“ICBE-EMF’s primary purpose is to make recommendations, based on the best peer-reviewed scientific research publications, that include, and go beyond establishing numerical exposure guidelines. We are dedicated to ensuring the protection of humans and other species from the harmful effects of non-ionizing radiation.” ICBE-EMF
The International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF) has just published their much anticipated second peer reviewed paper on wireless radiofrequency radiation(RFR) exposure standards, Cell Phone Radiation Exposure Limits and Engineering Solutions. The ICBE-EMF was recently formed as an independent scientific authority with goals similar to the International Commission on Non-ionizing Radiation protection (ICNIRP), but with a different perspective. Both address the key issue of safety and exposure standards of non-ionizing radiofrequency radiation from burgeoning wireless devices and infrastructure. The powerful 12 member ICNIRP, however, is criticized by the ICBE-EMF, among others, for using outdated and flawed criteria, creating exposure standards that are 1) based only on heat 2) Do not consider long term exposure 3) do not take into account sensitive populations 4) do not consider new research into health effects and biological harm at levels that are far below current standards.
ICNIRP and FCC Wireless Standards for 5G are Invalidated by Scientific Studies
The first paper of this independent group of scientists and physicians, Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G, was published in October 2022.
The ICBE-EMF authors carefully review the surprising history and enduring standards for wireless RFR developed using 5 monkeys and 8 rats with a 40-60 minute exposure and an endpoint of behavioral cues, along with a heat absorption standard (SAR). It was assumed there could be no health effects other than heating thus appropriate premarket research was not performed. The paper examines an encyclopedia of scientific research linking wireless RFR from common electronic devices with everyday exposures to DNA damage, cardiomyopathy, carcinogenicity, sperm damage, and neurological effects, including electromagnetic hypersensitivity. The paper also lists 14 flawed assumptions which are the basis of the current flawed ICNIRP/FCC guidelines. They note, “Thus, urgently needed are health protective exposure limits for humans and the environment. These limits must be based on scientific evidence rather than on erroneous assumptions, especially given the increasing worldwide exposures of people and the environment to RFR, including novel forms of radiation from 5G telecommunications for which there are no adequate health effects studies.”
14 Flawed Assumptions of ICNIRP
Detailed explanations with references accompany each flawed assumption in the ICBE-EMF first paper
Assumption 1) There is a threshold exposure for any adverse health effect caused by RF radiation; in the frequency range of 100 kHz to 6 GHz it is a whole-body exposure that exceeds an SAR of 4 W/kg. Any biological effect of RF radiation above the threshold exposure is due to tissue heating.
Assumption 2) RF radiation is incapable of causing DNA damage other than by heating; there is no mechanism for non-thermal DNA damage.
Assumption 3) Two to seven exposures to RF radiation for up to 1 hour duration are sufficient to exclude adverse effects for any duration of exposure including chronic exposures.
Assumption 4) No additional effects would occur from RF radiation with co-exposure to other environmental agents.
Assumption 5) Health effects are dependent only on the time-averaged SAR value; carrier wave modulations, frequency, or pulsing do not matter except as they influence the SAR.
Assumption 6) The multiple human studies that find associations between exposure to cell phone RF radiation and increases in brain tumor risk are flawed because of biases in the published case-control studies, and because brain cancer rates have remained steady since the time that use of wireless communication devices became widespread.
Assumption 7) There are no differences among individuals, including children, in the absorption of RF-EMF and susceptibility to this radiation.
Assumption 8) There are no differences among individuals in their sensitivity to RF radiation-induced health effects.
Assumption 9) A 50-fold safety factor for whole body exposure to RF radiation is adequate for protecting the general population to any health risks from RF radiation.
Assumption 10) A 10-fold safety factor for whole body exposure to RF radiation is adequate for protecting workers to any health risks from RF radiation.
Assumption 11) Exposure of any gram of cube-shaped tissue up to 1.6 W/kg, or 10 g of cube-shaped tissue up to 2 W/kg, (duration not specified) will not increase the risk of that tissue to any toxic or carcinogenic effects in the general population.
Assumption 12) Exposure of any gram of cube-shaped tissue up to 8 W/kg, or 10 g of cube-shaped tissue up to 10 W/kg, (duration not specified) will not increase the risk of that tissue to any toxic or carcinogenic effects in workers.
Assumption 13) There is no concern for environmental effects of RF radiation or for effects on wildlife or household pets.
