American Conference of Governmental Industrial Hygienists (p. 235) 

1 1 1 That the mining industry establish for its employees, where such is not 
now provided, occupational health surveillance by a supervising medi- 
cal director or consultant experienced in occupational medicine (p. 237) 

1 12 That the labour unions individually or in consort appoint to their staff a 
consulting specialist in occupational medicine (p. 237) 

1 13 That under the Workmen's Compensation Act provision be made for 
the levying on all employers in class 5 an amount of 0.03 per cent of 
wages currently subject to levy under the Act to create a fund for 
research on occupational health and safety by the joint labour- 
management health and safety committees (p. 239) 



CHAPTER 6: POLICY FOR OCCUPATIONAL HEALTH 
AND SAFETY IN IHE MINING INDUSTRY 

14 That a Health and Safety in Mines and Plants Act, separate from the 
Mining Act, be prepared to replace part ix and the relevant sections of 
part XI of the Mining Act and be administered within an Occupational 
Health and Safety Authority established in the Ministry of Labour 

(p. 254) 

1 5 That the Health and Safety in Mines and Plants Act consist of a core of 



277 Recommendations 

general provisions supplemented by regulations the issuance of which 
is authorized by the Act (p. 254) 

1 16 That the general provisions ot the Health and Safety in Mines and 
Plants Act identify the duties and responsibilities of the Mines f{n- 
gineering and Inspection Branch and the Occcupational Health and 
Safety Branch (p. 254) 

1 17 That an Occupational Health and Safety Authority, encompassing the 
Mines Engineering and Inspection Branch, the corresponding branches 
under the Industrial Safety Act and the Construction Safety Act, and 
the Occupational Health and Safety Branch, be established in the 
Ministry of Labour under an assistant deputy minister (p. 254) 



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APPHNDIX C: R A D 1 () (; i- N i C I.UN(j CANC1,K IN 
ONTARIO URANIUM MINERS 1955-74 



The findings presented in this appendix are based on data about eighty-one 
deaths of miners or former miners from lung cancer during the period 
1955-74 (see Table c.4), together with corresponding data on eighty-one 
other miners who were still alive at the end of that period. That is, these 
findings are derived from comparisons internal to the population listed on 
the Uranium Nominal Roll. For proper interpretation of these findings it is 
necessary to keep in mind the main mortality study, as summarized in 
chapter 3, in which the miners' experience of lung cancer was compared 
with an external standard, namely, that set by the contemporary mortality 
rates of Ontario male residents. It was there inferred that the eighty-one 
lung cancer deaths comprise a mixture, in approximately equal propor- 
tions, of cases that would have occurred even if the miners had not been 
exposed to any unusual risks and cases attributable to the special circums- 
tances of uranium mining.' 

Work histories have been compiled by the Workmen's Compensation 
Board for all current and former Ontario uranium miners, but not in 
machine-readable form, so that to have analysed this material in its entirety 
would have involved unjustifiable cost and delay. A comparison series for 
the lung cancer cases was therefore constituted on a sample basis (with a 
saving of approximately two and one-half man-years of clerical work) as 
follows. From among members of the Nominal Roll whose certificate 
numbers ended in the randomly chosen digits 34, of whom there were 158, 
there were first eliminated eleven men known to have died within the study 
period. Of the 147 survivors, 80 who had been born in or before February 
1933 were of an age to have been in the work force when hiring began for the 
Ontario uranium mines in 1954- as were 80 of the 81 fatal lung cancers so 
far ascertained - and these were all included in the comparison series. To 



320 Appendix c 

balance the one cancer case bom in 1936, one more comparison subject 
was selected at random from among the five available survivors in the 1 per 
cent sample who had been born in that year. 

The use of randomly selected surviving subjects for the comparison 
series was convenient and appropriate, but unless a special correction was 
made it could have introduced a bias in the comparison of exposure 
histories. This would arise because the survivors could continue to work 
and to accumulate further exposure right up to the end of 1974, by which 
time all members of the case series were dead. To counteract this bias each 
member of the comparison series was assigned a notional 'year of death,' 
equal to the actual year of death of a case with which it had been paired in a 
random fashion. (For this matching the cases were sequenced in order of 
entering the industry, survivors in the order- approximately alphabetical - 
in which they appear in the Nominal Roll.) Exposures incurred later than 
this notional year of death were then deleted from the data. 

