Necessary questions for risk assessment EMF & Health

Relevance and completeness of the questions for risk assessment posed to SCENIHR

Introduction
The International EMF Alliance (IEMFA) appreciates that an update of overall risks assessment on EMF and health is being prepared and that a public consultation is launched. Comments of the public are explicitly asked on the relevance and completeness of the questions for risk assessment posed to SCENIHR. IEMFA chooses to place the relevance and completeness of these questions within the following wider context. Background Last decade there is a rising number of warnings for bio-accumulative health hazards of longterm exposure to EMFs. National and international authorities and governments receive urgent calls from, communities of doctors, scientists and parliaments for a thorough review of the science basis of the current EMF & Health protection standards. Not only the current science basis appears questionable. There are mounting indications that also the underlying risk assessment system is fundamentally inappropriate, as a result of obsolete paradigms and vested interests. In line, the current protection standards for EMF exposure are increasingly considered obsolete and inappropriate by the growing international community that is mentioned above.

Risk assessment system To enable a better risk assessment and appreciation of the multitude of EMF warnings, and to stimulate an appropriate basis for an international system for long-term health protection, any review of the current science basis will therefore be irrelevant and incomplete, if not first a wider assessment is done. This is a thorough review of the current risk assessment system EMF & Health. This underlying system of the current science basis is set up in the last century and consists of a set of ideas, rules and institutions. A thorough review of this underlying risk assessment system can be done by providing a richer body of information from more diverse sources, using a wide perspective. Such a multidimensional review of the appropriateness of the existing risk assessment system may stimulate global debate and necessary transitions in risk assessment. As such, it may help society to do substantially better in the future at achieving a responsible balance between EMF innovations and their hazards.

Relevance of the questions for risk assessment

The International EMF Alliance considers the current questions for risk assessment posed to SCENIHR, mentioned in the terms of reference therefore largely as irrelevant, if not first the appropriateness of the underlying risk assessment system itself is assessed. This also counts

for the currently used risk assessment method. As mentioned it is the underlying system of the current science basis that increasingly is criticised worldwide. IEMFA therefor fundamentally disagrees with what is currently presented by established parties as the scientific credible risks.

Questions for the risk assessment system

To assess the appropriateness of the prevailing risk assessment system, and thereby the essential fundamentals of risk assessment in any sector, literature indicate that mainly three overlapping domains of knowledge should be investigated. 1) Gathering a wide body of information, 2) Clarifying scientific paradigms and 3) Unveiling interests, politics and perceptions. These three domains should deliver the input for relevant questions for indepth risk assessment. The overall assessments of these domains should be done by integrating the outcomes of many part questions into a coherent, multidimensional whole. The three domains of deeper risk assessment will get elaborated below

Gathering a wide body of information To improve our capability of early detection of environmental risks, the European Environment Agency found, after studying fourteen historical environmental-health cases were early warnings were interpreted that if more account - scientifically, politically and economically - is taken of a richer body of information from more diverse sources1. Then society may do substantially better in the future at achieving a better balance between innovations and their hazards To know more, for example by searching out blind spots within disciplines, reaching out to other disciplines, accessing lay and local knowledge to appraisal early warnings, and taking account of wider social perspectives. Interpretation of warnings is not a matter of universities alone, but also for other people and institutions involved in knowledge production. It is about using alternative sources of knowledge and being open of various types of knowledge and nature of evidence: theoretical, empirical and even anecdotal Since real world conditions can be very different from theoretical assumptions, and these differences can have serious consequences2,3.

Clarifying scientific paradigms Science can be seen as the combination of theories, methods and facts collected in current hand and textbooks. In science, there are various communities that start from different frames of mind. Conceptual frameworks define the paradigm and give it its explanatory
1 Scientific credibility is considered too narrow a criterion for the early detection of new risks, because of the danger of missing early warnings that only stand the scientific test after evidence of harm is established. Advisory Council for Research on Spatial Planning, Environment and Nature, New risks into the picture?, Ph van Notten, To Learn from Early Warnings, Meta-analysis of Late Lessons from Early Warnings, Essay Series 20 2 International EMF Alliance and other public interest NGOs, scientists, members of European parliament and medical doctors, Call for transparent, impartial and pluralist expert assessment on health risks of non-ionizing electromagnetic fields (EMF). Open letter to commissioner John DALLI, Health and Consumer Policy, Strasbourg, November 14, 2011 3 European Environment Agency, Late lessons from early warnings: the precautionary principle 1896 , Environmental Issue Report No ,

value. Risk-assessment systems are largely based on underlying paradigms. Paradigms form a self-reliant explanatory model or conceptual framework of a scientific discipline, shaped by the communitys background and the context of the historical moment They can also be described as a thought pattern or model of thinking in a scientific community that generates the organizing and understanding of reality, or as theoretical framework and set of practices constituting a more specific way of viewing reality4. Science does not speak with a common voice, but it is a collection of dominant paradigms and dissenting opinions. Assessment of (new) risks occurs within an existent scientific framework of reference5. Based on a meta-analysis of the report Late Lessons from Early Warnings it is advised to pay attention to dissenting opinions. The above is in line with the observations of science philosopher Thomas Kuhn. In his book The Structure of Scientific revolutions6. Kuhn speaks of a revolutionary competition between different scientific communities, especially in early stages of scientific development. Thus, it takes time for evidence of scientific discoveries to become accepted, since it must invariably compete with other evidence.

