Petition: No. 235
http://www.oag-bvg.gc.ca/internet/English/esd_pet_235_e_30191.html
Issue(s): Environmental assessment, human health/environmental health, and
science and technology
Petitioner(s): Frank Woodcock
Date Received: 4 January 2008
Status: Reply (replies) pending
Summary: The petitioner is concerned about the guidelines of Safety Code 6 after a cellular tower was installed 300 metres from his property, without any public consultation. The petitioner is concerned about the health effects of the microwave radiation emanating from this tower. He is asking Health Canada and Industry Canada whether it is safe to be exposed to
electromagnetic radiation.
Federal Departments Responsible for Reply: Health Canada, Industry Canada
Petition
Frank Woodcock
35 Tyrell St.
Simcoe, ON
N3Y2H2
January 3, 2008
The Auditor General of Canada Commissioner of the Environment and Sustainable Development
240 Sparks St.
Ottawa, ON
K1A 0G6
Attn. Petitions
Auditor General,
Please accept the following petition under the Auditor General Act.
My neighbours, my family and I live within 300 metres of the Union Street water tower supporting a cell tower. We have lived in the neighbourhood for many years prior to the surprise erection of this cell tower. We are concerned about the health effects of the microwave radiation emanating from this tower and have been unable to find any official, whether municipal, provincial or federal, who can guarantee our physical safety. Also within 300 metres of this cell tower are a school, a nursing home and a hospital.
I have sought help from the Minister of Health Canada, our local school board, the Haldimand/Norfolk health unit, my MPP, my MP, the Director of the Consumer and Clinical Radiation Protection Bureau of Canada and the Director of the Central and Western Ontario District of Industry Canada, with other bureaucrats in between. Throughout this process there has been no official willing to guarantee the safety of living within 300 metres of this cell
tower.
I asked Malcolm S. Lock, Acting Medical Officer of Health, Haldimand-Norfolk Health Unit, "As medical officer of health I request your looking into medical complaints in my neighbourhood. His response, "The Health Unit has not been advised of any health issues within city limits. Everyone within the municipality is serviced by the municipal water supply with potable water therefore ground water contamination is not an issue for consumption.
To my knowledge there has been no air quality issues reported. This leaves little within the jurisdictions of the Health Unit to investigate. I would remind you that air quality lies within the purview of the Ministry of Environment as does ground soil issues..."
Canadians are supposed to be protected from electromagnetic radiation (EMR) by Safety Code 6 (SC6), a guideline under the supervision of the Consumer and Clinical Radiation Protection Bureau of Canada (CCRPB) under the leadership of [name withheld]. When I asked [name withheld] if health issues relating to the cell tower were Health Canada's (HC) purview, he replied, ".this is a public health issue that needs to be addressed locally."
1) Who is responsible for the health of individuals affected by proximity to a cell tower?
[Name withheld] stated, "As indicated previously, this is a public health question that needs to be addressed locally. From your earlier correspondence I understand that you have raised this with the city. While they may not be able to attribute cause to any symptoms or illnesses
reported by the residents, it seems to me reasonable that they can survey and validate the claims stated by the citizens. Analysis of the symptoms, pattern of illness etc. would add to the understanding of the situation."
2) Considering the health concerns of the community within the vicinity of the Simcoe cell tower, would HC provide continuous health monitoring of nearby citizens?
When asked if it is safe to live within 300 metres of a cell tower, [name withheld] replied, "In all risk assessment scenarios, one looks to establish levels that are hazardous or dangerous as these are relatively easily determined. One first chooses an adverse health outcome for which a known
mechanism of interaction of the hazardous agent exists and then a determination of the level of exposure that will cause the outcome is made.
The final step is to set exposure limits that will be protective against these particular adverse health outcomes. In subsequent monitoring and review of the emerging science around the hazard under consideration, one strives to confirm or modify as necessary these previously determined levels. This is, in simple terms, the approach taken in establishing the levels indicated in the current standard for exposure limits for wireless communication devices.
In the specific issue at hand, the exposure limits for radiation fields arising from wireless communication towers have been determined in the manner outlined above taking into consideration the collective body of peer-reviewed science. No adverse health outcomes that have an accepted causal relationship to exposure to the electric and magnetic fields produced
by the towers have been identified for exposures at or below the limits set out in SC6."
3) I do not consider [name withheld] response an adequate answer and would simplify the question by rephrasing, "Are the residents in the vicinity of the Union Street Cell Tower in Simcoe, Ontario as safe today as they were before the cell tower was enabled?"
According to the SC6 document posted on the government website, it has not been updated since 1999. Given the very recent explosion in popularity of cell phones, wireless internet, and other such devices, it is probably not an exaggeration to estimate that we are now being exposed to levels of electromagnetic radiation at levels thousands of times higher than we were in 1999.
4a) Why has SC6 not been updated since 1999? If it has not been updated, why not?
4b) If it has been updated does it include any of the above findings?
The particular cell tower in question is atop a water tower. I assume [name withheld] scientists have taken water towers into account in SC6. This water tower is also a 3042 watt microwave cell tower. Water flows in and out of the water tower like a river. This river is encased in metal, almost an inside-out parabola. The water is flowing in this large metal case (refer to SC6 about large metal objects). The case is encircled with electricity going to the eight antennae. A microwave dish is attached to the tower. Microwaves constantly bombard the water tower. All this is in the middle of a residential community that includes a hospital, nursing home and elementary school.
5a) I ask Industry Canada (IC) and HC if such a tower is safe from a physics, electrical,.point of view?
5b) Would such a tower meet IEEE standards?
5c) Is it grounded properly?
5d) Who has verified the grounding?
5e) What part do metal objects play in the reflection of microwaves?
5f) Why does SC6 warn against large metal objects and then place a microwave on a large metal object?
5g) What is the appropriate SC6 signage for such a structure?
5h) Is this tower properly signed?
5i) What is the appropriate SC6 fencing for such a structure?
5j) Has such fencing been installed?
5k) What part does flowing water play in the reflection of microwaves?
Residents in Bayview, Long Island, NY, have gone to the Supreme Court over a cell tower located near a park and school. Four Bayville Primary School children have been diagnosed with leukemia or brain tumors; three of the children have since died. In addition, six teachers and several school aids have been diagnosed with serious cancer. Four of the adults have
subsequently died.
Dr. Andrew Goldsworthy, Biological Sciences, writes, "Being exposed to chronic irradiation from a cell tower is not a good idea anyway, but to put the antennas on water towers is particularly bad because of the risk of electromagnetic contamination of the water. Treating water with weak pulsed electromagnetic radiation is the basis of many commercial "electronic water conditioners", which are now widely used to remove and prevent lime scale in plumbing.
But it also has biological effects. Brief exposure of the water to such fields (as when it flows through a conditioner) and supplying it to yeast, plants and farm animals can, stimulate their growth. However, when we tested exposures of more than about a minute (as it might be in a water storage tank with an antenna attached), we found that it inhibited the growth of
yeast and was arguably harmful (See Goldsworthy et al. 1999 "Biological effects of physically conditioned water". Water Research 33 (7) 1618-1626).
The mechanism of the conditioning effect is controversial, but it appears to depend on the presence of colloidal impurities, and not all water supplies are equally affected. Its biological effect is probably because it removes structurally-important calcium ions from cell membranes in much the same way as it removes lime scale from plumbing. This would then make them leak and affect metabolism in the same way as direct exposure to electromagnetic fields (See http://tinyurl.com/28Lo82 ).
In so much as water treated with pulsed electromagnetic radiation can have unusual and sometimes harmful biological effects, there should be a moratorium on placing cell phone antennas on water tanks until electromagnetically treated water has received full FDA approval."
6a) Is HC aware of Dr. Goldsworthy's work?
6b) Why is his work not included in SC6?
6c) Why does Industry Canada give preference to siting cell towers on water towers?
6d) What science does Industry Canada cite for such a preference?
The residents were never consulted on the siting of the cell tower and many have become ill, many seek medical attention and are on medications. [Name withheld] SC6 tells us the tower is safe. Our bodies tell us differently.
