Application of the precautionary principle to RF-EMF

Summary

The requester sought clarification on the Isle of Man Government's application of the precautionary principle regarding RF-EMF health impacts, specifically requesting meeting minutes and correspondence between departments. The Cabinet Office responded by providing a letter addressing a 5G mast application in Ramsey and clarifying that ICNIRP guidelines were reviewed in 2009, while noting the request was too broad for other departments.

Key Facts

• The 2009 Comin Report recommended applying the precautionary principle to mobile phone masts in the Isle of Man.
• The requester asked for all meeting minutes and correspondence regarding RF-EMF between government departments since October 2011.
• The Cabinet Office advised that the request was too broad and separate requests would be needed for other departments.
• A response letter addressed a 5G mast application by Sure (IOM) Ltd in Ramsey.
• ICNIRP safety guidelines for RF-EMF were published in 1998 and underwent a full review in 2009.

Data Disclosed

• 2009
• 11 October 2011
• 1998
• 30th May 2019
• 13th May 2019
• 11 April 2018
• 25 February 2019
• 24 March to 10 April 2019
• 8 pages
• 2 documents

Original Request

It appears that the approach and the general approach adopted by Isle of Man Government in relation to potential adverse health and environmental impacts of RF EMF, is an inversion and abandonment of the 'Precautionary Principle', which seeks to avert potential harm before it has occurred. We refer you to the 2009 Comin Report, 'A Review into the Health Impacts of Mobile Phone Masts in the Isle of Man' (2009), which recommended the application of the 'Precautionary Principle' in a number of its detailed Conclusions and Recommendations. Hon W E Teare ACIB MHK (then Minister for DHSS) stated: 'The attached report is a report of the Working Party on Mobile Phone Masts; the Working Party has based its conclusions and recommendations on available scientific evidence and does accept that where there is insufficient evidence, we should adopt a precautionary approach.' The report quotes Unesco's World Commission on the Ethics of Scientific Knowledge and Technology (COMEST, 2005) which defined the application of the precautionary principle to scientific advances: 'when human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm'. We would be grateful for your clarification as to why the precautionary approach is not being applied in relation to potential adverse health and environmental impacts of RF EMF in the Isle of Man. We asked for clarification: Because you are seeking an opinion on your question as opposed to asking for data or specific information we are unable to reply to your request as it does not describe clearly what exact information it is that you are requesting. In order that we can try to locate the relevant information to assist you, please can you give an exact confirmation as to what specific information it is that you require? For example, is it specific documents or data that you require? Please note the Act applies to information created on or after 11 October 2011. The requester clarified their request: Please may we see all and any meeting minutes, correspondence and requests for, or replies giving advice or opinion between any Government department, working group or committee (including the Department of Education, Sport and Culture (or previously named educational department), GTS and Manx Utilities), and the Department of Public Health regarding the health effects of RF-EMF radiation including (but not exclusively) wireless router emissions, smart meters and 5G. Please would you confirm whether the Department of Public Health has ever (or since 11 Oct 2011) been asked for advice by the Dept of Education, Sport and Culture (or previously named educational department) regarding the safety of wireless emissions in schools? We advised the requester: The nature of your request remains very broad, a search can be made of the Cabinet Office including GTS and Public Health in relation to your request, however if you require information that might be held by other Government departments you will need to make separate FoI requests to each individually.

Data Tables (1)

