TIG response to the NRPB consultation document

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.

Proportionality

The evaluation of a risk should be firmly founded on full consideration of the weight of evidence, and any selection of precautionary measures designed to be proportionate to that risk.

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.

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