Addendum 4
| The ‘P’ in ICNIRP |
Dear William,
Ronald L. Melnick Ph.D: ‘The ‘P’ in ICNIRP stands for Protection. One must wonder who this commission is trying to protect – evidently, it is not public health.’
Although it may appear somewhat repetitive, due to the fact that Public Health England’s adherence to the ICNIRP guidelines puts the British public’s health at serious risk of harm I feel it absolutely necessary to send you the following critique of the 2018 ICNIRP draft on the grounds that: ‘When we have documents where the health and safety of essentially every single human being on earth may be at risk and the health and safety of many other living beings and whole ecosystems may be at risk, such as in this ICNIRP draft document and its appendices, …..’
ICNIRP DRAFT COMMENT:
Lennart Hardell MD PhD, Professor Emeritus, Örebro University Hospital, Department of Oncology: ‘If this draft represents the final version on ICNIRP guidelines it is time to close down ICNIRP since their evaluation is not based on science but on selective data such as only thermal effects from RFR … The draft represents a worst-case scenario for public health‘
ICNIRP DRAFT CRITIQUE:
‘Martin L. Pall, PhD, Professor Emeritus of Biochemistry and Basic Medical Sciences, Washington State University
Rainer Nyberg, EdD, Professor Emeritus. Vassa, Finland.
‘It is our opinion that safety can only be assessed biologically and that the whole structure that ICNIRP proposes is deeply flawed.’
Introduction
Scientific documents such as this ICNIRP draft document and its two associated appendices must:
. Be shown to be science-based on several widely accepted principles
. Provide an objective assessment of the scientific literature
. Use clear logic in making inferences or coming to conclusions
. Contain statements supported by citations or provide information, such that the reader can assess whether or not those statements are likely to be valid
. Contain scientific statements that are testable and falsifiable, such that it should be obvious how such statements can be falsified by the reader.
When we have documents where the health and safety of essentially every single human being on earth may be at risk and the health and safety of many other living beings and whole ecosystems may be at risk, such as in this ICNIRP draft document and its appendices, it is especially important that these principles be followed. Accordingly, the following must be viewed as very serious flaws in the ICNIRP draft document and its two appendices.
II. Serious flaws in 2018 ICNIRP draft guidelines and appendix B
1. The biological portions of these ICNIRP drafts have 64 different claims for which no evidence is provided. Each of these 64 claims should be documented in terms of the larger scientific literature, not just by cherry picking one or a few studies that can be claimed to support the ICNIRP position. This is particularly important because there is a very large literature contradicting many of these claims.
2. Among the most egregious claims are the undocumented claims that certain EMF effects have no demonstrated health impacts. It is our belief that most, if not all, EMF effects have demonstrated health impacts, as shown by the biomedical scientific literature. Claims of no demonstrated health impacts must, therefore, be based on an extensive review of the biomedical literature on what health effects, if any, are produced by each EMF effect.
3. The conditions used in a study determine what results are obtained. Therefore, a study done under one set of conditions cannot conflict with or show inconsistencies with another done under another set of conditions. The only way to show conflicts or inconsistencies is to do identical studies and produce different results. ICNIRP and other similar organizations often suggest that there are conflicts or inconsistencies based on some superficial similarities, while providing no evidence whatsoever that any such inconsistencies actually exist. This is, therefore, a fundamental logical flaw that needs to be corrected in the ICNIRP draft.
4. A number of specific issues derived from appendix 1 of this document are dealt with below. These include both the biological parts of the ICNIRP draft and various critiques of it. The following 14 critiques are considered particularly important and are therefore singled out for comment here.
III. Critiques of biological parts of ICNIRP draft
1. Neurological and/or neuropsychiatric effects that occur at microwave frequencies
ICNIRP claims that frequencies above 10 MHz are not known to stimulate nerves. However, 27 different reviews listed in appendix 2 show that there are neurological and/or neuropsychiatric effects that occur at microwave frequencies. This claim is therefore false and must be deleted.
