Electromagnetic Fields and the Precautionary Principle

Environ Health Perspect. doi:10.1289/ehp.0901111 available via http://dx.doi.org [Online 26 October 2009]

Referencing: The Precautionary Principle in the Context of Mobile Phone and Base Station Radiofrequency Exposures

Since Galileo, debates in science are supported by logical reasoning and reference to statements of fact and not by reference to “authorities.” Consequently, literature serves or should serve two purposes: to give credit to thoughts expressed earlier by others, and to refer to statements of facts.

The article by Dolan and Rowley (2009)— employees of the mobile telephone industry—is an example of a compilation of points of views expressed by authorities. No number of references to authoritative statements can replace scientific discourse. The article can be summarized as follows: There is no convincing evidence of harm from exposure to microwaves below levels recommended by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) (1998); therefore, there is no harm, and hence application of the precautionary principle is not indicated.

Indeed, the precautionary principle is not intended as a response to unfounded fears of the public or to aim at zero risk, but as a risk management strategy in case of scientific uncertainty about the existence or magnitude of a risk. Apparently Dolan and Rowley (2009) are not aware that their subjective reasoning does not differ from the unfounded fears of the public and can be summarized as “unfounded reassurance of no harm.”

In principle, ethical considerations, value judgments, and consensus play an important role when giving guidance to public health policy. This is because “it is impossible to derive . . . a proposal for a policy from a sentence stating a fact” (Popper 1945). Use of subjective terms such as “sufficient evidence” (let alone “convincing evidence”— convincing for whom?) or “adverse effect” is unavoidable. Referring to the World Health Organization (WHO 2000), Dolan and Rowley (2009) stated: “The corresponding advice to governments is to adopt science based guidelines and not to undermine confidence by incorporating additional arbitrary safety factors.” The expression “science-based guidelines,” if taken literally, is a contradiction in terms. Although public health guidelines should be based on a thorough risk assessment, neither the assessment itself nor the reasoning that is applied to derive a guideline can be scientific. No scientific evidence can define a margin of safety; no scientific evidence can replace the value judgment of which evidence to rely on, which evidence to dismiss, and so forth. Safety factors are always—at least to certain degree—arbitrary. For example, we very rarely have scientific evidence about the distribution of sensitivity to a toxic agent in the population; therefore, we apply arbitrary factors for taking interindividual differences into account. What is important, and nearly always neglected in the area of electromagnetic fields (EMF), is to clearly state where value judgments and arbitrary decisions entered the argument and the derivation of guidelines.

The international standards for EMF (ICNIRP 1998; IEEE 2006) are based on immediate effects of exposure, such as excitation of nerve or muscle cells for low-frequency fields and increase of body temperature for high-frequency fields, not because there are no other effects, even at levels far below the guideline levels derived from these acute effects, but because the panels came to the consensus that these other effects cannot (yet) form the basis for the derivation of guidelines. For example, the International Agency for Research on Cancer (IARC 2002) classified power frequency magnetic fields as a possible human carcinogen. In that case, the subjectivity of the assessment is fully transparent: The basic rules of IARC were violated, as the panel questioned whether epidemiologic evidence can be causally interpreted in spite of evidence that neither bias nor confounding accounts for the increased childhood leukemia risk. The exposure level for which there is evidence of an increased childhood leukemia risk is far below the international standards, but the panels setting the standard did not use this evidence as a basis for the derivation of a guideline level for power frequency fields. There are surely many arguments for this decision. However, none are scientific. This is not meant as a reproach, because we recognize the fact that guidelines cannot be derived from scientific statements alone.

It would be much more appropriate if Dolan and Rowley expressly stated that they are completely satisfied with the international standards and that the industry does not want to be bothered by allusions to precaution.

This letter has been reviewed in accordance with the peer- and administrative-review policies of the authors’ organizations. The views expressed here are those of the authors and do not necessarily reflect the opinions and/or policies of their employers.

C.S. is the owner of Sage Associates, an environmental planning firm that provides consulting services on EMF issues. The other authors declare they have no competing financial interests.

Michael Kundi
Institute of Environmental Health
Medical University of Vienna
Vienna, Austria
E-mail: michael.kundi@meduniwien.ac.at

Lennart Hardell
Department of Oncology
Örebro University Hospital
Örebro, Sweden

Cindy Sage
Sage Associates
Santa Barbara, California

Eugene Sobel
Friends Research Institute
Los Angeles, California

References

Dolan M, Rowley J. 2009. The precautionary principle in the context of mobile phone and base station radiofrequency exposures. Environ Health Perspect 117:1329–1332; doi:10.1289/ehp.0900727 [Online 18 May 2009].

IARC (International Agency for Research in Cancer). 2002. Non-Ionizing Radiation, Part 1: Static and Extremely Low-Frequency (ELF) Electric and Magnetic Fields. IARC Monogr Eval Carcinog Risk Hum 80:1–429.

ICNIRP (International Commission on Non-Ionizing Radiation Protection). 1998. Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz). Health Phys 74(4):494–522.

