Energy and Climate Change CommitteeWritten evidence submitted by the Alliance for Natural Health International (SMR81)

Executive Summary

Regarding smart meters (SMs), the Alliance for Natural Health International (ANH-Intl) believes that the only sensible public-health policy approach is to immediately halt their planned UK-wide rollout, for the following reasons:

The most comprehensive collation of worldwide data on the health effects of radiofrequency (RF) electromagnetic radiation (EMR), the BioInitiative Report 2012, contains convincing scientific evidence that the wireless transmission/receiving mechanism of SMs is a major source of public health concern.

Documented health effects are wide ranging, from fainting, dizziness and nausea to increased cancer risk and impairment of fertility, immune function and reproduction.

The view of the Health Protection Agency and UK government is informed by the independent Advisory Group on Non-Ionising Radiation (AGNIR), which believes that, “There is no convincing evidence that RF field exposure below guideline levels causes health effects in adults or children”.

AGNIR and other similar reports concern themselves solely with the heating effect of RF-EMR on bodily tissues, whereas the evidence shows that non-thermal (or low-intensity) exposures also cause bioeffects, some of which are likely to cause adverse health effects upon chronic exposure.

In addition, ANH-Intl wishes to put on record its disquiet with the wording and scope of the present consultation, which gives the impression that a decision to proceed with rollout has already been taken, regardless of public misgivings.

1. The Alliance for Natural Health International (ANH-Intl) believes that smart meters (SMs) are unnecessary, intrusive, a threat to privacy and of benefit only to the utility companies and governments, both UK and foreign.

2. However, ANH-Intl’s main issues with a UK-wide SM rollout concern damage to the health of residents of SM-equipped houses.

3. Documented health problems associated with SMs include: heart palpitations, chest pain, dizziness, inability to concentrate, memory loss, fainting spells, headaches, nausea, sleeplessness, memory loss and an increased risk of cancer[1] and references contained therein].

4. The wording of the present consultation[2] presents SMs as entirely beneficial to all sides: “Energy suppliers are expected to benefit from reduced operating and generation costs, and some of these savings should be passed on to consumers...Consumers are also expected to benefit from...reduce[d] energy consumption and...energy bills. In future, automated controls and smart appliances may help consumers to reduce their energy use further.”

5. Nowhere are health concerns even alluded to, except for in a single question in the terms of reference: “Are consumers’ concerns about privacy and health being addressed adequately?” [2]

6. Our short answer to this question is: No, not by any means, and in fact there appears to be no official UK government acknowledgment of any risks to health from SMs. For example, the Health Protection Agency (HPA) states that: “The evidence to date suggests exposures to the radio waves produced by smart meters do not pose a risk to health”.[3]

7. This is a shocking statement, since reliable reports of negative health effects associated with SMs are available from numerous sources [1 and all references contained therein]—including the World Health Organization (WHO).

8. SMs transmit data using radiofrequency (RF) (microwave) electromagnetic radiation (EMR), with multiple devices per premises in a network. According to a report prepared for the HPA by the independent Advisory Group on Non-Ionising Radiation (AGNIR),[4] “At regular intervals data are transmitted from the device to the utility company...the technology...is commonly called home area networking (HAN), which involves networking several devices in the household premises. Smart meters also transmit and receive data wirelessly between the meter and a central server.”

9. Clearly, then, with SMs in 24-hour operation, 365 days per year, UK citizens living in SM-equipped households will be subject to an invisible and permanent “sea” of RF-EMR.

10. The International Agency for Research on Cancer (IARC), part of the WHO, considers RF electromagnetic fields to be “possibly carcinogenic” to humans.[5]

11. The 2012 update of the BioInitiative Report represents possibly the most comprehensive existing collation of data related to the health effects of EMR.[1] Its scientific standing is impeccable, having been prepared by, “29 authors from 10 countries, ten holding medical degrees (MDs), 21 PhDs, and three MsC, MA or MPHs. Among the authors are three former presidents of the Bioelectromagnetics Society [BEMS], and five full members of BEMS. One distinguished author is the Chair of the Russian National Committee on Non-Ionizing Radiation. Another is a Senior Advisor to the European Environmental Agency”.[1]

12. The purpose of the BioInitiative Report was to, “Assess scientific evidence on health impacts from electromagnetic radiation below current public exposure limits and evaluate what changes in these limits are warranted now to reduce possible public health risks in the future”.[1]

13. Since it considers results from approximately 1800 new studies performed in the last 5 years, several of the BioInitiative Report’s conclusions are worth listing in the context of the present consultation.[1] Another excellent source of scientific papers on RF-EMR is held at the Powerwatch website;[6] papers are divided into those that found evidence of negative health effects of RF-EMR, those that found no evidence and those that provided useful insights but no positive or null conclusions regarding health effects.

14. “The clear consensus of the BioInitiative Working Group members is that the existing public safety limits are inadequate for both ELF [extremely low frequency radiation, emanating from electronic and electrical appliances and power lines] and RF”.[1]

15. “It appears it is the information conveyed by electromagnetic radiation (rather than heat) that causes biological changes—some of these biological changes may lead to loss of wellbeing, disease and even death”.[1]

16. “Biological effects may include both potential adverse health effects and loss of homeostasis and well-being”.[1]

17. “There may be no lower limit at which exposures do not affect us...it is unwise from a public health perspective to continue ‘business-as-usual’ deploying new technologies that increase ELF and RF exposures”.[1]

18. “The existing ICNIRP and FCC limits for public and occupational exposure to ELF and RF are insufficiently protective of public health”.[1]