2. Non-thermal effects of microwave frequency electromagnetic fields (EMFs)
2018 ICNIRP draft guidelines, subsect. 4.3.3 (Temperature elevation):
“For very low exposure levels (such as within the ICNIRP (1998) basic restrictions), there is extensive evidence that the amount of heat generated is not sufficient to cause harm, but for exposure levels above those of the ICNIRP (1998) basic restriction levels, yet below those shown to produce harm, there is still uncertainty.”
ICNIRP provides no evidence for this claim, which is falsified by each of the 89 reviews listed in appendix 2. If ICNIRP wishes to argue against those findings, it should first cite each review, discuss in detail the findings reported and then attempt to rebut each of those 89 bodies of evidence.
2018 ICNIRP draft guidelines, subsect. 4.3.3 (Temperature elevation):
“Where there is good reason to expect health impairment at temperatures lower than those shown to impair health via radiofrequency EMF exposure, ICNIRP uses those lower temperatures to base limits on.”
No evidence is provided to support this claim. Again, this statement clearly appears to be false based on those same 89 bodies of evidence.
3. Electromagnetic hypersensitivity or EHS
2018 ICNIRP draft guidelines, appendix B, sect. 2.2 (Symptoms and well being):
“A small portion of the population attributes non-specific symptoms to various types of radiofrequency EMF exposure; this is referred to as Idiopathic Environmental Intolerance attributed to EMF (IEI-EMF). Double-blind experimental studies have consistently failed to identify a relation between radiofrequency EMF exposure and such symptoms in the IEI-EMF population, as well as in healthy population samples. These human experimental studies provided evidence that ‘belief about exposure’ (e.g. the so-called ‘nocebo’ effect), and not exposure itself, is the relevant symptom determinant.”
No evidence is provided in support of these assertions. The accepted name for what ICNIRP calls “IEI-EMF” is “electromagnetic hypersensitivity” or EHS and there is much information about it in the scientific literature. It has been shown in four studies that it is possible to identify people with apparent EHS and show that they can be tested in blinded fashion using objectively measurable responses, showing that they are genuinely hypersensitive when compared with normal controls. The four studies are:
1. Rea WR, Pan Y, Yenyves EJ, Sujisawa I, Suyama N, Ross GH. 1991. Electromagnetic field sensitivity. J Bioelectr 10:241-256.
2. Havas M. 2006 Electromagnetic hypersensitivity: biological effects of dirty electricity with emphasis on diabetes and multiple sclerosis. Electromagn Biol Med 2006;25(4):259–68.
3. Havas M, et al. 2010 Provocation study using heart rate variability shows microwave radiation from DECT phone affects autonomic nervous system. In: Giuliani L, Soffritti M, editors. “Nonthermal Effects and Mechanisms of Interaction Between Electromagnetic Fields and Living Matter”, European J Oncology — Library. National Institute for the Study and Control of Cancer and Environmental Disease Bologna: Mattioli; 2010. pp. 273–300. 2010.
4. McCarty DE, et al. 2011 Electromagnetic hypersensitivity: evidence for a novel neurological syndrome. Int J Neurosci. www.ncbi.nlm.nih.gov/pubmed/21793784. 2011 Sep 5.
There are other studies that show that there are genuine physiological changes occurring in EHS. Two studies have shown that EHS people have high levels of oxidative stress:
1. De Luca C, Raskovic D, Pacifico V, Thai JC, Korkina L. 2011 The search for reliable biomarkers of disease in multiple chemical sensitivity and other environmental intolerances. Int J Environ Res Public Health. 2011 Jul;8(7):2770-97. doi: 10.3390/ijerph8072770.
2. Irigaray P, Caccamo D, Belpomme D. 2018 Oxidative stress in electrohypersensitivity selfreporting patients: Results of a prospective in vivo investigation with comprehensive molecular analysis. Int J Mol Med. 2018 Oct;42(4):1885-1898. doi: 10.3892/ijmm.2018.3774.
