I was asked to write an intro to my wireless submission for the folks over at Stop Smart Meters Australia. You can read it on their site for a précis of my current thoughts on why parents (unfortunately) need to assume responsibility for decision making, including a look at the convoluted trail of responsibility that apparently leads back to us as consumers (even early iPhone manuals admitted that carrying an iPhone in the pocket may result in guidelines being exceeded).

A couple of emails from people involved with some community concern sites (Parents Against Wifi in Schools and Stop Smart Meters Australia) have reminded me that I’ve dropped the ball on this a bit, so, an update.

After I met with Andrew Wilkie to discuss my concerns, he wrote (in December 2012) to Stephen Conroy enquiring about the state of play given the World Health Organisation’s classification of Radio Frequency radiation as a possible human carcinogen.

It was many months before I received a copy of the reply (May 2013). You can view the reply here.

In summary, it’s more of the same: ‘we are within the standard’, and that’s no longer surprising to me. But I take issue with some of the diction in Senator Conroy’s reply.

Senator Conroy states “the IARC’s decision was based on limited evidence of increased health risks amongst heavy users or wireless phone handsets. It should be noted that this evidence only related to the use of wireless handsets. The IARC found there was inadequate evidence to draw conclusions about other sources of exposure to radiofrequency EME, including from wireless base stations.”

While this is strictly true, it is, on my reading of the IARC Monograph, far from a balanced representation of all the facts. Compare Senator Conroy’s comments with those from the IARC regarding their own assessment:

“…it should be emphasized that the evaluations in this volume address the general question of whether RF radiation causes cancer in humans or in experimental animals: it does not specifically or exclusively consider mobile phones.” Following on from this, I would also note that the IARC classification for “possible human carcinogen” in question, is of RF radiation as a whole (a very broad range, which includes mobiles, bluetooth, wifi, radio, TV…) and not that only radiation in the specific frequencies of mobile phones are possibly carcinogenic. My point here is that yes, the evidence that really pushed RF radiation over the line was regarding mobile phones, but if IARC thought that this means that only mobile phones are a possible risk, why class all RF radiation as a possible human carcinogen?

And further, while Senator Conroy comments that “the ARPANSA exposure limits are set well below the level at which adverse health effects are known to occur”, the IARC report states, “Although it has been argued that RF radiation cannot induce physiological effects at exposure intensities that do not cause an increase in tissue temperature, it is likely that not all mechanisms of interaction between weak RF-EMF (with the various signal modulations used in wireless communications) and biological structures have been discovered or fully characterized.” So, again, Senator Conroy is right, in that the limits are set below the level adverse health effects are known to occur (if we regard “known” health effects as equating to the level at which laboratory animals are disturbed enough to no longer want to earn food), but IARC has made an important concession to the possibility (or, in their terms, a probability, since they used the word “likely”) that interactions could be going on well below those levels. In short, Senator Conroy is promoting the “it’s all okay” version, while IARC has actually said, despite not being convinced by any of the current science on offer that RF radiation definitely is a carcinogen, “it may well not all be okay, we don’t know, and we think it’s a possible human carcinogen”.

To my mind, the fact that RF radiation has received this assessment from the WHO, some 120 years after its introduction into the human-made sphere, tells us just how little we really know, and how long it will take for us to have any real idea what the current incarnation of these technologies may be doing to us.

In this post I’ll attempt to do what I probably should have done to start with – make a brief précis of why I think parents should be concerned about the astronomical uptake of wireless technologies in education.

Concerns about the standard itself

The baseline

The standard against which wireless devices are currently tested is based on science that determines:

• the point at which the radiation level is such that it causes body tissues to be heated by one degree celcius after half an hour’s exposure.¹
• the point at which the radiation level is such that it disrupts food-motivated learned behaviour in laboratory animals² (that is, the point at which lab animals no longer do the tasks that they have learned will earn them food – the level at which gross behavioural changes are noted, not changes in biochemistry or DNA expression or any other such ‘subtle but sinister’ changes that might occur.)

