Comment on Letter: “Post‐Normal Science and the Management of Uncertainty in Bioelectromagnetic Controversies” by A.W. Wood

Abstract

The letter to the editor [Wood, 2019] touches on
some important points, and Andrew Wood should be
commended for highlighting problems that we are
witnessing in interpreting electromagnetic field (EMF)‐
related science. Wood notes that half a century of
scientific research into the safety of EMFs (from static
to 300 GHz) has not resulted in any substantial policy
advice changes. The question that we believe needs to
be asked is as follows: Is the continuing unchanged
policy advice on EMFs occurring because those who
are trying to advocate change have no voice in the
process and because the process is dominated by
groups with self‐interests in maintaining the status quo?

Full text

Bioelectromagnetics 41:80--84 (2020)
LETTER
Comment on Letter: “Post‐Normal Scienceandthe
Management of Uncertainty in
Bioelectromagnetic Controversies”by A.W. Wood
Steven Weller ,VictorLeach ,* and Murray May
Oceania Radiofrequency Scientific Advisory Association, Brisbane, Queensland,
Australia
The letter to the editor [Wood, 2019] touches on
some important points, and Andrew Wood should be
commended for highlighting problems that we are
witnessing in interpreting electromagnetic field (EMF)‐
related science. Wood notes that half a century of
scientific research into the safety of EMFs (from static
to 300 GHz) has not resulted in any substantial policy
advice changes. The question that we believe needs to
be asked is as follows: Is the continuing unchanged
policy advice on EMFs occurring because those who
are trying to advocate change have no voice in the
process and because the process is dominated by
groups with self‐interests in maintaining the status quo?
Radiofrequency electromagnetic radiation (RF‐
EMF) in particular is of critical importance to defense
for communications, surveillance, missile guidance, and
detection. RF technology is a booming multi‐trillion
dollar industry globally, and changing current prescribed
safety levels to more stringent standards would bring
about unfavorable financial consequences and affect
industrial and military functions. In some countries,
such as Australia, the regulator, which has a health
protection responsibility, also sells RF spectrum licenses,
which represents a clear conflict of interest. The very
same agencies with responsibility for providing safety
advice to the public are also considered by some to have
been captured by the industry [Alster, 2015].
THERMAL AND NON‐THERMAL BIO‐EFFECTS: A
PARADIGM GULF?
Wood suggests that when it comes to low‐level
effects, there is an “apparent”division between expert
groups. We do not consider that it is a case of being
“apparently”divided, implying this might not really be
the case. The reality is far more obvious with a clear
division existing between different “camps”that have
significant differences of opinion. The International
CommissiononNon‐Ionizing Radiation Protection
(ICNIRP) [ICNIRP, 2002] vs. BioInitiative group
[Sage, 2012] is one clear example. A letter to the United
Nations and its subordinates [IEMFSA, 2014], now
signed by 250 concerned international scientists from 42
countries, is another example that to date has not been
adequately addressed or acknowledged by the World
Health Organization (WHO) or other relevant bodies such
as ICNIRP. These divergent expert groups are diame-
trically split based on their understanding and support, or
lack of support, for non‐thermal bio‐effects. Frey [1969]
summed this up very succinctly: “Misunderstanding can
be traced to the controversy on thermal vs non‐thermal
effects. A very heated controversy developed between
those who thought that only thermal effects could occur
and those who thought non‐thermal effects could also
occur”along with “…investigators polarized into two
opposing camps.”Nothing has really changed fifty years
later. The thermal‐only effects camp (ICNIRP) still
dominates positions of power when it comes to
establishing safety guidelines. However, a considerable
and developing literature demonstrates that bio‐effects are
occurring in the absence of heating, with many having
the potential to cause harm, especially if sustained.
At the Oceania Radiofrequency Scientific
Advisory Association (ORSAA), of which we are
members, our scientific team has constructed the
world’s largest categorized online database of peer‐
reviewed studies on RF‐EMF and other man‐made
Received for review 3 August 2019; Accepted 27 September 2019
DOI:10.1002/bem.22225
Published online 13 October 2020 in Wiley Online Library
(wileyonlinelibrary.com).
