Letters to and from Dr Mike Clark, UK HPA

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Sep 24, 2007, 4:27:43 PM9/24/07
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WiFi In Schools

Letters to and from Dr Mike Clark

Spokesperson FOR HPA Radiation Protection Division


The letter below was emailed to Dr Mike Clark of the Health Protection Agency on 17th September in response to his reply (copied below this letter) to my original letter to him some months before.

In my letter below I have highlighted key points in Dr Clark’s reply that I think will be of general interest. 

My original letter, copied below his reply, includes a statement of my intent to copy both that letter and his reply to other interested parties, and my understanding that he would be agreeable to any reply that he sent being disseminated in this way.  There is of course no breach of confidentiality or ethics in making public text which Dr Clark sent in full knowledge that it would be made public - he had the option of stating that he wouldn’t want to comment under such circumstances.

Dr Grahame Blackwell



Dear Dr Clark

Thank you for your recent response to my letter received by you almost three months ago.  I'm only sorry that it has taken no less than three follow-up recorded-delivery letters, plus a specific request written on my behalf by my local MP, to elicit a response from the spokesperson for a national advisory body.

I'm rather disappointed also that, despite all the time you've taken to reply, you don't appear to have squarely addressed any of the points that I raised in my letter nor have you answered any of my questions.  In particular you have signally failed to answer the question posed at the end of that letter: Given your reported confirmation that we are "all guinea pigs in some multi-billion pound commercial experiment", are we to understand that you and your colleagues at the HPA are in agreement with the nation’s children becoming the youngest, arguably the most vulnerable and probably the most thoroughly exposed guinea pigs in that commercial experiment?

This is far from being a frivolous question.  Both the Stewart Report and the follow-up NRPB (now HPA-RPD) Report warned of “scientific evidence … which suggests that there may be biological effects occurring at exposures below [ICNIRP] guidelines.”  The Spectrum Management Advisory Group, which reports directly to government ministers, states in its Position Paper on WiFi that “Note should be taken of the recommendations in the Stewart Report on Health Effects in the Use of Mobile Phones” and “Adaptive r.f. power control should be an important part of system design, thereby minimising the overall level of r.f. energy emitted.”

These cautionary observations on the health issue, including one from your own organization, do not sit well with advice from that same body that there is “no reason why schools and others should not use WiFi equipment.”  Your stand appears remarkably similar to that of the officials of Amity Island (of ‘Jaws’ fame): “Yes, there have been reported sightings of a great white shark in the bay - but there’s absolutely no reason why your kids shouldn’t go out swimming.”

I note that you have been highly selective – and somewhat obvious – in your choice of wording in your response to my letter.  For example, you have avoided my quote from HPA advice on use of WiFi in schools (copied above) in favour of a different sentence that includes the phrase continue to be used in schools” [my emphasis].  This gives the impression that your advice is aimed only at schools that already have WiFi installed, which is demonstrably not the case, as evidenced above.

You likewise refer to remarks attributed to Lawrie Challis in relation to definite non-thermal effects” [my emphasis].  I have never seen, or made, any such remark.  If you read my letter again you’ll see that I refer to Prof Challis’ apparent concern about possible non-thermal effects.  The fact that you chose to modify my wording makes it clear to me that you’re not willing to squarely face the fact that I’m highlighting.

Similarly, in respect of my illustrative examples on aspects of response to evidence, you choose to address a totally different issue from the one I have raised.  I can easily believe that you can’t see the relevance of my example of sexual activity not producing a ‘consistent’ effect in terms of pregnancy – but I think that even all those schoolchildren who, on your advice, are being subjected to unproven and potentially harmful technology would see from that example the ludicrousness of the HPA’s apparent position that biological cause-and-effect has to be ‘consistent’ in order to be credible.

I’m frankly baffled by your assertion that “We need to look at all the evidence not just the biological.”  What other words did you have in mind?  Financial?  Political?  Dr Clark, we’re looking here at effects on living organisms – this is a biological issue, pure and simple.  Anyone who can’t see that surely has no place in a so-called ‘Health Protection Agency’.

