We Consider ICNIRP Flawed

What and who is ICNIRP?

ICNIRP is a private German association consisting of a Commission of up to 14 members with a scientific background, most of whom are very closely related to the industry. *1, page 98 Its board members have a long-time history of employment within the telco industry (directly or as consultants). One such example is Martin Röösli.

Martin Röösli (Switzerland) is employed in his main job as a Professor of Environmental Epidemiology at the Swiss Tropical and Public Health Institute in Basel. This institute serves many corporate clients, including Swisscom, the largest telecommunications company in Switzerland. In its 2019 annual report, the institute discloses that of the total budget of about 90 million Swiss francs, 78.6% was "competitively acquired". *1, page 98 Martin Röösli is also a member of the Swedish Radiation Protection Authority *1, page 96 and does unpaid work for the COSMOS study, which received strong financial support from telecommunications companies. *1, page 98 Furthermore, Martin Röösli is a board member of the Swiss FSM organization, (the Research Foundation for Electricity and Mobile Communications), which is financed by telecommunications companies, and is receiving funding from Swissgrid and Swisscomm. *1, page 98 Many studies selected by Röösli or carried out by him were directly financed by the Research Foundation Electricity and Mobile Communication. *1, page 98

In addition, Röösli does not have the necessary medical, biological or physical expertise to assess the health effects of mobile phone radiation. In an Expert Opinion *2 from Lennart Hardell (Professor of Oncology at Örebro University, Sweden) sent to the Swiss Federal Council there is the clear conclusion that the Federal Council and the federal offices responsible for mobile radiation are completely misadvised by the misinformation and false assessments of Professor Röösli with fatal consequences. *1, page 98

The election process for new ICNIRP members in particular should be questioned. This is a closed election procedure. This means they are elected to the commission every four years on the proposal of the current members and the Executive Council of the International Radiation Protection Association (IRPA). Looking closely at the qualifications of the 13 members in total, it becomes clear that only few are trained RF EMF experts and can make a professional judgment on this subject.

ICNIRP Guidelines

The ICNIRP 1998 recommendations were adopted by the EU in its Council Recommendation of 1999. These ICNIRP recommendations are not comprehensive enough and are based on a few selected studies that conform to certain guidelines predefined by ICNIRP, which exclude a big number of studies that show adverse effects from RF EMF. ICNIRP guidelines are flawed because:

— bioactive parameters have not been included in evaluations

— interaction of frequencies is not evaluated

— total exposure as a sum of fields is not evaluated

— cumulative effects are not evaluated

— heating of tissue is the only accepted parameter

When such factors are not included, the guidelines for RF EMF exposure limits will be erroneous and will be set too high to accommodate the industry that wants to be able to use very high frequencies for the development of their industrial products.

And this is exactly the case. Throughout the world, ICNIRP guidelines are the de facto standards for safe exposure to RF and EMFs. The only problem is that they are not safe.

Experts such as David Carpenter, professor of environmental medicine at the University at Albany, New York, warned WHO that ICNIRP was ignoring studies. Environmental scientist Professor Neil Cherry was particularly outspoken. He was commissioned by the New Zealand government to review the ICNIRP guideline before it was introduced. For this purpose he wrote the "ICNIRP Guideline Critique" in 1999, which has been ignored until today, but remained unchallenged. His conclusion: "The ICNIRP guideline is flawed and contrary to law. It contains a pattern of biases, omissions and deliberate distortions" (https://waveguard.com/strahlenschutzgrenzwerte/).

What ICNIRP guidelines are NOT

At an international EMF conference in London (2008), Professor Paolo Vecchia, ICNIRP Chairman from 2004 to 2012, said about the exposure guidelines “What they are not”: “They are not mandatory prescriptions for safety”, “They are not the ‘last word’ on the issue”, and “They are not defensive walls for industry or others”.

The European Economic and Social Committee have published the Opinion called Secure 5G deployment– EU toolbox. Point 4.10 states:
“However, the EESC notes that ICNIRP are not recognised by all the community, with some scientists promoting much stricter population exposure limits according to the ALARA principle. The solutions that might be proposed to complement the 5G communications infrastructure includes the use of fixed data connections by existing non-radio technologies (Ethernet cables, fibre optics, etc.), in situations where the use is fixed (e.g. ATMs, banking POS, industrial robots, remote controlled medical robots, etc.) and where large data transmission users operate (digital service providers, companies/ businesses, etc.); IoT Internet of Things present in fixed, non-mobile locations (Smart Home, Smart City, sensors on public utility equipment, etc.).”

