DECEMBER 2021 – SUBMISSION TO IRISH GOVERNMENT ON ICNIRP GUIDELINES

Submission 2021 re ICNIRP Guidelines pdf

Submission to Government Departments

ARE THE ELECTROMAGNETIC RADIATION GUIDELINES CURRENTLY BEING USED, PARTICULARLY THOSE FOR WIRELESS TELECOMMUNICATIONS, PROTECTIVE OF OUR HEALTH?

It seems that all enquiries to Government Departments regarding possible health effects from emissions of Electromagnetic radiation (EMR) and in particular, for the purpose of this submission Radiofrequency (RF) from wireless telecommunication devices and infrastructure are responded to with assurances that there are no health effects below the ICNIRP (1) guidelines.  The question is, what are the ICNIRP guidelines and have these been efficiently examined by the Government to protect us, our children and other living things?

Guidelines currently used by our Government were first published in 1998 and moderately updated in 2020 and have been produced by the International Commission on Non-ionising Radiation Protection (ICNIRP), a registered private association based in Germany.  The ICNIRP is recognized as the main body of expertise in non-ionising radiation protection for the World Health Organisation (WHO) and the E.U.  As with the WHO the ICNIRP is a non-governmental organisation and, as the scientific arm of the WHO, established the WHO International EMF Project with funds collected from governments and industry.  The ICNIRP have gained huge influence globally as a majority of countries around the world have adopted their guidelines on limits of protection and potential health risks from EMR/RF.

Over the past twenty years numerous Appeals and Consensus statements from International Scientists and Physicians, NGOs, concerned professionals and the public have been sent to the WHO, the U.N., Council of Europe and various Governments asking for the ICNIRP guidelines to be reviewed in light of up-dated science .(2), (3), (4), (5)  To date all of these have been ignored despite scientific proof of cancers, adverse health effects, and the growing number of people who now suffer from Electrohypersensitivity (EHS)/ microwave sickness (5% to 10% of the global population).

So, if the EU, other major countries and our own Government continue to disregard Appeals from independent scientists and physicians, and concerns from the public with a mantra that there is no scientific evidence of health effects below ICNIRPs limits, is this factually correct?  Does any real evidence regarding health risks from RF exist?  Is it okay not to protect citizens under the pretext of ‘scientific uncertainty’?

With the knowledge that politicians don’t undertake research themselves and that our health, our children’s health and the health of our planet is paramount, the nitty-gritty of the guidelines should be scrutinized, questions asked and findings opened up in the public arena.

Weaknesses in the ICNIRP Guidelines

The ICNIRP guidelines are based on an experiment undertaken in 1953 by Dr Herman Schwan (6) a German scientist invited to the USA after the Second World War.  Schwan studied the absorption of Electromagnetic field energy (including RF) by the body for heat stress, an experiment that was performed on mannequins composed of bags of fluids considered to mimic bodily contents.  The heating/thermal effects of EMR/RF on the mannequins were then measured in order to produce a hypothesis regarding the safe limits for human exposure to EMR/RF.  The results of this experiment became the basis for most EMR/RF exposure standards that continue to be used today. Schwan’s experiment did not address the potential effects on the body of non-thermal radiation and are based on physics/physiology and not on the body at biological, cellular or molecular level.  The Mid-Term Review of the EU Environment and Health Action Plan 2004-2010 (Ref P6-TA-2008-0410 Point 22) (7) notes that limits of exposure set for the general public are obsolete given that current science is excluded along with potential effects on vulnerable groups.

The guidelines continue to be based solely upon the potential impact of heating/thermal effects of EMR/RF on the body.  The ICNIRP actively continue to assure the world that there is no scientific evidence of harmful effects from the radiation emitted by this relatively new communications technology below the proposed heating/thermal limits. In 2015 (Istanbul) ICNIRP stated in a draft review that ‘non-thermal effects do not exist because …  we do not know [any] mechanism that could cause them’.  (See ICNIRP will debate ‘Thresholds of thermal damage’) (8)  At that time scientific literature already existed on the mechanisms by which non-thermal effects occur.  Nowadays the majority of independent scientists accept the mechanistic basis behind biological effects. (9)

The ICNIRP guidelines only consider acute exposure, and short-term exposure to RF (6 minutes in 1998 and 6 – 30 minutes in 2020). Today most people are subjected to long-term chronic exposure to pulsed/modulated emissions of RF on a 24/7/365 basis.  This would seem to be a crucial element to take into account when considering potential health effects, yet it has not been.