Soon after the tower was erected, one family was forced from their home due to illness. Their home lies within the shadow of the tower. The husband has been diagnosed with electro-hypersensitivity (EHS) by a specialist. [Name withheld] and his scientists will tell you that EHS sufferers have not been proven sensitive to low-level radiation.
Is it within the Canadian Government's ethical standards to erect such a controversial tower?
Whereas Safety Code 6 is 8 years old and in dire need of being updated, the BioInitiative Report (2007) is a very recent document compiled by an international working group of scientists, researchers and public health policy professionals. The document presents serious scientific concerns about current limits that regulate exposure to EMFs from power lines, cell phones, and many other sources. The excerpt below gives an excellent overview of the current problem:
"You cannot see it, taste it or smell it, but it is one of the most pervasive environmental exposures in industrialized countries today.
Electromagnetic radiation (EMR) or electromagnetic fields (EMFs) are the terms that broadly describe exposures created by the vast array of wired and wireless technologies that have altered the landscape of our lives in countless beneficial ways. However, these technologies were designed to maximize energy efficiency and convenience; not with biological effects on people in mind. Based on new studies, there is growing evidence among scientists and the public about possible health risks associated with these technologies.
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.
In some cases, this can cause discomfort and disease. Since World War II, the background level of EMF from electrical sources has risen exponentially, most recently by the soaring popularity of wireless technologies such as cell phones (two billion and counting in 2006), cordless phones, WI-FI and WI-MAX networks. Several decades of international scientific research confirm that EMFs are biologically active in animals and in humans, which could have major public health consequences.
Today's public exposure limits for telecommunications are based on the presumption that heating of tissue (for RF) or induced electric currents in the body (for ELF) are the only concerns when living organisms are exposed to RF. These exposures can create tissue heating that is well known to be harmful in even very short-term doses. As such, thermal limits do serve a purpose. For example, for people whose occupations require them to work around radar facilities or RF heat-sealers, or for people who install and service wireless antenna tower, thermally-based limits are necessary to prevent damage from heating (or, in the case of power-frequency ELF from induced current flow in tissues).
In the past, scientists and engineers developed exposure standards for electromagnetic radiation based on what we now believe are faulty assumptions that the right way to measure how much non-ionizing energy humans can tolerate (how much exposure) without harm is to measure only the heating of tissue (RF) or induced currents in the body (ELF).
In the last few decades, it has been established beyond any reasonable doubt that bioeffects and some adverse health effects occur at far lower levels of RF and ELF exposure where no heating (or induced currents) occurs at all; some effects are shown to occur at several hundred thousand times below the existing public safety limits where heating is an impossibility."[1]
7a) Does the CCRPB agree with the above statements?
7b) What in particular causes the disagreement and how can the disagreement be proved 100%, with no doubts?
Speaking earlier this year in San Francisco, Dr. M Havas said, "The Federal Communications Commission (FCC) (22) Guideline is similar to the international guideline ICNIRP guideline (15) and is based on short-term thermal effects. This guideline is based on the assumption that if microwave energy does not heat tissue it is not harmful. This assumption is incorrect.
Adverse biological effects have been documented at levels below federal guidelines and there are no federal guidelines for non-thermal effects, nor are there guidelines for long-term exposure. The technological developments and uses of wireless devices are running well ahead of the policy decisions necessary to ensure their safety."
According to Norbert Hankin, Environmental Scientist, U.S. Environmental Protection Agency:
"The U.S. Federal Communications Commission, (FCC's) exposure guidelines is considered protective of effects arising from a thermal mechanism but not from all possible mechanisms. Therefore, the generalization by many that the guidelines protect human beings from harm by any or all mechanisms is not justified." (http://www.protectschools.org/epa%20letter.pdf)
Organizations that set safety standards such as ANSI/IEEE or ICNIRP are quick to point out that "safe" radio frequency exposure rests on the fact that exposure is too weak to produce a rise in body temperature, or a "thermal" effect. Whether non-thermal effects occur is no longer the issue, the issue is at what level do these non-thermal effects occur and what are the safe levels of long-term exposure."[2]
8a) Does SC6 take into account non-thermal effects and long term exposure?
8b) What are the studies to back this claim?
Canada is subject to guidelines enforced by Industry Canada but generated by HC under the document SC6. There are only 3 sentences referencing biological effects in the whole document. It references biological effects thus: "Biological effects of RF fields at levels too low to produce significant heating have also been reviewed (3,6). These effects are not well established, nor are their implications for human health sufficiently well understood. Thus, they cannot provide a basis for making recommendation towards the restriction of human exposures to such low-intensity RF fields."
9) In a document as important to the safety of Canadians as SC6, why are there only 3 sentences referring to biological effects? How in the light of all the studies can it be said, "These effects are not well established, nor are their implications for human health sufficiently understood?"
Their references 3 and 6 are as follows:
3) World Health Organization. Environmental Health Criteria 137:
Electromagnetic Fields (300 Hz - 300 GHz), 1993 (Available from: WHO,
Geneva, or Canadian Public Health Association, Ottawa, Ontario)
6) M.H. Repacholi. Low-Level Exposure to Radiofrequency Fields: Health
Effects and Research Needs. Bioelectromagnetics, Vol. 19, pp. 1-19, 1998.
10) With the biological effects of radiation so important, how can a document as important as SC6 have only two references to biological effects?
Note the first reference is dated 1993 and both involve Dr. Michael Repacholi. In the first study he was chairman of the study while at the Royal Adelaide Hospital, the second study while heading the Project into EMFs by the WHO. He was also emeritus chairman of ICNIRP, the body charged with setting "safe" International Exposure limits.
While leading the WHO EMF project Repacholi funneled industry donated money through the Royal Adelaide Hospital to the WHO. Seven years ago, Norm Sandler, a Motorola spokesman said, "This is the process for all supporters of the WHO program." At the time Motorola was sending $50,000 each year and the Mobile Manufacturers Forum gave the project $150,000 a year. (Microwave News)
A WHO Progress Report lists its funding as follows: Income: $249,682
Governments, $529,820 others, for a total USD of $779,502. If the "Others" listed above were sourced from the Royal Adelaide Hospital (industry), then only less than 1/3 of the WHO EMF funding came from Governments around the world." (Microwave News)
Despite the UK Health Protection Agency's own advice that children under 16 should use mobile phones and other wireless equipment as little as possible because they are more prone to harm from them, Dr. Repacholi promoted wireless/microwave emitting devices to children at the Handheld Learning Conference, 10-12 October, 2007 in London, England.
11a) Mr. Repacholi was chairman of the Royal Adelaide Hospital studies, WHO studies, and chairman emeritus of ICNIRP. He has had great influence on world-wide standards for EMFs. Mr. Repacholi has ties to Industry. Did Mr. Repacholi at any time work for HC?
11b) What was his position?
11c) What influence did he have in the creation of SC6?
In a correspondence [name and position withheld], HC, wrote, "SC6 limits are based on both thermal and non-thermal effects. For frequencies from 3 kHz to 100 kHz, the biological endpoint on which the limits are based is nerve and muscle stimulation. Although these are acute effects, they are non-thermal in nature. At higher frequencies, non-thermal effects have not been
convincingly demonstrated. Thus, they have not been accepted by either this Bureau or other international bodies such as ICNIRP and IEEE to be used as a basis for setting exposure limits. SC6 is protective of the identified non-thermal effect indicated above."
12a) Are there frequencies below 3kHz? What happens biologically at frequencies below 3 kHz?
12b) Exactly how is SC6 protective of non-thermal effects?
[Name wihheld] also says, "In addition, the biological tests that have been used in our examination of non-thermal effects are standard toxicological assays that are used throughout the scientific world for examining the effects of a multitude of environmental toxins. They are used primarily to detect damage to the genetic material in cells exposed to toxic agents.
Before each test is applied, it is checked for sensitivity against agents such as a known dose of x-rays, which has a clearly defined and quantifiable effect on the genetic material in the cells. In this way, it is assured that the tests are able to detect any damage to the cells caused by electromagnetic radiation." And, "To date, experimental and epidemiological studies throughout the world have failed to provide clear support for a causal relationship between electromagnetic fields and complaints. The experimental studies strongly suggest that EHS symptoms are not related to actual exposures to electric or magnetic fields, and that electromagnetically hypersensitive individuals are no better than non-hypersensitive individuals in detecting the presence of EMF. EHS has no clear diagnostic criteria and there is no scientific basis to link
electromagnetic hypersensitivity symptoms to EMF exposure.
