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Comments on ICNIRP GuidelinesOctober
29, 2009
I sit here surrounded by mountains of boxes, packed to move away from the recently upgraded 230 kV x 1,200MW power lines installed 20 m away from our home, as well as 147 other residential homes, schools andnurseries. While, the BC government in Canada cites that the WHO’s EMF position that power line EMFs aresafe, I am providing the following comments on the ICNIRP’s Draft EMF Guidelines. Thirty years after theWertheimer Report correlated power line EMFs with childhood leukemia, the WHO and ICNIRP still adamantlyrefuse to recognize power line health hazards, arguing that plausible mechanisms are not found and replicationsof positive reports are hard to achieve. I hereby present the facts about how low-level EMFs affect biologicalorganisms, based on
scientific principles that have been grossly ignored.
Contrary to Line 727 of the draft,which found no causal effects, I list seven fundamental mistakes that may obscure the harmful effects of power line EMFs.
1.
 
Using the Root Mean Square (RMS) (Line 573) instead of the peak-to-peak is incorrect.
MostGauss meters measure RMS value, which is equivalent to the DC amplitude that can deliver the sameamount of 
thermal energy
to a resistive load. However, to a living cell in our body, the
peak-to-peak
 amplitude is more meaningful than the RMS value. For a power frequency (PF) sine wave, the peak isequal to 1.414 times the RMS value and the peak-to-peak is twice the peak value.
 
For example,
 
150mG
 
RMS under the power line will translate into a
424.2 mG swing
(+150 x 1.414)(
http://cp.literature.agilent.com/litweb/pdf/5988-6916EN.pdf 
). Accordingly, if 833 mG RMS is the limit foracute exposure, it should be logical to
adjust down to 589 mG RMS (833 / 1.414) or 833 mGpeak for chronic exposure because cells experience 833 mG pulses 120 times per minute.
 
These Peaks will affect the cell more RMS affect lessFig. 1 Average, RMS, Peak and Peak-to-Peak Values
. (Root Mean Square
 
)
 
2.
 
Ignoring geomagnetic field (GMF) (no mention in draft) is incorrect.
The GMF has been thought tominimally affect living organisms. However, many symptoms related to the combination of powerfrequency magnetic field (PFMF) and GMF are reported in
 
Geomagnetic Fields
.
 
Also the risk of childhood leukemia may be related to the combinations of AC and GMF.
 
(Hypothesis: the risk of childhoodleukemia
 
)
.
 
Due to the GMF, the PFMF oscillation becomes lopsided as shown in Fig. 2. As magnetic fieldsadd vectorially when the power line magnetic field is parallel to the GMF (500 mG), the resultingmagnetic field is
712.1 mG
(500 mG + 212.1 mG), and
287.9 mG
(500 mG – 212.1 mG) in theantiparallel direction. (Dip angle or other factors are not considered here).
These elevated and lopsidedpulses will act on the cells 60 times per minute;
 
therefore the chronic exposure limit should beadjusted down to 295 mG (833 / 1.414 / 2) RMS (833 mG peak).
 
2
Fig 2. Interaction Between GMF and Power Line EMFs: Above the Wire - Antiparallel,Below the Wire – Parallel
(Fundamentals of Physics, p717)
 
3.
 
Ignoring high frequency (HF) noises on PF
(no mention in draft)
is incorrect.
The HF
noiseson power lines
are caused by: power line carriers; corona discharge; HF inductions from radio,TV, cell phone signals and equipment operations; lightning; power line radiation amplified(~1000 times) by magnetosphere and ionosphere; and so on. These noise waves are aggregatedto generate amplitudes much higher than individual amplitudes
(ICNIRP Statement GUIDANCE).
Todenote the nature of a wave, crest factor (CF), defined as peak value divided by RMS value, isused. Because of the pulsed nature of HF noises, the CF can be much larger than that of a sinewave
posing health hazards.
Assuming HF RMS is 0.2 mG and CF is 16, the peak value is 16x 0.2 mG = 3.2 mG.
 
