On 24 February 2015, the House of Commons Standing Committee on
Health (the Committee) adopted the following motion:
That the Committee undertake a comprehensive study
of no fewer than two meetings, plus one to consider a draft report, to study
the Health Canada Safety Code 6 on human exposure to electromagnetic energy,
that it invite relevant witnesses to appear, and that the committee reports its
findings to the House.
At the time that the motion was adopted, the 2009 version of Limits
of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency
Range from 3 kHz to 300 GHz (Safety Code 6) was under review by Health
Canada. The revised version of Safety Code 6 was
published on 13 March, which was prior to the Committee’s first meeting on the
Andrew Adams, Director General of the Environmental and Radiation
Health Sciences Directorate at Health Canada, stated to the Committee that “[w]ith the recent update, Canadians should be confident that
the radiofrequency exposure limits in Safety Code 6 are now among the most
stringent science-based limits in the world.”
Numerous concerns relating to radiofrequency (RF) exposure were
raised by witnesses during Committee meetings on Safety Code 6 as well as in
the briefs that were submitted. Many witnesses suggested that there were
problems relating to the Expert Panel of the Royal Society of Canada (Expert
Panel) that had been asked by Health Canada to review its proposed revision,
and a number of witnesses raised issues relating to how Health Canada
determined what scientific evidence to consider when it established the RF
exposure limits contained in Safety Code 6. Witnesses also spoke to possible
links between RF exposure and cancer, reproductive issues and autism. These
concerns tied in to other testimony that expressed unease about RF exposure in
schools as a result of the use of Wi-Fi; the need for RF exposure limits and
guidelines to protect vulnerable populations such as pregnant women, infants
and children, and others who may be more susceptible to the effects of RF
exposure; and electromagnetic hypersensitivity (EHS).
While witness testimony and briefs often emphasized the need for
Health Canada to take a precautionary approach to RF exposure by reducing the
limits established by Safety Code 6 (and sometimes provided examples of limits
and other measures taken to protect populations from RF exposure in other
jurisdictions), they also referred to steps that individuals can take to reduce
their own RF exposure. Finally, some witnesses stated that industry should play
a role in reducing RF exposure.
Wireless devices such as cell and cordless phones, baby monitors
and smart meters transmit and receive signals from fixed base stations: cell
towers in the case of cell phones and a base component in the case of cordless
phones. The signal used for this communication is RF electromagnetic radiation
(EMR). The electromagnetic spectrum spans from high energy X-rays and gamma
rays at one end to lower energy radiowaves and microwaves at the other, with
visible light in between. Higher energy radiation is referred to as ionizing,
while lower energy radiation is referred to as non-ionizing. Ionizing radiation
has sufficient energy to break molecular bonds and to remove electrons from
atoms or molecules, resulting in the formation of a charged atom, called an
ion. The damaging effects of ionizing radiation result from this ability to
change the composition of matter. Non-ionizing radiation, which is the type
emitted by cell and cordless phones, emits only sufficient energy to vibrate
atoms (heating), but not enough to remove electrons. The area occupied by the
EMR is referred to as the electromagnetic field (EMF), and the farther away
from the source of the EMR, the weaker the EMF becomes.
According to Health Canada, the purpose of Safety Code 6
… is to establish safety limits for human exposure
to radiofrequency (RF) fields in the frequency range from 3 kHz to 300 GHz. The
safety limits in this code apply to all individuals working at, or visiting,
federally regulated sites. These guidelines may also be adopted by the
provinces, industry or other interested parties.
This code has been adopted as the scientific basis
for equipment certification and RF field exposure compliance specifications
outlined in Industry Canada's regulatory documents (1-3), that govern the use
of wireless devices in Canada, such as cell phones, cell towers (base stations)
and broadcast antennas. Safety Code 6 does not apply to the deliberate exposure
for treatment of patients by, or under the direction of, medical practitioners.
Safety Code 6 is not intended for use as a product performance specification
document, as the limits in this safety code are for controlling human exposure
and are independent of the source of RF energy.
In a field where technology is advancing rapidly and
where unexpected and unique exposure scenarios may occur, this code cannot
cover all possible situations. Consequently, the specifications in this code
may require interpretation under special circumstances. This interpretation
should be done in consultation with scientific staff at the Consumer and
Clinical Radiation Protection Bureau, Health Canada.
The safety limits in this code are based on an
ongoing review of published scientific studies on the health impacts of RF
energy and how it interacts with the human body. This code is periodically
revised to reflect new knowledge in the scientific literature and the exposure
limits may be modified, if deemed necessary.
As Andrew Adams explained to the Committee, “[w]hile Safety Code 6
recommends limits for safe human exposure, Health Canada does not regulate the
general public's exposure to electromagnetic RF energy.”
In December 2010, the Committee released a report titled An
Examination of the Potential Health Impacts of Radiofrequency Electromagnetic
Radiation. The Committee held three meetings and heard from a variety
of witnesses, including government officials, stakeholders and scientists with
expertise in the field. At that time, the Committee heard testimony relating to
the development and implementation of Safety Code 6 as well as concerns
relating to Safety Code 6.
The Committee made the following recommendations:
the Government of Canada consider providing funding to the Canadian Institutes
of Health Research in support of long-term studies examining the potential
health impacts of exposure to radiofrequency electromagnetic radiation.
Health Canada request that the Council of Canadian Academies or another appropriate
independent institution conduct an assessment of the Canadian and international
scientific literature regarding the potential health impacts of short and
long-term exposure to radiofrequency electromagnetic radiation, which would
include an examination of electromagnetic sensitivity and a comparison of
public policies in other countries governing exposure to radiofrequency
electromagnetic radiation; and report on its findings.
Health Canada and Industry Canada develop a comprehensive risk awareness
program for exposure to radiofrequency electromagnetic radiation, which would
include Health Canada making public in an accessible and transparent way all
the studies and analyses undertaken by the Department on the impact of
radiofrequency electromagnetic radiation on human health, as well as the
provision of information promoting the safe use of wireless technologies.
Health Canada and Industry Canada offer to provide information, including
awareness sessions on exposure to radiofrequency electromagnetic radiation.
Health Canada ensure that it has a process in place to receive and respond to
reports of adverse reactions to electromagnetic radiation emitting devices.
There was no government response to this report prior to the
dissolution of Parliament when the 2011 federal election was called.
In 2013, Health Canada drafted revisions to Safety Code 6 and asked
the Royal Society of Canada to establish an expert panel to review the proposed
Code. An expert panel of the Royal Society of Canada had also been asked to
review the first version of Safety Code 6 (SC6) in 1998.
In its spring 2014 report, A
Review of Safety Code 6 (2013): Health Canada’s Safety Limits for Exposure to
Radiofrequency Fields, the Royal Society of Canada stated that it “was
asked to address five key questions.” These questions were:
- Do the basic restrictions specified in SC6 (2013) provide adequate protection for both workers and the general population from established adverse health effects from RF fields?
- Are there any other established adverse health effects occurring at exposure levels below the basic restrictions in SC6 (2013) that should be considered for revising the basic restrictions and reference levels in SC6 (2013)?
- Is there sufficient evidence upon which to establish separate basic restrictions or recommendations for the eye?
- Do the reference levels established in SC6 (2013) provide adequate protection against exceeding the basic restrictions in SC6 (2013)?
- Should additional precautionary measures be introduced into the human exposure limits in SC6 (2013)? If so, what is recommended and why?
With respect to the five questions that the Expert Panel had been
asked to examine, its chair, Dr. Paul Demers, explained to the Committee that
the panel concluded that the basic restrictions in Safety Code 6 provided
adequate protection from established adverse health effects, that there were no
other established adverse health effects occurring at exposure levels below the
basic restrictions in Safety Code 6, that there was insufficient evidence to
warrant establishing separate basic restrictions or recommendations for the
eye, and that Health Canada should review the proposed reference levels “to
make them somewhat more restrictive in some frequency ranges to ensure a larger
safety margin for Canadians, including newborn infants and children.” Finally, with respect to whether additional precautionary measures should be
introduced into Safety Code 6’s RF exposure limits, Dr. Demers stated that
although there was a range of opinions on the
panel regarding precautionary efforts, overall the panel believed that Safety
Code 6 was well-designed to avoid established health effects; we did not have any
science-based recommendations for precautionary measures to lower the limits.…
He also explained that the panel had made a number of other
recommendations to Health Canada, including that Health Canada should:
- investigate EHS;
- develop a public, suspected disease cluster reporting system along with a protocol to investigate clusters;
- expand its risk communication strategy and provide consumers with more information about RF radiation; and
- identify additional practical measures that individuals can take to reduce their RF exposure.