At this time, neither HC nor the WHO recognize that symptoms attributed to EHS from low-level RF fields (as located around cell towers) are causally related to RF field exposure."
13a) I ask HC to name 3 such studies.
13b) What part did industry play in these studies?
13c) What was the background of the scientists running the study? Did any of them have a background in EHS?
13d) Did any of the scientists suffer and therefore understand EHS?
13e) Why would anyone with EHS put themselves through the pain of a study?
13f) Were EHS sufferers consulted on the design of the study?
13g) Most importantly, how many EHS dropped out of the study? How did these drop-outs influence the results of the study?
In the report, "Electrohypersensitivity (EHS) in the Netherlands - A Questionnaire survey" by Hugo Schooneveld and Juliette Kuiper of the Dutch Electrohypersensitivity (EHS) Foundation, December 2007, they state "Some persons have become electrosensitive and respond to some specific EMFs in their environment and show some of the possible health effects induced by
their personal stress system.One of the main problems is that many people with EHS symptoms have no idea which type of EMF -if any- is specifically annoying to him or her. This is caused by the length of time usually elapsing between EMF exposure and health effect: several hours is not unusual (Schooneveld and Arends-Zimmermann, 2006). One simply does not see the connection.The point never contemplated so far is that EHS is a problem of the individual, not of a group. We all tend to expect the classical picture of an illness: much like measles would make the skin of children appear reddish, and influenza would elevate body temperature, we expect a
similar marker for EHS. An obvious marker apparently does not exist so far and we should perhaps stop looking for physically recognizable signs of EHS.There have been quite a few studies in which EMF sensitive and non-sensitive volunteers were exposed to high-frequency EMFs, signals mimicking those of GSM or UMTS transmitters. The question was whether EHS
people could demonstrate -under controlled conditions- that they could `feel' whether the transmitter was `on' or `off''.The outcome was mostly negative and authors like Rubin et al. (2006) and others conclude that there was no evidence for an EMF-feeling talent. The present data show that the situation is more complex: not all EHS people will react to high-frequency
EMFs. In future experiments, more attention should be paid to the specific conditions under which EHS can be demonstrated by individual volunteers.Therefore, it seems essential that volunteers participating in such studies should be selected with care and questioned in detail about their personal experiences. Exposure conditions should be adjusted to those individual preferences."
14) Were the above characteristics of EHS sufferers taken into account in the EHS studies cited by [name withheld]?
As mentioned, soon after the tower was erected, one family was forced from their home within the shadow of the tower. The husband has been diagnosed with electro-hypersensitivity (EHS) by specialists. [Name withheld] and his scientists will tell you that EHS sufferers have not been proven sensitive to low-level radiation. [Name withheld] states that "At this time, neither
HC nor the WHO recognize that symptoms attributed to EHS from low-level RF fields (as located around cell towers) are causally related to RF field exposure."
15) When a family is forced from their home due to policies set forth by HC and implemented by IC, what government instituted recourse do they have to regain their family home?
In 1998, 1/3 of Canadian households owned a computer and today the figure is 70%. Canadian cell phone users have increased from 98,000 in 1987 to 18,000,000 to-day (Ottawa Citizen). In 1999, worldwide there were 86.1 million cell phones (World Almanac and book of facts 2001.571). 3 billion are in use today (Reuters). Although I have no statistics for Toronto, the
city of San Francisco, with an area of only seven square miles, has over 2,500 licensed cell phone antennas positioned at 530 locations throughout the city. In practical terms, this city, like thousands of others, is being wave-nuked 24 hours day.
(http://www.globalresearch.ca/index.php?context=va&aid=7025)
16a) How many towers were in Canada in Jan 2000? How many towers are in Canada today? How many towers are projected for Canada in 2010?
16b) How many people are subjected to cell tower radiation ½ hour a day; 8 hours a day and 24 hours a day?
Of the references used in Safety Code 6, 29 are from the 1990's, 14 from the 1980's and 6 pre 1980. There are no references beyond the year 2000 when Canada experienced an explosion of cell tower construction. Of the references in Magda Havas' paper, 17 are dated between 2000-2004, 20 in the 1990's and 3 are from between 1988-89.
17a) Why are there so few studies referenced in SC6?
17b) When is the next published update?
The following studies are not referenced in SC6.
1) Santini et al. (2002). A study of the health of people living in the vicinity of mobile phone base stations. Pathologie Biologies, 50, 369-373 Investigation on the health of people living near mobile telephone relay stations: Incidence according to distance and sex.
A survey study, using questionnaire was conducted in 530 people (270 men, 260 women) living or not in the vicinity of cellular phone base stations, on 18 Non Specific Health Symptoms. Comparisons of complaints frequencies (CHI-SQUARE test with Yates correction) in relation with distance from base station and sex, show significant (p < 0.05) increase as compared to people living > 300 m or not exposed to base station, till 300 m for tiredness, 200 m for headache, sleep disturbance, discomfort, etc. 100 m for irritability, depression, loss of memory, dizziness, libido decrease, etc. Women significantly more often than men (p < 0.05) complained of headache, nausea, loss of appetite, sleep disturbance, depression, discomfort and visual
perturbations. This first study on symptoms experienced by people living in vicinity of base stations shows that, in view of radioprotection, minimal distance of people from cellular phone base stations should not be < 300 m.
2)
The result of the study shows that the proportion of newly developing cancer cases was significantly higher among those patients who had lived during the past ten years at a distance of up to 400 metres from the cellular transmitter site, which bas been in operation since 1993, compared to those patients living further away, and that the patients fell ill on average 8 years earlier.
In the years 1999-2004, i.e. after five years' operation of the transmitting installation, the relative risk of getting cancer had trebled for the residents of the area in the proximity of the installation compared to the inhabitants of Naila outside the area.
3) Ecolog, 2000, T-Mobile\Ecolog Institute - Mobile Communications and health; review of current scientific research in view of precautionary health.
This review of over 220 peer-reviewed and published papers found strong indications for the cancer-initiating and cancer-promoting effects of high frequency electromagnetic fields used by mobile telephone technology. Experiments on cell cultures at power flux densities much lower than the guidelines, yielded strong indications for genotoxic effects of these fields, like single and double stranded DNA breaks and damage to chromosomes. The findings that high frequency electromagnetic fields influence cell transformation, cell growth promotion and cell communication also point on a carcinogenic potential of the fields used for mobile telephony. The study also found teratogenic effects (birth deformities) and loss of fertility in animal studies. Moreover, disruptions of other cellular processes, like the synthesis of proteins and the control of cell functions by enzymes, have been demonstrated.
4) BioInitiative Report, Aug, 2007 - An international working group of scientists, researchers and public health policy professionals (The BioInitiative Working Group) released a report on electromagnetic fields (EMF) and health. They document serious scientific concerns about current limits regulating how much EMF is allowable from power lines, cell phones, and many other sources of EMF exposure in daily life. The report concludes the existing standards for public safety are inadequate to protect public health.
18) When will these studies be reflected in SC6?
According to [name withheld], "SC6 limits are based on both thermal and non-thermal effects. For frequencies from 3 kHz to 100 kHz, the biological endpoint on which the limits are based is nerve and muscle stimulation. Although these are acute effects, they are non-thermal in nature. At higher frequencies, non-thermal effects have not been convincingly demonstrated. Thus, they have not been accepted by either this Bureau or other international bodies such as ICNIRP and IEEE to be used as a basis for setting exposure limits. SC6 is protective of the identified non-thermal effect indicated above."
19) How does HC reconcile [name withheld] words with the above studies?
[Name withheld] makes the claim that studies are considered as long as they are "referenced in the context of peer-reviewed publications".
20a) Why are the studies listed in the above ignored?
20b) They are all valid studies, and they all show biological effects at levels many, many times below Safety Code 6. I would like an explanation as to why the studies listed above have not played a role in informing HC's policies?
