According to the state of Washington Department of Health website:

“A Washington resident concerned about the safety of Wi-Fi in schools asked the Washington State Department of Health and the Office of the Superintendent of Public Instruction to review research about health effects from Wi-Fi devices.

The two agencies reviewed all summary documents published in English by national or international health agencies since 2000.  The reviewed documents included a thorough review of scientific literature on some aspect of human exposure to radiofrequency (RF) fields. Wi-Fi devices generate RF fields, as do cell phones, cell towers, radar, microwaves, and radio and TV broadcasts.  None of the 16 documents reviewed found evidence that low levels of RF fields have any adverse health effects in humans. …  [emphasis added]

The state Department of Public Health has issued a draft report the concludes that “based on current evidence, the low level RF exposure produced by Wi-Fi is unlikely to pose a health risk.”

“Washington residents are invited to submit comments…” on the draft document which is Responding to Wi-Fi Safety Concerns in Our Schools-working draft (PDF).

“Public comments and questions will be accepted until 5 p.m. Monday, March 3, 2014.”

SkyVision Solutions would like to put forward the assertion that the state of Washington draft report on Wi-Fi safety is extremely limited in scope, biased, and flawed in several respects.

1.  Limited Scope of Review

The scope of review was limited to summary reports from purported national and international “health agencies” that were published in English.  Among the organizations recognized as a “health agency” in the draft report is the International Commission on Non-Ionizing Radiation Protection (ICNIRP).  The ICNIRP is not an agency but a self-constituted non-governmental organization that only recognizes biological effects due to a thermal mechanism in the face of overwhelming evidence that biological effects consistently occur below the level needed to induce thermal effects.

The draft report excludes a considerable body of evidence based upon independent expert opinion, peer-reviewed articles, and credible governmental and non-governmental organizational positions on the topic of Wi-Fi radiofrequency (RF) radiation emissions that in many instances clearly indicate hazards related to Wi-Fi exposure in schools.  As an example, in November 2013, the American Academy of Environmental Medicine (AAEM) issued a position on “Wireless Radiofrequency Radiation in Schools” that includes the following language:

“The AAEM strongly supports the use of wired Internet connections and encourages avoidance of radiofrequency [radiation] such as from Wi-Fi, cellular and mobile phones and towers, and ‘smart meters’.

The peer reviewed, scientific literature demonstrates the correlation between RF exposure and neurological, cardiac, and pulmonary disease as well as reproductive and developmental disorders, immune dysfunction, cancer and other health conditions. …

In May 2011 the World Health Organization elevated exposure to wireless radiation, including WiFi, into the Class 2b list of Carcinogens; recent research strengthens the level of evidence regarding carcinogenicity.

There is consistent, emerging science that shows people, especially children who are more vulnerable due to developing brains and thinner skulls, are being affected by the increasing exposure to wireless radiation.

In September 2010, the Journal of the American Society for Reproductive Medicine-Fertility and Sterility, reported that only four hours of exposure to a standard laptop using WiFi caused DNA damage to human sperm. …

With WiFi in public facilities as well as schools, children would be exposed to WiFi for unprecedented periods of time, for their entire childhood.  Some of these signals will be much more powerful than would be received at home, due to the need for the signals to go through thick walls and to serve many computers simultaneously.  Signals in institutions are dozens of times more powerful than café and restaurant systems.”

2.  Improper Technical Conclusions

The state of Washington draft report makes an improper technical conclusion that any possible adverse health effects related to cell phones could not extend to Wi-Fi because they are supposedly of much lower power density as compared to cell phones.  Specifically, the preliminary (draft) conclusion is:  “Although there is some uncertainty regarding the possible effects of cell phones, which expose users to RF fields with much higher power density, there is little uncertainty regarding health effects of the low levels of RF produced by Wi-Fi equipment.” [emphasis added]

The above conclusion ignores at least four relevant points:

• There have been more research studies conducted related to cell phone radiation exposure and thus more results to review that might indicate health effects.  A relative lack of extensive studies for Wi-Fi should not give reassurance of safety.

• Wi-Fi exposure in schools would be considered chronic in nature as opposed to intermittent cell phone use; thus over time, it is quite possible that total exposure to RF energy for individuals would exceed that due to cell phone exposure.

• Cell phone use is a voluntary experience while mandated Wi-Fi exposure would an involuntary exposure to RF emissions to an entire young and vulnerable population group.  Involuntary exposure to an entire population group deserves consideration of more stringent requirements.

• Especially for chronic exposure, the “power density” of the RF emissions may not be the most important biological parameter, but rather the nature of the signal in terms of modulation and intermittence of the signal may be more important than total field intensity values.  As stated in The BioInitiative Report 2012:  “There is increasing reason to believe that the critical factor for biologic significance is the intermittent pulse of RF, not the time-averaged SAR [specific absorption rate].”

3.  Unsubstantiated and Biased Statements

The state of Washington draft report contains unsubstantiated and thus biased, non-conservative statements.  The most obvious example is that in referencing the “IARC Working Group on the Evaluation of Carcinogenic Risks to Humans. Non-ionizing radiation, Part II: Radiofrequency electromagnetic fields, vol. 102,” the draft report makes the following statement:

“(p. 419) ‘Radiofrequency electromagnetic fields are possibly carcinogenic to humans (Group 2B).’  There was no evidence that environmental exposure [i.e. RF from cell towers and radio/TV transmitters] causes cancer.”

Although the first sentence above is a quote from the IARC document, the second sentence is not.  In fact, the second sentence represents biased commentary and conflicts with the overall intent of the IARC Group 2B declaration as stipulated on page 33 of the IARC document as follows:

“The topic of this Monograph is the evaluation of the carcinogenicity of radiation in the radiofrequency (RF) range (30 kHz to 300 GHz) of the electromagnetic spectrum.  This type of radiation is emitted by devices used in wireless telecommunication, including mobile phones, and by many other sources in occupational and general environmental settings. … it should be emphasized that the evaluations in this volume address the general question of whether RF radiation causes cancer in humans or in experimental animals: it does not specifically or exclusively consider mobile phones, but rather the type of radiation emitted by mobile phones and various other sources.” [emphasis added]

Thus, the WHO’s IARC Monograph for non-ionizing radiation addresses all RF emission types including Wi-Fi, and it is totally improper to suggest that the document provides no evidence that “environmental exposure” could cause cancer.

4.  Comments Requested Solely from State of Washington Residents

The state of Washington is inviting comments on the draft document solely from “Washington residents,” thereby possibly excluding (or at least deterring) much of the expert relevant opinion that might otherwise be provided to the state for consideration.

5.  Report Does Not Acknowledge Use of the Precautionary Approach

Even though some of the reviewed documents were acknowledged as showing adverse health effects, they were dismissed and described as not providing “clear and consistent evidence.”  This perspective is based upon a binary simplistic logic; is non-conservative from a public health protection viewpoint; and does not acknowledge utilizing a precautionary approach when limited evidence exists for adverse health effects but where the actual magnitude of the risks cannot be determined with certainty.

It is noted that the term precautionary principle is defined on the last page of the draft report in “Appendix B: Glossary” (in a somewhat ambiguous manner), but that is the only instance where the term appears in the document.

In general, the draft document ignores reality by not mentioning or addressing the actions being taken elsewhere in the world in accordance with a precautionary approach to limit exposure of both teachers and children to Wi-Fi emissions in schools, such as described at the following link:
http://www.wifi-in-schools-australia.org/p/worldwide.html.

In addition, by not reviewing relevant documents that may have been written in a language other than English, the working group responsible for the draft report may have missed many documents including the Israeli “Position Paper on Electromagnetic Radiation in a School Environment” written in 2010 in Hebrew (available at: http://tinyurl.com/64ptqvj) and which partially translates as follows:

[Updated, July 2015:  During a review of this webpage, it was noted that the above link is no longer displaying the desired document; an alternate archival link where the same information can be viewed is here:  Position Paper on Electromagnetic Radiation in a School Environment.]

“The use of WLAN, Wi-Fi and Laptops by Teachers and Students

Background:

The International Telecommunication Union, a specialized agency of the United Nations (UN), has set a goal of providing access to knowledge through High Speed Information and Technology Communication Systems in all schools throughout the world.

Several methods can be used to achieve this goal.  One of them uses routers and laptops which communicate via wireless networks (WLAN and Wi-Fi).  Wireless networks communicate using transmission and reception of radio frequencies (RF), which are a form of non-ionizing radiation.

In April 2009, the European Parliament, by a majority of 559-22, adopted decision ENVI/6/65496, regarding potential adverse health effects associated with electromagnetic radiation (EMF).  The decision declared that wireless technology (which includes cell phones, Bluetooth, Wi-Fi and cordless phones) emit electromagnetic radiation which may impose danger to human health.  The decision states that it is important for schools to be as ‘clean’ as possible from electromagnetic radiation. [emphasis added]

Furthermore, most computer use in schools is done in set and predetermined places, i.e., desks.

Problems with the educational institutions in Israel:

Around the world, as well as in Israel, the use of laptops and Internet in schools is growing.  Many schools are choosing to use wireless networks as the preferred Internet access system, and their use exposes students to electromagnetic radiation.

It should be remembered that the school population comprises children and youth, a group with unique characteristics:

• In general, for all carcinogens, including ionizing radiation, and for most cancer sites, an inverse association exists between age at time of exposure, and the risk of becoming sick.  Therefore, this population should be regarded as a sensitive population in comparison to the adult population.

• The student population is expected to live for many years, during which diseases with long latency periods may develop.

• The student population is obligated by law to attend school.  Moreover, in most cases the students and their parents do not have a choice regarding which school and which classes the student will attend.

Method of Operation:

It is agreed by all, that the education system and the country are under a moral and legal obligation to protect the health of the students.

It is agreed that the precautionary principle should be adopted as it was adopted in the Non-Ionizing Radiation Act of 2006.  The principles upon which the Health Ministry based its guidelines regarding cell phones and cordless phones should also be applied to wireless network systems.

These principles should be adopted in order to achieve a balance between the needs and the potential adverse health risks from exposure to Wi-Fi and WLAN in this special population in which the exposure is forced.

Since there are alternative ways to establish computer networks which are safer and do not require exposure to RF, such as the use of wired technology by connecting directly to a internet-allocated socket, there is no reason to use wireless technologies such as WLAN and Wi-Fi for computer networks in schools.” [emphasis added]

6.  Additional Information

The people preparing the state of Washington report on Wi-Fi safety in schools could benefit by studying material at the link entitled, “Wi-Fi in Schools (formerly Expert Opposition to the Los Angeles Public Schools Wi-Fi Policy)” at:
http://www.saferemr.com/2013/03/opposition-to-los-angeles-public.html, where it provides considerable evidence to support the conclusion that:

“Many health experts have raised serious concerns about exposing students to wireless radiation in school because no research proves that long-term exposure to low intensity, microwave radiation is safe for children.  Moreover, a considerable amount of research published in peer-reviewed journals strongly suggests that wireless radiation from laptops and other wireless devices (including cell phones and cordless phones) is harmful to health.”

7.  Conclusion

On the subject of Wi-Fi and based upon the available evidence, SkyVision Solutions shares the position taken by the American Academy of Environmental Medicine (AAEM):

“To install Wi-Fi in schools plus public spaces risks a widespread public health hazard that the medical system is not yet prepared to address. … It is better to exercise caution and substitute with a safe alternate such as a wired connection.  While more research is being conducted, children must be protected.  Wired technology is not only safer; it [is] more secure.”