Dr. Frank Prato, Imaging Program Leader and Assistant Scientific
Director, Lawson Health Research Institute, noted that in section 10.2 of the
panel’s report the panel recommended that Health Canada pursue research
relating to the possible effects of exposure to RF energy at levels below the
limits in Safety Code 6.
A number of witnesses expressed concerns with respect to the Expert
Panel’s review of Safety Code 6. For example, Prof. Martin Blank stated that
there should have been a biologist on the panel, and Dr. Anthony Miller, who was a peer reviewer for the draft Expert Panel
report, noted that “the panel had insufficient expertise in epidemiology.” Dr. Miller also stated that “the panel was conflicted” and that the panel report “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,” a situation which, according to Dr. Miller, led them to false conclusions.
Prof. Dariusz Leszczynski stated that “some of the experts [on the panel] are
known to advise the telecom industry. This is a serious potential conflict of
Much of the testimony during the Committee’s hearings focussed on
which studies Health Canada had considered as part of its review of Safety Code
6. A number of witnesses referenced 140 studies that had been submitted by
Canadians for Safe Technology (C4ST) to Health Canada but that Health Canada
had not included in its consideration of the revision of the Code.
When he appeared before the Committee, Andrew Adams from Health
Canada explained that
[w]hen developing the exposure limits in the
revised Safety Code 6, departmental scientists considered all peer-reviewed
scientific studies, including those pertaining to both thermal and non-thermal
[effects], and employed a weight-of-evidence approach when evaluating possible
health risks from exposure to RF energy.
The weight-of-evidence approach takes into account
both the quantity of studies on a particular end point and the quality of those
studies. Poorly conducted studies receive relatively little weight, while
properly conducted studies receive more weight.
ln updating Safety Code 6, Health Canada made use
of existing internationally recognized reviews of the literature along with its
own expert review of the relevant scientific literature. Numerous reviews on
this issue have been written in recent years by international organizations
such as the World Health Organization, the European Commission's Scientific
Committee on Emerging Newly identified Health Risks, and ICNIRP.…
While Safety Code 6 references these international
reviews, the code is an exposure guideline, not a scientific review article.
Accordingly, most individual scientific studies are not referenced in the code.
However, this does not mean that Health Canada did not consider all relevant
scientific information when deriving the science-based exposure limits in the
lt should be noted that studies with inappropriate
study design or methodology can lead to erroneous results that are
Studies were considered not to be of sufficient
quality to inform the recent update if it was not possible to determine the
dosage studied, if the study lacked an appropriate control, if experiments
within the study were not repeated a sufficient number of times, if no
statistical analysis of the results was conducted, or if other improper
scientific techniques were used. Of the 140 studies that have been cited, a
large number fall into this category.
Other studies were not considered to be within
scope. For example, some of these studies looked at exposures to a frequency
range outside of the frequency range covered by Safety Code 6 and were
therefore not considered relevant.
However, Health Canada did consider all studies
that were considered to be both in scope and of sufficient quality for
inclusion in our risk assessment. While it is true that 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.
Health Canada submitted a summary table of the 140 studies that had
been presented by C4ST. That document noted that 36 of the studies “were
considered to be in scope and of sufficient quality for risk assessment.” Frank Clegg, Chief Executive Officer of C4ST, stated that “all of these studies
show impacts with radiation below Safety Code 6 limits.” Furthermore, he stated
that “[i]t is unclear how many studies you need to outweigh 36 studies that
show harm, especially to children.… Despite requests to publish the
weight-of-evidence criteria, as per international standards, Health Canada
refuses to do so.” Prof. Blank referenced the studies presented by C4ST, noting that “they were
omitted through an evaluation by non-biologists.” Dr. Meg Sears, Adjunct Investigator at the Children’s Hospital of Eastern
Ontario Research Institute, stated that “[a] lot of the recent research
demonstrating potential harm was omitted from reports that supported Safety
The Committee heard that the World Health Organization’s (WHO)
International Agency for Research on Cancer (IARC) has classified RF exposure
as a possible human carcinogen. Andrew Adams stated that “Health Canada
certainly is monitoring the scientific literature when it comes to what is
going on with cancer and RF fields and will continue to do so.” James McNamee, Chief, Health Effects and Assessments Division, Healthy
Environments and Consumer Safety Branch, Health Canada, who was a member of the
IARC panel, stated that
you can never prove that something is safe or that
something will never happen. We're subject to the evidence base we have at this
time. The IARC committee looked at that evidence. Basically, there were studies
that found effects and studies that didn't find effects. Many animal and in
vitro studies were looked at. Based on this examination, they made a
recommendation that it be classified 2B, as possibly carcinogenic to humans.
That recommendation acknowledged that there was some credible evidence
suggesting that there might be a risk in the long term, but that it was impossible
to make a causal association at this time.
Prof. Rob Tarzwell, Clinical Assistant Professor, Faculty of
Medicine at the University of British Columbia, supported IARC’s conclusion
that there was limited evidence of a causal link between carcinogenicity and RF
exposure, “meaning the quality of the evidence is limited.”
In contrast, Anthony Miller stated that there have been a number of
studies since the IARC review and that, in his view, those studies “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.”
Dr. Demers indicated that the Expert Panel had “tried to identify papers that
were published since [the IARC review], and then looked at the entire body of
research that was done.”
A number of witnesses put forward evidence that they had compiled
to support the link between RF exposure and cancer. Studies and other evidence
cited by witnesses that demonstrate links between RF exposure and cancer include:
- “up to fourfold increases … were seen in Sweden with use of wireless phones, both cellphones and cordless phones;”
- research by Alexander Lerchl that showed that “electromagnetic fields obviously enhance the growth of tumours”;
- “a large case controlled study [in France], 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”;
- “seven case reports of women who developed unusual breast cancers in the exact position where they kept cellphones in their bras”;
- “evidence of testicular cancer among police officers that had radar guns and were using radar to detect speeding. They very seldom turned the guns off and just kept them on their laps”; and
- “Increased risk of brain cancer in long-term, avid users … shown by three replicated epidemiological studies: European INTERPHONE, Swedish Hardell group, and French CERENAT studies”.
Prof. Tarzwell noted the possibility that the INTERPHONE and
Swedish studies may have been affected by recall bias.
Some witnesses emphasized the need for cancer data collection. As Dr. Sears explained,
The data collection for cancers is usually done by
the Canadian Cancer Society and StatsCan, but it's very, very crude data that
they're bringing together. For instance, you can find data since 1992 on brain
tumours and [the] central nervous system, but you can't find glioma or
something like that. Hardell could do his studies because in Sweden they were
collecting very specific data, and they've been collecting it for ages.
Andrew Adams from Health Canada indicated that he was “not aware of
databases that Health Canada has established to look at cancers and perhaps
clusters, but I think there is a question of jurisdiction here that would have
to be considered as well.”
Considering the evidence it heard with respect to the potential
carcinogenicity of RF exposure from wireless devices such as cell phones, as
well as the need for better data collection relating to cancer incidence and
cell phone use, the Committee therefore recommends
That the Government of Canada, in collaboration with the health
departments of the provinces and territories, examine existing cancer data
collection methods to improve the collection of information relating to
wireless device use and cancer.
Dr. Devra Davis, President and Founder of Environmental Health
Trust, discussed studies relating to the effects of RF exposure on sperm.
Effects of cell phone radiation on sperm included decreasing the number of live
sperm and damaging sperm’s motility. Sperm exposed to a laptop were also damaged. Dr. Davis also referenced a study that found that middle-aged male rats that
were exposed to a computer-generated mobile phone signal for two hours per day
for 45 days had lower testosterone levels and decreased fertility. Dr. Meg Sears also referenced a study that demonstrated that sperm exposed to
cell phone radiation stop swimming, have damaged DNA and die.
Martha Herbert, Assistant Professor of Neurology at Harvard Medical
School, Massachusetts General Hospital, explained to the Committee that
the alterations in cell chemistry and physiology
that have been identified in autism have virtually all been documented as
affective electromagnetic frequencies including radio frequency radiation.
Other environmental exposures and genetic vulnerabilities may also contribute
to this impairment of cell function, but the cumulative effect, the total load
of these environmental stressors, is likely to be what causes autism and
triggers or exacerbates its challenging behaviours, and we can do something
about the contribution of electromagnetic fields.
One of the recommendations made by the Expert Panel was that Health
Canada “investigate the problems of individuals with what's called
electromagnetic hypersensitivity … with the aim of understanding their health
conditions and finding ways to provide effective treatment.” As Dr. Magda Havas explained to the Committee:
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.