You also say “Biological evidence may be indicative but it is not conclusive”.  Conclusive of what, exactly?  Are you saying that, because research evidence to date is ‘indicative’ of a possible health hazard but not ‘conclusive’, you will continue to encourage LEAs to unreservedly irradiate a whole generation of schoolchildren?

You further say “apart from heating, there is no accepted biological effect caused by wireless signals that can be replicated.”  In this casual throwaway you appear to summarily dismiss quality peer-reviewed replicated research showing reduction of melatonin production at sub-thermal levels of RF exposure, also the multiply-replicated findings of a number of partners across Europe, in the EU-funded REFLEX Project, of single- and double-strand DNA breaks also at sub-thermal levels of exposure.  Both of these findings, supported by a raft of anecdotal evidence of effects, are accepted by a wide body of scientific opinion across the world – if not by the HPA.  Whilst the REFLEX team are properly cautious about what they have and have not shown, they make no bones about the likely implications for human health – and it is a replicated biological effect, contrary to your assertion.

[In passing I’d observe that misdirected guesses at what I “seem to be assuming” are both unhelpful and unscientific.]

You say that “there is no ambiguity in what HPA advises now and what was said in the Stewart Report in 2000.”  At risk of repeating myself, I’d say that “scientific evidence … which suggests … biological effects … below these guidelines.” is not exactly consistent with no reason why schools and others should not use WiFi equipment.” [ my emphasis]

You also say that HPA advice “is consistent with advice from most other authorities world-wide.”  It appears that doesn’t include Germany, whose Environment Ministry has recommended that people should keep their exposure to radiation from Wi-Fi (and phones) as low as possible by choosing conventional wired connections.  It’s interesting to note that this advice comes direct from the German equivalent of your own organization.  Not exactly a technologically backward country, Germany, is it?

Finally, the BioInitiative Report, released last month, blows a major hole in the HPA’s reassurances on RF emissions.  This Report has been drawn up by fourteen world-class researchers and leading figures in this field, including no less than three former Presidents of the Bioelectromagnetics Society – the top research society in the world on this subject.  For the UK HPA to take issue with the findings of such an august group would be akin to a local parish council standing in judgment on a statement from the United Nations.

The report provides detailed scientific information on health impacts from exposure hundreds or even thousands of times below FCC (US) and ICNIRP guidelines. The authors reviewed more than 2000 scientific studies and reviews, and concluded that existing public safety limits are inadequate to protect public health.  To ignore such authoritative findings could be considered culpable negligence.  I note that the European Environment Agency has seen fit to issue a call for immediate action to reduce exposure from WiFi, mobile phones and masts, in stark contrast to the HPA’s apparent complacency.  I note also that a report commissioned by the Australian Democrats has identified a wide variety of conditions that may be caused by phone & mast emissions, and calls for a ban on mobile phone antennae near homes or schools.

I should be truly glad if you'd prove me wrong by following the lead set by Germany and the EEA.

Yours sincerely

Dr Grahame Blackwell

Footnote (not included in my letter to Dr Clark)

There have been no known studies on WiFi published, but the Times Educational Supplement recently (30 March 2007) published details of an unpublished Report by the UK educational technology agency, BECTA, on a study carried out by them seven years ago. According to the TES, the Report said that the radiation produced by any device involving wireless technology raised health and safety questions. The TES quotes the Report: "During the testing carried out by Becta, which involved using at least six sets of equipment simultaneously, some engineers complained of headaches at the end of the working day. But whether this is due to exposure to radio waves or some other factor is unclear." Apparently Mike Clark’s observation on this was "A problem with very common symptoms such as headaches is that they can be caused by many things." The fact that this symptom was reported by a number of engineers specifically in relation to their testing of WiFi (otherwise it wouldn’t be in the Report - these are professionals we’re talking about) appears to have slipped past this custodian of the nation’s health - including the health of its children.