Of the studies referenced in SC6, all before 2000, there are no acknowledgements of EHS symptoms relating to EMR.
Regarding EHS, Dr. Havas writes, "Symptoms of EHS include: cognitive dysfunction (memory, concentration, problem-solving); balance, dizziness & vertigo; facial flushing, skin rash; chest pressure, rapid heart rate; depression, anxiety, irritability, frustration, temper; fatigue, sleep disruptions; body aches, headaches; ringing in the ear (tinnitus) and are consistent with chronic fatigue and fibromyalgia.
`Electro hypersensitivity (EHS) is now recognized by the World Health Organization (WHO) and is defined as: ". . . a phenomenon where individuals experience adverse health effects while using or being in the vicinity of devices emanating electric, magnetic, or electromagnetic fields (EMFs). . . Whatever its cause, EHS is a real and sometimes a debilitating problem for the affected persons, while the level of EMF in their neighborhood is no greater than is encountered in normal living environments. Their exposures are generally several orders of magnitude under the limits in internationally accepted standards.'
EHS is classified as a disability in
21) On what basis can SC6 ignore these facts?
22) What is the cost to the Canadian health care system of EHS? Why are there no statistics on the cost to the Canadian health care system of EHS?
I have neighbours within 300 metres of a cell tower who are not in the 2% of the highly sensitive and they visit their doctors concerning cognitive dysfunction (memory, concentration, problem-solving); balance, dizziness & vertigo; facial flushing, skin rash; chest pressure, rapid heart rate; depression, anxiety, irritability, frustration, temper; fatigue, poor sleep; body aches, headaches; ringing in the ear (tinnitus) and are consistent with chronic fatigue and fibromyalgia.
23) Why are there no HC initiatives to recognize EHS? What is HC doing to inform the general public and physicians of EHS?
The Santini, Naila, Ecolog and BioInitiative studies are just the tip of a multitude of similar studies. The Bioinitiative Reoprt alone has over 600 pages and 1387 references covering multiple topics relating to electromagnetic radiation (EMR) or electromagnetic fields (EMF's).
24) I have talked to CCRPB's scientists and they pooh-pooh these studies. They can cite opposing views, and yet by conceding the existence of opposing views, is it not logical to conclude that doubt exists in the science?
When it was pointed out that
25) If the precautionary principle is referred to by [name withheld] as "social policy considerations" why are we not taking it into account in
It is because of this doubt I reference the precautionary principle.
The precautionary principle is a moral and political principle which states that if an action or policy might cause severe or irreversible harm to the public, in the absence of a scientific consensus that harm would not ensue, the burden of proof falls on those who would advocate taking the action. As taken from the Canadian government pamphlet on the precautionary principle - http://www.ec.gc.ca/econom
26) Was the precautionary principle used in the formulation of SC6?
The Vorsorgeprinzip, or "foresight" principle, only emerged as a specific policy tool during the German debates on the possible role of air pollution as a cause of "forest death" in the 1970-80s. However, [name withheld], one of Bush's science policy advisors, and trenchant critic of the precautionary principle, has noted that:
"Precaution, whether or not described as a formal principle, has served mankind well in the past and the history of public health instructs us to keep the spirit of precaution alive and well". ([Name withheld] 2002).
[Name withheld] might have been thinking of the cholera episode of 1854 when precaution did indeed serve the people of
The
Some measures that could help limit the consequences of ignorance and the impacts of surprises are:
a.. using intrinsic properties as generic predictors for unknown but possible impacts e.g. the persistence, bioaccumulation and spatial range potential of chemical substances. (Stroebe et al., 2004)
b.. reducing specific exposures to potentially harmful agents on the basis of credible `early warnings' of initial harmful impacts, thus limiting the size of any other `surprise' impacts from the same agent, such as the asbestos cancers that followed asbestosis; and the PCB neurotoxicological effects that followed its wildlife impacts.
c.. promoting a diversity of robust and adaptable technological and social options to meet needs, which limits technological `monopolies' (such as those like asbestos, CFCs, PCBs etc.), and therefore reduces the scale of any `surprise' from any one technological option.
d.. using more long-term research and monitoring of what appear to be "surprise sensitive sentinels", such as frogs and fetuses.[1]
27a) Does HC use intrinsic properties as generic predictors for unknown but possible impacts e.g. the persistence, bioaccumulation and spatial range potential of chemical substances when formulating SC6?
27b) Does HC reduce specific exposures to potentially harmful agents on the basis of credible `early warnings' of initial harmful impacts, thus limiting the size of any other `surprise' impacts from the same agent, such as the asbestos cancers that followed asbestosis; and the PCB neurotoxicological effects that followed its wildlife impacts when formulating SC6?
27c) Does HC promote a diversity of robust and adaptable technological and social options to meet needs, which limits technological `monopolies' (such as those like asbestos, CFCs, PCBs etc.), and therefore reduces the scale of any `surprise' from any one technological option when formulating SC6?
27d) Does HC use more long-term research and monitoring of what appear to be "surprise sensitive sentinels", such as frogs and fetuses when formulating SC6?
The distinction between prevention and precaution is also important. Preventing hazards from "known" risks is relatively easy and does not require precaution.
Banning smoking, or asbestos, today requires only acts of prevention to avoid the well-known risks. However, it would have needed precaution, (or foresight, based on a sufficiency of evidence), to have justified acts to avoid exposure to the then uncertain hazards of asbestos in the 1930s -50s, or of tobacco smoke in the 1960's). Such precautionary acts then, if implemented successfully, would have saved many more lives in
28a) How is foresight used to formulate SC6?
28b) Does the existing strength of evidence justify precautionary actions now?
28c) Or will exposure reduction be delayed until the evidence is clear enough to justify the more belated and overall less protective prevention of "known" causes, so that EMF replicates the fate of asbestos, smoking and most of the other cases in the EEA report?
The key to understanding the added value of the PP requires a) acknowledging the distinction between prevention and precaution described above; b) an appreciation of the further distinctions between the primary, secondary and tertiary preventative measures that have long between adopted in public health, and the prior justification for any such measure, which the PP brings; and c) a recognition of the increased legitimacy and transparency that arises from the articulation and adoption of the PP in legal texts, international agreements and conventions, as opposed to being merely part of general practice.
More empirically, the evidence that many scientific disciples, legal scholars (de Sadeleer, 2007),and international policymakers, have, since the 1970s, recognized the need for legitimizing the PP as a new policy tool that is better able to deal with systems complexities, ignorance and uncertainties, suggests that the PP brings added value to the protection of the environment and the public.
There is much discussion generated by the different meanings often attached to the common terms "prevention", "precaution", "risk", "uncertainty" and "ignorance".
There are some relatively rare but successful acts of "precautionary prevention" in the EEA report such as on cholera in1854, on TBT in
29) The failure to use the precautionary principle in the other case studies (EEA, 2001), these illustrate the wisdom of taking appropriate precautionary actions to avoid plausible and serious threats to health or environments, especially when the impacts are irreversible and likely to be much more costly to society than the precautionary measures. When it comes to EMR is there wisdom to change SC6 to reflect new information?
Some commentators have stressed the need for policymakers to take account of the foreseeable, or plausible, countervailing (secondary) costs of otherwise genuine precautionary attempts to protect the environment and health. This consideration of countervailing costs has long been recognized by the better policymakers, even if it is difficult in practice to anticipate and account for all consequences of actions. And of course there are the secondary benefits of precautionary actions as well, which tend to be less stressed, such as the benefit of reduced respiratory and cardiovascular disease from the reduced combustion of fossil fuels: a large and early secondary benefit of that climate change measure.
The outcomes of some controversial actions based on the PP, such as the EU ban on antibiotics as growth promoters, which is a Late Lessons case study, have since been scrutinized, and have been considered sound ,or unsound, depending on the science used and its interpretation by different interests.
