A Review of the Health Risks of Radiofrequency Radiation Employed in 5G Technology
and the Implications for Policymaking

Tom Butler Ph.D. MSc |  Professor




Biography.  Butler Tom PhD MSc is a Professor of Information Systems (IS) at University College Cork, Ireland. A former  satellite and microwave telecommunications engineer, Tom teaches a range of computing (including data  communications and WiFi) and informatics courses at all levels. Of special import are his seminars on the  scientific method and philosophy of science to PhDs. He has over 200 publications in the IS field’s leading  journals and conferences and a rage of other outlets. Tom has garnered over €8.5m in research funding in the  past 15 years and has several technology innovations to his name. He is considered a global thought leader in  the field of regulatory risk and compliance, having worked with the Bank of England and the FCA on Digital  Regulatory Reporting. In 2018-2019, Tom was a member of the Expert Group on Regulatory Obstacles  Financial Innovation (ROFIEG) at the European’s Commission’s Directorate-General for Financial Stability,  Financial Services and Capital Markets Union (DG FISMA). In 2015, Tom began researching the risks posed  by wireless technologies to children, following a suggestion by the Chief Risk Officer of an insurance company.  This short report summarises the findings of his subsequent research reviews. Tom is now part of an  international community of scientists, all experts in their fields of epidemiology, oncology, biology, medicine,  physics, electrical and electronic engineering, and so on, and is regarded as one who can communicate the  findings of multi-disciplinary research to policy makers and the public in an unbiased and accessible manner.


This document was prepared to the request of the petitioners to the Israeli supreme court in the matter of the 5G antennae rollout

this short critical review explores the findings of extant
research on the health risks posed by 5G technologies  that emit
radiofrequency radiation (RFR), see comment 1 on the side of the page. It also provides evidence that the  processes by which policy decisions  have been made concerning the  protection of public health may be significantly flawed, as the  overwhelming  body of scientific evidence appears to have been ignored  by relevant government departments and agencies in  arriving at  decisions about the introduction of 5G. This lacuna comes about due to  the over-reliance on expert  opinion from the International Commission  on Non-Ionizing Radiation Protection (ICNIRP), an NGO whose  members  have traditionally had close ties to industry. It is significant, for  example, that governments or  regulatory agencies internationally have  neither sought nor obtained independent scientific advice on a matter  of  importance to public health.

Consequently, they are failing in their  duties to identify, assess, and mitigate the  risks posed by RFR-based  technologies before their introduction, specifically 5G networking and  related  TEchnologies, thereby protecting public health. This short  review examines this in the UK context: However  the same could be said  to apply in the US, where the FCC and FDA are captured agencies (Alster,  2015), or to  other democracies worldwide, where policymakers and  regulators fail to understand the difference between the  type and  strength of scientific evidence required to demonstrate causality and  the level of evidence necessary to  invoke the precautionary principle  and mitigate risks to human health and well-being (cf. Gee, 2008).

What does science have to say about the health risks of 5G Technology?

The World Health Organization (WHO) classifies non-ionizing radiofrequency radiation (RFR) as a possible  human carcinogen. It is, therefore, incredible that not a single, peer-reviewed scientific study has been carried  out on the health risks associated with 5G technologies that emit low frequency (700MHz), high frequency (3.4-3.8 GHz, centimetre (CM)) or extremely high-frequency millimeter (MM) (26 GHz and above) RFR. The  overwhelming majority of published peer-reviewed scientific studies in biomedical research databases PubMed,  Ovid Medline, EMBASE, Cochrane Library, and those listed in Google Scholar, indicate significant health risks  with RFR of the type used in 5G technologies, both near field in the home and far-field in antennae, whether on  access points or masts. The majority of scientific studies also show physical and biological effects viz. “As of  the 15th September 2017, the clear majority of 2653 papers captured in the database examine outcomes in the
300 MHz–3 GHz range. There are 3 times more biological “Effect” than “No Effect” papers; nearly a third of  papers provide no funding statement; industry-funded studies more often than not find “No Effect”, while  institutional funding commonly reveal “Effects”” (Leach et al. 2018). Simply put, as of 2017 68% of peer-reviewed scientific research studies, or the majority view, find physical and biological non-thermal effects,  while only 32% of studies, the minority position, find no evidence of non-effects (cf. Bandara and Carpenter,  2018). Logically speaking, the view of the majority of scientists across the biomedical and related fields is that  there are non-thermal physical and biological effects and they are significant: However, the minority view is  led by a group of 13 influential scientists from the International Commission on Non-Ionizing Radiation
Protection (ICNIRP) (Buchner and Rivasi, 2020).  Significantly, commission members have strong links with the telecommunications industry and hold key roles  in the WHO, the International Agency for Research on Cancer (IARC), and the EU’s Scientific Committee on  Emerging and Newly Identified Health Risks (SCENIHR). Thus, the minority view dominates through political  influence, not the preponderance of scientific evidence. The majority view is represented in the findings of  thousands of peer-reviewed empirical studies on microwave non-ionizing RFR focusing on the biomedical  effects of 2-4G and WiFi technologies (see Di Ciaula, 2018; Miligi, 2019; Russell, 2018; and Kostof et al. 2020,  for examples). There are also several reviews and general studies focusing on extremely high frequencies up to  100GHz that may be used in 5G (Neufeld and Kuster, 2018; Simkó and Mattsson, 2019). The overwhelming  majority of studies conclude that there is a high risk of adverse biological effects on humans at low, high and  extremely high frequencies. Recent research funded by DARPA (US Defense Advanced Research Projects  Agency) finds that ICNIRP guidelines focus on short-term risks only, not long‐term exposures to weak RFR:  this despite “a large and growing amount of evidence  indicates that long‐term exposure to weak fields can  affect biological systems and might have effects on human health” with significant “public health issues”  (Barnes and Greenebaum, 2020). Furthermore, research also finds biological effects at high frequencies may  add to and compound those predicted at lower frequencies (Kostof et al., 2020).


