Unanswered Questions Sent to ICNIRP March 27, 2021 from Theodora Scarato Regarding Wireless Radiation
Theodora Scarato frst sent a letter to ICNIRP in November 2020 and ICNIRP Responded with a short letter December 11, 2020. However ICNIRP did not answer the questions in full.
Dear ICNIRP,
I still have not received an answer to my questions and it has been three months now since I sent the follow up letter.
Please see our update list of questions.
FOLLOW UP QUESTION 1
I asked “ 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? “
ICNIRP responded on Dec 11, 2020 that “In terms of your request for details about how ICNIRP derived the restrictions for whole body SAR, this is described in the 2020 RF Guidelines.”
However when I go to ICNIRP 2020 one cannot find the studies cited. Please direct me to the studies specifically- as ICNIRP 2020 does not clarify this. The ICNIRP 2020 simply states
Pg 488 “As described in Appendix B, body core temperature rise due to radiofrequency EMFs that results in harm is only seen where temperature increases more than +1°C, with no clear evidence of a specific thresh- old for adverse health effects.” When I go to Appendix B APPENDIX B: HEALTH RISK ASSESSMENT LITERATURE Pg 518 states “Both rodents and non-human primates have shown a decrease in food-reinforced memory performance with exposures to radiofrequency EMFs at a whole-body average SAR >5 W kg−1 for rats, and a whole-body average SAR >4 W kg−1 for non-human primates, exposures which correspond to increases in body core temperatures of approximately 1°C. However, there is no indication that these changes were due to reduced cognitive ability, rather than the normal temperature-induced reduction of motivation (hunger).”
Yet the reference to these studies are not cited.
Question 1: Can you please provide the studies, with author, journal date and the full citation- you are referring to when you state on pg 518 “Both rodents and non-human primates have shown a decrease in food-reinforced memory performance with exposures to radiofrequency EMFs at a whole-body average SAR >5 W kg−1 for rats, and a whole-body average SAR >4 W kg−1 for non-human primates, exposures which correspond to increases in body core temperatures of approximately 1°C.”
FOLLOW UP QUESTION 2
I asked on November 10, 2020 “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? “
ICNIRP answered December 11, 2020 “Note that you have referred to some effects (e.g. RF effects on the EEG) as adverse health effects. Although we won’t comment on the research itself, please note that this confuses biological effects that do not result in adverse health effects, with adverse health effects. ICNIRP’s mandate is to protect against adverse health effects, and so ICNIRP guidelines do not specifically attempt to avoid bioeffects that do not result in adverse health effects.”
Scarato follow up question 2: ICNIRP states on page 37 “ Studies analyzing frequency components of the EEG have reliably shown that the 8–13 Hz alpha band in waking EEG and the 10–14 Hz “sleep spindle” frequency range in sleep EEG, are affected by radiofrequency EMF exposure with specific energy absorption rates (SAR) <2 W kg−1 , but there is no evidence that these relate to adverse health effects (e.g., Loughran et al. 2012).” but is there evidence that such brain wave changes are safe? ICNIRP seems to be stating that although these bioeffects clearly have been found, they are not health effects. Has research been done demonstrating that altering brain waves night after night is safe?
FOLLOW UP QUESTION 3
I asked on November 10, 2020 “ In the same interview (Go to minute 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). “
ICNIRP answered December 11, 2020 , “In terms of your question about the IARC 2B classification, this is often misinterpreted, and by ‘possibly carcinogenic’ it merely means that it cannot be excluded that there is an effect. Although the IARC classification was back in 2011, from what we know now in 2020 there is no reason to change that conclusion, and thus no possibility to use carcinogenicity as a basis for exposure guidelines.”
The ICNIRP statement that ‘possibly carcinogenic’ “merely means that it cannot be excluded that there is an effect.” is false.
The International Agency for Research on Cancer (IARC) of World Health Organization lists what possibly carcinogenic means in their preamble accessed online and it states of the Class 2 B Classification that “This category includes agents for which, at one extreme, the degree of evidence of carcinogenicity in humans is almost sufficient, as well as those for which, at the other extreme, there are no human data but for which there is evidence of carcinogenicity in experimental animals.”
In 2019, the advisory group of the International Agency for Research on Cancer (IARC) of the World Health Organization released new recommendations to reassess as a “high priority” the cancer risks of radiofrequency (RF) radiation between 2020–2024 due to new research study findings in animals. The recommendations were published in The Lancet Oncology on April 18, 2019 and the full report cites new epidemiological studies as well as new animal studies published after the 2011 classification as the reason the new review is needed.
Follow up Question 3: Is ICNIRP aware that the advisory group of the International Agency for Research on Cancer (IARC) of the World Health Organization has released new recommendations to reassess as a “high priority” the cancer risks of radiofrequency (RF) radiation?
