Reaction of the Dutch National Platform on Radiationrisks on the draft ICNIRP Guidelines for limitingexposure to time-varying electric and magnetic fields(1 Hz to 100 kHz) of 29 July 2009

October 31 2009

1. Relevant mechanisms & multilevel pathways

General mechanism of development health effects by environmental factors

In general, adverse health effects of environmental factors are often the result of a gradualaccumulation and intrinsic amplification of a multitude of smaller biological disruptions,generated by an environmental factor over longer time.

From general physical interactions with tissues, to realistic biological mechanisms

(lines 78-140) In the last decades, the knowledge development on the possible influences of EMFs on a diversity of biological activities and processes of organisms has increasedexponentially. Where in the second half of the last century, still had to be relied ontheoretical, model-based and calculated assumptions that only

general physical interaction

of EMFs with tissues - such as (

„

heating

‟

for HF EMF and)

„

electrical stimulati

on‟

depending onthe electrical conductivity of the medium - would be able to generate adverse health effects,nowadays a wide range of

biological mechanisms

and multilevel pathways have emerged,that appear to get influenced by EMFs. For instance multiple types of oxidation processes,cellular stress mechanisms, disruptions of the functioning of cell membranes and of mitochondria, functioning of cross-membrane ion transports, disruptions of the secretion of hormones and hormonal regulation, altered electrical activity of nervous cells and effects onneurology and behaviour. The precise reacting of these sub-mechanisms of life on EMFs isnot fully comprehended yet with established fragmenting research methods, since they seemto be related to combination of a complex mix of exposure characteristics and a multitude of involved biological characteristics. But it becomes more and more clear that an accumulationand intrinsic amplification of the heterogeneous multitude of biological disruptions by EMFsthat are reported in scientific research, can over longer time result in substantial adversehealth effects. The natural ability of organisms to restore homeostatic balance as a primarylife regulation function, can thus be lost structurally, seeing the multitude of reportedbiological disruptions. In line with this, an unnatural rupture between

„

biological effect

s‟

and

„

health effects

‟

, in other words, is artificial and not appropriate in approaching thedevelopment of possible health effects of EMFs.

Complete physically-based exposure limits with biologically-based exposure limits

According to the National Platform on Radiation Risks of the Netherlanmds (NPS) this makesit urgent, that a shift should be made whereby possible physical disruption mechanisms of EMFs with tissues in general, will be completed with more deeper and true-to-realitybiological mechanisms and accumulating multilevel pathways of organisms that EMFs canmultiple disrupt. In line, not only physical EMFs-limits count, such as an assumed anddefined

„

excess of current density

‟

(or

„

overheating of tissue

s‟

for HF EMF). Also more refinedEMF-limits do count, based on levels of exposure where an accumulation of biologicaldisruptions of EMFs can occur.

2. Methods for scientific research & evaluation

Scientific methods should guarantee outcomes true-to-reality

In general, it is important that the scientific views and methods used in a certain era,approach reality as close as possible. Since there have been a succession of progressiveeras in the knowledge development on EMF&H in the last decades, traditional perspectivesand methods should be evaluated and if possible be updated to modern times. From theyears of growing EMF-appliances 1950 to 2010, the National Platform on Radiation Riskshas distinct seven progressive eras that indicate a gradual improving of understanding of health effects of EMFs. The partly overlapping eras contain progressive views on involvedmechanisms, methods and related health effects. See the

NPS discussion paper

“

Progressive Eras in Knowledge Development and State of Science in the Field of Electromagnetic Fields & Health - Towards a true-to-reality State of Science

”

, on the site of NPS.

