ES.OZ(Electrosensitivity Australia)
c/o Dr J. McCredden (Secretary)
24 Eric Road,
Holland Park, Q. 4121
2 May 2014
Public submission to the ACMA committee for reviewing submissions to the
Remaking the Human Exposure Standard & Electromagnetic Radiation Labelling Notice
Dear Submissions Review Committee,
We are a newly formed organisation called ES.OZ representing the Electrosensitive and other vulnerable members of the Australian community whose health is affected by electro-magnetic radiation which has been classified as a possible 2B carcinogen.
This collective vulnerable group is identified by ICNIRP, The Seletun Scientific Panel [1], The Council of Europe 2011 [2], Parliamentary Assembly and the World Health Organisation (WHO) [3]. All of these groups concede that levels for the general public will not protect the vulnerable. The Seletun Scientific Panel made very clear recommendations and advice for Government to follow and we are particularly concerned with protecting children's health as a priority by introducing precautionary measures.
We respectfully request an urgent review of legislative instruments with consideration for current science [4,5,6,7] and safety recommendations made by ICNIRP in 2002 [8] and the Seletun Scientific Panel 2010 with to protect the vulnerable population. The ICNIRP update recommends decision makers set NIR levels that are suitable for protecting the health and wellbeing of the vulnerable community which includes our children and future generations.
The ICNIRP thermal safety guidelines which are adopted by ARPANSA are nearly 20 years old, drafted long before the widespread uptake and use of wireless devices, WiFi and smartphone technology. They are not based on biological harm as has been highlighted by recent studies. They clearly exclude children (due to being based on a six minute exposure to a 200 pound fully grown male.)
Please consider the following paragraphs from the ICNIRP Statement 2002:
Nature of health effects” (p 541)
“Exposure to NIR may cause different biological effects, with a variety of consequences for a human being. Biological effects may be without any known adverse or beneficial consequences, other effects may result in pathological conditions (diseases), while still other biological effects have beneficial consequences for a person. Annoyance or discomfort may not be pathological per se but, if substantiated, can affect the physical and mental well-being of a person and the resultant effect should be considered as a potential health hazard.”
People being protected” (p 545)
“Different groups in a population may have differences in their ability to tolerate a particular NIR exposure. For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the population. Under such circumstances, it may be useful or necessary to develop separate guideline levels for different groups within the general population…”
“Some guidelines may still not provide adequate protection for certain sensitive individuals nor for normal individuals exposed concomitantly to other agents, which may exacerbate the effect of the NIR exposure, an example being individuals with photo-sensitivity. Where such situations have been identified, appropriate specific advice should be developed….”
“ICNIRP distinguishes occupational and public exposures in general terms. When applying the guidelines to specific situations, it is ICNIRP’s opinion that the relevant authorities in each country should decide on whether occupational or general public guideline levels are to be applied.…”
“Environmental conditions may also influence the effect of whole-body exposure to optical or RF radiation. Seriously ill patients might be considered as more vulnerable when exposed to NIR, but ICNIRP guidelines do not consider these potential vulnerabilities….”
We note that the responsibility here lies with the relevant authorities in Australia; i.e. with ACMA not with parents or teachers who are relying on ACMA to fulfil their obligations. We are therefore asking you to inform us of how any new guidelines will be accommodating for sensitive and vunerable individuals, and what advice has been gathered to inform these guidelines.
“What guidelines cannot account for...”[9]
“…Guidelines are set for the average population and cannot directly address the requirements of a minority of potentially more sensitive people…”
ARPANSA's Factsheet 14 [10]recommendation that time, distance and power are important for reducing radiation exposure is not being applied in a school settings because teachers and the general public are not aware. How is this being measured or monitored and by whom?
The ICNIRP 1998 thermal recommendations and the 2002 updates are not being managed or referred to. A typical day at school using WiFi:
Distance: usually above the children’s or teacher's head (within 7m)
Time: 6 hours a day
Power: Industrial strength systems expected to run 100's of computers at once
Children are potentially exposed for 6 hours a day to their entire body by a classified 2B carcinogen at school and at home due to ignorance of the possible risks - which could be partly remedied by labelling and more stringent guidelines to which schools must adhere. See the above calculations on the effects of long term exposure to school children below made by Barrie Trower, former military worker in microwave warfare for the UK Government [11] (see below).
Safety legislation needs to include clear labelling so that parents and teachers know how to use the wireless technology safely (i.e. in aeroplane mode) or the choices they have and the risks involved if the devices are not handled as directed.
