Date: Tue, 2 Jul 2019 12:23:27 +0100
To: WRAGG, William <william.wragg.mp@parliament.uk>,
norman.lamb.mp@parliament.uk, Jeremy.wright.mp@parliament.uk,
matt.hancock.mp@parliament.uk, commonsleader@cabinetoffice.gov.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’
(https://www.degruyter.com/
downloadpdf/j/reveh.2016.31.issue-4/reveh-2016-0060/reveh-2016-0060.pdf):
‘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
described
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
studies’
‘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
conclusions:
On 14 Dec 2018, at 19:55, I wrote:
‘https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
attachment_data/file/333080/RCE-20_Health_Effects_RF_Electromagnetic_fields.pdf
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
studies’
‘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.
Parents and Concerned Citizens Against 5G 