Any policy effectiveness analysis of measures taken to deal with such multi-causal and long term hazards as antibiotics as growth promoters is fraught with methodological difficulties and is hampered by long latencies and complex biological systems: untangling the causal impact of one stressor amongst many inter-dependent ones is virtually impossible. The value of applying more probabilistic and value of information data to such conundrums is recognized by many risk managers. However, this cannot remove the need for scientific and political judgment about how to take appropriate and proportionate action in the face of irreducible uncertainties, ignorance and plausible hazards which could have serious, widespread and irreversible impacts and for which probabilities are not possible at the time when they are most needed. This is the current case with many EMF exposures. [1]
30a) Would the CCRPB scientists agree with this statement?
30b) If not, specifically why not?
30c) If yes, specifically what parts of the statement do they agree with?
30d) Does SC6 take into account the foreseeable, or plausible, countervailing (secondary) costs of otherwise genuine precautionary attempts to protect the environment and health?
The increasing awareness of complexity and uncertainty during the 1980/90's led to the German debates on the Vorsorgeprinzip shifting to the international level, initially in the field of conservation (World Charter for Nature UN 1982), but then particularly in marine pollution, where an overload of data accompanied an insufficiency of knowledge. (Marine Pollution Bulletin, 1997) This generated the need to act with precaution to reduce the large amounts of chemical pollution entering the
Since then many international treaties have included the PP (including the often cited version from the Third North Sea Ministerial Conference, 1990) reference to the precautionary principle, or, as they refer to it in the
The N. Sea declaration called for "action to avoid potentially damaging impacts of substances, even where there is no scientific evidence to prove a causal link between emissions and effects".
This definition has often, and sometimes mischievously, been used to deride the precautionary principle by claims that it appears to justify action even when there is "no scientific evidence" that associates exposures with effects. However, the N. Sea Conference definition clearly links the words "no scientific evidence" with the words "to prove a causal link". We have already seen with the
31a) Is there enough evidence to establish a causal link between EMR and cell damage?
31b) "Where there is uncertainty as to the existence or extent of risks to human health, the institutions may take protective measures without having to wait until the reality and seriousness of those risks become fully apparent" (Christoforou, 2002). Would the CCRPB agree with this statement? Would the CCRPB take this into account when formulating SC6?
31c) How are developing children taken into account in SC6?
31d) EHS is irreversible, is this irreversibility taken into account in SC6? If SC6 does not protect from citizens developing EHS, is HC legally liable? Would scientists who have suppressed this information be legally liable? Would they be fired?
31e) Is the goal of SC6 to protect public health, consumer safety and the safety of the environment? Is the consumer given a high, medium or low "balance of evidence or probability" when formulating SC6 guidelines? Since the broad shoulders of the telecommunications industry are able to bear the costs of mistaken judgments rather better than the much narrower shoulders of the injured citizen, should the citizen be given broader leeway when determining safety standards such as SC6?
31f) Is it possible to use different levels of proof when formulating SC6?
31g) How robust, and over what periods of time, does the evidence on the absence of harm have to be before concluding that a restricted substance or activity is without significant risk?
31h) Why is the bias within SC6 towards avoiding "false positives", thereby generating more "false negatives", and the dominance within decision-making of short-term, specific, economic and political interests over the longer term, diffuse, and overall welfare interests of society?
31i) Are HC conducting any long term studies on EMR and young children? If not, why not?
[Name witheld], July 13, 2007 wrote. "To date, experimental and epidemiological studies throughout the world have failed to provide clear support for a causal relationship between electromagnetic fields and complaints."
Bradford Hill established nine criteria for helping to move from association to causation in environmental health which have been, and still are, widely used in debates on issues such as EMF. Two of the apparently more robust of the "criteria" may not be so robust in the context of multi-causality, complexity and gene/host variability. For example, "consistency" of study findings is not always to be expected. As Prof. Needleman, who provided the first of what could be called the second generation of early warnings on lead in petrol in 1979 has observed: It follows that the presence of consistency of results between studies on the same hazard can provide robust evidence for a causal link, but the absence of such consistency may not provide very robust evidence for the absence of a real association. In other words, the "criterion" of consistency is asymmetrical, like most of the other Bradford Hill "criteria". [1]
32a) Are every decision of HC based on causality?
32b) What determines how causality is used in HC's decision making?
33c) Why are HC decisions on EMR pinned to causality when the absence of consistency may not provide very robust evidence for the absence of association?
Similarly, the criterion of "temporality", which says that the putative cause X of harm Y must come before Y appears, is robust in a simple, uni-causal world. In a multi-causal, complex world of common biological end points that have several chains of causation this may not necessarily be so. For example, falling sperm counts can have multiple, co-causal factors, some of which may have been effective at increasing the incidence of the biological end point in question in advance of the stressors in focus, thereby confusing the analysis of temporality. The resulting overall sperm count trends could then be rising, falling or static, depending on the combined direction and strengths of the co-causal factors and the time lags of their impacts. It follows that say, chlorine chemicals, may or may not be co-causal factors in falling sperm counts: but the use of the "temporality" argument by the WHO, who observed that sperm counts began to fall before chlorine chemistry production took off, does not provide robust evidence that they are not causally involved. [1]
34a) If people living near cell towers are becoming ill, if HC cannot guarantee their health, if HC does not test for non thermal effects at cell tower sites, then how can they use causality as an excuse to do nothing?
34b) Does HC allow risk managers to provide risk assessors with guidance on the science policy to apply in their risk assessments of SC6?
34c) Does HC do risk analysis? Has a risk analysis been done on SC6? Is HC willing to wait 30-100 years to review the consequences of their actions regarding EMR?
34d) 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. Is this HC's position? If not, why not?
34e) There may be no lower limit at which exposures do not affect us. Until we know if there is a lower limit below which bioeffects and adverse health impacts do not occur, is it unwise from a public health perspective to continue "business-as-usual" deploying new technologies that increase ELF and RF exposures, particularly involuntary exposures?
A WHO definition states that: "(A)nnoyance or discomforts caused by EMF exposure may not be pathological per se, but, if substantiated, can affect the physical and mental well-being of a person and the resultant effect may be considered as an adverse health effect. A health effect is thus defined as a biological effect that is detrimental to health or well-being. According to the WHO Constitution, health is a state of complete physical, mental, and social well-being and not merely the absence of disease or infirmity." www.who.int/peh-emf [1]
35) [Name withheld] states that "At this time, neither HC nor the WHO recognize that symptoms attributed to EHS from low-level RF fields (as located around cell towers) are causally related to RF field exposure." When [name withheld] refers to WHO does he take the above into account?
Environmental Issue Report Number 29 from the World Health Organization (2002) cautions about the effects of radiofrequency radiation on children's health. As part of a publication on "Children's Health and Environment: A Review of Evidence" the World Health Organization (WHO) wrote:
"The possible adverse health effects in children associated with radiofrequency fields have not been fully investigated."
"Because there are suggestions that RF exposure may be more hazardous for the fetus and child due to their greater susceptibility, prudent avoidance is one approach to keeping children's exposure as low as possible."
"Further research is needed to clarify the potential risks of ELF-EMF and radiofrequency fields for children's health." [1]
36a) Does the HC support cell phone use by children and pregnant mothers?
36b) When findings prove EMR is a threat to the health of children will HC recommend age limits for cell phone use as there are age limits for smoking?
36c) Has childhood leukemia increased in
36d) What specifically in SC6 protects children from cancer?
The Parliament of the
Conclusions and recommendations from the Stewart Report (for Sir William Stewart) indicated that the Group has some reservation about continued wireless technology expansion without more consideration of planning, zoning and potential public health concerns. Further, the Report acknowledges significant public concern over community siting of mobile phone and other communication antennas in residential areas and near schools and hospitals.
"Children may be more vulnerable because of their developing nervous system, the greater absorption of energy in the tissue of the head and a longer lifetime of exposure."
"The siting of base stations in residential areas can cause considerable concern and distress. These include schools, residential areas and hospitals."
"There may be indirect health risks from living near base stations with a need for mobile phone operators to consult the public when installing base stations."
"Monitoring should be especially strict near schools, and that emissions of greatest intensity should not fall within school grounds."
"The report recommends "a register of occupationally exposed workers be established and that cancer risks and mortality should be examined to determine whether there are any harmful effects." (IEGMP, 2000) [1]
37a) It may be noted that the Simcoe cell tower is located near a school, hospital and nursing home, let alone the dense residential area. There was no notification given of the erection of the cell tower. Why, with all the warnings about EMR, was there no consideration to resident consultation?