The De Luca et al. citation also showed that genetic polymorphisms in genes encoding enzymes for glutathione utilization produce increased susceptibility to EHS. These findings show that oxidative stress and lowered chemical metabolism have roles in causing EHS and that the ICNIRP claim that it is caused by a nocebo effect is again falsified.
Furthermore, it has been shown using fMRI that there are regions of the brain in EHS people who are especially sensitive to EMF stimulation:
Heuser G, Heuser SA. 2017 Functional brain MRI in patients complaining of electrohypersensitivity after long term exposure to electromagnetic fields. Rev Environ Health. 2017 Sep 26;32(3):291-299. doi: 10.1515/reveh-2017-0014.
It can be seen from this that EHS is a genuine hypersensitivity condition with major sensitivity responses in the brain. Consequently, not only is what ICNIRP says in this area undocumented, but also each of the ICNIRP claims is also false.
4. Associations between exposure and symptoms or well-being
2018 ICNIRP draft guidelines, appendix B, sect. 2.2 (Symptoms and wellbeing):
“Overall, the epidemiological research does not provide evidence of a causal effect of radiofrequency EMF exposure on symptoms or well-being.”
No evidence is provided in support of this claim. The same 26 reviews on neurological/neuropsychiatric effects that were referred to above also falsify these ICNIRP claims regarding cell phone effects. Similar effects were found, including sleep disruption, fatigue, headache, memory dysfunction, depression, lack of concentration, anxiety, sensory dysfunction and several others. These were found to be produced by many different types of EMF exposures. These included radar, other occupational exposures, three types of broadcast radiation, heavy cell phone use, living near cell phone towers and microwave radiation of the US embassy in Moscow. Clearly these are not caused by behavioral changes specific for cell phone use, as ICNIRP argues here. When these problems are becoming almost universal in every single technologically advanced country on earth, surely it is time for ICNIRP to start protecting us from them.
5. High frequency EMF exposure affects symptoms
2018 ICNIRP draft guidelines, appendix B, sect. 2.2 (Symptoms and well being):
“There is thus no evidence that high frequency EMF exposure affects symptoms, except for pain (and potentially tissue damage) at high exposure levels.”
No evidence is provided in support of this claim. It is shown to be completely untrue by the 27 reviews on neurological/neuropsychiatric effects previously discussed.
6. Physiological functions and adverse health effects
2018 ICNIRP draft guidelines, appendix B, sect. 2.3 (Other brain physiology and related functions):
“A number of studies of physiological functions that could in principle lead to adverse health effects have been conducted, primarily using in vitro techniques. These have included multiple cell lines and assessed such functions as intra- and intercellular signaling, membrane ion channel currents and input resistance, Ca2+ dynamics, signal transduction pathways, cytokine expression, biomarkers of neurodegeneration, heat shock proteins, and oxidative stress-related processes. Some of these studies also tested for effects of co-exposure of radiofrequency EMF with known toxins. Although some effects have been reported for some of these endpoints, there is currently no evidence of effects relevant to human health.”
No evidence is provided in support of these claims. Is ICNIRP really trying to argue that important signaling pathways, excessive intracellular calcium, inflammation including inflammatory cytokines, neurodegeneration, heat shock responses and oxidative stress have “no relevance to human health”? If so, ICNIRP needs to debunk hundreds of thousands of studies in the PubMed database.
7. Evidence of eye damage
2018 ICNIRP draft guidelines, appendix B, sect. 2.3 (Other brain physiology and related functions):
“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.”
Why does ICNIRP state that there is no evidence of human relevance but never tells us if there is any evidence that the findings are not relevant to humans? If there is simply a lack of evidence, then the way ICNIRP describes this speaks to an unconscionable bias on the part of ICNIRP.
