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Inaccurate official assessment of radiofrequency safety by the Advisory Group on Non-ionising Radiation

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The Advisory Group on Non-ionising Radiation (AGNIR) 2012 report forms the basis of official advice on the safety of radiofrequency (RF) electromagnetic fields in the United Kingdom and has been relied upon by health protection agencies around the world. This review describes incorrect and misleading statements from within the report, omissions and conflict of interest, which make it unsuitable for health risk assessment. The executive summary and overall conclusions did not accurately reflect the scientific evidence available. Independence is needed from the International Commission on Non-Ionizing Radiation Protection (ICNIRP), the group that set the exposure guidelines being assessed. This conflict of interest critically needs to be addressed for the forthcoming World Health Organisation (WHO) Environmental Health Criteria Monograph on Radiofrequency Fields. Decision makers, organisations and individuals require accurate information about the safety of RF electromagnetic signals if they are to be able to fulfil their safeguarding responsibilities and protect those for whom they have legal responsibility.
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Rev Environ Health 2016; 31(4): 493–503
Open Access
Sarah J. Starkey*
Inaccurate official assessment of radiofrequency
safety by the Advisory Group on Non-ionising
Radiation
DOI 10.1515/reveh-2016-0060
Received September 30, 2016; accepted October 16, 2016
Abstract: The Advisory Group on Non-ionising Radiation
(AGNIR) 2012 report forms the basis of official advice
on the safety of radiofrequency (RF) electromagnetic
fields in the United Kingdom and has been relied upon
by health protection agencies around the world. This
review describes incorrect and misleading statements
from within the report, omissions and conflict of inter-
est, which make it unsuitable for health risk assessment.
The executive summary and overall conclusions did not
accurately reflect the scientific evidence available. Inde-
pendence is needed from the International Commission
on Non-Ionizing Radiation Protection (ICNIRP), the group
that set the exposure guidelines being assessed. This con-
flict of interest critically needs to be addressed for the
forthcoming World Health Organisation (WHO) Environ-
mental Health Criteria Monograph on Radiofrequency
Fields. Decision makers, organisations and individuals
require accurate information about the safety of RF elec-
tromagnetic signals if they are to be able to fulfil their
safeguarding responsibilities and protect those for whom
they have legal responsibility.
Keywords: AGNIR; brain; cognition; development; EEG;
electromagnetic; fertility; genotoxicity; health; ICNIRP;
immune; membranes; misleading; oxidative stress; pro-
teins; Public Health England (PHE); symptoms; tumours;
wireless; WHO.
Introduction
The International Commission on Non-Ionizing Radiation
Protection (ICNIRP) set international exposure guidelines
for radiofrequency (RF) electromagnetic fields in 1998
(1). Conclusions from subsequent ICNIRP reviews have
supported the guidelines. Within the United Kingdom
(UK), Public Health England (PHE) commission scientific
reviews by the Advisory Group on Non-ionising Radiation
(AGNIR) to assess the safety of RF fields. AGNIR reviews,
along with PHE in-house assessments of exposures, form
the basis of PHE’s advice on the safety of RF signals. This
guides the UK government, organisations and decision
makers when assessing the safety of wireless devices and
infrastructure. The latest AGNIR review (2) has also been
relied upon by health protection agencies around the
world, including the Australian Radiation Protection and
Nuclear Safety Agency (3) and Health Canada (4).
The majority of the global population absorb RF radi-
ation on a daily basis from smartphones, tablet comput-
ers, body-worn devices, Wi-Fi and Bluetooth transmitters,
cordless phones, base stations, wireless utility meters
and other transmitters. For public health to be protected,
decisions need to be based on accurate information. The
AGNIR report is considered here for conflicts of interest
and scientific accuracy.
Conflicts of interest
PHE stated, “The 2012 AGNIR report considered whether
there was evidence for health effects occurring in relation
to exposures below the ICNIRP levels” (5). At the time of
writing the report, the chairman of AGNIR was also chair
of the ICNIRP standing committee on epidemiology. Cur-
rently, six members of AGNIR and three members of PHE
or its parent organisation, the Department of Health (DH),
are or have been part of ICNIRP (Table 1). When the group
charged with assessing whether there is evidence of health
effects occurring at exposures below current ICNIRP values
have members who are responsible for setting the guide-
lines, it introduces a conflict of interest. How can AGNIR
report that the scientific literature contains evidence of
harmful effects below the current guidelines when several
of them are responsible for those guidelines? PHE provide
*Corresponding author: Sarah J. Starkey, Independent Neuroscience
and Environmental Health Research, 27 Old Gloucester Street,
London WC1N 3AX, United Kingdom of Great Britain and Northern
Ireland, E-mail: sarahstarkey@tesco.net
©2016, Sarah J. Starkey, published by De Gruyter.
