ICNIRP's guidelines

ICNIRP (the International Commission on Non-IonisingRadiation Protection) ICNIRP was formed in 1992. In 1998 ICNIRP published itsthermal (heating and shock) guidelines. These have beenwidely criticized for rejecting evidence of adverse health effectsat sub-thermal or biological and cancer levels. Many scientistsnow feel that, unless ICNIRP adopts appropriate biologicalguidelines, it should be disbanded or its membership should bereplaced by those who accept biological evidence. Suchscientists could be drawn from the authors of the BioInitiativeReport in 2007 or the International Commission forElectromagnetic Safety (ICEMS) or the many medical doctorswho have petitioned governments to set new standards, alongwith the many other concerned scientists around the world whoargue that to protect the human race it is essential to havebiological and cancer safety guidelines. Weaknesses in ICNIRP’s rationale for its 1998guidelines

1.    A supposed absence of “consistency” and“established effects”. A typical phrase in ICNIRP’s justification forrejecting the thousands of studies showingsub-thermal adverse effects is that there is “noconsistent evidence of adverse … effects” (p.498).

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Thus, if a few studies, perhaps sponsored byindustry show no effects, these negative findingsare held by ICNIRP to outweigh all the positivefindings by independent scientists. Another wordbased on similar reasoning is “established”. ThusICNIRP states that “Restrictions on the effects ofexposure are based on established health effects”(p.508), although it is not often made clear howstudies would provide the “established” effectsnecessary for instituting biological guidelinescompared with heating safety levels, despite thefact that many scientists would accept that manysub-heating effects are now very well “established”.. 2.    A supposed absence of mechanism. Where a possible mechanism has not been fullyelucidated, ICNIRP feels competent to rejectepidemiological results it otherwise accepts. Thusthe link between power lines and childhoodleukaemia was published in 1979 and almost allscientists now accept its validity. Even ICNIRP in1998 accepted its validity from epidemiologicalevidence - “The fact that results for leukemia basedon proximity of homes to power lines are relativelyconsistent …” (p.499) - but then rejected the

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implications of the overwhelming epidemiologicalevidence on the grounds that “experimentalresearch” and “laboratory studies”, presumably intopossible mechanisms, did not provide a sufficientlystrong support: “It is the view of the ICNIRP that theresults from the epidemiological research on EMFfield exposure and cancer, including childhoodleukemia, are not strong enough in the absence ofsupport from experimental research to form ascientific basis for setting exposure guidelines”(p.499) and “In the absence of support fromlaboratory studies, the epidemiological data areinsufficient to allow an exposure guideline to beestablished” (p.503). This is an extraordinary approach to public health.In many other areas of risk, such as the linkbetween smoking and lung cancer, the failure toidentify an exact mechanism has not preventedgovernments from restricting smoking. IARC wasable to classify power line frequencies as possiblycarcinogenic without establishing a mechanism. 3.    A supposed absence of “clear” or “conclusive”or “convincing” evidence

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Other phrases used by ICNIRP to reject adversereactions include a lack of “clear” or “conclusive” or“convincing” evidence, although it is unclear whatthese words actually mean. Thus “However, there isno clear evidence that these biological interactionsof low frequency fields lead to adverse healtheffects” (p.501) seems both to admit “biologicalinteractions” but also simultaneously to assume thatthey have positive health effects because noharmful effects have yet been perceived. Again, while listing studies which appear to showlinks between leukaemia and radio or TV stations,ICNIRP blandly asserts that “recent studies ofpopulations living near EMF transmitters havesuggested a local increase in leukemia incidence(Hocking et al. 1996; Dolk et at. 1997a, b), but theresults are inconclusive” (p.504). Even as regards microwave radiation, where therehave been numerous reports of adverse effects atsub-heating levels since the 1950s, ICNIRP evadesfacing the issue by stating: “Although there aredeficiencies in the epidemiological work, such aspoor exposure assessment, the studies have