*Correspondence to: Victor Leach, Oceania Radiofrequency
Scientific Advisory Association.
E‐mail: victor.leach@orsaa.org
©2019 Bioelectromagnetics Society

EMFs of lower frequencies. A recent evaluation of
2,266 studies (including in vitro and in vivo studies in
human, animal, and plant experimental systems and
population studies) found that most studies (n=1,546,
68.2%) have demonstrated significant biological and/
or potential health effects associated with exposure to
anthropogenic EMFs. Because these bio‐effects defy
traditional thinking that the energy from low‐level RF
non‐ionizing radiation is too insignificant to cause
direct cell damage, they do not appear to be taken
seriously [ICNIRP, 2002]. Non‐ionizing radiation
may not have sufficient energy to knock electrons
off from atoms, but it can affect molecular structures
and interfere with metabolic processes as evidenced
by the categorized biological effects noted in the
ORSAA database [Leach et al., 2018].
SCIENCE IN CRISIS
Wood refers to the good governance of science
and its use or misuse for policy formation. Further-
more, he cautions against clinging to the myth of the
value‐neutral nature of science. Reinforcing such
observations, today we see powerful lobby groups
influencing science and government policy. It appears
that tobacco science is still alive and well with many
of the techniques being adopted and improved upon.
Leaked internal memos from telecommunications
companies show they are “war gaming”the science
[Hertsgaard and Dowie, 2018]. Who benefits from
such ethically challenged activities?
LACK OF TRUST
Wood then identifies some of the problems that
potentially create friction and discontent with reference
to methods of collection, analysis, and comparison of
evidence. We believe he is right on the mark with this
assessment. “Cherry picking”papers, misrepresenting
the balance of evidence, the exclusion of evidence
under the guise of methodological flaws, avoiding the
discussion of topics that challenge safety or worse, or
dismissing them as unimportant are just a few examples
of the concerns being raised by concerned scientists
from around the world. This is most evident with
SCENIHR 2015 [Pall, 2018; Sage et al., 2015], the UK
Health Protection Agency (HPA) Advisory Group on
Non‐Ionizing Radiation’s (AGNIR) report [Starkey,
2016], and even the Australian Radiation Protection
and Nuclear Safety Agency’s(ARPANSA)TRS‐164
report [Leach and Weller, 2017].
As part of a post‐normal science paradigm, we
are witnessing an unprecedented number of public
websites being established by concerned citizens and
independent scientists to address what they consider to
be government and industry rhetoric via media
channels on the benefits of wireless technology.
Professional scientific organizations such as the
International EMF Alliance, ORSAA, and the Envir-
onmental Health Trust (EHT) have been established in
order to provide support services and unfiltered
scientific advice that is absent from regulators and
radiation protection authorities. The issue of trust is at
the forefront of this activity. After all, we only have to
look at the recent past to see how governments and
“mainstream”science have gotten it wrong before—
many times. Tobacco smoking, asbestos, Agent
Orange, and thalidomide are just a few obvious
examples. A current topical example in Australia is
buildings covered in the flammable cladding that now
has to be removed at huge financial cost. RF‐EMF is
also likely to be a candidate added to this growing list
of government/industry mishandling and misconduct.
RISK MANAGEMENT AVOIDANCE
Evidence of potential harm is being downplayed—
or worse, swept under the carpet by the dominant
industry groups and government regulatory bodies.
Financial gains masked by claims of community benefits
appear to be a higher priority than disclosing the long‐
term risks to public health. Nation‐states (predominantly
Western) regulatory bodies, and the non‐ionizing
radiation protection NGO ICNIRP, are looking for
established evidence of harm before they will act, which
is not a recognized world’s best practice for risk
management. To establish harm is the point at which a
potential risk materializes and automatically becomes an
issue, which is far too late given the size of the
population being exposed without any formal consent.
Risk management best practice calls for the
identification of all potential risks, weighing them and
developing mitigation strategies to prevent them from
developing into full‐blown problems. We need to change
behavior to promote better practices that result in
reduced exposures to microwave radiation from mobile
phones, cell towers, and other wireless devices, in light
of growing scientific concerns about the impact such
radiation may have on the developing brain and body.
