this blog is long so, please be patient and read to the end

Yesterday, I have written, yet again and as for the last nearly 20 years, that ICNIRP is a private club. Its new members are selected by the current members. There are no published criteria for the selection of new members. Nobody checks whether the selected experts are sufficiently good experts.

There is no responsibility, before nobody, for what and how ICNIRP does.

What if time will show that ICNIRP review of science was incorrect? Nothing, at least to ICNIRP members… but it could be a big problem for the telecom industry and us, the users.

On the contrary to claims by ICNIRP and by telecoms, it is difficult to believe that the telecoms do not influence who will be elected to ICNIRP Main Commission and don’t influence how the scientific evidence is interpreted by ICNIRP.

It is logically certain that some kind of lobbying happens.

Thinking otherwise is illogical. Just imagine the multi-billion-worth telecom industry to meekly wait for what ICNIRP does. It would be completely irresponsible for the telecom bosses. They need to be certain that ICNIRP guidelines are designed as necessary to continue business as usual.

With the “new” guidelines, ICNIRP gave carte blanche to the telecom industry.

ICNIRP safety guidelines

The recently published ICNIRP safety guidelines cover EMF spectrum from 100 kHz to 300 GHz, what includes the 5G millimeter-wave frequencies. The ICNIRP review of the biological effects of the EMF spectrum is presented, very sparingly, in Appendix B: Health risk assessment literature.

ICNIRP document noted that the guidelines for safety are based only on the so-called ‘substantiated’ adverse health effects. The definition of substantiated adverse health effect is not well defined in the ICNIRP guidelines document.

ICNIRP states:

“…ICNIRP first identified published scientific literature concerning effects of radiofrequency EMF exposure on biological systems, and established which of these were both harmful to human health and scientifically substantiated.”


“…ICNIRP considers that, in general, reported adverse effects of radiofrequency EMFs on health need to be independently verified, be of sufficient scientific quality and consistent with current scientific understanding, in order to be taken as “evidence” and used for setting exposure restrictions. Within the guidelines, “evidence” will be used within this context, and “substantiated effect” used to describe reported effects that satisfy this definition of evidence.


In order to set safe exposure levels, ICNIRP first decided whether there was evidence that radiofrequency EMFs impair health, and for each adverse effect that was substantiated, both the mechanism of interaction and the minimum exposure required to cause harm were determined (where available).”

Importantly, the majority of the science review in the ICNIRP guidelines is said to come from the reviews prepared and published in recent years by a variety of organizations such as WHO 2014, SCENIHR 2015, SSI 2015, 2016, 2018.

What is puzzling, the ICNIRP document completely omits the evaluation and classification of cell phone radiation as a possible human carcinogen, prepared by IARC in 2011 and published in 2012.

The Appendix B of the ICNIRP 2020 Guidelines, listing the summary of biological and health effects of various EMF frequencies, doesn’t mention at all about the possible biological effects of millimeter-waves on skin. This is significant omission because of the importance of millimeter-waves frequencies for the 5G.

ICNIRP seems to assume that all frequencies from 100 kHz to 6 GHz act similarly on the living matter. Thus, when ICNIRP claims that the EMF frequencies currently used for wireless communication, e.g. 900MHz, 1800 MHz, 2400 MHz, do not cause health hazard then the EMF frequencies currently used for 5G, like 3.5 – 3.6 GHz, will be also safe for health. However, this is assumption only and there are lack of studies examining biological effects of these frequencies.

ICNIRP claims that the biological effects caused by exposures below the safety limits are of no concern as they do not cause health effects. However, the issue is not so simple. ICNIRP safety guidelines assume that the biological effects triggered by low level exposures are indifferent for health. However, ICNIRP does not know whether repeated induction of certain biological effects that are not immediately harmful to health could lead to negative impact on cell/tissue/organ function and develop, over the long period of exposures (years – tens-of years) into a pathology. ICNIRP guidelines cover acute effects but do not cover at all chronic or delayed effects. That is a serious pitfall of the ICNIRP safety guidelines.

Doubting the ICNIRP safety guidelines on mm-waves

However, not everyone accepts ICNIRP opinion and, in fact, it is possible to wonder why ICNIRP claims safety there where the data nearly doesn’t exist – the millimeter-waves that will be in few years used by the 5G networks.

The Executive Summary of the Health Council of the Netherlands said clearly that there is no information on mm-waves and human health:

“…There has been almost no research into the effects of exposure to frequencies around 26 GHz…”


“…The committee recommends not using the 26 GHz frequency band for 5G for as long as the potential health risks have not been investigated…”

There have been published review articles in peer-reviewed journals that demonstrated lack of studies and knowledge on the possible effects of mm-waves on human health.