Assumption 14) No health effects data are needed for exposures to 5G; safety is assumed because penetration is limited to the skin (“minimal body penetration”).
Engineering Solutions to Lower the Wireless Emissions of Cell Phones: ICBE-EMF second Paper
The ICBE-EMF contributed a second concise and equally well written paper, Cell Phone Radiation Exposure Limits and Engineering Solutions, which first reveals the 1990 history of the RFR risk assessment for human exposure provided by the Institute of Electrical and Electronics Engineers (IEEE), discussing seven “blind spots” in their risk assessment. They follow this with practical engineering solutions the Telecommunications Industry can use to provide protection from these devices we have become increasingly dependent on with close and constant RFR exposures.
Regulatory “Blind Spots”
Clear, concise and well-referenced explanations of the “Blind Spots” in the second article are provided. Here are summaries.
Blind Spot #1: RFR Toxicology and Risk Assessment
In the 1960’s a host of research papers found “observable” and “adverse” effects from RFR at lower levels than current IEEE standards, however, for a variety of reasons, no replication studies were done. The IEEE focused only on heat as a model, rather than a biological model, which is more sensitive to many variables. Epidemiology, not biology won in the assessment, thus classic scientific risk assessment used in pesticides and other toxins was ignored, other than the original monkey and rat study looking at behavioral thresholds with a single outcome. Toxicology experiments on a chemical may look at 20 or more biological outcomes.
Blind Spot #2: 40–60 Min Is Not a Lifetime
The original de Lorge monkey and rat experiments were carried out with a short exposure time of 40-60 minutes and the data was arbitrarily extrapolated to chronic exposure in a “leap of faith”. The authors quote an ICNIRP representative, “ICNIRP only considers acute effects in its precautionary principle approach. Consideration of long-term effects is not possible” and the “IEEE used these acute experiments focused exclusively on heat and behavior (Blind Spot #1; ) to set safety limits within their C95 committee, while at the same time promoting in other public and government forums that their safety limits encompassed all risks and applied over a human lifetime.”
Blind Spot #3: Averaging Human Exposures over 6 or 30 Min
They explain that IEEE-ICNIRP’s maximum permissible exposure limits for wireless radiofrequency radiation “quantify exposures by averaging and compiling 6- or 30-min exposures into a single number.” This was done to account for the time it may take to heat the tissue. This, however, does not help elucidate a variety of biological effects from a succession of instantaneous peak data pulses within the 6 or 30 minutes, carrying different frequencies, polarizations and signaling, which disturb biological processes. Exposure time is a factor in adverse effects yet sidelines the real culprits of modulation and peak intensities associated with adverse neurologic, membrane and biological macromolecule (DNA, Lipids, Proteins) effects.
Blind Spot #4: RFR’s Human Costs
There are a host of health effects increasingly associated with RFR in the literature, including brain cancer, thyroid cancer, miscarriage and other reproductive effects, neurologic effects, as well as, mechanistic links to oxidative cellular stress causing DNA oxidative damage, signaling disturbance in cell membranes, and disruption of normal body homeostasis. The authors point out robust literature indicating human harm that to date this has not been considered in adequately addressing policy or regulation.
Possible Carcinogens. They point out that electromagnetic radiation from a variety of sources in homes, schools, businesses, transformers and cell towers (Extremely Low Frequency-ELF and higher radiofrequency radiation-RFR) is already classified by the International Agency for Research on Cancer (IARC) as a 2B, “possibly carcinogenic to humans”.
- For ELF, IARC in 2002 concluded, “overall, extremely low frequency magnetic fields were evaluated as possibly carcinogenic to humans (IIB), based on the statistical association of higher level residential ELF magnetic fields and increased risk for childhood leukaemia.”
- For RFR, IARC in 2011 listed Radiofrequency Electromagnetic Fields as possibly carcinogenic as well, after reviewing the literature. They note, “This interest reflects the high prevalence of exposure (which increasingly extends to children), the vast scope of the telecommunications industry, the findings of some epidemiological studies that suggest an increased risk of cancer”
Despite the emergence of and increasing reports of electrosensitivity (EHS) rates in connection with increasing RFR, policies have not taken this issue into account. The authors note that ICNIRP does admit, “Different groups in a population may have differences in their ability to tolerate a particular non-ionizing radiation (NIR) exposure. For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the population”.
