Memorandum submitted by Alasdair MacLean
Philips, Director, Powerwatch
1.1 I am Director of Powerwatch, an "independent"
consumer information service founded 10 years ago which gives
information regarding the possible adverse health effects of non-ionising
radiation. We collect and evaluate world scientific literature
in the field of bio-electromagnetics and attempt to supply the
enquiring public with unbiased information about the possible
hazards (and advantages) that have been associated with our use
of electricity, radio and microwaves. We also hire out meters
for measuring fields. We do not sell any so called "protection
devices or gadgets".
We contribute to the "Electromagnetic Hazard
& Therapy" quarterly newsletter and we are currently
web-site linked next to the NRPB on the BBC Internet news pages.
1.2 I am recognised as an "independent"
UK voice on the possible adverse health effects of non-ionising
radiation and I have given Expert Evidence on Electric and Magnetic
Fields (EMF) bioeffects in Judicial Reviews, Public Inquiries,
Wayleave and Lands Tribunal Hearings and at the 1998 Coghill "Mobile
Phone Warning Labels" case. I have been involved with technical
aspects of mobile communications for over 30 years and have also
worked in agricultural science research.
I am a Consultant in the areas of Electromagnetic
Compatibility (EMC), advising on design of equipment to pass the
European and UK EMC Regulations. I am a member of the OFFER Eastern
Electricity Consumers' Committee. I have written and published
extensively on EMF and health issues. In 1996 I was Team Leader
for a Survey and Report on the possible health consequences of
the Kuwait cellular telephone system which was commissioned for
the Kuwait Government by the Kuwait Institute of Scientific Research.
I am Chairing the first day of a two-day international conference
on mobile phone safety to be held in Götenborg, Sweden, in
Powerwatch seems to be the only UK group that
knowledgeably serves the interest of consumers. Due to the NRPB's
denials that mobile phone use can cause adverse health problems,
many mobile phone users who are experiencing problems are usually
treated by their GP for a psychological problem and given tranquillisers
or anti-depressants. In many cases telling them to reduce or stop
their mobile phone use is all that is necessary. I believe, and
attempt to show, that:
2.1 . . . the current advice on these matters
provided by the UK National Radiological Protection Board (NRPB)
is inadequate and flawed and does not incorporate the Precautionary
Principle which both this and previous UK Governments have accepted
should apply in matters of health and environment. [see Section
2.2 . . . current procedures for obtaining
good quality scientific advice are flawed. [Section 4]
2.3 . . . the current system of the NRPB
providing "advice" to the DoH and the DETR includes
seconding staff to the DoH to draft official guidance and has
produced unhealthily close links with little independent "third
party" input being possible. The UK lacks an open and objective
forum for evaluation of both scientific and technical information
and also for draft official public policy based on this evaluation.
[see Section 5]
2.4 . . . there is enough good scientific
evidence now available to require health warning labels to be
affixed to all mobile phones. [see Section 6]
2.5 . . . there is clear need for further
urgent research free from industry influences which seem to be
present even where the WHO EMF project is concerned. [see Section
DIFFERENT STANDARDS FOR GENERAL PUBLIC EXPOSURE
(900 and 1,800 MHz are the two main
existing UK mobile phone bands)
|General Public Reference Bodies||MHz
|(Current UK Investigation Levels)||1,800
|ANSI, 1990 (USA)||900
|IEEE C95.1-1992 (USA)||1,800
|ICNIRP, 1998 (recognised by WHO)||900
|CENELEC, 1995 (EU)||1,800
|Two USA research bases (non thermal)||30-100,000
|GOST 12.1.0061988 (Russia)||300-300,000
|Previous Russian Std (non thermal)||300-3,000
|Italian law (Jan 1999) (non thermal)||(30-30,000)
|Suggested prudent avoidance (non-th)||100-2,500
|EN 50082 EU & UK EMC Regulations equipment
susceptibility test level
|Average US (EPA 1980)>|
City Dweller (FCC 1999)>
|"Natural" background "noise"
|Typical maximum at ground near 15m base station|
masts (can be much higher)
|900 & 1,800||3||0.027
|Typical, close to handset antenna||900 & 1,800
Note: "Near-field" levels next to a working
mobile phone handset vary enormously depending on the antenna
design and other parameters but will almost always exceed the
electric field and power density levels set in the general exposure
standards. Instead of using these standards, attempts are to mathematically
model, and also to measure using a "phantom" model head,
the likely Specific Absorption Rates (SAR) and these are compared
with the basic restrictions in the various standards.
