Dr. Anthony Miller (Professor Emeritus, Dalla Lana School of Public Health, University of Toronto, As an Individual):
Mr. Chair, members of the committee, thank you very much for giving me the opportunity to present on Health Canada's review of the evidence for Safety Code 6, which I believe has led to unsafe conclusions.
I am a physician and epidemiologist specializing in cancer etiology, prevention, and screening. I have performed research on ionizing radiation and cancer, electromagnetic fields and cancer, and other aspects of cancer causation. I have served on many committees assessing the carcinogenicity of various exposures, including working groups of the International Agency for Research on Cancer, commonly known as IARC, of which Canada is a member. I was the first Canadian member of their scientific council.
I was a visiting senior scientist in the monographs program in IARC in September 2011 until January 2012, where as part of my duties I reviewed the scientific literature that was used by a working group to designate radio frequency fields as a class 2B carcinogen, that is, a possible carcinogen. I was also one of the peer reviewers invited by the Royal Society of Canada to review the draft report of the Royal Society panel on Safety Code 6.
I have a number of concerns over the documents that have recently been released by Health Canada on Safety Code 6 and the document called “Rationale”. What Health Canada has said in its latest iteration of Safety Code 6 is that it should be distinguished from some municipal and national guidelines that are based on socio-political considerations. I find that a strange statement because it seems to provide no room for emerging evidence on health hazards, which surely should be considered if the safety of humans is the objective.
Since the IARC review, which identified radio frequency fields as a possible human carcinogen, there had been a number of studies that have been reported. In my view—and that of a number of colleagues who've written a couple of papers with me on this issue, one of whom will present to you next week—these studies, we believe, reinforce the evidence that radio frequency fields are not just a possible human carcinogen but a probable human carcinogen, putting it in the category 2A. It would be impossible to ignore such a hazard in regulatory approaches.
One of the most important was a study in France, a large case-controlled study, which found a doubling of risk of glioma, the most malignant form of brain tumour, after two years of exposure to cellphones. After five years it was five times the risk. They also identified the fact that in those who lived in urban environments, where there are probably a number of other carcinogens that could impact upon brain tumours, the risk was even higher.
That brings us back to Safety Code 6 and the document that Health Canada contracted to produce a review of the evidence. This was the document produced by the Royal Society panel. I feel that panel was conflicted. As you probably know, the chair changed and the panel had insufficient expertise in epidemiology. My friend, Paul Demers, was called in to be chair of that panel. I believe he presented to you fairly recently. I feel he was put in an impossible situation.
If you read that document carefully, it says that the panel did not have adequate time to do a full review of the data, they therefore relied on reviews of other people and they did not do a detailed evaluation of the studies. That led them, I believe, to false conclusions.
It's important to recognize that there are no safe levels of exposure to human carcinogens. Although risk increases with increasing intensity of exposure, and for many carcinogens, such as tobacco smoke, even more with increasing duration of exposure, the only way to avoid the carcinogenic risk is to avoid exposure altogether. This is why we tend to ban carcinogens from the environment. Asbestos is one particular example of why much effort is taken to get people, particularly young people, not to smoke. Further, we now recognize that people vary in their genetic makeup, and that certain genes can make some people more susceptible than others to the effect of carcinogens. It is those who are susceptible that safety codes should be designed to protect.
As an epidemiologist who has done a great deal of work on breast cancer, one of the most concerning factors that have come to light is a series of case reports, starting with some reports from California and recently with the identification of a similar case in Saskatchewan. In all, there are now seven case reports of women who developed unusual breast cancers in the exact position where they kept cellphones in their bras. These are unusual tumours. They're multifocal, which means they occur in several places. They seem to mirror where the cellphone was being kept. The radiation from the cellphone seems to have increased in these women the risk, which they presumably already had, of developing breast cancer. They were all relatively young women. This is a most unusual occurrence that must concern us greatly.
We have brain cancers and parotid gland tumours, which are tumours of the salivary gland. There have been several instances of people who have developed this. In Israel recently a study identified increasing risk of these cancers, particularly with increasing exposure.
Given the long natural history of cancer and the fact that human populations have not been exposed for a sufficient length of time to exclude a carcinogenic effect, it is in my view extremely important to adopt a precautionary approach to the exposure of humans, particularly children, to radio frequency fields. We should note that an individual, if appropriately informed, can reduce their exposure to radio frequency fields from devices that use Wi-Fi, but in the case of cell towers and smart meters, the exposure they receive is outside their control. Then, with the people who manufacture these devices and those who promote Wi-Fi in all sorts of instances, we're reaching a situation where homes are being saturated with radio frequency fields.
It will be very difficult to prove conclusively an effect. Spread over a large population, if the normal occurrence is relatively rare—and it is relatively rare for brain tumours to occur—even if you double the risk, triple the risk, or even quadruple the risk, it will be difficult to identify that precisely. We need to do these studies.
