July 25, 2022
A new peer-reviewed paper published in the journal, Reviews of Environmental Health, found that the International Commission for Non-Ionizing Radiation Protection
(ICNIRP)
bases its recommended exposure limits
for wireless (i.e., radio frequency [RF]) radiation primarily on research produced by its own members, their former students and close colleagues.
ICNIRP claims that their "thermal-only paradigm" "is consistent with
current scientific understanding" despite the fact that the predominance of peer-reviewed research finds non-thermal effects.
The ICNIRP limits, designed to protect humans only from the acute effects of heating induced by RF radiation, are promoted by the World Health Organization and are similar to those adopted by the FCC.
In 2019 investigative journalists from eight European countries published 22 articles in major newspapers and magazines which exposed conflicts of interest in this "ICNIRP cartel." More recently, the former editor of the journal of the Bioelectromagnetics Society accused ICNIRP of "groupthink." For more information see the article below: "The 'ICNIRP Cartel' and 'The 5G Mass Experiment'" (posted February 12, 2019, updated January 9, 2020).
Is ICNIRP a modern-day Wizard of Oz? In this new paper, Else Nordhagen and Einar Flydal pull back the curtain revealing the Wizard to be a fraud, all smoke and mirrors. They conclude:
"the ICNIRP 2020 Guidelines fail to meet fundamental scientific quality
requirements and are therefore not suited as the basis on which to set
RF EMF exposure limits for the protection of human health.
With its thermal-only view, ICNIRP contrasts with the majority of
research findings, and would therefore need a particularly solid
scientific foundation. Our analysis demonstrates the contrary to be the
case. Hence, the ICNIRP 2020 Guidelines cannot offer a basis for good
governance."
Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines
Else K Nordhagen, Einar Flydal.
Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines. Rev Environ Health. 2022 Jun 27. doi: 10.1515/reveh-2022-0037.
Abstract
In March 2020, ICNIRP (the International Commission for Non-Ionizing Radiation Protection) published a set of guidelines for limiting exposure to electromagnetic fields (100 kHz to 300 GHz). ICNIRP claims this publication's view on EMF and health, a view usually termed "the thermal-only paradigm", is consistent with current scientific understanding.
We investigated the literature referenced in ICNIRP 2020 to assess if the variation in authors and research groups behind it meets the fundamental requirement of constituting a broad scientific base and thus a view consistent with current scientific understanding, a requirement that such an important set of guidelines is expected to satisfy. To assess if this requirement has been met, we investigated the span of authors and research groups of the referenced literature of the ICNIRP 2020 Guidelines and annexes.
Our analysis shows that ICNIRP 2020 itself, and in practice all its referenced supporting literature stem from a network of co-authors with just 17 researchers at its core, most of them affiliated with ICNIRP and/or the IEEE, and some of them being ICNIRP 2020 authors themselves. Moreover, literature reviews presented by ICNIRP 2020 as being from independent committees, are in fact products of this same informal network of collaborating authors, all committees having ICNIRP 2020 authors as members.
This shows that the ICNIRP 2020 Guidelines fail to meet fundamental scientific quality requirements and are therefore not suited as the basis on which to set RF EMF exposure limits for the protection of human health. With its thermal-only view, ICNIRP contrasts with the majority of research findings, and would therefore need a particularly solid scientific foundation. Our analysis demonstrates the contrary to be the case. Hence, the ICNIRP 2020 Guidelines cannot offer a basis for good governance.
Excerpts
... ICNIRP members are found to have conflicts of interest, as pointed out by e.g., [3]: “the Ethical Board at the Karolinska Institute in Stockholm, Sweden concluded already in 2008 that being a member of ICNIRP may be a conflict of interest that should be stated officially whenever a member from ICNIRP makes opinions on health risks from EMF (Karolinska Institute diary number: 3753-2008-609)”. An EU report [4] concluded in June 2020 that “for really independent scientific advice we cannot rely on ICNIRP”....
As is apparent from the debate on this issue, a majority of peer-reviewed papers support the opposing view, i.e., that sub-thermal RF EMFs have health effects [5]. Several athermal mechanisms have been identified [6], [7], [8], [9], [10] and accepted as evidenced, if not proven....
All in all, ICNIRP 2020 has 158 unique references. Not all have been authored by the ICNIRP co-authorship network found in Pattern 1. We found that the network co-authored 78 of the referenced peer reviewed papers, seven of the literature reviews, and six ICNIRP publications, in total 91 documents. In addition to these 91 documents, there are 67 references to other documents.
Of these 67 documents, only 15 are peer reviewed papers on RF EMF and health. The remaining 52 are documents with no direct relation to this topic. We termed these 52 “technical documents”, as they address topics such as WHO’s definition of “health” and other general terms used (three documents), thermal regulation (20 documents), contact currents and pain (five documents), technical documentation (three documents) and SAR-modelling and calculations (21 documents). We excluded these technical documents from further analyses (see Figure 1) .
Conclusions
In the introduction we raised five questions relating to the authorship behind the referenced literature used to underpin the ICNIRP 2020 thermal-only view. Below we repeat the patterns found, answering these questions whilst adding some overarching conclusions.
Pattern 1: ICNIRP affiliates and ICNIRP 2020 authors are heavily involved in literature referenced in ICNIRP 2020 to underpin it. Figure 2 shows the graph of the complete network of co-authorship relations found in the referenced literature in ICNIRP 2020 originating from the ICNIRP affiliates, displaying that ICNIRP affiliates are the most central nodes of the network, and seven of the most central nodes being ICNIRP 2020 authors.
Pattern 4: a small and tight network of just 17 authors is behind all the literature used to underpin ICNIRP 2020. Of these 17, 10 were ICNIRP affiliates, of whom six were also authors of ICNIRP 2020. Five of these 17 were IEEE C95.1 2019 authors, two of whom were also ICNIRP 2020 authors.
Pattern 2: ICNIRP 2020 authors are involved in all the literature reviews referenced in ICNIRP 2020 to underpin it. In addition to the ICNIRP 2020 authors, these committees are manned by several other ICNIRP affiliates.
Pattern 3: All scientific papers used to underpin ICNIRP 2020 are from the same co-author network centered around ICNIRP affiliates.
Only four papers were found to be used to underpin ICNIRP 2020 that were not linked to the ICNIRP co-authorship network. Of these four, a simple internet search revealed that two of them have authors who have co-authored several papers with ICNIRP affiliates and thus cannot be seen as independent from ICNIRP. The two last were misinterpreted to underpin ICNIRP 2020 or offered no scientifically sound support.
Pattern 5: The spread of first authors gives a false impression of broad support. While there is a high variation of first authors, most of them not affiliated with ICNIRP/IEEE, a tight network of just 16 key authors, dominated by ICNIRP and IEEE affiliates, is involved in all the papers used to underpin ICNIRP 2020 (Pattern 4). Moreover, in the co-authorship network (Pattern 1) ICNIRP affiliates are found as central nodes, while most first authors are peripheral in the network.
Intentionally or not, the domination of ICNIRP affiliated authorship is blurred by the practice of having many different non-affiliates as first authors. This conceals the fact that effectively all referenced papers used to support ICNIRP 2020 originate from a network of researchers completely dominated by ICNIRP affiliates and a few who are closely related.
Pattern 6: All referenced papers not authored by the ICNIRP co-authorship network are either rejected, misinterpreted to underpin ICNIRP 2020, or offer no scientifically sound support.
Our analysis shows that ICNIRP 2020 itself and, in practice, all its referenced supportive literature stem from a network of co-authors with just 17 researchers at its core, most of them affiliated with ICNIRP and/or the IEEE and with ICNIRP 2020 authors in prominent positions, where those who are not are still closely related.
The overlaps between ICNIRP and the committees authoring the referenced literature reviews have been documented multiple times [4, 19, 20]. However, it was not anticipated that these ties would be so strong, that they include all committees behind the literature reviews, as well as the authorships of all the peer reviewed papers used to underpin ICNIRP 2020. Indeed, we would never have expected to find as few as 17 key authors as the smallest set of authors involved in all the literature used to underpin the ICNIRP 2020, and that they constitute a network heavily overlapping with the ICNIRP 2020 authors themselves. It was also not anticipated that the ICNIRP 2020 authors themselves would be represented in all committees. This means that the authors of ICNIRP 2020 are exclusively referring to themselves and their fellow network members as the basis for their own scientifically highly controversial recommendations.
As well, it was highly unexpected to find that the WHO report [11] described in ICNIRP 2020 as “an in-depth review from the World Health Organization on radiofrequency EMF exposure and health” [2 p. 486] and presented in these words: “This independent review is the most comprehensive and thorough appraisal of the adverse effects of radiofrequency EMFs on health” [2 p. 517], is in fact a retracted draft where five out of six WHO core group members were ICNIRP affiliates, of whom three are among the authors of ICNIRP 2020. Such a claim and circularity of authorship is encroaching upon something very similar to fraud.
From our findings we draw the conclusion that the referenced literature used in ICNIRP 2020 to underpin its guidelines is neither varied, nor independent or balanced, and is by no means “consistent with current scientific knowledge”, as claimed by ICNIRP 2020 [2 p. 484]. ICNIRP 2020 bases this claim within this small network only, a claim that runs contrary to the majority of biology-oriented researchers and publications within this research field. Hence, our review shows that the ICNIRP 2020 guidelines fail to meet fundamental scientific quality requirements as to being built on a broad, solid and established knowledge base, uphold a view contrary to well established knowledge within the field, and therefore cannot offer a basis for good governance when setting RF exposure limits for the protection of human health.