Average SARs from phones are always below the NRPB maximum
head SAR 10 W/kg in any 10g sample of tissue; typically 0.3 to
1.5 W/kg, but ranging up to about 6 W/kg in the worst case. The
US Standard of 1.6 W/kg in any 1g sample of tissue is amost certaintly
exceeded by some mobile phone handsets when operating at full
power and held in some positions.
It is not clear that the SAR is the only metric that needs
to be specified. It is possible that the high localised electric
field levels could be causing the reported headaches, earaches
and skin problems. Some phones with low SAR levels have a high
number of users reporting headaches, etc.
I gather that the EU Health Ministers have just formally
adopted the ICNIRP standard listed above. The NRPB have always
advised against the need to adopt these lower levels that are
still based on thermal (tissue heating) considerations.
Italy is the only country with non-thermal regulations: Decree
No 381 of 10 September 1998, "Regulation laying down standards
for the determination of radio frequency ceilings compatible with
human health", entered into force on 2 January 1999, and
provides for an exposure limit of 6 V/m for broadcast and cellular
phone transmitters in respect of buildings in which people live
or work for more than four hours per day.
3. QUALITY AND
3.1 The NRPB is responsible for providing "Advice"
on any health implications of electromagnetic fields. Their current
position is that there are no serious health effects from microwave
levels which are too low to cause tissue heating. Paragraphs 3.5
and 3.6, below, show that this is only a part of a complex story
and there are inconsistencies between some NRPB documents and
their official "Advice".
3.2 The NRPB Guidance for the general public allows for
higher human exposure levels to microwaves than any other regulatory
body in the world, even though some of these Standards are also
based on thermal considerations (see Table 1). It is interesting
to note that while many other bodies have been lowering their
public human exposure guidance the current (1993) NRPB Guidance
had the effect of significantly increasing the permissible exposure
levels compared with their 1988 (GS11) Guidance. This took place
around the same time as mobile phones were being introduced.
3.3 Dr John Stather, the NRPB Senior Assistant Director,
confirmed their view on BBC2 TV "Money Programme" on
Sunday 18 April 1999 with "if it doesn't heat you, then
it doesn't harm you". He was followed by Dr David de
Pomerai talking about his recent work at Nottingham University
where his team had found high levels of heat shock proteins being
produced in nematode worms by cellular-phone-levels of microwave
exposure. The levels of heat shock proteins, a sign of cell stress,
were equivalent to those produced by a three or four degree Celsius
rise in temperature even though no rise in temperature from microwaves
was measurable. I consider these results to be extremely important
as they seem to demonstrate an easy-to-test and very important
non-thermal effect. The team is currently repeating the experiments
using a different frequency and other institutions should attempt
to replicate the work as soon as possible.
3.4 There is an apparent "promotion from within"
policy that seems to have operated many times at the NRPB. I believe
that this has led, and is still leading, to reductionist and extremely
conservative thinking. Many large companies now recognise that
bringing "fresh minds" into their organisation at senior
levels is important to keep at the leading edge of their field.
3.4.1 The current head of the Non-Ionising Department
at the NRPB on leaving school worked for the Scottish Department
of Health who sponsored his degree studies. He joined the NRPB
not long after it was formed in 1970 and obtained his PhD in experimental
radiation dosimetry at Paisley College of Technology. He has now
worked for the NRPB for well over a quarter of a century. He has
published nothing in the peer-reviewed literature on the biological
effects of microwave or radiofrequency radiation. Under oath in
the Coghill "Mobile Phones Warning Label" Court case
in Wales in November 1998, he repeatedly stated that he only understood
dosimetry (the science of measuring signals) and had no understanding
of the biological or medical implications of the interaction of
electric and magnetic fields with living tissues. He stated that
he relied completely on his colleagues for their advice in those
areas and refused to venture his own opinion when pressed by the
Chairman of the Bench to do so. Yet Dr McKinlay currently represents
the NRPB and, effectively, the United Kingdom, on most of the
European and International Committees on Non-Ionising Radiation
3.5 In 1996 the European Commission set up an Expert
Group mandated to draw up a blueprint for research into possible
health effects relating to the use of mobile telephony. Dr McKinlay
(NRPB) Chaired this group which reported to the EC at the end
of September 1996. Their report called for funding of further
research. On page three of the Report, under the heading "Health
concerns", we find:
"Public concern about the health hazards of electromagnetic
fields from radio-telephones has increased. Specifically, there
is concern that, as the handsets deployed in the new generation
of personal telecommunications systems are brought close to the
head, there may be either a thermal insult produced by power deposition
in tissue (acute effect) or other (long-term) effects."