The Safe Schools Report 2012 [12a] details recommendations for best practice legislation (see Appendix 4 of the safe School Report: Commentary on Schools & Best Practice EMF Legislation by Dr Isaac Jamieson March 2012 [12b]). We invite you to review this document which outlines many issues around microwave radiation and its effects on our children. They state:
“The presence or absence of environmental pollutants, such as electromagnetic pollution, may significantly impact on the learning and wellbeing of some individuals and reductions often be achieved at low or no cost. “Healthy students learn better. The core business of a school is maximising learning outcomes. Effective Health Promoting Schools (HPS) make a major contribution to schools achieving their educational and social goals.” IUHPE (2010).”
Most 2B possible carcinogens have a Material Safety Data Sheet and nearly all recommend keeping out of children's reach. Despite being rated a 2B Possible Carcinogen EMR has no such safety guidelines for public use.
UK unions state:
“Caution should be used to prevent exposure to substances in Group 2B,” and that “the aim should be to remove all exposure to any known or suspected carcinogen in the workplace” (TUC 2008).
IPads come with safety guidelines but many people are not aware of the health warnings that accompany them. The instructions are online and must be downloaded for consumers and teachers to find out how to use them safely. Here is what they say:
Exposure to Radio Frequency Energy
iPad contains radio transmitters and receivers. When on, iPad sends and receives radio frequency (RF) energy through its antenna. The Wi-Fi and Bluetooth® antennas are located behind the screen to the left of the Home button, and behind the Apple logo. iPad has been tested and meets the SAR exposure requirements for Wi-Fi and Bluetooth operation.
A cellular antenna is located at the top edge of iPad Wi-Fi + 3G, when oriented with the Home button at the bottom. For optimal mobile device performance and to be sure that human exposure to RF energy does not exceed the FCC, IC, and European Union guidelines, always follow these instructions and precautions: Orient the device in portrait mode with the Home button at the bottom of the display, or in landscape mode with the cellular antenna (located under the black edge at the top of the device) away from your body or other objects...
If you are still concerned about exposure to RF energy, you can further limit your exposure by limiting the amount of time using iPad Wi-Fi + 3G in wireless mode, since time is a factor in how much exposure a person receives, and by placing more distance between your body and iPad Wi-Fi + 3G, since exposure level drops off dramatically with distance.
The manual warns that if a user does not handle the iPad exactly as instructed, the radiation level will exceed governments' exposure limits for humans. It also concedes that time of exposure is a factor in determining risk.
We request that ACMA inform us of the steps that ACMA has made to ensure the risks are clear to schools, or to IT providers to advise schools of the risks?
In their document Wireless Technologies in Schools, Addressing Health Concerns Aruba advise that:
“The RP standard includes a requirement to minimise public exposure. In schools this means using laptops at a desk and arranging classrooms so no student is seated within half a metre of the antennae of network devices.”
An ipad 3, popular within schools has 5 antenna. A laptop may have at least 3. These also output significant radiation levels right in the child's face, heart, lap (near reproductive organs).
Given that children are vulnerable and studies (published by ARPANSA on their website demonstrate biological harm to an adult) [13] how does a child use these from a half a metre away if antennas have been identified as the source to keep distance from?
How is ACMA monitoring this?
Children are biologically more vulnerable and impacted by all types of radiation and environmental pollutants than adults. [14]
“Children, however, are not little adults and are disproportionately impacted by all environmental exposures, including cell phone radiation. In fact, according to IARC, when used by children, the average RF energy deposition is two times higher in the brain and 10 times higher in the bone marrow of the skull, compared with mobile phone use by adults…it is essential that any new standard for cell phones or other wireless devices be based on protecting the youngest and most vulnerable populations to ensure they are safeguarded throughout their lifetimes.” – Dr. Robert Block, President of the American Academy of Pediatrics, (2012)
With WiFi this is a whole body exposure plus the close range impact from 5 antennae in an ipad or 3 antennae in a laptop.
At many schools there is also the issue of the closeness of cellphone towers to schools. Solid research has shown the correlation between proximity to cell phone towers (see the Safe Schools report Appendix 3). Opening up the spectrum to higher and more potentially dangerous frequencies will mean children are being exposed to these for 6 hours a day at close proximity. How is ACMA addressing these exposure levels and the risk to the health of our children while at school. There are similar concerns for towers placed near retirement villages and masts on hospitals. How is ACMA going to ensure that these venerable populations are protected, (as they are currently not protected).
The medical community has adopted the ALARA principle, As Low As Reasonably Achievable [15]. In the absence of absolute proof but knowing they are vulnerable they adopt the precautionary principle and apply ALARA.
Ethically we can't deliberately expose children with EMR for studies but we know that rodents give scientists very accurate results which we can trust to identify possible health risks.
“ Likewise, select genes can be turned off or made inactive, creating "knockout mice," which can be used to evaluate the effects of cancer-causing chemicals (carcinogens) and assess drug safety, according to the FBR.”[16]
ARPANSA have 2 studies demonstrating harm on their website: One to an adult male and the other test on rodents. [13]
So it has been established that children are vulnerable, WiFi effects adults biologically and rodents are a reliable indicator of biological harm to humans.