8. Endocrine, including neuroendocrine systems, impacted by non-thermal EMF exposures
In contrast with the many ICNIRP statements with no evidence provided, the endocrine, including neuroendocrine systems, have been widely found to be impacted by non-thermal EMF exposures as shown by the following 12 reviews:
1. Glaser ZR, PhD. 1971 Naval Medical Research Institute Research Report, June 1971. Bibliography of Reported Biological Phenomena (“Effects”) and Clinical Manifestations Attributed to Microwave and Radio-Frequency Radiation. Report No. 2 Revised.
scholar.google.com/scholar?q=Glaser+naval+medical+microwave+radiofrequency+1972&btnG=&hl=en&as_sdt=0%2C38 (Accessed Sept. 9, 2017)
2. Tolgskaya MS, Gordon ZV. 1973. Pathological Effects of Radio Waves, Translated from Russian by B Haigh. Consultants Bureau, New York/London, 146 pages.
3. Raines, J. K. 1981. Electromagnetic Field Interactions with the Human Body: Observed Effects and Theories. Greenbelt, Maryland: National Aeronautics and Space Administration 1981; 116 p.
4. Hardell, L., Sage, C. 2008. Biological effects from electromagnetic field exposure and public exposure standards. Biomed. Pharmacother. 62, 104-109.
5. Makker K, Varghese A, Desai NR, Mouradi R, Agarwal A. 2009 Cell phones: modern man’s nemesis? Reprod Biomed Online 18:148-157.
6. Gye MC, Park CJ. 2012 Effect of electromagnetic field exposure on the reproductive system. Clin Exp Reprod Med 39:1-9. doi.org/10.5653/cerm.2012.39.1.1
7. Pall, M. L. 2015. Scientific evidence contradicts findings and assumptions of Canadian Safety Panel 6: microwaves act through voltage-gated calcium channel activation to induce biological impacts at non-thermal levels, supporting a paradigm shift for microwave/lower frequency electromagnetic field action. Rev. Environ. Health 3, 99-116.
8. Sangün Ö, Dündar B, Çömlekçi S, Büyükgebiz A. 2016 The Effects of Electromagnetic Field on the Endocrine System in Children and Adolescents. Pediatr Endocrinol Rev 13:531-545.
9. Hecht, Karl. 2016 Health Implications of Long-Term Exposures to Electrosmog. Brochure 6 of A Brochure Series of the Competence Initiative for the Protection of Humanity, the Environment and Democracy. kompetenzinitiative.net/KIT/wpcontent/uploads/2016/07/KI_Brochure-6_K_Hecht_web.pdf (accessed Feb. 11, 2018)
10. Asghari A, Khaki AA, Rajabzadeh A, Khaki A. 2016 A review on Electromagnetic fields (EMFs) and the reproductive system. Electron Physician. 2016 Jul 25;8(7):2655-2662. doi: 10.19082/2655.
11. Pall ML. 2018 Wi-Fi is an important threat to human health. Environ Res 164:404-416.
12. Wilke I. 2018 Biological and pathological effects of 2.45 GHz on cells, fertility, brain and behavior. Umwelt Medizin Gesselshaft 2018 Feb 31 (1).
If ICNIRP wishes to disagree with the findings in these reviews, it should cite each of these reviews and describe what findings were documented in each of them. Only then could ICNIRP feel free to disagree with any conclusions reached. Ignoring vast amounts of contrary data and opinion undercuts any claim that ICNIRP may make to providing unbiased science.
9. Neuronal cell death following non-thermal EMF exposures
2018 ICNIRP draft guidelines, appendix B, chap. 5 (Neurodegenerative Diseases):
“Although one group has reported that exposure to pulsed radiofrequency EMF fields increased neuronal death in rats, which might contribute to an increased risk of neurodegenerative disease, two studies have failed to confirm these results.”