What are the health risks of non-ionizing RFR?


A recent research review on the health risks of RFR, involving independent verification based on 5,400 studies in the MedLine database, concludes that “the literature shows there is much valid reason for concern about potential adverse health effects from both 4G and 5G technology” and that extant research “should be viewed as extremely conservative, substantially underestimating the adverse impacts of this new technology” (Kostoff et al. 2020). Kostoff et al. report that peer-reviewed studies show the following adverse health effects well below  the safety limits set by the UK based on ICNIRP guidelines

   “*carcinogenicity (brain tumors/glioma, breast cancer, acoustic neuromas, leukemia, parotid gland  tumors), genotoxicity (DNA damage, DNA repair inhibition, chromatin structure), mutagenicity, teratogenicity,

neurodegenerative diseases (Alzheimer’s Disease, Amyotrophic Lateral Sclerosis)

neurobehavioral problems, autism, reproductive problems, pregnancy outcomes, excessive reactive  oxygen species/oxidative stress, inflammation, apoptosis, blood-brain barrier disruption, pineal  gland/melatonin production, sleep disturbance, headache, irritability, fatigue, concentration  difficulties, depression, dizziness, tinnitus, burning and flushed skin, digestive disturbance, tremor,  cardiac irregularities,

adverse impacts on the neural, circulatory, immune, endocrine, and skeletal systems.”

What is the scientific consensus on health risks?


It is significant that the vast majority of independent original  experimental and epidemiological research studies  and scientific review papers identify the health effects documented above (cf. Belpomme et al. 2018; Belyaev  Page 2 of 17et al. 2016; Miller et al., 2018; Barnes and Greenebaum, 2020, for examples of the latter). In addition, following
its own extensive empirical research on 2-3G radiation, which identifies clear evidence that RFR is carcinogenic  (Lin, 2019), the US National Institute of Environmental Health Sciences’ National Toxicology Program (NTP)  is investigating whether 5G poses similar risks to human health (National Toxicology Program, 2018b). Interalia, “NTP scientists found that RFR exposure was associated with an increase in DNA damage. Specifically,  they found RFR exposure was linked with significant increases in DNA damage in: the frontal cortex of the
brain in male mice, the blood cells of female mice, and the hippocampus of male rats” (NTP, 2018b). These  concerns are echoed and amplified in the conclusions of other systematic reviews (see Di Ciaula, 2018; Russell,
2018), which argue that precautionary approaches need to be adopted by governments, given the known risks  (Miligi, 2019). Significantly, Italian medical consultant and researcher Agostino Di Ciaula (2018) underlines
concerns and concludes from his review of the scientific and medical literature that 5G technology is of great  concern as the “available findings seem sufficient to demonstrate the existence of biomedical effects, to invoke  the precautionary principle, to define exposed subjects as potentially vulnerable and to revise existing limits.”
Thus, the majority of peer-reviewed scientific studies conclude that 2-4G and WiFi, and by logical  generalization, 5G, puts those exposed to RFR signals at significant health risks, even at exposure levels 100,000
times lower than Public Health England (PHE)/ICNIRP safety guidelines. However, the European Academy for  Environmental Medicine (EUROPAEM) EMF Guidelines (Belyaev et al., 2016) indicates a non-thermal safety  level of 1,000,000 to 100,000,000 times less than PHE and ICNIRP guidelines.


Is 5G RFR carcinogenic?


Few policymakers and healthcare professionals understand why in 2011 the WHO’s IARC classified non-ionizing RFR as a Class 2B possible carcinogen. RFR’s status as a major environmental toxin and probable
carcinogen has been confirmed in numerous studies since. A recent scientific review of RFR studies and the  links with cancer is unequivocal and states that “[m]obile phone radiation causes brain tumors and should be  classified as a probable human carcinogen (2A)”. However, new experimental and epidemiological research  has scientists conceding that it should be reclassified as a Class 1 human carcinogen. Accordingly, an IARC  Advisory Group of 29 scientists from 18 countries recommended that non-ionizing radiation be prioritized by  the WHO’s International Agency for Research on Cancer (IARC) Monographs programme during 2020–24  (IARC Monographs Priorities Group, 2019). It is significant that former ICNIRP members are now recognizing  this and also calling on the IARC to review its classification (see Lin, 2019). It is therefore of concern that 5G  RFR’s status as a carcinogen is played down by the UK  government and PHE: furthermore, it is clear that RFR’s  health risks as such are not understood, particularly by scientists and medical practitioners advising PHE.


What is the primary biological mechanism that leads to toxicogenic and carcinogenic  effects?

Non-ionizing RFR is considered by the majority of independent scientists as a potent environmental toxin, due  to its ability to cause oxidative stress in animal and human cells (Belpomme et al. 2018; Yakymenko et al.,  2016). The relationship between non-ionizing RFR, the increase in free radicals/reactive oxygen species, the  reduction in anti-oxidants, and oxidative stress in human cells of all types is significant (Kıvrak et al., 2017).
The vast majority of studies identify oxidative stress as the mechanism through which cancer and a range of  other more immediate health ill-effects, such as neurological and immunological effects, occur through
exposure to most environmental toxins, including RFR (cf. Barnes and Greenebaum, 2020). Bandara and  Carpenter (2018) report that “89% (216 of 242) of experimental studies that investigated oxidative stress
endpoints showed significant effects. This weight of scientific evidence refutes the prominent claim that the  deployment of wireless technologies poses no health risks at the currently permitted non-thermal
radiofrequency exposure levels.” Of particular concern here to many scientists are the effects on children’s  neurological and psychological development caused by RFR exposure (Belyaev et al., 2016).


Why are the health risks of exposure to RFR significant?