Open access paper: https://www.degruyter.com/document/doi/10.1515/reveh-2022-0037/html
See also:
van Scharen H. "The International Commission on Non-Ionizing Radiation Protection: Conflicts of interest, corporate capture and the push for 5G." Brussels, 2020. Commissioned by Michèle Rivasi and Klaus Buchner, members of the European Parliament. https://bit.ly/3NK3qpH
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Science, Politics, and Groupthink [Health Matters]
The "privately constituted group, with self-appointed membership" referred to in this paper is the International Commission on Non-Ionizing Radiation Protection
(ICNIRP). ICNIRP has global influence on official regulations regarding
wireless radiation exposure limits including the WHO and the FCC. Dr. Lin, an
ICNIRP Commission member from 2004-2016, accuses the organization of groupthink in this paper published in the IEEE Microwave Magazine.
James C. Lin, Professor Emeritus in the Department of Electrical and Computer Engineering at the University of Illinois Chicago is one of the most renowned scientists who has studied the biological interactions of wireless radiation. He is a fellow of the American Association for the Advancement of Science, the Institute of Electrical and Electronics Engineers (IEEE), and the American Institute for Medical and Biological Engineering. Since 2006 he has been the Editor-in-Chief of the Bioelectromagnetics journal published on behalf of the Bioelectromagnetics Society (BEMS), an international organization of biological and physical scientists, physicians and engineers interested in the interactions of electromagnetic fields with biological systems.
(I bolded key sentences in the excerpts below. The one-sentence abstract seems misleading which makes me wonder whether the editors of IEEE Microwave Magazine censored the original abstract.)
James C. Lin. Science, Politics, and Groupthink [Health Matters].
IEEE Microwave Magazine. 22(5):24-26. May 2021. doi:
10.1109/MMM.2021.3056975.
Abstract
Discusses
how the COVID-19 health pandemic worldwide was complicated by not only
health and medical concerns, but the inclusion of politics, conspiracy
theories, and social media.
Excerpts
"Fast forward to the 21st century, when, in 2011, the World Health Organization’s International Agency for Research on Cancer (IARC) classified exposure to RF radiation as 2B—a possible cancer-causing agent to humans. The IARC had evaluated the then-available scientific studies and, although evidence was incomplete and limited (especially regarding results from animal experiments), concluded that the epidemiological studies of humans reported increased health risks for long-term users of cellular mobile telephones. These risks included gliomas (a type of malignant brain cancer) and acoustic neuromas (or acoustic schwannomas—a nonmalignant tumor of the auditory nerves on the side of the brain). This evidence was sufficiently strong to support a classification of exposure to RF radiation possibly being carcinogenic for humans [2], [3].
In 2018, the National Toxicology Program (NTP) of the U.S. National Institute of Environmental Health Science (NIEHS) reported observations of two types of cancers in laboratory rats that were exposed, for their entire lives, to RF radiation used for 2G and 3G wireless cellular mobile telephone operations [4], [5]. This is the largest health-effect study ever undertaken by the NIEHS/NTP for any agent. A 12-member peer review panel of independent scientists convened by NIEHS/NTP evaluated the toxicology and carcinogenesis studies and concluded, among other observations, that there was statistically significant and “clear evidence” that the RF radiation had led to the development of malignant schwannoma in the heart of male rats.
Shortly after the NTP report, the Cesare Maltoni Cancer Research Center at the Ramazzini Institute in Bologna, Italy, published the results from its comprehensive study on carcinogenicity in rats with lifelong exposure to 2G/3G 1,800-MHz RF radiation [6]. The study involved whole-body exposure of male and female rats under plane-wave equivalent or far-zone exposure conditions. A statistically significant increase in the rate of schwannomas in the hearts of male rats was detected for 0.1-W/kg RF exposure. It is critical to note that the recent NTP and Ramazzini RF exposure studies presented similar findings about heart schwannomas and brain gliomas. Thus, two relatively well-conducted RF exposure studies, employing the same strain of rats, showed consistent results of significantly increased cancer risks from mobile phone exposures.
It is critical to note that the recent NTP and Ramazzini RF exposure
studies presented similar findings about heart schwannomas and brain
gliomas. Thus, two relatively well-conducted RF exposure studies,
employing the same strain of rats, showed consistent results of
significantly increased cancer risks from mobile phone exposures.
Recently, a privately constituted group, with self-appointed membership, published a set of guidelines for limiting exposure to RF electromagnetic fields in the 100-kHz and 300-GHz frequency range [7]. The proposed guidelines were primarily based on the tissue-heating potentials of RF radiation to elevate animal body temperatures to greater than 1° C. While recognizing that the two aforementioned studies used large numbers of animals, best laboratory practice, and animals exposed for the entirety of their lives, the private group preferred to quibble with alleged “chance differences” between treatment conditions and the fact that the measured animal body core temperature changes reached 1° C, implying that a 1° C body core temperature rise is carcinogenic, ignoring the RF exposure. The group then pronounced that, when considered either in isolation or within the context of other animal carcinogenicity research, these findings do not provide evidence that RF radiation is carcinogenic.
Furthermore, the group noted that, even though many epidemiological studies of RF radiation associated with mobile phone use and cancer risk had been performed, studies on brain tumors, acoustic neuroma, meningioma, and parotid gland tumors had not provided evidence of an increased cancer risk. It suggested that, although somewhat elevated odds ratios were observed, inconsistencies and limitations, including recall or selection bias, precluded these results from being considered for setting exposure guidelines. The simultaneous penchant to dismiss and criticize positive results and the fondness for and eager acceptance of negative findings are palpable and concerning.
In contrast, the IARC’s evaluation of the same epidemiological studies ended up officially classifying RF radiation as possibly carcinogenic to humans [2], [3].
An understandable question that comes to mind is this: How can there be such divergent evaluations and conclusions of the same scientific studies? Humans are not always rational or as transparent as advertised, and scientists are not impervious to conflicts of interest and can be driven by egocentric motivations. Humans frequently make choices and decisions that defy clear logic.
Science has never been devoid of politics, believe it or not."
Recently, a privately constituted group, with self-appointed membership, published a set of guidelines for limiting exposure to RF electromagnetic fields in the 100-kHz and 300-GHz frequency range [7]. The proposed guidelines were primarily based on the tissue-heating potentials of RF radiation to elevate animal body temperatures to greater than 1° C. While recognizing that the two aforementioned studies used large numbers of animals, best laboratory practice, and animals exposed for the entirety of their lives, the private group preferred to quibble with alleged “chance differences” between treatment conditions and the fact that the measured animal body core temperature changes reached 1° C, implying that a 1° C body core temperature rise is carcinogenic, ignoring the RF exposure. The group then pronounced that, when considered either in isolation or within the context of other animal carcinogenicity research, these findings do not provide evidence that RF radiation is carcinogenic.
Furthermore, the group noted that, even though many epidemiological studies of RF radiation associated with mobile phone use and cancer risk had been performed, studies on brain tumors, acoustic neuroma, meningioma, and parotid gland tumors had not provided evidence of an increased cancer risk. It suggested that, although somewhat elevated odds ratios were observed, inconsistencies and limitations, including recall or selection bias, precluded these results from being considered for setting exposure guidelines. The simultaneous penchant to dismiss and criticize positive results and the fondness for and eager acceptance of negative findings are palpable and concerning.
In contrast, the IARC’s evaluation of the same epidemiological studies ended up officially classifying RF radiation as possibly carcinogenic to humans [2], [3].
An understandable question that comes to mind is this: How can there be such divergent evaluations and conclusions of the same scientific studies? Humans are not always rational or as transparent as advertised, and scientists are not impervious to conflicts of interest and can be driven by egocentric motivations. Humans frequently make choices and decisions that defy clear logic.
Science has never been devoid of politics, believe it or not."
"Biases
can impair rational judgment and lead to poor decisions. Emotions can
keep humans from being rational and prevent us from arriving at obvious
conclusions. At times, humans systematically make choices and decisions
that defy clear logic. Regrettably, the herd mentality or groupthink is
as rampant today as ever.
Some years ago, I commented, “Science has become partisan. And the corollary, if science becomes partisan, is it science or politics, or would it be political science?” [8]. Perhaps, it is simply a matter of the willing being politically correct.
When decisions are not arrived at by prudently balancing the facts or are made via impaired rational judgment, it could lead to poor decisions through biases.
Cellular mobile communication and associated wireless technologies have proven, beyond any debate, their direct benefit to humans. However, as for the verdict on the health and safety of billions of people who are exposed to unnecessary levels of RF radiation over extended lengths of time or even over their lifetimes, the jury is still out. When confronted with such divergent assessments of science, the ALARA—as low as reasonably achievable—practice and principle should be followed for RF health and safety."
Some years ago, I commented, “Science has become partisan. And the corollary, if science becomes partisan, is it science or politics, or would it be political science?” [8]. Perhaps, it is simply a matter of the willing being politically correct.
When decisions are not arrived at by prudently balancing the facts or are made via impaired rational judgment, it could lead to poor decisions through biases.
Cellular mobile communication and associated wireless technologies have proven, beyond any debate, their direct benefit to humans. However, as for the verdict on the health and safety of billions of people who are exposed to unnecessary levels of RF radiation over extended lengths of time or even over their lifetimes, the jury is still out. When confronted with such divergent assessments of science, the ALARA—as low as reasonably achievable—practice and principle should be followed for RF health and safety."