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yielded no convincing evidence that typicalexposure levels lead to adverse reproductiveoutcomes or an increased cancer risk in exposedindividuals” (p.507). Many other scientists have argued that theevidence is sufficiently “clear” or “conclusive” or“convincing” and that ICNIRP’s rejection of theevidence on subjective grounds lacks scientificobjectivity. 4.    Assumptions about medical effects of EMR Some of ICNIRP’s attempts to dismiss studiesfinding links with cancer appear to makeassumptions which are unwarranted, given theexisting level of medical research, such as: “Anelevated cancer risk among exposed individualswas observed, but the type of cancer of which thiswas true varied from study to study” (p.500). Again:“If there is truly a link between occupationalexposure to magnetic fields and cancer, greaterconsistency and stronger associations would beexpected of these recent studies based on moresophisticated exposure data” (p.500). It is notexplained why electro-magnetic radiation operating

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at a quantum level and at sub-thermal exposureshas to affect the human body in ways so farobserved which are less varied and more consistentwith expectations from conventional medicine. 5.    Assumptions based on a priori beliefs Where studies have revealed new and unexpectedfindings on how EMFs are biologically active,ICNIRP appears to think that the effects may notexist or are unimportant, based on a belief that sucha finding “challenges the traditional concept” or istoo “complicated”. Thus “Interpretation of severalobserved biological effects of AM electromagneticfields is further complicated by the apparentexistence of ‘windows’ of response in both thepower density and frequency domains. There are noaccepted models that adequately explain thisphenomenon, which challenges the traditionalconcept of a monotonic relationship between thefield intensity and the severity of the resultingbiological effects” (p.507). As often, the ICNIRPattitude is to ignore such findings, howevercomplex, rather than seek to understand andevaluate them: “Overall, the literature on athermaleffects of AM electromagnetic fields is so complex,

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ICNIRP's guidelines

the validity of reported effects so poorly established,and the relevance of the effects to human health isso uncertain, that it is impossible to use this body ofinformation as a basis for setting limits on humanexposure to these fields” (p.507). To dismiss all the hundreds of studies on adversesub-thermal effects simply because the science iscomplex and subtle and also challenges existingassumptions appears inadequate for a committeeclaiming expertise in this area. 6.    Assertion that more confirmation is needed It is sometimes unclear how many studies areneeded to confirm an observation and for whatreason. Six studies, for instance, by more than fourscientists are listed in support of the statement that“Studies on mammary cancer development inrodents treated with a chemical initiator havesuggested a cancer-promoting effect of exposure topower-frequency magnetic fields in the range0.01–30 mT” (p.502). The next sentence explainsthe hypothesis that EMR leads to the “suppressionof pineal melatonin and a resulting elevation insteroid hormone levels and breast cancer risk”,

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supported by two studies by the same scientist. Theparagraph then continues: “However, replicationefforts by independent laboratories are neededbefore conclusions can be drawn regarding theimplications of these findings for a promoting effectof ELF magnetic fields on mammary tumors.” Another example is “An association betweenAlzheimer’s disease and occupational exposure tomagnetic fields has recently been suggested (Sobeland Davanipour 1996). However, this effect has notbeen confirmed” (p.500). Here a recent study (Husset al., 2008), with dose-dependent findings basedon a population survey of 4.7 million people, hasappeared to confirm this suggestion of 12 yearsbefore. It could be argued, however, that ICNIRPshould have acted on the basis of precaution in1998 without awaiting an ill-defined ”confirmation”and thus saved much suffering. 7.    Supposed single interpretation of data It is odd that ICNIRP in 1998 did not admit eventhen to a considerable degree of uncertainty and theneed for differing interpretations, since many of theleading involved scientists had long believed that

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there were sub-thermal adverse effects from EMR.It was therefore misleading to draw conclusionsfrom the vast amount of data claiming that therewas only one possible interpretation: “it can only beconcluded that there is currently no convincingevidence for carcinogenic effects of these fields andthat these data cannot be used as a basis fordeveloping exposure guidelines” (p.503). Here, inaddition, the unsupported use of the word“convincing” begs the argument, since otherscientists were convinced on less evidence longbefore 1998 and some in the 1970s. 8.    Susceptible sub-groups of the general public There is problem over the definition of “the generalpublic”. In contrast to “occupational exposure” itmeans anyone who is not employed in the electricityor transmitting industry. Nevertheless there arelikely to be sub-groups of the general populationwho are especially susceptible to EMR for geneticor epigenetic reasons. This factor is admitted by theICNIRP statement: “By contrast [with occupationallyexposed adults], the general public comprisesindividuals of all ages and of varying health status,and may include particularly susceptible groups or