An initial comparison between the lung cancer cases and the survivors in 
terms of the number of months worked in Ontario uranium mines showed 
that the cases, with an average of 43.2 months, had significantly longer 
exposure than the survivors (average of 25.6 months), by a margin of 69 per 
cent. When these months are weighted by the corresponding exposure 
levels (based on mine averages for years up to 1968 and on personal records 
thereafter) to obtain average numbers of Working Level Months, the 
margin of difference widens to 127 per cent (cases 74.5 wlm, survivors 32.8 
wlm). Thus the records of exposure level, however imperfect they may be, 
do yield an index that discriminates more effectively between cases and 
survivors than the index based on duration of exposure alone. This 
strengthens the presumption that ionizing radiation, rather than some 
other, as yet unidentified, factor associated with uranium mining is respon- 
sible for the excessive frequency of lung cancer in uranium miners. These 
statistics also illustrate the distinctive character of the experience in On- 
tario, where the typical exposures have been in the under-100 wlm range, 
concerning which there is little to be learned from the us data except by 
hazardous extrapolation (Lundin et al., 1971). 

Though the exposures reported in the present study are small compared 
with those reported from Colorado, they are just as likely to overstate the 
quantity of radiation actually needed to produce cancer, and this for the 
same essentially statistical reason, which needs to be clarified before the 
exposition is taken further. The process of carcinogenesis in man is be- 
lieved to require a lapse of time between a causal exposure and its overt 
effect which is both long, being measured in years or even decades, and 



321 Lung cancer 

highly variable between individuals. |{mpirical studies further suggest that 
the statistical distiibution of such time intervals may be oflognormal form 
(Armenian and Lilienteld, 1974), that is, with the majority of cases develop- 
ing after a period of time exceeding the modal interval. This lapse of time 
provides an opportunity for subjects who have already been affected by 
prior exposure to accumulate further exposures, which contribute nothing 
to the outcome already determined and yet add to the apparent dose, if, for 
each individual, the amounts of exposure in successive time intervals were 
independent, these adventitious extra doses would shift the dose-response 
curve to the right (possibly suggesting the presence of a 'quasi-threshold': 
Stewart, 1975) but would not otherwise modify its slope to any important 
extent. In the real world, however, there will usually be some correlation of 
exposure levels between successive time intervals. Negative correlation 
would tend to obliterate the exposure difference between affected and 
unaffected subjects. Positive correlation between time intervals^ would 
tend to inflate this difference, thus overstating the amount of exposure 
required to produce an effect and understating the increment of risk per 
unit exposure. This point can easily elude any investigator who is accus- 
tomed to think in terms of research by means of tidily planned experiments 
- in which such complications can be prevented from arising - rather than 
in terms of an observational discipline such as epidemiology. 

If the form and parameter values of the latent interval distribution were 
already known, one could compute the 'relevant' dose for each subject as 
an appropriately weighted sum of the doses received in each time-interval 
prior to death or onset. Unfortunately this is not the situation with 
radiogenic lung cancer: no certainly appropriate set of weights is yet 
available, and various plausible sets suggest wholly different values of risk 
per unit dose. It is hoped that further analyses of the Ontario data will help 
to define the latent interval distribution for radiogenic lung cancer. In this 
interim report the convention has been adopted of giving all intervals equal 
weight, except for the terminal interval, which is given zero weight."* This is 
the basis on which Table c. 1 and Figure c. 1 have been constructed, for the 
sole puipose of testing whether there is any detectable dependence of lung 
cancer risk on dose within the range of doses experienced by Ontario 
uranium miners. This analysis is most emphatically not offered as the basis 
for any estimate of risk per unit dose. In Table c. 1 the lung cancer cases and 
surviving subjects are classified into three major ranges of wlm. A test has 
been made of the null hypothesis that the underlying distribution over these 
ranges was the same for cancer deaths and for survivors. This hypothesis 
was easily discredited (x^2) ^ 11.76; P < 0.005), the data favouring a 



322 Appendix c 



TABLE c.l 

Dependence of lung cancer risk on total wlm 



Range of 

total WLM 



Numbers of 



cancer deaths 



Tea 
Lcc 



comparison survivors 



in this range of wlm 



Expected 



Observed 



If risk not 
related to wlm 



If risk increases 
linearly with wlm 







1-29 



30-59 



60-89 



90-119 



120 + 



Total 



Goodness of fit 
between observed 
and expected 




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displacement of cases towards higher wlm or, to put it more familiarly, an 
increase in lung cancer risk with increasing dose. 