This is an escalating public health issue with an increase in rates of EHS to above 3-5% of the population. Heroux et al state, “Current thermal protection has clearly failed this group, which often faces the incomprehension and skepticism of physicians who rely on national recommendations. Not only do EHS sufferers need protection in the form of low-field environments, but preventing an increased incidence of EHS is important in the maintenance of a healthy workforce.”
Federal Court Agrees With Flawed FCC Revaluation of Safety Standards
Note that a Federal judge in 2021 agreed with the sentiment of flawed consideration of scientific literature of EMF adverse health and environmental effects when the Federal Communications Commission (FCC) lost a lawsuit brought by the Environmental Health Trust and the Children’s Health Defense. The 2020 lawsuit claims a failure to protect human health and the environment by dismissing scientific evidence of harm from wireless radiation. The Petitioners challenged the FCC’s refusal to reevaluate and update their 24-year-old radiofrequency (RF) safety guidelines for existing and new telecommunications technologies.
The DC Court of Appeals Decision on Jan 25, 2021 states,”First, The Commission’s failure to provide a reasoned explanation for its determination that exposure to RF radiation at levels below its current limits does not cause negative health effects therefore renders inadequate the Commission’s explanation for its refusal to modify its testing procedures…. Second, The Commission equally failed to provide a reasoned explanation for brushing off record evidence addressing non-cancer-related health effects arising from the impact of RF radiation on children….Third, The Commission’s failure to provide a reasoned explanation for its determination that exposure to RF radiation at levels below its current limits does not cause negative health effects unrelated to cancer renders inadequate the Commission’s explanation for its failure to discuss the implications of long-term exposure to RF radiation, exposure to RF pulsation or modulation, or the implications of technological developments that have occurred since 1996, including the ubiquity of wireless devices and Wi-Fi, and the emergence of “5G” technology.”
Blind Spot #5: Specific Absorption Rates Determined at Unrealistic Distances
FCC Specific Absorption Rate (SAR) exposure limits listed on cell phones is a measure of heat, and was not based on how people use their phones, against the head and pressed to the ear (and now in the ear), as we see on every city sidewalk and cafe. These near field exposure limits were based on computations using a plastic male head with the phone at a variable distance from the head. The authors note “Yet it was progressively realized that modeling SAR values with precision at small distances from the head (in the near field) and in proximity to complex layers of biological tissues is difficult and carries an uncertainty of at least 25%” and new antenna designs, number and placement in the phone can lower SAR numbers but still carry a biologic risk close to the head and body. They point out that “as much as 90% of the power emitted by the antenna is dissipated in the user’s head, as opposed to contributing to communication.”
Blind Spot #6: Specific Absorption Rates Averaged over 1 or 10 g
FCC cell phone SAR standards were developed by averaging heat absorbed in a cube of tissue, either 1 gram or 10 grams. It does not distinguish which cells are in that tissue, or if the tissue is uniform in its absorption. That gram of tissue may contain 50 million critical glial nerve cells in the brain or it could contain inactive ear cartilage. The authors note that standards for SAR have been progressively relaxed to accommodate industry changes in phone design. “FCC-13-39A1 reclassified the external part of the ear (aka pinna) as an extremity  despite evidence that DNA damage in the ear canal was connected to cell phone use  and despite objections to classifying a body part proximate to the brain as a non-essential “extremity”.
Blind Spot #7: Enclosing the RFR Source
The hand which holds the phone was not considered in the SAR simulations. A large amount of radiated power may dissipate into the body via the hand. The authors state,
“Since in real-use scenarios, the head and hand together envelop the source, and since the power drawn by conductive/dissipative body tissues is larger than geometrically expected, a cell phone effectively acts as a microwave heater held close to the body. A surprising thermalist opinion which we do not accept even promotes heating people using microwaves within their homes in the winter, as an economical substitute for conventional house heating . The SAR estimation techniques prescribed by IEEE-ICNIRP for cellular phones are defective not only because of distance to head and cube size but also because they have been established with highly unrealistic models.”
Blind Spot #8 Summary
“IEEE transformed risk assessment into a calorimetric exercise on inert materials while ignoring the processes and structures of life, specifically the motion of electrons and protons, and the properties of protein and enzymes… The influence of industry extends inside the World Health Organization’s International EMF Project, which anticipates a future where human exposure to EMF “will continue to increase as technology advances” . Since there are no adequate health effects studies on the projected evolution of wireless systems such as 5G , and because the effects of 1G to 4G systems have been ignored, one can legitimately ask whether the WHO provides health protection independently from the wireless communications industry .”
