Enact RF EMF exposure limits based on all health and biological effects, not only those related to temperature, to protect humans – above all children, pregnant women, patients, the elderly, the infirm, electrohypersensitive people (EHS), those injured by this radiation and those using electromedical devices or implants; apply the precautionary principle.
In many cases, duration of exposure from a mixture of sources of RF EMF is 24/7/365. Existing exposure limits cannot protect living beings due to the following factors not taken into account:
- the frequency, the level, duration and type of exposure (Irish STATUTORY INSTRUMENTS No. 337 of 2016 page 7, point 7b),
- wave characteristics (modulation, power-density, polarization, pulsation, directionality and beam concentration, harmonics and heterodyning),
- duration of exposure, distance from sources of radiation, complex combination of multiple radiation sources,
- potential for Time-Dependant Sensitization in exposed organisms producing effects at decreasing intensities,
- the amplifying effects of different types of radiation as well as peak values,
- pulse frequencies must be considered separately from the fundamental frequency (Current EU legislation is based on the time integral of the EMF field intensity and does not take into account high pulse waveform of EMF modulated field. These can be extremely high in terms of signal propagation, while the time integral of the EMF limit is very small. Pulsed EMFs are usually much more biologically active than non-pulsed *1 *2)
RF EMF have negative effects as they interfere with biological, chemical and electrical systems in human organisms at lower intensities than current exposure limits allow. WHO EMF Project Report 2021 confirms that RF EMF induces oxidative stress in cells, which can lead to mitochondria DNA damage and adverse effects on other biological processes and organs. It has been proven bothin vitro and in vivo via several peer-reviewed studies that RF EMF opens up CA+(calcium voltage gated channels) *3 *4 *5 in cell membranes causing calcium reflux into the cells that starts multiple pathogenic processes within the body (oxidative stress *6, cellular signalling and cell metabolism, reproduction *7 *8 *9, fetal development *10, nervous system *11 *12, blood and cardiovascular systems, immune systems *13, etc.). 1998 ICNIRP guidelines confirm 'microwave hearing' and 'retinal damage' (page 14). Workplace Directive 2013/35/EU states 'stimulation of muscles, nerves or sensory organs' (Article 2). Continuous exposure to RF EMF maximizes the risk of persistent and continuous oxidative stress and, consequently, makes humans vulnerable to all health risks.
"High frequency electromagnetic fields (GSM signals) affect gene expression levels in tumor suppressor p53-deficient embryonic stem cells" *14
"The research established that while the current digital society will continue investment into 5G network technology, caution must be applied not to deploy 5G network under ultra-high frequency above 20 GHz due to its adverse health effects." *15 It is known that high-frequency EMF affects the sweat glands (which may serve as helical antennas) and may have indirect effects on many organs in the body. *16 *17
Also proven by several peer-reviewed studies, long-term, below-ICNIRP limits exposure causes both single and double bond breakage of DNA. International Agency for Research of Cancer (IARC) classified RF-EMF as a “Class 2B” (a possible human carcinogen) in 2011 and in 2019 instructed research groups to focus on RF-EMF as a causal agent in their upcoming monographies. There is a common consensus that this will most probably lead to a re-evaluation of category, more severe than 2B.
Directive 2013/35/EU recognizes Non-thermal RF EMF effects as a known workplace health risk,although workplace guidelines are still based on 6 minutes, which does not represent normal workplace exposure. Adult workers have legally binding RF EMF directives recognising detrimental effects of exposure intensities less than worldwide RF EMF limits on the physical and mental health of employees. We ask the EU Commission to actively enforce Directive 2013/35/EU by implementing RF EMF risk assesment in all workplaces. Mental health is a global issue. The EU Commission have an opportunity to demonstrate leadership by promoting RF EMF Risk assessments to help reduce stress and anxiety in the workplace.
Practical notes on workplace exposure are in Explanation of Proposal 7.
The EU Commission does not extend this legal recognition to the general public. Radiation protection must be provided equally to all, to people at home and in public spheres, not only at workplaces. This is discrimination against the general public as compared to employees at a workplace.