The 2020 limit value proposal from ICNIRP

ICNIRP 2020 has revised its mobile operator-friendly limit recommendations issued in 1998 to give legitimacy to the radio exposure that will increase with 5G *3. We oppose changes because:

— ICNIRP insist on thermal dogma only

— biological mechanisms of action are denied

— auditory effect is excluded (list of Differences)

— mentioning "A higher SAR is required to reach this temperature rise in children due to their more-efficient heat dissipation" is unacceptable in view of EU's effort to protect children more (ICNIRP 2020, page 488)

— introduction of Type-1 and Type-2 tissue with accepted temperature rises of 5°C and 2°C, which is unacceptable for us (ICNIRP 2020, page 489).

— The scientific base of the new guidelines is unclear, since the evaluation of the scientific reports by ICNIRP is not published. Only general statements were made public. There is an exception in respect of the NTP report on cell phone radiation studies. A detailed ICNIRP comment is available. In this comment ICNIRP does not accept the outcome of this study, although the peer review was exceptionally extensive. The ICNIRP view is not generally supported nor shared by NTP.

— ICNIRP has not published any response to the comments received. The comments are noted at the website, the response remains a secret.

Dr. Mutter says (2020): “If you get sick, but this does not happen from overheating, then it has nothing to do with mobile phone radiation. By law, damages below the ICNIRP limit are excluded; thus, if someone is harmed, legal action is excluded.” *Mutter, page 61

Since the current, extremely high limits in the range above 10GHz are not sufficient for 5G, ICNIRP has revised its recommendations. *4 Buchner&Krout, page 124

Because ICNIRP only works with average limit values, it is important to know that 5G works differently. In many cases with 5G, the signal is no longer emitted around the cell tower as before, but is sharply focused on the user. High energy flows are beamed out, which impact the user and all those in between the source and the target. A major problem here is that the intensity of the radiation is calculated as an average. From a biological point of view, however, the peak values are the most important ones. Since 5G uses intense radiation to transmit information in a very short time, the average means that the biological effects are greatly understated. *Buchner&Krout, page 124-131

An example: you immerse your hand in 20 degree Celsius tempered water for 50 seconds and then in 100 degree Celsius hot water for 10 seconds; now we can claim that the average temperature in the measured 60 seconds was 33.33 degrees Celsius, which is a well tolerated temperature. The part of your skin that was in 100-degree water for 10 seconds will definitely be scalded, and still we can say, "That was just a little 10-second peak."

At the frequency of 26 GHz planned for 5G, a penetration depth into human tissue is only about 1.5mm *Buchner&Krout, page 80, chapter "Was ist bei 5G anders?", which is associated with a local temperature increase of 2.51degrees Celsius *Buchner&Krout, page 125, after three minutes an increase of 4.14 degrees Celsius, and after 6 minutes eyes would be heated by an increase of at least 5.7 degrees Celsius.

Damage to the eye and clouding of the lens could be the result as well as the development of skin cancer. *Buchner&Krout, page 125

The NTP Study

In a U.S. Department of Health and Human Services program, 3080 mice and rats were exposed to different levels of cell phone radiation over a lifetime. This showed clearly and statistically significantly that male rats developed more tumours in the heart (schwannomas) and in the brain (gliomas) compared to the control group.

ICNIRP reacted to this study by claiming that the study had not been conducted properly; therefore, no conclusions could be drawn from it. *Buchner&Krout, page 134 Even Prof. James C. Lin of the University of Illinois at Chicago who himself had been a member of ICNIRP for 12 years contradicted this. He called this study a clear proof of the carcinogenic effect of cell phone radiation. Prof. Lin had published this in an industry journal and thus silenced ICNIRP. Today, the NTP study, along with the Ramazzini study, is considered convincing evidence of the carcinogenic effects of radio radiation. *Buchner&Krout, page 135 This is an example of ICNIRP being unreliable regarding assessments of studies and only pick out the ones that agree with their view.

ICNIRP refutes studies they will not use for limit setting by raising doubts on the validity of the study. As an example ICNIRP has made an assessment of a study where the conclusion is allegedly "unclear" and the proven mutagenic effects of EMFs is doubted:

In the case of cells of soft tissues such as glands, connective tissue, etc., the hereditary damaging effect of radio radiation can be observed very clearly, but not so in the case of muscle cells. But the former scientific advisory body SCENIHR of the EU Commission, which included several ICNIRP members, simply mixed together studies on muscle cells, where no effect was found, with those on soft tissue cells and claimed that the scientific situation was unclear because the experiments were contradictory. *Buchner&Krout, page 135

This is a highly incompetent way of dealing with scientific studies; the above mentioned "cell study" or its results were obviously interpreted inaccurately and was finally deemed "unclear". Studies with "unclear" results are not used to assess EMFs and allow the mobile phone companies to adhere to their limits.

As has been shown clearly above, the private association ICNIRP alone is not in a position to determine and recommend safe limit values for the environment and the population.