. . ."A large body of literature exists on the biological
effects of radiofrequency and microwave radiation . . . Overall
. . . while providing useful information, [it] provides no convincing
evidence that the use of radiotelephones, whether analogue or
digital, poses a long-term public health hazard . . .
. . . Microwave radiation absorption occurs at the molecular,
cellular, tissue and whole-body levels"
. . . "A substantial body of data exists describing biological
responses to amplitude-modulated radiofrequency (including microwave)
fields at SARs too low to involve any response to heating. It
has been suggested that non-equilibrium processes are significant
in the bioenergetics of living systems, challenging the traditional
approach of equilibrium thermodynamics. . . ."
3.6 OTHER, NOT
"Biological Effects of Time Varying Electromagnetic Fields"
is an internal document written by Dr Zenon Sienkiewicz for the
NRPB Training Section.  This includes (on page 5):
"There are in addition a large number of biological effects
that have been reported in cell cultures and in animals, often
in reponse to relatively low field levels, which are not well
established but which may have health implications and are the
subject of much ongoing research."
"These include research on the effects of ELF fields
on the body's daily (circadian) rhythms and on growth and development
of the embryo and foetus, on the effects of ELF fields and RF
radiation on carcinogenic processes, on the existence of specific
frequency and amplitude `window' effects, and on effects of low
level pulsed RF radiation."
[eg GSM digital mobile phone radiationmy comment and underlining]
. . . "The possibility that only certain combinations
(windows) of EMF frequency and amplitude could elicit biological
effects has been reported in studies in which exposure to very
low levels of amplitude modulated RF radiation, too low to involve
heating, altered the brain activity in cats and rabbits, the activity
of an enzyme involved in tumour promotion, and to affect calcium
ion mobility in brain tissue in vitro and in vivo." . . .
. . . "Recent well-conducted studies by one group of
research workers suggest that the retina, iris and corneal endothelium
of primate eyes are susceptible to low-level microwave irradiation,
particularly to pulsed radiation. Various degenerative changes,
particularly of the light-sensitive cells in the retina, have
been reported." . . .
. . . "Exposure to low levels of pulsed or continuous
wave RF or microwave radiation have been reported to affect neurotransmitter
metabolism and the concentration of receptors involved in stress
and anxiety responses in different parts of the rat brain."
3.7 On the evidence acknowledged by the NRPB alone, summarised
in 3.5 and 3.6 above, I hold the view that the responsible action
would be to apply the precautionary principle and at least affix
warning labels to mobile phones.
3.8 Neither the NRPB nor its Advisory Group on Non-Ionising
Radiation (AGNIR) have published critiques of most of the scientific
literature on this issue which has been published since the original
Doll Report (NRPB Vol 3 No 1, 1992). They issued a brief and incomplete
update statement (dated 12th April 1994) in the back of NRPB Docs
Vol. 5 No. 2. 1994. Since then, all the NRPB has issued are occasional
press statements about specific selected pieces of published research.
Even though they are promising a new report by AGNIR by the end
1999, given the large number of relevant scientific reports which
have been published in the last five years, the lack of published
assessments is an anomaly for a publicly accountable body.
3.9 In the Doll Report they made little attempt to sort
the "good" studies from those with admitted "flaws"
which diluted the significance of any real effects. The NRPB also
chooses not to include some peer-reviewed published studies in
its literature reviews. I do not believe that ignoring studies
without setting out credible scientific justification is appropriate.