IEEE. 2006. IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz. IEEE Std C95.1-2005. New York:IEEE.

Popper KR. 1945. The Open Society and its Enemies, Volume 2: The High Tide of Prophecy: Hegel, Marx, and the Aftermath. London:Routledge.

WHO (World Health Organization). 2000. Electromagnetic Fields and Public Health: Mobile Telephones and Their Base Stations. Fact Sheet No. 193. Available: http://www.who.int/mediacentre/factsheets/fs193/en/ [accessed 2 June 2009].

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EMF and the Precautionary Principle: Dolan and Rowley Respond

Environ Health Perspect. doi:10.1289/ehp.0901111R available via http://dx.doi.org [Online 26 October 2009]

In their letter commenting on our article (Dolan and Rowley 2009), Kundi et al.attempt to discredit us as “employees of the mobile telephone industry” and imply that we are merely advocating an industry position of support for the international radiofrequency exposure guidelines rather than addressing issues of substance regarding the application of the precautionary principle to mobile telephony. A careful reading of our article clearly demonstrates this is not the case.

With few exceptions, countries around the world have implemented the international guidelines based on many scientific reviews undertaken by experts appointed by national governments over the past decade. Kundi et al. simply ignore these reviews and their conclusions because they do not agree with them. Although Kundi et al. are entitled to hold and promulgate their own views, they should acknowledge that they are acting as advocates for lower guidelines (based on their own subjective analysis of existing scientific evidence) and they should not simply dismiss anyone who does not agree with their point of view.

Kundi et al. seem to think that the precautionary principle should be applied whenever there is some scientific doubt or uncertainty, without recognizing that its use is limited by national regulatory and legal constraints, which we addressed in our commentary (Dolan and Rowley 2009). In particular, the concerns should be plausible (World Commission on the Ethics of Scientific Knowledge and Technology 2005). As an example, the European Court of First Instance (Pfizer Animal Health SA v. Council of the European Union 2002) has ruled that

[A] preventive measure cannot properly be based on a purely hypothetical approach to the risk, founded on mere conjecture which has not been scientifically verified . . . . [A] preventive measure may be taken only if the risk, although the reality and extent thereof have not been fully demonstrated by conclusive scientific evidence, appears nevertheless to be adequately backed up by the scientific data available at the time when the measure was taken.

The many scientific review bodies we referred to in our article (Dolan and Rowley 2009) have not considered the existing health data on mobile telephony adequate to trigger the application of the precautionary principle.

We accept that decisions regarding application of the precautionary principle are not to be made by scientists alone because they “have neither democratic legitimacy nor political responsibilities” (Pfizer Animal Health SA v. Council of the European Union 2002). However, governments should not simply disregard scientific advice or adopt popularist policies and “fall prey to public fear when it is baseless” (Telstra Corporation Limited v. Hornsby Shire Council 2006).

In the conclusion of our commentary (Dolan and Rowley 2009), we made it clear that there are many things that governments and industry can do to better address public concern, including supporting ongoing research and conducting education and information programs for the public who, when fully informed, are better able to take their own personal precautionary measures if they wish to do so. What should be avoided is the rush to adopt measures—justified by reference to the precautionary principle—to reassure the public, because this has been shown to actually increase public concern (Weidemann and Schutz 2005).

The views expressed in this paper are those of the authors and do not necessarily represent the views of any organizations or companies with which they are professionally associated. Their freedom to design, conduct, interpret, and publish research is not compromised by any controlling sponsor as a condition of review and publication.

Both authors are employed by trade associations representing the mobile communications industry.

Mike Dolan
Mobile Operators Association
London, United Kingdom
E-mail: mikedolan@ukmoa.org

Jack Rowley
GSM Association London,
United Kingdom
E-mail: jrowley@gsm.org

References

Dolan M, Rowley J. 2009. The precautionary principle in the context of mobile phone and base station radiofrequency exposures. Environ Health Perspect 117:1329–1332; doi:10.1289/ehp.0900727 [Online 18 May 2009].

Pfizer Animal Health SA v. Council of the European Union. 2002. Judgment of the Court of First Instance of 11 September 2002 in Case T-13/99. Available: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:61999A0013:EN:HTML [accessed 3 July 2009].

Telstra Corporation Limited v. Hornsby Shire Council. 2006. NSWLEC 133. Available: http://www.lawlink.nsw.gov.au/lecjudgments/2006nswlec.nsf/c45212a2bef99be4ca256736001f37bd/fdf89ace6e00928bca25713800832056?OpenDocument [accessed 3 July 2009].

Wiedemann PM, Schütz H. 2005. The precautionary principle and risk perception: experimental studies in the EMF area. Environ Health Perspect 113:402–405.

World Commission on the Ethics of Scientific Knowledge and Technology. 2005. The Precautionary Principle. Paris: United Nations Educational, Scientific and Cultural Organization. Available: http://unesdoc.unesco.org/images/0013/001395/139578e.pdf [accessed 3 July 2009].