No evidence is provided in support of this claim. This is completely inaccurate: approximately a dozen studies found elevated levels of neuronal cell death following non-thermal EMF exposures reviewed in the Tolgaskya and Gordon 1973 review. The two studies by Zhang et al. in rats showed that repeated pulsed microwave/RF radiation in young rats caused them to develop Alzheimer’s-like effects as middle-aged rats, including elevated levels of amyloid beta protein and oxidative stress in their brains and including Alzheimer’s-like behavioral and memory deficiencies. Other studies have found increased levels of amyloid beta protein following EMF exposures. Why is ICNIRP ignoring such evidence?
10. Link between radiofrequency EMF exposure and measures of cardiovascular health
2018 ICNIRP draft guidelines, appendix B, chap. 6 (Cardiovascular System, Autonomic Nervous System, and Thermoregulation):
“The changes were also inconsistent and may be due to methodological limitations or chance.”
No evidence is provided in support of this claim. Again, the only way to show inconsistency is to perform identical studies that produce widely different findings. If ICNIRP has such studies, it should produce them. If it does not, it should stop falsely claiming inconsistency when one may be looking simply at variation due to changes in the conditions used. When ICNIRP claims there are methodological problems, these need to be clearly stated and clearly documented.
11. Non-thermal radiofrequency EMF exposures produce autoimmune responses
2018 ICNIRP draft guidelines, appendix B, chap. 7 (Immune System and Haematology):
“There is currently no evidence that such reported effects, if real, are relevant to human health.”
A total of 11 animal studies in the EMF Portal database show that non-thermal radiofrequency EMF exposures produce autoimmune responses. These can be easily found by searching that database for autoimmune or autoimmunity for EMFs over 10 MHz. If ICNIRP wishes to argue that these findings are irrelevant to the large increases in autoimmune incidence and prevalence we have seen in recent years in humans, it should make whatever argument it feels is appropriate. To have ICNIRP ignoring this pattern of evidence is unacceptable.
12. Effects of radiofrequency EMF exposure on reproduction and development
2018 ICNIRP draft guidelines, appendix B, chap. 8 (Fertility, Reproduction, and Childhood Development):
“There is very little human experimental research addressing possible effects of radiofrequency EMF exposure on reproduction and development. What is available has focused on hormones that are relevant to reproduction and development, and as described in the Neuroendocrine System section above, there is no evidence that they are affected by radiofrequency EMF exposure.”
This is completely untrue. There are 13 studies showing that such EMFs impact human male reproduction, including sperm motility and aberrations in sperm structure; long-term exposures produce decreases in sperm count. These impacts are shown in the following studies:
1. Avendaño, Mata AM, Sanchez Sarmiento CA. 2012 Use of laptop computers connected to the internet through Wi-Fi deceases human sperm motility and increases sperm DNA fragmentation. Fertil Steril 97: No. 1, January 2012 0015-8282.
2. Agarwal A, Desai NR, Makker K, Varghese A, Mouradi R, Sabanegh E, Sharma R. 2008 Effects of radiofrequency electromagnetic waves (RF-EMW) from cellular phones on human ejaculated semen: an in vitro pilot study. Fertil Steril 92: 1318-1325.
3. Erogul O, Oztas E, Yildirim U, Kir T, Emin A, Komeski G, Irkilata, HC, Irmak MK, Peker AF. 2006 Effects of electromagnetic radiation from cellular phone on human sperm motility. Arch Med Res 37:840-843.
4. Wdowiak A, Wdowiak L, Wiktor H. 2007 Evaluation of the effect of using mobile phones on male fertility. Ann Agric Environ Med 2007, 14: 169-172
The following additional nine studies can all be accessed in the EMF Portal database:
Oni et al., 2011; Iuliis et al., 2009; Zalata et al., 2015; Gorpinchenko et al., 2014; Wang et al., 2015; Baste et al., 2008; Davoudi et al., 2002; Kilgallon and Simmons, 2005; Fejes et al., 2005.