Dr. Riina Bray, Medical Director of the Environmental Health Clinic
at the Women’s College Hospital, noted that the number of diagnosed cases of
EHS has increased dramatically in the last 10 years and that many individuals
who are sensitive to EMF “find everyday life and work difficult and
uncomfortable.” Symptoms can come
on quickly and can require as long as a day to recover from, depending on the
She also stated that there was a need for better
collection of data and better education for physicians relating to the effects
of EMF and the condition of EHS, pointing to the
Austrian Medical Society (which published a report on diagnosis and treatment
of EHS patients) as an example of a physician initiative. C4ST also highlighted the need to collect better information and
better educate physicians. Andrew Adams stated that consumers who have complaints relating to
RF fields created by cell phones can use the Canadian consumer product safety
A number of briefs outlined individual struggles
with EHS. One individual who wrote to the Committee anonymously indicated
that he had been diagnosed as having EHS at the Environmental Health Clinic in
Despite the fact that the school board has three
letters of diagnosis and answers to difficult questions it posed about my
functional disability, the school board nor the union have made any
accommodations for me in the work place. This is because our board cites Safety
Code 6 as being protective enough, and relies on it, despite my physical
ailments due to ongoing exposure.
I have been suffering the ill health effects from
low level microwave radiation for over 4 years now since the school board had
18 to 19 WiFi routers installed in every school, and my symptoms have increased
in severity and frequency.
Tammy Beck also shared her EHS experience in a letter to the
My symptoms include incredible headaches that
leave me feeling buzzed and unclear for hours after exposure. I have difficulty
concentrating, memory impairment and difficulty sleeping. I feel fatigued and
sometimes dizzy from close or prolonged exposure. EHS is a cumulative illness
and my symptoms are worsening at an alarming rate.
Wi fi and cell phones are everywhere. I cannot go
to the coffee shop with friends or even the grocery store (which now has 17
routers). I cannot step into my children’s schools without instantly feeling
ill, so I am no longer actively involved in school activities and trips, which
greatly disappoints my children.
I have been moody and irritable with my family
because I feel awful a lot of the time and my children and husband do not
deserve this. They are suffering too and it breaks my heart[.]
Prof. Anne-Marie Nicol, who helped with the Expert Panel’s public
consultation, stated that
we need a place for people to go and discuss their
symptoms or the constellations of symptoms. Here in B.C. we have what are
called complex chronic disease clinics. I know in Ontario we have environmental
health clinics. I think these are very important places for people to be
treated and to start to collect data for surveillance.
As an epidemiologist I believe it's important that
we understand what people are exposed to, or their symptoms, so that we can at
least come up with an overall sense of what's going on in this country.
Currently that data is not being collected. In fact, we allow these people to
be shunted from one specialist to another where they get increasingly
frustrated and become incredibly vulnerable to non-medical interventions. I
think, as a society, we need to be doing a better job of addressing these
people who appear to be very seriously affected by this.
A number of recommendations were proposed by witnesses and submitted
in briefs to address EHS-related issues, including:
- having Parliament recognize the physical symptoms of EHS;
- developing a method to track people suffering from EHS;
- recognizing EHS as a functional disability;
- establishing a Canada-wide program to train health care professionals to recognize, diagnose and treat patients with EHS effectively;
- accommodating EHS sufferers in the workplace;
- allocating resources for research for testing, diagnosis and treatment; and
- systematically collecting data relating to EHS (via the Canadian Community Health Survey, having physicians report to the Canadian Institute for Health Information and establishing an on-line reporting system for reporting adverse symptoms and triggers).
The Committee agrees that more research into EHS is needed.
Specifically, the Committee supports the witness recommendation that better
data need to be collected with respect to potential incidences of EHS and that
individuals who have symptoms that they attribute to EHS should be supported by
the health care system. The Committee therefore recommends
That Statistics Canada consider including questions related to
electromagnetic hypersensitivity in the Canadian Community Health Survey.
That the Government of Canada, through the Canadian Institutes of
Health Research, consider funding research into electromagnetic
hypersensitivity testing, diagnosis and treatment, and its possible impacts on
health in the workplace.
That the Canadian Medical Association, the Royal College of
Physicians and Surgeons, the College of Family Physicians of Canada and the
World Health Organization consider updating their guidelines and continuing
education materials regarding the diagnosis and treatment of electromagnetic
hypersensitivity to ensure they are based on the latest scientific evidence and
reflect the symptoms of affected Canadians.