Parliamentary Assembly Resolution 1815 in point 8.1.1. states: "all reasonable measures to reduce exposure to electromagnetic fields, especially to radio frequencies from mobile phones, and particularly the exposure to children and young people who seem to be most at risk from head tumours".
The EU Commission does not provide recognised non-thermal *18 EMF protection for children, neither in schools nor in homes or public places. The health of the children is neglected whereby they are discriminated against (Art. 21 of CFR) and it is a breach of the TEU, UNCRC.
Children are not little adults: *19
- The thickness of the skull acts as a barrier to radiation absorbtion. Since children have smaller heads and much thinner skulls than adults, they have less protection *20 and receive aproportionally greater intracranial peak tissue dose.
- Cell phones and wireless radiation can go deeper into their brains also because children have a shorter distance *21 from their skull to their brain center. Research shows that children can absorb up to ten times the radiation in the bone marrow of their skulls *22 than adults.
- Children have a higher content of water in their cerebral tissues, and also in their bodies. This makes their bodies more conductive so they absorb more of this wireless energy radiation *23 to their tissues because of their unique physiology.
- Children have smaller bodies and shorter arms. They hold cell phones, tablets, and wireless devices closer to their faces, brain, bodies . Children thus receive a much higher cumulative exposure than adults, when using similar devices. *2
- They have a rapid rate of growth and development and incomplete myelination *25 of the brain, which make children uniquely susceptible to the effects of radiation. Scientists who expose animal brains to even small amounts of microwaves find damaged brain cells and more dead cells. Research shows that disruption of brain development *26 at an early age can cause significant neurological changes later on in life.
- Children have more active stem cells *27 in their bodies, that are present in higher density, especially in the first stages of development. Research *28 shows that stem cells are often more sensitive and reactive to low levels of microwave radiation than other cells. Stem cells are critical for children’s development but are also impacted the most by wireless! *29 *30
- Regulations are not based on a child’s head but on a proportions of a head of mature man.
Published research has found impaired communication skills, memory and learning deficits, congentital heart disease and behavioral problems associate with prenatal exposures. *31
Maternal cell phone use during pregnancy may be associated with an increased risk of behavioral problems, particularly hyperactivity/inattention problems, in the offspring. *32
For newborns whose mothers used their mobile phones for more than 30 minutes/day there was an association with significantly lower fetal development scores. *33
The elderly and the infirm:
Their immune system is compromised and cocktail effect with other diseases may occur. Exposure to RF EMF may contribute to worsening their condition: "RF-EMR studies indicate increased specific vulnerabilities in the young (fetus to adolescent), the elderly, and those with cancer." *34
Those injured by and sensitive to RF EMF:
"In population-based surveys, the prevalence of EHS has ranged from 1.5% in Sweden to 13.3% in Taiwan." *35
"...data strongly suggest that EHS is a neurologic pathological disorder which can be diagnosed, treated, and prevented. Because EHS is becoming a new insidious worldwide plague involving millions of people, we ask the World Health Organization (WHO) to include EHS as a neurologic disorder in the international classification of diseases." *36
The Austrian Medical Association has developed a guideline for differential diagnosis and potential treatment of unspecific health problems associated with electrosmog. *37
"In Sweden, electrohypersensitivity (EHS) is an officially fully recognized functional impairment (i.e., it is not regarded as a disease). Survey studies show that somewhere between 230,000-290,000 Swedish men and women report a variety of symptoms when being in contact with electromagnetic field (EMF) sources." *38
(Updated in January 2022: Already in 1995 the Swedish government decided that The Swedish Association for the Electrosensitive is a disability organisation. As such it was granted yearly support for its work. This fact has sometimes been misinterpreted as if electromagnetic hypersensitivity is a recognised medical diagnosis in Sweden.)
Those who use electromedical devices or implants:
The American Food&Drug Agency provides Pacemaker Wearers with a list of precautions.
The review Electromagnetic interference in cardiac electronic implants shows that the factors influencing electromagnetic interference are not sufficiently characterized and radiation limit valuesfor patients cannot be derived yet.
The study Are patients with cardiac implants protected against electromagnetic interference in dailylife and occupational environment? shows that electromagnetic interferences are associated with potential risk in "device patients".