Therefore, the claim by ICNIRP that there are few studies of the effects of EMFs on human reproduction are clearly false. There is also concern about EMF causation of increased spontaneous abortion in humans from an earlier review and from four recent primary literature citations:
1. Goldsmith JR. 1997 Epidemiologic evidence relevant to radar (microwave) effects. Environ Health Perspect. 1997 Dec;105 Suppl 6:1579-87.
2. Mahmoudabadi FS, Ziaei S, Firoozabadi M, Kazemnejad A. 2015 Use of mobile phone during pregnancy and the risk of spontaneous abortion. J Environ Health Sci Eng. 2015 Apr 21;13:34. doi: 10.1186/s40201-015-0193-z.
3. Mortazavi SMJ, Mortazavi SA, Paknahad M. 2012 Association between electromagnetic field exposure and abortion in pregnant women living in Tehran. Int J Reprod Biomed (Yazd) 2017 Feb;15(2):115-116.
4. Liu XY, Bian XM, Han JX, Cao ZJ, Fan GS, Zhang C, Zhang WL, Zhang SZ, Sun XG. 2007 (Risk factors in the living environment of early spontaneous abortion pregnant women). Zhongguo Yi Xue Ke Xue Yuan Xue Bao. 2007 Oct;29(5):661-4.
5. Zhou LY, Zhang HX, Lan YL, Li Y, Liang Y, Yu L, Ma YM, Jia CW, Wang SY. Epidemiological investigation of risk factors of the pregnant women with early spontaneous abortion in Beijing. Chin J Integr Med. 2017 May;23(5):345-349. doi: 10.1007/s11655-015-2144-z. Epub 2015 Apr 14.
ICNIRP can, if it wishes, argue against these findings, but it cannot simply ignore them and have any sustainable claim that it is protecting our health from EMF effects.
13. Prenatal exposure to EMF non-thermal radiation can produce neurological effects.
2018 ICNIRP draft guidelines, appendix B, chap. 8 (Fertility, Reproduction, and Childhood Development):
“There is currently no evidence that developmental phase is relevant to this issue.”
No evidence is provided in support of this claim. Six studies have found that late prenatal EMF non-thermal exposures in rodents produce long-term neurological changes that are maintained as adults, changes similar to those found in ADHD or autism. No similar changes are produced in adults. These changes were found to be produced by cell phone radiation, cordless phone radiation and by Wi-Fi, suggesting that prenatal exposure to a broad range of such radiation can produce these effects. These studies are as follows:
1. Aldad TS, Gan G, Gao X-B, Taylor HS. 2012 Fetal radiofrequency radiation from 800-1900 MHrated cellular telephone affects neurodevelopment and behavior in mice. Scientific Rep 2, article 312.
2. Othman, H., Ammari, M., Rtibi, K., Bensaid, N., Sakly, M., Abdelmelek, H. 2017. Postnatal development and behavior effects of in-utero exposure of rats to radiofrequency waves emitted from conventional WiFi devices. Environ. Toxicol. Pharmacol. 52:239-247. doi: 10.1016/j.etap.2017.04.016.
3. Bas O, Sönmez OF, Aslan A, Ikinci A, Hanci H, Yildirim M, Kaya H, Akca M, Odaci E. 2013 Pyramidal Cell Loss in the Cornu Ammonis of 32-day-old Female Rats Following Exposure to a 900 Megahertz Electromagnetic Field During Prenatal Days 13-21. Neuroquantology 11: 591599.
4. Kumari K, Koivisto H, Myles C, Jonne N, Matti V, Heikki T, Jukka J. 2017 Behavioural phenotypes in mice after prenatal and early postnatal exposure to intermediate frequency magnetic fields. Environ Res 162: 27-34.
5. Othman H, Ammari M, Sakly M, Abdelmelek H. 2017 Effects of prenatal exposure to WIFI signal (2.45GHz) on postnatal development and behavior in rat: Influence of maternal restraint. Behav Brain Res 326: 291-302 doi: 10.1016/j.bbr.2017.03.011.