These examples of articles were not written by anti-5G activists. These articles were written by scientists and, what is more, some written by scientists at the request of, and paid by, the telecom industry.

Here are some examples:

Wu, Rappaport & Collins, 2015: Safe for Generations to Come. IEEE Microw Mag. 16: 65-84.

This review of science stemming from a symposium and prepared at the request of the telecom industry: the Brooklyn 5G Summit in April 2014, sponsored by Nokia and the New York University (NYU) WIRELESS research center.

The symposium dealt with the developing 5G wireless communication systems that will use millimeter-wave (mmWave) frequencies be able to have multi-gigabit-per-second (Gb/s) data rates.

One of the topics at the symposium was health safety:

“…The increasing investigations of mmWave applications and technologies have stimulated interest in, as well as concerns about, biological safety at mmWave frequencies. Biological study of mmWaves is needed to ensure safety and to enhance our fundamental understanding of the interactions of mmWave systems with the human body. Moreover, from a safety point of view, research on mmWave biological effects is also necessary for accurately evaluating the potential health hazards related to mmWave exposure and for developing and updating safety standards for the mmWave regime…”

Wu, Rappaport & Collins also pointed out that the then (in 2014) used human health safety guidelines were obsolete:

“…It is important to note that many governments presently rely on regulations that were developed before the year 2000, well before the rapid growth of wireless communications and low-cost mmWave devices. Thus, new approaches and additional data are needed to mitigate any unnecessary anxiety of the general public as new mmWave technologies evolve, while ensuring the safe use of future mmWave systems and devices…”

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Right now these obsolete guidelines were updated when the ICNIRP published in 2020 new safety guidelines (mentioned above).

Wu, Rappaport & Collins stated in their review several important observations. The first and, in my opinion, the most important observation, from the point of view of human and environmental health and safety, is the lack of research on biological effects of millimeter-waves:

“…Compared with lower frequency bands, relatively little careful research has been conducted evaluating the potential of more subtle long-term effects than tissue damage due directly to heating at mmWave frequencies

Further, Wu, Rappaport & Collins provided some details of what research in particular is of importance for the use of millimeter-waves.

“…Existing measured data of skin permittivity is rare in the mmWave band compared with frequencies below 20 GHz due to technical limitations, such as availability of vector network analyzers, in the mmWave frequency range…”

“…Since most mmWave energy is absorbed near the surface of the human body, leading to localized temperature elevations near the skin surface, the study of mmWave heating of the skin is critical to protecting humans from mmWave overexposure…”

“…At microwave frequencies, it is widely accepted that antennas placed in close proximity to lossy media, such as the human body, experience strong power absorption into the media, radiation pattern distortion, shift in resonance frequency, and change in the input impedance. In the mmWave band, the electromagnetic coupling between antennas and the human body as well as the possible perturbations of antenna characteristics due to the body require more study…”

Eyes, due to their lack of blood circulation that can provide cooling, are especially sensitive to potential temperature increases caused by EMF exposures, including the millimeter-waves. Wu, Rappaport & Collins pointed to two important problems with eye exposure to millimeter-waves:

“…As with the eyes, however, more work is required to determine temperature increases from higher exposure levels that might be experienced in the near field from specific communication devices with high-gain antennas and to develop and demonstrate reliable mechanisms to ensure that no hazardous levels of energy are transmitted to the skin…”

“…More work may be required to determine the possible effects from exposure above 10 mW/cm2 that might be experienced in the near field from specific communication devices with adaptive antennas as well as to ensure that mechanisms are in place to ensure that no hazardous levels of energy are transmitted into the eyes…”

Already in 2015, Wu, Rappaport & Collins have pointed out that the exposures to millimeter-waves will be rapidly increasing and the biological research will be difficult to assess [bold emphasis added by Leszczynski]:

“…The available data regarding exposure to mmWave energy and the scrutiny of it will continue to increase in the future, as now thousands of travelers are exposed to low-level mmWave radiation during airport security screenings throughout the United States. If the history of studies regarding exposure to nonionizing radiation is a guide, it may have either helpful […] or harmful […] effects in specific exposures much higher than those to which the general public is exposed. Also, as the exposure of the general public to each frequency band increases, individual studies reporting biological effects levels at or below those allowed for the general public will likely receive increased attention, but demonstration of consistently repeatable results at such low levels may be challenging […]…

Wu, Rappaport & Collins have ended their review with several health safety-pertinent statements:

  • “…The FCC and ICNIRP standards are designed principally to protect against thermal hazards since ionizing radiation is not a concern at mmWave frequencies…”
  • “…At mmWave frequencies, where most of the energy is absorbed in the few outer millimeters of tissue, even a 1-g averaging volume can seem large…”
  • “…We suggest that performing temperature elevation measurements for the compliance evaluation of mmWave wireless devices operating very close to the human body…”


  • “…mmWave attenuation of most garment materials is negligible…”
  • “…The eyes are particularly vulnerable to mmWave radiation-induced heating…”
  • “…Further measurements of dielectric permittivity on different body sites and different human subjects are warranted to characterize the variability and distribution of properties for the development of accurate human models…”
  • “…Major decisions on public policy or health care should not typically be made based on reports that were not reproduced independently…”

The importance of correct dosimetry of exposures is of paramount importance for the research on biological effects of EMF, including millimeter-waves. As pointed out by Kuster & Schmid, the to-date performed research examining in vitro biological effects of the cell phone-emitted radiation might be underestimating the effects. Inaccurate dosimetry might be the reason why the in vitro laboratory studies have provided such limited and contradictory evidence of the induced effects. Kuster & Schmid, 2015. The discrepancy between maximum in vitro exposure levels and realistic conservative exposure levels of mobile phones operating at 900/1800 MHz. Bioelectromagnetics 36:133-148.

“…The analysis demonstrated that exposure of skin, blood and muscle tissues may well exceed 40 W/kg at the cell level. Consequently, in vitro studies reporting minimal or no effects in response to maximum exposure of 2 W/kg or less averaged the cell media, which includes the cells, may be of only limited value for analyzing risk from realistic mobile phone exposure. We, therefore, recommend future in vitro experiments use specific absorption rate levels that reflect maximum exposures and that additional temperature control groups be included to account for sample heating…”

Di Ciaula, 2018: Towards 5G communication systems: Are there health implications? Int J Hyg Envir Health, 221: 367-375

The majority of the review looks at biological and health effects of RF-EMF. Only the last chapter focuses on the effects of millimeter-waves.

In the introduction, Di Ciaula points out that RF-EMF was shown to cause oxidative stress and oxidative DNA base damage. These effects are being suggested to pay a role in RF-EMF-exposure-induced health effects.

However, the issue is not that simple and the link between the oxidative stress and DNA damage and human health effects remains to be demonstrated. These biological effects were demonstrated in laboratory in vitro and animal studies. What is missing is demonstration that the same effects not only occur in humans but that their magnitude is of such extent that it can affect normal physiological processed and cause pathological event. This has not been shown and therefore, solely the observations of these events is insufficient to claim that health can be affected by them.

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The majority of the studies looking for the biological effects of millimeter-waves deal with the in vitro studies. However, Di Ciaula suggests that the systemic effects are possible:

“…Although the effects of exposure are limited to superficial tissues, systemic effects cannot be ruled out, due to irradiation of cutaneous vessels and surrounding tissues […]. This hypothesis seems to be confirmed, in an animal model, by the release of macrophage-activating mediators into the plasma following exposure to 35 GHz millimeter waves […]…”

Di Ciaula admits that the evidence concerning health effects of RF-EMF is still insufficient to claim that the exposures certainly affect human health:

“…Evidences about the biological properties of RF-EMF are progressively accumulating and, although they are in some case still preliminary or controversial, clearly point to the existence of multi-level interactions between high-frequency EMF and biological systems, and to the possibility of oncologic and non-oncologic (mainly reproductive, metabolic, neurologic, microbiologic) effects.…”

However, even though the evidence pointing to possible health hazard is still incomplete, Di Ciaula points out that the ICNIRP safety guidelines might be inadequate to protect users from the effects of exposures:

“…Biological effects have also been recorded at exposure levels below the regulatory limits, leading to growing doubts about the real safety of the currently employed ICNIRP standards…”

Apart of the reliability of ICNIRP safety guidelines, Di Ciaula pointed out the problem of 5G network antennas:

“…Particular concerns derive from the wide (and rapidly increasing) density of wireless devices and antennas (also in view of the forthcoming 5G networks), from the increased susceptibility to RF-EMF in children […] and from the effects of RF-EMF at a cellular and molecular level, in particular regarding the ability to promote oxidative processes […], DNA damage […], alterations of gene expression […] and to influence the development of stem cells […]…

However, the above listed several biological processes, considered by Di Ciaula as known to be caused by 5G and known to be hazardous to health, are not proven yet, as presented in an in press review by Leszczynski: “Physiological effects of millimeter-waves on skin and skin cells: an overview of the to date published studies” in Reviews on Environmental Health.