As with any environmental toxin, the risks related to RFR exposures increase with the frequency and duration  of such exposures over time, even at low levels of exposure: put simply, it is the extent of the exposure to all  sources of RFR that poses the greatest risk to individuals and society (Barnes and Greenebaum, 2020). Unlike  other toxins and carcinogens, RFR is truly ubiquitous: it radiates from multiple personal and WiFi devices,  routers, access points—these radiate 3-5G telecommunications and data signals, 2.4 and 5G Wifi signals and
Bluetooth RFR—in the home, public spaces, hospitals, cars, in schools, and a web of antennae across the built  environment. Thus, exposure to this carcinogen and toxin is of high frequency and long, if not continuous,
duration. This continuous exposure maximizes the risk of persistent and continuous oxidative stress and,  consequently, makes humans vulnerable to ALL the health risks listed earlier. Children are particularly at risk.
Hence, scientists and medical practitioners globally believe that ubiquitous 5G sources present high levels of  risk to human health and well-being (5G Appeal, 2019). Just how significant are the health risks? What follows  is a precis of the major health risks.


On the Elevated Risk of Cancers from RFR


A recent study by US economists demonstrates “that mobile phone subscription rates are positively and  statistically significantly associated with death rates from brain cancer 15-20 years later” (Mialon, and Nesson,  2019). This 25-year cross country analysis provides solid evidence of the link between mobile phone use and  cancer of the central nervous system (CNS) when positioned alongside epidemiological studies. Brain tumours  and other cancers of the CNS have long been linked with RFR exposure: The challenge for scientists is to prove  the link. This, unfortunately, is not an easy thing to do: However, recent research provided “clear evidence” of  this relationship.
On November 1 st 2018, the final report of a 10-year $30m comprehensive study by US National Institute of  Environmental Health Sciences’ National Toxicology Program (NTP) confirmed that radiofrequency radiation  from 2G and 3G cell phones caused cancer in animals exposed in the near field (National Toxicology
Programme 2018a). That study refutes the long-held theory that non-ionizing radiation, such as RFR, cannot  cause DNA damage and related cancers or lead to other effects on the health and well-being of the animals  studied, and human beings by extrapolation (National Toxicology Programme, 2018b). In their peer-reviewed  publication on the NTP study in 2020, 11 distinguished scientists concluded “that exposure to RFR is associated  with an increase in DNA damage” (Smith-Roe., et al. 2020, p. 220).
In a separate ground-breaking study at the world-renowned Ramazzini Institute study involving 17 world-class  scientists, Falcioni et al. (2018, p. 496) found that “far field exposure to RFR [that] are consistent with and
reinforce the results of the NTP study on near field exposure, as both reported an increase in the incidence of  tumors of the brain and heart in RFR-exposed Sprague-Dawley rats. These tumors are of the same histotype of  those observed in some epidemiological studies on cell phone users. These experimental studies provide  sufficient evidence to call for the re-evaluation of IARC conclusions regarding the carcinogenic potential of  RFR in humans.” Again to emphasize, this study is notable as it focused on the health implications of far-field  RFR sources on humans living or working in the proximity of mobile phone base stations, as opposed to  operating 2 & 3 G handsets near field. Peleg, Nativ and Richter (2018) prove that occupational exposure to  RFR, at levels well-below ICNIRP guidelines, increased the risk and incidence of hematolymphatic (HL)  cancers in military and occupational settings. They prove that RFR exposure was associated with, and  significantly increased, HL cancer risk in the four groups studied across three countries: the findings  demonstrated a cause-effect relationship between RFR and cancer (ibid).  In his critical review of both the above studies, former ICNIRP commissioner James Lin (2019, p. 19) concluded  that: “The time is right for the IARC to upgrade its previous epidemiology based classification of RF exposure  to higher levels in terms of the carcinogenicity of RF radiation for humans.” This is clear and unambiguous as  the findings of both the NTP and Ramazzini Institute studies that provided “clear evidence,” the highest burden
of scientific proof possible concerning the carcinogenicity of RFR (Melnick, 2019).

After more than 25 years of widespread cell phone use, one would expect to see a rise in cancers, particularly brain tumours. The evidence here is mounting: Take for example new studies in the US note a disturbing rise
in cancers of the Central Nervous System, particularly in adolescents. There is also a marked increase in other  cancers. Nevertheless, while recent research has provided “clear evidence” of a link between RFR and cancers  in laboratory animals, epidemiological studies have yet to provide conclusive evidence of an increase in the
incidence, prevalence, and mortality rates in humans of cancers directly linked with RFR from 2-4G and  wireless devices. There are several reasons for this. One of the chief explanations is the fact that it typically
takes between 20 or 30 years for many types of cancers to develop following exposure to a carcinogen, and for  epidemiological data to reflect this and to enable risk assessment viz. well-designed studies “require  populations that are followed for at least 20 years, preferably 30 or more” (Michaels, 2008). That has not been  the case with extant or industry-sponsored studies (cf. Belpomme et al., 2018): Thus, the findings and  conclusions drawn from “observations [of such studies] may be premature, as cell phone use has become  commonplace only within the past two decades, a period of time that may be insufficient to accurately assess  cancer-related outcomes” (Smith-Roe, 2020).
There are other problems with extant studies which the telecoms industry and ICNIRP claim show little or no  risk: “Generally speaking, a poorly conducted study is more likely to result in a false negative (that is it fails to  find a risk that is actually present) than in a false positive (mistakenly identifying and excess risk when none in  fact exists). For the results of a negative study to be taken seriously, the study must be large and sensitive and  gather accurate exposure data” (Michaels, 2008). It is clear from the research literature that poorly conducted,  biased or manipulated studies are more likely to produce false negatives and show no effect, than robust rigorous  studies which tend to show positive links between environmental toxins and health risks and demonstrate the
existence of effects. Thus, Miller et al. (2018) argue that epidemiological studies that result in false negatives  may have significant flaws, indicating the need for additional “epidemiological studies of brain cancer to be  carried out [that] should include validated measures of exposure and/or biomarkers of possible impact of RFR  on biological processes.” Nonetheless, a recent review of 24 epidemiological case-controlled studies illustrated  an increased risk of gliomas and other brain tumours with long-term exposure to RFR from mobile phones  (Bortkiewicz, Gadzicka, and Szymczak, 2017).