In the meantime, to avoid a potential epidemic of cancer caused by radio frequency fields from Wi-Fi and other devices, we should strengthen the codes that are meant to protect the public. In my view, Health Canada has not done an adequate job. Safety Code 6, in its current iteration, needs to be re-revised.
I thank you, Mr. Chairman.
Mr. Frank Clegg (Chief Executive Officer, C4ST, Canadians For Safe Technology):
Mr. Chair and committee members, I'd like to thank you for the invitation to speak with you this afternoon and for deciding to invest committee time on Safety Code 6.
When I ran the Canadian operations for Microsoft, I learned that it is critical to focus on process. Today, as a board member for Indigo Books and Music, my role has shifted more towards governance and oversight. In both roles, process is critical to success. Government is the largest corporation of all, so process is of paramount importance. As someone who regularly examines success and failure, I believe I can explain why the Safety Code 6 process is a failure by all metrics and has left Canadians unprotected.
There is a book written by Nassim Taleb called The Black Swan, a focus on very low-probability, high-impact events that aren't supposed to happen. Oil spills, train derailments, and airplane crashes are some of the events in this category. Taleb calls these “black swan” events.
If one decides that all swans are white and refuses evidence of black swans, then one will conclude that all swans are white. Black swans are rare, but they do exist. Unfortunately, experts convinced themselves that these events had zero probability. They did not plan appropriately and people died.
The American Academy of Environmental Medicine is an international organization of physicians and scientists that has predicted, among other things, the rise in multiple chemical sensitivity, which is now protected in many public policies. Regarding the unprecedented increase in wireless devices, the academy forecasts “a widespread public health hazard that the medical system is not yet prepared to address”.
I believe Health Canada's analysis focuses on identifying and counting white swans, while ignoring black swan evidence. Health Canada's representative informed this committee on March 24:
||...some of these studies report biological or adverse health effects of RF fields at levels below the limits in Safety Code 6, I want to emphasize that these studies are in the minority and they do not represent the prevailing line of scientific evidence in this area.
In other words, black swans exist.
In your handout—I don't know if you have it, as we put it in for translation—is a document entitled “Analysis of 140 Studies Submitted by Canadians for Safe Technology (C4ST) During the Public Comment Period on Safety Code 6”. A chart in that document shows that Health Canada accepts that there are in fact 36 studies all passing Health Canada's quality criteria showing harm at levels below Safety Code 6.
As a Canadian, I find this confusing. As an executive, I find it inexcusable.
Of the 36 studies Health Canada deemed satisfactory, cancer is linked in six of them. In 13 of them, the brain and/or nervous system is disrupted. In 16 studies, Health Canada admits that biochemical disruption occurs. Finally, seven high-level scientific studies indicate an effect on intellectual development and/or learning behaviour. All of these studies show impacts with radiation below Safety Code 6 limits. How was this black swan evidence evaluated?
In our two-year investigation, C4ST has determined that Health Canada doesn't even have the proper software required to access, summarize, and analyze the large number of relevant studies. If our group of learned and qualified volunteers can uncover 140 studies, how many more are being missed or ignored?
Health Canada references its weight-of-evidence approach. It is unclear how many studies you need to outweigh 36 studies that show harm, especially to children. I just can't fathom why Health Canada is not highlighting these studies and prioritizing their implications. Despite requests to publish the weight-of-evidence criteria as per international standards, Health Canada refuses to do so. Even the recent 2015 rationale document does not provide this critical information.
Health Canada dismisses scientific evidence unless it shows harm where the microwave levels are strong enough to heat your skin. The notion that microwaves are not harmful unless they heat your skin is decades out of date. The core premise of this white swan dates back to Einstein's theory that non-ionizing radiation cannot cause harm, or if it does, it must heat tissue to do that. Albert Einstein passed away the same year Steve Jobs was born. To think that science has not evolved since then is classic white swan thinking. It's part of a process predetermined to fail.
Health Canada says on its website today that there is no chance that Wi-Fi or cellphones can harm you because it has studied all the science, but when pressed under oath, Health Canada officials give a more fulsome answer. In Quebec Superior Court in September 2013, Health Canada senior scientist James McNamee admitted that Health Canada only assesses risk based on the thermal effect, i.e., the heating of tissue.
Unfortunately, Canada has not invested the necessary time nor had the balanced opinion of experts necessary to undertake a proper review. Our research has uncovered that the Health Canada author of Safety Code 6 has published papers demonstrating his bias towards this topic.
In a few hours over three days, this health committee has spent more time speaking with scientific experts who believe there is harm from wireless radiation below Safety Code 6 than all of Health Canada combined. You can't find black swans when you don't talk to the experts who've identified them.
There is a fundamental business rule: you can't manage what you don't measure. It is clear that Health Canada not only doesn't follow that rule but even resists it. A memo obtained under access to information to the Minister of Health in March of 2012 revealed that Health Canada “does not support the recommendation to establish an adverse reaction reporting process specifically for RF exposures”. The memo goes on to state that “consumer complaints...may be directed to...the web-based system...under the...Canada Consumer Product Safety Act”. This is an inadequate solution and, I believe, a missed opportunity.