The ICNIRPs updated version of the guidelines (2020) continue to promote the opinion that the only proven health effects induced by EMR/RF are those that occur through the heating of human tissue. The ICNIRP continue to maintain their safe threshold level as being upwards to 61V/m (volts per metre).  In stark contrast to this the European Academy for Environmental Medicine (EUROPAEM (2016) (10) and the BioInitiative Group Report (2012) (11) (a collaboration of prestigious scientists and health experts) concur that 0.6 V/m should be the upper threshold and that levels above this have been scientifically proven to cause biological harm.

The ICNIRP guidelines are being promoted as referring to all humans exposed to EMR/RF despite experiments on one-size mannequins (body and head).  They therefore do not take the developing bodies of children, the elderly or those with illnesses/vulnerabilities into account. Foetuses are treated as a ‘member of the general public’ (16)  Independent scientists concur that children are more exposed to radio-frequency radiation than adults. (12)

The ICNIRP guidelines do not consider effects on animals, plants, insects, biodiversity, the environment or the planet, despite numerous available peer-reviewed scientific papers identifying actual harmful effects on them from EMR/RF as identified in the comprehensive report Bees, Birds and Mankind, Destroying Nature by Electrosmog, (13) Dr Ulrich Warnke and recent review by the National Institute of Environmental Research (NIER). (14)

The ICNIRP guidelines are now the minority scientific opinion.  The 1998 guidelines and the updated version (2020) excludes scientific research that contradicted the ICNIRP opinion, a bias that saw rejection of the ever-growing number of peer-reviewed scientific studies on negative health effects from EMR/RF non-thermal radiation.  It was noted that not one of the five reviews used to update the ICNIRP guidelines has been published after peer-review in a scientific journal, and criticism by the scientific community against several of these reviews has been ignored.  (Hardell et al Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on radiofrequency Radiation …  pg 255) (15)

Some documented points in ICNIRPs 1998 guidelines such as ‘microwave hearing’ have been removed in the updated version.  The reason provided by ICNIRP is that ‘there is no evidence that it would adversely affect health’. (Differences Between the ICNIRP (2020) and Previous Guidelines) (16) This is particularly concerning given that this is one of the most torturous effects of microwave sickness/EHS and experienced constantly by many people who are already suffering from EHS.  Microwave hearing was first recognised in 1962 by Dr Allan Frey and the science is continuously being updated, e.g., James Lin’s work (17) and more recently by Dr. Beatrice Golomb (18) in light of what is being referred to as The Havana Syndrome (EHS/microwave sickness).  The European Council Recommendations 1999/519/EC (pg 65) (19) recognised effects of localized EMF exposure of the head and recommended that limitations be taken into account in order to avoid the auditory effect.  For sufferers it seems that these limitations have been completely ignored.

There appears to be no real oversight or control over the ICNIRP, nobody controls it, nobody supervises it, nobody checks it for conflicts of Interests, nobody checks it for the scientific accuracy. (Environmental Health Trust – Deep Industry Ties, No Oversight and Only 14 Members…) (20)  It is questionable why the WHO works so closely with ICNIRP to the exclusion of other research groups and public health professionals.

The ICNIRP are defined as a self-selected closed group with strong links to industry and the military through the WHO, the Institute of Electrical and Electronic Engineers (IEEE) and the International Committee on Electromagnetic Safety (ICES), which it is believed, accounts for biased guidelines/reports.  As a closed group ICNIRP appoints its own members who shift position within ICNIRP and move around monopolising other evaluation committees, for example the Irish Expert Group (2007). (21) This creates a situation in which the ‘no risk’ mantra is enabled and reinforced as the only narrative.  The group ‘Investigate Europe’ provide an interactive graph to visually understand this better: https://www.kumu.io/Investigate-Europe/whos-who (22)

The EU Report The International Commission on Non-Ionising Radiation Protection: Conflicts of Interest, Corporate Capture and the Push for 5G, (23) produced by MEPs Klaus Buchner and Michele Rivasi informs us, among other things, that ICNIRPS invitation to industry organisations IEEE and the ICES to make comment on the then upcoming 2020 guidelines gave them special permission to influence the conclusion.  The implication of such an action is ‘that large telecom-companies … as well as US military, had a direct influence on ICNIRP guidelines which are still the basis for EU-policies in this domain’.  (Hardell et al, pg 269) (15)

The ICNIRP guidelines are only guidelines, yet they are being used as de facto/factual standards.  Given this, no legal responsibility for subsequent harm falls onto that organisation for countries that have chosen to use their guidelines.