Michaels (2008) illustrates that if epidemiological studies of general populations are not possible where  carcinogens or toxins are concerned, then the approach scientists and regulators take is to study sub-populations  in an industry: “Much of what we know about the toxic effects of common environmental exposures, especially
airborne exposures, comes from the study of workers.” The study by Peleg, Nativ and Richter (2018) provides
“clear evidence” of industrial exposure to RFR, within ICNIRP guidelines, and the incidence of  hematolymphatic (HL) cancers in military and occupational settings. This study concludes that: “The consistent
association of RFR and highly elevated HL cancer risk in the four groups spread over three countries, operating  different RFR equipment types and analyzed by different research protocols, suggests a cause-effect relationship  between RFR and HL cancers in military/occupational settings” (Peleg, Nativ and Richter, 2018). They add  that: “Overall, the epidemiological studies on excess risk for HL and other cancers together with brain tumors  in cellphone users and experimental studies on RFR and carcinogenicity make a coherent case for a cause-effect relationship and classifying RFR exposure as a human carcinogen (IARC group 1).” In order to provide  support for the thesis that RFR poses a real and present danger to human health, a short review of recent 
epidemiological evidence is instructive and heightens the need for a precautionary approach by policymakers  to protect public health (Miller et al., 2018).


CNS Cancers


In 2019, The Lancet Neurology observed that “CNS cancer is responsible for substantial morbidity and  mortality worldwide, and the incidence increased between 1990 and 2016” (Patel et al., 2019). This is just one
of several recent epidemiological studies that note such increases (see Ostrom et al., 2016: Khanna et al., 2017;  Withrow et al., 2018, for others). In the UK context, Philips et al. (2018) studied the incidence of glioblastoma  multiforme brain tumours in England during 1995–2015 and found “a sustained and highly statistically  significant ASR [(incidence rate)] rise in glioblastoma multiforme (GBM) across all ages. The ASR for GBMmore than doubled from 2.4 to 5.0, with annual case numbers rising from 983 to 2531. Overall, this rise is  mostly hidden in the overall data by a reduced incidence of lower-grade tumours.” In the UK in 1995, 553
frontal lobe tumours were diagnosed in patients, while 1231 were found in 2015. Likewise, 334 temporal lobe  tumours were reported in 1995, while 994 were diagnosed in 2015. The increase in these cancers of the CNS is
clear and unambiguous. The authors of this study argue that: “The rise cannot be fully accounted for by  promotion of lower–grade tumours, random chance or improvement in diagnostic techniques as it affects
specific areas of the brain and only one type of brain tumour. Despite the large variation in case numbers by  age, the percentage rise is similar across the age groups, which suggests widespread environmental or lifestyle  factors may be responsible.” Scientists have concluded there is strong evidence that RFR is the environmental  factor responsible. Indeed, the Turin Court of Appeal came to the same conclusion in 2019.


Colorectal Cancer


We have all witnessed how adolescents and young adults predominantly carry their smartphones in trouser  pockets. If the theory that RFR causes cancer is correct then we should see an uptick in local cancers in that
region of the body as the radio units in smartphones are active, even in standby. In 2019, the journal Cancer  described a rising incidence of colorectal cancer among young Americans, with rectal cancers being slightly  higher than colon cancers (Virostko et al., 2019). Another contemporary study found significant increases in  colorectal cancer among people under 50 in Denmark, New Zealand, and the UK since 2009 (Araghi et al.,  2019). Yet another study of colorectal cancer in young adults in 20 European countries over the last 25 years  found that over the last 10 years, the incidence of colorectal cancer increased 8% per year among people in their  20s, by 5% for people in their 30s, and by 1.6% for those in their 40s (Vuik et al., 2019). Dr. De-Kun Li (2, comment in what follow see next)  maintains that “When placed in trouser pockets, the phones are in the vicinity of the rectum and the distal colon
and these are the sites of the largest increases in cancer.” He concludes that there is a link between how people  carry, as well as use, their phones, and the rising incidences of various cancers and other health risks. Take for  example that researchers found that RFR from cell phones may be triggering breast cancer in young women  who carry their devices on or near their breasts (West et al., 2013)

(2)  De-Kun Li, MD, PhD, MPH, is a Senior Research Scientist at the Division of Research, Kaiser Permanente Northern
California. https://microwavenews.com/news-center/de-kun-li-crc


Skin Cancers


5G systems present a perfect storm where the above health risks are concerned. Not only will they expose adults  and children to near- and far-field 3-5G RFR signals, but 5G technologies also expose them with low frequency,  high frequency and extremely high frequency RFR simultaneously. The aforementioned health risks are linked
with low frequency 5G RFR which penetrates deep into the body, high frequency, which penetrates sufficiently  deep to be of significant concern, permeating as it does the brain, and extremely high frequency, which chiefly  affects the skin and eyes. Scientists at the ICNIRP have questionable competencies to deal with this from a
biomedical perspective, as they dismiss any significant thermal or non-thermal risks in light of the cumulative  body of evidence.
Extremely high-frequency RFR penetrates and is absorbed into the skin, i.e. epidermis, dermis, and  subcutaneous fat, and also into the eyes (Feldman et al., 2009). Research on the biological effects of extremely
high-frequency RFR is mature (Zalyubovskaya, 1977): There are, therefore, significant concerns on the  biological effects of this type of RFR in relation to their use in 5G (Di Ciaula, 2018). In medical and scientific  terms the skin does not form a barrier to extremely high-frequency RFR, it is permeable, it is a biological organ  that protects the body, but is itself prone to infections and environmental influence. It contains capillaries and  nerve endings and is both an input and output from the CNS (Duck, 1990)—it is in medical terms a vital organ.
Significantly, therefore, researchers point out that “More than 90% of the transmitted power [of extremely high  frequency RFR] is absorbed by the skin” (Zhadobov et al., 2011). This is significant, as this energy is not  harmlessly dissipated, as the ICNIRP hold: with regular exposure, studies have demonstrated that skin cells go  into oxidative stress with significant health implications and risks (Neufeld and Kuster, 2018).