In the late 1950s and early 1960s Sir Richard made the mistake
of both publicly ignoring and trying to block publication of Dr
Alice Stewart's work on the dangers of x-raying pregnant women.
Now it is accepted that her study conclusions were both important
3.10 I have repeatedly requested that the NRPB examines
a number of ill mobile phone users who have contacted me claiming
adverse health problems. It seems to me that their examination
and testing might shed some light on what is happening. However,
the NRPB refuses to examine such people "in case they try
to claim compensation as the NRPB is not prepared to be a witness
in any litigation". They also refuse to arrange and pay for
such testing to be done by a third party expert. It is not clear
what Government body has the remit to help resolve these issues
3.11 Professor Roger Clarke, in his verbal evidence to
this committee on 9 June 1999, is reported as saying "I think
that sometimes, if I understand the physics of the mobile telephone
correctly, if you shield it and reduce its ability to connect
with base stations, it is liable to make up its own mind to increase
its power level and end up with the same exposure as before".
It appears that the NRPB has not really got a good understanding
of what occurs in practice. Roger Clarke's statement is almost
the same as many industry statements dismissing these "screening
cases" and it seems that he is speaking from theoretical
considerations and "industry say-so" and that the NRPB
has not obtained and carried out detailed tests on such a case
before passing comment.
His remark is mostly relevant to a product called "Microshield"
which works by sliding a spring metal strip up the side of the
antenna and this does, indeed, make the phone increase its power.
A standard GSM handset can control its peak output power in 12
steps from 2 Watts down to 8 mW.
However, the Microshield case has been tested by many independent
laboratories including ones in the UK, Russia and Australia and
has been found to significantly reduce the Specific Absorbed Radiation
(SAR) level in a phantom human head. The latest two laboratories
in the UK that have tested it are BT Mobile (an industry lab)
and the National Physical Laboratory (in two separate sets of
tests paid for by the BBC and by the Sunday Mirror). The NRPB
approved the protocol of the NPL tests paid for by the BBC and
were sent the results in February 1999. The NPL found that while
the Microshield case reduced the radiation by up to 90 per cent
when the phone was already operating at full power, even in the
"worst case" when the phone increased its power from
originally operating at a low level it still reduced the final
SAR in the meningeal layer of the phantom head by about 25 per
3.12 The NRPB has not been prepared to enter into any
meaningful dialogue with me regarding any scientific matters where
we hold differing views. If I am to be on site as an observer
they now even refuse to take ambient microwave level measurements
that clients are paying for. Last Autumn there was a scientific
meeting of the WHO EMF Project on future EMF Metrics which was
held at the NRPB. About 45 people, including industry representatives
and a number of researchers who had not got any EMF related research
experience were invited. I repeatedly asked Drs McKinlay and Stather
if I could attend and they refused. I then contacted Dr Mike Repacholi,
Head of the WHO project, and received the following reply: "There
will be further meetings without the restrictions placed on the
NRPB meeting that will allow you to provide your input. I have
asked my secretary to place you on our mailing list for future
meetings. Yours sincerely, Mike Repacholi."
3.13 Directly after the Coghill warning label court case
last November I asked Dr Mike Clark, the usual NRPB public spokesman,
why they did not produce a couple of sides of A4 describing the
reported mobile phone health problems in a very factual and questioning
way. He answered me: "We are instructed not to admit to any
adverse effects." Who is giving this instruction?
3.14 The Parliamentary Office of Science and Technology
POST note 109, "Health Risks and Mobile Phones", dated
January 1998 is more informative than many NRPB public documents.
4. ASSESSMENT OF
4.1 I am aware of the work of the NRPB organisation and
COMARE. In the UK the NRPB has the responsibility for advising
Government on the possible adverse health effects of both ionising
and non-ionising radiation. Using this advice, the Health and
Safety Executive (HSE) is responsible, with the Secretary of State
for Health and the Government, for proposing and enacting safety
4.2 I believe that these orgnisations should be instructed
to include the precautionary principle in coming to a decision
on what to include in their "Advice".
4.3 I question the cost-effectiveness of the public funding
of the NRPB's current organisational structure. Currently they
are doing virtually no practical EMF bio-exposure work at all.