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.
494     Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR
the official advice on the safety of wireless signals within
the UK, but having members in ICNIRP introduces a con-
flict of interest which could prevent them from acknowl-
edging adverse effects below ICNIRP guidelines.
PHE (the then Health Protection Agency) responded
to the report with “The Health Protection Agency welcomes
this comprehensive and critical review of scientific studies
prepared by the independent Advisory Group on Non-ionis-
ing Radiation” (6). The implication was that an independ-
ent group had produced the report and presented it to PHE.
However, at the time of writing, 43% of those in AGNIR were
from PHE or the DH (2) (Table 1). PHE had misleadingly
welcomed the report which they were involved in preparing.
Scientific accuracy
The executive summary of the AGNIR report included
Taken together, these studies provide no evidence of health
effects of RF field exposures below internationally accepted
guideline levels” [page 3 of the report (2)] and “the evi-
dence considered overall has not demonstrated any adverse
health effects of RF field exposures below internationally
accepted guideline levels” [page 4 (2)]. Accuracy is vital
when most people only read the executive summary and
overall conclusions from a 348-page report and national
and international public health decisions and exposures
are based on them. These conclusions did not accurately
reflect the evidence, as described in examples below.
(a) Studies were omitted, included in other sections
but without any conclusions, or conclusions left out; (b)
evidence was dismissed and ignored in conclusions; (c)
there were incorrect statements. Terms such as ‘convinc-
ing’ or ‘consistent’ were used to imply that there was no
evidence. Some examples fall into more than one category.
(a) Studies omitted, included in other sections but
without any conclusions, or conclusions left out
Only 7 studies were included in the section on reactive
oxygen species [ROS; page 94 (2); Figure 1]. These were
summarised by “production of reactive oxygen species
(ROS) were increased in some studies, but not others
[page 106 (2)]. At least a further 30 studies relevant to
ROS or the possible resulting damaging state of oxidative
stress were included throughout the report, but with no
reference to ROS or oxidative stress within the main text
for 16 of these (listed in Supplementary Information, SI)
and no mention of this subject in any other summaries
or conclusions. At least 40studies were omitted (using
AGNIR restriction to the English language; identified from
PubMed and EMF-Portal databases or references within
the papers; SI). If these had been included, 79% of studies
(61 out of 77) would have demonstrated evidence of sig-
nificantly increased ROS or oxidative stress in response to
Table 1: AGNIR in 2012 and 2016 and membership of ICNIRP, PHE or DH.
AGNIR  AGNIR 
Swerdlow A.J. (Chair)ICNIRP Chair of standing
committee on epidemiology
Swerdlow A.J. (Chair)formerly ICNIRP
Conney S.W. DH Conney S.W. DH
Coulton L.A. Coulton L.A.
Duck F.A. Duck F.A. ICNIRP
Feychting M. ICNIRP Feychting M. Vice-Chair ICNIRP
Haggard P. Haggard P.
Lomas D.J. Lomas D.
Noble D.
Mann S.M. HPA Mann S.M. ICNIRP, PHE
Maslanyj M.P. HPA Maslanyj M.P. PHE
Meara J.R. HPA Meara J.R. PHE
O’Hagan J.O. ICNIRP, PHE
Peyman A. HPA Peyman A. PHE
Powers H.
Rhodes L.
Rubin G.J. Rubin G.J.
Sienkiewicz Z.J. ICNIRP, HPA Sienkiewicz Z.J. ICNIRP, PHE
Tedstone A. PHE
Young A.
PHE was formerly known as the Health Protection Agency, HPA. PHE is part of the Department of Health, DH.
Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR    495
RF fields (Figure 1; SI). By only including a few of the avail-
able studies, not referring to many scattered throughout
the report and not mentioning ROS or oxidative stress in
any conclusions or the executive summary, this important
area of research was misrepresented. Oxidative stress is a
toxic state which can lead to cellular DNA, RNA, protein
or lipid damage (7, 8), is accepted as a major cause of
cancer (7), as well as being implicated in many reproduc-
tive, central nervous system, cardiovascular, immune and
metabolic disorders (7–14).
The conclusion for male fertility studies in animals
was “A substantial number of studies have investigated
the effects of RF fields on testicular function, principally
in rats, and most report large, obvious effects. However,
these results are largely uninterpretable due to inadequate
dosimetry or other shortcomings in the studies, and thus
are unsuitable for the purposes of health risk assessment.
One well-conducted study reported no effects on testicu-
lar function in rats exposed to 848 MHz CDMA signals
[page 191 (2)]. For male fertility in humans (in vivo), it
was concluded, “The evidence on the effect of RF fields
on sperm quality is still weak and the addition of the two
new studies does not allow reliable evaluation of the pres-
ence or absence of a health effect. Some suggestive posi-
tive results, although not convincing, give justification for
0
10
20
30
40
50
60
70
80
ABCDEFG
Number of studies
Figure 1: Comparison of the number of studies included in the
AGNIR report with those that could have been, for ROS, oxidative
stress or male fertility.
(A) studies included in the ROS section; (B) studies scattered
throughout the report on ROS or oxidative stress (but with no
summary or conclusion); (C) studies which could have been included
for ROS or oxidative stress; (D) studies included on male fertility in
the cellular studies chapter; (E) studies included on male fertility
in animal studies; (F) studies included on male fertility in humans
(invivo); (G) studies which could have been included for male fertil-
ity. Dark shading indicates evidence of significant increase of ROS
or oxidative stress, adverse effect on male fertility or altered male
testosterone concentrations in response to a radiofrequency field;
light shading indicates no significant increase of ROS or oxidative
stress, adverse effect on male fertility or altered male testosterone
concentrations. Studies are listed in SI.
further studies with improved methods. The evidence on
effects on male subfertility is very limited, and allows no
conclusions”.
At least 22 studies on male fertility were omitted
(AGNIR restriction to the English language; identified
from PubMed or EMF-Portal databases or references
within the papers; listed in SI). Considering those iden-
tified as included throughout the report (excluding three
subsequently retracted, SI), 78% of studies (18 out of
23) described significant adverse effects on sperm, male
reproductive organs or changes in male testosterone con-
centrations (SI). If the 22 references identified as omitted
had also been included, this would have been 35 out of 45,
78% (Figure 1; SI). Isolating small samples of evidence in
chapters on cells, animals or humans (Figure 1) may have
made it easier to dismiss significant effects on male repro-
ductive health. Inaccurately, in the overall and executive
summaries, the evidence for adverse effects on male fer-
tility disappeared: “Despite many studies investigating
effects on male fertility, there is no convincing evidence
that low level exposure results in any adverse outcomes on
testicular function” [page 192 (2)] and for humans, in vivo,
The limited available data on other non-cancer outcomes
show no effects of RF field exposure” [page 4 (2)]. The term
‘convincing’ is subjective and can erroneously imply that
there is no evidence. The human data on male fertility did
not show “no effects of RF field exposure”.
Some studies, mostly those which had tested signals
from real mobile devices, were dismissed as uninterpret-
able because they had not described the dosimetry, the
process of determining internal electromagnetic quan-
tities relating to exposure in tissues, in enough detail.
Limited descriptions restrict possible interpretations,
but do not make them uninterpretable. If the question
is ‘do mobile phone signals damage male fertility?’, real
phone signals are highly relevant because they allow pos-
sible effects of the complex patterns of fields to which
humans are exposed to be investigated. ICNIRP only
accept thermal effects of RF fields and focus on average
energy absorbed. Highly controlled, simulated signals
with descriptions of overall specific absorption rates
(SARs) are suited to the assessment of temperature rises
in cells or tissues. Real signals make it more difficult to
measure average energy, but have characteristics which
controlled, simulated signals lack. The complex field
patterns, with variable peak field strengths and intervals
between transmissions, may influence biology in ways
that controlled, simulated patterns cannot, but they are
not represented by time-averaged, duty factor reductions
of described energy absorption. Responses to RF fields
can be greater for intermittent exposures than continuous
496     Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR
(15, 16) and depend upon the pulse characteristics for the
same average power (17). Effects can be dependent on fre-
quency, modulation, signal strength (intensity windows),
durations of exposure and polarisation (18, 19). For the
nervous system, complex signals from real devices may
modulate neuronal activity, similar to endogenous electric
field ephaptic (non-synaptic) coupling in the brain (20).