I refer you to the C4ST fact sheet. I think you have it. I'd like to highlight three examples from that fact sheet: Health Canada's Safety Code 6 is among the countries with the worst guidelines in the world; Canada has fallen behind countries such as France, Taiwan, and Belgium in protecting Canadians; and finally, Health Canada wasted over $100,000 of taxpayers' money, as the Royal Society report is not an independent review.
Health Canada also states that Safety Code 6 is a guideline and that other organizations at the provincial and local levels of government are free to implement lower levels as they see fit; however, that's not the reality of what happens. We have witnessed school boards, power and water utilities, Industry Canada, and manufacturers depending on Health Canada's analysis, and frankly, abdicating to it. They don't perform their own analysis.
Safer solutions exist. There are several situations in Canada regarding cell towers where the proponents have voluntarily offered to restrict radiation exposure, in some cases to thousands of times less than Safety Code 6. There is a solution in Iowa for smart meters that use a wired meter that provides a safer, more secure solution at a lower cost.
Given that our track record in North America is not successful regarding such products as tobacco, asbestos, BPA, thalidomide, DDT, urea-formaldahyde insulation, and many others, use of the precautionary principle of prudent avoidance should be recommended until the science proves beyond reasonable doubt that there is no potential for harm.
For the last three years, science has published a new study every month that shows irreparable harm at levels below Safety Code 6. That is why we're asking the committee to take three decisive steps.
First, conduct a national campaign to educate Canadians about methods to minimize exposure to RF radiation, ban Wi-Fi in day care centres and preschools, and ban the marketing of wireless devices to children.
Second, protect individuals who are sensitive to RF radiation by accommodating them with safer levels of wireless exposure in federal workplaces and federal areas of responsibility.
Third, and finally, create an adverse reporting system for Canadians and a publicly available database to collect improved data regarding potential links between health effects and exposure to RF radiation.
Parallel to the above, recommend that Health Canada conduct a comprehensive systematic review, subject to international standards, regarding the potential harmfulness of RF radiation to human health, with a scientific review panel that is balanced in opinion. It was a textbook case of black swan thinking that has led to this failure of Safety Code 6.
In conclusion, C4ST volunteers found 36 black swans that Health Canada agrees are high quality. How many would be available if Health Canada sincerely looked? Better yet, how many black swans will it take before Health Canada takes serious actions? Thank you very much.
Dr. Magda Havas:
Thank you very much for the invitation to address you today. My name is Dr. Magda Havas and I'm an associate professor of environmental and resource studies at Trent University in Peterborough, Ontario.
For the past 25 years I have been teaching university students about the biological effects of electromagnetic fields and electromagnetic radiation, which are collectively referred to as “electrosmog”. It is my belief that electrosmog is the emerging public health issue, due largely but not entirely to the rapid proliferation of wireless technology. Concern among health care practitioners and the public is growing as chronic illness increases and health care costs rise.
Since 2000 I have been invited to give more than 300 lectures at medical conferences, at universities, to congressional and Senate staff in the United States, and to community groups concerned with Wi-Fi in schools and antennas in their neighbourhoods. In 2002 Charles Caccia invited me to present to the environment committee of the House of Commons. In 2010 I appeared before the HESA committee to discuss the very same issue we are discussing today. In 2013 we presented to the Canadian Medical Association and the Royal College of Physicians and Surgeons about the harmful effects of electrosmog and the need for public protection.
I began my career as an environmental toxicologist in the mid-1970s, and the emerging issue at that time was acid rain. I was one of the scientists who studied the damage that acid rain does to forests and lakes. My peer-reviewed, published research and that of other scientists helped bring in clean air legislation, referred to as the acid rain accord, signed into international law by Prime Minister Mulroney and President Bush in 1991. This accord guaranteed cleaner air and a healthier environment for millions of Canadians and Americans, and protected our aquatic and terrestrial ecosystems.
We need similar steps to be taken for electrosmog legislation. That accord was due to the work of the Canadian Coalition on Acid Rain, federal and provincial ministers of the environment like Charles Caccia and Jim Bradley, and a large number of scientific studies from eastern North America and north-central Europe. The accord came 15 years after my studies on the effects of acid rain began. We were able to get clean air legislation because members of Parliament based their policy decisions on the science and not on misinformation provided by industry representatives.
At that time, acid rain was not taken seriously. Industry scientists repeatedly claimed that acid rain did not exist or was natural, and was not responsible for the loss of fish and the death of trees. This denial of a problem is common in health and environmental issues that have financial consequences for those generating the pollution. We have seen it with asbestos, DDT, lead, cigarettes, and now electrosmog.