‘Safety guidelines developed by the ICNIRP are ‘the sole guidance used by the Telecommunications industry that manufactures and operates wireless communication hardware and infrastructure throughout most of the world’ (Professor Leszczynski) (21) and the guidelines are being used to justify the workings of industry through Governments and their agencies.

THE REGULATORY POSITION IN IRELAND

The Telecommunications Antennae and Support Structures Guidelines for Planning Authorities 1996 and the ICNIRP guidelines are the standards used in relation to EMR/RF regulation in Ireland.

The ICNIRP guidelines bypassed the scrutiny of Dáil Eireann and the approval of the Houses of the Oireachtas by being adopted directly into licensing practice for Telecommunications operators through the Commission for Communication Regulation (ComReg).

No primary legislation exists to protect public health, no implementation measures are taken on basic restrictions and the precautionary principle does not appear to have been adopted in Ireland.

Any existing regulations appear to be pro-industry with minimal monitoring e.g. planning authorities have been instructed not to take health into account regarding planning applications – through Circular Letter PL 07/12. (24)  This letter stipulates that health has been replaced by ‘other codes’.  These ‘codes’ remain elusive as, in response to a number of enquires sent, no Government Department or official has managed to identify what these are.

The subsequent Circular Letter PL 01/2018 (25) removed restrictions regarding size, number, placement etc of antennae and Circular PL 11/2020 (26) allowed certain ‘overground electronic infrastructure’ to become exempt from planning permission under Section 254 licenses.  These three Circular Letters saw the removal of any possibility of the public exercising their right to effectively object to, or being consulted about, developments, ie. 12, 15 or 18 metre high telecommunications structures, that would potentially affect their person, home and community.

ComReg, because of its remit, cannot avoid being heavily influenced by the telecommunications industry and it is therefore difficult for it to be impartial. There is an inherent conflict of Interest in being responsible for selling frequencies to the industry and also regulating it, and this is not helped by the vast amounts of finance involved which might encourage complicity and lead to the science not being efficiently examined.

ComReg had, up to recently, offered a service of monitoring the homes of people who made contact with them with concerns about levels of RF/microwaves in their environment.  Monitoring was based, as per ICNIRP guidelines, only on thermal effects and only for a short period (6 minutes) and only for average measurements, all of which lead to the risk being underestimated.  The Environmental Protection Agency has now taken over this service on a similar basis.

The Department of Communications, Climate Action and Environment is identified by other Government Departments as having responsibility for policy in relation to health and EMR/RF.  There are two major issues here:  The Department of Health has no legislative or Constitutional right to devolve responsibility for health to another Department nor to ignore their own role regarding public health.  Furthermore, response to inquiries seem to indicate that no actual policy with regard to health and EMR/RF exists.

Over the years warnings have been placed before the Dáil and various Government Departments by the public and elected representatives, e.g. through Questions in the Dáil and through The Mobile Phone Warning Bill (Members Bill No. 24 of 2011) (27) which passed through a number of stages in Seanad Eireann but was mysteriously quashed on 31st May 2011.  Aggressive lobbying by the wireless industry has seen similar actions occur in other countries – is this what happened to Bill No. 24, a bill that was generated to protect people, especially children?

The telecommunications industry is insulated from any responsibility for public health issues and subsequent financial costs should harm occur.  These have been shifted onto the taxpayer and ultimately it is the Exchequer/public purse that will bear the cost.

Understanding the risks of EMR/RF has seen the Insurance Industry remove themselves from risk of potential loss through Exclusion 32. (28)

Fifty per cent of the Irish Expert Group who produced the report Health Effects of Electromagnetic Fields 2007 (29) were members of the ICNIRP group.  A third member had represented a Telecom company at a Joint Committee on Non-ionising Microwave Radiation from masts (1998) (30) and the fourth member famously declared at a Seminar on EMF Risk Perception, Canada (1998) that ‘Ireland’s EMF policy is not to allow the EMF-health issue effect the growth and prosperity of the Irish economy’. (31)  The Irish Expert Report dismisses any health concerns below thermal/heating levels i.e. ICNIRP guideline levels.