37b) Was this an isolated incident or was it general policy to allow cell towers near hospitals, nursing homes and schools?
37c) The policy of notifying residents begins in January 2008. Will special arrangements be made for schools, hospitals and nursing homes? If not, why not?
The evidence that power lines and other sources of ELF are consistently associated with higher rates of childhood leukemia has resulted in the International Agency for Cancer Research (an arm of the World Health Organization) to classify ELF as a Possible Human Carcinogen (in the Group 2B carcinogen list). Leukemia is the most common type of cancer in children. [1]
38a) Is there doubt that exposure to ELF causes childhood leukemia? Could HC explain?
38b) Is it true there is some evidence that other childhood cancers may be related to ELF exposure but not enough studies have been done?
38c) Children who have leukemia and are in recovery have poorer survival rates if their ELF exposure at home (or where they are recovering) is between 1mG and 2 mG in one /study; over 3 mG in another study. Is this something to be taken into account in SC6?
Factors that determine effects can depend on head shape and size, the location, size and shape of internal brain structures, thinness of the head and face, hydration of tissues, thickness of various tissues, dialectric constant of the tissues and so on. Age of the individual and state of health also appear to be important variables. Exposure conditions also greatly influence the outcome of studies, and can have opposite results depending on the conditions of exposure including frequency, waveform, orientation of exposure, duration of exposure, number of exposures, any pulse modulation of the signal, and when effects are measured (some responses to RF are delayed). There is large variability in the results of ELF and RF testing, which would be expected based on the large variability of factors that can influence test results. However, it is clearly demonstrated that under some conditions of exposure, the brain and nervous system functions of humans are altered. The consequence of long-term or prolonged exposures have not been thoroughly studied in either adults or in children. [1]
39) The consequence of prolonged exposures to children, whose nervous systems continue to develop until late adolescence, is unknown at this time. This could have serious implications to adult health and functioning in society if years of exposure of the young to both ELF and RF result in diminished capacity for thinking, judgment, memory, learning, and control over behavior. What child studies has HC (not others) initiated to investigate the effects of long-term or prolonged exposure?
The National Toxicology Program (NTP) is a part of the National Institute for Environmental Health Sciences, National Institutes for Health. Public and agency comment has been solicited on whether to add radiofrequency radiation to its list of substances to be tested by NTP as carcinogens. In February 2000 the FDA made a recommendation to the NPT urging that RF be tested for carcinogenicity (www.fda.gov.us). The recommendation is based in part on written testimony stating:
" Animal experiments are crucial because meaningful data will not be available from epidemiological studies for many years due to the long latency period between exposure to a carcinogen and the diagnosis of a tumor.
"There is currently insufficient scientific basis for concluding either that wireless communication technologies are safe or that they pose a risk to millions of users."
"FCC radiofrequency radiation guidelines are based on protection from acute injury from thermal effects of RF exposure and may not be protective against any non-thermal effects of chronic exposures."
In March of 2003, the National Toxicology Program issued a Fact Sheet regarding its toxicology and carcinogenicity testing of radiofrequency/microwave radiation. These studies will evaluate radiofrequency radiation in the cellular frequencies.
"The existing exposure guidelines are based on protection from acute injury from thermal effects of RF exposure. Current data are insufficient to draw definitive conclusions concerning the adequacy of these guidelines to be protective against any non-thermal effects of chronic exposures. "[1]
40) The American National Institute for Environmental Health Sciences - National Toxicology Program is considering going away from the acute injury from thermals theory and the short term exposure concept. Is HC considering such a move?
An Assessment of Non-Lethal Weapons Science and Technology by the Naval Studies Board, Division of Engineering and Physical Sciences (National Academies Press (2002) has produced a report that confirms the existence of non-thermal bioeffects from information transmitted by radiofrequency radiation at low intensities that cannot act by tissue heating.
In this report, the section on Directed-Energy Non-Lethal Weapons it states that:
"The first radiofrequency non-lethal weapons, VMADS, is based on a biophysical susceptibility known empirically for decades. More in-depth health effects studies were launched only after the decision was made to develop that capability as a weapon. The heating action of RF signals is well understood and can be the basis for several additional directed-energy weapons. Leap-ahead non-lethal weapons technologies will probably be based on more subtle human/RF interactions in which the signal information within the RF exposure causes an effect other than simply heating: for example, stun, seizure, startle and decreased spontaneous activity. Recent developments in the technology are leading to ultrawideband, very high peak power and ultrashort signal capabilities, suggesting the phase space to be explored for subtle, yet potentially effective non-thermal biophysical susceptibilities is vast. Advances will require a dedicated effort to identify useful susceptibilities."
This admission by the Naval Studies Board confirms several critical issues with respect to non-thermal or low-intensity RF exposures. First, it confirms the existence of bioeffects from non-thermal exposure levels of RF. Second, it identifies that some of these non-thermal effects can be weaponized with bioeffects that are incontrovertibly adverse to health (stun, seizure, startle, decreased spontaneous activity). Third, it confirms that there has been knowledge for decades about the susceptibility of human beings to non-thermal levels of RF exposure. Fourth, it provides confirmation of the concept that radiofrequency interacts with humans based on the RF information content (signal information) rather than heating, so it can occur at subtle energy levels, not at high levels associated with tissue heating. Finally, the report indicates that a dedicated scientific research effort is needed to really understand and refine non-thermal RF as a weapon, but it is promising enough for continued federal funding. [1]
41) Is HC aware of the above information? If not, why not, considering the health implications for Canadians? If yes, why have they withheld it from Canadians by not factoring it in to SC6?
For brain tumors, people who have used a cell phone for 10 years or longer have a 20% increase in risk (when the cell phone is used on both sides of the head). For people who have used a cell phone for 10 years or longer predominantly on one side of the head, there is a 200% increased risk of a brain tumor. This information relies on the combined results of many brain tumor/cell phone studies taken together (a meta-analysis of studies). [1]
42a) People who have used a cell phone for ten years or more have higher rates of malignant brain tumor and acoustic neuromas. It is worse if the cell phone has been used primarily on one side of the head. Does the Canadian government take this information into account when issuing guidelines?
42b) The current standard for exposure to the emissions of cell phones and cordless phones is not safe considering studies reporting long-term brain tumor and acoustic neuroma risks. Is this the position of the Canadian government?
42c) In formulating SC6 Canadian government officials may have ignored relevant studies. In ignoring these studies are the Canadian government scientists negligent? Have they broken any oaths to uphold the safety of Canadians? What process is in place to address negligent Canadian government officials?
It can no longer be said that the current state of knowledge rules out or precludes risks to human health. The enormous societal costs and impacts on human suffering by not dealing proactively with this issue require substantive public health policy actions; and actions of governmental agencies charged with the protection of public health to act on the basis of the evidence at hand. [1]
43a) Why does HC ignore this current state of knowledge? Is it reasonable to conclude that HC would rather err on the side of Industry?
43b) Alzheimer's disease is a disease of the nervous system. There is strong evidence that long term exposure to ELF is a risk factor for Alzheimer's disease. Is this correct or does HC ignore this? Are the doctors, scientists, health care professionals, and beauraucrats all willing to let their fellow Canadians submit to such exposure?
Cancer risk is related to DNA damage, which alters the genetic blueprint for growth and development. If DNA is damaged (the genes are damaged) there is a risk that these damaged cells will not die. Instead they will continue to reproduce themselves with damaged DNA, and this is one necessary pre-condition for cancer. Reduced DNA repair may also be an important part of this story. When the rate of damage to DNA exceeds the rate at which DNA can be repaired, there is the possibility of retaining mutations and initiating cancer. [1]
44a) A person like myself who lives 90% of his time within 300 metres of a cell tower is bombarded by microwaves day after day after day. What are the effects of such close bombardment?
44b) Does the bombardment bounce off the skin? Does the bombardment pass through the body? On average how much of the bombardment penestrates the skin? To what depth? Does it dissipate? Does it just sit there? Does it interact with the body in any way? Does it affect cellular structure? Is the bombardment benign?