That the Government of Canada continue to provide reasonable
accommodations for environmental sensitivities, including electromagnetic
hypersensitivity, as required under the Canadian Human Rights Act.
That Health Canada ensure the openness and transparency of its
processes for the review of Safety Code 6, so that all Canadians have an
opportunity to be informed about the evidence considered or excluded in such
reviews, that outside experts are provided full information when doing
independent reviews, and that the scientific rationale for any change is
That the Government of Canada establish a system for Canadians to
report potential adverse reactions to radiofrequency fields.
As was mentioned earlier, the Expert Panel had recommended that “the
proposed reference levels in Safety Code 6 be reviewed by Health Canada to make
them somewhat more restrictive in some frequency ranges to ensure a larger
safety margin for Canadians, including newborn infants and children.” Andrew Adams indicated that the Expert Panel’s recommendations “were taken into
consideration when finalizing the revised guideline.”
Martha Herbert pointed to differences between children and adults
with respect to vulnerability to RF exposure: “Children are not little adults.
They are developing, and perturbations during windows of development may have
lifelong repercussions.” Dr. Bray noted that “those at highest risk for EHS include the fetus, children,
the elderly, the infirm, those with predisposing morbidities – usually cardiac
and neurological – and those with a toxic overload.”
Material provided to the Committee by C4ST states that “Safety Code
6 does not provide the extra protection needed for children and pregnant
women.” Carmen Krogh, who recommended that industrial wind energy and solar facilities
should be considered in reviews of Safety Code 6, stated that “[w]hile we have
to be concerned about the general population at large, we would like to see
priorities given to the fetus and neonatal exposure, as well as babies, children,
youth, the elderly, and those with pre-existing medical conditions or disease
and special needs.”
Dr. Havas noted that the nitrogen levels in drinking water are
based on protecting infants, and that Safety Code 6 should follow that example
by “protecting the most sensitive people within our population.”
Witnesses pointed to measures adopted in other countries to protect
vulnerable infants and young children:
- banning Wi-Fi in nurseries and daycares (France);
- prohibiting children under the age of 2 from using electronic devices (Taiwan); and
- prohibiting the sale and marketing of cell phones to children (Belgium).
Given the testimony that vulnerable groups, such as infants and
young children, are being exposed to radiofrequency fields and the fact that
other countries have taken protective measures, the Committee recommends
That an independent scientific body recognized by Health Canada
examine whether measures taken and guidelines provided in other countries, such
as France and Israel, to limit the exposure of vulnerable populations, including
infants, and young children in the school environment, to radiofrequencies
should be adopted in Canada.
Multiple witnesses and many of the briefs that were submitted to
the Committee raised the issue of Wi-Fi in classrooms and schools. As Martin
I particularly worry about the children, because
children are sitting in schools six hours a day, five days a week, subject to
Wi-Fi that's continuously on. That, I think, is something that doesn't have to
be. It may cost a little more to put cables in to supply the same information
in the educational programs, but you certainly don't need Wi-Fi to accomplish
the educational results. I think it's a sin to have this kind of exposure for
children when we don't know if it's safe — and many suspect it is not.
Parents of school-aged children expressed concern about their
children’s exposure to Wi-Fi in school, noting frustration in some cases that their
attempts to reduce this exposure were unsuccessful. In her letter, Kristin
Concerned families across Canada have encouraged
and supported the use of technology in school but asked that boards follow safe
practices by utilizing wired internet as opposed to wireless internet or at
least minimizing use of wireless devices and turning off WiFi routers when not
in use. Unfortunately most Canadian public school boards will not agree to
these requests nor will they agree to educate students on the safety instructions
that come with wireless devices. They are adamant that there is nothing to
worry about because “Health Canada’s Safety Code 6 indicates that radiation
levels from routers and wireless devices are safe for children and there are no
warnings from the Canadian government which would warrant taking precautions.”
Marcey Kliparchuk referred to the Canadian Teachers’ Federation
brief, “The Use of Wi-Fi in Schools” (2014). Ms. Kliparchuk noted that the
brief called for Wi-Fi to be turned off when not in use and that there should
be resources to educate the public about reducing exposure.