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Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on Radiofrequency Radiation
Lennart Hardell, Mona Nilsson, Tarmo Koppel, Michael Carlberg. Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on Radiofrequency Radiation. J Cancer Sci Clin Ther. 2021; 5(2): 250-285. doi: 10.26502/jcsct.5079117.
Abstract
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) published 2020 updated guidelines on radiofrequency (RF) radiation in the frequency range 100 kHz to 300 GHz. Harmful effects on human health and the environment at levels below the guidelines are downplayed although evidence is steadily increasing. Only thermal (heating) effects are acknowledged and therefore form the basis for the guidelines. Despite the increasing scientific evidence of non-thermal effects, the new ICNIRP guidelines are not lower compared with the previous levels. Expert groups from the WHO, the EU Commission and Sweden are to a large extent made up of members from ICNIRP, with no representative from the many scientists who are critical of the ICNIRP standpoint.
Excerpts
"As a general rule ICNIRP, WHO, SCENIHR and SSM have for many years dismissed available studies showing harmful effects from non-thermal RF exposure and have based their conclusions mainly on studies showing no effects. Results showing risk are criticized, disregarded or not even cited while studies showing no risks are accepted as evidence of no risk in spite of severe methodological problems. Many statements by these agencies are misleading and not correct. They are easily rebutted by reading the relevant publications....
All these expert groups dominated by ICNIRP consequently reach similar conclusions that there are no health effects below ICNIRP guidelines. No representative from the scientific community that is of the opinion that there is increasing evidence of health risks below the ICNIRP guidelines, e.g. as expressed in the EMF Scientists Appeal [24], has ever been a member of the expert groups at the WHO, the EU, the SSM or ICNIRP. Certainly scientists who do not discount evidence of health effects from exposure to RF radiation that are observed at exposures below guideline levels should be represented....
ICNIRP is not representative of the scientific community since it does not include representatives from scientists that agree there is evidence of harmful effects at levels well below ICNIRPs limits although these scientists are in majority in the scientific community [24]."
Conclusion
"ICNIRP’s conclusion [48] on cancer risks is: “In summary, no effects of radiofrequency EMFs on the induction or development of cancer have been substantiated.” This conclusion is not correct and is contradicted by scientific evidence. Abundant and convincing evidence of increased cancer risks and other negative health effects are today available. The ICNIRP 2020 guidelines allow exposure at levels known to be harmful. In the interest of public health, the ICNIRP 2020 guidelines should be immediately replaced by truly protective guidelines produced by independent scientists."
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5g tests the limits of trust
Dariusz Leszczynski, Tekniikka & Talous, Jan 20, 2022 (Google translation from Finnish)
Dariusz Leszczynski estimates that the regulation of radiation in mobile communications is not sufficiently based on scientific evidence. More data. Coverage of 5g networks is increasing all the time.
In 2020, the International Commission on Non-Ionizing Radiation (ICNIRP) updated its safety guidelines regarding exposure to radio frequency radiation (RF-EMF) emitted by wireless communication devices such as mobile phones and their base stations. The previous standard was from 1998.
The World Health Organization WHO recommends the mentioned guideline, which has been adopted by a large part of the world's countries and has become part of the wireless regulatory framework. Although the US uses IEEE/ICES and FCC standards, it also seeks to "harmonize" with Icnirp.
ICNIRP's safety instructions are based on one basic principle, according to which the only proven health effect caused by radiation exposure is the thermal effect. It appears when the temperature of the skin tissue rises above 1 degree Celsius, and when the temperature rise falls below one degree Celsius, the radiation is considered harmless to health. ICNIRP's view is that the radiation level of wireless devices according to its safety guidelines is not sufficient to produce a temperature rise in skin tissue. Furthermore, according to ICNIRP's science review, without that temperature rise there can be no proven effects. ICNIRP has drawn up its safety instructions to protect consumers only from possible thermal effects, which the commission considers sufficient.
However, there are a large number of experimentally observed thermal-independent, non-thermal effects in both animals and laboratory-grown cells caused by exposure to wireless radiation well below the current exposure limits set by ICNIRP. The researchers are concerned that similar, non-thermal reactions would also occur in users of mobile devices. This could lead to health problems. According to ICNIRP's scientific position, this could not happen. Is the assessment of scientific evidence biased? Not all observations made by researchers about non-thermal effects can be "pure hallucinations".
ICNIRP's instructions therefore only prevent the occurrence of an acute heat effect lasting from minutes to hours, but not repeated and long-lasting from months to decades. Although there have been published studies on acute effects that occur during or shortly after exposure, there are very few publications on long-term chronic exposure. The application of ICNIRP's standards to the real situation seems to be based on a mere safety assumption without a scientific basis.
The standard is advertised as sufficient for every user regardless of age or health. ICNIRP assures that all population groups are equally protected, whether it is the growing and developing body of a small child, or an elderly person suffering from a chronic, potentially fatal disease, or a young, healthy, robust adult man.
Since human experimentation is limited for obvious ethical reasons, we need to look at epidemiology to determine long-term effects. Studies of long-term biological effects or health effects can take years and have limitations, so information is scarce. That is, there is no evidence to guarantee that Icnirp's safety instructions would cover everyone, regardless of age or health status, also taking into account how long people have been using wireless devices. It's all about assumptions without a scientific basis.
Looking at the ICNIRP commission, it is easy to see that the members have very similar views on key issues. They have expressed almost the same opinion; "wireless networks are absolutely safe within all security limits set by ICNIRP." The scientific assessments prepared by ICNIRP's experts are often in conflict with the assessments of researchers outside the organisation's operations. It is even more interesting to observe how the members of the commission act when they are placed in national scientific committees in the company of scientists from outside the organization. In this case, they may draw conclusions that conflict with ICNIRP's views. Recently, these dissenting opinions were published by, among others, the BERENIS Committee in Switzerland,
For most users of wireless technology, Icnirp is just an abbreviation. Consumers are told that it acts only as a committee on science with no other influence, be it industry or a government radiation regulatory body. However, many users are not aware of how Icnirp works in practice. For your consideration:
1. ICNIRP is a group of about a dozen scientists who do not claim to represent anyone but themselves.
2. It presents itself as outside the lobbying influence of industry and national radiation protection organizations.
3. Retired members will be replaced by new members elected by the current members.
4. ICNIRP's selection criteria and their justifications for selecting new members are not publicly available. Only members know why a person has been selected for their group.
5. ICNIRP is not responsible for the scientific decisions it makes to any party.
6. No one can control the methods used by ICNIRP to achieve the safety guidelines it recommends.
7. No one supervises its operation.
8. It is not legally responsible for its scientific statements. Legal liability is limited to what members say. It's just a matter of instructions and no one is legally obliged to use them. Even if the instructions turned out to be incorrect, no one could legally sue ICNIRP.
However, the telecommunications industry and national radiation protection organizations have ended up using ICNIRP's safety instructions. By doing so, they are legally responsible for any health risks caused by the devices they manufacture, even if they meet ICNIRP's guidelines. In other words, the Commission avoids the legal responsibility that remains with the operators in the field if the use of the equipment causes health problems. The members themselves are responsible only to "God and history" for all the right or wrong decisions they make.
In order to fully understand the great significance of this complete lack of oversight of Icnirp's operations, it must be remembered that the safety guidelines developed by Icnirp are the only guidelines used by the industry that manufactures and operates wireless communication equipment and infrastructure in most of the world.
Basically, ICNIRP's security guidelines legitimize the operation of the telecommunications industry, which in 2019 had an annual value of approximately $1.74 trillion worldwide. The ICNIRP in question is an organization that claims to be completely independent of all outside interests and operates without any kind of supervisor or control, without responsibility for its scientific decisions.
The introduction of the new 5th generation wireless communication, 5g, which is currently underway, has further raised the debate about the validity of ICNIRP's standards. New in wireless 5g communication is the use of millimeter waves and frequencies above 20 GHz – 300 GHz. Although millimeter waves can transfer large amounts of data, they have the problem of how far the data can be sent within the limits of short wavelength bandwidth. This causes very frequent deployment of base stations (cell antennas) in different areas. Roughly estimating, one small base station would be placed on every other lamp post, and base stations would also be required inside buildings. In practice, this leads to the fact that in a few years, urban environments will be saturated with millimeter waves, when 5g has been fully implemented.
In its 2020 guidelines, ICNIRP assures that consumers' health is fully protected. How does the Commission know that? Research on millimeter waves and health is limited. Recently published scientific reviews have selected various databases and found only a small number of studies on the health effects of millimeter waves. Most of the publications deal with radiation measurements and dosimetry, not biological or health effects. In 2019 Simkó and Mattsson published a review that included only 97 experimental studies and in 2020 Leszczynski published a review of 99 experimental studies. In 2021, Karipidis et al. published a review that included 107 experimental studies. Most millimeter wave studies consist of small, laboratory or animal experiments,
The lack of research causes confusion and problems in communities. When users ask for scientific evidence about the health effects of 5g millimeter waves, they get no answers. Research has not yet been done sufficiently and the safety of 5g cannot be scientifically proven. However, it would be possible to conduct a sufficient number of studies on 5g that would either show whether the health effects are minor or even insignificant.