The next simplest hypothesis is that of a linear dependence of risk 
[indexed by the ratio cases/( 100 x survivors)], as plotted in Figure c. 1 for 
six ranges of total wlm. The area of each spot in this diagram has been 
made proportional to the quantity {CS)I{C +5), where C and S are the 
numbers of cancer cases and surviving subjects within the dose range. 
These quantities were also used as weights in computing the fitted straight 
line, from which, in turn, were computed the expected frequencies shown 
in the right-hand column of Table c.l. Because this fitting procedure 
absorbs one degree of freedom, there is only one degree of freedom left for 
testing the goodness of fit between the observed frequencies (30, 48; 26, 48; 



323 Lung cancer 



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00 



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120 



180 



Total WLM experienced in Ontario uranium mines 

FIGURE c. 1 Relationship between total wlm experienced in Ontario and risk of 
lung cancer. 



25, 9) and the second set of expected frequencies (26.20, 51.80; etc.). The 
comparatively small discrepancies are now within the limits of chance 
fluctuation (x^,,, = 1.83; P >0. 17). Hence there is no statistical justification 
for fitting any more complex model (threshold, multiple hit, etc.) to these 
data. The possibility of a 'safe' threshold dose cannot be excluded by 
these, or by any other finite amount of data. However, further analyses, to 
be reported in full elsewhere, have shown that, to be at all plausible in 
relation to the Ontario experience, a postulated threshold would have to be 
lower than 10 wlm. 

Given that there is dose-dependent variation in cancer risk within the 
range of doses experienced by Ontario uranium miners, te^gether with some 
knowledge of historical and geographical variations in working levels 
within the province (see Table 18 in text), two testable predictions can 
be made; 
1 A history of employment at the Bancroft camp will prove to be as- 



324 Appendix c 



TABLE C.2 

Estimates of relative risk associated with area and 
calendar period of entry into uranium mining in Ontario 



Characteristic 
of cases 



Cancer Surviving 
cases subjects 

(N) (N) 



Relative risk estimate 



Ever worked in 28 16 

Bancroft area 

Never worked in 53 65 

Bancroft area 



Risk of dying of cancer 
by 1974 for persons 
ever working in Bancroft 
area relative to those 
who never worker there 



28 / 53 
16 / 65 



= 4^ -TT = 2.1" 



Entered exposure in 
or before 1957 



53 



Entered exposure in 28 
or after 1958 



35 



46 



Risk of dying of cancer 
by 1974 for persons 
entering exposure before 
1958, relative to those 
who entered thereafter 



35 /46 ~ ^-^ 



a Significant at P < 0.05 
b Significant at P < 0.01 



sociated with a high relative risk of lung cancer (MacMahon and Pugh, 
1970). This prediction is verified, at a satisfactory level of statistical 
significance, by the figures shown in the upper half of Table c.2, where it 
appears that men with any period of employment at Bancroft have experi- 
enced a lung cancer risk about twice as great as that for men who have 
worked only at Elliot Lake.'* 

2 Early entry into the industry will prove to have been associated with a 
high relative risk of lung cancer. This prediction is verified, at a satisfactory 
level of statistical significance, by the figures shown in the lower half of 
Table c.2, where it appears that men whose exposure began in the first few 
years of the industry have experienced a lung cancer risk more than double 
that of cohorts entering in 1958 or later years. 

The principal shortcoming of the Ontario study material on lung cancer 
in uranium miners is that at present it contains no data on individual 
smoking habits thai can be linked to the radiation exposure histories. This 
is unfortunate because cigarette smoking is quite possibly a more important 
determinant of lung cancer, even in this irradiated population, than the 
radiation itself, and it is important to gain some appreciation of the way in 
which these two factors relate to one another - whether, for example, their 
effects on cancer risk are simply additive or multiplicative. However, there 