As we have shown ICNIRP and WHO acknowledge there is a vulnerable community that needs to be considered and this is a task for decision makers to implement and it is not ICNIRP's remit. You are decision makers and need to protect the vulnerable via legislation.
Finally, it is not ethical or acceptable to wait for proof of harm. Especially in the case of children and fetuses who are highlighted as the most vulnerable. The medical community acted in a precautionary manner using ALARA in the case of IR, where it was known that children were vulnerable but evidence was still not clear.
We ask that legislation takes the vulnerable population into serious consideration and refers to the various recommendations made by the Seletun Scientific Panel, the Bioinitiative Report 2012 and the Council of Europe 2011, Resolution 1815 in order to provide an inclusive, accessible and health-smart society for all.
We also ask that consideration be given to the potential risk the vulnerable are exposed to daily now that wireless technology is sold with little monitoring, guidelines for safe use and regulation. We ask that regulation of the use of this technology in public spaces allows for inclusion of the entire community not just the general public.
We ask you to advise us how you plan to incorporate ICNIRP's recommendations for the vulnerable into your legislative instruments.
SUMMARY:
Given the two objectives of the SAR standards:
- reflect current best international practice; and
- provide accurate information regarding exposure to EME from a mobile or wireless device under all possible transmission modes.
We recommend in the interest of children and our vulnerable members that:
- ACMA look to the Bioinitiative Report 2012 for guidelines rather than an outdated standard set in the 60's as the thermal effects of non-Ionizing radiant adopted by ICNIRP; and
- The information regarding possible risks of opening up the spectrum that is available from military and scientific sources be seriously considered by ACMA as well as disseminated with IT services and at high levels of decision making within Australian Educational Institutions.
Further recommendations:
- Material Safety Data Sheet to include warnings for children and safe management handling
- Education for Teachers on how to apply the Airplane mode
- Recommendation to prefer wired options in school settings
- Clear labelling
- Education on safer choices – wired, airplane mode etc
- Monitoring and regulation of wireless devices in the public arena
- Establishment of white zones
- Regulation of where cell phone towers may be located with respect to closeness to schools and aged care homes and hospitals.
- Regulation and guidelines for the use of wireless technologies (2B possible carcinogen) in places inhabited by children, school, day care, home carers, Cinemas, sports centres, play centres, hospitals, medical centres, public transport and aircraft.
- All such information needs to be promoted and made visible to the educators and decision makers in education at all primary, secondary and tertiary institutions in Australia.
Yours sincerely
Dr Julie McCredden
Secretary ES.OZ
on behalf of Karla Tighe
President ES.OZ
References
[1]Scientific Panel on Electromagnetic Field Health Risks: Consensus Points, Recommendations, and Rationales - Scientific Meeting: Seletun,Norway, November 17-21
[2]Council of Europe 2011, Parliamentary Assembly, Resolution 1815 (2011)
[3]Electromagnetic fields (EMF) - World Health Organisation (WHO)
[4]The Bioinitiative Report 2012 - A Rationale for Biologically-based exposure standards For Low Intensity Electro- Magnetic Radiation
[5]Case-control study of the association between malignant brain tumours diagnosed between 2007 and 2009 and mobile and cordless phone use
[6] Pooled analysis of case-control studies on acoustic neuroma diagnosed 1997-2003 and 2007-2009 and use of mobile and cordless phones
[7]Meningioma patients diagnosed 2007–2009 and the association with use of mobile and cordless phones: a case–control study
[8]General Approach to Protection Against Non-Ionnizing Radiation Protection – Published in: Health Physics 82 (4): 540-548; 2002
[9]Electromagnetic fields (EMF) - What the Guidelines cannot account for
[10]Factsheet 14 - How to reduce exposure from mobile phones and other wireless devices
[11] Amended Declaration of Barrie Trower, United States District Court, District of Oregon, Portland Division, 2011 (see attached)
[12a]Safe Schools Report 2012
[12b] A Commentary on Schools & Best Practice EMF Legislation Dr Isaac Jamieson March 2012 Appendix 4 of the Safe Schools report
[13]EMR Literature Survey - November 2011 - Effects of radiofrequency radiation exposure on blood-brain barrier permeability in male and femalerats & Use of laptop computers connected to internet through Wi-Fi decreases human sperm motility and increases sperm DNA fragmentation see items 3 and 4 at
[14] Underestimation of EMF exposure for Children for mobile telephones and for EAS systems. Om P. Gandhi, Department of Electrical & Computer Engineering, University of Utah
[15] ALARA principle: see
[16]Why Scientists Use Rodents in Studies