There is evidence that endogenous electric fields feedback
to modulate neuronal activity (21). Fields with amplitudes
similar to those found in vivo, applied to neocortical brain
slices, modulated and entrained neuronal spiking activity
(21). Irregular patterns of fields with complex dynamics,
which mimicked in vivo fluctuations, entrained neuronal
activity more strongly than sine waves (21). There are valid
reasons for testing the effects of signals from real mobile
devices, and dismissing these limited and misrepresented
the evidence.
The summary for neurocognitive effects in humans
stated, “Studies of cognitive function and human perfor-
mance do not suggest acute effects of exposure to RF fields
from mobile phones and base stations” [page 226 (2)]. But
acute detrimental effects on cognition were omitted from
the report (22–25) or mentioned in different sections (26–
29). Increased errors during a memory task (26), slowed
performance (27) or decreased accuracy in a cognitive test
(28) were reported in the electroencephalogram (EEG)
section [pages 209–213 (2)]; slowed performance in cog-
nitive tests (29) were reported under sleep [page 215 (2)].
Omitting the studies which found effects in the relevant
section led to an incorrect conclusion.
For symptoms in humans, “Sufferers differ in terms
of the type of symptoms that they report, the speed with
which symptoms develop and the types of electromagnetic
field that appear to be problematic” [page 232 (2)]. Acute
provocation studies in humans expose all subjects to the
same short electromagnetic signal to see whether they
all respond with the same immediate symptoms. If the
speed with which symptoms develop and types of trigger
differ between individuals, then in a group overall a lack
of significance might be expected for identical acute
provocations, but this does not mean that some indi-
viduals cannot respond to certain fields given adequate
exposure durations, intervals between provocations
and low background electromagnetic fields, as has been
reported (30, 31). The executive summary concluded,
The evidence suggests that RF field exposures below
guideline levels do not cause acute symptoms in humans
[page 3 (2)], without explaining limitations.
Many of the longer-term observational studies
described significant associations of RF exposures with
symptoms, albeit with limitations in study designs: “While
some, though by no means all, of the studies reviewed
above appear to suggest an association between mobile
phone use and symptoms” [page 245 (2)], followed by
“almost all of the studies share a fundamental methodo-
logical problem which makes it difficult to draw any firm
conclusions from them: these studies relied upon the partic-
ipants’ own descriptions of their mobile phone usage as the
exposure variable for their analysis and on self-description
of symptoms while knowing exposure status” (2). Longer-
term studies on symptoms were omitted from the execu-
tive summary.
No mention was made of the World Health Organiza-
tion (WHO) International Agency for Research on Cancer
(IARC) classification of RF fields as a possible human
carcinogen in 2011, which was based on limited evidence
supporting carcinogenicity below ICNIRP guideline
values (32).
(b) Evidence dismissed and ignored in conclusions
For in vitro membrane effects, the report showed that all
studies included (seventeen (33–49); non-blood-brain
barrier (BBB)) described significant responses to RF signals
except for one, which had tested extremely high powers,
far greater than ICNIRP guidelines, that heated the tissue
[250–3600 W/kg time-averaged SAR (50); pages 102 and
103 (2)]. This heating study had reported an effect, an in
vitro recoverable decrease in population spike amplitude
in the hippocampus in response to the RF signal, but no
effect on long-term potentiation (50). The report text also
mentioned that Falzone etal. had found no changes to the
cell membrane [(51), page 101 (2)], but they had measured
markers of apoptosis, programmed cell death, not direct
effects on membranes; this paper was not included in
the table of studies on membrane effects. The membrane
studies were weakly dismissed: “In general, most studies
report finding effects on cell membranes when exposures
are made at mobile phone frequencies. However, the effects
reported are varied and, although the majority find effects,
neither is this unanimous nor does it necessarily provide
supporting evidence of a consistent effect. The variety of
cellular systems and exposures makes comparisons of the
effects on the cell membrane problematic and without inde-
pendent replication it is difficult to assess the robustness
or even the validity of the findings.” Studies had looked
at a range of effects and all, below high power heating,
reported significant changes, strengthening the validity of
the findings.