325 Lung cancer 



TABLE C.3 

Estimate of rcli 
by age at entry 


itivc 
into 


risk associated with wi.m of 30 or 
uranium mining in Ontario 


more, 




Age at entry 




Total 

WLM 


Number of 

cancer 

cases 


Number of 

survivor 

subjects 


Relative 
risk estimate 


Up to 35 




Up to 29 
30 and over 


7 
15 


28 
25 


25/ 28 ~ ^-^ 


36 and over 




Up to 29 

30 and over 


23 
36 


20 

8 


8/ 20 " ^^ 



is no shortage of information on age, which in turn is an even more 
important determinant of risk than smoking, in as much as the death rate 
from lung cancer increases approximately with the seventh power of age 
(data for Ontario male residents aged 25-65, period 1960-9). The interac- 
tion between the factors of age and exposure to the uranium mining envi- 
ronment was analysed in the general mortality study, where miners' lung 
cancer deaths in excess of the Ontario male standard were found to have an 
age-distribution incompatible with the hypothesis of simple additivity, and 
in good agreement with a multiplicative effect. That is, age-specific mortal- 
ity rates were found to be increased by a constant/ac/or, rather than by an 
equal absolute amount. This question, which is vital for prediction, and 
hence for policy-making, can also be studied on the basis of comparisons 
internal to the mining population, and Table c.3 has been drawn up to 
illustrate the method. If exposure to 30 or more wlm entailed the same 
additional risk of lung cancer for miners of any age, then the relative risk 
(MacMahon and Pugh, 1970) would be much higher at young ages (when 
spontaneous cancer rates are much lower). So far from this being the case. 
Table c.3 indicates a relative risk for men first exposed after age thirty-six 
fully as high as, if not higher than, for those exposed before age thirty-five.-*^ 
It is therefore reasonable to infer that a given amount of exposure can be 
more harmful to a subject whose expectation of cancer is already high than 
to one whose expectation is lower. Strictly speaking this has only been 
shown in relation to age, but it would be prudent to think in terms of 
more-than-additive effects when radiation is conjoined with other risk 
factors, possibly even including previous irradiation. In this way it would 
also be possible, without postulating any true threshold, to accommodate 



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329 Lung cancer 

the idea of a response more than proportional to cumulative dose, f'inally, 
it must be stressed that the evidence reviewed here all relates to effects 
expressed within twenty years of exposure. In the long run, when effects 
are summed over the remaining lifespan of those exposed, it could well be 
that exposure of a younger subject is more harmful than physically equival- 
ent exposure of an older subject; indeed, this is quite likely to be true if the 
latent interval distribution does have a lognormal form. 

DAVID HEWITT, Associdtc Profcssof, Department oj Preventive Medicine 
and Biostatistics, University of Toronto 

1 A conservative estimate of the component attributable to occupational factors is 44 per 
cent (=(81 - 45)/8l); a more realistic estimate, incorporating an allowance for under- 
ascertainment of miners' deaths in the present study, is 52 percent ( =(93 - 45)/93). Three 
additional deaths of miners, known to have had lung cancer but certified as having died of 
other causes, have been omitted from both the external and internal comparisons. 

2 For 159 miners surviving through 1961, the correlation between wlms received in 1960 
and 1961 was +0.742. 

3 The intervals used in the analysis are necessarily calendar years. For members of the 
survivor series the terminal year is a full twelve-month period; for cases, it is on average 
only six months long and falls mainly within the period between diagnosis of the fatal 
illness and death. 

4 With or without some out-of-province exposure in uranium mines 

5 It may also be observed in Table c.3 that, within the comparison series taken to be 
representative of the uranium mining population generally, a higher proportion of the 
younger men accumulated a dose in excess of 30 wlm (25/53 compared with 8/28). It seems 
that any bias introduced by omission of age-matching (except at the cut-point of birth in 
1933) may have been a conservative one. In other words, it is reasonable to suppose that a 
comparison using more precise age-matching would have yielded at least as strong a 
contrast between cases and survivors as that shown in Table c. 1 and Figure c. 1 . 



REFERENCES 

Armenian, H.K. and A.M. Lilienfeld ( 1974) American Journal of 

Epidemiology, 99, 92 

Lundin, F.E. jr, J.K. Wagoner, and V.G. Archer {\97 \) Radon Daughter 

Exposure and Respiratory Cancer: Quantitative and Temporal Aspects, 

National Institute for Occupational Safety and Health, National Institute 

of Environmental Health Sciences, Joint Monograph No. 1, us Dept of 

Health, Education and Welfare 

MacMahon, B. and T.F. Pugh (1970) Epidemiology -Principles and 

Methods, Boston 

Stewart, C.G. (1975) 'Dose response relations: the incidence of carcinomas 

of the lung in uranium miners,' lecture given to the Japan Nuclear Safety 

Research Association 



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TABLE D.6 

Estimated distribution of the workforce 
in the mining industry 1971 





Proportion 




of 




employees 


Age (years)" 