44c) If there is any penetration of the skin and if there is some doubt whether or not it might be harmful, should the precautionary principle be applied?
44d) For a person living 90% of their time within 300 metres of the Simcoe cell tower, how many units of radiation is the person bombarded with per day/per year/per lifetime?
In nearly every living organism, there is a special protection launched by cells when they are under attack from environmental toxins or adverse environmental conditions. This is called a stress response, and what are produced are stress proteins (also known as heat shock proteins).
Plants, animals and bacteria all produce stress proteins to survive environmental stressors like high temperatures, lack of oxygen, heavy metal poisoning, and oxidative stress (a cause of premature aging). We can now add ELF and RF exposures to this list of environmental stressors that cause a physiological stress response. [1]
45) Very low-level ELF and RF exposures can cause cells to produce stress proteins, meaning that the cell recognizes ELF and RF exposures as harmful. This is another important way in which scientists have documented that ELF and RF exposures can be harmful, and it happens at levels far below the existing public safety standards. What studies does HC have to refute this statement?
The immune system is another defense we have against invading organisms (viruses, bacteria, and other foreign molecules). It protects us against illness, infectious diseases, and tumor cells.
There are many different kinds of immune cells; each type of cell has a particular purpose, and is launched to defend the body against different kinds of exposures that the body determines might be harmful. [1]
46) There is substantial evidence that ELF and RF can cause inflammatory reactions, allergy reactions and change normal immune function at levels allowed by current public safety standards. Oxidative stress through the action of free radical damage to DNA is a plausible biological mechanism for cancer and diseases that involve damage from ELF to the central nervous system. Is HC in agreement with this statement? If not, specifically why not?
[Name withheld] wrote the following about SC6, "All aspects were reviewed, including possible effects related to cancer. It is important to note that this safety code, and all other codes and guidelines produced by this Bureau, rely on an understanding and assessment of the body of science, not selected studies that support a preconceived conclusion. This is the only approach that is justifiable and defensible in dealing with matters related to health and safety of the Canadian public." [1]
47) How can HC defend such a statement in light of the overwhelming contradictory evidence?
[Name withheld] also wrote, "In addition to these documents, HC staff participated in a specific review of the evidence for a link between EMR and cancer and this document contains more references: Moulder JE, Foster KR, Erdreich LS, McNamee JP. Mobile phones, mobile phone base stations and cancer: a review. Int J Radiat Biol. 2005 Mar;81(3):189-203) which is available at: http://www.informaworld.com
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48a) I have read this paper. It was written before both the Wolf & Wolf (2004) study and before the Naila study. What is HC's response to this considering the Naila study is not referenced by HC?
48b) Are studies being selectively omitted from HC documents because they do not agree with the current administration's theories or objectives?
Many people are surprised to learn that certain kinds of EMFs treatments actually can heal.
These are medical treatments that use EMFs in specific ways to help in healing bone fractures, to heal wounds to the skin and underlying tissues, to reduce pain and swelling, and for other post surgical needs. Some forms of EMFs exposure are used to treat depression.
EMFs have been shown to be effective in treating conditions of disease at energy levels far below current public exposure standards. This leads to the obvious question. How can scientists dispute the harmful effects of EMF exposures while at the same time using forms of EMF treatment that are proven to heal the body? [1]
49a) Medical conditions are successfully treated using EMFs at levels below current public safety standards, proving another way that the body recognizes and responds to low-intensity EMF signals. Otherwise, these medical treatments could not work. The FDA has approved EMFs medical treatment devices, so is clearly aware of this paradox. Is HC aware of the paradox? Will HC resolve the paradox?
49b) No one would recommend that drugs used in medical treatments and prevention of disease be randomly given to the public, especially to children. Why then do random and involuntary exposures to EMFs occur all the time in daily life?
In July, 2007, The Alaska Supreme Court (Court) upheld the decision of the Alaska Workers' Compensation Board (Board) awarding an AT&T equipment installer 100% disability as a result of his workplace electromagnetic field exposure to radiofrequency (RF) radiation at levels slightly above the FCC RF safety limit. The award was based on the psychological and cognitive effects of RF radiation over-exposure. This decision is significant because the FCC RF limit is designed to keep people from being heated and ignores evidence of other adverse biological effects at much lower levels. The RF radiation exposure level in question was well below the FCC's recognized level of "thermal" harm. The FCC contends that there are no scientifically established harmful health effects below the thermal threshold. The Board decision agrees with the medical experts who found adverse health effects from this RF radiation exposure, which occurred above the FCC safety limit but below the thermal threshold. The complete text of Alaska Supreme Court OPINION No. 6139 - July 6, 2007 is found at: www.emrpolicy.org/litigation
50) When I contacted CCRPB on this ruling I was told the subject was overexposed to radiation. However, overexposure is not what the judge used to make his decision. I suggest CCRPB review the judgment more carefully.
According to the Canadian Human Rights Commission Policy on Environmental Sensitivities, "Individuals with environmental sensitivities experience a variety of adverse reactions to environmental agents at concentrations well below those that might affect the `average person'". This medical condition is a disability and those living with environmental sensitivities are entitled to the protection of the Canadian Human Rights Act, which prohibits discrimination on the basis of disability. The Canadian Human Rights Commission will receive any inquiry and process any complaint from any person who believes that he or she has been discriminated against because of an environmental sensitivity. Like others with a disability, those with environmental sensitivities are required by law to be accommodated. EHS is considered a disability in Canada. The Canadian Human Rights Commission Policy on Environmental Sensitivities accommodates EHS.
51) HC maintains Canadians are protected by SC6 but it does not protect Canadians with EHS, therefore the Ministry of Health is in violation of the Canadian Human Rights Commission. Is this statement correct?
Recently Europe's top environmental watchdog, the European Environment Agency (EEA), has called for immediate action to reduce exposure to radiation from Wi-Fi, mobile phones and their masts. It suggests that delay could lead to a health crisis similar to those caused by asbestos, smoking and lead in petrol. The warning follows an international scientific review which concluded that safety limits set for the radiation are "thousands of times too lenient", and an official British report which concluded that it could not rule out the development of cancers from using mobile phones.
52) Is any such warning proposed by HC?
And the evidence keeps poring in. In a lecture held on 1 October 2007 at the "Open University" in Gelsenkirchen, Germany, Prof. Franz Adlkofer presented his research results regarding the effect of UMTS radiation on human cells for the first time. There is no doubt - UMTS is ten times more damaging to genes than GSM radiation. He pointed out that the evidence of DNA strand breaks in conjunction with the formation of micronuclei does not allow any further doubting of the genotoxic effect of UMTS signals. This means that Prof Adlkofer demonstrated for UMTS what he had already demonstrated for GSM in the REFLEX project, which he headed: Mobile phone radiation damages the genetic material and raises the risk of cancer. The European Environment Agency , the highest scientific body within the EU, published a statement on 17 September 2007 in which it ranked the danger potential from mobile radiation and the policies supporting it in one line with Asbestos and PCBs.
And the evidence keeps poring in. Washington, DC, November 16, 2007 - A groundbreaking scientific study published this week in the peer-reviewed "Australasian Journal of Clinical Environmental Medicine" warns that wireless communication technology may be responsible for accelerating the rise in autism among the world's children. (J.Aust.Coll.Nutr.& Env.Med, 2007; Vol.26, No.2 pages 3 - 7)
And the evidence keeps pouring in. Recently from the "Indian Express", November 26, 2007, "ICMR Study Confirms Health Risks From Mobile Phones". "Continuous use of cell phones can pose a serious threat to your reproductive health, says a study conducted by the Indian Council of Medical Research (ICMR). The Preliminary results of the study have indicated significant reduction of testicular size, weight and sperm count due to the Radio Frequency Radiation (RFR) emitted from cell phones.
53) What are HC's views on these three studies in light of the fact they cast doubt on the protection afforded Canadians by SC6?
The tobacco industry, 40 years ago, reacted to the historic Surgeon General's report linking cigarette smoking to cancer and other lung diseases by organizing a disinformation campaign. One of their memos, prepared in the 1960's, was recently uncovered during one of the lawsuits against the tobacco companies on behalf of millions of people who have been killed by their product. It is interesting to read it 40 years later in the context of the intransigence of HC: "Doubt is our product, since it is the best means of competing with the "body of fact" that exists in the mind of the general public. It is also the means of establishing controversy." Brown and Williamson Tobacco Company memo, 1960's.