These effects that the standard is concerned with are referred to as “thermal” effects – the effects purely due to heating. There is no scientific consideration within the standard of what are referred to variously as “non-thermal”, “sub-thermal”, “athermal”, or “biological” effects – that is, any ill-effects caused by the radiation interacting with tissues in ways other than heating. The standards body considers that such non-thermal effects cannot be ruled out, but that there is no scientific consensus or convincing evidence for such effects.

Do biological, non-thermal effects exist?

A brief search in the literature shows that yes, there is certainly evidence to suggest that adverse biological effects are created by non-thermal levels of radiation across a broad spectrum of frequencies – frequencies in which non-thermal effects are not ‘supposed’ to occur, according the standards body. There are certainly scientists who are in no doubt about it. For just one example, consider the study entitled “2.45 GHz radiofrequency fields alter gene expression in cultured human cells”. This study showed that radiation at the frequency of Bluetooth, and very similar to typical wireless, alters one of the most fundamental ‘building’ mechanisms in all life: “data from our study indicate that RF [Radio Frequency] indeed has biological effects”, and that “the altered gene expression in the RF exposed cells was due to non-thermal mechanism(s)”³

Furthermore, in 2010 an international group of concerned life science/health professionals calling themselves the Seletun Scientific Panel, published the Seletun Scientific Statement which, among other things, calls for the current microwave/RF limits to be lowered by 50,000 to 60,000 times.⁴

Further demonstrating the trend toward growing concern and evidence, in 2011 the World Health Organisation added radio-frequency radiation (which includes wireless) to its list of “possible human carcinogens”.⁵

The buffer

The actual standard against which wireless devices are currently tested includes a buffer. Anything below the baseline level at which thermal effects are noted is considered safe, but the standard includes a 50-fold buffer for added safety. That is, wireless devices are required to create radiation levels resulting in absorption 50 times lower than the level at which thermal effects have been noted.

While this is a more comforting level, it has already been demonstrated (and acknowledged by the standards body) that the testing methodologies for radiation absorption levels are flawed. The standards body provides a list of radiation levels (called ‘reference levels’) at which radiation absorption limits would not be exceeded. It has been demonstrated that, in children (due to age/body shape/size), these reference levels result in the standard’s maximum radiation absorption levels being exceeded by 40%.⁶

With regard to the adequacy of the 50-fold buffer, recall that the Seletun Statement recommended lowering the current limit by 50,000 to 60,000 times.

Similary, a paper presented at the 2001 WHO Eastern Regional EMF Meeting and Workshop noted that exposure limits set in China, Russia, and Switzerland were 1000 times lower than those in the US and other countries whose limits were based on the same standard as used in the US (including Australia).⁷

Is wireless dwarfed by other forms of radiation?

A common argument against concerns for wireless is that, in the mix, wireless accounts for a ridiculously low percentage of the radiation exposures we face on a daily basis anyway. For example, radio and television (which are said to be bombarding us all the time) and mobile phones are often cited as far greater concerns. The absorption due to radiation from a ceiling-mounted wireless router (a common installation technique in schools), for example, is often said to be far less than holding a mobile phone to the head.

This may be true, but more needs to be taken into account than just the power of the devices and the proximity of the router. For example, a study commissioned by the University of Queensland (which was subsequently used by the university to allay concerns) into the wireless radiation levels on that campus actually showed that while the radiation levels on campus were indeed orders of magnitude below the level required by the standard, wireless accounted for 97% of radiation on that campus, against the background levels tested.⁸

Similarly, even a study funded by the WiFi alliance (a wireless industry body with the stated goal of “driving adoption of high-speed wireless local area networking”) noted that if the antenna of a wireless networking card is placed near the body, the absorbed radiation would be “comparable to that produced by a mobile phone handset”⁹ – so, if you’re holding a wireless device (like a laptop) or sitting it in your lap, the radiation absorption levels are comparable to that of a mobile phone.