From: Mike Clark

To: Dr Grahame Blackwell

Sent: Thursday, September 06, 2007 4:10 PM

Subject: RE: HPA position on WiFi


Dear Dr Blackwell

I am replying to your "open letter" received here on June 22 and subsequently by various routes.

First, HPA advice on the possible health effects from wireless is published, evidence-based and clear. It is consistent with advice from most other authorities world-wide. Second, there is no ambiguity in what HPA advises now and what was said in the Stewart Report in 2000.

Regarding WiFi, the HPA website states, "On the basis of the studies so far carried out in house, the Agency sees no reason why WiFi should not continue to be used in schools. However with any new technology it is a sensible precautionary approach, as happened with mobile phones, to keep the situation under ongoing review so that parents and others can have as much reassurance as possible. That is why our Chairman, Sir William Stewart, has stated it would be timely to carry out further studies as this new technology is rolled out. The Health Protection Agency is discussing this with relevant parties." Given the evidence available before and since 2000, this is a consistent precautionary approach.

In your letter you concentrate on evidence for biological effects. Biological evidence may be indicative but it is not conclusive, especially when results cannot be replicated in other laboratories. We need to look at all the evidence not just the biological. In any case, apart from heating, there is no accepted biological effect caused by wireless signals that can be replicated. Compliance with ICNIRP guidelines avoids any chance of heating and, at the much lower levels used by WiFi, there are no biological effects that are widely accepted and are replicable. You seem to be assuming that any laboratory in-vitro finding anywhere could be indicative of a serious health effect and demands action from health authorities. If this was the case, you could be advised not to drink chilled water. It can have dramatic in-vitro (i.e., biological) effects.

You refer to some reported remarks by Professor Challis and some alleged concerns of his. I understand that Professor Challis feels his remarks were taken out of context by the Daily Telegraph. As a result, some sensible precautionary advice has been misinterpreted as evidence of a concern about definite non-thermal effects.

On the points you raise about assessing possible new health risks and their cause, your analogy with bubonic plague is very misplaced. The plague had distinct symptoms and the disease had obvious fatal consequences. There are no such effects from wireless. Then you introduce a causality argument based on the outcome of sexual intercourse. I do not see the relevance of this nor is it appropriate in my view.

Yours sincerely 

Michael Clark 

Dr Michael Clark

Health Protection Agency



Oxon OX11 0RQ




Open Letter to Dr Mike Clark

(Spokesperson for the Health Protection Agency – Radiation Protection Division)

On the Subject of WiFi in Schools

15th June 2007

Dear Dr Clark

I’m writing to you in your capacity as spokesperson for the HPA-RPD in the hope of obtaining clarification on what appears to be an ambiguous position held by that body in respect of possible biological effects of WiFi signals – particularly in relation to usage in schools.

I note that the HPA website carries a page entitled ‘WiFi Summary’.  This appears to be a response to various recent media expressions of public concerns in respect of this technology, especially in respect of its possible impact on schoolchildren.  The final sentence of that summary reads: There is no consistent evidence of health effects from RF exposures below guideline levels and no reason why schools and others should not use WiFi equipment.”

You will no doubt be aware that various public bodies, including notably local education authorities, take pronouncements by the HPA as the definitive statement on such matters; I was told as much just yesterday by representatives from a local authority department concerned with deployment of WiFi in schools.  I understand that they take this position irrespective of any scientific evidence to the contrary, since yours is the government-appointed advisory body on such matters.  It follows, whether you would wish it or not, that the HPA-RPD is answerable for national deployment of WiFi in schools.

I would now refer you to an observation made first in the Stewart Report (April 2000) and repeated by your organisation (under its former title of National Radiological Protection Board) in Autumn 2004.  In the Executive Summary of your report ‘Mobile Phones and Health’, your Board stated:

“The balance of evidence suggests that exposures to radiation below NRPB and ICNIRP guidelines do not cause adverse health effects to the general population.

“There is now scientific evidence, however, which suggests that there may be biological effects occurring at exposures below these guidelines.

