Appendix B
Why official guidelines on wi-fi are inadequate

As we have seen, the Health Protection Agency (HPA) follows ICNIRP guidelines on the safety of wi-fi, and ICNIRP’s main concern in establishing guidelines is to maintain a stringent level of proof in relation to cause and effect. As a way of ensuring safety, this approach is seriously misguided.

In ICNIRP’s view, research results must be:
• peer-reviewed
• replicated by separate research groups
• consistently find the same effects at approximately the same magnitude
• show a clear mechanistic cause and effect. 103

As an account of scientific method, these criteria are unexceptionable.

Many studies of the health effects of microwave exposure satisfy the first three criteria, and this applies in the three categories considered above: behavioural / functional degradation, neurological damage and cancer. Some studies suggest plausible mechanisms.104 But the mechanisms have not been established, meaning that the fourth criterion is not satisfied.

The fourth criterion refers to theory, the description of what is going on, discussed in Appendix A above. For this criterion to be satisfied, ICNIRP requires the demonstration of four separate scientific stages: physical, chemical, biological, and the connection of the interactions in each case with health effects.

This requirement ensures that the level of proof of a causal relationship will be 95% certain or more. If the requirement is not met—and so far it has not been met—ICNIRP will not take evidence of adverse health effects into account in determining guidelines for microwave exposure.

But this is not how we normally make judgements of safety.
We look at two questions, not one:
• the likelihood that harm or damage will occur, and
the gravity of the harm or damage, if it does occur.

ICNIRP addresses itself to the first question, but not the second. It concerns itself only with the science. But if we are concerned about safety, both questions are important, and we treat them as linked.

If the harm or damage would be great if it happened, we do not look for 95% certainty that it will happen before we take precautions against it. A much lower level of proof is enough for us to be concerned: perhaps 20%, or 10% or even lower.
In other words, if we know something grave may occur, we take the precautionary approach, even if we don’t know how likely it is to occur

Moreover, in taking precautions, we are not concerned principally with theory, but with experience. If I see that a tree is about to topple onto me, I do not think to myself, “I don’t understand how gravitational fields work, so there is nothing to worry about.” I don’t even think about gravity. I act on what experience shows me gravity could do. I act because the cost to me of action if it turns out not to have been required is negligible compared to the cost of inaction if it is shown afterwards to have been necessary.

In judgements of safety, questions about theory—or ‘mechanism’—are a red herring. What matters is the evidence of effects.

On the basis of evidence to date, the harm done by exposure to microwave radiation could be very grave, and the likelihood of its occurring has been shown repeatedly to be high enough to give reason for concern and action.

The level of proof ICNIRP requires is inappropriate, and the HPA is mistaken in following ICNIRP’s guidance.

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103 Report on a conference held in September 2008 entitled EMF & Health—a Global Issue ... Exploring appropriate precautionary approaches, section entitled, ‘ICNIRP, WHO and international guidance’, at
Some of the following information is also drawn from this report.
104 For example: Roux D et al (2008), High frequency (900 MHz) low amplitude (5 V m-1) electromagnetic field: a genuine environmental stimulus that affects transcription, translation, calcium and energy charge in tomato, Planta. 2008 Mar;227 (4):883-91. Epub 2007 Nov 20
Friedman J et al (2007), Mechanism of short-term ERK activation by electromagnetic fields at mobile phone frequencies, Biochem J, 2007 Aug 1;405(3):559-68.
Nylund R, Leszczynski D (2006), Mobile phone radiation causes changes in gene and protein expression in human endothelial cell lines and the response seems to be genome- and proteome-dependent, Proteomics, 2006 Sep;6(17):4769-80 LINK
Neil Cherry (2000), Health effects associated with mobile base stations in communities: the need for health studies, Lincoln University, Environmental Management and Design Division, Canterbury, New Zealand
Neurological effects of radiofrequency electromagnetic radiation, Mobile Phones and Health, Symposium, October 25-28, 1998, University of Vienna, Austria