But You Cannot Fool

Date: Tue, 2 Jul 2019 12:23:27 +0100
To: WRAGG, William <william.wragg.mp@parliament.uk>,

Dear William,

2012 AGNIR Report

‘You can fool all the people some of the time and some of the people all 
the time, but you cannot fool all the people all the time.’

Prof. Dariusz Leszczynski: ‘One thing seems to be clear, unlike the 
claims on HPA
website, the UK HPA AGNIR Report 2012 is not a comprehensive review but 
it is a biased review’.

 From Dr Sarah Starkey’s ‘Inaccurate official assessment of radiofrequency
safety by the Advisory Group on Non-ionising Radiation’ 

‘Abstract: The Advisory Group on Non-ionising Radiation (AGNIR) 2012 
report forms the basis of official advice on the safety of 
radiofrequency (RF) electromagnetic fields in the United Kingdom and has 
been relied upon by health protection agencies around the world. This 
review describes incorrect and misleading statements from within the 
report, omissions and conflict of interest, which make it unsuitable for 
health risk assessment. The executive summary and overall conclusions 
did not accurately reflect the scientific evidence available.’

‘The executive summary of the AGNIR report included “Taken together, 
these studies
provide no evidence of health effects of RF field exposures below 
internationally accepted guideline levels” and “the evidence considered 
overall has not demonstrated any adverse health effects of RF field 
exposures below internationally accepted guideline levels” …These 
conclusions did not accurately reflect the evidence, as described in 
examples below. a) Studies were omitted, included in other sections but 
without any conclusions, or conclusions left out; (b) evidence was 
dismissed and ignored in conclusions; (c) there were incorrect 
statements. Terms such as ‘convincing’ or ‘consistent were used to imply 
that there was no evidence. Some examples fall into more than one category.’

‘Only 7 studies were included in the section on reactive oxygen species. 
These were summarised by “production of reactive oxygen species (ROS) 
were increased in some studies, but not others”. … At least 40 studies 
were omitted. If these had been included, 79% of studies (61 out of 77) 
would have demonstrated evidence of significantly increased ROS or 
oxidative stress in response to RF field. By only
including a few of the available studies, not referring to many 
scattered throughout the report and not mentioning ROS or oxidative 
stress in any conclusions or the executive summary, this important area 
of research was misrepresented. Oxidative stress is a toxic state which 
can lead to cellular DNA, RNA, protein or lipid damage, is accepted as a 
major cause of cancer, as well as being implicated in many reproductive, 
central nervous system, cardiovascular, immune and metabolic disorders.’

‘The conclusion for male fertility studies in animals was “A substantial 
number of studies have investigated the effects of RF fields on 
testicular function, principally in rats, and most report large, obvious 
effects. However, these results are largely uninterpretable due to 
inadequate dosimetry or other shortcomings in the studies, and thus are 
unsuitable for the purposes of health risk assessment. One 
well-conducted study reported no effects on testicular function in rats 
exposed to 848 MHz CDMA signals”. For male fertility in humans (in 
vivo), it was concluded, “The evidence on the effect of RF fields on 
sperm quality is still weak and the addition of the two new studies does 
not allow reliable evaluation of the presence or absence of a health 
effect. Some suggestive positive results, although not convincing, give 
justification for further studies with improved methods. The evidence on 
effects on male subfertility is very limited, and allows no 
conclusions”. At least 22 studies on male fertility were omitted. … If 
the 22 references identified as omitted had also been included, this 
would have been 35 out of 45, 78%.’

‘Inaccurately, in the overall and executive summaries, the evidence for 
adverse effects on male fertility disappeared: “Despite many studies 
investigating effects on male fertility, there is no convincing evidence 
that low level exposure results in any adverse outcomes on testicular 
function” and for humans, in vivo, “The limited available data on other 
noncancer outcomes show no effects of RF field exposure”.’

‘For direct effects on proteins, 15 out of 16 studies listed found 
significant effects of RF fields. The conclusion was “In general, most 
of the studies that have investigated changes in protein function or 
structure due to exposure to RF fields have found effects. However, at 
the present time the effects have not been demonstrated to be robust by 
independent replication; so although the concept of a direct effect of 
RF field exposure on protein structure is interesting, further research 
is needed to establish if this is a real phenomenon.” Ninety-four 
percent of the studies listed on direct effects on proteins, from 14 
different groups, found significant effects, but the conclusion was 
turned around to imply that these may not be real.’

