Questions sent to ICNIRP Chairman Dr. Rodney Croft in Fall of 2020.

In response to the below questions send in November 2020, Croft  stated, “In terms of the questions that you sent before, as I advised before, I do not have time to address these within my University of Wollongong capacity. However, if you would like to request that ICNIRP comment on your questions that is fine. The best thing would be to submit the questions via the website (, or if you feel that you cannot restrict your questions to the required format, to contact the ICNIRP secretariat ([email protected]). I would note though that some of the questions have been asked in a way that, in order to address them, would require a journal publication (or equivalent piece) to outline how science works and how the literature is put together to arrive at a conclusion, whereas others are of a form that would allow simple answers. As the former type would take a substantial amount of time to provide (if ICNIRP decided that it was sufficiently important to dedicate its resources to do so), given your timeline, you might like to consider asking questions that would make it possible for ICNIRP to answer quickly.”

  1. Has the ICNIRP ever done a full review of the  effects of radiofrequency to trees and plants? If so, are ICNIRP limits designed to protect trees and plants?Please note research showing impacts to plants and damage to trees from cell antennas (Waldmann Selsam 2016,Helmut 2016,Haggerty 2010, Halgamuge 2017, Pall 2016, Halgamuge and Davis 2019).
  2. Has the ICNIRP ever done a full review of the effects of radiofrequency to bees and insects? If so, are ICNIRP limits designed to protect bees and insects?Please note research showing effect to bees after non ionizing electromagnetic radiation exposure such as inducing artificial worker piping(Favre, 2011), disrupting navigation abilities (Goldsworthy, 2009;Sainudeen, 2011; Kimmel et al., 2007) decreasing rate egg laying rate and reducing colony strength (Sharma and Kumar, 2010;Harst et al., 2006).
  3. Are you aware of the study “Exposure of Insects to Radio-Frequency Electromagnetic Fields from 2 to 120 GHz” published in Scientific Reports (Thielens 2018)  which was the first study to investigate how insects (including the Western honeybee) absorb the higher frequencies (2 GHz to 120 GHz) to be used in the 4G/5G rollout. The researcher’s  scientific simulations showed increases in absorbed power between 3% to 370% when the insects were exposed to higher frequencies and the researchers warn that “the shift of 10% of the incident power density to frequencies above 6 GHz would lead to an increase in absorbed power between 3–370%. This could lead to changes in insect behaviour, physiology, and morphology over time due to an increase in body temperatures, from dielectric heating.” Thus different frequencies could have different heating effects depending on the size of the insect.Will ICNIRP be looking at different sized insects and radiofrequency effects at the higher frequencies to be used in 5G? 
  4. Has the ICNIRP  ever done a full review of the effects of radiofrequency to birds? If so, are ICNIRP limits designed to protect birds? There is research associating increases in radiofrequency to species disappearance (Broomhall 2015)and studies showing  non-ionizing radiation can impact birds at levels that are compliant with FCC and ICNIRP limits (Schwarze 2016,Engels et al., 2014,Balmori 2009,Balmori 2015, Manville 2009,Wiltschko 2015, Kavokin 2014,Tsybulin 2013,Everaert 2007).
  5. If ICNIRP has not done a review of the effects to wildlife then do you know any entity that has done a systematic review of the impact to wildlife (including trees, plants and vegetation)  and who has then developed science based safety limits documented to be adequate to protect  wildlife and our natural environment?  
  6. Are you aware of the  American Cancer Societyfunded researchby Yale researchers (Luo 2020) that found thyroid cancer linked to cell phone radiation exposure and that thyroid cancer is rising worldwide (Deng et al., 2020) and specifically in youth in the United States (Bernier 2019,CDC 2018? If you are aware of this research linking thyroid cancer to cell phone radiation, please explain why ICNIRP is not lowering their reference levels in response? 
  7. ICNIRP has put forward an ELF EMF threshold far far higher than the levels   of exposure for pregnant women at which California Kaiser Permanente researchers found increased miscarriage(a replicated study), increased ADHD, increased obesityand increased  asthma  in the woman’s prenatally exposed children. Arecent large-scale study again found associations between ELF EMF with cancer.  Can you respond to these studies showing adverse effects from non ionizing radiation at levels from 3 to 4 milligauss (far lower than ICNIRP restrictions) please and explain why you and /or ICNIRP are not acting to recommend pregnant women and children reduce their exposure to ELF-EMF?