It is interesting, but also worrying, to note what Rodney Croft, chairman of ICNIRP, a professor of psychology at the University of Wollongong, Australia, stated in an interview on Australian TV on June 16, 2020: "There is no harm associated with 5g". "Look, it's quite true that the amount of research looking at 5g is very limited, but from a science perspective, this is simply not relevant."
In this scientifically and legally complex situation, there is an urgent need to carry out an independent validation of the results of ICNIRP's scientific review and the validity of its safety guidelines.
The author is PhD, DSc, docent of biochemistry at the University of Helsinki and editor-in-chief of the Radiation and Health section of Frontiers in Public Health (impact factor 3.709). He has worked from 2000 to 2013 as a research professor at the Radiation Protection Center.
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Health risks from radiofrequency radiation, including 5G, should be assessed by experts with no conflicts of interest
Lennart Hardell, Michael Carlberg, Health risks from radiofrequency radiation, including 5G, should be assessed by experts with no conflicts of interest. Oncol Lett. 2020 Oct;20(4):15. doi: 10.3892/ol.2020.11876.
Abstract
The fifth generation, 5G, of radiofrequency (RF) radiation is about to be implemented globally without investigating the risks to human health and the environment. This has created debate among concerned individuals in numerous countries. In an appeal to the European Union (EU) in September 2017, currently endorsed by >390 scientists and medical doctors, a moratorium on 5G deployment was requested until proper scientific evaluation of potential negative consequences has been conducted. This request has not been acknowledged by the EU. The evaluation of RF radiation health risks from 5G technology is ignored in a report by a government expert group in Switzerland and a recent publication from The International Commission on Non-Ionizing Radiation Protection. Conflicts of interest and ties to the industry seem to have contributed to the biased reports. The lack of proper unbiased risk evaluation of the 5G technology places populations at risk. Furthermore, there seems to be a cartel of individuals monopolizing evaluation committees, thus reinforcing the no-risk paradigm. We believe that this activity should qualify as scientific misconduct.
Abstract
The fifth generation, 5G, of radiofrequency (RF) radiation is about to be implemented globally without investigating the risks to human health and the environment. This has created debate among concerned individuals in numerous countries. In an appeal to the European Union (EU) in September 2017, currently endorsed by >390 scientists and medical doctors, a moratorium on 5G deployment was requested until proper scientific evaluation of potential negative consequences has been conducted. This request has not been acknowledged by the EU. The evaluation of RF radiation health risks from 5G technology is ignored in a report by a government expert group in Switzerland and a recent publication from The International Commission on Non-Ionizing Radiation Protection. Conflicts of interest and ties to the industry seem to have contributed to the biased reports. The lack of proper unbiased risk evaluation of the 5G technology places populations at risk. Furthermore, there seems to be a cartel of individuals monopolizing evaluation committees, thus reinforcing the no-risk paradigm. We believe that this activity should qualify as scientific misconduct.
Open access paper: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7405337/
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The International Commission on Non-Ionizing Radiation Protection: Conflicts of interest, corporate capture and the push for 5G
June 2020
This 98 page report
was commissioned, coordinated and published by two Members of the European
Parliament – Michèle Rivasi and Klaus Buchner. The report was written by Hans
van Scharen with editing by Erik Lamberand additional research support from Tomas Vanheste.
The Greens/EfA group in the European Parliament financed the preparation of this report.
Excerpts
“This report deals with an
issue of which the importance cannot be overrated: the possible health effects
of Radiofrequency Radiation (RfR) or electro magnetic fields (EMF). It deals more specifically with how the scientific
debate has been hijacked by corporate interests from the Telecom industry.”
“The findings of this report
(‘The International Commission on Non-Ionizing Radiation Protection: Conflicts
of interest and the push for 5G’) give us an uncomfortable déjà-vu: many facts
and processes that lead to the actual situation whereby European authorities –
from the European Commission to most of the member states – simply close their
eyes for real scientific facts and early warnings. We have seen exactly the
same scenario in the debate on Tobacco, asbestos, climate change and
pesticides.
Also in its latest guidelines
from March this year, ICNIRP assures the world that there is no scientific
evidence of adverse health effects from the radiation that comes with the new
communication technologies, within the limits it proposes. But at the same time
a growing number of scientists and also citizens are worried that EMFs do cause
health problems. ICNIRP pretends to be scientifically neutral, and free from
vested interests of the Telecom industry. We show with this study that this is
‘playing with the truth’ or simply a lie.”
“In the debate on EMF and possible health effects, terms like ‘corporate
capture’ of scientific research and ‘war game science’ are
often used, and references to the tactics of the tobacco industry are often
made. According to several authors, these tactics also influence organisations
like ICNIRP and WHO’s International EMF Project….”
“This appears to be a global
issue. US researcher, Norm Alster, in his report ‘Captured
Agency’ describes what this kind of corporate capture can lead to by referring
to the workings of the FCC (Federal Communications Commission), which is the
main official US institution that deals with Telecom issues, and is sometimes
mentioned in critiques of ICNIRP: “That is a term that comes up time and time
again with the FCC. Captured agencies are essentially controlled by the
industries they are supposed to regulate. A detailed look at FCC actions—and
non-actions—shows that over the years the FCC has granted the wireless industry
pretty much what it has wanted”.
“As a result, consumer safety,
health, and privacy, along with consumer wallets, have all been overlooked,
sacrificed, or raided due to unchecked industry influence. (…) Most insidious
of all, the wireless industry has been allowed to grow unchecked and virtually
unregulated, with fundamental questions on public health impact routinely
ignored. (…) Industry control, in the case of wireless health issues, extends
beyond Congress and regulators to basic scientific research. And in an obvious
echo of the hardball tactics of the tobacco industry, the wireless industry has
backed up its economic and political power by stonewalling on public relations
and bullying potential threats into submission with its huge standing army of
lawyers. (…) Industry behaviour also includes self-serving public relations and
hyper aggressive legal action. It can also involve undermining the credibility
of, and cutting off funding for, researchers who do not endorse cellular
safety. It is these hardball tactics that recall 20th century Big
Tobacco tactics.”
Conclusion
“ICNIRP presents itself, and is
described by the European Commission and in the media, as an independent
international commission that gives advice based on scientific evidence. We
believe that there are various reasons to question this (self)-image.
The composition of ICNIRP is
very one sided. With only one
medically qualified person (but not an expert in wireless radiation) out of a
total of 14 scientists in the ICNIRP Commission and also a small minority of
members with medical qualifications in the Scientific Expert Group, we can
safely say that ICNIRP has been, and is
still, dominated by physical scientists. This may not be the wisest composition
when your remit is to offer advice on human health and safety to governments
around the world.
As one can read in the 45
portraits of the members of the ICNIRP commission and of the Scientific Expert
Group (SEG), they all share the same position on the safety issues:
non-ionising radiation poses no health threats and the only effects it has are
thermal. ICNIRP says "non-ionising radiation poses no health threats if it
does not heat the tissue by more than 1 °C", by which it admits that there
are possible health effects, but only if exposure levels to strong radiation
are too high”.
Over the past years, and on
many platforms, various EMF-experts have stated that ICNIRP is wrong to
continue dismissing certain scientific studies showing adverse health effects –
like the American NTP-study - and is mistaken in its almost dogmatic conviction
that “non-ionising radiation poses no health threats and the only possible
health effects it has are thermal in case of strong radiation”.
Even after much criticism from
members of the global scientific community, ICNIRP still adheres to the
paradigm that the only proven effects (on health) are thermal. “ICNIRP appears
to take into account only the warming of tissue and uncontrolled muscle
contractions, although they claim in the most recent advice, that they also
evaluated other mechanisms”, writes Dutch Professor Hans Kromhout, who is
currently leading a long-term study (in the Netherlands) into the effects of
mobile phone use on human health, and who is chairman of a special committee on
Electromagnetic Fields of the leading Dutch Health Council, which advises the
Dutch government.
It seems that “a closed circle
of like-minded scientists” has turned ICNIRP into a self-indulgent science
club, with a lack of bio-medical expertise, as well as a lack of scientific
expertise in specific risk assessments. Thereby, creating a situation which
might easily lead to “tunnel-vision” in the organisation’s scope. Two leading
experts, Hans Kromhout and Chris Portier, confirmed to us that ICNIRP is a
closed, non-accountable and one-sided organisation.
As many scientists and critical
observers have pointed out, it seems that ICNIRP members are either oblivious
to, or are ignoring, scientific studies that find possible adverse health
effects in the absence of heating. Even though some ICNIRP-members have
themselves acknowledged that industry-funded scientific research tends to
produce less findings showing adverse health effects of EMF, whereas publicly
funded studies – like the NTP-study – do find significant links between EMF and
adverse health effects, this does not seem to influence one iota the views of
ICNIRP-members.
The majority of
ICNIRP-scientists have done, or are doing, research partly funded by industry.
Is this important? As we argue in the introduction, we believe it is.
Scientific publications, co-authored by two ICNIRP-scientists – Anke Huss and
Martin Röösli, confirm the importance of funding. In 2006 and 2009 they did a
systematic review of the effects of the source of funding in experimental
studies of mobile phone use on health, and their conclusion was that, “industry-sponsored studies were least
likely to report results suggesting (adverse health) effects”. And theirs is
not the only study that showed this, as there have been numerous studies of the
differences in reporting from industry-funded research versus publicly-funded
research that suggest a strong funding bias on the results.