Hooray! Engineering Solutions to Reduce Wireless Radiation in Phones
The ICB-EMF discusses three practical approaches to cell phone exposure abatement that may not be costly but would provide substantially more protection, saving money indirectly on health care and social services:
- Blocking the phone’s RFR emissions, but not its reception, when it is positioned close to the head/body.
- Modifying the antenna emission pattern (to hemispherical) to radiate away from the head and the body.
- Limiting call durations according to an estimation of the effective radiated power emitted by the antenna over a specific period.
Heroux et al express a final point that cell phone manufacturers have received patents since the mid-1990s to reduce cell phone radiation to consumers. There are 25 different designs in publications between 2005-2020 that have been proposed to reduce cumulative radiation exposure and harm, without degrading the quality of communications. It is hoped that this paper is a call to action for industry to advance public health protections over a profit margin from our societies highly connected phones which are emitting more powerful radiation, using more antennas, and transmitting a wider variety of frequencies and pulsed modulated signals.
Opposition to ICBE-EMF
Since the inception of ICBE-EMF there have been critics that say we need do not need another commission (ICBE-EMF) to look at the safety of RFR, we need an open round-table debate between the polarized groups who are in favor of current guidelines and criteria versus those challenging current regulations (Leszczynski 2022). Unfortunately this view ignores the power structure of entrenched groups, as well as long time industry influence in any regulation be it telecom, fracking, sugar in soda, pesticides or tobacco. These groups have employed PR agencies and conducted their own potentially biased research to create their own “spin”, in order to reach conclusions of safety for their products. Industry can as well have more subtle unrecognized influence on those with official authority to regulate EMF standards, pointed out by Hardell and others.
ICBE-EMF Calls on Independent EMF Evaluation and Moratorium on 5G
It is noted that the ICBE-EMF is also calling for an independent evaluation by official authorities and based on the full body of scientific evidence to establish safer and lower exposure limits. In addition they ask for a moratorium on 5G until health and environmental studies are completed. A truly unbiased group of scientists and engineers are need to lead this effort for a “Science for Public Health Protection” model versus a “Science for Profit“ model, the later of which contributes to the “Illusion of Evidence Based Medicine”.
“I do not worry that our system is not sustainable. I worry that it is. I am afraid that we can continue to lay waste to the living earth, indefinitely, ending up on a concrete world, so chronically ill physically and mentally that we must incorporate technological assistance into our very brains and bodies. I am afraid we will compensate for the lost connection to a living world with a burgeoning array of virtual substitutes, digital realities, and online adventures, tragically seeking something that we come to forget we ever had.” Charles Eisenstein, How the Environmental Movement Can Find Its Way Again
ICB-EMF – International Commission on the Biological Effects of Electromagnetic Fields https://icbe-emf.org/
Paper #1 October 2022. International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Environmental Health. 21, 92 (2022). Published Oct 18, 2022. https://ehjournal.biomedcentral.com/articles/10.1186/s12940-022-00900-9
Paper #2 March 2022. Cell Phone Radiation Exposure Limits and Engineering Solutions. ICBE-EMF. Heroux P, Belyaev I, Chamberlin K, et al. nt. J. Environ. Res. Public Health 2023, 20(7), 5398; https://www.mdpi.com/1660-4601/20/7/5398
ICNIRP. International Commission on Non-Ionizing Radiation Protection. https://www.icnirp.org
Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines. (2022) Else K Nordhagen, Einar Flydal. Rev Environ Health. 2022 Jun 27. https://www.degruyter.com/document/doi/10.1515/reveh-2022-0037/html
Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on Radiofrequency Radiation. (2021) Hardell L et al. J Cancer Sci Clin Ther 2021; 5 (2): 250-285. https://www.fortunejournals.com/articles/aspects-on-the-international-commission-on-nonionizing-radiation-protection-icnirp-2020-guidelines-on-radiofrequency-radiation.pdf
Berenis disagrees with ICNIRP, BRHP. Dariusz Leszcynski. January 26, 2021 https://betweenrockandhardplace.wordpress.com/2021/01/26/berneis-disagrees-with-icnirp/
Call for consensus debate on mobile phone radiation and health: Are current safety guidelines sufficient to protect everyone’s health? Darius Leszczynski. Front. Public Health, 15 December 2022. Vol. 10. Sec. Radiation and Health . https://www.frontiersin.org/articles/10.3389/fpubh.2022.1085821/full
New Challenge to ICNIRP: Dissident Scientists Seek Tighter Health Limits. Will They Succeed Where Others Failed? Microwave News. Nov 1, 2022. https://www.microwavenews.com/news-center/new-challenge-icnirp
We need CONSENSUS, not another COMMISSION… Between a rock and a hard place. Oct 18, 2022. Darius Leszczynski.