Today I find myself in a situation similar to the one I was in with acid rain. We have industry scientists who repeatedly claim that electromagnetic pollution does not cause cancer or adverse effects on health. These wireless industries are able to hide behind Health Canada's Safety Code 6, which affords more protection to them than to the public.
Schools that have installed Wi-Fi, the telecommunications industry that installs antennas on hospitals and in residential communities, and provincial and municipal governments that do not have expertise in this area, all hide behind Health Canada's Safety Code 6, with the false perception that they are being protected. What they don't realize is that this guideline was designed to protect military personnel from heating of tissue averaged over a six-minute period. It was not intended to protect the infant in the crib lying next to a wireless baby monitor that emits microwave radiation for 12 hours a day.
The science that I teach dates back to the 1940s, when U.S. Navy labs documented illness among radar equipment operators. Back then it was called microwave illness. Today it is called electrohypersensitivity. Radar operators were made sick by the same frequencies later used for the microwave oven, which originally was called the radar range. The same frequencies are now used in Wi-Fi devices. We wouldn't want to live near a radar installation, yet we generate radar frequencies in our home with our wireless technology.
Symptoms of electrohypersensitivity include headaches, chronic pain, chronic fatigue, sleeping problems, difficulty concentrating, poor short-term memory, mood disorders including depression and anxiety, dizziness, nausea, and tinnitus. As many as 3% of the population, one million Canadians, have EHS symptoms that are so severe they are unable to function in our modern world.
Another 35%, 10 million Canadians, have mild to moderate symptoms. These symptoms resemble aging and I refer to electrohypersensitivity as rapid aging syndrome.
My research shows that radio frequency radiation from a cordless phone at levels well below 1% of Safety Code 6 causes an irregular or rapid heart rate in those who are sensitive. This is called tachycardia. In a few individuals, their heart rate increases from 60 beats per minute to 100 beats per minute while they're lying down on a bed without knowing whether the device is turned on or off. The tachycardia is often associated with anxiety. The feeling is that they are experiencing a heart attack.
Dr. Stephen Sinatra, an American cardiologist, believes that minor heart abnormalities, one of which is called Wolff-Parkinson-White syndrome, affects one in 700 children. Combined with exercise and exposure to microwave radiation, such as Wi-Fi or nearby cellphone antennas, this creates the perfect storm that could result in cardiac arrest.
The population in Ottawa elementary schools, with approximately 143,000 students, may have as many as 200 students who are at risk because of this particular heart effect if they have Wi-Fi in their school environment. In the early studies with radar operators, doctors recommended that workers be screened for heart irregularities before working with microwave radiation. Perhaps students should be screened before attending Wi-Fi-equipped schools.
As part of my research, I am trying to find biomarkers for electrohypersensitivity so that doctors can be better equipped to diagnose the environmental illness. So far we have found several—heart rate, heart rate variability, blood viscosity, sugar among diabetics, and muscular coordination problems with people who have multiple sclerosis. More biomarkers are needed. Unlike epidemiological studies that document an association between an agent and an outcome, our studies demonstrate a cause and effect relationship.
Experts who testify at hearings such as this have general or specific backgrounds in science or medicine. Those with a general background and no experience with their patients, or through their own research, are likely to provide misleading information. The reason for this is that we are going through a paradigm shift in our understanding of the relationship between electromagnetic energy and how the human body works.
We now recognize that our cells and organs communicate with each other using electromagnetic impulses rather than just chemical messengers. Any signal that interferes with that communication may adversely affect the health of individuals. The effects are a function of not only intensity, but also frequency modulation waveform.
What you see in front of you, in the bottom slide, is a picture of my blood under the microscope. The cells around.... A few are connected. Most of them are free. This looks like fairly healthy blood.
After I use a computer for 50 minutes, I get the blood you see in the top left-hand corner. The blood cells are sticking together. Ten minutes after using a cordless phone, my blood becomes very sticky, very viscous, and it doesn't distribute the oxygen in my body the way it should. This is one of the symptoms of electrohypersensitivity.
Doctors are not taught in medical schools about electrosmog, as it is a relatively recent problem, nor are they taught how to diagnose electrohypersensitivity. For them, this illness does not exist. When doctors can't identify an illness they often assume it is psychological. I have spoken to psychiatrists who tell me that they are regularly sent patients who have physiological problems and not psychological ones. Some of these people are electrically hypersensitive.
Industry scientists often refer to studies that report that subjects who claim to have EHS are unable to subjectively determine whether a device is on or off. They falsely conclude that this means the person is not electrically hypersensitive. The flawed assumption here is that perception is not necessary for a physiological action to occur and that reactions occur immediately. Neither are true.
We can be outside on a sunny day when the sun is not visible or hot and still get a sunburn. We do not perceive ultraviolet radiation. The sunburn develops over time. Sensitivity to the sun varies among individuals, as does electrohypersensitivity. Indeed, sensitivity to the sun is a good analogy for EHS. The longer you are exposed, the more severe the sunburn.