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individuals” (p.509). Now that epigenetic factors, inthe form of a variant gene which does not promoteDNA repair but which is carried by 4-20% of thepopulation, has been linked with incidences ofchildhood leukaemia in a dose-responserelationship in proximity to power lines (Yang 2008),it appears that, to protect such sub-groups, generalaction will be needed which will affect all the generalpopulation. Guidelines therefore need to be set tocater for the very low exposure levels at whichthese sub-groups are susceptible. One majorsub-group is that of children, whose nervoussystems are still developing and whose bodies willproportionately and cumulatively absorb more radioand microwave frequency radiation than adults. 9.    Failure to provide protection Even where ICNIRP admits that a sub-thermaleffect is well established, it can still refuse toimplement any form of protection. Thus ICNIRPadmits that “microwave hearing” has been studiedwith papers published since 1961, and the 1998ICNIRP review states “Repeated or prolongedexposure to microwave auditory effects may bestressful and potentially harmful” (p.506), but there

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is no suggestion of protecting the general public.

Read ICNIRP’s rationale of its 1998 guidelineshere...

Uncertainties over ICNIRP’smembership and aims

1.    Inadequate evaluation, protection andindependence

ICNIRP claims that it is “an independentgroup of experts established to evaluate the

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state of knowledge about the effects of NIRon human health and well being, and,where appropriate, to provide scientificallybased advice on non-ionizing radiationprotection including the provision ofguidelines on limiting exposure” (p.540). Allthese three claims – independence,evaluation and protection - have been muchdisputed in recent years:

- Inadequate evaluation - AlthoughICNIRP claims sufficient expertise toevaluate appropriately all the scientificevidence on the health dangers ofnon-ionising radiation, its traditionalpreponderance of physicists has suggestedotherwise. The fact 14 leading internationalscientists studied the same evidence butdeduced entirely different results in the formof the BioInitiative Report of 2007, suggests

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that either ICNIRP or the BioInitiativescientists are inadequately skilled in theirevaluation. Moreover other organizations,such as the Russian NCNIRP have agreedwith the BioInitiative scientists and notICNIRP. The sheer weight of evidence,where even the WHO admits that 80% ofstudies in some areas show sub-heatingadverse health effects, suggests thatICNIRP as currently constituted lacks thenecessary medical and biological expertiseto assess the relevant data.

- Inadequate protection - AlthoughICNIRP’s title includes the word ‘Protection’,it does not appear to operate as acommittee protecting the health of thegeneral public. Such a “protection”committee would act decisively on evidence

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suggesting even a 10-30% likelihood of ahealth risk from environmental pollution likeelectro-magnetic radiation. To demand 95%scientific certainty may suit a researchcommittee, but not one committed tosafeguarding public health where caution inthe face of growing evidence of harm isessential.

- Inadequate independence - AlthoughINCIRP claims its members “are notaffiliated with commercial or industrialenterprises” (p.540), many observers regardICNIRP as simply a front for the demands ofthe telecoms and TV industries. There is,for instance, serious disquiet about the wayICNIRP members are selected. Dr LouisSlesin wrote in June 2007:

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ICNIRP's guidelines

"It should be noted that ICNIRP is not a

transparent organization. It has neverdisclosed the sources of its funding nor theprocedures for the selection of its members.ICNIRP was established by Mike Repacholi,who has long had financial ties to both thetelecom and electric utility industries. “

2.    Out-dated statements and infrequentreviews

Some of ICNIRP’s statements claiming nobiological effects are now generallyregarded as out-dated. Thus, for pulsedelectro-magnetic radiation, the assertionthat “Epidemiological studies on exposed