This would not necessarily matter if they were actively involved
in practical ways with good research at European Universities,
but they are not. I suggest consideration is given to creating
a number of (funded) senior leading scientific research positions
to which leading scientists in the field from around the world
could be seconded for specific projects lasting from one to three
years. I believe this would lead to much more up to date thinking
and stimulate the practice of good science.
4.4 Both the main NRPB Board and their Advisory Groups
should be required to have members specifically with Consumer
and Trade Union Health and Safety backgrounds.
5. THE PROCESSES
5.1 At present the NRPB filters scientific research and
does not publicly acknowledge the potential implications of research
which show effects other than thermal ones. This refusal to incorporate
the precautionary principle in its advice means that the Department
of Health and the Health and Safety Executive are not in possession
of the full picture. This then means that they have insufficient
information to know how to, and when it would be appropriate to,
apply the precautionary principle.
5.2 A recent DETR/DH draft Joint Circular 99: Land Use
Planning and Electromagnetic Fields was circulated to councils
for comment in December 1998. This document was primarily drafted
at the Department of Health by NRPB's Philip Chadwick who had
been seconded to them part time for the previous couple of years.
His authorship is not acknowledged and Circular 99 in no way represents
a precautionary stance.
5.3 It was circulated by the DETR who also enclosed "a
copy of a briefing document on EMFs prepared by the World Health
Organisation (WHO). They have kindly agreed to our sending this
advance copy to assist consultees in their consideration of the
draft circular." The WHO draft document was prepared by Philip
Chadwick and Zenon Sienkiewicz and this was stated on it. What
was not stated, however, was that they are both members of staff
of the UK NRPB and the draft had had little consideration by other
countries who are members of WHO. It does not take a precautionary
stance and basically sets out the standard NRPB viewpoint.
5.4 I, among many others, prepared responses to both
documents, neither of which incorporated the precautionary principle.
On two occasions I have asked how the formal consideration of
the various submitted comments would be done and if there would
be a reply to points raised. The only reply I had from the DETR
was: We are currently considering the responses received. You
may be interersted to note that all responses to the draft circular
(other than those made on a confidential basis) have been placed
in the DETR library". That was not an answer to my question
asking how the points in the responses would be considered.
5.5 Talking to Local Government Association officers,
I now gather that comments are often apparently ignored and it
is usually left to the original authors to read the responses
and to chose whether, or not, to incorporate any of them into
the final document. This does not leave an adequate audit trail
of the decision making process and seems to make a nonsense of
the consultation process.
5.6 There needs to be a new forum for assessing controversial
science, including that regarding mobile phones and health. The
Court of Law are not appropriate and the NRPB system is effectively
closed to outside dissenting voices. The NRPB do not need to publicly
debate the reasons for holding their view. The DH and DETR systems
do not seem to incorporate adequate safeguards for checking that
concerns raised in the responses to draft consultation documents
are adequately addressed.
6. THE EXTENT
6.1 I could easily write a long memorandum on this subject
alone but I will restrict myself here to a few more points, leaving
detailed considerations for the new "expert group" which
is now being set up.
6.2 I have now talked to several thousand members of
the general public who believe that mobile phone use has caused
them adverse health problems ranging from merely irritating to
extremely serious. They report headaches, loss of concentration,
skin tingling or burning, twitching, eye tics, very poor short-term
memory, buzzing in their head at night, and other less common
effects. Headaches often come first and/or skin effects. Then
concentration and short-term memory tends to deteriorate. Initially
it can be missing an intended turning off a motorway or forgetting
appointments. At first, learning or remembering NEW facts, similar
to early signs of dementia, are experienced. Users also report
headaches and excessive tiredness. Many reports are from engineers
who use their phones extensively and were very sceptical of EMF
adverse health effects until they started to experience them.
6.3 These reports are similar to those reported by Mild
et al, National Institute for Working Life, Sweden .
They analysed responses from around 12,000 mobile phone users
in Sweden and Norway. Although not a main design hypothesis of
their study, their Summary includes finding: "a statistically
significant association between calling time/number of calls per
day and the prevalence of warmth behind/around or on the ear,
headaches and fatigue". Their reference categories were mobile
phone users who used their phone less than two minutes or two
calls per day and they found dose/response relationships with
concentration, memory loss, fatigue and headache. Statistically
significant Odds Ratios rise to 4.74 (2.19-10.3) for fatigue and
7.00 (2.68-18.3) for headaches (95 per cent confidence limits)
for people who used the phones for over one hour per day total.