If you look at the 20 years it took for acid rain and the 50 years it took to address tobacco, the outlook for wireless technology is bleak. That's because it's not one culprit. There are many things in our environment that generate electrosmog.
The bottom line is that levels of microwave radiation are currently well above background levels and continue to increase as more wireless devices are brought to market. These levels, despite being below Safety Code 6, are adversely affecting human health. We can wait another five years, or we can take steps in the right direction to reduce our exposure. If we err, we should err on the side of caution.
I have a quick demonstration if you give me half a minute.
The Honourable Hedy Fry (Vancouver Centre, Lib.):
This is like déjà vu. I think you asked a very important question, Dr. Havas. I don't understand. Inherent, for instance, in the medical ethos is to first do no harm, so the primary thing for a physician is the precautionary principle unless you see that the benefits outweigh the risks and you are prepared to do some harm in order to divert worse harm.
I've been listening to this so I called up my son and my daughter-in-law and I said, “Hey, you guys have a wireless baby monitor on my granddaughter's crib. I'm hearing this stuff and I think maybe you should take precautions and get a plug-in monitor or find a way to turn it on only when you need to”.
They said to me, “Oh, for God's sake, that is such a bunch of hokey stuff. The guidelines are clear, blah, blah, blah”, and of course I was almost accused of crying wolf.
If I couldn't convince my children that this is not reasonable and fair.... I think you said that it was 50 years before we got anybody to understand, in spite of evidence, that cigarettes caused cancer; and in the case of acid rain, it was 20 years. Surely to goodness we have learned by now that we shouldn't be taking that long. We need to see the harm that not acting on evidence sooner does.
Given that those blocking this the most are in industry themselves, and the fact that, let's be honest, governments have to balance economic growth and development and progress against harm to the greater good, and given that there is almost this conflict of interest between how governments currently operate and how governments could operate to protect people, how can we convince the public, which is completely addicted to Wi-Fi and to wireless devices, when they don't know anything else?
I'm addicted. I can't put away my stupid BlackBerry, so how do we convince people, because public awareness, obviously, as Frank said, must be a part of the recommendations? How do you put forward a public awareness program that will actually reach people and sink in without people saying, “Oh my God, everybody is being so hysterical about this”?
Professor Dariusz Leszczynski (Adjunct Professor, Department of Biosciences, University of Helsinki, As an Individual):
Thank you very much.
Thank you for inviting me to this hearing. It's an honour and a pleasure.
My name is Dariusz Leszczynski. I'm currently adjunct professor for biochemistry at the University of Helsinki, in Finland. I have done research in the area of biological and health effects of cellphone-emitted radiation since 1997. I was a member of the expert group of IARC, which in 2011 classified cellphone radiation as a possible human carcinogen.
When scientific evidence is unclear, contradictory, or ambivalent, careful and unbiased interpretation of it is of paramount importance. However, it is often the case that such scientific evidence gives room for a diverse interpretation that may lead to the development of contradictory expert opinions, causing confusion and impairing development of rational recommendations aimed at protecting the general population.
This is the current situation in the area of cellphone- and wireless communication-emitted radiation. Unclear experimental evidence leads to the polarization of the scientific opinions into two extremes: the no-effect opinion and the harmful-effect opinion. Currently scientists do not agree on the matter of biological and health effects of radiation exposures. The term “consensus” might be be misleading for the general public. We should rather speak about “differences in scientific opinion”.
A recent comment by the head of the World Health Organization's EMF project, Dr. Emilie van Deventer, well describes the current situation, and I will quote her comment given for The Daily Princetonian, “There is no consensus, it’s true. There’s a big group and a little group, but it’s still two groups.”
Talking about a big and a small group is a pure speculation because the size of the groups was never examined. From my nearly 19 years of experience in this area of research, I know that the vast majority of the scientists do not openly take a side in the debate.
The interpretation of scientific evidence by committee is of most use for the decision-makers. This is the reason that the development of unbiased opinions by committees are of paramount importance. Opinions of committees are defined by the expert composition. In an ideal committee, experts would not have conflict-of-interest issues and would be independent of any kind of lobbying; only science would matter. Nearly all of the committees dealing with the health effects of radiation emitted by wireless communication devices have a problem of biased expert selection, a potential conflict of interest, and a potential influence by an industrial lobby, which may occur in spite of set-up firewalls.
The majority of the committees consist of scientists having the same expert opinion. Individual committees experts commonly do not reflect all current scientific opinions. This concerns both international committees and national committees. This includes the committee in Canada that provided evidence for Safety Code 6. The composition of the Health Canada expert committee was clearly biased towards the no-effect opinion, and some of the experts are known to advise the telecom industry. This is a serious potential conflict of interest.
