Select Committee on Science and Technology Appendices to the Minutes of Evidence


APPENDIX 6

Memorandum submitted by Alasdair MacLean Philips, Director, Powerwatch

1.  INTRODUCTION

  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 December 1999.

2.  SUMMARY

  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 3]

  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 7]

Table 1

DIFFERENT STANDARDS FOR GENERAL PUBLIC EXPOSURE LEVELS

 (900 and 1,800 MHz are the two main existing UK mobile phone bands)


FrequencyE field PowerPower
General Public Reference BodiesMHz V/mW/m2 µW/cm2

NRPB, 1993900112 333,300
(Current UK Investigation Levels)1,800 19410010,000
ANSI, 1990 (USA)900 476600
IEEE C95.1-1992 (USA)1,800 66121,200
ICNIRP, 1998 (recognised by WHO)900 414.5450
CENELEC, 1995 (EU)1,800 589900
Two USA research bases (non thermal)30-100,000 201100
GOST 12.1.006—1988 (Russia)300-300,000 100.2525
Previous Russian Std (non thermal)300-3,000 (3.4)0.033
Italian law (Jan 1999) (non thermal)(30-30,000) 6(0.095)(9.5)
Suggested prudent avoidance (non-th)100-2,500 (2.7)0.022
EN 50082 EU & UK EMC Regulations equipment
  susceptibility test level
30-1,0003(0.027) (2.7)
Average US (EPA 1980)——>
City Dweller (FCC 1999)——>
approx
30-300,000
<0.00005
<0.01
<0.005
<1
"Natural" background "noise" 300-3,000<0.00001 <0.001
Typical maximum at ground near 15m base station
  masts (can be much higher)
900 & 1,80030.027 2.7
Typical, close to handset antenna900 & 1,800 100-300see note see note


  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 OBJECTIVITY OF THE ADVICE PROVIDED AT PRESENT

  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 Protection.

  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 SO ACCESSIBLE, NRPB LITERATURE

    "Biological Effects of Time Varying Electromagnetic Fields" is an internal document written by Dr Zenon Sienkiewicz for the NRPB Training Section. [1] 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 radiation—my 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 and correct.

  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 for consumers.

  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 cent.

  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 CURRENT PROCEDURES FOR OBTAINING GOOD QUALITY SCIENTIFIC ADVICE

  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 legislation.

  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 FOR ASSESSING SCIENTIFIC ADVICE IN POLICY MAKING AND REGULATION

  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 TO WHICH THERE ARE GROUNDS FOR HEALTH CONCERNS

  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 [2]. 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 [3]. 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 3.54-13.67, p<0.001).

  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 "Electrosmog—a phantom risk" [4]. 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 whole—a 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 phenomena."

    . . . "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 bear."

    . . . "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 to accept."

7.  THE OPPORTUNITIES FOR NEW TECHNOLOGIES TO REDUCE HEALTH RISKS

  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 FOR FURTHER RESEARCH

  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. [5] shows the results of testing 19 different handset models.

  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.

REFERENCES:

    (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.[7]

    (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 ISSN 1401-2928.

    (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)   "Electrosmog—a phantom risk", Christian Brauner, published by Swiss Re, 1996.

    (5)  Histogram from a talk at "Mobile Phones—is there a health risk" IBC Conference 14th October 1998 by Dr Neils Kuster, Swiss Federal Institute of Technology, Switzerland.

6 June 1999


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