The public have not been made aware of the dangers of EMR/RF despite recommendations from the EU Council e.g. Parliamentary Assembly Doc. 12608 Report, May 2011 (32) and its subsequent Resolution 1815 (2011), The potential dangers of electromagnetic fields and their effect on the environment (33) and the Parliamentary Report A6-0089/2009 On health concerns associated with electromagnetic fields 2008/2211(INI) (34). These have all been ignored along with the European Environment Agency’s (EEA) reports on Late Lessons from Early Warnings (35). (36).  (See also Science of Spin: Targeted Strategies to Manufacture Doubt with Detrimental Effects on Environmental and Public Health) (37)

Despite the fact that microwave sickness/EHS has been known about since the 1930s, it is not formerly recognized by the Irish Government.

The burden of proof is placed on the victim of EMR/RF pollution whose daily physical symptoms prevent them from living an equal life to others and for whom daily tasks can become insurmountable problems.  Instead of having their experiences taken seriously many are subjected to ridicule, labelled as conspiracy theorists, Luddites or of having psychological problems.  If research clearly demonstrates the fact that plants, animals and insects are affected by EMR/RF, surely it cannot all result from fear generated through access to media sources.  A scientific consensus International report by 32 scientists working in the field of EMR/RF puts paid to such a notion.  The Critical Importance of Molecular Biomarkers and Imaging in the Study of Electrohypersensitivity (2021) (Belpomme, Carlo et al). (38)

 Medical practitioners have not been trained in environmental illnesses such as EHS or the sometimes related, multi-chemical sensitivity.  Instead, doctors have been informed that ‘treatment of affected individuals should focus on the health symptoms and clinical picture’ and that ‘GPs should be informed that the (EHS) symptoms are not due to EMF exposure’. (Expert Group 2007 pg 5 and pg 54). (29)

Despite being informed that a Swisscom system is available to assist in the reduction of electrosmog from wireless local area networks designed to reduce the risk of damage to health, no action has been taken. Swisscom (one of the largest telecommunications companies) have a patent application that confirms adverse health effects and also confirms that health destruction is ‘not dependent upon temperature increases/thermal. (See page two – WIPO Patentscope, 1. (W02004075583) – Reduction of Electrosmog in Wireless Local Networks. (39)

CONCLUSION

The Irish Government and its agencies seem to have contented themselves with replicating and adopting the recommendations advocated by the ICNIRP in order not to impede the expansion of technological progress/economic growth/job creation and also because political decision-makers still have little involvement in matters of assessing technological risks for health and the environment.  This has resulted in decision-making regarding EMR/RF being based on ICNIRPs obsolete guidelines.  These guidelines are not biologically based and emerged from a thermal only physiological experiment undertaken in the 1950s.

In 2016, the Irish Government did commission the National Institute for Public Health and the Environment (RIVM) (40) in the Netherlands to review updated possible health effects from EMR/RF and policies used in other EU countries. In reviewing radiofrequency, the RIVM considered findings from ICNIRP, SCENIHR and AGNIR i.e. groups with the same ‘experts’.   This process of asking the same people the same question while expecting to get a different answer is quite insane.  It undermines credibility of real evidence and creates doubt.  Both SCENIHR and AGNIR were later dissolved due to Conflicts of Interest and inaccurate reflection of the scientific evidence available and we have now learned about potential Conflicts of Interest in the ICNIRP group (41).  The EMF Call to the U.N., WHO and all Governments from hundreds of scientists in 2018 requested that they do not accept the ICNIRP guidelines as they are not protective and pose a serious risk. (2)

Scientifically justifiable worries appear to be actively dismissed as scare tactics, hostility to technology or ignorance.  Ordinary citizens, many of whom have become ill, are faced with an inaccessible environment and ignoring of their human rights.  Those who are active experience the daily chore involved in navigating the lack of transparency, an official game of pass-the parcel and an ostrich style management towards care of the public.

