Mr Tonhauser was speaking in Brussels, Belgium at the start of a two-day workshop on the prospects of a civil nuclear liability regime within the framework of the European Union. The workshop is studying the obstacles to a harmonised civil nuclear liability system for Europe, including the compatibility of a European system with a global regime.

“We are faced with a fragmented situation in both Europe and in the world,” said Mr Tonhauser, referring to the “patchwork” of nuclear liability regimes followed by both nuclear and non-nuclear states.

Nuclear third party liability rules are not harmonised in the EU, where with the exception of five countries, all member states accede to either the Paris or Vienna Convention. For most of these states, the Joint Protocol formed under the Organisation for Economic Cooperation and Development (OECD) and IAEA also applies.

“The difficulties arising are not necessarily from a lack of uniformity of the rules, but the inadequacy of some of the rules and the levels of compensation,” said a representative from the Irish government’s environmental policy radiation section.

But Julia Schwartz of the OECD’s Nuclear Energy Agency said the international conventions provide a degree of certainty. “The reason international regimes have attracted such support is that they are comprehensive regimes that are applicable to all third party victims.”

Ms Schwartz, head of legal affairs at the NEA, said that the agency “would support a harmonised nuclear liability law in the European Union and a regime which provides the best support for the victims”. But “the adoption of an additional EU-only regime would simply complicate the patchwork of systems in place”.