6. Stasinopoulou M, Fragopoulou AF, Stamatakis A, Mantziaras G, Skouroliakou K, Papassideri IS, Stylianopoulou F, Lai H, Kostomitsopoulos N, Margaritis LH. 2016 Effects of pre- and postnatal exposure to 1880-1900 MHz DECT base radiation on development in the rat. Reprod Toxicol 2016; 65: 248-262.
There is a second type of study that also produces clear evidence of fetal effects not seen in adults. These are the two studies in cattle that clearly show high sensitivity of the fetus to EMFs. Conducted by Professor Hässig and his colleagues in Switzerland, they demonstrate effects deep within the body, on cataract formation in newborn calves where the mothers were grazing near a cell phone tower:
1. Hässig M, Jud F, Naegeli H, Kupper J, Spiess BM. 2009 Prevalence of nuclear cataract in Swiss veal calves and its possible association with mobile telephone antenna base stations. Schweiz Arch Tierheilkd 151:471-478.
2. Hässig M, Jud F, Spiess B. 2012 (Increased occurrence of nuclear cataract in the calf after erection of a mobile phone base station). Schweiz Arch Tierheilkd 154:82-86.
The Swiss safety guidelines are 100 times more stringent than are the ICNIRP safety guidelines, emphasizing the complete inadequacy of the ICNIRP safety guidelines. These two studies clearly show that when pregnant cows are grazing near mobile phone base stations (also called cell phone towers), the calves are born with very greatly increased incidences of cataracts. It follows from these findings that, even though the developing fetuses are very deep in the body of the mother and should be highly protected from the EMF exposures, they are not so protected. Furthermore, because the mothers do not develop cataracts despite their eyes being much more exposed to cell phone tower radiation, this clearly argues that the fetal eye tissue is vastly more sensitive to EMF effects than is adult eye tissue. When ICNIRP claims there is no evidence but there clearly is evidence, this destroys whatever credibility ICNIRP may have had.
14. EMF exposure has important role in cancer causation
2018 ICNIRP draft guidelines, appendix B, chap. 9 (Cancer):
“There is a large body of literature concerning cellular and molecular processes that are of particular relevance to cancer. This includes studies of cell proliferation, differentiation and apoptosis-related processes, proto-oncogene expression, genotoxicity, increased oxidative stress, and DNA strand breaks. Although there are reports of effects of radiofrequency EMF on a number of these endpoints, there is no substantiated evidence of health-relevant effects.”
No evidence is provided in support of this claim. What ICNIRP is apparently claiming is that these effects of EMF exposure, each of which has been shown in an extraordinarily large scientific literature to have an important role in cancer causation, are—inexplicably—not relevant to health! We are relying on the Melnick critique to provide a much broader-ranging assessment of the many flaws in this cancer section of the ICNIRP draft. We urge ICNIRP to pay close attention to the Melnick critique.
5. Appendix 2 contains reviews documenting each of eight different non-thermal EMF effects. These effects are as follows:
1. Effects on cellular DNA including single-strand and double-strand breaks in cellular DNA and on oxidized bases in cellular DNA; also evidence for chromosomal mutations produced by double strand DNA breaks (23 reviews). 2. Lowered fertility, including tissue remodeling changes in the testis, lowered sperm count and sperm quality, lowered female fertility including ovarian remodeling, oocyte (follicle) loss, lowered estrogen, progesterone and testosterone levels (that is sex hormone levels), increased spontaneous abortion incidence, lowered libido (19 reviews).
3. Widespread neurological/neuropsychiatric effects (27 reviews).
4. Apoptosis/cell death (an important process in production of neurodegenerative diseases that is also important in producing infertility responses) (13 reviews).
5. Oxidative stress/free radical damage (important mechanisms involved in almost all chronic diseases; direct cause of cellular DNA damage) (21 reviews).
6. Endocrine, that is hormonal effects, including neuroendocrine, peptide and other non-steroid hormones; also steroid hormones (12 reviews).