Increasing gab between

‘

sci

ence’ and

‘r

eality

’

(line 51) There is an growing gab between what is considered by organisations includingICNIRP and WHO as

„

established science

‟

, and an increasing amount of other indications for

„

reality

‟

, what health effects of EMFs are concerned. For this, NPS points to theinternationally increasing number of Medical Appeals since 1992, whereby groups of doctorswarn their governments for revealed health problems by EMFs, based on their empiricalpractices. Also, the number of people that associate a large diversity of health symptoms(such as chronic fatigue, headaches, migraines, sleeping problems, and concentrationproblems) with all kinds of electromagnetic fields at home and in work situations, seems toincrease. Furthermore, groups of scientific researchers and non-governmental organisationsbegin to warn for a range of non-specific symptoms related to these fields, including immunesystem disturbances and depressions.

Take into account gab between

‘

sci

ence’ and

‘

grey literatur

e’

(line 51) There is always a gab between that what the current established scientific methodscan understand and actually proof, related to reality. Despite substantial progress, sciencewill therefore always contain uncertainties. Science can thus expect to be in time behind or outdated, compared to ongoing technological development. Also, there is a generalvulnerability of man versus the environment. For the sake of protecting public health it is

therefore wise not only to take into account 100% scientifically proved data, but also have aglance at important grey literature, to see what might be ahead in future. Also, grey literaturemight indicate less robust parts in traditional established views and research methods.

‘

Scientific absolutist

s’

approach increasingly needs a

‘

precautionary

’

shift

(line 51) In line with this, the traditional

'scientific absolutists'

view on health risks

graduallybecomes inadequate and irresponsible, in the light of sufficiently protecting public health anddetermining proper guidelines for EMFs exposure and EMF emissions for products &appliances. Regarding the growing amount of indications and evidence for a range of serioushealth effects by an accumulation of a multitude of biological disruptions, a more'

environmental centrist' or 'cautious environmentalist'

perspective seems more appropriate toset proper guidelines. In other words: the growing flow of serious indications for a range of health effects in the last decades, makes a more

„

precautionary environmentalist

’

perspectiveurgently needed. In line with this development and the achievements already made, NPSstresses the need for reversing the burden of proof, where long-term health effects of EMFsare concerned.

Physical model-based calculation method has insufficient correspondence to reality

(lines 68-97, 545) Calculating possible health effects of EMFs, by mathematical modelling of expected physical interaction of EMFs, results in an estimation that does not guaranteecorrespondence true-to-reality. For a technical/physicists point of view on living matter, willnot guarantee sufficient correspondence with the actual whole of inner biological processesand activities of organisms. In fact, a technical and physicist points of view will contain alarge percentage of

„

black box

‟

perspective, where actual biological processes and activitiesof living organisms are concerned. Occurrence of health effects indirectly deduced from

“

theelectrical conductivity of the medium

”

(line 90) may therefore deviate substantially fromreality.

Physical theory and calculations need replaced by empiric-biological fundaments

(lines 68-97) The National Platform on Radiation Risks (NPS) considers it not necessary andappropriate anymore to estimate possible occurring biological and health effects of EMFs byusing theories and mathematical-modelling based calculations of estimated densities of electrical currents in tissues and ditto estimated heating of tissue when exposed to EMFs.Decades ago this has been an acceptable approach for a start, since other bodies of knowledge were less developed. But since then, a large amount of peer reviewed empiricalbiological research has been conducted internationally, to replace these physical-theoreticalbased, calculated estimations of the last century (see for instance the BioInitiative Report or Ecolog Report). A disruption of many thousands of biological processes, activities and thefunctioning of an organism appears to take place in a much more subtle and complex waythan just a general overheating reaction or electrical currents in tissues.(lines 414-419) Although calculations based on anatomically and electrically adapted modelsmight be slightly better than the former assumed magnetic field models that the body has ahomogeneous and isotroptic conductivity (..), of both ways of theoretically-mathematicalmodelling, there is no sufficient evidence that this type of calculation-based modelling hasany relation with reality for the body. Theoretical-mathematical models to determine possiblehealth effects were good for a start in the last millennium, but can and should now urgentlybe replaced by the mass of actual

empirical

findings of experimental biological research,combined with epidemiological findings.

Ch. Weiss:

“a

ll risks are denied, unless the opposite can be proven with absolute certainty

”