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workers and the general public haveprovided limited information and failed todemonstrate any health effects” (p.508) hasbeen disproved by studies over the lastseven years showing ill health indose-dependent levels around mobilephone transmitter masts, in addition tothose on radar, TV and radio transmitters. By setting the timing of the first interimreview of the 1998 guidelines at elevenyears later, in 2009, and then in 20013, itappears that ICNIRP is directly responsiblefor much human suffering, even assumingthat biological and cancer safety limitguidelines are introduced then. Equally,ICNIRP also appears responsible forsignificant ecological damage fromenvironmental EMR pollution. 3.    The power of the telecommunication

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and TV industry

Before ICNIRP began, in 1985 Becker andSelden, two leading researchers onsub-thermal effects, wrote: “Our survivaldepends on the ability of upright scientistsand other people of goodwill to break themilitary-industrial death grip on ourpolicy-making institutions.” (Becker, RO,and Selden, G, The Body Electric:Electromagnetism and the Foundation ofLife, (New YorkL Harper) 1985, p.329.) For many people the problem with ICNIRPis the way it appears to respond to thewishes of the military, TV operators andmobile phone industries, and governmentswho rely on them for tax revenues and forchecking locations of citizens by tracking

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mobile phones. Most scientists and doctorsassume that ICNIRP should respond to thehealth needs of the general population,instead of apparently supporting guidelineswhich seem to maximize immediate profitand tax revenue. It is unlikely to be ignorance of the sciencewhich holds back ICNIRP from issuingsub-thermal or biological guidelines. In 1992the German Radiation ProtectionCommission stated that adversesub-thermal effects had been publishedsince 1977: "Specific effects which are notrelated to heating have been described inthe scientific literature for approximately 15years. If a high frequency radiation isamplitude modulated with anotherfrequency, field effects can occur, which donot exist under un-modulated radiation.These manifest mostly as changes in the

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permeability of the cell membranes." Federal Gazette no. 43, Publications of theFederal Radiation Protection Commission,Germany, 03 March 1992, 24, p.6. http://www.hese-project.org/hese-uk/en/niemr/health.php?content_type=R&list=frequency In August 1995, before ICNIRP’s denial ofsub-thermal dangers in 1998, ProfessorRoss Adey, chairman for the U.S. NationalCouncil for Radiation Protection andMeasurement's (NCRP) committeeevaluating the standards for power-linefrequency electromagnetic fields, wrote: "The laboratory evidence for athermaleffects of both ELF and RF/Microwavefields now constitutes a major body ofscientific literature in peer-reviewedjournals. It is my personal view that to

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continue to ignore this work in the course ofstandard setting is irresponsible to the pointof it being a public scandal." Dr. John Goldsmith (author of‘Epidemiological Evidence ofRadiofrequency Radiation (Microwave)Effects on Military, Broadcasting andOccupational Studies’, 1995) wrote:   "There are strong political and economicreasons for wanting there to be no healtheffect of RF/MW (radiofrequency/microwave) exposure, just as there are strong publichealth reasons for more accuratelyportraying the risks. Those of us who intendto speak for public health must be ready foropposition that is nominally but not truly,scientific." Quoted in Eletromagnetics Forum, 1997, 1(2), no. 7:

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http://www.emfacts.com/forum/issue2/mag_6.html At first the main opposition to sub-thermalor biological safety limits came from thewestern governments and their militaryforces. Once the health risks were identifiedin the 1940s and 1950s from radar, itbecame increasingly expensive to providesufficient buffer zones around airports andpower lines. Only Russia, China and othercountries following the implications of theirmedical research adopted biological limits.In the early 1990s, when the first linksbetween mobile phones and brain tumoursappeared, the industry, supported by somegovernments, lobbied for health issues tobe banned from planning permission fortransmitter masts. At the same timeMotorola established a research team,which was accused of trying to find only

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positive evidence about phones, andICNIRP was established. The industry hadlearnt from the problems faced by tobaccocompanies and wanted to maximize theirprofits for as long as possible before legalclaims could be upheld.

Read ICNIRP's statement, “Generalapproach to protection against non-ionisingradiation” here...

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