In this newsletter installment we look at two important topics. The regulation of health and safety protection with respect to radio transmitters in Australia and the National Toxicology Program (NTP) study.
1. Health and safety regulation of radio transmitters in Australia
Background: For those not familiar with Australian regulations, the Australian Communications Media Authority (ACMA) are the radio communications regulator. The Radiocommunications Act 1992. Section 162 imposes upon ACMA regulatory responsibility to provide health and safety protection to persons who operate, work with or use wireless equipment via the establishment of standards.
Currently, the ACMA collects revenue on behalf of the Australian Government through broadcasting, radio communications and telecommunications taxes, charges and licence fees. It also collects revenue from price-based allocation of the RF spectrum to industry and government bodies . When taking into consideration the health and safety protection responsibilities, this raises serious concerns about conflict of interest.
Another major problem which is often overlooked is that ACMA chose only certain subsections of the ARPANSA RPS3 (based on ICNIRP 1998 RF Guidelines) as the "standard” to provide health and safety protection. Specifically, the ACMA excluded 5.7 (e) covering precautionary measures because “Inclusion of the precautionary principle in the ACMA regulatory instruments would place a regulatory burden on industry which would require strong justification. Down load outcomes paper : The ACMA does not discern that justification.”
ACMA typically refers those with health complaints associated with RF exposure/overexposure to ARPANSA, justifying this denial of responsibility on the basis of ACMA not being a health authority. In fact, neither ARPANSA nor ACMA are health authorities because both organisations lack the necessary requisite medical and biological science expertise.
The majority of the research on EMR bioeffects in Australia is performed by ACEBR in Wollongong which is classified as a Centre of Excellence (CoE) for RF bioeffect research. However, ACEBR is dominated by psychologists with industry connections (Telstra, AMTA and EPRI) and ACBEBR is suggesting that those who claim to be injured by microwaves are most likely suffering from a psychologically based communicated disorder based on the ‘nocebo effect’.
More recently, the ACMA has sought public comment on the 5G spectrum planning to which ORSAA has made a submission (see attached).
2. National Toxicology Program (NTP) Animal Studies.
You can listen to the NTP animal studies briefing that occurred on May 2016 .
You can download the audio file and the text transcript associated with the recording. We suggest you also take the time to listen to it yourself if you have not done so already.
These rats were exposed to whole body doses of SDMA and GSM modulated waves at exposures, which would allow their body organs to experience EMF levels similar to those at which human’s brains are currently subject to when using mobile phones. A small but significant number of rats produced hyperplastic legions and glial cell neoplasms of heart nerves and brain.
These very rare tumours have also been found in humans and have been shown in a number of studies to be associated with heavy cell phone usage. For example, IARC’s 2011 classification of radio frequency radiation as a possible carcinogen was substantially based on brain cancers (gliomas) and hearing nerve tumors (vestibular Schwannomas or acoustic neuroma). There was a dose response observed for the Schwannomas.
What do the NTP results mean for humans?
There have been many questions about what these results mean for human cellphone usage. The authors of the NTP report have speculated about this meaning, and in fact, the links to human responses motivated an early release of the report.
From the transcript:
John Bucher: "We’ve brought these findings to the attention of the scientific community and the public for the reasons that I indicated earlier that we do have a suspicion that in the human studies, there are increases in gliomas and schwannomas. The fact that these are the same tumors sites that we’re seeing these small increases is of interest to us and we feel that it contributes to the conversation. That’s basically our position at this point."
John Bucher: "So this is a study that is looking at the plausibility, biological plausibility of carcinogenic effect due to cell phone radiation. The direct translation of these findings to the way humans are using cell telephones is not currently completely worked out and that’s part of the evaluation that’s going forward. This may have relevance, it may have no relevance. “
More than 70% of the researchers that looked at this study (e.g. outside pathologists experienced in brain tumours) suggested that that there is a significant association between radio frequency (RFR) glioma and Schwannomas.
The rare tumour types found in the NTP study; i.e. vestibular Schwannoma and glioma have been seen in human epidemiological studies; see Hardell and Carlberg whose 2015 study reports cellphone use up to >25 years . The link between the NTP animal studies and the epidemiological studies are these rare tumour types.
Looking at this purely from the risk of developing a tumour in animals (rats) it was found to be roughly 3% in the NTP study. When we look at human epidemiological studies such as the CERENAT case-control study these same tumours are found amongst those classified as heavy users. An important aspect of this paper relates to heavy users - “Among heaviest users (cumulative duration ≥896 h), time since first use was occasionally less than 5 years (11%) but mostly 5– 9 years (49%) and 10 years and more (40%) (table 5). The highest risk of brain cancer among heavy users (8.2-fold) were from urban use only.
Thirty-three per cent of the cell phone users were commercial agents or sales people, and 22% were chief operating officers or production and operation managers. Sixty-two per cent of them reported occupational mobile phone use. Their median cumulative duration of calls was 1925 h, corresponding to 54 min/day (IQR: 30, 96 min), with a maximum of 6.6 h/day.” So within the “heavy user” category a median rate of use is someone who uses a phone to their head for an hour a day. The highest user in this category is 6.6 hrs per day. Coincidently this report shows a person who used a phone in close proximity to his head for 6 hrs per day.
You might ask the question: Why would anyone hold a mobile phone to their ear for 6 hours per day? The answer is simple; they believed it to be totally safe. One could also say it demonstrates authorities are failing to provide adequate risk advice to the general public.
You might like to contrast ORSAA’s summary with the ACEBR take on the preliminary NTP study findings. The ACEBR suggests, "That it does not contribute to the mobile telecommunications health debate; we are left with the current consensus that there is no evidence that mobile telecommunications-related RF causes cancer.”
With respect to ionising radiation (X-ray and Gamma rays) there is a precedent in radiation protection in using animal risk factors in lieu of not having human data. Following the atomic bomb test in WWII, the ICRP decided to use genetic risk factors derived from mice experiments (see picture below) as a precautionary approach.
Picture above : Circa 1956 Dr Liane Russell studying effects of radiation on mouse genetics at Oak Ridge National Laboratories. Note the tails visible from the irradiation chambers.
The human data of the bomb survivors was followed some 40 years later and so we were able to establish the data on genetic risk factors, which were found to be much lower. Of course, we need to be cautious in our interpretation of the results of animal experiments and the translation to humans as biological differences exist. However, animal experiments are used, as surrogates in the absence of any data on humans and any positive data must be seriously taken into consideration as possibly relevant and plausible to humans. This precedent has already been used many times in radiation protection. So, we should accept the risk factor of 3% from NTP as our best guess of the risk factor for heavy users getting a brain tumour. We can correct this when we have the data 30 years from now when the data on humans becomes available. This is the application of the precautionary approach.
So, you may ask: why is this not being done now for non-ionizing radiation exposure? A good question to be asked of our radiation protection authorities.
Given all the uncertainties, even a small risk factor would mean a large cost burden to society over the next few decades and as such we recommend the implementation of the precautionary approach immediately, along with educating the community on the safe practices with these radiation devices.
PS. Lloyd Morgan (one of our trusted advisors) radio program went to air. In case you missed it archived recording: <https://kpfa.org/program/project-censored> and then click on Oct. 20, 2017