“We conclude therefore that it is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach.”

It’s most puzzling that the NRPB/HPA can (along with numerous others) recognise the existence of scientific evidence of biological effects below national guidelines, can explicitly acknowledge that exposures at levels below those guidelines may possibly lead to adverse health effects – and yet that same body can confidently assert, without any caveats, that “there is … no reason why schools and others should not use WiFi equipment.”  This despite the fact that children were specifically identified in the Stewart Report as one of the groups most vulnerable to those possible adverse health effects.  [It should be added that WiFi signals are very similar in nature and frequency to those considered in that Report].

I’m also more than a little puzzled at the fact that the NRPB/HPA recommends a Precautionary Approach specifically because the ICNIRP guidelines are potentially inadequate – but seems quite content for our government to use those suspect guidelines as their chosen ‘ precaution’ against their own shortcomings!

As you know the ICNIRP guidelines provide effective protection against surface shocks and short-term heating effects – and only against those effects.  Those biological effects at levels below ICNIRP are therefore, almost by definition, not thermal effects.  This is explicitly recognized in the Stewart Report, which refers in places to evidence of biological effects at power levels “too low to cause significant heating” – if these were thermal effects then that heating would by definition be ‘significant’.

This point is highlighted specifically in respect of WiFi by Professor Lawrie Challis, head of the government’s Mobile Telecommunications Health Research programme.  Professor Challis has recently been widely reported as advising against children using WiFi-enabled laptops on their laps.  It’s beyond doubt that every laptop in use in this country conforms with the ICNIRP guidelines and therefore poses absolutely no threat from any form of heat-based effect (Prof Challis is not reported as in any way suggesting that he was referring to illicit non-ICNIRP-compliant equipment).

It follows that the head of the MTHR programme, who has a very thorough knowledge of research in this field, apparently has concerns over possible non-thermal effects.  Obviously any such effects will be totally different in terms of their action on living organisms from thermal effects, so any references to thermal-based guidelines are totally irrelevant to such a potential hazard.  Even such terms as ‘thousands of times below’ have no meaning – think of size-based criteria to filter out threats from terrorists in the form of guns or bombs, then consider how effective such criteria might be against a virus attack.

It’s also inappropriate, as has been done, to cast doubt on a potential hazard on the basis that no clear causal mechanism can be identified.  Medical history is littered with such situations, for example the role of fleas on rats in the spread of bubonic plague was identified and addressed long before a causal mechanism was known.  Likewise the HPA’s repeated reference to “no consistent evidence” is wholly inappropriate: if ten young women had regular sexual relations with their partners for six months and at the end of that time five of them were pregnant and five were not, would the HPA regard that as ‘inconsistent’ and therefore question the causative role of those sexual activities in producing those pregnancies?  There are countless other examples in the field of biological causation.

In short, if there is any plausible evidence of any non-thermal effects from this type of radiation – and there are peer-reviewed replicated studies showing such effects, some referred to in the Stewart Report – then non-thermal interaction of this type of radiation with living tissue becomes a possibility.  At that point the ICNIRP guidelines become irrelevant, any supposed protection for ourselves and our children becomes a pious hope and the level of emissions which can be considered safe becomes anybody’s guess.

In autumn 2004, when asked in a press interview “Are we all guinea pigs in some global multi-billion pound commercial experiment?”, your response as quoted was “In a way, yes, we are.  (Sunday Times, 3/10/04, referring to mobile telecommunications emissions very similar to those used in WiFi).  Are we to understand that you and your colleagues at the HPA are in agreement with the nation’s children becoming the youngest, arguably the most vulnerable and probably the most thoroughly exposed guinea pigs in that commercial experiment?

[I shall in due course copy this letter to a number of groups that share my concerns over these questions and will be most interested to know your response, which I will also copy to them all.  As the spokesperson for an advisory body I’m confident that you’ll be agreeable to your advice being disseminated in this way.]


Yours sincerely


Dr Grahame Blackwell



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