In addition to the fact that
certain members of ICNIRP, are simultaneously members of the International
Committee on Electromagnetic Safety (ICES) of the US-registered Institute of
Electrical and Electronics Engineers (IEEE), we have seen further evidence of a
close cooperation between ICNIRP and ICES, an organisation in which many people
from the media and telecom industries, as well as from the military, are
actively and structurally involved. During the current
leadership of ICNIRP, these ties have become even closer “with the goal of setting internationally
harmonized safety limits for exposure to electromagnetic fields”. This must surely be considered as a situation in which
conflicts of interest are a real possibility.
It is clear from ICES minutes that ICNIRP worked very closely with IEEE/ICES on the
creation of the new RF safety guidelines that were published in March 2020. And
this implies that large telecom-companies such as Motorola and others, as well
as US military, had a direct influence on the ICNIRP guidelines, which are
still the basis for EU-policies in this domain ….
Despite ICNIRP positioning
itself, during the last 25 years, as the sole purveyor of scientific truth when
it comes to possible relation between EMF and adverse health effects, it would
not be right to hold this scientific NGO solely accountable if, one day, it
were to become undisputed that EMF do cause health problems. National
governments, as well as the European Commission, which is, after all, the
‘Guardian of the Treaty’, have a duty of care and protection of their citizens,
and therefore should also take the legally binding ‘precautionary principle’
into account.
We think that the call for more
independent scientific assessment in this area is, for all the arguments
mentioned above and in what follows, fully justified.
That is the most important
conclusion of this report: for really independent scientific advice we cannot
rely on ICNIRP. The European Commission and national governments, from
countries like Germany, should stop funding ICNIRP. It is high time that the
European Commission creates a new, public and fully independent advisory
council on non-ionizing radiation. The funds currently allocated to ICNIRP
could be used to set up this new organisation. And given the overall rise in
R&D funding via Horizon Europe, with a foreseen budget (for 2021-2027) of
between 75 and 100 billion euros, funding should in no way constitute an
insurmountable hurdle to setting up this new, truly independent, body.”
Open Access Report: https://bit.ly/icnirpCOIreport
P.S. Dr. Christopher Portier, while the Director of the CDC National Center for Environmental Health, represented the U.S. government on the expert working group convened in 2011 by the International Agency for Research on Cancer of the World Health Organization to review the carcinogenic classification of radio frequency radiation.
See also:
5G : l’impartialité du comité qui guide l’Europe pour protéger la population des ondes en question
Un
rapport de deux députés européens accuse la commission internationale
de protection contre les rayonnements non ionisants d’être trop proche
de l’industrie des télécoms.
Stéphane Mandard, Le Monde, 19 juin 2020
==
New Guidelines Adopted by the International Commission on Non‐Ionizing Radiation Protection (ICNIRP)
Protect Us Only from Thermal or Heating Effects
The ICNIRP issued a media release today to announce the publication of its new human exposure guidelines for non-ionizing radiation (100 KHz to 300 GHz) in the journal Health Physics. The guidelines address radio, WiFi, and Bluetooth in addition to 3G, 4G, and 5G cell phones and cell towers.
According to ICNIRP Chairman, Eric van Rongen, "We know parts of the community are concerned about the safety of 5G and we hope the updated guidelines will help put people at ease."
However, ICNIRP's new guidelines are likely to have the opposite effect and increase public concerns about wireless technology because the guidelines were designed to protect us only from short-term heating (or thermal) effects. The guidelines fail to protect us from non-thermal effects, especially from long-term exposure to wireless radiation because ICNIRP continues to dismiss the many hundreds of peer-reviewed studies that have found biologic and health effects from exposure to low-intensity, radio frequency radiation including many human as well as animal studies. The preponderance of the research has found evidence of increased cancer incidence, oxidative stress, DNA damage, and infertility from exposure to wireless radiation.
ICNIRP. Guidelines for limiting exposure to
electromagnetic fields (100 kHz to 300 GHz). Health Phys
118(00):000–000; 2020. Pre-print. DOI: 10.1097/HP.0000000000001210. https://www.icnirp.org/cms/upload/publications/ICNIRPrfgdl2020.pdf
==
January 1, 2020
ICNIRP's Revised RF Exposure Limits Will Ignore Expert Opinions of Most EMF Scientists
According to Eric van Rongen, chairman of the International Commission on Non-ionizing Research Protection (ICNIRP), in August or September the ICNIRP plans to publish its revised guidelines regarding safe human exposure limits to radiofrequency (RF) electromagnetic fields (EMF) (100 kHz - 300 GHz).
On April 17, 2019, Van Rongen made a presentation about the revised guidelines to the French National Frequency Agency. The ICNIRP guidelines will still be based only on thermal or heating effects. The Commission continues to ignore the many hundreds of peer-reviewed studies that have found bioeffects and health effects from exposure to low intensity, non-thermal levels of RF radiation.
Van Rongen made the following claims (see slide 8 of the presentation):
- "No evidence that RF EMF causes such diseases as cancer
- Results of NTP, Falcioni studies (animals, lifetime exposure) not convincing (statement on ICNIRP website)
- No evidence that RF EMF impairs health beyond effects that are due to established mechanisms of interaction"
The 13 commissioners of the ICNIRP strongly disagree with more than 240 EMF scientists who signed the International EMF Scientist Appeal. These scientists who have published over 2,000 papers in professional journals on EMF and biology or health stated:
"The various agencies setting safety standards have failed to impose sufficient guidelines to protect the general public, particularly children who are more vulnerable to the effects of EMF. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) established in 1998 the “Guidelines For Limiting Exposure To Time-Varying Electric, Magnetic, and Electromagnetic Fields (up to 300 GHz)” . These guidelines are accepted by the WHO and numerous countries around the world. The WHO is calling for all nations to adopt the ICNIRP guidelines to encourage international harmonization of standards. In 2009, the ICNIRP released a statement saying that it was reaffirming its 1998 guidelines, as in their opinion, the scientific literature published since that time “has provided no evidence of any adverse effects below the basic restrictions and does not necessitate an immediate revision of its guidance on limiting exposure to high frequency electromagnetic fields. ICNIRP continues to the present day to make these assertions, in spite of growing scientific evidence to the contrary. It is our opinion that, because the ICNIRP guidelines do not cover long-term exposure and low-intensity effects, they are insufficient to protect public health."
During the public consultation period, about 120 contributors provided the ICNIRP with more than 1,000 comments regarding the draft guidelines.
How many contributors called for RF exposure guidelines that protect humans and other species from health risks due to exposure to low-intensity or non-thermal levels of RF radiation? Did the ICNIRP seriously consider the public input in revising the guidelines? Will the ICNIRP publish these comments?
How many contributors called for RF exposure guidelines that protect humans and other species from health risks due to exposure to low-intensity or non-thermal levels of RF radiation? Did the ICNIRP seriously consider the public input in revising the guidelines? Will the ICNIRP publish these comments?
The slides from the van Rongen presentation (marked "Draft -- Do Not Cite or Quote") are available at: https://www.anfr.fr/fileadmin/mediatheque/documents/expace/workshop-5G/20190417-Workshop-ANFR-ICNIRP-presentation.pdf
Related posts:
"Cell Phones, Cell Towers, and Wireless Safety" (UC Berkeley presentation / video & slides, Feb. 2019)
PowerWatch: 1,670 Scientific Papers on EMF (1979 - 2018)
==
February 12, 2019 (Links updated January 30, 2024)
The "ICNIRP Cartel" and "The 5G Mass Experiment"
"... it could also harm your health. Europe's
governments ignore the danger."
As part of
a project called, “The 5G Mass Experiment,” Investigate Europe, a team of
investigative journalists from the European Union (EU), examined the risks of
deployment of 5G, the fifth generation of mobile phone technology, and the
adequacy of electromagnetic field (EMF) safety guidelines promoted by the
International Commission for Non-Ionizing Radiation Protection (ICNIRP).
To date,
the team has published 22 articles in major newspapers and magazines in eight countries: France, Germany, Italy, Netherlands, Norway, Poland, Portugal, and the United Kingdom.
Investigate
Europe alleges the existence of an “ICNIRP
cartel.” The journalists identified a group of fourteen scientists who either
helped create, or defend, the EMF exposure guidelines disseminated by ICNIRP, a
non-governmental organization (NGO) based in Germany. ICNIRP’s self-selected
members and advisors believe that EMF safety guidelines need to protect humans
only from heating (or thermal) effects due to acute EMF exposure. ICNIRP scientists
argue that the thousands of peer-reviewed studies that have found harmful
biologic or health effects from chronic exposure to non-thermal levels of EMF
are insufficient to warrant stronger safety guidelines. The journalists argue that
the cartel promotes the ICNIRP guidelines by conducting biased reviews of the scientific
literature that minimize health risks from EMF exposure. These reviews have
been conducted for the World Health Organization (WHO) and other government
agencies. By preserving the ICNIRP EMF exposure guidelines favored by industry,
the cartel ensures that the cellular industry will continue to fund health
effects research. Besides these fourteen scientists, perhaps several dozen EMF
scientists in the EU and other countries actively defend the ICNIRP exposure
guidelines.
In
contrast to the dozens of EMF scientists who support the ICNIRP EMF exposure
guidelines, more than 240 EMF scientists from 42 nations who published
peer-reviewed research on EMF and biology or health totaling over 2,000 papers
have signed the International EMF Scientist Appeal. The Appeal calls on
the WHO, the United Nations and all member nations to adopt much stronger EMF exposure guidelines that
protect humans and other species from sub-thermal levels of EMF exposure and
to issue health warnings about the risks of EMF exposure.