The above-mentioned system of firewalls to protect experts from influence of industry doesn't work. Industry sponsors know who receives funding; sponsored scientists know who provides funding. This is especially worrisome when the influential ICNIRP committee is in part funded by the industry through firewalls of the Royal Adelaide Hospital in Australia. The same goes for the EMF project of the WHO. If your experts know very well that the opinions of ICNIRP will be unfavourable for the telecom industry, their sponsorship may end. The firewall is only a gimmick.
Currently, WHO's EMF project is preparing an evaluation of the scientific evidence concerning health effects of radiation emitted by wireless communication devices, the so-called environmental health criteria for RF-EMF. The major problem with the draft document of environmental health criteria is the lack of balanced presentation of the scientific evidence. The environmental health criteria draft was written solely by scientists with a no-effect opinion.
The environmental health criteria document will have a global impact on billions of users of wireless technology and on the multi-trillion dollar business. This is why it is disturbing that preparation of such a document is solely reflecting opinions of ICNIRP, an organization with a firm, single-sided, no-effect opinion. This is a disturbing situation, where one group of scientists was given preferential treatment only because of their close link with the WHO and where other relevant expert opinions were deliberately and arbitrarily excluded without scientific debate.
Recommendations for decision-makers developed by committees, where memberships are consistently biased towards either a no-effect opinion or harmful effect opinion, are not representative of the whole currently available scientific evidence and should be viewed with extreme caution, or outright dismissed, until the proper, unbiased evaluation takes place.
To my knowledge there was only one scientific committee—IARC's working expert group in 2011, of which I was a member—where the full scope of diverse scientific opinions were represented. IARC classification completely disagreed with one-sided opinions of the majority of international and national committees, including Health Canada. Until an unbiased, round table of scientific debate takes place, where all scientific opinions will be duly represented and evaluated, the opinions developed to date by various international and national committees, based on biased expert selections, should be dismissed by decision-makers as insufficient.
According to year 2000 documents of the European Union on the precautionary principle, there are three criteria that need to be fulfilled in order to implement the precautionary principle. All of them are currently fulfilled.
Number one, scientific information is insufficient, inconclusive, or uncertain to make a firm decision. This is exactly what the IARC classification says on cellphone radiation as a possible human carcinogen, group 2B.
Number two, there are indications that the possible effects to human health may be potentially dangerous. Increased risk of brain cancer in long-term, avid users is a dangerous outcome, shown by three replicated epidemiological studies: European INTERPHONE, Swedish Hardell group, and French CERENAT studies.
Number three, the effects are inconsistent with the chosen level of protection. Epidemiological studies showing an increased risk in long-term, avid users were generated in populations using regular cellphones meeting all current safety standards. This means that the current safety standards are insufficient to protect users because the risk of developing cancer increases in long-term, avid users.
Proponents of the precautionary principle need to understand that precaution does not equal prevention of use of wireless technology. Requirements to develop more efficient, less radiation-emitting technology, and further biomedical research on the radiation effects, will create new knowledge through research and will create jobs in the research and technology. Implementation of the precautionary principle will not prevent technological developments. Claims by some that the implementation of the precautionary principle will cause economic stagnation are unfounded.
In the current situation of inadequate review of scientific evidence by groups of scientists with biased selection of members, and until the round table, unbiased review is performed, decision-makers should implement the precautionary principle. The reason is not that the harm was proven beyond doubt, but because the harm is possible and evidence is uncertain and suggesting that harmful health effects are possible. The precautionary principle was developed just for such situations where scientific uncertainty with concomitant indications of possible harm requires society to wait for more scientific evidence. Saying, “Better to be safe than sorry” applies here.
Dr. Rob Tarzwell:
Very good. I'll pull direct quotes, then, in that instance.
The IARC working group—this would be the first document you'd be looking at—has a single-page summary of evidence leading to the 2B conclusion in 2013, based on the 2011 meetings, and 2B means “possibly carcinogenic to humans”. What the IARC means by that is, and I'll quote directly from their preamble:
|| This category is used for agents for which there is limited evidence of carcinogenicity in humans and less than sufficient evidence of carcinogenicity in experimental animals. It may also be used when there is inadequate evidence of carcinogenicity in humans but there is sufficient evidence of carcinogenicity in experimental animals.
The document itself makes reference to a number of different studies that were broken down into occupational, environmental, and personal exposures. The studies that the committee thought presented the strongest evidence were specifically the case-control studies that have been referred to. INTERPHONE has been mentioned. The Swedish studies have also been mentioned.
It's important to understand what a case-control study is. As has been pointed out, the real way to find out if something is a health risk is, prospectively, to look over time at individuals who are experiencing the exposure, documenting rates of conversion to disease in the exposed versus the non-exposed, and then see if there's a dose-response relationship. In other words, do individuals with higher levels of exposure to a risk convert to disease at higher rates? As far as I'm aware, this sort of information is not available in human populations for RF-EMF, so we do the best we can with case-control studies.