Industry involvement in public health measures

There is a plethora of evidence to suggest that the telecommunications industry carries far too much sway in the ‘scientific’ considerations of public health measures relating to their technologies. Consider, for example, the 280-odd-page PhD thesis written by a gentleman who was actually involved in the standards setting process for RF radiation, subtitled “an examination of the manipulation of telecommunications standards by political, military, and industrial vested interests at the expense of public health protection”.¹⁰

An interesting example of how “spin” can create reassurance, is the report of the UK’s Health Protection Agency (HPA), which after extensive study found that “there is no reason why Wi-Fi should not continue to be used in schools”, despite the HPA’s previous chairman having released a report stating that “We conclude therefore that it is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach”. In my submission to the Department of Education, I discussed some of the problems with the HPA’s very forthright, subsequent statement, in light of other research, concluding that:

“In summary, that there is ‘no reason’ wireless networks should not be used in schools, may be true within the apparently very narrow aims of establishing [standards] compliance, but it is far from the full picture. This is a very good example of a case where media coverage of a study could convey very reassuring findings to an unsuspecting public, when in fact all the study has achieved is to demonstrate that devices adhere to standards which are 14 years old, which are demonstrably flawed, which are now being revised, and which could be orders of magnitude too high.”

Simple tests performed by me at a local primary school suggested that wireless networking was “always on” in schools, running 24 hours a day, 7 days a week, institutionally exposing children (who are known to be at higher risk) to a phenomena that the WHO has classed as a possible human carcinogen.

All of the above is discussed in more depth (and, therefore, with more balance) in my submission to the Department of Education (best viewed in a non-browser-based PDF viewer to ensure diagrams are rendered correctly).

References

1: pp. 507, 509 http://www.icnirp.de/documents/emfgdl.pdf

2: “The threshold of 4 W/kg for the disruption of complex behavioral performance in several animal species and under diverse exposure conditions has formed the basis for the setting of human exposure guidelines since 1982.” D’Andrea et al 2003, S58 http://grouper.ieee.org/groups/scc28/sc4/Behavioral%20effects.pdf

3: http://www.ncbi.nlm.nih.gov/pubmed/16107253

4: http://iemfa.org/index.php/publications/seletun-resolution

5: International Agency for Research on Cancer 2011. www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf

6: http://iopscience.iop.org/0031-9155/53/6/001/pdf/pmb8_6_001.pdf

7: http://www.who.int/entity/peh-emf/meetings/en/day2Varna_Foster.pdf

8: http://uqconnect.net/helpdesk/wireless/Wireless-Device-Safety-v5.pdf

9: Foster KR 2007, p 287. http://www.ncbi.nlm.nih.gov/pubmed/17293700

10: http://www.emfacts.com/the-procrustean-approach

Following on from the Department of Education’s recommendation that I should contact the Australian Communications and Media Authority (ACMA) for more information about the ARPANSA (Australian Radiation Protection and Nuclear Safety Agency) standard, I did so.

I asked ACMA for their opinion on Section 5.7(e) of ARPANSA‘s “Maximum Exposure Levels to Radiofrequency Fields 3 kHz to 300 GHz”, which refers to “minimising, as appropriate, RF exposure which is unnecessary or incidental to achievement of service objectives or process requirements, provided this can be readily achieved at reasonable expense.” Specifically, I asked for an opinion on a body such as the Department of Education running wireless networks in schools, apparently 24 hours, 7 days a week, given the minimisation principle above.

ACMA‘s response was that Section 5.7(e) is outside its remit; ACMA has only been tasked with regulating the devices’ outputs, not when they are used. The email disclaimer does, however, note that “opinions contained in this email or any of its attachments do not necessarily reflect the opinions of ACMA“. ACMA also suggested that I may wish to raise the issue with ARPANSA.

Which I did. I asked ARPANSA who is responsible for ensuring Section 5.7(e) is being adhered to. The response was that ACMA isn’t, and that ARPANSA has no direct role in overseeing the use of wireless technologies. In other words, as far as I can tell, no-one has any responsibility for ensuring that RF exposure is ‘minimised as appropriate’.

