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

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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?
Bioelectromagnetics 41:80--84 (2020)
LETTER
Comment on Letter: PostNormal Scienceandthe
Management of Uncertainty in
Bioelectromagnetic Controversiesby A.W. Wood
Steven Weller ,VictorLeach ,* and Murray May
Oceania Radiofrequency Scientic 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 eld (EMF)
related science. Wood notes that half a century of
scientic 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 selfinterests 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 multitrillion
dollar industry globally, and changing current prescribed
safety levels to more stringent standards would bring
about unfavorable nancial 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 conict 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 NONTHERMAL BIOEFFECTS: A
PARADIGM GULF?
Wood suggests that when it comes to lowlevel
effects, there is an apparentdivision between expert
groups. We do not consider that it is a case of being
apparentlydivided, implying this might not really be
the case. The reality is far more obvious with a clear
division existing between different campsthat have
signicant differences of opinion. The International
CommissiononNonIonizing 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 nonthermal bioeffects. Frey [1969]
summed this up very succinctly: Misunderstanding can
be traced to the controversy on thermal vs nonthermal
effects. A very heated controversy developed between
those who thought that only thermal effects could occur
and those who thought nonthermal effects could also
occuralong with “…investigators polarized into two
opposing camps.Nothing has really changed fty years
later. The thermalonly effects camp (ICNIRP) still
dominates positions of power when it comes to
establishing safety guidelines. However, a considerable
and developing literature demonstrates that bioeffects are
occurring in the absence of heating, with many having
the potential to cause harm, especially if sustained.
At the Oceania Radiofrequency Scientic
Advisory Association (ORSAA), of which we are
members, our scientic team has constructed the
worlds largest categorized online database of peer
reviewed studies on RFEMF and other manmade
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
Scientic Advisory Association.
Email: 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 signicant biological and/
or potential health effects associated with exposure to
anthropogenic EMFs. Because these bioeffects defy
traditional thinking that the energy from lowlevel RF
nonionizing radiation is too insignicant to cause
direct cell damage, they do not appear to be taken
seriously [ICNIRP, 2002]. Nonionizing radiation
may not have sufcient 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
valueneutral nature of science. Reinforcing such
observations, today we see powerful lobby groups
inuencing 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 gamingthe science
[Hertsgaard and Dowie, 2018]. Who benets from
such ethically challenged activities?
LACK OF TRUST
Wood then identies 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 pickingpapers, misrepresenting
the balance of evidence, the exclusion of evidence
under the guise of methodological aws, 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
NonIonizing Radiations (AGNIR) report [Starkey,
2016], and even the Australian Radiation Protection
and Nuclear Safety Agencys(ARPANSA)TRS164
report [Leach and Weller, 2017].
As part of a postnormal 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 benets of wireless technology.
Professional scientic 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 unltered
scientic 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
mainstreamscience 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 ammable cladding that now
has to be removed at huge nancial cost. RFEMF 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 benets
appear to be a higher priority than disclosing the long
term risks to public health. Nationstates (predominantly
Western) regulatory bodies, and the nonionizing
radiation protection NGO ICNIRP, are looking for
established evidence of harm before they will act, which
is not a recognized worlds 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
identication of all potential risks, weighing them and
developing mitigation strategies to prevent them from
developing into fullblown 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 scientic concerns about the impact such
radiation may have on the developing brain and body.
Wireless devices are not riskfree, 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 wellconducted
peerreviewed studies that show nonthermal bioeffects
Bioelectromagnetic Controversie 81
Bioelectromagnetics
that pose real risks to health [Leach et al., 2018]. The
Precautionary Approach is used as a risk management
framework in the face of scientic uncertainty [Gee,
2009]. It is curious indeed that Woodsletteron
uncertainty in bioelectromagnetic controversiesmakes
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 Gees paper Late Lessons from Early
Warnings[Gee, 2009] underlines the importance of
timing. For example, the time from the rst scienti-
cally based early warnings for many toxic agents
(1896 for medical Xrays, 1897 for benzene, 1898 for
asbestos) to the time of riskreduction policy action
has often been 30100 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
chlorouorocarbons (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
signicant 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 ozonedepleting substances. The Montreal
Protocol has now been ratied 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 manmade RFEMF can damage DNA, not only in
humans, but also in insects, plants, and animals.
Prolonged exposure to manmade RFEMF 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
bioeffects noted in research include cancer, neurode-
generation, mental illness, fertility issues, and cardi-
ovascular disease, to name but a few [Hardell, 2017].
POSTNORMAL SCIENCE
Hardell [2017] notes that the ICNIRP has not
recognized nonthermal bioeffects as being a health
hazard. Nonthermal biological effects from RF
radiation are dismissed as constituting scientic
evidence. Numerous health hazards are disregarded
such as cancer, neurodegeneration, bloodbrainbar-
rier, cognition, psychological addiction, sleep, beha-
vioral problems, and fertility effects [Hardell, 2017].
This reects the situation of science in its social
contextdiscussed by a pioneer of postnormal
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 advocatesand 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 citizensjuries 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 scientic
subjects.
PAPER C O U NT S
Wood discussed the limited value of simply
capturing paper counts of Effectsvs. 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: specicbioeffect
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 inuences 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 qualied,
cover a wide range of viewpoints, and include
82 Weller et al.
Bioelectromagnetics
representation from countries that have more stringent
scientically based RF standards.
This approach is consistent with the postnormal
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 realpolarizedpulsed RF signals with
complex patterns of lowfrequency modulations,
which vary in intensity, are much more bioactive.
This is symptomatic of the organismsdefense
systems being placed under stress and struggling to
adapt [Panagopoulos et al., 2015]. Simulated signals,
therefore, dont give a realistic world picture.
CONCLUSION
Woods 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 preventionis 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
scientic 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 scientic
research. Lowdose ionizing radiation dose limits are
in the same category as manmade RFEMF, yet the
International Commission on Radiological Protection
(ICRP) takes a precautionary approach when setting
limits, whereas this paradigm is completely absent in
the ICNIRPs philosophy on radiation protection. Post
Normal Science (PNS) critiques science in its social
contextwith too much acceptance of the role of
institutional stakeholders and opens the debate via the
PNS concept of the extended peer community.
ICNIRPs international guidelines only recognize
thermal effects, and pay no recognition to the non
thermal effects of nonionizing EMF. However, a large
body of scientic evidence suggests that bioeffects and
health impacts can and do occur at low exposure levels,
which can be thousands of times below public safety
limits. That is, ICNIRPs presumption that exposure to
nonthermal levels is safe is fundamentally awed.
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 yesterdays research and standards
obsolete.
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TABLE 1. Number of BioEffect Mobile Phone Studies With Signal Type and Waveform
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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