Memory loss and fatigue ORs were generally between two and three
for this group of users.
Overall, my assessment of their data is that about one in
10 of users are likely to experience significant subjective effects
with extended use and maybe around another 15 per cent some apparent
adverse effects. Maybe around 75 per cent of the population can
use a mobile phone fairly extensively without experiencing these
effects to any significant degree. There are currently around
15 million UK mobile phone users. If about a third of these use
their phones regularly then the health and performance of between
0.5 and one million people may adversely be affected by their
mobile phone use.
6.4 Looking at a more serious outcome, namely cancer,
there are a number of studies which indicate we should be adopting
a very precautionary approach in these matters. I will mention
only a couple. Back in the early 1980s Sam Milham, in the USA,
reported excess leukaemias among amateur radio operators, with
deaths from acute and chronic myeloid leukaemias nearly three
times higher than expected. Then in the mid-1980s Stanlislaw Szmigielski
reported that Polish military personnel exposed to RF energy showed
elevated leukaemia levels. He published a 1996 update . This
is a study of all Polish military personnel for 15 years (1971-85),
approximately 128,000 people each year. Of these about 3,700 (3
per cent) were considered to be occupationally exposed to microwave
radiation. The largest increases were found for chronic myelocytic
leukaemia (CML), with an astounding Odds Ratio increase of 13.9
(95 per cent CI 6.72-22.12, p<0.001), acute myeloblastic leukaemia
(AML) with an OR of 8.62 (95 per cent CI 3.54-13.67, p<0.001),
and non-Hodgkin's lymphomas with an OR of 5.82 (95 per cent CI
NHL is one of the cancers whose incidence in the UK is currently
increasing for no known reason.
The highly exposed category that produced the above ORs were
estimated to have time averaged exposures in the range 2 to 6
µW/cm2 with a workday mean around 10 µW/cm2.
The reasons that these exposure levels were so low is that, at
the time, the Polish unrestricted exposure standard was set at
10 µW/cm2 with a work-shift maximum of 200 µW/cm2
apart from time limited "hazardous" exposure for authorised
personnel of 4,400 µW/cm2 for one minute and 10,000
µW/cm2 for only 20 seconds.
It is interesting to note that the current NRPB "Advice"
allows unlimited public exposure to levels up to 10,000 µW/cm2
at frequencies above 1,550 MHz.
6.5 Swiss Re is one of the largest re-insurance companies
in the world. Part of their survival strategy is to look into
the future to predict potential large liabilities and they have
determined that EMF litigation is one such area. They published
a report on the subject in late 1996, called "Electrosmoga
phantom risk" . In my opinion it is a landmark publication
and contains much debate that is missing from official UK documents
on the possible risks of EMFs. I extract a few key paragraphs,
some slightly paraphrased for brevity.
"Generally it is expected that the question as to whether
electromagnetic fields and radiation pose a health risk will be
answered sooner or later with a clear Yes or No, which would then
more or less automatically clarify the question of legal liability.
This expectation is erroneous because it is based on a mistaken
assumption: namely, that the relationships between EMF exposure
and diseases such as cancer, immune deficiency, Alzheimer's Disease
and Parkinson's Disease are merely complicated. In fact, however,
we are dealing with complex relationships which cannot even be
identified, let alone understood, using the research methods presently
available. . . . . . . The only reliable answer to "do EMFs
impair health?" is "Perhaps".
"With only inconclusive findings to go on we find ourselves
facing the task of trying to achieve a just balance between the
individual's need for protection and the interests of society
as a wholea technology that benefits many but may possibly
seriously harm some few." . . .