The 5G Mass Experiment and the ICNIRP Cartel
A compilation of the information gathered by Investigate Europe about the ICNIRP Cartel members and the health agencies that the Cartel affected can be downloaded at:
http://bit.ly/ICNIRPcartel-031519.
The information on these pages was extracted from “The ICNIRP Cartel: Who’s Who in the EMF Research World,” an interactive graphic developed by Investigate Europe which can be found at https://www.kumu.io/Investigate-Europe/whos-who.
A compilation of the information gathered by Investigate Europe about the ICNIRP Cartel members and the health agencies that the Cartel affected can be downloaded at:
http://bit.ly/ICNIRPcartel-031519.
The information on these pages was extracted from “The ICNIRP Cartel: Who’s Who in the EMF Research World,” an interactive graphic developed by Investigate Europe which can be found at https://www.kumu.io/Investigate-Europe/whos-who.
For more
information see:
Investigate
Europe (2019). The 5G Mass Experiment. https://web.archive.org/web/20190331035052/https://www.investigate-europe.eu/publications/the-5g-mass-experiment/. (Google Translate is a useful tool for translating these
articles into other languages.)
Investigate Europe (2019). How Much is Safe? https://www.investigate-europe.eu/posts/how-much-is-safe
Investigate Europe (2019). Mobile phones and health: Is 5G being rolled out too fast? https://www.computerweekly.com/feature/Mobile-phones-and-health-is-5G-being-rolled-out-too-fast
Investigate Europe (2019). How Much is Safe? https://www.investigate-europe.eu/posts/how-much-is-safe
Investigate Europe (2019). Mobile phones and health: Is 5G being rolled out too fast? https://www.computerweekly.com/feature/Mobile-phones-and-health-is-5G-being-rolled-out-too-fast
Countries are deploying 5G at breakneck speed to gain a competitive edge, but scientists have concerns about effects on public health and are calling for a precautionary approach.
Related Information:
WHO Radiofrequency Radiation Policy
WHO Radiofrequency Radiation Policy
Nov 1, 2018
THE EMF CALL: Scientists and NGO's call for better protection from Exposure to Radiation from Wireless Technology
Press-Release Nov 1, 2018
157
scientists and medical doctors together with 86 non-governmental
organizations (NGO’s) from all over the world are calling for more
protective limits for exposure to radiofrequency radiation from wireless
technologies. In a joint statement, THE EMF CALL, they conclude that
the ICNIRP guidelines are unscientific and do not protect against
harmful health effects including cancer.
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) issued draft Guidelines on 11th July 2018 for limiting exposure to electric, magnetic and electromagnetic fields (EMF) (100 kHz to 300 GHz). The
guidelines are inadequate to protect humans and the environment, as
they only protect against acute thermal effects from very short and
intense exposure. They do not protect against cancer, reproductive harm,
or effects on the nervous system, although the preponderance of the
peer-reviewed research has found adverse effects from chronic exposure
at intensities below the ICNIRP limits.
In
May, 2011, the World Health Organization’s cancer agency, the
International Agency for Research on Cancer (IARC), concluded that
radiofrequency radiation in the frequency range 30 kHz–300 GHz is a “possible” human carcinogen (Group 2B). However, the ICNIRP ignores this as well as the increasing evidence in recent years for carcinogenicity.
The
scientists and the NGO’s demand the development and adoption of new
medical guidelines that represent the state of medical science and that
are truly protective of human health and the environment. The
scientists and medical doctors, selected to review the scientific
literature and propose new radiofrequency radiation safety guidelines,
must be free of conflicts of interest including direct and indirect ties
to industry.
Professor David Carpenter, Director at the Institute for Health and the Environment, University of Albany, USA notes that:
- The
evidence for harm from both 50/60 Hz EMFs and radiofrequency exposures
is strong in both human and animal studies. There are associations
between increasing exposure not only with cancer, but also with adverse
reproductive outcomes in both males and females, adverse effects on
cognitive function and behavior and increased risk of development of the
syndrome of electro-hypersensitivity. We must find ways of reducing
human exposure in order to reduce the incidence of human disease.
Dr. Lennart Hardell, Swedish oncologist with long-term research in this area says:
- The
roll-out of 5G, the fifth generation of telecommunication technology
will substantially increase exposure to radiofrequency radiation. Thus,
in addition to the urgent need for new guidelines on current exposure a
moratorium on the roll-out of 5G should be implemented.
Dr Joel Moskowitz, from the School of Public Health, University of California, Berkeley, USA points out that the EMF CALL re-iterates the concerns raised
by the scientific community in the International EMF Scientist Appeal
about the harm caused by chronic exposure to low-intensity EMF:
- The
Appeal, which has been signed by more than 240 scientists who have
published over 2,000 peer-reviewed papers on EMF and biology or health,
calls for strengthening of EMF guidelines, especially to protect
children and pregnant women. For more information about the Appeal, see https://
According to Dr Gerd Oberfeld, from the Salzburg Public Health Department, Austria, the world has too long relied on incomplete EMF exposure guidelines:
- The
body of scientific evidence for detrimental health effects from EMF
exposure is overwhelming. There is now even no need to call the
precautionary principle into play to take action. It is the duty of
scientists to inform the public and the duty of the public to force
governments to apply new truly protective EMF exposure guidelines as
well as to educate the society how to reduce EMF exposures.
Contacts:
David Carpenter, email: dcarpenter@albany.edu
Lennart Hardell, email: lennart.hardell@
Joel Moskowitz, email: jmm@berkeley.edu
Gerd Oberfeld, email: gerd.oberfeld@salzburg.gv.at
See THE EMF CALL and all signatories at: www.emfcall.org
Franz Adlkofer, Pandora Foundation for independent research, Oct 26, 2018
The development of mobile communication technologies starting with 1G
up to now 5G is a success story rarely heard of previously. It has only
been possible because industry experts in charge of the technology
assumed that radiofrequency (RF) radiation and its modulations – similar
to visible light – are biologically harmless. They believed in safety
limits that reliably protect people only from the acute thermal effects
of RF radiation inherent in the system. Biological effects below the
safety limits were categorically ruled out because their existence
allegedly contradicted the laws of physics.
So, the technical use of RF radiation in mobile communication has
experienced hardly any limitation. Doubts about the harmlessness of this
radiation, just as old as the technique itself, have been countered by
the mobile communication industry as wrong and without basis. Compliant
scientists, whose preferred opinion was more important than their
qualifications, were generously supported and, by using political
connections, placed in national and international advisory and
decision-making bodies.
A milestone in putting through the interests of the mobile
communication industry was the establishment of the International
Commission on Non-Ionizing Radiation Protection (ICNIRP) in 1992. It is a
non-governmental organization. Michael Repacholi, then head of the
WHO’s EMF Project, managed to get official recognition for this group by
the WHO as well as the EU and a series of its member states, among them
Germany. Repacholi, first ICNIRP chairman and later emeritus – member,
left the WHO after allegations of corruption in 2006 and found a new
position as a consultant to an American electricity provider. ICNIRP’s
most important task is the establishment of safety limits for
non-ionizing radiation including RF radiation. Its decisions are of
utmost importance for the mobile communication industry’s economic and
strategic planning. The ICNIRP, whose members are convinced of the
harmlessness of RF radiation, has never changed its attitude despite all
research progress made in this field since 1992. To guarantee that the
mobile communication industry can permanently rely on ICNIRP, the
succession of a member who leaves is regulated by statute. The remaining
members select the new one on the basis of mutual understanding.
Together with the other groups mentioned above ICNIRP has ensured that
mobile communication industry is not only dominating the technical
research to which it is entitled to, but also the biological research –
this at the expense of the human health.
Excerpts
"There is no doubt that the evaluation of the NTP Study results by the invited panel members met all scientific criteria. This is also proven by the fact that the scientists responsible for the NTP Study have been confronted with numerous mistakes and other flaws, which could have been avoided with a better planning and implementation. However, these mistakes and flaws are by far not enough to question the most important result of the NTP Study, the evidence of carcinogenicity from mobile communication radiation."
"From the NTP Study it must be concluded that the safety limits established by ICNIRP are unable to guarantee the intended purpose, which is the protection of people from harmful effects of the mobile communication radiation, and that therefore time has come for IARC to adjust the classification of RF radiation from “possibly carcinogenic for humans” (Group 2B) to “probably carcinogenic to humans” (Group 2A) or even “carcinogenic to humans” (Group 1). Casting doubt on the NTP results, which threaten the business model of the mobile communication industry, as done by ICNIRP, is betrayal of science. If any further proof that ICNIRP is a public relations organization of the mobile communication industry would have been necessary, its Note on recent animal carcinogenesis studies (2) quoted above has finally adduced it. [See below.]
ICNIRP argues that the NTP Study has no reliable basis to revise the current safety limits for RF radiation. Since its guidelines are solely based on acute thermal effects of the radiation, believing that other effects do not exist, the argument is not without logic to them. However, the NTP Study has clearly shown that this stand is absolutely unfounded, because the RF radiation unfolds its harmful effects also within the safety limits, when the exposure time is long enough. The NTP Study, up to now certainly the most ambitious and the most convincing one, has proven this with “clear evidence” (3,5). At the same time, it has refuted the reliability of the current safety limits. As always in such cases the robot-like answer by ICNIRP is that many questions must be answered until causality can finally be acknowledged.