Wireless devices are not risk‐free, and the public must
be informed so that they can make informed decisions
about how they choose to use wireless technology.
PRECAUTIONARYAPPROACH AND THE
PRECAUTIONARY PRINCIPLE
Currently, there are thousands of well‐conducted
peer‐reviewed studies that show non‐thermal bio‐effects
Bioelectromagnetic Controversie 81
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that pose real risks to health [Leach et al., 2018]. The
Precautionary Approach is used as a risk management
framework in the face of scientific uncertainty [Gee,
2009]. It is curious indeed that Wood’sletteron
“uncertainty in bioelectromagnetic controversies”makes
no mention of this important principle. The trigger points
for invoking the Precautionary Principle can be variable
depending on the perceived or likelihood of risk [Leach
and Bromwich, 2018].
There are two main factors that trigger the
precautionary approach: the strength or balance of
evidence, and the potential cost of doing nothing.
David Gee’s paper “Late Lessons from Early
Warnings”[Gee, 2009] underlines the importance of
timing. For example, the time from the first scienti-
fically based early warnings for many toxic agents
(1896 for medical X‐rays, 1897 for benzene, 1898 for
asbestos) to the time of risk‐reduction policy action
has often been 30–100 years, during which time
exposure increased considerably. One consequence of
failure to act in time is greater and irreversible damage
over longer time periods. A further example is
chlorofluorocarbons (CFCs) which were discovered
in 1928 and later put into industrial use as refrigerants.
It turned out that ignorance of the effects that CFCs
have on stratospheric ozone became a major life‐
threatening gap in understanding when it was
discovered in the 1980s that there was a huge hole
in the ozone layer over the South Pole. Predictions of
significant increases in the incidence of skin cancer
resulting from continued use of CFCs spurred
international action. In 1987, 56 countries agreed
under what became known as the Montreal Protocol to
phase out ozone‐depleting substances. The Montreal
Protocol has now been ratified by 197 parties.
Use of the ORSAA database can readily identify
risks, which need to be handled appropriately. The
accumulated evidence is suggesting chronic exposures
to man‐made RF‐EMF can damage DNA, not only in
humans, but also in insects, plants, and animals.
Prolonged exposure to man‐made RF‐EMF results in
cellular stress and the production of free radicals,
disruption of the endocrine system, and changes in
neurotransmitter levels [Leach and Weller, 2017]. The
health risks from this subset of an even greater list of
bio‐effects noted in research include cancer, neurode-
generation, mental illness, fertility issues, and cardi-
ovascular disease, to name but a few [Hardell, 2017].
POST‐NORMAL SCIENCE
Hardell [2017] notes that the ICNIRP has not
recognized non‐thermal bio‐effects as being a health
hazard. Non‐thermal biological effects from RF
radiation are dismissed as constituting scientific
evidence. Numerous health hazards are disregarded
such as cancer, neurodegeneration, blood‐brain‐bar-
rier, cognition, psychological addiction, sleep, beha-
vioral problems, and fertility effects [Hardell, 2017].
This reflects the “situation of science in its social
context”discussed by a pioneer of post‐normal
science concepts [Ravetz, 1999]. Ravetz asks “in
whose interest, and under whose control, the basic
science is done.”He questions “scientists who present
themselves as impartial judges when they are actually
committed advocates”and calls for an “extended peer
community,”consisting “not merely of persons with
some form or other of institutional accreditation
(“stakeholders”),”but rather all those seeking a broad
base of consensus including scientists with a differing
viewpoint and communities via citizens’juries and so
on. Instructive in relation to community groups
wishing to place a moratorium on implementing 5G,
Ravetz says, “it turns out that educated common sense
can be quite effective in the assessment of policy
implications of even the most technical of scientific
subjects.”
PAPER C O U NT S
Wood discussed the limited value of simply
capturing paper counts of “Effects”vs. “No Effects.”