Di Ciaula has called for further research but, at the same time to not underestimate the already gathered scientific information on EMF and health:

“…Further experimental and epidemiologic studies are urgently needed in order to better and fully explore the health effects caused in humans by the exposure to generic or specific (i.e. MMW) RF-EMF frequencies in different age groups and with increasing exposure density.

However, underestimating the relevance of available results (in particular those from in vitro and animal models) do not appear to be ethically acceptable since, as has been observed reasoning in terms of primary prevention, it “is equivalent to accepting that a potential hazardous effect of an environmental agent can be assessed only a posteriori, after the agent has had time to cause its harmful effects […]…

Di Ciaula also called for implementation of the Precautionary Principle that is in his opinion granted because of the very large exposed population and because simultaneously with EMF exposures, population is exposed to multiple environmental pollutants. Using approach of a single-pollutant is not correct in current situation of large population exposed simultaneously to multiple-pollutants. Precautionary Principle would not be applied to stop deployment of 5G but to reconsider how and when deployment would be scientifically prudent.

In summary, Di Ciaula considers that there is sufficient already research to prove hazards of the EMF exposures, including millimeter-waves of the 5G, and deployment of the 5G networks should be considered in context of Precautionary Principle.

Simko and Mattsson, 2019: 5G wireless communication and health effects – A pragmatic review based on available studies regarding 6 to 100 GHz. Int J Environ Res Public Health 16: 3406

The problem of 5G deployment, presented by Simko & Mattsson, is similar to the questions asked above by Di Ciaula, namely the geographic escalation to provide coverage throughout the globe and high density of indoor/outdoor deployment of base stations and devices connected through networks:

“…The introduction of the fifth generation (5G) of wireless communication will increase the number of high-frequency-powered base stations and other devices. The question is if such higher frequencies (in this review, 6–100 GHz, millimeter waves, MMW) can have a health impact…”

Simko & Mattsson performed literature search on PubMed and EMF Portal as well as in the published scientific reviews by WHO, ICNIRP, SCENIHR, IARC, and IEEE. After the process of selection of publications according to their scientific quality, they included in the review 94 studies published by the end of 2018 in English language and covering the effects of EMF frequencies from 6 to 100 GHz (which they call shortly millimeter-waves).

Simko & Mattsson have identified as the gaps in the knowledge, for obvious reasons, the effects of millimeter-waves on skin, both acute and chronic and delayed effects:

“…Exposure of humans can occur through 5G devices with frequencies above 6 GHz, and may be primarily on the skin and, to a lesser extent, on the eyes. This is due to the very low penetration depth of this MMW. Therefore, it is important to investigate whether there are any health-related effects on the skin and/or effects associated with the skin. These include acute skin damage from tissue heating (burns), but possibly also less acute effects (such as inflammation, tumor development, etc.). Such effects could appear after prolonged and repeated heating of superficial structures (the skin). This would mean that thermal effects occur that are not due to acute but to chronic damage…”

They also pointed out that not only humans might be affected by the 5G millimeter-waves but also environment with all its living inhabitants:

“…There are also questions about the environmental impact, with potential consequences for human health. Since many MMW devices will be installed in the environment, the impact of MMW on insects, plants, bacteria, and fungi is relevant to investigate. Particularly relevant is the question of temperature increase in very small organisms, as the depth of penetration of the MMW could warm the whole organism…”

An important message stems from the review by Simko & Mattsson – there is too little of research on biological effects of millimeter-waves (they identified only 94 studies of sufficient quality) to decide whether there will be or will not be any health hazard associated with the deployment of 5G millimeter-waves-emitting base stations and devices

Simko & Mattsson have provided several important summary conclusions:

  • “…ranges up to 30 GHz and over 90 GHz are sparingly represented…”
  • “…the majority of studies with MMW exposures show biological responses…”
  • “…no in-depth conclusions can be drawn regarding the biological and health effects of MMW exposures in the 6–100 GHz frequency range…”
  • “…does not seem to be a consistent relationship between intensity (power density), exposure time, or frequency, and the effects of exposure…”
  • “…Some authors refer to their study results as having “non-thermal” causes, but few have applied appropriate temperature controls. The question therefore remains whether warming is the main cause of any observed MMW effects?…”
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Lastly, for the context of presentation of the data, the review by Simko & Mattsson has be performed at the request and financed by the industry. However, there is no visible bias in the search and evaluation of the science.

“…Funding: This research was funded by Deutsche Telekom Technik GmbH, Bonn, Germany…”

Leszczynski, 2020: Physiological effects of millimeter-waves on skin and skin cells: an overview of the to-date published studies. Rev Environ Health, ahead of print (

The currently ongoing deployment if the 5th generation of the wireless communication technology, the 5G technology, has reignited the health debate around the new kind of radiation that will be used/emitted by the 5G devices and networks – the millimeter-waves. The new aspect of the 5G technology, that is of concern to some of the future users, is that both, antennas and devices will be continuously in a very close proximity of the users’ bodies. Skin is the only organ of the human body, besides the eyes, that will be directly exposed to the mm-waves of the 5G technology. However, the whole scientific evidence on the possible effects of millimeter-waves on skin and skin cells, currently consists of only some 99 studies. This clearly indicates that the scientific evidence concerning the possible effects of millimeter-waves on humans is insufficient to devise science-based exposure limits and to develop science-based human health policies. The sufficient research has not been done and, therefore, precautionary measures should be considered for the deployment of the 5G, before the sufficient number of quality research studies will be executed and health risk, or lack of it, scientifically established.

The question is: do we know enough about the interactions between skin and skin cells with mm-waves to determine what health impact, if any, will have the acute and the long-term (life-time) exposure of skin to mm-waves?

Skin is not just a thin overcoat on the surface of the human body but it is an aggregate of numerous cells and microorganisms living together and playing a crucial role in regulating of the health and wellbeing of human body. As Sanford and Gallo [3] pointed out in their review article:

“…The skin, the human body’s largest organ, is home to a diverse and complex variety of innate and adaptive immune functions […] the skin immune system should be considered a collective mixture of elements from the host and microbes acting in a mutualistic relationship…”

Leszczynski reviewed studies: Articles have been selected from the following science databases: PubMed (, EMF-Portal ( and ORSAA ( The following keywords or combinations of keywords were used: “millimeter waves”, “skin”, “human”, “mice”, and “rats”. Studies presenting effects of mm-waves on skin physiology and on skin-dependent and skin-induced whole body physiology were analyzed. Peer reviewed original experimental studies published in the English language until September 2019 were considered.

In general, the to date published studies examining the effects of millimeter waves on the skin and skin cells provide very haphazard and lacking consistency picture of the possible/probable effects. However, the lack of replications and small size of the studies hamper the efforts to determine whether the skin exposures to millimeter-waves will, or will not, have any physiologically meaningful effects on human health.

When evaluating the health risk of any agent, the scientific evidence taken into consideration by the health regulatory authorities consists, in order of importance, of the following types of research studies:

  • Epidemiology studies
  • Human volunteer studies
  • Animal in vivo studies
  • Laboratory in vitro studies

The epidemiology studies are possible to execute only after the technology has been deployed and sizable parts of the population are being exposed to the examined agent, in this case the mm-waves radiation emitted by the 5G technology. Thus, this considered to be the most important and relevant scientific evidence is currently not available.

As presented in Leszczynski’s review, the whole scientific evidence on the possible effects of mm-waves on skin and skin cells consists of only some 99 studies, where 11 are human volunteer studies, 54 are animal in vivo studies (rats & mice) and 34 are in vitro laboratory studies using human and animal cell cultures.

This clearly indicates that the scientific evidence concerning the mm-waves effects on skin is extremely very limited. The evidence from the 99 studies is insufficient to make any reliable, science based evaluation of whether the mm-waves will have or will not have any health effects.

Therefore, the recently published guidelines by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), stating that the ICNIRP proposed mm-waves radiation exposure limits are protecting users form health effects of mm-waves are only an assumption that is not sufficiently based on scientific evidence because the research on effects of mm-waves on skin has not been performed. This is why any claims, including ICNIRP’s, that the current safety limits protect all users, no matter of their age or their health status, have no sufficient scientific basis. The safety limits that are suggested to protect from health effects of mm-waves are based on scientifically unsupported assumptions.

Final conclusion

There is an urgent need for research on the biological and health effects of mm-waves because, using the currently available evidence on skin effects, the claims that “we know skin and human health will not be affected” as well as the claims that “we know skin and human health will be affected” are premature assumptions that lack sufficient scientific basis.

Final wrap-up

…and to wrap-up a self-explanatory image presenting opinion of ICNIRP Chair, Rodney Croft that he presented in Australian TV interview., that ICNIRP knows there is not enough research on mm-waves but ICNIRP does not care.

This brings the story back to the title of this blog:

There is something utterly wrong with the ICNIRP membership

Between a Rock and a Hard Place – Dariusz Leszczynski