ARPANSA also pointed out that 5.7(e) is not intended to apply to de minimis (insignificant) situations, and provided some figures demonstrating that Wifi operates at many orders of magnitude below the standards, with the comment that broadcast AM, FM and TV transmissions are likely dominate. The email concluded by saying that it is, however, reasonable for “the school to implement some minimisation of exposure for the students through good engineering design of the network and sensible classroom habits as regards use of laptop computers”.

I replied that despite the apparently low levels (which studies have shown are actually similar to mobile phones when a laptop is used at close proximity, for example) I still find the situation of interest given that the World Health Organisation has recently classified RF radiation as a possible human carcinogen, and given that we’re talking about institutionalised exposure of children (arguably something we should never regard as de minimis), citing the University of Queensland assessment that showed that 97% of on-campus radiation was actually coming from wifi. I also asked what ARPANSA had in mind as ‘sensible classroom habits’.

My first email to ARPANSA was answered in 6 days. My second email, to the same staff member who answered the first, has been unanswered for over a month.

Last week I received a one-page response from the Department of Education, regarding my sixty-page submission (around 30 of which were my own research as an IT consultant) raising concerns that the current radiation standards were inadequate, particularly for children.

In a nutshell, their response: “we’re within the standard”.  They referred my submission to the Department of Health and Human Services, who advised that all telecomms equipment in Australia is regulated by the Australian Communications and Media Authority, who enfore the ARPANSA (Australian Radiation Protection and Nuclear Safety Agency) standard. Which, as my submission noted, is based on the ICNIRP standard, which is what dozens of experts are saying is hopelessly inadequate.

Their response came in the same week that news broke about the Italian Supreme Court ruling which, in what is probably likely to be a precedent-setting decision, links mobile phone use to cancer, forcing workers’ compensation to be paid to an employee who used a mobile phone for work and developed a facial tumor.

I recently did some research on the potential health effects of wireless networking in schools.

[Updates to this post follow the main text below.]

As a result of this research, I’m quite troubled by the apparently widespread use of this technology in schools. I subsequently submitted a paper to Tasmania’s Department of Education, and also to a number of politicians, in an effort to have the issues heard.

That was nearly two weeks ago, on May 2nd. I sent the submission to the IT department and the office of the Secretary, as well as Nick McKim (Education Minister), Will Hodgman (Leader of the Opposition), Jackie Petrusma (Liberal MP for Franklin), David O’Byrne (Labor MP for Franklin), and Paul Harriss (MLC for Huon). So far I’ve received no reply of any substance, just ‘read’ receipts and an assurance from Ms Petrusma’s office that she will read it with interest.

I know things move slowly in the bureaucracy and it may be some time before I hear anything about it again (if ever), but still, I’m posting it here in the hope that making the paper more easily available will generate more public interest and therefore more political pressure.

The Executive Summary of the paper is as follows (support for these points is in the document itself, below):