The current EMR/RF exposure limits need to be reviewed again by independent scientists as a matter of urgency as they are not protective of human health or indeed of our flora, fauna, insects, environment or the planet.

In August 2021 the FCC (equivalent of our ComReg) was challenged in a Court of Appeals (USA) regarding their EMR/RF guidelines.  The Court ruled against the FCC stating that their guidelines were not evidence based due to exclusion of current science and cannot be considered to provide an assurance of safety.  At the hearing 11,000 pieces of evidence regarding the health effects of EMR/RF were contained in the brief, the link to this information is provided for your perusal.  (42), (43), (44) & (45)

This submission is important as it is a voice for people within our population who suffer from microwave sickness/EHS. (46)  It is for the children who cannot attend school due to feeling unwell around WiFi networks, the young people who cannot stay in employment, those who have lost their homes or cannot leave them, the elderly who are travelling the roads seeking a safe place to sleep, the victims living in sheds and tents.  The main issue for EHS lies in an inaccessible environment associated with unsustainable levels of EMR/RF both within and outside the home. The most noted symptoms are extreme pressure in the head, burning head and face, brain fog, severe pain especially in head and limbs, palpitations, eye and ear problems, insomnia, vertigo, skin tingling, skin rashes and ‘microwave hearing’ etc.  Long-term effects include Cancer, Neurological/Neuropsychiatric effects, Anxiety and Stress, Alzheimers, Autism, Genetic effects such as male sterility, DNA damage, Miscarriage and Birth defects, Asthma, Diabetes, Thyroid dysfunction, Bleeding disorders, and significantly decreased sperm counts. (BioInitiative Report 2012) (11).  Allowing this situation to continue is shameful given that there are safer ways to have a communications infrastructure, access the internet and benefit from use of this technology where wireless radiation is not necessary, or significantly reduced.

Thank you for reading this

Researched and Written by Ethna Monks on behalf of Electromagnetic Sense Ireland

 ES Ireland is a Member of the Co-ordination of organisations in Europe for an EMF exposure regulation which truly protects public health: http://www.peccem.org/DocumentacionDescarga/Plataforma-Estatal/notasprensa/European.coordination.press.release-february-2017.pdf

ES Ireland at https://es-ireland.com


 

CHECKLIST REGARDING WEAKNESSES OF THE LIMITS OF PROTECTION IN THE ICNIRP GUIDELINES AND THE IRISH REGULATORY SYSTEM RE WIRELESS TECHNOLOGIES

The ICNIRP guidelines are obsolete as they are based on experiments carried out in 1953 and don’t take current research into account

The experiment was carried out on fluid-filled bags thought to mimic the body

They are based on physics/physiology and not on biological/cellular/molecular level

They only take thermal/heating effects into account

Mechanistic basis of non-thermal effects not accepted despite available science

They only consider acute exposure

They only consider short-term exposure

Their ‘safe’ level is up to 61 V/m whereas majority science threshold level prior to harm is 0.6 V/m

No difference in age, vulnerability, developing bodies of children or foetuses are taken into account

No mention is made of effects on other living things e.g. flora, fauna, insects or biodiversity

Their opinion is the minority scientific opinion, based on assumptions of safety and not on current scientific evidence

Bias in choice of scientific studies used to produce guidelines, all contradictory research excluded

None of the documents used to update the ICNIRP guidelines have been published in scientific journals after peer-review, and criticism of them has been ignored.  (Hardell pg 255)

Removal of points noted in the 1998 version when updated in 2020 e.g. ‘microwave hearing’

No oversight or control of the ICNIRP

Bias involved in membership through the exclusion of other research groups and public health professionals

A closed group of 14 scientists with strong links to the telecommunications industry and the military and with no accountability

They are only guidelines yet they are being used as de facto standards

ICNIRP have no legal responsibility for potential harm

Being used as sole guidance and to justify workings of the industry through Governments and their agencies

Do not take social or economic considerations into account e.g. health and cost of health implications

REGULATORY POSITION IN IRELAND (in addition to the above)

 The ICNRIP guidelines bypassed the legislative process by being adopted directly into ComReg’s licensing practice

No primary legislation exists to protect public health

Instructions from Government not to take health into account in planning Circular Letter: PL 07/12

All regulations regarding size, place and number of antennae removed through Circular Letter PL 01/2018