For direct effects on proteins, 15 out of 16 studies
listed found significant effects of RF fields [pages 103–105
(2); (52–67) effect; (53) no effect]. The conclusion was “In
general, most of the studies that have investigated changes
Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR    497
in protein function or structure due to exposure to RF fields
have found effects. However, at the present time the effects
have not been demonstrated to be robust by independent
replication; so although the concept of a direct effect of RF
field exposure on protein structure is interesting, further
research is needed to establish if this is a real phenom-
enon.” Ninety-four percent of the studies listed on direct
effects on proteins, from 14 different groups, found sig-
nificant effects, but the conclusion was turned around to
imply that these may not be real.
Where replications have been undertaken they do not
support the original findings. This continued lack of robust
evidence makes the possibility of an effect of RF fields on
cells more unlikely” [page 105 (2)]. An effect on cells is not
unlikely when there were significant effects in all of the
relevant studies on membranes (excluding BBB), all of the
studies except one on direct protein effects, the majority
of the studies on oxidative stress or male fertility, all of the
included in vitro genotoxicity studies on epithelial cells
[see c; page 84 (2)] and 47% of in vitro genotoxicity studies
which could have been included in the report (see c; SI).
Studies on cell membranes and direct effects on pro-
teins mostly found effects of RF field exposure. However, no
conclusions can be made as there are no common patterns
of exposure conditions or types of effects caused by the
exposure” [page 106 (2)]. Out of 33studies on direct effects
on proteins or cell membranes, 32 described significant
effects of RF signals below high power heating, but these
disappeared in the conclusions.
By the end of the report, the conclusion on cellular
studies had incorrectly become “There are now several
hundred studies in the published literature that have looked
for effects on isolated cells or their components when
exposed to RF fields. None has provided robust evidence for
an effect” [page 318 (2)].
A summary for human brain EEG recordings stated,
the EEG studies published since 2003 do provide some
evidence that RF fields could influence brain function, and
this should remain an area of interest” [page 226 (2)]. Many
EEG studies (awake or asleep subjects) reported changes
in electrical field potential oscillations, evoked responses
or interhemispheric coupling, but these were dismissed:
it remains unclear whether these RF effects, if they exist,
are material to human health or not”. Electrical field
potential oscillations can synchronise activity of local
networks (21) or propagate signals over large regions, con-
trolling brain developmental processes, including neu-
rogenesis, apoptosis, neuronal migration, differentiation
and network formation (68). Oscillations have been linked
with active processing or inhibition of cognitive functions
(69) and cyclic modulations of neuronal excitability (21).
References available at the time of the report describing
behavioural problems (70–72) and changed psychomotor
performance (73) associated with pre-natal or childhood
RF exposures, cell death and reduced cell numbers in the
brain (74–83) and cognitive inhibition (22–29, 78, 79, 84–
88) supported the possibility that RF-induced changes in
electrical activity could contribute to altered brain devel-
opment or cognition.
The executive summary included “There has been no
consistent evidence of effects on the brain, nervous system
or the blood-brain barrier, on auditory function, or on fer-
tility and reproduction” [page 3 (2)]. The term ‘consistent’
dismissed areas for which the majority of studies had
found adverse effects, such as male fertility. Of the studies
included in the report on pregnancy and development,
which quantified effects of pre-natal or early neonatal RF
exposures on neuronal cell numbers in the developing
brain [pages 184–187 (2)], four found significant decreases:
pyramidal cells in the rat hippocampus (74), granule cells
in the rat dentate gyrus (75), Purkinje cells in the mouse
cerebellum (76) and a transient increase in neurogenesis
of the subventricular zone following 8h of RF exposure
over 2days, but a long-lasting decrease in neurogenesis
following a 24 h exposure over 3days (77), measured from
proliferating cells in the rat rostral migratory stream. One
study described no effect on neuronal numbers in the
mouse hippocampus (89). Whilst not all reported effects,
the studies supported RF exposures decreasing neuronal
numbers in the brain during pre-natal and early neonatal
development at least in some circumstances (74–77). The
executive summary misleadingly implied that because not
all studies reported the same effects, RF signals have no
effect.