Unveiling interests, politics and perceptions In collecting a rich body of information, it also appears important to identify the interests that might work or suppress research and communication on early warnings on possible risks. Hulme argues in his book Why We Disagree About Climate Change7, that for a more fruitful debate, it is better to identify existing frames of mind and recognize them, and not hide the politics. Solutions arise from the fact that in the debate, people are led by different frames. Finally an assessment of the institutions of science is important too. In their book Bending Sciences How Special Interests Corrupt Public Health Research8, McGarity and Wagner also point out that the current science institutions are under attack. Not only science production frequently proves to be cleverly manipulated scientific junk This counts also for the social perceptions of the outcomes of science The pipeline of sound science production appears multi-fold surreptitious infiltrated by advocates of interest groups. Influence science and influence social perceptions.

Needed widening of proposed risk assessment

Indication of additional questions for a realistic risk assessment In the figure below, different domains of the risk assessment system are indicated. In essence, for optimal risk assessment pluralistic research is needed, whereby the information of all these interrelated knowledge parts is brought together to a consistent whole.
4 Kuhn TS, The Structure of Scientific Revolutions, The University of Chicago Press, 1962 5 Advisory Council for Research on Spatial Planning, Environment and Nature. New risks into the picture?. Ph van Notten, To learn from early warnings, meta-analysis of Late lessons from early warnings, Essay Series 2004 6 Kuhn Th S. The Structure of Scientific revolutions, . University of Chicago press 7 Hulme M, Why We Disagree About Climate Change; Understanding Controversy, Inaction and Opportunity. University of East Anglia, 2009 8 McGarity ThO, Wagner WE, Bending Science. How Special Interests Corrupt Public Health Research. Harvard University Press, 2008

Figure 1. Wider knowledge gathering for better risk assessment

Recommended wider gathering of knowledge for better appreciation of early warnings and risk assessment, largely expressed according to the EEA 2001, subsequent meta-analysis of the report in 2004, and others. See references elsewhere.

Interests

Assumptions and theories

Methods & approaches

Paradigms Frames of mind

Dissenting opinions

Wider social perspective

Politics & economics

History

Established Institutes of science

Established sciences

Lay knowledge

Books

Theoretical knowledge

Other institutes and people Empirical knowledge

Additional sciences

Local knowledge Other disciplines

Anecdotal knowledge

Perceptions

Values

Traditional disciplines

Blind spots within disciplines

Et cetera

Wider credibility appraisal of warnings

better risk assessment / appreciation of early warnings Interpretations of science and practice

The type of questions to assess the appropriateness of the risk assessment system is divided into three parts. The questions given are indicative Using a wide body of information To what extend: is risk assessment system open to various types of knowledge? o what different types of knowledge are used and do these types have consistent outcomes? are diverse sources of knowledge used? o which sources of knowledge? is both scientific, political and economic information used? o what background framework of interpretation exists? is seared for blind spots within disciplines; and reached out to other disciplines? o which blind spots and links to other disciplines? is also lay and local knowledge assessed? o of what groups knowledge is used? are wider social perspectives taken in to account ? o which perspectives? are both theoretical, empirical and anecdotal perspectives taken into account?

o are these three perspective lying in line? are real world conditions used? o do theoretical assumptions and empirical conditions reflect real world? are both universities and other people and institutes involved? o what universities and what other people is attention paid to dissenting opinions? o is there unanimous consensus on the risks of EMFs between different groups?

Paradigms What is the dominant frame of reference that is used? What other frames of reference or paradigms are presented? What dissenting opinions are collected or heard? Are there indications that dissenting opinions are excluded? Etcetera

Interests, and perceptions What special interests are involved, qualitatively and quantitatively? What parties developed the prevailing frame of reference? What parties use and prescribe the prevailing frame of reference? What parties determined the method of research and risk assessment= Is the risk assessment process transparent? Can the risk assessment procedure be called impartial? What institutions are included, what institutions excluded? What scientists are included, what scientists are excluded? What non-governmental organisations are included or excluded? What expert types and groups dominate the risk assessment?

The International EMF Alliance Alex Swinkels Alex@international-emf-alliance.org www.international-emf-alliance.org