Furthermore, it is important to note also that “the cumulative body of research and scientific evidence  demonstrates beyond a reasonable doubt that [extremely high-frequency RFR] not only penetrate the skin of
humans but present a heightened risk of ill-effects on all biological systems including cells, bacteria, yeast,  animals and humans” (Zhadobov et al., 2011). This evidence refutes the ICNIRP assertion that 5G RFR
produces thermal effects only. An example of the implications of ubiquitous extremely high-frequency RFR  will illustrate. Research on ultraviolet radiation indicates that UVB is ionizing radiation and directly damages  DNA, which may lead to melanoma. UVA, on the other hand, is non-ionizing. Both are on the electromagnetic  spectrum along with non-ionizing RFR. UVA, which accounts for 95% of incident UV radiation, causes  oxidative DNA damage through how it creates reactive oxygen species (ROS) (Brem et al., 2017). “DNA  damage caused by UVA-induced ROS is a potential contributor to sun-induced mutation and cancer”
(McAdam, Brem, and Karran, 2016, p. 612). Scientists acknowledge that “the growing incidence of melanoma  is a serious public health issue…[and] UVA-associated DNA damage responses may contribute to melanoma  development” (Khan, Travers, and Kemp, 2018). Any exogenous agent that increases ROS can either directly  or indirectly cause skin cancers such as melanoma. Research has demonstrated unequivocally that RFR  increases ROS and decreases vital anti-oxidants. Thus, it is axiomatic that extremely high-frequency RFR poses  a significant threat to human health as people are increasingly vulnerable to skin cancers—both melanoma and  non-melanoma.

On the risks to pregnant women and their offspring

A prospective cohort study of 913 pregnant women conducted by Dr. De-Kun Li and his team at US healthcare  provider Kaiser Permanente examined the association between exposure to non-ionizing radiation from low-frequency EMF sources and the risk of miscarriage (Li et al., 2017).

After controlling for multiple other factors,  women who were exposed to higher levels had 2.72 times the risk of miscarriage (hazard ratio = 2.72, 95% CI:  1.42–5.19) than those with lower exposures. The increased risk of miscarriage was consistently observed  regardless of the EMF sources (Li et al., 2017). However, follow-up studies on children born to mothers with  the same high levels of exposure found that in-utero exposure was related to increased risk in children of the
following conditions:

Asthma 2.7 times;
Obesity 5 times;
ADHD 2.9 times. (Li et al. 2011, 2012)

Li et al. (2017) link the results from this study with contemporary epidemiological research on the links between  far-field exposure to RFR from mobile phone antennae and miscarriage (Zhou et al. 2017) and near-field  exposure linked with mobile phone use during pregnancy (Mahmoudabadi et al., 2017).

Research conducted at Professor Hugh Taylor’s research laboratory at Yale comments on the significant  increase in the incidence of ADHD in children. Taylor and his team posit that one or more environmental factors
are involved. The paper showed that prenatal in-utero exposure of pregnant mice to real cell phone RFR  produced three highly statistically significant changes observed in mice exposed in-utero. These are: (1) a
decrease in memory function; (2) hyperactivity; and (3) an increase in anxiety. The researchers conclude “that  these behavioral changes were due to altered neuronal developmental programming” (Aldad et al., 2012).
These results have been replicated in several subsequent experimental studies on rodents (Othman et al.,  2017a,b; Kumari et al., 2017). However, there are also several epidemiological studies that identify similar  outcomes in children (Divan et al., 2008, 2012). More recently, Birks et al. (2017) used data from studies in five
different countries involving 83,884 children which concluded that mobile phone use by mothers during  pregnancy increased the risk of hyperactivity and attention issues with children.

This body of research provides evidence for an association between prenatal exposure to cell phone RFR and  neurological development as well as the risk of spontaneous abortion. This should stimulate a reassessment of  the risks concerning all EMF and RFR exposure, particularly to children and pregnant women, as “[t]he level
of proof required to justify action for health protection should be less than that required to constitute causality   as a scientific principle” (Frentzel-Beyme, 1994). We are far beyond that level of proof where RFR is

Neurological and Neurodegenerative Risks from RFR


The research cited above indicates a significant risk to the neurological development of children in utero from  RFR. There are numerous studies on the abnormal behaviour and learning of mice and rats exposed to RFR. A  recent research review investigated the mechanisms by which RFR causes neurophysiological and behavioral  dysfunctions (Sharma et al., 2017). The review indicated that impaired cognitive and memory functions. The  impact and severity of effects identified are linked to the duration of exposure, and level of exposure. Other  recent research includes a study by Deshmukh et al. (2015), who examined the effects of chronic, low-level  RFR exposure on learning capacity and memory. The researchers observed that spatial orientation, as well as  learning and memory, were impaired. In another recent study, Hassanshahi et al. (2017) divided 80 male rats  into control and experimental groups and exposed them to Wifi signals 12 hours a day: the researchers observed
that the experimental rats displayed impaired cognitive performance.
Dr. Henry Lai (2018) reviewed summarized research from 2007-2017 on the neurobiological effects of RFR.

Lai reports deficits in short-term memory in human subjects exposed to RFR, with one study reporting  significant changes in cognitive functions in adolescents that impoverished the accuracy of their working
memory. While these studies focused on the effects near-field RFR, a study by Meo et al. (2019) reported that  high-level far-field RFR negatively affected the fine and gross motor skills, spatial working memory, and  attention in school-going adolescents, as opposed to those exposed to very weak levels of RFR. Thus, near-field and far-field RFR poses significant risks to children’s neurobiological health (Markov, 2018; Elhence,  Chamola, and Guizani, 2020). This is underpinned by a significant cumulative body of research in Russia, with  one longitudinal study from 2006 to 2017 indicating the risks that RFR sources present to children (Grigoriev  and Khorseva, 2018). These researchers find that chronic exposure to RFR may negatively affect the central  nervous systems of the children.