The AGNIR report suggested that symptoms in
humans may be caused by people’s perception of being
exposed, rather than the actual electromagnetic fields
[page 246 (2)]. Imagining a signal to be present is unlikely
to explain all responses, particularly symptoms reported
in response to RF signals under blind or double-blind
conditions (30, 31, 90). Many other studies support bio-
logical responses being related to the electromagnetic
signal, including evidence from cultured cells, in vitro
preparations, animals, plants or asleep humans, none
of which reacted with significant changes because they
imagined that RF signals were present. That living things
can respond to low power RF signals is now supported by
a large body of research.
(c) Incorrect statements
For child development [page 260 (2)], maternal mobile
phone use during pregnancy was associated with
498     Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR
behavioural problems in children at the age of 7 (70, 71)
and lower psychomotor performance was described for
children of mothers who had the highest mobile phone
use during pregnancy (73). The report said, “these results
are only suggestive of an effect, rather than being conclu-
sive evidence of one”. Increased conduct problems were
reported in 8–17-year-olds with the highest quartile of
RF exposures (72) [page 250 (2)]. As studies suggested
an effect on child development, the executive summary
incorrectly stated, “data on other non-cancer outcomes
show no effects of RF field exposure” [page 4 (2)].
For risks of brain tumours or acoustic neuromas in
humans, “the similar results of all investigators except
the Hardell group, with no methodological inferiorities
in these other investigatorsstudies overall, suggest that
the results of the Hardell group are the problematic ones
[page 308 (2)]. However, some significantly increased
risks of brain tumours or acoustic neuromas were
described in Hardell and non-Hardell studies [pages
282–306 (2), (91)], although non-Hardell significant data
were omitted from the data tables and only mentioned
in the text. For example, for gliomas with an ipsilateral
mobile phone use of    1640 cumulative hours (ages
30–59), the international Interphone study reported
a significant odds ratio (95% confidence interval) of
1.96 (1.223.16) and Hardell etal. reported a significant
odds ratio of 2.32 (1.14–4.73) (91). Had the data tables
included results for ipsilateral exposures, duration of
use and more detail of the pooled Interphone studies,
it would have been clearer that significantly increased
risks had been reported. “With no methodological infe-
riorities in these other investigators’ studies” was incor-
rect. The Interphone study did not take cordless phone
use into account in the analysis for mobile phones (91);
the Danish cohort study misclassified corporate mobile
phone users as non-users, as well as those who took
subscriptions out after 1995 (92).
The comment in the executive summary, “the accu-
mulating evidence on cancer risks, notably in relation to
mobile phone use, is not definitive, but overall is increas-
ingly in the direction of no material effect of exposure
[page 4 (2)], was misleading. Significant risks were most
common for ipsilateral exposures, latencies of 10years
or more since first use or the highest cumulative hours
of use (2), (91). If anything, as use increased, the evi-
dence increasingly pointed towards possible risks.
The executive summary stated for cells in vitro: “In
particular, there has been no convincing evidence that RF
fields cause genetic damage or increase the likelihood of
cells becoming malignant” [page 3 (2)] and in the chapter
on cellular studies: “Results from studies using other cell
types are also contradictory. Epithelial cells exposed to …
[page 86 (2)]. However, all in vitro studies included on
epithelial cells [four, one retracted, page 84 (2), (93–95)],
from more than one laboratory, found damage to DNA or
chromosomal aberrations in response to RF signals. Forty-
six percent of genotoxicity studies identified as included
in the report (36 out of 78; SI) described evidence for geno-
toxicity in response to RF fields, but at least 40 genotoxic-
ity studies were omitted (SI). If these had been included,
52% (61 out of 118) of genotoxicity studies overall and 47%
of in vitro (36 out of 76) would have described evidence
for genotoxicity (SI; AGNIR restriction to the English
language; identified from PubMed and EMF-Portal data-
bases). AGNIR found the genotoxicity evidence uncon-
vincing, but a more accurate conclusion could have been
that RF signals appear to be genotoxic under certain cir-
cumstances, but not others.