If ICNIRP is aware of these recommendations, does the 14 member ICNIRP Commission disagree with the need for a re-evaluation?
FOLLOW UP QUESTION 4
I asked “ In a news interview in Australia (Go to minute 13:25) where Rodney Croft 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? “
ICNIRP answered December 11, 2020 “Note that although you appear concerned that 5G will result in substantially more RF exposure relative to pre-5G levels, it is highly uncertain that this is indeed the case. However, ICNIRP’s remit is not to control exposure levels in the community, but to set protective limits.”
Scarato Response: Please explain what you mean “ it is highly uncertain that this is indeed the case that 5G will result in substantially more RF exposure?’” The documentation I have shows both industry and published research studies show an increase in ambient environmental levels of RF. For example:
The above is ample evidence from industry itself that 4G and 5G networks will increase environmental levels of RF. If there is not going to be increases in radiofrequency radiation exposure then why are companies publishing white papers stating that countries with more stringent RF limits should change their limits to accommodate 5G?
There are several studies documenting that the ambient level of radiofrequency will increase such as
- A 2018 study published in Annals of Telecommunications found increased RF-EMF exposure from small cell LTE networks in two urban cities in France and the Netherlands that found that the small cell networks increased the radio emissions from base stations (called downlink) by a factor of 7–46 while decreasing the radio emissions from user equipment exposure (called ) by a factor of 5–17. So while the devices themselves could emit less radiation, the cell antennas will increase the levels from cell antennas (Mazloum et al., 2019).
- A 2020 paper “Radiation Analysis in a Gradual 5G Network Deployment Strategy,” found significant increases in levels of radio frequency radiation would result if a mmWave-based 5G network was fully deployed in Austin Texas based on a simulation of existing infrastructure and the needed 5G base stations.
Research shows that base station antennas are a significant source of exposure. Industry is densifying 4G antennas for the future 5G network. Numerous 5G networks are using low band frequencies that have deeper penetration.
- A 2018 study, published in Environment International, looked at 529 children in Denmark, the Netherlands, Slovenia, Switzerland and Spain who wore meters around the waist or carried in a backpack during the day and placed close to the bed at night. Researchers found “the largest contributors to total personal environmental RF-EMF exposure were downlink (meaning from cell tower base stations) and broadcast” (Birks et al., 2018).
- A 2018 published study in the Science of The Total Environment journal, gave 50 Korean parents and their child a measuring device for 48 hours found that “the contribution of base-station exposure to total RF-EMF exposure was the highest both in parents and children.”
- A 2018 study co-authored by ICNIRP’s Rodney Croft equipped Australian adults with an RF measuring device in a small hip bag for approximately 24 consecutive hours. The study found “downlink and broadcast are the main contributors to total RF-EMF personal exposure.” Downlink (RF from mobile phone base station) contributed 40.4% of the total RF-EMF exposure (Zeleke et al., 2018).
The ambient levels will increase as the research cited clearly documents. Animals, babies, and toddlers do not use cell phones but they do play outside. This is involuntary exposure.
Furthermore, the study “Human Electromagnetic Field Exposure in 5G at 28 GHz” published in IEEE Consumer Electronics Magazine evaluated human exposure to radiofrequency for three wireless systems -5G, 4G, and 3.9G and found that 5G’s higher frequencies penetrate into the skin very intensely despite the fact that the depth of penetration is more shallow.“The SAR is inversely proportional to the penetration depth, and hence, a shallower penetration occurring in 5G yields a higher absorption.” The authors conclude that “the fact that a high-frequency EMF cannot penetrate deep into human skin does not mean that it is not dangerous.”
Scarato follow up question 4: Can you please share the scientific documentation substantiating this statement by ICNIRP “Note that although you appear concerned that 5G will result in substantially more RF exposure relative to pre-5G levels, it is highly uncertain that this is indeed the case.” Please ensure your response incorporates real work scenarios in terms of the RF level that would be expected with 5G deployment and the densification of other networks such as LTE considered the backbone of 5G.
FOLLOW UP QUESTION 5
I asked 5 questions to which ICNIRP responded with one paragraph.
Here are the questions I asked:
- 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).
- 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).
- 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?
- 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).
- 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?
ICNIRP did not answer these questions but said Dec 11, 2020 “In terms of your questions 1-5, ICNIRP has not conducted a thorough review of the literature relating to potential adverse effects on ecology and the environment, and accordingly, ecology and the environment have not been included within the scope of the RF guidelines. However, ICNIRP has looked at this issue, and consistent with what was reported at the ELF and RF flora and fauna workshop that was run by the German government in autumn last year, there is no reliable indication at present that RF exposure within the ICNIRP guidelines adversely affects ecology and the environment. Details of the workshop can be found at https://www.bfs.de/DE/bfs/wissenschaft-forschung/ergebnisse/emf-umwelt/emf-umwelt_node.html.”