Inherent Conflict of Interest between selling frequencies and notionally regulating them (ComReg)

Influence by industry

Monitoring is limited to ICNIRP guidelines based on thermal, short-term (6 minutes) and only on average measurements – potentially underestimating risk

Transfer of responsibility re policy on health effects from EMR/RF to DCCAE is unconstitutional

DCCAE does not seem to have any particular policy on health effects from EMR/RF

Warnings placed before the Dáil through questions and Bills (Bill No 24 of 2011) ignored and quashed

Insulation of industry from any cost for health effects, transferred to the public purse

Fifty per cent of the Irish Expert Group were also members of the ICNIRP – Conflict of Interest

The public have not been made aware of dangers from EMR/RF despite EU recommendations

Burden of proof is placed on victims of electropollution

The Insurance industry understands the EMR/RF risks and have removed themselves from potential loss (Exclusion 32)

The RIVM report commissioned by the Irish Government was based on inaccurate reflection of current scientific evidence available.  Two of the organisations providing information for the RIVM on RF have since been dissolved for this reason and due to Conflicts of Interest.

Reduction of Human Rights for those suffering from microwave sickness/EHS

No recognition, no resources, no help, no redress for those adversely affected by electromagnetic & wireless radiation


REFERENCES

  1. ICNIRP Guidelines 2020 https://www.icnirp.org
  2. EMF Call for Truly Protective Limits for Exposure to Electromagnetic Fields https://www.emfcall.org/the-emf-call/
  3. EMF Scientists Appeal 2016 – to UN, WHO and UN member nations  https://emfscientist.org
  4. International Appeal – Stop 5G on Earth and in Space – to UN, WHO, Council of Europe and Governments https://www.5gspaceappeal.org/the-appeal
  5. PHIRE Medical Organisation: 2020 Consensus Statement of UK and International Medical and Scientific Experts and Practitioners on Health Effects of Non-Ionising Radiation (NIR) Press Release:   https://phiremedical.org/wp-content/uploads/2020/11/Press-Release-2020-Non-Ionising-Radiation-Consensus-Statement.pdf
  6. Herman P. Schwan: A Scientist and Pioneer in Biomedical Engineering by Kenneth Foster:  Annual Review of Biomedical Engineering Volume 4: 1-27 (Volume publication date August 2002) https://www.annualreviews.org/doi/10.1146/annurev.bioeng.4.092001.093625
  7. Mid-Term review of the European Environment and health Action Plan 2004 – 2010 http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+REPORT+A6-2008-0260+0+DOC+XML+V0//EN
  8. ICNIRP will debate ‘Thresholds of thermal damage’ Professor Darius Leszczynski   May 21, 2015 https://betweenrockandhardplace.wordpress.com/?s=ICNIRP+will+debate+thresholds&submit=Search
  9. Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or adverse effects Martin L Pall PhD, June 2013 Journal of Cellular and Molecular Medicine 17(8) https://www.researchgate.net/publication/242331926_Electromagnetic_fields_act_via_activation_of_voltage-gated_calcium_channels_to_produce_beneficial_or_adverse_effects
  10. EUROPAEM: European Academy for Environmental Medicine – EMF Working Group:  Europaem EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses     Belyaev et al.  Rev Environ Health 2016, 31(3):  363-397 https://www.researchgate.net/publication/305689940_EUROPAEM_EMF_Guideline_2016_for_the_prevention_diagnosis_and_treatment_of_EMF-related_health_problems_and_illnesses
  11. BioInitiative Report: A Rationale for a Biological based Public Exposure Standard for Electromagnetic Radiation. Sage, C. and Carpenter, D, Editorshttp://www.bioinitiative.org/conclusions/
  12.  Redmayne M, Johansson O.  Radiofrequency exposure in young and old:  different sensitivities in light of age-relevant natural differences.  Rev Environ Health, 2015 Dec 1 30(4):  323- https://www.researchgate.net/publication/284888146_Radiofrequency_exposure_in_young_and_old_Different_sensitivities_in_light_of_age-relevant_natural_differences