To address concerns relating to children’s exposure to Wi-Fi in
schools, some witnesses and briefs also recommended that schools rely on wired
access use. Another
option would be to have Wi-Fi free zones in schools for children who are
sensitive to RF fields or for children whose parents want to limit their
children’s exposure to RF fields.
In a letter to the Committee, Paulette Rende recommended the
establishment of a “National Wireless Device Safety Initiative for
Schoolchildren (and all Canadians),” and Dorethy Luyks recommended that “radiation and electric field measurements
need to be monitored in our schools and communities to meet safety standards.” Malini Menon stated that “Health Canada should be issuing precautionary
directives to provincial education authorities, and strongly discouraging the
use of all forms of wireless technology in schools.” She also noted that Israel has established daily and weekly RF exposure limits
for children in grades one to three. Kristin Morrison made a similar recommendation, noting that school boards
should “educate youth on the importance of using technology safely.” Dr. Bray suggested that there should be legislation “to have hard-wiring
The Committee agrees that children in schools should be protected
from unnecessary exposure to wireless technology, particularly when alternative
technologies exist. The Committee therefore recommends
That the Government of Canada develop an awareness campaign
relating to the safe use of wireless technologies, such as cell phones and
Wi-Fi, in key environments such as the school and home to ensure that Canadian
families and children are reducing risks related to radiofrequency exposure.
The vast majority of witnesses and briefs recommended lowering the RF
exposure limits in Safety Code 6. While no one made recommendations with
respect to the actual levels that they would like to see included in Safety
Code 6, witnesses referenced countries that had adopted lower levels (Russia,
China, Italy and Switzerland). Those witnesses also focused on the need for
Health Canada to adopt a precautionary approach when establishing the safe RF
exposure limits contained in Safety Code 6. C4ST
recommends that “Health Canada be instructed to recommend precautionary
approaches regarding exposures to electromagnetic radiation from wireless
communications devices that are as Low as Reasonably Achievable (ALARA).”
Prof. Leszczynski explained that European Union criteria relating
to the precautionary principle “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.
Frank Clegg from Canadians for Safe Technology pointed out to the Committee
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 [therefore] be recommended until the
science proves beyond reasonable doubt that there is no potential for harm.
Anthony Miller noted:
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.
Dr. Bray suggested that it is imperative to use precaution and put
protective measures in place rather than wait for more studies.
As was mentioned earlier, Paul Demers noted that the panel
concluded that Safety Code 6 avoided established health effects.
Those individuals who were of the opinion that Safety Code 6’s
current levels are sufficiently protective and that greater precaution is
unwarranted included Prof. Tarzwell, Bernard Lord and Tom Whitney. A brief from the U.S.-based Telecommunications Industry Association recommends
that some exposure limits in Safety Code 6 are, in fact, too restrictive and
are no longer consistent with international standards. Bernard Lord stated that “[the precautionary approach] is applied by the
standards that are set by Safety Code 6 and Health Canada.”
One brief noted the concern that “Safety Code 6 does not adequately
deal with Near and Intermediate Field Radiation.”
Many witnesses and briefs referred to the need for more research
into the effects of exposure to RF fields, including research into EHS (discussed above). As was mentioned earlier, Dr.
Prato noted that the report of the Expert Panel on Safety Code 6 also
recommended that Health Canada pursue research relating to the effects of RF
exposure at levels below the limits in Safety Code 6.
Dr. Demers stated that, in the Expert Panel’s report, “each section
on a particular health effect usually ends by basically pointing out that more
research is needed on that health effect.” Dr. Prato also stated that research is still needed with respect to non‑thermal
effects of RF exposure.
Dr. Sears stated that environmental health data (both exposures and
health outcomes) and detailed cancer incidence data need to be collected. She
also recommended that “Health Canada … systematically access, assess and act
upon all the science from scratch. It needs specific tools as well as
methodological and library expertise to accomplish this.” C4ST recommended that “Health Canada conduct a comprehensive systematic review
according to international best practices of the current scientific evidence on
potential risks to human health caused by EMR.”
Andrew Adams agreed that more research is needed into the potential
link between RF fields and carcinogenicity, and Bernard Lord stated that the CWTA “… continue[s] to support and encourage
more scientific research, if it is warranted and desired.”
The Committee agrees that a more careful review of the existing
literature relating to the potential link between RF fields and carcinogenicity
is needed and that further research into the possibility of such a link also
needs to be examined. The Committee therefore recommends
That Health Canada conduct a comprehensive review of all existing
literature relating to radiofrequency fields and carcinogenicity based on
international best practices.