Scarato follow up question 5 :
Please explain the exact studies ICNIRP reviewed that underpin your statement that “there is no reliable indication at present that RF exposure within the ICNIRP guidelines adversely affects ecology and the environment” as I shared published research clearly showing effects. You referred to a “ ELF and RF flora and fauna workshop that was run by the German government in autumn last year” (and I will note that the webpage does not list the studies and in fact under “Effects of high frequency electromagnetic fields on vertebrates” only lists one study on calves which is rather odd..) so is it the protocol of ICNIRP to simply use the conclusions of the German government workshop which was not a systematic review and which has no publication available regarding the presentation itself or methodology used in such a determination?
FOLLOW UP QUESTION 6
I asked November 2020 to ICNIRP , “ 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.
ICNIRP answered December 11, 2020, “In terms of the WHO technical document, ICNIRP used the list and description of the individual studies from the WHO draft, whereas the conclusions on the different endpoints were ICNIRP’s.”
Scarato follow up question: So ICNIRP is confirming that it was referring to a draft document by the WHO, one which was never finalized and in fact, will be superseded by a new “review.” Please confirm you used the outdated, non final and non published review – the 2014 WHO draft ?
FOLLOW UP QUESTION 7
I asked November 2020 to ICNIRP, “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 WHO 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 the monograph 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.) “
See WHO website where it clearly states that the new “review” will update the 1993 monograph here.
ICNIRP answered December 11, 2020, “For details about what WHO documents have been published, you would need to contact the WHO.”
Scarato follow up question: Are members of ICNIRP aware that the WHO EMF Project states on their website that they last issued a monograph in 1993 stating “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 the monograph on radiofrequency fields (1993).” My question is to understand if you are aware of this fact.
FOLLOW UP QUESTION 8
I would like clarity regarding the ICNIRP Local SAR (100 kHz to 6 GHz). What is the safety factor for the head and torso ?
FOLLOW UP QUESTION 9
Regarding basic restrictions, what are the ICNIRP Local SAR (100 kHz to 6 GHz) limits for the eyes? I would appreciate it if you would provide the scientific documentation for this development of the restriction.
FOLLOW UP QUESTION 10
I asked several questions and ICNIRP did not answer them in the December 11, 2020 letter so I will try to clarify my questions one by one.
I asked- 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., 2012; Birks 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?
ICNIRP answered December 11, 2020 “You have also asked about specific studies. Except for a few exceptions (e.g. the NTP study), ICNIRP does not provide in depth commentary on individual studies.”
Scarato updated question: If ICNIRP has reviewed the research on impacts to the brain, it must be aware of this research and my question is why wont ICNIRP recommend parents reduce children’s exposure as there are not studies showing long term safety?
FOLLOW UP QUESTION 11
I asked “ Are you aware of the American Cancer Society funded research by 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 et.al 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? “
ICNIRP answered December 11, 2020 “You have also asked about specific studies. Except for a few exceptions (e.g. the NTP study), ICNIRP does not provide in depth commentary on individual studies. ICNIRP bases its assessments and guidelines on the literature as a whole, which includes consideration of individual studies as part of the hazard assessment process. As further assessments are conducted, ICNIRP will provide the sort of material that will hopefully answer your questions. “
Scarato updated question: Has ICNIRP reviewed the research on impacts to the thyroid at all? If so please provide documentation.
FOLLOW UP QUESTION 12
I asked “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? “
ICNIRP answered December 11, 2020 “You have also asked about specific studies. Except for a few exceptions (e.g. the NTP study), ICNIRP does not provide in depth commentary on individual studies. ICNIRP bases its assessments and guidelines on the literature as a whole, which includes consideration of individual studies as part of the hazard assessment process. As further assessments are conducted, ICNIRP will provide the sort of material that will hopefully answer your questions. “
Scarato updated question: Does ICNIRP consider cell towers near schools hazardous due to potential impacts on the developing brains and bodies of children?
FOLLOW UP QUESTION 13
I asked “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 obesity and increased asthma in the woman’s prenatally exposed children. A recent 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?
ICNIRP answered December 11, 2020 “For example, the claims that you’ve made about ELF causing a range of adverse health effects will be evaluated and communicated in the upcoming ELF hazard assessment.”
Scarato updated question: I did not make” claims” but merely cited published research studies. My question had to do with why ICNIRP is not taking preventive action regarding children. So for clarification as to your upcoming review, will ICNIRP be reviewing research that has looked at long term exposures to pregnant women?
FOLLOW UP QUESTION 14
ICNIRP has up to 14 Commissioners. What is the oversight process for ICNIRP ? Is there any entity that reviews the ICNIRP guidelines to ensure they are protective?
Thank you very much for answering these questions,
Theodora Scarato
https://ehtrust.org/39680-2/ Source: Environmental Health Trust