<20 


0.039 


20-24 


0.179 


25-29 


0.132 


30-34 


0.117 


35-39 


0.111 


40-44 


0.108 


45-49 


0.098 


50-54 


0.088 


55-59 


0.073 


>60 


0.055 


Work experience 




with company {yearsY 




<1 


0.119 


1-5 


0.141 


>5 


0.740 


Shift' 




7-3 


0.589 


3-11 


0.284 


11-7 


0.127 


Category of personnel'* 




Unskilled and semi-skilled 


0.35-0.65 


Skilled trades 


0.45-0.15 


Engineering/Technical 


0.05 


Management/Supervision 


0.10 


Clerical 


0.05 



a From Statistics Canada, Census of 
Canada, 1971, Ottawa, 1975 

b Based on data supplied by inco Ltd 

c See note h 

d Data provided to the Commission by 
companies. The higher percentage of 
unskilled and semi-skilled personnel 
applies in operations that are primarily 
underground and do not have complete 
processing plants 






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TABLE 1x8 

Non-fatal injuries 1970-4 by type of accident 
and bodily region of injury 





Proportion 


Proportion 




of injuries 


of injuries 




1974 


1970-4 


Type of accident 






Slips and falls 


0.246 


0.272 


Collisions 


0.170 


0.180 


Over-exertion 


0.178 


0.182 


Caught between 


0.109 


0.115 


Free-falling objects 


0.058 


0.051 


Rock falls 


0.076 


0.065 


Propelled flying objects 


0.024 


0.037 


Extreme temperature 


0.030 


0.025 


Inhalation 


0.043 


0.019 


Nails, splinters 


0.020 


0.016 


Run of muck 


0.009 


0.011 


Explosives 


0.004 


0.005 


Other 


0.033 


0.021 


Region of injury 






Head and neck 


0.126 


0.119 


Torso 


0.296 


0.308 


Hands, arms, 






legs, and feet 


0.569 


0.561 


Other 


0.009 


0.012 



source: Mines Accident Prevention Association of Ontario, 
Annual Reports 1974-1975 



TABLE D.9 

Comparison of actual deaths of Northern Ontario males 
with expected deaths for all Ontario males 



Violent causes 
1374 : 934.91 



Motor vehicle accidents 

468 : 368.34 
Suicide 

192 : 147.12 
Other 

714 : 419.45 



All causes 

9554 : 8410.26 



'Natural' Causes 
8180 : 7475.35 



Respiratory tuberculosis 

39 : 25.62 
Cancer of lung 

370 : 345 
Cancer of stomach 

182 : 128.75 
Arteriosclerotic heart disease 

3514 : 3060.78 
Hypertension 

115 : 103.67 
Respiratory disease 

578 : 542.86 
Balance 

3382 : 3268.64 



APPHNDIX H: STUDIES C () N D U C I i: D \()\< \\\E 
COMMISSION 



The mortality experience of persons With the Assistance of Statistics 



on the Uranium Nominal Roll 

1955-74 

D. Hewitt, Associate Professor, 
Department of Preventive 
Medicine and Biostatistics, Uni- 
versity of Toronto 

Radiogenic lung cancer in Ontario 

uranium miners 1955-74 

D. Hewitt, Associate Professor, 
Department of Preventive 
Medicine and Biostatistics, Uni- 
versity of Toronto 



Canada, the Registrars General, the 
Workmen's Compensation Board, 
the Ministry of Health, and the 
Ministry of Natural Resources. 
Major results are included in chap- 
ter 3. 

As above, except that the major re- 
sults are included as appendix c. 



Health and safety in mines 
F.D.K. Liddell, Professor of 
Medical Statistics, McGill Uni- 
versity 



An annotated bibliography on the 
pneumoconioses, asbestosis and 
silicosis, on lung cancer, and on 
chronic obstructive pulmonary dis- 
ease. 



Study of health and safety in metal- 
lurgical plants 

Jan H. Reimers and Associates 

Ltd 



A study of health and safety aspects 
of the design and operation of metal- 
lurgical plants. Representative pro- 
cess flow sheets are included in 
chapters. 



7S- ^ 



gublications 



•■^^