  8. An Australian study also found that children in kindergartens with nearby antenna installations had nearly three-and-a-half times higher RF exposures than children with installations further away (more than 300 meters (Bhatt 2016). The research study “Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations.”found people living closer to cell antennas had statistically significant higher frequency of micronuclei and a rise in lipid peroxidation in their blood. These changes are considered biomarkers predictive of cancer.Do you think cell towers are safe to be near schools and playgrounds or do you think there should be restrictions to cell towers? 
  9. Research on animals  (Bas et al., 2009;Deshmukh et al., 2015; Shahin et al., 2017;Megha et al., 2015;Aldad et al., 2012;Zhang et al., 2015) shows impacts after RFR exposure to the brain such as  alterations in neurodevelopment and behavior of offspring,  impaired learning and spatial memory, a deleterious impact on hippocampal, pyramidal or cortical neurons and induced markers of oxidative stress and inflammation in the brain.  Human studies have found  higher cell phone radiation associated with behavioral problems and memory damage (Divan et al., 2012Birks et al. 2017; Foerster et. al., 2018 ). A study you co-authored also found cognitive impacts –Verrender et. al., 2016 (as have several studies you published). In light of this research showing impacts to the brain, why not recommend the public keep the phone away from the brain? Or at a minimum that parents ensure children do not place the phone to their head? 
  10. ICNIRP has “ identified the ‘adverse health effect threshold’ at approximately 1° C and a whole-body exposure with an average SAR of 4 W/kg corresponding to the operational adverse health effect threshold for frequencies up to 6 GHz. Can you share the study or  studies  that determined this specific  threshold specifically?
  11. Research you published and others has found that brain waves are affected by radiofrequency radiation (the 8–13 Hz alpha band in waking EEG and the 10–14 Hz “sleep spindle” frequency range in sleep EEG). See Schmid et. al., 2012 Croft et. al., 2010, Yang et. al., 2016,Danker-Hopfe et. al., 2019. These effects were found at exposure levels compliant with (and lower than)   ICNIRP and FCC limits.As these EEG effects are considered proven, can you please explain why you do not advocate for RF limits that protect against these changes to brain waves? 
  12. ICNIRP 2020 cites “an in-depth review from the World Health Organization (WHO) on radiofrequency EMF exposure and health that was released as a draft Technical Document (WHO 2014)” however that draft was never finalized nor was the full draft ever publicly shared. The draft was missing the  very important chapters: #1 (Summary and recommendations for further study), #13 (Health risk assessment) and #14 (Protective measures).  Thus it is not a valid scientific reference. We understand several ICNIRP members were also part of the group of scientists drafting the draft  Technical Document which never was made final.Did ICNIRP use draft material (summaries of health risk) that have not ever been published or publicly shared? Or was the reference to never finalized (also never published) drafts released for comment.   
  13. According to the WHO webpage, the World Health Organization has NOT done an evaluation of the current body of research on radiofrequency radiation since 1993.  This is stated on the website “The World Health Organization is undertaking a health risk assessment of radiofrequency electromagnetic fields, to be published as a monograph in the Environmental Health Criteria Series. This publication will..update themonograph on radiofrequency fields(  1993).” Has there been any more recent complete systematic evaluation of the science by the World Health Organization  in terms of health effects performed since the date of 1993?(I am asking about a completed evaluation of the hazard, not a draft document please.)
  14. In a news interview in Australia (Go to minute 13:25) where you stated that “It’s very true that the amount of studies that have specifically looked at 5G are very limited, but from a science perspective that just isn’t relevant. What’s relevant is the electromagnetic energy and how that affects us..” Why is it not relevant when 5G will increase ambient levels of Radiofrequency, add in millimeter waves and there will be billions of new interconnected devices, including dozens in our homes? 
  15. In the same interview (Go tominute 12:52)  you stated regarding the World Health Organization International Agency for Research on Cancer  classification of Radiofrequency as a Class 2 B possible carcinogen that  “What they have actually said is that we don’t have any evidence that mobile phones cause cancer but it’s possible that it does..” Please explain the basis for this statement as the WHO/IARC classification was based specifically on published scientific evidence showing an association between cell phone use  and glioma and acoustic neuroma.  We are aware that more science was needed by the panel, especially animal data back in 2011. However evidence did show associations at that time. Numerous publications since 2011 have documented the recent science adding to the weight of evidence. Now several scientists state that the classification should be upgraded to status as a confirmed human carcinogen (Miller et al., 2018, Hardell and Carlberg 2019).
Share Source: Environmental Health Trust