For the immune system [page 174 (2)], a Russian
study was included (96), which mostly replicated
earlier Russian studies and a French one which did not
(97). The conclusion was “it is clear that the results of
the original Soviet studies have not been confirmed”. It
was not clear, as the report also referred to the Russian
study with “These results do not appear to be identical
to the original, although they do show the same tendency.
Results of ELISA reinforced this conclusion. Grigoriev and
colleagues also reported that very few pregnant animals
receiving serum from exposed animals gave birth to live
animals (4 out of 12), which is also supportive of the previ-
ous results”.
The report described cognitive performance of RF-
exposed and sham-exposed Alzheimer’s disease-like
transgenic mice (98) [pages 144147 (2)]. However, there
were no shams in the study, as controls were housed in a
separate room without a Faraday cage; exposed mice (two
1 h exposures per day, 918MHz, SAR 0.25 W/kg) were con-
tinuously housed within a Faraday cage for up to 9months
(98). Cognitive improvements in the exposed groups com-
pared to controls may have been the result of long-term
protection from environmental electromagnetic fields by
the Faraday cage. Because background man-made elec-
tromagnetic fields may alter experimental results and are
often present in experimental environments, they ought
to be described in the Methods section for all biological
studies, but are often omitted, as in this paper. The AGNIR
report conclusions [page 318 (2)] described this as a well-
performed study, whilst other effects of RF signals on cog-
nition were dismissed as inconsistent. Varied responses
might indicate dependency upon physiological or experi-
mental conditions and do not automatically justify ignor-
ing evidence.
Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR    499
Conclusions
Decisions about involuntary, continuous and widespread
RF exposures in schools, hospitals, workplaces and public
and private spaces in the UK and around the world have
been made based upon inaccurate conclusions of the
AGNIR report. Published in 2012, it continues to be used
to justify RF exposures and dismiss concerns about possi-
ble adverse effects on health, well-being or development.
The denial of the existence of adverse effects of RF
fields below ICNIRP guidelines in the AGNIR report con-
clusions is not supported by the scientific evidence.
Studies have, as described as examples in this review,
reported damage to male reproductive health, proteins
and cellular membranes, increased oxidative stress, cell
death and genotoxicity, altered electrical brain activity
and cognition, increased behavioural problems in chil-
dren and risks of some cancers. For future official RF
reports, it is important to check that conclusions accu-
rately reflect available evidence before decisions which
impact on public health are made based on the executive
summary and overall conclusions.
The involvement of ICNIRP scientists in the mislead-
ing report calls into question the basis and validity of
the international exposure guidelines. To protect public
health, we need accurate official assessments of whether
there are adverse effects of RF signals below current inter-
national ICNIRP guidelines, independent of the group
who set the guidelines.
The anticipated WHO Environmental Health Crite-
ria Monograph on Radiofrequency Fields, due in 2017, is
being prepared by a core group and additional experts
(99), with 50% of those named, being, or having been,
members of AGNIR or ICNIRP (Table 2). Considering the
importance of the Monograph for worldwide public health
and the inaccuracies described here, independence from
AGNIR would increase confidence in the report findings.
Independence from ICNIRP is necessary to remove the
conflict of interest when effects below ICNIRP exposure
guidelines are being assessed.
Schools, hospitals, employers, organisations and
individuals have legal responsibilities to safeguard the
health, safety, well-being and development of children,
employees and members of the public. But they are unable
to fulfil their legal responsibilities when they have been
provided with inaccurate information and the evidence of
possible harm has been covered up.
Individuals and organisations who/that have made
decisions about the often compulsory exposures of others
to wireless RF communication signals may be unaware of
the physical harm that they may have caused, and may
Table 2: Named contributors to the WHO Environmental Health
Criteria Monograph on Radiofrequency Fields [(99), in preparation]
and membership of ICNIRP or AGNIR.
Core group
Feychting M. Vice-Chair ICNIRP, AGNIR
Mann S.M. ICNIRP, AGNIR
Oftedal G. ICNIRP
van Rongen E. Chair ICNIRP
Scarfi M.R.
Zmirou D.
Additional experts
Aicardi G.
Challis L. Formerly AGNIR
Curcio G.
Hug K.
Juutilainen J. ICNIRP
Lagorio S.
Loughran S. ICNIRP
Marino C. ICNIRP
McNamee J.
Naarala J.
Peyman A. AGNIR
Röösli M. ICNIRP
Rubin G.J. AGNIR
Schoemaker M.