". . . a relationship that is especially important for
gaining a correct understanding of the EMF issue is that living
organisms can amplify the energy of signals. The actual cause
of the biological response is this amplification process, not
the signal itself which "merely" triggers it. It is
therefore necessary to distinguish between energy effects and
signal effects and two different dangers posed by electromagnetic
. . . "Up until the beginning of this century, science
was able to study only questions which could be answered with
Yes or No. In the course of this century, it has become ever more
apparent that practically all causal laws are, in reality, mere
statistical observations. . . . At first glance, there is only
a minor quantitative distinction between `certain' and `highly
probable'. In fact, however, the difference is fundamental and
qualitative because it is the difference between `must' and `can',
between `yes/no' and `perhaps', between `doubtful' and `doubtless',
between `certain' and `uncertain', between `possible' and `impossible'.
It is the difference between `knowledge' and `conjecture'. And
because all scientific knowledge is based on statistical observations,
the knowledge of science is mere presumptive knowledge. . . .
This change of paradigm, which was initiated early in this century
through the insights of nuclear physics and is now starting to
take concrete form in new scientific disciplines such as complexity
research, has been accompanied by a fundamental change in the
concept of causality." "While classical science is
considered a cause to be only that which must necessarily bring
about an effect as a result of the causal principle, today a cause
is also considered to be that which may bring about an effect.
The possibility that electromagnetic exposure might favour the
incidence of certain diseases cannot be excluded. According to
our present understanding, electromagnetic fields would then be
a cause of disease just like a flu virus which may, but need not
necessarily, result in influenza."
"The socio-political risk must be classed as extraordinarily
high because the legal instrument of liability is increasingly
being used, or even misused, as a means of coping with the problems
of life. But who decides what is right and what is wrong, what
is detrimental and what is beneficial, what is to be permitted
and what is to be prohibited? Natural science denies responsibility,
and politics proves to be unequal to the task of bringing about
a social consensus on what risks people are willing to enter into
conjointly, and what share of these risks each individual must
. . . "The EMF problem cannot be resolved through further
research alone: on the contrary, there is a need for new, practice-oriented
categories for assessing the research results currently available.
. . . The EMF problem cannot be delegated to individual groups
or institutions: that would be like leaving the formulation of
a contract to just one of the parties. . . . It is not acceptable
to force risks upon individual human beings; neither is it in
the interest of the general public to dispense with technological
opportunity that might benefit the many because of the possibility
that some individuals might suffer harm. What is required is a
consensus on how much risk individuals may reasonably be expected
7. THE OPPORTUNITIES
7.1 All the major manufacturers have been patenting new
designs which reduce the amount of radiation absorbed by the user's
head. Various methods are being used.
7.2 The 2nd generation digital systems chosen by Europe
(GSM/PCN/DCS) use a Time Domain Multiplexed Access (TDMA) approach
which results in bursts of microwave radiation from the handset
with relatively long gaps (one slot in eight is transmitted at
a basic repetition rate of 217 Hz). Pulsed microwaves have been
shown to be more biologically active than continuous radiation
of the same frequency and power level. Up to 80 per cent of the
transmitted power can be absorbed by the user's head, which means
that their brain cells are being "hit" by these radiation
pulses 217 times every second. The NRPB, and others, average the
power from a digital phone over one second, and so divide the
pulse power by eight. They correctly argue that the tissue has
time to cool down between pulses, but then go on to deduce that
no damage will therefore take place. This is similar to saying
that placing a hammer on a "cell" (an egg, for example)
exerting a small steady force, will produce the same effect as
hitting the egg, using eight times the force briefly once a second.
As most practical engineers know, when trying to loosen a stuck
nut and bolt, the effect of constant pressure on the spanner
is far less than when tapping the spanner with a hammer.
In addition, GSM digital phones and the new DECT cordless
phones also put high levels of low frequency magnetic fields,
due to the battery current surges, into the user's head (from
about 0.5 to 5 microtesla [µT]. Concerns about ELF magnetic
fields and childhood leukaemia start at levels from less than
0.5 µT, and the effect on cellular growth control enzyme
ornithine decarboxylase [ODC] has been shown to double in activity
by about 1.2 µT. These low frequency magnetic fields may
be more responsible for the dementia (memory) effects than the
pulsed microwaves. The NRPB has not investigated, or commented
on, this aspect of mobile phone fields.
7.3 The newer American Code Domain Multiple Access (CDMA)
system works differently and does not emit the sharp-edged low
frequency magnetic pulses nor the short bursts of microwaves.