Science, Politics, and Groupthink. May 2021. James C Lin IEEE Health Matters. https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=9393739
The International Commission on Non-Ionizing Radiation Protection: Conflicts of interest, corporate capture and the push for 5G. June 2020. Laus Buchner and Michele Rivasi. https://www.michele-rivasi.eu/wp-content/uploads/2020/06/ICNIRP-report-FINAL-JUNE-2020_EN.pdf
Conflicts of Interest and Misleading Statements in Official Reports about the Health Consequences of Radiofrequency Radiation and Some New Measurements of Exposure Levels. (2019) Susan Pockett. Magnetochemistry 2019, 5(2), 31. May 5, 2019. https://www.mdpi.com/2312-7481/5/2/31/htm
AVAATE Publishes White Paper on Industry Influence at ICNIRP. THERE APPEARS TO BE A CONFLICT OF INTEREST BETWEEN THE WORLD HEALTH ORGANIZATION AND THE INTERNATIONAL COMMISSION NON-IONIZING RADIATION: https://www.avaate.org/documentos/article/conflictos-de-interes-existentes-en-la-comision-internacional-para-la or go to https://www.avaate.org/IMG/pdf/escrito_web_icnirp_ingles_final.pdf
Regarding ICNIRP’S Evaluation of the National Toxicology Program’s Carcinogenicity Studies on Radiofrequency Electromagnetic Fields. Correspondence. Melnick R. Health Physics. June 2020; 118(6): 678-682. https://journals.lww.com/health-physics/Citation/2020/06000/Regarding_ICNIRP_S_Evaluation_of_the_National.11.aspx
Dr. Lennart Hardell Letter to Swiss Confederation about ICNIRP, Roosli and Reevaluation of radiofrequency and 5G. Jan 2, 2020 – Highlights scientific flaws in ICNIRP assessment. Lettter Hardell -re: Roosli to Mrs. SommarugaSwiss Confederation Reevalaution of safety Standards, ICNIRP 5G -BERENIS_UVEK_January 2, 2020
The science of spin: targeted strategies to manufacture doubt with detrimental effects on environmental and public health. Rebecca F Goldberg and Laura N Vandenberg. Environmental Health. March 26, 2021. 0, Article number: 33 (2021). https://ehjournal.biomedcentral.com/articles/10.1186/s12940-021-00723-0
The Science for Profit Model—How and why corporations influence science and the use of science in policy and practice. (2021)Tess Legg, Jenny Hatchard, Anna B. Gilmore. PLOS One. Published: June 23, 2021. doi: 10.1371/journal.pone.0253272.https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0253272
Union of Concerned Scientists Book Review. The Triumph of Doubt Exposes the Disinformation Playbook in Action. David Michaels. Feb 14, 2020. https://blog.ucsusa.org/kathleen-rest/book-review-the-triumph-of-doubt-exposes-the-disinformation-playbook-in-action
Public Meets Private: Conversations Between Coca-Cola and the CDC. (2019) Hessari M et al. Milbank Q. 2019 Mar;97(1):74-90. https://www.ncbi.nlm.nih.gov/pubmed/30693564
The illusion of evidence based medicine. Evidence based medicine has been corrupted by corporate interests, failed regulation, and commercialisation of academia, argue these authors. Jon Jureidini and Leemon B. McHenry. BMJ. March 16, 2022; 376. https://www.bmj.com/content/376/bmj.o702
SAFER EMR- ICNIRP’s Exposure Guidelines for Radio Frequency Fields. Safer EMR. https://www.saferemr.com/2018/07/icnirps-exposure-guidelines-for-radio.html
Environmental Health Trust. ICNIRP: PUBLISHED RESEARCH ON CONFLICTS OF INTEREST AND LACK OF PROTECTION. https://ehtrust.org/icnirp-published-research-on-conflicts-of-interest-and-lack-of-protection/
Physicians for Safe Technology. Industry Influence in Science. https://mdsafetech.org/problems/industry-influence-in-science/