Electrohypersensitivity (EHS) is a medically recognised condition that affects people who have developed an  intolerance to EMFs. EHS describes a clinical condition suggested by experts for the European Commission  (Bergqvist et al., 1997). The relationship of EHS with RFR was identified in Sweden with research indicating  a relatively high incidence among those living near mobile phone base stations (Santini et al., 2003). The global  increase in people reporting EHS, prompted the WHO to organise an international workshop in Prague. The  Prague working group report clearly defined EHS as “a phenomenon where individuals experience adverse  health effects while using or being in the vicinity of devices emanating electric, magnetic or electromagnetic
fields” (Belpomme et al. 2018): subsequently, the WHO acknowledged EHS as an adverse health condition  (WHO, 2005). Research reveals that it remains on the increase, with occurrences having a strong link with
oxidative stress: Take for example that in one study “80% of EHS patients presented with an increase in  oxidative/nitrosative stress-related biomarkers” (Belpomme and Irigaray, 2020, p. 1): they (ibid., p. 6) indicate  that “in addition to low-grade inflammation and an anti-white matter autoimmune response, EHS can also be  diagnosed by the presence of oxidative/nitrosative stress.” This finding indicates that EHS is a very real  phenomenon that has significant public health consequences as RFR becomes ubiquitous and physicians  recognise “that EHS is a neurologic pathological disorder which can be diagnosed, treated, and prevented.  Because EHS is becoming a new insidious worldwide plague involving millions of people” (ibid., p. 1).

The most troubling neurodegenerative condition facing modern society is Alzheimer’s Disease. Stefi et al.  (2019) find evidence that RFR promotes molecular pathogenic mechanisms associated with Alzheimer’s
Disease. A possible link between electromagnetic fields and the occurrence of Alzheimer’s Disease has long  been noted (Sobel et al., 1995). However, there is a concern as to the increasing incidence of and deaths from  this neurodegenerative disease (Vieira et al. 2013), particularly the increasing trend since the 1990s (Niu et al.,2017).

Figure 1 illustrates the trend in mortality from the disease comparing males and females. Note the growth  in the incidence of mortality in the UK which far outstrips age at which the population is aging. Given the
growth in RFR sources across society, researchers are concerned that it may be one of the environmental factors  responsible for the dramatic increase in the incidence, aging population aside (Hallberg and Johansson, 2005;  Hallberg, 2015). Hallberg and Johansson (2005) investigate the correlation between the increase in RFR from  mobile cellular networks in Sweden and the dramatic increase in the incidence in Alzheimer’s Disease and find  a direct correlation. We can see from Figure 1 that Sweden, one of the first economies to adopt mobile telephony,  has a significant increase in mortality rates that is in lockstep with the growth of RFR sources. The question  facing epidemiologists is what are the causal mechanisms that have RFR exposure increase the risk of  Alzheimer’s Disease? One common cause of neurodegenerative diseases is oxidative stress in CNS cells  (Paloczi et al. 2018), and this condition is strongly linked with Alzheimer’s Disease (Butterfield, Howard, and  LaFontain, 2001; Tönnies and Trushina, 2017).

The CNS appears to be the most vulnerable human biological system, with neurodegenerative diseases,  neurobehavioral (including problems with learning and development in children), and immunological problems
the source of greatest concern to scientists (see Barnes and Greenebaum, 2020; Belpomme et al. 2018; Belyaev  et al. 2016; Di Ciaula, 2018; Miller et al., 2018; Russell, 2018, among many others). There is a unanimous
agreement that the property of RFR to place human cells into oxidative stress lies at the core of almost all health  risks (Yakymenko et al., 2016). The generation of reactive oxygen species (ROS) contributes greatly to this.

Because health and other government agencies look to the ICNIRP, 3 and because it ignores the majority of  scientific evidence demonstrating harmful non-thermal exposures, citizens and their children are exposed to
RFR that generates high levels of oxidative stress in their bodies, and which neutralizes the body’s antioxidant  defence system (Kıvrak et al., 2017). Recent studies of people living in proximity to mobile base stations found  evidence for elevated levels of ROS in their blood, which is a biochemical indicator of oxidative stress,  indicating that they are exposed to greater risks of ill-health (Zothansiama et al., 2017). Scientists and medical  practitioners are concerned about the significant risks all this places on the most vulnerable in society, such as
children, pregnant women, those with existing health issues, and senior citizens.

(3)   https://www.gov.uk/government/publications/mobile-phone-base-stations-radio-waves-and-health/mobile-phone-base-stations-radio-

Figure 1 Trends in mortality from Alzheimer’s disease in the European Union, 1994–2013.

Why have not governments and their agencies acted to protect public health?


This section uses the case of the United Kingdom (UK) of Great Britain and Ireland to help answer this question.
UK policymakers look to Public Health England (PHE) to assess the safety of non-ionising RFR. The PHE’s  position on this draws heavily upon two reports by the Advisory Group on Non-ionising Radiation (AGNIR).
These were published in 2012 and 2017. The Department of Health’s Committee on Medical Aspects of  Radiation in the Environment (COMARE) also looks to the AGNIR reports for guidance. It is therefore  incredible that when it issued its last report, ICNIRP members, from the NGO based in Munich, constituted  30% of the 18 member UK committee. Note that AGNIR’s primary role was to assess the ICNIRP’s safety  guidelines, which reflect industry interests not those of public health. In no other regulated sector or area of  business activity would this be acceptable from a conflict of interest or corporate governance perspective.

ICNIRP scientists were not going to judge their own guidelines unsafe. Thus, they had a significant conflict of  interest which compromised the entire decision-making process on UK policy towards RFR and public health,  specifically, the introduction of 5G.

