APPENDIX 8
Memorandum from the Engineering and Physical
Sciences Research Council (EPSRC)
1. This memorandum provides evidence from
the Engineering and Physical Sciences Research Council (EPSRC)
in response to the above inquiry, in relation to the case study
"The use of MRI equipment: the EU Physical Agents (Electromagnetic
Fields) Directive".
INTRODUCTION
2. EPSRC is the main UK government agency
for funding research and training in engineering and the physical
sciences, investing around £500 million a year in a broad
range of subjects—from mathematics to materials science,
and from information technology to structural engineering.
3. The Council operates to meet the needs
of industry and society by working in partnership with universities
to invest in people and scientific discovery and innovation. The
knowledge and expertise gained maintains a technological leading
edge, builds a strong economy and improves people's quality of
life.
4. The work of EPSRC is complementary to
other research investors including other Research Councils, government
agencies, industry and the European Union. The Council actively
engages in and encourages partnerships and collaborations across
disciplines, boundaries and internationally.
5. EPSRC also actively promote public engagement
in science, engineering and technology.
EU ELECTROMAGNETIC
FIELDS DIRECTIVE
6. EPSRC welcomes any appropriate legislation
that ensures the continued safety of the researchers it supports.
7. MRI is a technique used by parts of our
research community. On 18 January 2006, EPSRC's research portfolio
included 95 grants related to MRI with a value of £28.2 million.
The directive may affect some areas of this portfolio, in particular
where experimental procedure requires the researcher to locate
within one to two million of the edge of the bore whilst imaging.
It is also possible that the directive may preclude certain promising
interventional MRI techniques thus limiting further and future
developments.
8. Our community has expressed concerns
that the impact of the legislation may be disproportionate to
the actual risk associated with exposure to the electromagnetic
fields in question. The community in question is very safety conscious,
in particular the medical imaging community (probably through
experience with X-Rays). We believe that with the appropriate
evidence base, the community will actively seek to implement the
directive quickly and effectively.
9. There is however a concern amongst our
community that at present the evidence base for the proposed exposure
limits defined in the directive is poor. In particular, there
is a belief that the limits in the 100Hz-100KHz range are based
on limited experimental data for the frequencies most important
to MRI, and they are extrapolated from effects that have not been
shown to occur at MRI frequencies. Some people argued that these
limits should be set based on peripheral nerve stimulation, not
central nervous system effects.
10. EPSRC has been in consultation with
a number of other bodies over this directive (in particular the
MRC, Wellcome Trust, HSE and AMRC). In particular we have been
looking to identify possible research challenges associated with
the directive and three immediate ones seem to present themselves:
— Computer modelling to establish actual
exposure of MRI workers. This is key to help understand how much
of a problem the directive may pose.
— Research to further verify the actual
exposure limits proposed (eg has the correct biological model
been used).
— Research into approaches to reduce
magnetic field exposure (eg through changes to work practices,
innovation in equipment design etc).
11. These scientific challenges are of varying
fit to EPSRC's remit, but we will continue to consult with other
bodies to ensure a collaborative approach.
12. With respect to "SCIENTIFIC ADVICE,
RISK AND EVIDENCE: HOW GOVERNMENT HANDLES THEM", it seems
clear that sections of EPSRC's community do not feel that the
evidence used to support the EU directive was adequate. A series
of research challenges are beginning to be developed that will
investigate these supposed deficiencies and provide further evidence
for any future revision or confirmation of the directive. In the
mean time we understand that the directive will be implemented
as it stands. The implementation notwithstanding, perhaps a consultation
process and involvement of all stakeholders at the earliest stage
would have led to a smoother implementation of new policies and
regulations.
January 2006
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