The digital RF signal resembles a noisy analogue signal and is
also likely to be less bio-active. The third generation European
UTMS system incorporates CDMA and should expose the users to lower
and less biologically active fields provided that it really does
not use the TDMA bursts from handsets.
8. THE NEED
8.1 There is a clearly identified agreed need for further
research, that the WHO EMF Project is attempting to address.
8.2 There is clear evidence that the Mobile Manufacturers
Forum (MMF) is trying to control where research funding is allocated
and for which projects. Led by Motorola, in Summer 1998 they set
up a "Research Planning Committee" in order to influence
the selection which laboratories would be allowed funding for
collaborative mobile-phone health related research. This seems
an unacceptable and restrictive practice. I believe Dr Preece
will address this in his Memorandum.
8.3 There are a number of types of electromagnetic field
emitted by a mobile phone handset and all these have a number
frequency components. These make the issue complicated to research.
The phones emit microwaves, which in the case of European digital
phones are emitted as short bursts lasting about 0.5 milliseconds
(ms) every 4.6 ms, ie 217 times every second. Thus the peak power
into the user's head is eight times the average power. The average
power is what causes the heating and is measured as an SAR (see
3.11) in watts per kg of body tissue. The NRPB and CENELEC average
the temperature rise over 10g of tissue whereas the ANSI/IEEE
standard uses a more critical 1g which means that the ANSI SAR
induced in head tissue by given 1,800 MHz microwave signal is
about twice the value of the NRPB SAR in a 10g sample. To complicate
matters further, phone handsets transmitting at nominally the
same power induce SARs in head tissue over approximately a 6:1
ratio; the most efficient only "wasting" about 13 per
cent of their energy into the user's head while for the least
efficient about 80 per cent of their total transmitted energy
is absorbed by the head.  shows the results of testing 19 different
The head is in what is called the "near-field"
of the phone where there is a variable relationship between the
electric and magnetic components of the microwaves. The electric
component can be over 300 volts/metre and impinges on the skin,
triggering skin and nerve reactions. The magnetic component passes
through the skull and induces currents to flow and SAR heating
in the meninges and brain tissue. Phones with stubby (non-extending)
antennas generally produce higher magnetic near-fields and phones
with an extended antenna higher electric near-fields.
The UK digital phones also produce real low frequency magnetic
fields (see 7.2 above). Both the microwave and low frequency pulses
have the 217 Hz (plus harmonics), and also 32, eight and two Hz
components mainly due to discontinuous transmission (DTX). It
is possible that these lower frequency signals might interfere
with normal brain function activity.
The GSM system continuously adjusts the transmit power of
the handset over a ratio of up to 250:1 in order to use the minimum
necessary to maintain the call. This means that two users making
identical calls from identical handsets can experience a 250-fold
difference in power level due to their physical location. This
will make epidemiological studies extremely hard to analyse.
The two main American digital systems are sufficiently different
technically to be likely to have quite different biological interactions
from the GSM system. The forthcoming Iridium satellite phones
use TDMA, like the GSM system, but pulse at around 11 Hz and so
may have further differences. It is easy, with this plethora of
different transmission techniques and frequencies, to miss discovering
important associations that are taking place for only some systems.
It will certainly reduce the usefulness of any meta-analyses.
(1) "Biological Effects of Time Varying Electromagnetic
Fields" Z J Sienkiewicz, . . .NRPB.
This was handed out at an NRPB Awareness Course on EMFs and
Human Health on 26 November 1997 I enclose a photocopy
(10 pages) as I do not believe the document is generally available.
(2) "Comparison of symptoms experienced by users
of analogue and digital mobile phones" (70 pages) Mild,
et al, National Institute of Working Life, Sweden. Arbetslivsrapport
(3) "Cancer morbidity in subjects occupationally
exposed to microwave electromagnetic radiation" S Szmigielski,
The Science of the Total Environment 180, 1996, pp 9-17, Elsevier.
(4) "Electrosmoga phantom risk",
Christian Brauner, published by Swiss Re, 1996.
(5) Histogram from a talk at "Mobile Phonesis
there a health risk" IBC Conference 14th October 1998
by Dr Neils Kuster, Swiss Federal Institute of Technology, Switzerland.
6 June 1999
Annex 1. Back