That the Government of Canada, through the Canadian Institutes of
Health Research, consider funding research into the link between radiofrequency
fields and potential health effects such as cancer, genetic damage,
infertility, impairment to development and behaviour, harmful effects to eyes
and on the brain, cardiovascular, biological and biochemical effects.
Prof. Nicol referred to the need for greater awareness of RF fields
on the part of the general public:
On the topic of exposure, it's very clear that
most people have very little understanding of what radio frequency is. Most
people do not realize that this is a question of proximity. They're very
concerned about the ubiquity of exposure without an understanding that the
closer a technology is to your body, the more dangerous it possibly could be to
you. This is a question of proximity and a question of education. Given the
ubiquity of radio frequency in our society, I do find it amazing that we are
not doing a very good job either in the public school system, or in general, of
discussing what RF is.
Many of the witnesses who wanted to see the safe exposure levels in
Safety Code 6 lowered wanted measures to be taken to increase public awareness
about the potential risks of exposure to RF. For example, C4ST recommends that
“Health Canada conduct a national campaign to educate Canadians about methods
to minimize exposure to RF radiation,” and the Environmental Health Association of Manitoba recommends the
establishment of public education programs “to make people aware of how to take
preventative measures.” Andrew Adams confirmed that, while information about RF fields is posted on its
website, Health Canada does not “have any programs to educate young people and
families about the effects of electromagnetic fields.”
Some witnesses also proposed ways in which individuals could limit
their exposure to RF. Measures for reducing exposure included
- Keeping cell phones away from the head by using the speaker or air tube earbuds;
- Using wired phones in the home instead of cordless ones;
- Using an Ethernet connection instead of Wi-Fi in the home;
- Putting Wi-Fi on a timer so that it is not on while you are sleeping;
- For children, keeping iPads on “airplane mode” or using an Ethernet connection;
- For pregnant women, keeping wireless devices away from the abdomen; and
- For men, not carrying cell phones in a front pants pocket.
The Committee agrees that the potential risks of exposure to RF
fields are a serious public health issue that needs to be brought to the
attention of Canadians so that they have the knowledge to use wireless devices
responsibly and are able to make decisions about the use of wireless devices in
a manner that protects their health and the health of their families.
Bernard Lord stated that “the wireless sector in Canada as well as
around the world is committed to a completely open process in the study of
health and safety issues related to wireless technologies.” He explained that the sector he represents adheres “to the science based safety
standards enforced by the Government of Canada and set by the Government of
Canada.” Mr. Lord was of the opinion that the standards set by Safety Code 6 “keep us
safe and that when you use the devices under the limits that are set, they are
believed to be safe in Canada and around the world.” He indicated that it would
be easy to comply with “not advertising devices to a certain group of the
In a follow-up response to Mr. Lord’s appearance, Kurt Eby,
Director of Regulatory Affairs and Government Relations for the Canadian
Wireless Telecommunications Association, stated that “CWTA is not aware [of]
any country where the wireless industry had to make any significant or
widespread adjustments to comply with existing or new EMF emission
Frank Clegg proposed that industry needs to be challenged to come
up with effective ways to work:
We have technology in Europe. The industry is not
jamming it or trying to go through the process to get it into Canada because
they don't need to. The industry will respond, it will react, and it will act
responsibly if we set the challenge in front of it. I think we're missing that
opportunity to go to the industry to lower the standards on Safety Code 6. If
we did that, industry would react and provide better products.
If you go to the technology industry and tell them
they are no longer allowed to sell wireless tablet devices to schools, you will
immediately have many solutions that are wired. So challenge. I'm asking the
community to challenge my industry to do a better job.
Devra Davis noted that “Industry has advice about how to use [tablets],
and I applaud them because recently they've become more forthright with advice
… about how to use these things safely.”
Witnesses, including Magda Havas, noted that European consumers can
purchase cordless phones and baby monitors that are voice-activated rather than
being on and emitting RF radiation 24 hours a day. The Committee heard that
these types of devices are not available in the United States or Canada.
Given some of the concerns expressed by witnesses relating to the
use of radiation emitting devices by children, the Committee recommends
That the Government of Canada and manufacturers consider policy
measures regarding the marketing of radiation emitting devices to children
under the age of 14, in order to ensure they are aware of the health risks and
how they can be avoided.