  13. Warnke, Ulrich: Bees, Birds and Mankind, Destroying Nature by ‘Electrosmog’ Effects of Wireless Communication Technologies.  English Edition 2009 https://www.researchgate.net/publication/241538484_BEES_BIRDS_AND_MANKIND
  14. NIER: Effects on Flora & Fauna:  A Major Review:  27 September 2021 https://www.microwavenews.com/short-takes-archive/review-emf-and-rf-effects-flora-and-fauna
  15. Hardell, Lennart, Mona Nilsson, Tarmo Koppel, Michael Carlberg Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on radiofrequency Radiation:  Journal of Cancer Science and Clinical Therapeutics 2021; 5(2):  250-285https://www.fortunejournals.com/articles/aspects-on-the-international-commission-on-nonionizing-radiation-protection-icnirp-2020-guidelines-on-radiofrequency-radiation.html
  16. Differences Between the ICNIRP (2020) and Previous Guidelineshttps://www.icnirp.org/en/differences.html
  17. Hearing of Microwave pulses by humans and animals: effects, mechanism, and thresholds. Lin, JC, Wang Zhttps://www.ncbi.nlm.nih.gov/pubmed/17495664
  18. Beatrice Golomb MD, PhD – Diplomats Mystery Illness and Radiofrequency/Microwave Radiation 2018 https://iervn.files.wordpress.com/2021/01/fa902-cuba2018-08-23c-nejm.pdf
  19. EU Commission Recommendation 1999/519 Implementation Report 2008 Council Recommendation of 12 July 1999 on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz)  –  (1999/519/EC) Official Journal of the European Communities 30.7.1999:  L199/59 – 70 https://ec.europa.eu/health/archive/ph_determinants/environment/emf/implement_rep_en.pdf
  20. Environmental Health Trust: ICNIRP the International Commission on Non Ionizing Radiation Protection: Deep Industry Ties, No Oversight and Only 14 Members,  March 31, 2021 https://ehtrust.org/icnirp-the-international-commission-on-non-ionizing-radiation-protection-deep-industry-ties-no-oversight-and-only-14-members/
  21. Leszczynski, Darius, Professor [Tribune] 5G is testing the limits of trust 8th September 2021 published on the Medium website on April 13, 2021https://www.phonegatealert.org/en/tribune-5G-is-testing-the-limits-of-trust
  22. Investigate Europe: an interactive graphic re members of the ICNIRPhttps://www.kumu.io/Investigate-Europe/whos-who
  23. The International Commission on Non-Ionizing RadiationProtection: Conflicts of interest, corporate capture and the push for 5G: Report on ICNIRP by MEPs Klaus Buchner and Michèle Rivasi 2020  https://www.michele-rivasi.eu/wp-content/uploads/2020/06/ICNIRP-report-FINAL-JUNE-2020_EN.pdf
  24. Circular Letter (PL 07/12) https://www.gov.ie/en/circular/2c470-circular-pl-072020-planning-and-development-section-38-regulations-2020-si-no-180-of-2020/
  25. Circular Letter (PL 01/2018) http://www.housing.gov.ie/planning/development-management/circular-pl-012018-amendments-exempted-development-provisions
  26. Circular Letter PL 11/2020 http://www.housing.old.gov.ie/sites/default/files/publications/files/pl_11-2020_telecoms_exemptions_17_dec_2020_final_headed.pdf
  27. Mobile Phone Radiation Warning Bill 2011 https://data.oireachtas.ie/ie/oireachtas/bill/2011/24/eng/initiated/b2411s1.pdf
  28. Exclusion 32 – Insurance Industryhttps://ehtrust.org/key-issues/electromagnetic-field-insurance-policy-exclusions/
  29. Irish Expert Report: Health Effects of Electromagnetic Fields 2007   https://www.three.ie/pdf/Expert%20Group%20on%20Health%20Effects%20of%20Electromagnetic%20Fields.pdf
  30. Joint Committee on Public Enterprise and Transport Report on Non-ionising Microwave Radiation Emissions from Communications Masts – 1998 http://archive.oireachtas.ie/1998/REPORT_26111998_0.html
  31. Proceedings International Seminar on EMF Risk Perception and Communications Canada, 31 August – 1 September 1998  https://www.who.int/peh-emf/publications/reports/ottawa.pdf