"As the number of radio frequency emitters increases under this new paradigm public health and safety must also be taken into account. This paper explores the electromagnetic interference on implantable cardiac rhythm management devices caused by RFID interrogators."
5G Deployment: State of play in Europe, USA and Asia is undergoing an in depth analysis at the request of the ITRE Committee. Among findings is: "Long-term technology research is essential. One key problem is the unusual propagation phenomena, especially controlling and measuring RF EMF exposure..."
Legal arguments for our proposal are:
- Article 3 of the TEU where it says, "The Union's aim is to promote peace, its values and the well-being of its peoples." and "It shall combat social exclusion and discrimination, and shall promote social justice and protection, equality between women and men, solidarity between generations and protection of the rights of the child."
- Article 4 of the TFEU that includes "common safety concerns in public health matters" among the 11 shared competences
- Article 168 of the TFEU where it says, "A high level of human health protection shall be ensured..." and "Union action... shall be directed towards improving public health, preventing physical and mental illness and diseases, and obviating sources of danger to physical and mental health."
- Article 191 of the TFEU that includes "protecting human health" among Union policy objectives.
- Article 153 of the TFEU where it says, "improvement in particular of the working environment to protect workers' health and safety"
- Article 21 of the CFR where it says, "Any discrimination based on any ground such as sex, race, colour, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of national minority, property, birth, disability, age or sexual orientation shall be prohibited."
- Article 24 of the CFR where it says, "Children shall have the right to such protection and care as is necessary for their well-being."
- Article 31 of the CFR where it says, "Every worker has the right to working conditions which respect his or her health, safety and dignity."
- Article 35 of the CFR where it says, “A high level of human health protection shall be ensured in the definition and implementation of all the Union's policies and activities.”
- Article 24 of the UNCRC where it says, "States Parties recognize the right of the child to the enjoyment of the highest attainable standard of health and to facilities for the treatment of illness and rehabilitation of health. States Parties shall strive to ensure that no child is deprived of his or her right of access to such health care services."
- Precautionary principle is explained in the chapter Precautionary principle.
- Our arguments against ICNIRP can be found in the chapter We Consider ICNIRP Flawed.
2 Panagopoulos, 2019: Comparing DNA damage induced by mobile telephony and other types of man-made electromagnetic fields; Mutation research 781; https://www.sciencedirect.com/science/article/abs/pii/S1383574218300991
4 Scheler 2016: Polarisation: Ein wesentlicher Faktor für das Verständnis biologischer Effekte von gepulsten elektromagnetischen Wellen niedriger Intensität; https://www.emfdata.org/de/dokumentationen/detail?id=103
5 Eberhardt and Halgamuge 2011: Reply to Comment on "Behavior of Charged Particles in a Biological CellExposed to AC-DC Electromagnetic Fields"; https://www.academia.edu/1133361/Reply_to_Comment_on_Behavior_of_Chto_AC_DC_Electromagnetic_Fields _and on_Comparison_Between_Two_Models_of_Interaction_Between_Electric _and_Magnetic_Fields_and_Proteins_in_Cell_Membranes_
8 Pooja Negi & Rajeev Singh, 2021: Association between reproductive health and nonionizing radiation exposure; Electromagnetic Biology and Medicine, https://www.tandfonline.com/doi/full/10.1080/15368378.2021.1874973
9 Gautam et al 2021: Impact of nonionizing electromagnetic radiation on male infertility: an assessment of the mechanism and consequences; International Journal of Radiation Biology,https://www.tandfonline.com/doi/full/10.1080/09553002.2020.1859154
10 Hozefa A Divan et al 2008: Prenatal and postnatal exposure to cell phone use and behavioral problems in children; https://pubmed.ncbi.nlm.nih.gov/18467962/
12 Pall 2016: Microwave frequency electromagnetic fields (EMFs) produce widespread neuropsychiatric effects including depression; Journal of Chemical Neuroanatomy; https://www.sciencedirect.com/science/article/pii/S0891061815000599