Both the INTERPHONE and the Swedish studies relied on interviewing individuals with glioma, with acoustic neuroma, and then interviewing random controls. What they found was that in individuals with these neoplasms, or cancers, was that the individuals report higher levels of exposure than controls. The question of recall bias is really important in a study like this, because we're relying on indirect lines of evidence to conclude what the exposures might have been. These folks weren't carrying detectors on them for years and years. These are telephone interviews, questionnaires.
The important thing which IARC, to its credit, acknowledges, is the potential for what's called “recall bias”. In other words, if you have a catastrophic health outcome, you will naturally search for causal evidence for that outcome. If a well-funded scientific committee wants to talk to you, then the implicit suggestion may be that it thinks there might be a link there. As a result, anxiety rises, and it's not very difficult to imagine how individuals with a glioma might report, “Why, yes, I believe I did have higher exposure to radio frequencies.”
The IARC also concluded that although this was a significant bias, they couldn't completely rule out these studies on the basis of bias. What they concluded, therefore, was that there's limited evidence of carcinogenicity, meaning the quality of the evidence is limited.
I want to point out what a 2B means. The IARC, again in its preamble on page 23, says the following:
|| This category is used for agents for which there is limited evidence of carcinogenicity in humans and less than sufficient evidence of carcinogenicity in experimental animals—
Wait. I've gone a bit backwards. I've already read that part.
I want to talk about what IARC means by “limited evidence”. The data suggest a carcinogenic effect, but it is prevented from making a definitive evaluation because, and I think in this case paragraph 6(b) is the most important, “there are unresolved questions regarding the adequacy of the design, conduct or interpretation of the studies”.
Of course this is an important signal within the literature and it's one that needs to be pursued, and indeed it has been pursued. The just-published 2015 text, Current Understanding and Treatment of Gliomas, which is available from Springer, the medical publisher, contains a book chapter titled, “The Epidemiology of Gliomas”; in other words, the causes and distribution of this disease.
Page 11 of that book reads as follows:
|| The scientific evidence used to produce the 2011 IARC report, as well as the scientific evidence reported since its publication does not support a significant association between use of cellular phones and risk of glioma. This exposure warrants continued monitoring and examination, as the potential risks of long-term heavy use, risk of use during childhood and adolescence, and length of glioma latency is not well understood.
However, the studies so far, in fact, would suggest against an association. Even in 2011 the strongest association that could be found was actually very weak.
Just to put this into some context, because I think Bill C-648, which in its own preamble specifically mentions the 2B classification as being relevant, there are currently 287 agents within category 2B. Essentially, if you cannot definitively exclude a risk, then you have to consider that it's possible. I'll give you some examples of what appears as possible carcinogenic agents: whole leaf extract of aloe vera, carpentry and joinery as an occupation, coconut oil, coffee, ginkgo biloba extract, kava extract, pickled vegetables, and talc body powder used perineally—in other words, baby powder.
The problem of scientifically proving a negative is very difficult. I can't prove to you that Santa is not real, because I'm not at the hearth of every single home on Christmas Eve. So from a purely scientific epidemiological point of view, I must concede it is possible that Santa Claus exists. But given the fact that scientifically I have to concede that possibility, it would be problematic to conclude that there is scientific evidence that Santa possibly exists. No, there is not sufficient evidence to completely refute it.
Epidemiologically speaking, that is how these studies are meant to be interpreted. Of course since, as the previous witness pointed out, the outcome is catastrophic, ongoing study is warranted. Studies to date, based on the latest and greatest evidence from glioma researchers and treaters, suggest there is no significant association.
As I said in my appearance before the Royal Society, I think Safety Code 6 is currently an adequate and satisfactory standard. I don't believe it needs to be changed. I believe if the committee wants to apply labels to RF-emitting devices on the basis of a 2B classification, then the door is open to labelling all 287 agents on the basis of their 2B classification. I don't know if that's territory into which the state wants to intrude to such a significant degree.
Prof. Dariusz Leszczynski:
We said earlier that when we began to smoke tobacco we waited 50 years to find out that it had some detrimental health effects. It was the same, for example, for the Hiroshima nuclear bomb. People got more cancer. We waited several tens of years after that ionizing radiation exposure.
Therefore, it is very problematic to say what we should do if later it appears that this was an unnecessary step. Should we protect ourselves when we are uncertain, or should we wait for the next 40 or 50 years for some sort of more definitive evidence and answer? But then we are facing another problem. What if indeed those epidemiological studies indicating that if somebody is using cellphone avidly....? “Avid” use was considered then to be using a cellphone for 10 years every day for half an hour per day. It was a long time ago—10 or 15 years ago—when cellphones and using them were expensive. People were not using them so much. Nowadays, with free minutes from the operators, people are using cellphones much more than before.
Already in 2011 we had those two sets of studies, the INTERPHONE one and the studies from Sweden. They were considered by these 30 scientists and 26 of them voted that there was enough scientific evidence to say that this is a possible human carcinogen. So we had two studies, and then, in 2014, last year, another study was published. It was the same type of study, from France, done in a different population, and arriving at exactly the same result: if a person is using a cellphone for 10 years or more avidly, half an hour per day or more, the risk of getting brain cancer increases. Many people say this, as was mentioned just now about what glioma scientists are thinking in regard to the connection between cellphone radiation and gliomas. It is not exactly so, because they say that right now they don't have the evidence.