Selmaoui B.
de Sèze R. ICNIRP
Sienkiewicz Z.J.ICNIRP, AGNIR
Simko M.
Vijaylaxmi
Zeni O.
still be causing, because they have not been accurately
informed of the risks. This has been a safeguarding failure
and the health of some children or adults may have been
damaged as a result. To prevent further possible harm,
restrictions on exposures are required, particularly for
children, pregnant women and individuals with medical
conditions. All children in schools and care environments
need protection from the potential harmful effects of RF
exposures and not, as is now often the case, a compulsory
use of wireless devices in the classroom. Children may
unjustly face losing their human right to an education if
they do not want to absorb RF fields every day at school
and no alternative environments are available. Attention
also needs to be given to the provision of safe working
environments for employees and safe public spaces, par-
ticularly where exposures are involuntary.
PHE and AGNIR had a responsibility to provide
accurate information about the safety of RF fields.
Unfortunately, the report suffered from an incorrect and
misleading executive summary and overall conclusions,
500     Starkey: Inaccurate official assessment of radiofrequency safety by AGNIR
inaccurate statements, omissions and conflict of inter-
est. Public health and the well-being of other species in
the natural world cannot be protected when evidence of
harm, no matter how inconvenient, is covered up.
Conflict of interest statement: The author states no con-
flict of interest.
Ethical approval: The conducted research is not related to
either human or animal use.
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... The ICNIRP (2010, 2020) limits are thousands of times above the levels where effects are recorded for both extremely low frequency and RF man-made EMF and account only for thermal effects, whereas the vast majority of recorded effects are non-thermal. These existing guidelines for public health protection only consider the effects of acute intense (thermal) exposures and do not protect from lower level long-term exposures (Israel et al., 2011;Yakymenko et al., 2011;Blank et al., 2015;Starkey, 2016;Belpomme and Irigaray, 2022). The exposure duration is crucial to assess the induced effects. ...
... A growing number of scientists have been calling internationally on governments to raise their safety standards for RF-EMF (Blank et al., 2015;Hardell and Nyberg, 2020;Frank, 2021). Thus, there is an urgent need to adopt the Precautionary Principle and impose more restrictive levels (Zinelis, 2010;Yakymenko et al., 2011;Blank et al., 2015;Starkey, 2016). ...
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... To address the concern of the potential harm of EVs, several researchers have measured EMF levels and compared these measures to the limits set by regulatory agencies. Predominately, the most commonly used regulations are those of the International Commission on Non-Ionizing Radiation Protection (ICNIRP) [9,10] and the Institute of Electrical and Electronics Engineers (IEEE) [11], but other agencies [12][13][14][15] have different limits due to differences in opinion and scientific deduction [16,17]. For example, the BioInitiative Working Group [17] argued that the ICNIRP limits were obtained using anatomical models and thus may not reflect the real human body. ...
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This study aimed to evaluate the direct current (DC) and alternating current (AC) electromagnetic field (EMF) intensity and distribution of an electric vehicle (EV). The results revealed that the EV generated DC and AC EMFs, which differed depending on the operation (resting, idling, and driving at speeds of 40 and 80 km/h). A correlation was established between the AC and DC components of the EMF, which was approximately 0.5 when idling and 0.8 at speeds of 40 and 80 km/h. The results obtained were below the harmful limit set by regulatory agencies, specifically the International Commission on Non‐Ionizing Radiation Protection (ICNIRP) and the Institute of Electrical and Electronics Engineers (IEEE). To further contribute to this field of study, the various measurement equipment used in the literature are summarized according to their parameters.
... Given the level of conflict of interest between the health sciences and the financial and political spheres [113][114][115][116], as well as the enormous military interests added to decades of research on weather modification techniques, could it be that solar geoengineering by SAI, able to change the weather and trigger serious environmental and health effects, is also tainted? ...
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... Industry-funded research, especially occupational and environmental health research, has been a topic of concern for decades, because it has often been found to be biased to support industry interests, according to numerous peer-reviewed papers, e.g., [8][9][10][11][12][13][14][15][16][17][18][19]. Moreover, several peer-reviewed papers have raised concerns about bias in industryfunded research on the effects of exposure to radio frequency radiation [20][21][22][23][24]. ...
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