‘Out of 33 studies on direct effects on proteins or cell membranes, 32 
significant effects of RF signals below high power heating, but these 
disappeared in the conclusions. By the end of the report, the conclusion 
on cellular studies had incorrectly become “There are now several 
hundred studies in the published literature that have looked for effects 
on isolated cells or their components when exposed to RF fields. None 
has provided robust evidence for an effect”

‘A summary for human brain EEG recordings stated, “the EEG studies 
published since 2003 do provide some evidence that RF fields could 
influence brain function, and this should remain an area of interest”. 
Many EEG studies (awake or asleep subjects) reported changes in 
electrical field potential oscillations, evoked responses or 
interhemispheric coupling, but these were dismissed…

‘For risks of brain tumours or acoustic neuromas in humans, “the similar 
results of all investigators except the Hardell group, with no 
methodological inferiorities in these other investigators’ studies 
overall, suggest that the results of the Hardell group are the 
problematic ones”. However, some significantly increased risks of brain 
tumours or acoustic neuromas were described in Hardell and non-Hardell 

‘The executive summary stated for cells in vitro: “In particular, there 
has been no
convincing evidence that RF fields cause genetic damage or increase the 
likelihood of cells becoming malignant” and in the chapter on cellular 
studies: “Results from studies using other cell types are also 
contradictory. Epithelial cells exposed to …”. However, all in vitro 
studies included on epithelial cells [four, one retracted], from more 
than one laboratory, found damage to DNA or chromosomal aberrations in 
response to RF signals. Forty six percent of genotoxicity studies 
identified as included in the report (36 out of 78) described evidence 
for genotoxicity in response to RF fields, but at least 40 genotoxicity 
studies were omitted. … AGNIR found the genotoxicity evidence 
unconvincing, but a more accurate conclusion could have been that RF 
signals appear to be genotoxic under certain circumstances, but not others.’

‘The executive summary included “There has been no consistent evidence 
of effects on the brain, nervous system or the blood-brain barrier, on 
auditory function, or on fertility and reproduction”. The term 
‘consistent’ dismissed areas for which the majority of studies had found 
adverse effects’

‘The denial of the existence of adverse effects of RF fields below 
ICNIRP guidelines in the AGNIR report conclusions is not supported by 
the scientific evidence. Studies have, as described as examples in this 
review, reported damage to male reproductive health, proteins and 
cellular membranes, increased oxidative stress, cell death and 
genotoxicity, altered electrical brain activity and cognition, increased 
behavioural problems in children and risks of some cancers.’

‘PHE and AGNIR had a responsibility to provide accurate information 
about the safety of RF fields. Unfortunately, the report suffered from 
an incorrect and misleading executive summary and overall conclusions, 
Inaccurate official assessment of radiofrequency safety by AGNIR 
inaccurate statements, omissions and conflict of interest. Public health 
and the well-being of other species in the natural world cannot be 
protected when evidence of harm, no matter how inconvenient, is covered up.’

Because I think it sums the situation up perfectly, I’ll include a 
correspondence with my friend, a trained medical researcher, about the 
glaring discrepancies between cited research in the report and AGNIR’s 

On 14 Dec 2018, at 19:55, I wrote:

102 – 114 plus following conclusions.

‘My friend’s reply: ‘I have now read through this and feel that they are 
finding ways to dismiss the alarming number of positive (ie negative) 
effects. Their conclusion should be “An alarming number of different 
studies show biological effects that could be adverse on a wide number 
of different cells and proteins, at a wide variety of different 
frequencies and the longest any of them have been done for is 6 days.“ 
When what they do say is “But hey, they are all different studies so 
they are “inconsistent”, none have been exactly replicated so we can 
ignore them and ICNIRP say it is fine so we’ll be off the hook when it 
all goes pear shaped, or whatever shape humans might become.”

In spite of the misrepresentations stated above, something which is 
clearly evident is that the AGNIR report doesn’t even approach the 
”All-clear” PHE is claiming because it still provides enough indication 
of risk to justify urgent implementation of the precautionary principle. 
For instance:

‘… production of reactive oxygen species (ROS) were increased in some 

‘A substantial number of studies have investigated the effects of RF 
fields on testicular function, principally in rats, and most report 
large, obvious effects. … Some suggestive positive results, although not 
convincing, give justification for further studies with improved methods.’

‘… so although the concept of a direct effect of RF field exposure on 
protein structure is interesting, further research is needed to 
establish if this is a real phenomenon.’

“Results from studies using other cell types are also contradictory.” 
(but still evident)
“the EEG studies published since 2003 do provide some evidence that RF 
fields could influence brain function, and this should remain an area of 
interest” … should remain an area of interest?

My next email will be about the 2015 SCENIHR report. Please will you 
forward this to your Westminster researcher. Thank you. I’ll be 
forwarding it to the Science and Technology/ Health and Social Care 
Committee members.


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