Adding this to GMF + PF EMF,
715.3
 
mG
and
284.7 mG
are obtained.
Affect More
 
RMS affect lessFig. 3 Pulsed Wave - Crest Factor, Peak / RMS (
Crest Factor
 
)
 
 
34.
 
The WHO uses a flawed assumption
 
(Line 579).
The WHO assumes that for any incoming EMFsignal to affect cell functions,
it must have a signal-to-intrinsic noise ratio (S/N) greater than one.
 (I
ntrinsic noises in the cell are thermal, shot and 1/f noises. (
EHC 238
 
Ch. 4)
)
.
Their claim even contradictsthe ICNIRP Statement that explains the
summation of EMFs
.
(
ICNIRP Statement; and
 
ICNIRP StatementGUIDANCE).
 
The cell is not an electronic device designed to retrieve useful signals and does not need todiscriminate between signals and noises. In fact, it is quite the contrary: amplified and lopsided signalscoming into the cell will add to intrinsic noises, most likely resulting in super-threshold EMFs thataffect the biological system.
 
The intrinsic noises generated by the cell will be elevated by 715 mG in theGMF direction and deflated by 285 mG in the opposite direction. Therefore,
S/N ratio should not bethe issue.
Further downward adjustment in chronic exposure limit is needed.
 
Threshold (Cell Homeostasis)Signal (Power line EMFs)Resulting Super-threshold EMFs: Body EMFnoises combined with power line EMFs
Fig.4. Signal (sub-threshold power line EMFs) + Noise (sub-threshold body EMFs) = Super-threshold
 
EMFs
5.
 
Faraday induction of electric fields by power line EMFs should not be used as absolutemeasurement of biological interaction. (Lines 126 – 128, as well as many other lines).
The cellplasma membranes exhibit more than 200 kV/m electric fields, shielding the nucleus and cytoplasmfrom the majority of influence from outside electric fields. The induced electric field caused by iondeflections due to magnetic field is mostly confined in the cell and out of the direction of the inducedelectric field.
Therefore, measurement of induced electric field is mainly dealing with the surfacecharges and the intercellular matrix, ignoring the electric field rearrangement in the cells.
 
6.
 
Ion deflection in the cell should be the main concern. (No line reference).
Ordinary Gauss meterscannot detect the
elevated and lopsided
 
field explained before
, but the body’s cells will detect it verywell because ions in it will deflect to one side much more than the other. It takes only
10 mG
tosufficiently deflect the electron beam of a video display unit and cause the picture to wobble. Thegenerally accepted
childhood leukemia onset threshold of 4 mG
RMS translates into a greater than
19mG
peak-to-peak swing -
enough to deflect electrons or ions away from the target area in a cell.
(Protein targeting
 
 
).
Even 2 mG RMS will deflect the ions a few nanometers to make themmiss the targeted intracellular mouth of a channel, which is several angstrom in diameter
.Many scientists believe that ion motions in the cell are dictated by the random Brownianmotion but the contrary is reported by many researchers (
Electrochemical structure )
. It isunbelievable that the highest organisms rely on random motions of ions for life, no matter howthey are evolved or created. Consequently
, the elevated and lopsided magnetic fields combined withthe body noises may help explain many
biological mechanisms
at very low sub-guideline EMFs
 
including
 
reduced adenosine triphosphate (ATP) production in mitochondrial electron transport chain(ETC)
(
Microwave effects on energy metabolism of rat brain
),
direct effect on DNA
(
Electromagnetic
),
DNA fragmentation
(
IngentaConnect
Bioenergetic aspects
 
),
the dislodge of structurally importantcalcium ions from the cell membrane causing a leakage of toxic materials,
(
The Cell Phone and TheCell:
),
caused leakage of albumin across the blood-brain barrier
(
EMFacts Consultancy
),
and other sucheffects.
Accordingly, the exposure limit should be adjusted down to 1-2 mG RMS.

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