ICNIRP wants the perfect study. The fact that this is impossible because of the nature of biological research, can obviously not be imparted to its members. So they show either incompetence in regard of their scientific qualifications or, most probably, the intention to help the mobile communication industry in a difficult situation. It looks as if ICNIRP is once again used by this industry to enforce its interests, and this time with a method copied from the tobacco industry. By sowing doubt for decades, the tobacco industry succeeded in keeping people unsure about the already certain fact that smoking causes lung cancer. Now the mobile communication industry uses the same tactic, and this with even more dire consequences: the addiction might be comparable, but the number of addicts is by far much higher."
https://betweenrockandhardplace.files.wordpress.com/2018/11/pandora_adlkofer_dealing-with-ntp_en.pdf
==
Sep 12, 2018
US Scientist Criticizes ICNIRP’s Refusal to Reassess Cell Phone Radiation Exposure Guidelines after US National Toxicology Program Studies Show Clear Evidence of Cancer
Ronald L.
Melnick, Ph.D., has issued a scientific critique of ICNIRPs dismissal of the cell phone radiation studies conducted by the U.S.
On
September 4, 2018, ICNIRP issued a “Note on Recent Animal Studies” that
concluded the $28 million NTP study did “not provide a reliable basis” for changing the over two
decades old guidelines on radio frequency- cell phone and wireless – radiation.
In response, Dr. Melnick addressed 15 concerns raised by the ICNIRP about the NTP studies. He presented data to show that the ICNIRP document contains “numerous false and misleading
statements" and concluded by questioning who the ICNIRP is protecting:
"Based on numerous incorrect and misleading claims, the ICNIRP report concludes that “these studies (NTP and Ramazzini) do not provide a reliable basis for revising the existing radiofrequency exposure guidelines.” The data on gliomas of the brain and schwannomas of the heart induced by cell phone radiation are suitable for conducting a quantitative risk assessment and subsequent re-evaluation of health-based exposure limits. The ‘P’ in ICNIRP stands for Protection. One must wonder who this commission is trying to protect – evidently, it is not public health."
Dr. Melnick was a Senior Scientist in the National Toxicology Program, National Institute of Environmental Health Sciences, National Institutes of Health. He served as a toxicologist for over 28 years before retiring in 2009. In 2007 he received the American Public Health Association’s David P. Rall Award for science-based advocacy in public health.
Melnick RL. Critique of the ICNIRP Note of September 4, 2018 Regarding Recent Animal Carcinogenesis Studies. Environmental Health Trust. Sep 12, 2018. Open access document: http://bit.ly/MelnickICNIRP9-12-2018
Melnick RL. Critique of the ICNIRP Note of September 4, 2018 Regarding Recent Animal Carcinogenesis Studies. Environmental Health Trust. Sep 12, 2018. Open access document: http://bit.ly/MelnickICNIRP9-12-2018
--
Comments about the ICNIRP evaluation of the NTP and Ramazzini Institute studies
by the Ramazzini Institute
In recent days, the International Commission for the Protection of Non-Ionizing Radiation (ICNIRP) has dismissed the results of the studies conducted by the Ramazzini Institute (RI) and the National Toxicology Program (NTP) on cell phone radiation as "unconvincing.
Following are the observations of Dr. Fiorella Belpoggi, director of the "Cesare Maltoni" cancer research center of the Ramazzini Institute.
1. Both the NTP and the RI studies were well performed,and no bias affected the results. The ICNIRP confirms this conclusion.
2. Schwannomas are tumors arising from the Schwann cells. They are peripheral glial cells which cover and protect the surface of all nerves diffused throughout the body; so vestibular (acoustic nerve) and heart schwannomas have the same tissue of origin: ICNIRP seems to ignore that.
3. In rats, increases in malignant heart schwannomas, malignant glial tumors of the brain and Schwann Cell Hyperplasia (a pre-malignant lesion) are rare yet these lesions were observed in exposed animals in both laboratories, at thousands of kilometers distance, in a wide range of radiofrequency radiation exposures studied. These findings could not be interpreted as occurring “by chance”.
4. We are scientists. Our role is to produce solid evidence for hazard and risk assessment. Underestimating the evidence from carcinogen bioassays and delays in regulation have already proven many times to have severe consequences, as in the case of asbestos, smoking and vinyl chloride. This position of ICNIRP represents its own responsibility toward citizens and public health.
5. ICNIRP is not a public health agency that routinely evaluates carcinogens. On the other hand, an independent agency that has evaluated over 1000 agents, IARC, as early as 2011 classified radio freqency radiation as a possible carcinogen on the basis of limited evidence in humans and limited evidence in animals. The studies of the RI and NTP will certainly contribute to the burden of evidence that IARC and other public health agencies can draw upon as a solid base for the re-evaluation of RFR carcinogenicity.
http://bit.ly/RI-ICNIRP==
ICNIRP Critique of the National Toxicology Program and Ramazzini Institute
Animal Studies of the Carcinogenicity of Long-Term Exposure to Cell Phone Radiation
ICNIRP. ICNIRP Note on Recent Animal Carcinogenesis Studies. Munich, Germany. Sep 4, 2018. https://www.icnirp.org/cms/upload/publications/ICNIRPnote2018.pdf
Introduction
Two recent animal studies investigating the carcinogenic potential of long-term exposure to
radiofrequency electromagnetic fields (EMFs) associated with mobile phones have been released: one by the U.S. National Toxicology Program (NTP 2018a, b) and the other from the Ramazzini Institute (Falcioni et al. 2018). These studies, among others, have been taken into account during revision of the ICNIRP radiofrequency exposure guidelines. However, both studies have inconsistencies and limitations that affect the usefulness of their results for setting exposure guidelines, and both need to be considered within the context of other animal and human carcinogenicity research. Overall, based on the considerations outlined below, ICNIRP concludes that these studies do not provide a reliable basis for revising the existing radiofrequency exposure guidelines.
<snip>
Conclusion
Although the NTP (2018a, b) and Falcioni et al. (2018) studies used large numbers of animals, best laboratory practice, and exposed animals for the whole of their lives, consideration of their findings does not provide evidence that radiofrequency EMF is carcinogenic. NTP reported that their strongest findings were of increased malignant cardiac schwannoma in male rats, however that is not consistent with the results of Falcioni et al. (2018), is not consistent with the NTP female rat nor male or female mouse results, and is not consistent with the radiofrequency EMF cancer literature more generally. While results from epidemiological studies suggest vestibular schwannoma is an outcome of interest,
this is not true for malignant cardiac schwannoma. NTP found no increase in schwannoma overall or for vestibular schwannoma. Further, as multiple comparisons were not controlled for in the NTP study, there is no indication that the increased incidence of malignant cardiac schwannomas in male rats was more than what would be expected by chance alone. ICNIRP considers that the NTP (2018a, b) and Falcioni et al. (2018) studies do not provide a consistent, reliable and generalizable body of evidence that can be used as a basis for revising current human exposure guidelines. Further research is required that addresses the above limitations.
==
Jul 23, 2018
ICNIRP requests public input on its radio frequency radiation
exposure guidelines
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) has recently announced that it wants
public input regarding a new draft of its guidelines on limiting radio
frequency (RF) fields (i.e., electromagnetic fields [EMF] from 100 kilohertz to
300 Gigahertz).
“The main objective of this publication is to
establish guidelines for limiting exposure to EMFs that will provide a high
level of protection for all people against known adverse health effects from
direct, non-medical exposures to both short- and long-term, continuous and
discontinuous radiofrequency EMFs.”
The new publication replaces the
1998 RF exposure guidelines which have influenced RF exposure standards in many
nations including the guidelines adopted by the U.S. Federal Communications
Commission.
ICNIRP is an
association with a scientific mission that is registered in Germany as a
nonprofit organization. It is “formally recognized as an official collaborating
non-governmental organization (NGO) by the World Health Organization (WHO) and
the International Labour Organization (ILO). ICNIRP is linked to many
organizations engaged in non-ionizing radiation protection worldwide and
consults with the European Commission.”
ICNIRP’s new draft safety guidelines dismiss the
research on the effects of chronic exposure to non-thermal levels of RF
radiation. In its latest health risk assessment, ICNIRP concludes that there
are no “substantiated”
adverse effects of RF radiation on human health. See Appendix B: Health Risk Assessment Literature and a summary
of the findings which appears below.
Following is ICNIRP’s justification for
ignoring most of the EMF research in its health risk assessment:
"ICNIRP
bases its guidelines on substantiated adverse health effects. This makes the
difference between a biological and an adverse health effect an important
distinction, where only adverse health effects require limits for the
protection of humans." (ICNIRP
Guidelines: Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic
and Electromagnetic Fields [100 kHz TO 300 GHz]. July 11, 2018 draft. p. 2)
“These guidelines specify quantitative EMF
levels for safe personal exposure. Adherence to these levels is intended to
protect people from all known harmful effects of radiofrequency EMF exposure.
To determine these levels, ICNIRP first identified published scientific
literature concerning effects of radiofrequency EMF exposure on biological
systems, and established
which of these were both harmful to human health, and scientifically
substantiated. This latter point is important because ICNIRP considers that, in
general, reported effects need to be independently replicated, be of sufficient
scientific quality and explicable more generally within the context of the
scientific literature, in order to be taken as ‘evidence’ and used for setting
exposure restrictions. Within the guidelines, ‘evidence’ will be used within
this context, and ‘substantiated effect’ used to describe reported effects that
satisfy this definition of evidence. (ICNIRP Guidelines: Guidelines for Limiting
Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields [100 kHz
TO 300 GHz].” July 11, 2018 draft.
p. 2)
Public consultation on ICNIRP RF exposure guidelines
If you choose to provide public input to ICNIRP, the draft documents
consist of RF exposure guidelines and two appendices. Appendix A reviews dosimetry, and Appendix B summarizes the health risk assessment.