The ICNIRP’s 2020 guidelines published in March of this year, update those published in 1998. The new  guidelines include only minor changes to the 1998 guidelines, primarily to accommodate 5G’s extremely high-
frequency millimeter RFR signals (Barnes and Greenebaum, 2020). It must be remembered the guidelines focus  on technical issues and present safety recommendations for the thermal effects of non-ionizing RFR at high-levels of exposure over the short-term measured in minutes. They effectively ignore or deny the existence of  non-thermal effects on adults and children and long-term exposure to RFR at low levels. The ICNIRP 2020  Guidelines ignore or dismiss on scientifically spurious grounds the significant body of scientific research since  1998. The majority of independent scientists consider the ICNIRP and the related EU SCENIHR as ‘captured’  organisations—that is they are heavily influenced by industry-funded researchers and industry itself.

Scientists from the ICNIRP, who are also, as indicated, members of SCENHIR and WHO, are accused of  conflicts of interest due to their close ties with industry (Buchner and Rivasi, 2020). An Italian court judgment
recently recognised this. In December 2019, Turin Court of Appeal president Dr. Rita Mancuso ruled that  research reviews carried out by ICNIRP and its members were biased and could not be trusted in determining  whether there was a causal link between wireless cell phone use and brain cancer  (see comment 4). The court decided that there
was such a link, and its judgment was based on extant independent scientific studies, such as those cited herein.

(4)  https://www.radiationresearch.org/wp-content/uploads/2020/01/Turin-Verdict-ICNIRP_Judgment-SUMMARY-of-the-Turin-Court-
of-Appeal-9042019_EN-min.pdf Original Italian https://www.diritto24.ilsole24ore.com/_Allegati/Free/Ca_torino_vers_1.pdf

In a 98 page detailed report on the ICNIRP and its activities, Members of the European Parliament, Michèle  Rivasi and Dr. Klaus Buchner find that “[t]he composition of ICNIRP is very one sided. With only one medically
qualified person (but not an expert in wireless radiation) out of a total of 14 scientists in the ICNIRP  Commission and also a small minority of members with medical qualifications in the Scientific Expert Group,
we can safely say that ICNIRP has been, and is still, dominated by physical scientists. This may not be the wisest  composition when your remit is to offer advice on human health and safety to governments around the world.”

However, they demonstrate that this makes it easier to ignore or dismiss research from medical and related  disciplines. Buchner and Rivasi (2020) observe that ““a closed circle of like-minded scientists” has turned
ICNIRP into a self-indulgent science club, with a lack of bio-medical expertise, as well as a lack of scientific  expertise in specific risk assessments. Thereby, creating a situation which might easily lead to “tunnel-vision” in the organisation’s scope. Two leading experts, Hans Kromhout and Chris Portier, confirmed to  us that ICNIRP is a closed, non-accountable and one-sided organisation.” They (ibid.) report that “In
addition to the fact that certain members of ICNIRP, are simultaneously members of the International  Committee on Electromagnetic Safety (ICES) of the US-registered Institute of Electrical and Electronics
Engineers (IEEE), we have seen further evidence of a close cooperation between ICNIRP and ICES, an  organisation in which many people from the media and telecom industries, as well as from the military,
are actively and structurally involved. During the current leadership of ICNIRP, these ties have become  even closer “with the goal of setting internationally harmonized safety limits for exposure to
electromagnetic fields”. This must surely be considered as a situation in which conflicts of interest are a  real possibility. It is clear from ICES minutes that ICNIRP worked very closely with IEEE/ICES on the
creation of the new RF safety guidelines that were published in March 2020. And this implies that large  telecom-companies such as Motorola and others, as well as US military, had a direct influence on the
ICNIRP guidelines, which are still the basis for EU-policies in this domain.”

This study provides detailed  evidence of a range of conflicts of interests of ICNIRP members, including its current chair.

So successful is the ICNIRP in influencing the EU and governments globally, including the US federal agencies  such as the FCC and FDA, that industry lobbying in this area is now practically non-existent, although that was  not always the case (Buchner and Rivasi, 2020) viz. the “European Telecommunications Networks Operators’  Association (ETNO) does not lobby for lowering the ICNIRP standards, as these are not seen as part of the  “regulatory pressure” that hampers technological development. On the contrary: the norms ICNIRP proposes  are the “harmonised limits” that ETNO welcomes. All in all, the telecom-sector seems to be quite pleased with  ICNIRP’s positioning. This deviates from the standard procedure in EU-policy making, where a specific  industry concerned will, on essential aspects, always try to influence laws and regulations in its favour through  various lobbying strategies. Apparently, in the case of ICNIRP, there is simply no need to do so. At the same
time, the insurance sector does not, at present, seem very reassured and does not want to be put in a situation  of having to pay potential litigation costs, if and when telecom companies get sued, something that is happening  more and more often.” The same applies to the US, where the industry has captured the FCC (Alster, 2015). 

How does Industry influence UK Policy and Public Opinion?


Industry sectors responsible for harming the environment and human health adopt well-articulated  pseudoscientific strategies to undermine independent rigorous research aimed at uncovering scientific truth
(McGarity and Wagner, 2008). Michaels (2008) illustrates graphically how the tobacco industry hired scientists  and commissioned papers to cast doubt on epidemiological and laboratory evidence on the risks to human health  of smoking. Michaels shows how that industry sows doubt about science and medical fact “since it is the best  means of competing with the 'body of fact' that exists in the minds of the general public.” This approach has  been adopted across industry sectors, including the telecommunications industry and its approach to neutralising
concerns about the health risks of RFR. Thus, through lobbyists, law firms, consulting scientists, targeted  scientific research funding and the co-optation of pseudo-independent organisations such as the ICNIRP, the
health risks of RFR have been disputed and scientific findings undermined using what Michaels terms “junk  science”. This involved the perverse and biased application of epidemiological approaches and statistical
methods to reinterpret valid scientific data in order to arrive at conclusions that support the industry view of no  harm or effect (Oreskes and Conway, 2011). In the current context, that view of no harm held by industry and  the ICNIRP posits that easily controlled thermal effects matter and that non-thermal effects do not exist  (Buchner and Rivasi, 2020).