14 Czyz et al 2004: High frequency electromagnetic fields (GSM signals) affect gene expression levels in tumor suppressor p53-deficient embryonic stem cells; PMID: 15114639; https://pubmed.ncbi.nlm.nih.gov/15114639/
15 Matthew et al 2021: Chemical Polarization Effects of Electromagnetic Field Radiation from the Novel 5G Network Deployment at Ultra High Frequency; Health and Technology; https://pubmed.ncbi.nlm.nih.gov/33527067/
16 Belyaev, 2019: Main Regularities and Health Risks from Exposure to Non-Thermal Microwaves of Mobile Communication; 14th International Conference on Advanced Technologies, Systems and Services in Telecommunications (TELSIKS); https://ieeexplore.ieee.org/document/9002324
18 Martin Pall, 2015: How to Approach the Challenge of Minimizing Non-Thermal Health Effects of Microwave Radiation from Electrical Devices: "22 additional scientific published reviews have each reviewed various types of non-thermal microwave effects in humans and/or experimental animals in various contexts, as have 26 studies in a recently published book. It can be seen from this that there is a widely held consensus in much of the scientific community that various non-thermal effects of microwave EMFs are well documented"; https://www.researchgate.net/publication/283017154HowtoApproachtheChallengeofMinimizingNon-ThermalHealthEffectsofMicrowaveRadiationfromElectricalDevices
19 WHO document Children are not little adults addresses the importance of ensuring a healthy environment for children and protecting them from environmental threats. It provides explanations that due to the increased and unique vulnerability of children are their risks of environmental hazards different from those of adults. https://www.who.int/ceh/capacity/Children_are_not_little_adults.pdf
21 Salles et al 2006: Electromagnetic absorption in the head of adults and children due to mobile phone operation closeto the head; Electromagnetic Biology and Medicine; https://pubmed.ncbi.nlm.nih.gov/17178592/
23 Fernández et al 2018: Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality, Environmental Research, Volume 167, 2018, Pages 694-699, ISSN 0013-9351, https://doi.org/10.1016/j.envres.2018.05.013
24 Belpomme et al 2018: Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international perspective; Environmental Pollution; https://www.sciencedirect.com/science/article/pii/S0269749118310157
25 Arain et al 2013: Maturation of the adolescent brain; https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3621648/
26 Bhargav et al 2015: Effect of Mobile Phone-Induced Electromagnetic Field on Brain Hemodynamics and Human Stem Cell Functioning: Possible Mechanistic Link to Cancer Risk and Early Diagnostic Value of Electronphotonic Imaging; https://www.researchgate.net/publication/305157931_Effect_of_Mobile_Phone-Induced_Electromagnetic_Field_on_Brain_Hemodynamics_and_Human_Stem_Cell _Functioning_Possible_Mechanistic_Link_to_Cancer_Risk_and_Early_Diagnostic _Value_of_Electronphotonic_Imagi
28 Belyaev, I.Y. et al. 2009. Microwaves from UMTS/GSM mobile phones induce long-lasting inhibition of 53BP1/gamma-H2AX DNA repair foci in human lymphocytes. Bioelectromagnetics 30: 129–141; https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.20445
29 Igor Belyaev et al 2009: Microwaves from Mobile Phones Inhibit 53BP1 Focus Formation in Human Stem Cells More Strongly Than in Differentiated Cells: Possible Mechanistic Link to Cancer Risk; https://lup.lub.lu.se/search/publication/41191802-89ab-4bbb-94f2-4fd6c515e9f4
36 Belpomme et al 2020: Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder: How to Diagnose, Treat, and Prevent It; https://pubmed.ncbi.nlm.nih.gov/32168876
37 Guideline of the Austrian Medical Association (ÖÄK) for the diagnosis and treatment of EMFrelated health problems and illnesses (EMF syndrome); https://www.elektrosmogazdravie.sk/wp-content/uploads/docs/OAK_guideline_en.pdf
39 J. R. Stachel, E. Sejdić, A. Ogirala and M. H. Mickle, "The impact of the internet of Things on implanted medical devices including pacemakers, and ICDs," 2013 IEEE International Instrumentation and Measurement Technology Conference (I2MTC), 2013, pp. 839-844, doi: 10.1109/I2MTC.2013.6555533. https://ieeexplore.ieee.org/document/6555533