• A growing body of peer-reviewed scientific evidence indicates that there may be very real health risks resulting from exposure to a broad spectrum of electromagnetic radiation (EMR) frequencies (EMF), including wireless local area networks (WLAN / ‘wireless networking’ / ‘wi-fi’).
• While some peak bodies assert that there is no scientific consensus supporting suggested health concerns, the historical direction of the debate shows that the scientific consensus is slowly shifting to a position of concern as the results come in from thousands of studies.
• Reflecting this growing consensus of concern, in May 2011 the World Health Organisation (WHO) classed radio frequency (RF) electromagnetic radiation (RF-EMR, which encompasses wi-fi) as a Group 2B “possible human carcinogen”.
• As early as 1988, experts warned that children absorb high frequency EMR more readily than adults. Consequently, current radiation absorption guideline limits are breached by up to 40% in experimental models of children at maximum exposure levels that were calculated to prevent these limits being reached.
• The Australian standard developed by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) recommends a precautionary approach which, according to ARPANSA’s fact sheet, “requires owners of RF sources to minimise unnecessary exposure of the public to RF fields”.
• Emerging international precedents are reflecting the growing concerns regarding EMR. For example, the Israeli Parliament is considering legislation that would require mobile phones to carry health warnings, and in a current case in a US civil court, a parent is suing his public school’s District due to WLAN.
• Despite the above, WLANs are becoming increasingly commonplace in schools, purely for convenience and the short-term fiscal benefits WLANs offers over wired networks. Tasmania’s Department of Education (DoE) stated that “the use of WLAN [i.e. a Group 2B possible human carcinogen] is a safe and practical solution to the computing communications needs in the modern teaching and learning environment”. DoE‘s implementation can hardly be considered to be limited to ‘necessary’ exposure – wi-fi is available 24/7, exposing children to RF EMR even when they are not using computers. This submission is a call to action to reassess current policy on the use of WLANs in schools.

One thing I touch on in the paper but don’t expand on, is the issue of permission. Despite the power of School Associations being enshrined in Tasmanian legislation and departmental policy, and despite my having chaired our School Association for a time, I’ve not been aware of a Tasmanian school that has been invited to make a decision on whether the school should use wi-fi. In our own school, the rollout of wireless networking seems to have ‘just happened’, as a fait accompli. Perhaps, if there is adequate concern, this could be one area where School Associations could flex their muscles.

The more I think about the issue, the more I get a sinking feeling. I suspect that with the growing normalisation of cancer (e.g. television viewers are currently regularly told that “one in two Australians will be diagnosed with cancer”), as a society we may just roll over and take whatever is dealt.

My submission is available, in full, here (best viewed in a non-browser-based PDF viewer to ensure diagrams are rendered correctly):  Wireless Networking in Schools

 Updates

• 15/5/2012 Following bodies provided with a link to the submission:
  • Australian Council of State School Organisations (ACSSO)
  • Australian Parents Council (APC)
  • Australian Professional Teachers Association
  • Independent Schools Council of Australia (ISCA)
  • Independent Schools Tasmania

• 16/5/2012 ACCSO acknowledges receipt and thanks me for the submission.
• 16/5/2012 APC acknowledges receipt.
• 16/5/2012 The Hon Will Hodgman’s office replies. He would be interested in any response from the Hon Nick McKim. The office has also provided a copy to shadow Ministers for Education and Health. No comment on the content of the submission itself other than that it demonstrates an investment of thought and time.
• 21/5/2012 receive a receipt stating that ISCA deleted my email without reading it.
• 21/5/2012 I write to ISCA to enquire whether my email was deleted by mistake, with a copy of my submission attached.
• 25/5/2012 Read receipt received from ISCA.
• 29/5/2012 Came across this document which is a PhD thesis subtitled “an examination of the manipulation of telecommunications standards by political, military, and industrial vested interests at the expense of public health protection“, and is written by a gentleman who was involved in the standards setting process for RF radiation. And, to my surprise, he lives in Tasmania. I’m only 30 pages in to the 280 odd page thesis, but it’s very interesting reading so far.
• 30/5/2012 Contacted Federal MP Andrew Wilkie to raise concerns, following his stance on the proposed mobile phone tower at Claremont. I pointed out that, as discussed in my submission above, a report commissioned by University of Queensland demonstrated that its wireless networks account for 97% of RF radiation on its campus (i.e. far outweighing other sources such as mobile phones).
• 21/06/2012 Received an email from the Director of DoE‘s Information & Technology Services, advising that my submission has been referred to radiation experts within the Department of Health & Human Services. I expect that the response will be that since wireless devices are operating within established guidelines, their ongoing use is acceptable, but here’s hoping that a public health approach may prevail, since my issue is that the guidelines themselves are the problem.
• Italian Supreme Court rules to award Workers’ Compensation to an employee on the basis of long term mobile phone use.

See the other posts in the “Wifi” category for more updates.

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