19. “Biologically-based public and occupational exposure standards for extra-low frequency and radiofrequency radiation are recommended to address bioeffects and potential adverse health effects of chronic exposure to ELF and RF. These effects are now widely reported to occur at exposure levels significantly below most current national and international limits”.[1]

20. “The existing standards are based on thermal (heating) limits, and do not address non-thermal (or low-intensity) exposures which are widely reported to cause bioeffects, some likely leading to adverse health effects with chronic exposure”.[1]

21. “Biologically-based exposure standards are needed to prevent disruption of normal body processes. Effects are reported for DNA damage (genotoxicity that is directly linked to integrity of the human genome), cellular communication, cellular metabolism and repair, cancer surveillance within the body; and for protection against cancer and neurological diseases. Also reported are neurological effects including impairment of sleep and sleep architecture, cognitive function and memory; depression; cardiac effects; pathological leakage of the blood-brain barrier; and impairment of normal immune function, fertility and reproduction”.[1]

22. “Plausible biological mechanisms that can account for genotoxicity (DNA damage) are already well known (oxidative damage via free-radical actions) although it should also be said that there is not yet proof. However, proof of mechanism is not required to set prudent public health policy, nor is it mandatory to set new guidelines or limits if adverse health effects occur at lower-than-existing IEEE and ICNIRP standards”.[1]

23. “There is inadequate warning and notice to the public about possible risks from wireless technologies in the marketplace, which is resulting in adoption and use of technologies that may have adverse health consequences which are still unknown to the public. There is no ‘informed consent’”.[1]

24. “No positive assertion of safety can be made by governments that continue to support and enforce exposure limits for RF and ELF based on ICNIRP [International Commission on Non-Ionizing Radiation Protection] or IEEE [Institute of Electrical and Electronics Engineers] criteria (or the equivalent)”.[1]

25. Section 4 of the BioInitiative Report contains the opinions of experts on the deficiencies of existing EMR exposure standards, including comments from the WHO, the US Food and Drug Administration (FDA), the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) report prepared for the European Commission, and others. It includes the following 2004 opinion from the UK’s National Radiation Protection Board (NRPB), which has since been superseded by the HPA: “The most coherent and plausible basis from which guidance could be developed on exposures to ELF EMFs concerned weak electric field interactions in the brain and [central nervous system]...The brain and nervous system operate using highly complex patterns of electrical signals. Therefore, the basic restrictions are designed to limit the electric fields and current densities in these tissues so as to not adversely affect their normal functioning...the basic restrictions should not be regarded as precisely determined values below which no adverse health effects can occur and above which clearly discernible effects will happen”.[1]

26. The present advice from the HPA is less nuanced than the NRPB’s 2004 opinion: “HPA considers there is no clear evidence of harm from exposure within the internationally agreed guideline levels...AGNIR’s main conclusion was that...there is no convincing evidence that radio wave exposures below guideline levels cause health effects in adults or children”.[3]

27. The AGNIR report is concerned solely with the thermal effects of RF-EMR exposure: “Current exposure guidelines are based on the thermal effects of RF fields...no consistently replicable effects [on human cells in vitro] have been found from RF field exposures at levels below those that produce detectable heating...[animal] studies provide no evidence of health effects of RF field exposures below internationally accepted guideline levels...The evidence suggests that RF field exposure does not cause acute symptoms in humans...[despite] some evidence that RF field exposure may effect EEG [electroencephalogram] readings and other markers of brain function...it is unclear whether they have any implications for health...Although research on the potential long-term effects of RF field exposures below guideline levels on other non-cancer outcomes has been very limited, the literature provides no substantial evidence of such effects”.[4]

28. AGNIR’s overall conclusion was unequivocal: “There is no convincing evidence that RF field exposure below guideline levels causes health effects in adults or children”.[4]

29. Fundamentally, the reason for the huge disconnect between the conclusions of the BioInitiative Report and those of AGNIR—which drive policy of the HPA and UK government—comes down to one fact that is recognised by the former, but less so by the latter: “Human beings are bioelectrical systems. Our hearts and brains are regulated by internal bioelectrical signals. Environmental exposures to artificial EMFs can interact with fundamental biological processes in the human body”.[1]

30. ANH-Intl agrees entirely with the conclusions of the BioInitiative Report as they relate to RF-EMR.[1] As regards SMs specifically, the only sensibly precautionary option from a public health perspective is to halt the planned roll-out of smart meters into UK homes immediately

31. In addition to purely health-related concerns, the VAASA-ETT report of 2010 found that, “As a technology, (without appropriate regulation) smart meters provide more benefits to the utilities than to the end consumers”.[7] The report also cited concerns with the clearly incompatible imperatives presented by utility companies, whose profits accrue from sales of units of electricity, water etc. seeking to reduce sales of those units via SMs.[7]

32. As well as the concerns already noted, we must also put on record our disquiet about the tone and scope of the present consultation. As noted in paragraph 4, SMs are presented as an unalloyed public good; the consultation is positioned as a means not of accurately gauging public feeling and subsequently adapting policy, but merely as a way of gathering information in order to mitigate public concern. Phrases such as, “If engagement levels do not increase and people refuse to allow smart meters to be installed in their home, then roll-out may be hindered and consumers may not benefit from the technology as they could”[2] contain no recognition that the public may have perfectly reasonable concerns about smart meters—concerns that are both logically and scientifically justifiable. We are concerned that the decision has already been made to roll out smart meters UK-wide, regardless of the science or public feeling, and that a “public relations” effort by means of a consultation is seen as the most effective method of subverting and diverting public misgivings. Nowhere in the terms of reference is the possibility of delaying or cancelling SM rollout considered, especially given that the precautionary principle should, in our view, dictate such an approach.