TIG response to the NRPB
consultation document
“Proposals
for limiting exposure to electromagnetic fields”
It
seems to us that the NRPB’s proposals can be broken down into three broad areas
of interest to the TETRA Industry Group. Our comments on each area are set out
below:
1
The adoption of ICNIRP standards both for general public exposure and for
occupational exposure, for EMF both below and above 100 kHz
TIG
welcomes this approach. We strongly support the use of science- based guidelines
on safe human exposure to radio-frequency (RF) energy, that are derived by
independent expert bodies from a critical evaluation of the whole body of
scientific evidence. We believe that the formal adoption of ICNIRP-based limits
in the UK can help strengthen public confidence, not only in the safety of our
products and services, but also in the authorities charged with overseeing
health and safety matters.
We
note that the ICNIRP limits are themselves set with caution in mind, and include
substantial safety margins. We believe that a rigorous approach to compliance
with such guidelines enables industry to demonstrate its commitment to product
and service safety. Moreover, we believe that the adoption of ICNIRP-based
exposure limits in the UK will help move us closer to the goal of international
harmonisation of RF safety standards, and a more consistent and rational
approach to health and safety.
2
The application of the developing WHO precautionary framework
We
have written to the WHO in response to its own consultative process on the
development of the Framework. The key points we made to the WHO can be
summarised as follows:
-
Consistency
The approach taken in the
WHO Framework should be consistent with existing WHO advice, and with the views
of the EU and other relevant bodies around the world on precautionary
approaches. The definition of the key terms on which the Framework is predicated
should be clear and consistently applied throughout.
-
The importance of
Science-based Standards
The continued application
of science-based standards is essential, and we support the view that it would
not be appropriate to use the Framework for extending or developing guidelines
through arbitrary reductions in exposure limits. The standards-setting process
should remain firmly grounded in a rigorous assessment of the whole weight of
scientific evidence.
-
Definitions of Terms
Key terms should be
defined clearly and used consistently. This applies in particular to the term
“uncertainty”, where a distinction needs to be made between what is meant by
scientific uncertainty - as defined on page 7 of the WHO document - and what the
general public might understand by the general use of the term ‘uncertainty’.
-
Scope
The Framework should deal
with the issue of public health protection through the management of
environmental risks rather than trying to tackle broader issues such as poverty
or social well-being. A distinction should be drawn between health risks and
public concern. Policies on precautionary approaches should be based on the best
available scientific evidence, and not formulated solely or primarily to tackle
public concern, as this would undermine the application of scientifically-based
standards.
-
Cost Benefit Analysis
Any cost benefit analysis
used as a basis for decision-making on any precautionary approach, should
consider fully the broader benefits of the agent or technology under
consideration, including the disbenefits to society of not using the agent or
technology. (The TETRA technology, for example, is used by many emergency
services organisations around the world, and can improve the coverage, speed and
reliability of communications to such an extent that lives can be saved).
-
Weight of Evidence
A distinction should be
drawn between the greater weight which should be given to science-based
evidence, and the lesser weight which should be given to information which is
drawn from qualitative observation, anecdotal experience, or emotionally-based
concern.
-
Legal Implications
It should be acknowledged
expressly that the implementation of precautionary measures should not be taken
as an admission of liability for any consequences of not having acted earlier,
or differently, or indeed that the measures are necessary. In an increasingly
litigious society, this is an important principle.
3
The invitation to the international scientific community to consider adopting
induced field strengths and reducing the partial-body occupational exposure
limit to 5 W/kg from 10 W/kg, averaged over 10 grams of tissue
While
these matters are undoubtedly best left to recognised experts, we do have
a few points to make:
-
There is a well-established scientific rationale for the existing ICNIRP
limits, and the notion of a possible reduction in the partial-body
occupational limit does not appear to derive strong support from the available
evidence. While NRPB has identified theoretical studies of temperature rise
that deserve further attention, these are at present an inadequate basis for
any reconsideration of the partial-body limit. We agree that further
dosimetric research is required and we would also support closer expert
evaluation of the modelling data presented in the Consultation Document. In
the meantime however, we believe that the public can have every confidence in
the existing ICNIRP limits, and that the NRPB has a valuable role to play in
securing this confidence, and educating the public about the importance of
science in standard-setting.
-
Whilst the NRPB puts
this forward as a scientific issue, it cannot be divorced from the broader
issue of public concern cited in the Consultation Document. We believe that
exposure limits should be based on the best available science, and not on
attempts to mitigate public concern. There is, in our view, little reason to
believe that lower exposure limits would alleviate public concern. To take an
example, the TETRA base stations used for the UK Airwave service operate many
hundreds or thousands of times below the ICNIRP limits, but this has not
served to reassure the general public or eliminate local community opposition
to base station siting.
-
In summary, changes in
existing exposure limits should not be considered lightly, and the public must
have confidence in the safety guidelines and in those who set them. We
therefore support more detailed consideration of the papers cited by NRPB as a
possible basis for a change to the partial-body occupational limit, to assess
the strength of the scientific foundation for such a move.
Finally, as a general comment, we agree that the involvement of all relevant
stakeholders is necessary and desirable in addressing public concern and trying
to reach a mutually acceptable way forward. However, such a dialogue should not
be permitted to undermine the application of science-based standards. It should
be borne in mind that public concern can be derived from many factors (such as
house prices, visual outlook etc) other than health, and can often be traced
back to sensationalist media reporting, or to the claims of self-styled
‘experts’. It would be unfortunate if emotional rather than rational concerns
were allowed to drive forward the debate, and if precautionary action was taken
solely or primarily on the basis of placating pressure groups or the media.
We
look forward to playing our part in the constructive public dialogue that can
flow from the Consultation Document. In closing we would like to reiterate our
support for NRPB in recommending the adoption of ICNIRP limits as dependable
safeguards.
ends
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