Full Response Text

From: To: Subject: Letter to go on letter head to Secretary of Planning Committee Date: 05 June 2019 17:16:38 Hi , Text of letter below – can be sent electronically on our letterhead – thanks. There’s a signature block and then cc to at the end – all to go on letter. We can email back to , think we’ll need to send a hard copy to . Dear Thank you for your letter dated 30th May 2019 and its enclosures. Your letter included a link to the minutes of the Planning Committee meeting held on 13th May 2019, when an application by Sure (IOM) Ltd. to erect a replacement tree mast in Ramsey was considered. I understand that the replacement mast is needed to extend the height to support existing telecommunications but will also support 5G (5th generation mobile telecommunications networks). Your letter included the following enclosures: 1. Cindy L Russell, ‘5G wireless telecommunications expansion: Public health and environmental implications’, Environmental Research, published on line 11 April 2018, https://doi.or/10.1016/j.envres.2018.01.016 2. A copy of the Sure declaration of conformity with ICNIRP public exposure guidelines 3. A print out of a news article headed ‘Sure launching 5G trial network to test the state- of-the-art mobile technology in the Isle of Man, this appears to have been downloaded from Sure’s website and is dated 25 February 2019. I note that the word ‘trial’ in the headline has been circled in blue pen. 4. A print out of webpages from the website ‘Take Back your Power’ headed ‘5G: The Dominoes Are Starting To Fall’ which lists 10 state/city authorities/national jurisdictions across Europe, the United States and Russia which are reported as having delayed, halted or otherwise slowed ‘roll out of 5G’ over the period 24 March to 10 April 2019. I will respond first to key points raised by as recorded in the minutes and will then address the content of the enclosures 1, 3 and 4 listed above. states that ‘the report on which Public Health would make reference to (sic) was over 20 years old. Sure, Public Health and the committee were relying on such old data to advise them (sic)’. I assume Mrs Powell is referring the ICNIRP guidelines which set safety guidelines for exposure to RF-EMF. The guidelines were published in 1998 but underwent a full review in 2009 and are currently undergoing further review. They are not, therefore, out of date and continue to set the safety standard followed around the world. Whilst ICNIRP set the exposure standards that are followed here on island and elsewhere, ICNIRP is not the only source of evidence for impact of RF-EMF on human health on which I draw as Director of Public Health. Over the past 30 years, there have been over 25,000 studies published on the impact of RF-EMF. The quality of these studies varies widely (and thus so too does the robustness of any conclusions that can be drawn from them). The papers include laboratory studies on cell cultures and animals (mostly mice and rats) and observational studies on human populations. There is a well- established and validated methodology for reviewing and critically appraising studies in order to answer a research question (in this case, ‘does exposure to RF-EMF have an adverse effect on biological systems/animals/humans’). This methodology is called ‘systematic review’. The World Health Organisation has in place an extensive, ongoing project to review impacts of RF-EMF. This has concluded: current evidence does not confirm the existence of any health consequences from exposure to low level electromagnetic fields. However, some gaps in knowledge about biological effects exist and need further research. Systematic reviews have also been carried out (independent of WHO) by over 30 national governments and health protection agencies. These have all reached similar conclusions regarding lack of evidence for adverse impacts of RF-EMF on human health. I have provided links to a selection of these reviews (the main ones available in English) below: • WHO International EMF Project: https://www.who.int/peh-emf/project/en/ • National government and health agency reports, e.g.: – https://www.gov.uk/government/publications/radiofrequency-electromagnetic- fields-health-effects (for the UK) – https://www.arpansa.gov.au/understanding-radiation/radiation-sources/more- radiation-sources/electricity (Australia) – https://www.health.govt.nz/publication/electric-and-magnetic-fields-and-your- health (New Zealand) – https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09583.html (Canada) – https://www.fcc.gov/general/radio-frequency-safety-0 (US) – https://www.stralsakerhetsmyndigheten.se/en/publications/reports/radiation- protection/2019/201908/ (Sweden) • Independent critical appraisals of major publications – www.emfandhealth.com • Quality assured database of EMF related publications: – https://www.emf-portal.org/en. I hope this will reassure the Planning Committee and that I have not based my advice on an ‘out of date’ document. Moving now to the paper by Cindy L Russell. This is described in the minutes as ‘a peer review reference’. I think this should have been recorded as ‘a peer reviewed reference’. All that means is that this is a paper which has been published in a journal which uses peer review as part of its procedure for accepting or rejecting papers submitted to it for possible publication. The fact that a paper has been published in a peer reviewed journal is no guarantee of the quality of the paper or the veracity of its contents. Within the abstract, Russell makes statements which are incorrect: 1. ‘[There is] concern that health and safety issues remain unknown’. This statement is not supported by the findings of the multiple systematic reviews mentioned above. 2. ‘Radiofrequency radiation is increasingly being recognized as a new form of environmental pollution’. This is not correct and she provides no evidence to support the claim. 3. She claims that her paper ‘review[s]…current scientific literature on the health implications [of RF-EMF].’ This might be taken to imply that she has carried out a systematic review (as described above). She hasn’t. At best this can be called an overview of the literature, using selected studies to support the arguments that the author wishes to make. Because she does not follow the methodology of a systematic review, it is impossible to tell whether the papers she cites do say what she claims they say, and whether the quality of them is good enough to make their conclusions robust. It would only be possible to check this by going back to each of the papers she cites. Clearly neither I, nor any other general reader, have the time to do this. I have looked at a couple of her references, picked at random, just to illustrate this: a. Huss et al, 2007. Russell claims this is ‘a systematic review regarding the association of cell phone use and brain tumours in relation to funding.’ It is not, in fact, a systematic review looking at association between cell phone use and brain tumours. Rather it is a systematic literature search which identified studies looking at the association between brain tumours and cell phone use and then looking at whether there was an association between industry funding of the study and negative results. There is one crucial step that has been missed out – there is no assessment of the quality of the study or the robustness of its conclusions. Without this, we cannot test the hypothesis that industry funded studies were actually better quality/more robust than the non-industry funded ones. b. Myung et al, 2009. Russell claims that this paper was ‘a meta-analysis [that] found significant elevation in brain tumours with long term cell phone use when high quality studies were examined.’ Firstly, this was not a meta-analysis of brain tumour risk (a meta-analysis is a method of pooling data from a number of trials to strengthen the conclusions that can be drawn from statistical analysis) but a meta-analysis of risk of any type of tumour (benign or malignant) at any site. Methodologically, it is extremely poor (you can read an expert critique of it here: https://ascopubs.org/doi/10.1200/JCO.2009.26.7443). Furthermore, Myung et al ran two analyses and stated that one of these actually showed a reduced risk of tumours in mobile phone users compared to non- or infrequent users. However, they chose to disregard that finding in their weak conclusion that ‘there is possible evidence [whatever that is supposed to mean] linking mobile phone use to increased risk of tumours’. So, not only is this a very poor study but Russell manages to misunderstand and misquote it. This poor quality selective literature review does not challenge the findings of the multiple systematic reviews listed above. Looking now at the news article from the Sure website – I assume the key point here is that someone has circled the word ‘trial’. However, there is nothing in the article to indicate that this is intended to be a trial of health impacts of 5G. No such trial is required since the frequencies that will support 5G are well within ICNIRP guidance range by a margin of some tens of GHz (i.e. a wide margin). In practice, 5G here on island will use frequencies that are already in use and so not represent exposure to a ‘new or different type of RF-EMF’. Finally, the pages from the ‘Take Back your Power’ website, claims that multiple city or national authorities have taken decisions to slow the roll out of 5G. Unfortunately, I have not been able to identify the website from which these pages came. Although they are headed ‘Take Back your Power’, there is no web address and a Google search simply returns information on a documentary of that name which is about smart metres. I cannot therefore click on what look like links to provide evidence for the claims these pages make. However, I have attempted to follow up one (at random). This is the claim that the ‘Russian Ministry of Defence refuses to transfer frequencies for 5G, which effectively delays any 5G rollout there for several years’. It is interesting that there is no claim that this is due to any concerns about health effects – and a Defence Ministry may have other reasons for concerns about roll out. However, courtesy of Google, I have found the following report: https://russiabusinesstoday.com/technology/russia- to-reach-80-5g-coverage-by-2025-report/, which states that commercial 5G will be rolled out from 2020 and will reach 80% coverage of the population by 2025. This does not seem to corroborate the claim in the ‘Take Back your Power’ document. I have previously seen press coverage of the situation in Brussels; https://www.brusselstimes.com/all-news/brussels-all- news/55052/radiation-concerns-halt-brussels-5g-for-now/. The issue here is that Brussels city authorities had previously decided to set the exposure threshold below that recommended by ICNIRP. This was a political decision which went beyond the scientific evidence. The result of that decision is that 5G cannot now be piloted because it is not possible to ensure that the additional