The ICNIRP in concert with industry-sponsored scientists in physics, toxicology, epidemiology, and risk  assessment systematically discredit research suggesting that exposure to RFR causes health risks. This is easily  achieved as Michaels argues that epidemiology is “a sitting duck for uncertainty campaigns” (see also Oreskes  and Conway, 2011). In considering RFR health risks, exposures must be estimated and risks to humans  extrapolated from animal studies in vivo or cellular studies in vitro. Persistent exposure to RFR may cause  diseases such as brain cancer or neurodegenerative conditions, but these diseases could also be triggered by  other environmental or genetic vectors. As with those from the tobacco, petrochemical, and drug industries, the  ICNIRP and industry scientists can easily, but unjustly, cast doubt on the assumptions, methods, and findings  of independent public health-minded scientists.
The telecom’s industry strategy for countering public health concerns is proving more successful than its  predecessors as indicated by the findings of research from Harvard Law School. In Captured Agency, Harvard  Research Fellow Norm Alster (2015) illustrates how the telecommunications industry captured the Federal  Communications Commission—the US regulator. Research adduced here indicates the same may apply where     it comes to the ICNIRP and its influence over the WHO and the UK’s AGNIR and PHE (Starkey, 2016; Pockett,    2019).

Implications for Policymaking

Independent peer-reviewed research continues to identify significant research deficiencies, comissions,  inaccuracies, and distortions in ICNIRP research reviews and guidelines: they also question SCENIHR reports,
due to the significant participation of ICNIRP commissioners (Starkey, 2016; Belpomme et al. 2018).

It is also  significant that five of the six core group members responsible for drafting the WHO’s Monograph on RF fields  were directly affiliated with the ICNIRP NGO (Hardell, 2017). Similarly, the chapter on RFR in the WHO’s  World Cancer Report 2020 was chiefly authored by ICNIRP member Professor Martin Röösli (see Laurier and  Röösli, 2020). Research has demonstrated that the WHO is deficient in managing conflicts of interest (Wang et  al., 2019). This is compounded by what many consider the blatant disregard of the ICNIRP for basic ethical  principles and its management of conflicts of interest: Take for example that Pockett (2019, p. 4) finds the  “ICNIRP is a self-selected, private (non-governmental) organization, populated exclusively by members invited  by existing members. The organization is very concerned to project the image that it is composed of disinterested  scientists—indeed all ICNIRP members are required to post on the organization’s website detailed declarations
of interest (DOIs). However, a closer inspection of these DOIs reveals that a good many of the sections of a  good many of the forms remain unfilled, and a detailed list of undeclared conflicts of interest among ICNIRP
members has been published by a group of concerned citizens. The relevant section of WHO is essentially  identical to ICNIRP… in spite of their stated rules and protestations to the contrary, there have been persistent  allegations that both ICNIRP and the relevant section of WHO are riddled with undeclared conflicts of interest.”

These points echo Starkey’s (2016) separate critical analysis of conflicts of interest involving the WHO,  ICNIRP, and AGNIR.

Former ICNIRP members now recognise that RFR is a significant risk to human health (see Lin, 2019). Because  of the over-reliance on what many scientists consider deeply flawed and biased ICNIRP guidelines, PHE and
UK policymakers possess a fundamental ignorance of the large body of extant research on the significant non-thermal health effects of RFR (cf. Starkey, 2016). There is an increasing body of evidence in peer-reviewed
academic research that confirms governments and policy-makers (1) may be misled by the ICNIRP (Pockett,  2019; Buchner and Rivasi, 2020); (2) are succumbing to pressures from industry and lobbyists (Michaels, 2008);
or (3) are turning a blind eye to scientific and public concerns for economic reasons (Alster, 2015; Buchner and  Rivasi, 2020)—which in the UK case relate its to digital transformation strategy, lucrative industry licenses,  and significant tax revenues.

Generalising from this case, it is clear that across the European Union, the US and, indeed all democracies, the  decision-making process on the introduction of 5G and its implications for public health are flawed and open to  question by the judiciary.

Yours Sincerely,
Professor Tom Butler
University College Cork
e: tbutler@ucc.ie
m: 0879865629



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 1 Radiofrequency radiation (RFR) is a type of non-ionizing radiation (NIR), which is also referred to as radiofrequency
(RF) electromagnetic fields (EMFs). RF EMFs are in the frequency range 100 KHz to 300 GHz, this includes all 2-5G,
WiFi and Bluetooth technologies. In the UK, 5G technologies will emit RFR (RF EMF) in the frequency 700 MHz-28GHz.
According to the latest ICNIRP Guidelines (2020, p. 3): “Radiofrequency EMFs [i.e. RFR] consist of oscillating electric
and magnetic fields; the number of oscillations per second is referred to as “frequency,” and is described in units of hertz
(Hz). As the field propagates away from a source, it transfers power from its source, described in units of watt (W), which
is equivalent to joule (J, a measure of energy) per unit of time (t). When the field impacts upon material, it interacts with
the atoms and molecules in that material. When a biological body is exposed to radiofrequency EMFs, some of the power
is reflected away from the body, and some is absorbed by it. This results in complex patterns of electromagnetic fields
inside the body that are heavily dependent on the EMF characteristics as well as the physical properties and dimensions
of the body. The main component of the radiofrequency EMF that affects the body is the electric field. Electric fields inside
the body are referred to as induced electric fields (Eind, measured in volt per meter; V m−1), and they can affect the body
in different ways that are potentially relevant to health.” In keeping with relevant research papers, this report employs the
term RFR, as opposed to RF EMF or simply EMF.