7. Increased intracellular calcium: intracellular calcium is maintained at very low levels (typically about 2 X 10-9 M) except for brief increases used to produce regulatory responses, such that sustained elevation of intracellular calcium levels produces many pathophysiological (that is disease-causing) responses) (16 reviews).
8. Cancer causation by EMF exposures (36 reviews).
ICNIRP appears to be systematically avoiding citing and discussing review articles that discuss contrary findings and express contrary opinions to those expressed by ICNIRP. That is not acceptable. If ICNIRP wishes to take a position contrary to those taken in these reviews, at a minimum, ICNIRP must cite each contrary review, discuss its main findings and only then can ICNIRP argue against the positions taken in these reviews.
6. Appendix 3 contains reviews showing that pulsed EMFs are, in most cases, much more biologically active than are non-pulsed (continuous wave) EMFs of the same average intensity (13 reviews). This is important because all wireless communication devices communicate via pulsations and because the “smarter” the device, the more it pulses because the pulsations convey the information. This raises the issue that such “smarter” devices may, in fact, be much more dangerous than are less “smart” devices, even if the “smart” devices have lower intensity radiation.
What should be obvious is that you could not study such pulsation roles if there were no biological effects produced by such EMFs. The pulsation studies alone tell us that there are many such EMF effects, despite ICNIRP’s claims to the contrary.
There is an additional complication here. There have been shown to be intensity windows of exposure, where exposures within a window produce maximum biological effects, but either lower or higher exposures produce much lower effects:
1. Belyaev, I., 2005. Non-thermal biological effects of microwaves. Microwave Rev. 11, 13-29.
2. Belyaev, I., 2015. Biophysical mechanisms for nonthermal microwave effects. In: Markov M.S. (Ed), Electromagnetic Fields in Biology and Medicine, CRC Press, New York, pp 49-67.
3. Pall, M. L. 2015 Scientific evidence contradicts findings and assumptions of Canadian Safety Panel 6: microwaves act through voltage-gated calcium channel activation to induce biological impacts at non-thermal levels, supporting a paradigm shift for microwave/lower frequency electromagnetic field action. Rev. Environ. Health 3, 99-116. doi: 10.1515/reveh-2015-0001.
Each of these issues seriously threatens the whole structure advocated by ICNIRP and must, therefore, be seriously considered by ICNIRP in order to produce a scientifically valid document. They threaten the ICNIRP claim that:
1. Effects are only seen if intensities are above some level but are not seen at lower intensities.
2. Average intensities are all that need to be considered, when in fact average intensities are often irrelevant to biological effects seen.
3. Pulsations can be ignored.
4. Dose response curves are linear or, at least, monotone.
IV. Conclusion
It is our opinion that safety can only be assessed biologically and that the whole structure that ICNIRP proposes is deeply flawed.
Signed:
Martin L. Pall, PhD, Professor Emeritus of Biochemistry and Basic Medical Sciences, Washington State University
Rainer Nyberg, EdD, Professor Emeritus. Vassa, Finland.
Co-author’s of the EU Appeal asking for a moratorium on 5G until research on health harm is done’
Dr Susan Pocket: ‘..this government department appears to be firmly and unshakably committed to the ICNIRP thermal-only dogma, exactly because that dogma allows unbridled expansion of the wireless and telecommunications industries.‘
ICNIRP’s borrowed time is up, it has been repeatedly and damningly discredited by independent scientists because its guidelines do not reflect the science and do not protect the British public from the biological damage caused by RF radiation exposure at non-thermal levels, including 5G levels. If Public Health England and the Government are to protect the public, they can no longer reference these guidelines to justify the deployment of 5G on the grounds that 5G frequencies are well within ICNIRP’s 300GHz limit of exposure.
The ICNIRP guidelines do not represent the scientific facts and they do not protect people from the ‘potential serious health effects of 5G’.
Parents and Concerned Citizens Against 5G 