confirmation as to what specific information it is that you require? For example, is it specific documents or data that you require? Please note the Act applies to information created on or after 11 October 2011.” On 11 August 2020 you responded as follows: “Please may we see all and any meeting minutes, correspondence and requests for, or replies giving advice or opinion between any Government department, working group or committee (including the Department of Education, Sport and Culture (or previously named educational department), GTS and Manx Utilities), and the Department of Public Health regarding the health effects of RF-EMF radiation including (but not exclusively) wireless router emissions, smart meters and 5G. Please would you confirm whether the Department of Public Health has ever (or since 11 Oct 2011) been asked for advice by the Dept of Education, Sport and Culture (or previously named educational department) regarding the safety of wireless emissions in schools?” We advised you: “The nature of your request remains very broad, a search can be made of the Cabinet Office including GTS and Public Health in relation to your request, however, if you require information that might be held by other Government departments you will need to make separate FoI requests to each individually.” Please find enclosed the information relevant to your request.
Please note that, within the scope of the request, there is no information held for the period 2011 to March 2015. Therefore a practical refusal reason under s11(2)(a) of the Act applies as the information is not held, as per s11(3)(b) of the Act. While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because it is absolutely exempt under section 25(b) of the Act (absolutely exempt personal information), namely a personal address has been redacted. The reasons why that exemption applies are that: a) The Cabinet Office is satisfied that the information amounts to personal data of which you are not the data subject; and b) The Cabinet Office is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Cabinet Office can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met. In the interests of providing advice and assistance (s15 of the Act), a request for information pre-2011 would need to be made via the Code of Practice on Access to

Government Information: https://www.gov.im/categories/home-and- neighbourhood/code-of-practice-on-access-to-government-information-access-code/ In respect of your original question, pre-clarification, which stated:
We would be grateful for your clarification as to why the precautionary approach is not being applied in relation to potential adverse health and environmental impacts of RF EMF in the Isle of Man. • The following outlines how ‘precaution’ is being applied with regard to use of RF- EMF: https://www.researchgate.net/publication/26808169 The Precautionary Principle in the Context of Mobile Phone and Base Station Radiofrequency Exposures • The international (WHO led) approach to ‘precaution’ is set out here: https://www.who.int/news-room/fact-sheets/detail/electromagnetic-fields-and- public-health-mobile-phones We would also like to make you aware that there is further information relevant to the scope of your request already available online, please see links below. As such under Section 20(2)(b) of the Act (Information accessible t

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