But we have to remember two things. First of all, cellphones have been in common avid use for not very many years, maybe for 10 or 15 years. They have been in use longer in Scandinavia, but at the beginning people were using those cellphones very little, because it was very expensive. In avid use, those cellphones last maybe 10 years, and we know that the glioma takes several tens of years to develop, 40 or 50 years. Therefore, when we expose ourselves for 10 years but glioma development takes 40 or 50 years, there is not the time for this exposure to affect this tumour that is happening later. There is simply no time for development.
We have to balance those two issues: one, a potentially serious outcome like glioma, and then, exposure to cellphone radiation, meaning not forbidding people to use it, but developing this technology better and limiting unnecessary exposure. What is better? Limiting unnecessary exposure and being sort of at peace with this, in that in 40 or 50 years we will not have a bump of gliomas? Or is it that we use cellphones widely, as we are using them right now, and rely on this point that within the first 10 years of avid use nothing was happening?
This is something like saying that within the first hour after midnight there was no daylight, so apparently there is no daylight, because it would be coming only eight or nine hours later. This is the sort of issue to consider.
I think that not only should we look into the population of normal healthy people, but we should also think about those populations you were asking about, people who might be compromised or weakened, such as children and pregnant people, those with threatened immune systems.
We are all different and we all may respond differently to this exposure because of our genetic predispositions and because of our environment. It is no wonder that there may be some people who would be more sensitive. Those who are more sensitive may be, of course, those developing organisms like young children, or developing organisms in the womb of mothers, or a person who does not otherwise have very good health or immune system and is not capable of combatting radiation exposure or the effects of radiation exposure.
Hon. Hedy Fry:
Thank you very much. I want to thank our two presenters.
I want to pick up and follow on my colleague Terence Young's questions a bit, because he was asking a question, and I understand, Dr. Leszczynski, you didn't have these answers at your fingertips with regard to possible carcinogens that were moved off or down the list, but I think you gave your own examples at the very beginning.
What I heard you asking in your particular presentation, which I think is what we need to struggle with here as a committee, is this. Is there an ethical and moral need for us to look at a precautionary principle, or do we continue to follow what we saw with acid rain, with cigarettes, etc., where generations of people were harmed, died, got cancers, heart diseases, etc., and the ecosystem was destroyed by acid rain? What is the ethical duty of parliamentarians or people who are in charge of the health and safety of a nation or communities to have a consideration of not just the clear and definite evidence...? As Mr. Young and Dr. Tarzwell were saying, yes, there is some evidence but not all.
I think this is eventually an ethical and moral issue for us all. Do we err on the side of safety and precaution so that we do no harm or as little harm as possible, or do we wait for definitive studies?
You talked about that, but you didn't give me an answer about what you think is the moral and ethical duty of people like us, parliamentarians, who actually have to create, make legislation or regulations that would keep our citizens safe. You didn't answer that question yourself. You posed it a lot of times. I'd like to hear what you think.
Prof. Dariusz Leszczynski:
There are two take-home messages from my presentation and what I wanted to present you with.
First, we need an unbiased, thorough review of the scientific evidence that is currently available. This is not done in most cases because the majority of committees that are set up have bias problems. We need this good review of evidence. This is what is most important for you as decision-makers, that you can have an unbiased evaluation of science, and this will be the basis of your decision on what to do.
When one committee was set up by IARC in such a way that many diverse scientific opinions were included, scientists with very different opinions, often opposite opinions, were invited to this working group. During nearly two weeks of debate we came up with the conclusion that we have evidence of possible harm. We found limited evidence in the epidemiology and limited evidence in animals that there is a possibility of harm. None of the committees, for example as I mentioned, ICNIRP, which is a very important committee, Health Canada, and many other committees came to the same conclusion. Either committees come to the conclusion there is absolutely no harm or they come to the conclusion there is really very serious harm, but when looking at the composition of those committees' experts, we can see that either committees consist of experts having a no-harm opinion or a harm opinion. This is one problem.
Second, once you have this kind of round table unbiased evaluation of science, there's this moral, ethical question. Should business go on as usual or should we protect the population, take some precautionary steps?
Because we don't know for sure, but we have indications, we have red flags that something might be happening. Should we protect the population or not? At the moment, I would suggest looking at our past. We should not forget about our past and we should learn from our history. We should learn from tobacco, asbestos, DDT, and from many other miraculous agents that we first developed. Humanity thought that was a really fantastic chemical, a fantastic application, we could use it fully to advance our goals, and later on we have to wait for tens of years to find out if there is some problem.
We should learn from the past. When we see some red flags, we should take precautions and use the precautionary principle.