  32. EU Parliamentary Assembly Doc. 12608 (6 May 2011)  https://pace.coe.int/en/files/13137/html
  33. EU. Parliamentary Assembly Resolution 1815 (2011), The potential dangers of electromagnetic fields and their effect on the environmenthttp://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en.asp?fileid=17994
  34. EU. Parliament Report A6-0089/2009 on health concerns associated with EMF -Committee on the Environment, Public health and Food Safety 2008/2211(INI)http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+REPORT+A6-2009-0089+0+DOC+PDF+V0//EN
  35. EEA – Late lessons from early warnings ii – Part A – Lessons from Health Hazards – Chapter 1 The Precautionary Principle and False Alarms by Steffen Foss Hansen and Joel A. Tickner https://www.eea.europa.eu/publications/late-lessons-2/part-a-lessons-from-health-hazards
  36. EEA Report – No. 1/2013, Part E, Implications for Science and government. Late Lessons ii Chapter 26 Science for Precautionary decision-making by Philippe Grandjean, page 623  https://www.eea.europa.eu/publications/late-lessons-2/late-lessons-chapters/late-lessons-ii-chapter-26/view
  37. The Science of Spin: Targeted Strategies to Manufacture Doubt with Detrimental Effects on Environmental and Public Health, Goldberg R., Vandenberg, L. Environmental Health Volume 20, Article Number: 33 (2021) https://ehjournal.biomedcentral.com/articles/10.1186/s12940-021-00723-0
  38. The Critical Importance of Molecular Biomarkers and Imaging in the Study of Electrohypersensitivity. International Medical Journal of Medical Science, 22, 7321. International Scientific Consensus written by 32 authors:  Dominique Belpomme, George L Carlo, Phillipe Irigaray, David Orlo Carpenter et al https://www.researchgate.net/publication/353095266_The_Critical_Importance_of_Molecular_Biomarkers_and_Imaging_in_the_Study_of_Electrohypersensitivity_A_Scientific_Consensus_International_Report/link/60e72a0630e8e50c01f011e6/download
  39. Swisscom Patent Application: WIPO Patentscope – 1. (WO2004075583) Reduction of Electrosmog in wireless local networks  https://www.emfacts.com/2014/04/swiss-teleco-acknowledges-rf-dangers-in-2003-patent-application/
  40. RIVM Report (National Institute for Public Health and the Environment, Netherlands) https://www.rivm.nl/bibliotheek/rapporten/2015-0073.pdf
  41. AGNIR (2017): Mobile Phone Cover-up?  Gov’t advisory body disbanded – inaccurate and misleading conclusions remain.  https://truepublica.org.uk/united-kingdom/mobile-phone-cover-up-govt-advisory-body-disbanded-inaccurate-and-misleading-conclusions-remain/
  42. The Defender, Children’s Health Defence, 21.1.21. 11,000 pages of Evidence filed in Landmark 5G Case Against the FCC hearing.  Links to Joint Appendix 27 Volumes https://childrenshealthdefense.org/defender/landmark-5g-case-against-fcc-hearing-set-jan-25/
  43. January 18th 2021 – Environmental Health Trust Et AL. V. FCC Key Documents in case https://ehtrust.org/environmental-health-trust-et-al-v-fcc-key-documents/
  44. Proposed FCC changes to Measuring and Evaluating Human Exposure to Radiofrequency Electromagnetic Fields and Wireless Power Transfer Devices are Flawed: need for biologically-based standards: Paul Ben Ishai 1* , Mikko Ahonen 2 , Hugo Gonçalves Silva 3 and Devra Davis https://ecfsapi.fcc.gov/file/1061621406508/FCC%20Submission%2019-226%20Environmental%20Health%20Trust.pdf
  45. IN HISTORIC DECISION, FEDERAL COURT ORDERS FCC TO EXPLAIN WHY IT IGNORED SCIENTIFIC EVIDENCE SHOWING HARM FROM WIRELESS RADIATION – August 13 2021 https://ehtrust.org/in-historic-decision-federal-court-finds-fcc-failed-to-explain-why-it-ignored-scientific-evidence-showing-harm-from-wireless-radiation/
  46. Electromagnetic Hypersensitivity – A Summary by Dr Erica Mallery-Blythe  https://www.radiationresearch.org/images/rrt_articles/Dr_Erica_Mallery-Blythe_EHS_A_Summary_Working_Draft_Version_1_Dec_2014_for_EESC_Brussels.pdf
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