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Neil CherryLincoln University25/4/2000INTRODUCTION:1.1 Background to this critiqueThere is a strong push from the WHO and the ICNIRP of harmonize nationalRF/MW exposure standards by individual states adopting the ICNIRPGuideline. This would be a good thing if the ICNIRP Guideline was set atan exposure level that provided sound protection of public health. Theevidence presented here shows that the ICNIRP Guideline exposure levelis set many orders of magnitude too high to accomplish this. It is basedon the preconceived and long held view of Western Government Authoritiesthat the only possible and only established biological effect of RF/MWexposure is tissue heating. This is referred to here as the RF-ThermalView. This view has been intransigently maintained in the face ofcompelling laboratory and epidemiological evidence of adverse healtheffects that would have had a chemical declared carcinogenic,neuropathogenic, cardiogenic and teratogenic for humans many years ago.This critique was originally written when the New Zealand Ministries ofHealth and Environment proposed to adopt the ICNIRP Guideline as thePublic Health Standard for Cell Site exposures. At the same time the NewZealand RF Standards Committee was proposing to use the ICNIRP Guidelineas the New Zealand RF/MW Standard. ICNIRP is the InternationalCommission on Non-Ionizing Radiation Protection. The ICNIRP RF/MWguideline and scientific assessment was published in Health Physics,Vol. 74 (4): 494-522, 1988. This is the primary source document forthis critique and will be referred to as ICNIRP (1998).The ICNIRP (1998) assessment of effects has been reviewed against theresearch literature cited and other published research. It is found thatboth the basic approach of ICNIRP and its treatment of the scientificresearch have serious flaws. The ICNIRP assessment is determined tomaintain the RF-Thermal View and it rejects or omits all evidence thatconflicts with this view. This may be termed "Constructive Dismissal"for a preconceived concept is used to inappropriately dismiss allevidence that challenges it.ICNIRP is particularly dismissive of epidemiological evidence becauseall existing studies involve nonthermal exposures. Hence accepting thevalidity of these studies would directly challenge the RF-Thermal View.In this way the approach to dealing with health effects from non-ionizing radiation was developed to follow a completely different methodthan for toxic chemicals, drugs or air pollution. Both the approach ofICNIRP and the assumptions made are severely scientifically challengedin this report.Overview of this report:Public health protection standards for toxic substances, chemicals,drugs, air pollution, ionizing radiation are set by WHO, IARC, E.U.,

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U.S. EPA and the U.K. Royal Commission on Environmental Pollutionprimarily using epidemiological evidence and secondarily using animalevidence. WHO and ICNIRP base non-ionizing radiation protectionstandards on a single biological mechanism, Tissue Heating. Theysystematically reject or ignore all epidemiological and animal evidenceof non-thermal effects, for which there is a large body.The history and basis of the RF-Thermal View which dominates ICNIRP,WHO, and national authority approaches, is documented and summarized. Itwill be shown that throughout the post-War period scientific researchand leading biological and medical scientists have challenged the RF-thermal assumptions. They present very strong evidence, amounting toproof, that biological systems intrinsically use EMR for body, organ,hormone and cellular functions and regulation, and that extrinsic EMRinterferes with these at extremely low exposure levels. These biologicaleffects do not involve heat but do involve non-linear, non-equilibriumresonant interactions between ELF oscillating signals.The well documented and established nonthermal biological effects of EMRinclude significant alteration of cellular calcium ion homeostasis,reduction of melatonin and the detection of Schumann Resonances by humanand avian brains, DNA strand breakage and enhanced chromosomeaberrations.The human health implications of these biological effects are discussedand documented. This shows that calcium ion efflux/influx and melatoninreduction are separately and jointly linked to DNA strand breaks,chromosome aberrations, enhanced proto oncogene activity, impairedimmune system competence and impaired neurological and cardiacfunctioning. Many projects, from independent labotories, have observedand reported that all of these effects are significantly related to EMRexposure.Human Biometeorology is a whole body of research that is ignored byICNIRP. This has provided the proof over 30 years ago that human brainsdetect and use the Schumann Resonances for synchronization of biologicalrhythms, i.e. as a Zeitgeber. This observation on its own is an absolutechallenge to the validity of the ICNIRP assumptions that there are noestablished non-thermal biological effects.Epidemiological reviews by Dr John Goldsmith show that adverse healtheffects, such as neurological, reproductive and cancer effects have beenobserved in EMR exposed populations. Based on this, and the traditionalpublic health protection approach, Dr Goldsmith challenges the validityof the ICNIRP guideline and approach.To summarize the scientific evidence an initial set of eightbioelectromagnetic principles are proposed and a brief summary of thescientific research that supports them is given. They are:EMR is intrinsic to our bodies.Our brains are the most electrically sensitive organs in our bodies.Our hearts are electrically sensitive.Cells are sensitive to EMR

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Our whole body acts as an aerialThe brain is linked to organs and cells through EMR-sensitive hormones.The EMR Spectrum Principle.The Intrinsic Free Radical PrincipleThese principles provide a sound and scientifically reliable approach toassessing EMR impacts on people and animals. They soundly challenge theICNIRP assumptions and approach. The ICNIRP assessment of biologicalmechanisms is reviewed and found to be selective, limited and flawed.Their assessment of RF/MW effects on reproductive outcomes is shown tobe limited, misleading and flawed. The cancer assessment is shown to beselective, misleading, inappropriate and flawed. An incorrectepidemiological approach is consistently applied.From the data in the studies cited (and misused) by the ICNIRP and WHOreviews, and supported by a great deal of other available researchevidence, a public health protection standard is recommended based onresidential dose-response relationships for cancer, neurological effectsand reproductive effects.2. Public Health Protection Standards are based on Epidemiology:The background to identifying environmental factors that produce cancerwill be given, along with an example using the chemical Benzene. Thenthe principles of epidemiology relating to assessment of cause andeffect will be outlined and the particular principles in theepidemiology of EMR will be discussed.2.1 Cancer Assessments are based on environmental epidemiology:Public health Protection Standards are based on EpidemiologicalEvidence. A primary textbook on Cancer, De Vita, Hellman and Rosenburg(1993), states:"In contrast to laboratory studies, epidemiology directly evaluates theexperience of human populations and their response to variousenvironmental exposures and host factors (the risk of disease)".Del Regato, Spjut and Cox (1985) introduce their medical textbook oncancer by discussing the use of Incidence Rates in human populations asthe means of detecting human cancers. Fraumeni et al. (1993) outline thehistorical role that epidemiology has played in identifying carcinogenicagents and the range of methods which are classically used.Setting public health standards for environmental carcinogens is therole of the United States Environmental Protection Agency (USEPA). Theirwebsite includes the Integrated Risk Information System (IRIS), _HYPERLINK "http://www.epa.gov/ngispgm3/iris/rfd.htm" __http://www.epa.gov/ngispgm3/iris/rfd.htm_, that details the proceduresfor carrying out assessments and the results for a wide range ofcarcinogens. This is primarily based on epidemiological assessments.Under the heading "Hazard Identification" the following statementrelates to the use of epidemiological studies: