On February 4, 2014, SCENIHR* published a “Preliminary Opinion on Potential Health Effects of Exposure to Electromagnetic fields (EMF).”  This is an update to a 2009 opinion.  This preliminary opinion was published in February with comments due April 16, 2014.

*SCENIHR is the European Union’s Scientific Committee on Emerging and Newly Identified Health Risks.

The BioInitiative Working Group provided comments on the 2014 SCENIHR preliminary opinion document, and these comments are quite comprehensive.  The purpose of this blog article is to focus on how the Working Group has demonstrated the tendency for the SCENIHR (and by extrapolation other scientific groups) to consistently not document the “potential” for EMF caused effects, even when such effects are well established.

As written in the BioInitiative Working Group comments:

“The [SCENIHR] Committee has not answered the question it was appointed to investigate.  There is no conclusion in the Executive Summary on whether the Committee determined that possible health effects of EMF are established for childhood leukemia and exist for genotoxicity, for neurological effects, for brain tumors, male fertility, fetal and neonatal effects or other key areas of research.

The title of the Opinion is ‘Preliminary Opinion on Possible Effects of Electromagnetic Fields (EMF) on Human Health’ (emphasis added).  The Committee has given an answer to a different question, limiting its conclusions to whether certainty or causal effect is established. …  This Opinion is better titled ‘Preliminary Opinion on Scientific Certainty of Health Harm from Electromagnetic Fields (EMF).’

… This report is not useful for the purpose intended due to the ambiguous basis for judging the sufficiency of the scientific evidence, which will eventually form a basis for concluding whether changes in the ICNIRP standards are warranted.  The lack of a clear statement about the basis for judging what constitutes sufficient evidence of ‘Possible Effects’, and the embedded up-shifting language to instead require a demonstration of ‘conclusive or unequivocal evidence’.”

Exhibit A of the BioInitiative Working Group comments is entitled, “Consistent Failure to Identify the Potential for Health Effects.”  Here are some quotes from that Exhibit:

“The evaluative language quoted below indicates the disparity between what was asked of the authors (to identify Possible Effects of EMF) and what they eventually chose to use as a basis for their analysis process that no change in the [exposure] standards is warranted at this time.

SIXTEEN (16) instances of ‘no causal evidence’ or ‘prevents a causal interpretation’ or ‘is not causally linked’ or ‘not informative for causal linkage’.

THREE (3) instances of ‘does not provide convincing evidence’.

THREE (3) instances of ‘not definitive’.

SEVEN (7) instances of ‘do not unequivocally indicate’.

These criteria are inconsistent with a review that is titled ‘Possible Effects’.  Further, the approach in judging the emerging evidence is inconsistent with the charter of the Scientific Committee to give advice needed for ‘consumer safety, public health and the environment on new or emerging problems.’  Some statements acknowledge important new evidence of effect; yet then shift the burden of proof to a higher level requiring that adverse health effect, a known mechanism, a causal level of evidence be conclusively demonstrated, or physical evidence of harm be demonstrated.  There is nothing in the report that says the authors were directed to provide proof of effect (or consistent indications, or consistent demonstration of effect; or consistent support for, or certainty of effects) at levels below ICNIRP limits.  With the same flawed approach in drawing conclusions from emerging science as demonstrated by the SCENIHR, hardly any environmental or occupational condition would be qualified as an emerging or newly identified health risk. …

There is a serious consequence which comes from dismissing effects linking EMF/RFR exposures reported in scientific studies to an ‘all or none’ finding by using embedded criteria that demand ‘causal’ or ‘conclusive’ or ‘definitive’ or ‘consistent demonstration of effect’.  It is clear that such erasing possible impacts of great global health consequence will chill public health responses that would otherwise occur if the correct standards for judging the evidence were used in this Opinion.  Public health activities hinge on not causality but sufficiency of evidence to warrant a proportionate preventative action in line with established precautionary principles.  This draft Opinion provides no guidance in this area.” [emphasis added]

The overall comments of the Working Group (after providing considerable additional evidence from what is given above) conclude with the following statement:

“All of these comments and criticisms argue most strongly for a conclusion in the SCENIHR Final Opinion on EMF that health effects are possible, and in some cases such effects are established.”

SkyVision Solutions Commentary:  The lesson here is that multiple organizations whether it be the European Union’s SCENIHR, the Expert Panel of the Royal Society of Canada, the Maine Public Utility Commission, the wireless industry, the smart grid industry, individual utility companies, or other organizations somehow related to the wireless industry perform almost a bait and switch.  They may in fact talk about scientific studies showing biological effects or adverse effects caused by EMF exposure but then when making a conclusion that might require some action if possible or actual effects were acknowledged, they suddenly declare that nothing conclusive was found.  There can only be one possible reason for this seemingly irrational behavior; … they don’t want any action taken to protect the public.  Now the motives behind this behavior can be varied:  conflicts of interest, political agendas, money, scientific bias, etc.  But the effect is the same. …  Inaction and a misinformed, possibly endangered public.