54) Is HC stalling the reviewing of SC6 thereby allowing Industry more time to build more towers?
Devra Lee Davis, Ph. D., MPH, is author of the recently released book "The Secret History of the War on Cancer. Dr. Davis is Professor at the University of Pittsburgh as well as Honorary Professor, London's School of Hygiene and Tropical Medicine, and an Expert Advisor to the World Health Organization. President Clinton appointed Dr. Davis to the Chemical Safety and Hazard Investigation Board, (1994-99), an independent executive branch agency that investigates, prevents, and mitigates chemical accidents.
As the former Senior Advisor to the Assistant Secretary for Health in the Department of Health and Human Services, she has counseled leading officials in the United States, United Nations, World Health Organization and World Bank. She was also a Distinguished Visiting Professor at The Yeshiva University and Stern College for 1996- 97 and Scholar in Residence and Executive Director of the Board on Environmental Studies and Toxicology at the U.S. National Research Council, of the National Academy of Science, 1983-93.
Dr. Davis holds a B.S. in physiological psychology and a M.A. in sociology from the University of Pittsburgh. She completed a Ph.D. in science studies at the University of Chicago, as a Danforth Foundation Graduate Fellow and a M.P.H. in epidemiology at the Johns Hopkins University, as a Senior National Cancer Institute Post-Doctoral Fellow.
She has also authored more than 170 publications.
What Dr. Davis has to say about cancer and cell phones should be listened to although it is predictable HC will not listen.
"Cell phones transform and save lives.Then think of Ronald Regan and George Bush Sr.'s political adviser Lee Atwater, General Electric's Jack Welch, Dan Case, the high empowered brother or AOL founder Steve Case, Calgary business leader Clark H. Smith, writer Bebe Moore Campbell and other heavy users of the first generation of cell phones when they were first introduced. Each of these brain cancer cases spent hours with some of the early cell phones next to their skulls. The problems posed by cell phones in the real world are like huge simultaneous equations.
When it comes to sorting through the risks of cell phones, we have lately been assured that there are none based upon reports from what appear to be independent scientific reviewers. For example, researchers from the Danish Cancer Society reported in the Journal of the National Cancer Institute in 2006 that they found no evidence of risk in persons who had used cell phones. Headlines around the world boasted of this latest finding from an impeccable source published in a first tier scientific journal.
But let's look at what the researchers actually studied.
They reviewed health records through 2002 of about 421,000 people who had first signed up for private use of cell phones between 1982 and 1995. A "cell phone user" in the study was anyone who made a single phone call a week for six months during the period 1981 to 1995. The study kicked out anyone who was part of a business that used cell phones, including only those who had used a cell phone for personal purposes for eight years.
This research design raises a lot of questions. Why did they not look at business users - those with far more frequent use of cell phones? Why lump all users together, putting those who might have made a single phone call a week with those who used the phones more often?
Why stop collecting information on brain tumors in 2002 when we know that brain tumors often take decades to develop and be diagnosed?
When you are looking at a large population to find an effect, generally the more people you study, the better your chance of finding something. But if you merge a large number of people with very limited exposure together with a small number of people with very high exposure, you dilute the high-exposure group and so lower your chances of finding any effect at all. It would be better to compare the frequent users with non-users, omitting the limited users altogether. Lumping all these various users together is like looking all over a city for a stolen car when you know it's in a five-block radius. Perhaps you'll find what you're looking for, but the chances are greater that you won't. The Danish study was designed to look definitely thorough - 421,000 people! - but in fact it was biased against positive findings from the start. Given how broadly cell signals now penetrate coffee shops, airports, and some downtown areas of major cities, it is very difficult to find any truly unexposed groups against which to compare results. Because cell phone use has grown so fast and its technologies change every year, it is as if we are trying to study the car in which we are driving.
Another study that s well published in 2000 found no increased risk in most types of brain cancer in cell phone users; but the average length of use among participants was less than three years. Still, the study found that those people who had used phones for even this short period of time had twice the risk of a very rare brain tumor - neuroepitheliomatous cancers, the kind that wraps itself around the nerve cells of the lining of the brain, right at the locus that cell signals can reach.
Of course, epidemiologic research is the research that works best when we have solid information on the nature of the use or exposure we are trying to understand. All of us have cell phone bills that provide detailed records of our use, and most of these can be accessed online. These were not used in the study, nor in any study of the industry to date. A gold mine of data lies untapped that could enable researchers to distinguish non-users from low frequency users from high frequency users, thereby increasing the validity and sensitivity of the studies.
Underlying this whole body of research is clear evidence that cell phone signals penetrate the brain. As the Danish researchers admitted in their own study, "During operation, the antenna of a cellular telephone emits radio frequency electromagnetic fields that can penetrate.
The studies to date that have not found a general, clear and consistent risk from cell phones need to be understood as tentative. They have for the most part looked at older technologies over short periods of exposure. None is asking about the impact on of cell phones on the brains of children and teenagers - one of the fastest growing groups of users in the world today. The governments of England, Israel and Sweden advise that those persons under eighteen should not use cell phones at all. American toddlers learn to play with toy versions of them.
What makes this especially troubling are the results from several other studies that have looked at more recent regular users. After a decade of heavy use, cell phone users have double the risk of brain cancer. The tumors tend to occur on the side of the head that the user favors.
Another, entirely different set of data on electromagnetic fields, exposures of which cell phone signals are but one type, come from looking at an illness even more extraordinarily rare than brain cancer - breast cancer in men. The total number of cases of male breast cancer in the United States today is thought to be less than 4,000 but some 1,400 new cases are reported each year, according to the American Cancer Society. Studies of men who work with electromagnetic fields in radio and television or in assembling cell towers have found that they have a much greater risk of breast cancer as well as cancer of the brain.
Men typically don't get breast cancer, and when they do, the disease is often much more difficult to treat. that for many professions involving work with electronics, men have between two and four times more breast cancer than those without such experiences.
Much of the research funding is provided by the telecommunications industry just as much of the research funding on more general electromagnetic field research was provided by the electric power industry. It may not surprise you to learn that the highly publicized Danish study that exonerated cell phones and the yet to be completed IARC study are directly funded by the industry."
55) Exactly how many more voices will it take to make Safety Code 6 more humane? This is not rhetorical.
John Updike wrote, "It is impossible for a man to understand something if his income depends on not understanding it." Public microwave exposure levels tolerated by Health/Industry Canada are a national health disaster. Yet, for pragmatic and lucrative reasons, federal exposure limits have been deliberately set so high that no matter how much additional wireless radiation is added to the national burden, it will always be "within standards". SC6 is outdated, lacking in modern EMR studies, does not adequately take into account low level radiation nor the long term effects of radiation exposure. SC6 fails to protect Canadians adequately by lacking a precautionary principal and in light of certain recent studies and court cases may even be considered lacking due diligence. SC6 discriminates against those with EHS, a recognized disability. SC6 does not protect Canadians' health and contributes to their ill health at significant cost to the health care system. On September 5, 2000 the court ruled that HC's civil servants and scientists are responsible to the Canadian people, and that politicians cannot shut them up when it suits them or their corporate friends.
56) Are whistleblowers like Dr. Chopra discouraged in the Consumer and Clinical Radiation Protection Bureau of Canada?
Again I would ask for a yes/no or percentage answer to the following question.
57) "Are the residents in the vicinity of the Union Street Water Tower Cell Tower in Simcoe, Ontario as safe today as they were before the cell tower was enabled?"
I submit the attached petition to have the responsible government agents answer for SC6's failings.
Sincerely,
[Original signed by Frank Woodcock]
Frank Woodcock
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[1] Bio Initiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF) 2007
[2] Analysis of Health and Environmental Effects of Proposed San Francisco Earthlink Wi-Fi Network, Magda Havis, B. Sc., Ph.D, Environmental & Resource Studies, Trent University.
[3] Microwave News,
http://www.mastsanity.org