The consultation process which began on July 11 ends on
October 9, 2018. ICNIRP members will review public comments prior to finalizing
the RF exposure guidelines. ICNIRP will
not reply to comments.
To provide comments on the draft
documents, complete the form on the ICNIRP website or the template available at
https://www.icnirp.org/en/activities/public-consultation/consultation-1.html
Files for download
My editorial comments
To date, 242 scientists who have published peer-reviewed research on EMF
and biology or health have signed the EMF Scientist Appeal. Collectively, these
scientists from 41 nations have published more than 2,000 papers on EMF. The Appeal
calls on the WHO and the United Nations including its member states to
adopt more protective exposure guidelines for EMF including RF radiation in the
face of increasing evidence of health risks since these exposures are a rapidly
growing form of worldwide environmental pollution.
In a recently published, peer-reviewed paper, “Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international perspective,” Belpomme and his colleagues (2018) criticize
the WHO due to its reliance upon ICNIRP and its members for expert advice. The
paper claims that ICNIRP and its advisors have “close associations with
industry,” and “conflicts of interest.” According to the authors, ICNIRP and its
advisors have been engaged in decades of “denial
of serious non-thermal effects of RF-EMFs in spite of overwhelming scientific
evidence to the contrary.”
Moreover,
Belpomme and his colleagues criticize ICNIRP’s safety limits:
“The
specific absorption rate (SAR)-based ICNIRP safety limits were established on
the basis of simulation of EMF energy absorption using standardized adult male
phantoms, and designed to protect people only from the thermal effects of EMFs.
These assumptions are not valid for two reasons. Not only do they fail to
consider the specific morphological and bioclinical vulnerabilities of
children, but also they ignore the effects known to occur at non-thermal
intensities….”
Finally, Belpomme and his colleagues (2018) provide a summary of the peer-reviewed scientific literature that arrives at very different conclusions than ICNIRP's health risk assessment:
"It is urgent that national and international bodies, particularly the WHO, take this significant public health hazard seriously and make appropriate recommendations for protective measures to reduce exposures. This is especially urgently needed for children and adolescents. It is also important that all parts of society, especially the medical community, educators, and the general public, become informed about the hazards associated with exposure to EMFs and of the steps that can be easily taken to reduce exposure and risk of associated disease."
The rules that ICNIRP applies for a study to be included in
its health risk assessment seem overly stringent. If other official bodies
(e.g., the International Agency for Research on Cancer or the U.S.
Environmental Protection Agency) were to adopt such rules, I suspect that very few
chemicals would be classified as toxins or carcinogens. By its own admission, ICNIRP
is not concerned about protecting animal or plant life from the adverse effects
of EMF exposure, and it is arguable that they are truly concerned about protecting
humans.
If the claims of some EMF scientists and scientific
organizations (e.g., the European Cancer and Environment Research Institute and
the Russian National Committee on Non-Ionizing Radiation Protection) are true
that ICNIRP’s members and scientific advisors are selected because they are biased toward industry,
then it is fruitless to engage in ICNIRP’s public consultation process
(see my posts from May 1 through June 27, 2017.)
Since the credibility of ICNIRP depends heavily
upon its association with the WHO, a more fruitful activity for the EMF scientific community might be to convince the WHO and governments not to rely on
ICNIRP for EMF guidelines and no longer consult ICNIRP’s advisors.
==
Summaries
from ICNIRP’s Draft Appendix B: Health Risk Assessment Literature
“ICNIRP bases its guidelines on substantiated adverse health
effects. This makes the difference between a biological and an adverse health
effect an important distinction, where only adverse health effects require
limits for the protection of humans.” (p. 2)
Brain electrical activity and
cognitive function
“In summary, there is no
substantiated experimental or epidemiological evidence that exposure to
radiofrequency EMF affects higher cognitive functions relevant to health.” (p.
3)
Symptoms and wellbeing
“In summary, no reports of adverse effects on symptoms and
wellbeing have been substantiated, except for pain, which is related to
elevated temperature at high exposure levels. Thresholds for these have not
been clearly identified, but the best estimate is within the vicinity of 10 and
20 mA for indirect contact currents, for children and adults respectively, and
12.5 kW m-2 for direct
millimeter-wave exposure.” (pp. 3-4)
Other brain
physiology and related functions
“In summary, there is no
evidence of effects of radiofrequency EMF on physiological processes or eye
pathology that impair health in humans. Some evidence of superficial eye damage
has been shown in rabbits at exposures of at least 1.4 kW m-2,
although the relevance of this to humans has not been demonstrated.“ (p. 4)
Auditory,
vestibular and ocular function
“In summary, no effects
on auditory, vestibular, or ocular function relevant to human health have been
substantiated.” (p. 5)
Neuroendocrine
system
“In summary, the lowest
level at which an effect of radiofrequency EMF on the neuroendocrine system has
been observed is 4 W kg-1 (in rodents and primates), but there is no
evidence that this translates to humans or is relevant to human health. No
other effects have been substantiated.” (p. 6)
Neurodegenerative
diseases
“In summary, no adverse effects on
neurodegenerative diseases have been substantiated.” (p. 6)
Cardiovascular
system, autonomic nervous system and thermoregulation
“In summary, no effects
on the cardiovascular system, autonomic nervous system, or thermoregulation
that compromise health have been substantiated for exposures with whole body
average SARs below approximately 1 W kg-1, and there is some
evidence that 4 W kg-1 is not sufficient to alter body core temperature
in hamsters. However, there is strong evidence that whole body exposures in
rats that are sufficient to increase body core temperature by several degrees
centigrade can cause serious adverse health effects in rats.” (p. 7)
Immune system and
haematology
“The few human studies
have not indicated any evidence that radiofrequency EMF affects health in
humans via the immune system or haematology.” (p. 7)
Fertility,
reproduction and childhood development
“In summary, no adverse
effects of radiofrequency EMF exposure on fertility, reproduction or
development relevant to human health have been substantiated.” (p. 8)
Cancer
“In summary, no effects
of radiofrequency EMF on cancer have been substantiated.” (pp. 8-9)
==
==
June 19, 2017
International EMF Expert Group to Counter ICNIRP
ECERI Newsletter. No. 6, June 2017
"Following a recent meeting with WHO representatives in Geneva, members of this ECERI group have decided to publish their own data in the form of a scientific consensus paper on the effects of non-thermal EMFs on behalf of the ECERI. Finally, since several ECERI scientists believe that environmental pollution may in fact be a cause of cancer and other diseases such as Alzheimer disease and autism, ECERI has proposed to create another international group comprising scientists and jurists to discuss the possibility that intentional massive pollution could be recognized by the International Criminal Court (ICC) as a true crime against health. This proposal will be discussed at the next ECERI Executive Committee and General Assembly in Brussels.
Following the meeting with WHO in Geneva on March, the 3rd, it was proposed to create an ECERI-related working group to oppose ICNIRP (International Commission on Non-Ionizing Radiation Protection), that might be termed “International commission of scientific expertise on non-thermal radiation effects (ICSENTRE). The members of this group so far are: Dominique Belpomme (France), Igor Belyaev (Slovakia), Ernesto Burgio (Italy), David Carpenter (USA), Lennart Hardell (Sweden), Magda Havas (Canada), SMJ Mortazavi (Iran), André Vander Vorst (Belgium) and Gérard Ledoigt (France). If you wish to join this group, please contact Christine Campagnac (sg.eceri@gmail.com)."
ECERI – European Cancer and Environment Research Institute, Square de Meeus 38-40, 1000 Brussels; Tél :0032 24 01 87 75 or 0033 1.45.78.53.52 sg.eceri@gmail.com==
July 10, 2015
CONFLICT OF INTEREST EXISTING AT THE INTERNATIONAL COMMISSION ON NON-IONIZING RADIATION (ICNIRP)
AVAATE (VALLISOLETANA ASSOCIATION OF AFFECTED BY MOBILE PHONE ANTENNAS), July 10, 2015
SUMMARY
This paper has been prepared in order to demonstrate the existence of numerous conflicts of interest among the members of the international organization ICNIRP (International Commission on Non Ionizing Radiation Protection. In Castilian, the International Commission for Non-ionizing radiation), that despite its private nature, is recognized by the World Health Organization (WHO) as reference entity to set limits of exposure for people of non-ionizing radiation in order to prevent such radiation affect your health.
The fact that the members of the organization engage in various conflicts of interest, being related to companies interested in the development of telecommunications and new technologies, undermines the impartiality that should govern the regulation of limits on non-ionizing radiation people.
It’s incomprehensible that an international organization such as WHO, which has numerous and qualified public resources to establish adequately these limits, has delegated to a private organization issues affecting public health of all humanity.
The information contained in the work presented below was obtained from searches of reliable publicly available sources on the Internet, which can be checked by anyone who has an interest in this topic.
It would be very interesting by any natural or legal person interested in this topic assumes as its own this report (AVAATE authorized fully to do so) and send it to the authorities of the United Nations, of the International Labor Organization and of the World Health Organization of the Health.