Without digging deeper into the data, this statement has
merit. However, paper counts can provide a wealth of
information when used in conjunction with other
attributes such as, but not limited to: specificbio‐effect
endpoints; cell types (for in vitro studies); funding
sources; country where principal research is conducted;
signal type (pulsed or continuous, amplitude modulated,
or frequency modulated); signal source (real mobile
phone or signal generator); authors of papers.
This approach allows discerning researchers to
look for trends and possible relationships between
these parameters and possible influences that may
affect outcomes. It can help highlight potential
sources of uncertainty.
Typical categories of biological effects include:
oxidative stress/ROS/super oxides/free radicals/lipid
peroxidation; DNA damage; altered enzyme activity/
protein damage/altered protein levels; biochemical
changes; cell irregularities/cell damage/morphological
change/apoptosis; neurobehavioral/cognitive changes;
and sperm effects.
To counter the cloning effect of coalitions of
experts with similar core values, it is important to
determine whether review panels are suitably estab-
lished with people who: are adequately qualified,
cover a wide range of viewpoints, and include
82 Weller et al.
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representation from countries that have more stringent
scientifically based RF standards.
This approach is consistent with the post‐normal
science concept of the “extended peer community.”
The last point is extremely important if the WHO
wishes to continue its efforts to establish a global
harmonized RF standard, something that is absent in
ICNIRP representation. One can also mine the data to
see if uncertainty is real or potentially manufactured.
A clear example includes the use of signal generators
vs real mobile phone emissions as shown in Table 1
[Leach et al., 2018].
Researchers use both real mobile phone signals
in their experiments as well as simulated signals, and
it is clear that real‐polarized‐pulsed RF signals with
complex patterns of low‐frequency modulations,
which vary in intensity, are much more bio‐active.
This is symptomatic of the organisms’defense
systems being placed under stress and struggling to
adapt [Panagopoulos et al., 2015]. Simulated signals,
therefore, don’t give a realistic world picture.
CONCLUSION
Wood’s letter states that there are now probably
more phone handsets than people in the world, and the
stakes of overlooking harm are high. We agree, but
consider that the management of uncertainty requires a
far more rigorous precautionary approach than he
appears to advocate. Lin [2016] similarly suggests that
because of the growing ubiquity of mobile phones and
wireless devices, an “ounce of prevention”is worthy of
consideration, particularly as full recognition of public
health risks can take time, as occurred with tobacco
smoking and various cancers. The wide divergence in
legislated maximum exposure limits in different
countries suggests that there is no such thing as
scientific consensus on EMF safety. People from
countries following the Federal Communications
Commission (FCC) recommendations or ICNIRP
guidelines need to ask why their regulators hold such
opposed views from the same body of scientific
research. Low‐dose ionizing radiation dose limits are
in the same category as man‐made RF‐EMF, yet the
International Commission on Radiological Protection
(ICRP) takes a precautionary approach when setting
limits, whereas this paradigm is completely absent in
the ICNIRP’s philosophy on radiation protection. Post‐
Normal Science (PNS) critiques “science in its social
context”with too much acceptance of the role of
institutional stakeholders and opens the debate via the
PNS concept of the “extended peer community.”
ICNIRP’s international guidelines only recognize
thermal effects, and pay no recognition to the non‐
thermal effects of non‐ionizing EMF. However, a large
body of scientific evidence suggests that bio‐effects and
health impacts can and do occur at low exposure levels,
which can be thousands of times below public safety
limits. That is, ICNIRP’s presumption that exposure to
non‐thermal levels is safe is fundamentally flawed.
Useful policy recommendations and challenges
for research arising from rapid technological changes
are outlined by Miller et al. [2019]. In addition to
addressing total cumulative exposure across the
spectrum from multiple sources and for sensitive
populations such as children, there is an increasing
need to address changes in carrier frequencies and
the growing complexity of modulation technologies,
rendering yesterday’s research and standards
obsolete.
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Research categories Real mobile phone used in experiments Simulated mobile phone used in experiments
Waveform Pulsed Pulsed
Outcome #Effect #No effect #Uncertain effect #Effect #No effect #Uncertain effect
in vivo 120 18 11 69 49 8
in vitro 28 8 1 60 63 7
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