Issue(s): Environmental assessment, human health/environmental health,
and science and technology
Petitioner(s): Frank Woodcock
Date Received: 4 January 2008
Status: Reply (replies) pending
Summary: The petitioner is concerned about the guidelines of Safety Code
6 after a cellular tower was installed 300 metres from his property,
without any public consultation. The petitioner is concerned about the
health effects of the microwave radiation emanating from this tower. He
is asking Health Canada and Industry Canada whether it is safe to be
exposed to electromagnetic radiation.
Federal Departments Responsible for Reply: Health Canada, Industry Canada
35 Tyrell St. Simcoe, ON N3Y2H2 January 3, 2008
The Auditor General of Canada Commissioner of the Environment and
240 Sparks St. Ottawa, ON K1A 0G6
Please accept the following petition under the Auditor General Act.
My neighbours, my family and I live within 300 metres of the Union
Street water tower supporting a cell tower. We have lived in the
neighbourhood for many years prior to the surprise erection of this cell
tower. We are concerned about the health effects of the microwave
radiation emanating from this tower and have been unable to find any
official, whether municipal, provincial or federal, who can guarantee
our physical safety. Also within 300 metres of this cell tower are a
school, a nursing home and a hospital.
I have sought help from the Minister of Health Canada, our local school
board, the Haldimand/Norfolk health unit, my MPP, my MP, the Director of
the Consumer and Clinical Radiation Protection Bureau of Canada and the
Director of the Central and Western Ontario District of Industry Canada,
with other bureaucrats in between. Throughout this process there has
been no official willing to guarantee the safety of living within 300
metres of this cell tower.
I asked Malcolm S. Lock, Acting Medical Officer of Health,
Haldimand-Norfolk Health Unit, "As medical officer of health I request
your looking into medical complaints in my neighbourhood. His response,
"The Health Unit has not been advised of any health issues within city
limits. Everyone within the municipality is serviced by the municipal
water supply with potable water therefore ground water contamination is
not an issue for consumption. To my knowledge there has been no air
quality issues reported. This leaves little within the jurisdictions of
the Health Unit to investigate. I would remind you that air quality lies
within the purview of the Ministry of Environment as does ground soil
Canadians are supposed to be protected from electromagnetic radiation
(EMR) by Safety Code 6 (SC6), a guideline under the supervision of the
Consumer and Clinical Radiation Protection Bureau of Canada (CCRPB)
under the leadership of [name withheld]. When I asked [name withheld] if
health issues relating to the cell tower were Health Canada's (HC)
purview, he replied, ".this is a public health issue that needs to be
1) Who is responsible for the health of individuals affected by
proximity to a cell tower?
[Name withheld] stated, "As indicated previously, this is a public
health question that needs to be addressed locally. From your earlier
correspondence I understand that you have raised this with the city.
While they may not be able to attribute cause to any symptoms or
illnesses reported by the residents, it seems to me reasonable that they
can survey and validate the claims stated by the citizens. Analysis of
the symptoms, pattern of illness etc. would add to the understanding of
2) Considering the health concerns of the community within the vicinity
of the Simcoe cell tower, would HC provide continuous health monitoring
of nearby citizens?
When asked if it is safe to live within 300 metres of a cell tower,
[name withheld] replied, "In all risk assessment scenarios, one looks to
establish levels that are hazardous or dangerous as these are relatively
easily determined. One first chooses an adverse health outcome for which
a known mechanism of interaction of the hazardous agent exists and then
a determination of the level of exposure that will cause the outcome is
made. The final step is to set exposure limits that will be protective
against these particular adverse health outcomes. In subsequent
monitoring and review of the emerging science around the hazard under
consideration, one strives to confirm or modify as necessary these
previously determined levels. This is, in simple terms, the approach
taken in establishing the levels indicated in the current standard for
exposure limits for wireless communication devices.
In the specific issue at hand, the exposure limits for radiation fields
arising from wireless communication towers have been determined in the
manner outlined above taking into consideration the collective body of
peer-reviewed science. No adverse health outcomes that have an accepted
causal relationship to exposure to the electric and magnetic fields
produced by the towers have been identified for exposures at or below
the limits set out in SC6."
3) I do not consider [name withheld] response an adequate answer and
would simplify the question by rephrasing, "Are the residents in the
vicinity of the Union Street Cell Tower in Simcoe, Ontario as safe today
as they were before the cell tower was enabled?"
According to the SC6 document posted on the government website, it has
not been updated since 1999. Given the very recent explosion in
popularity of cell phones, wireless internet, and other such devices, it
is probably not an exaggeration to estimate that we are now being
exposed to levels of electromagnetic radiation at levels thousands of
times higher than we were in 1999.
4a) Why has SC6 not been updated since 1999? If it has not been updated,
4b) If it has been updated does it include any of the above findings?
The particular cell tower in question is atop a water tower. I assume
[name withheld] scientists have taken water towers into account in SC6.
This water tower is also a 3042 watt microwave cell tower. Water flows
in and out of the water tower like a river. This river is encased in
metal, almost an inside-out parabola. The water is flowing in this large
metal case (refer to SC6 about large metal objects). The case is
encircled with electricity going to the eight antennae. A microwave dish
is attached to the tower. Microwaves constantly bombard the water tower.
All this is in the middle of a residential community that includes a
hospital, nursing home and elementary school.
5a) I ask Industry Canada (IC) and HC if such a tower is safe from a
physics, electrical,.point of view?
5b) Would such a tower meet IEEE standards?
5c) Is it grounded properly?
5d) Who has verified the grounding?
5e) What part do metal objects play in the reflection of microwaves?
5f) Why does SC6 warn against large metal objects and then place a
microwave on a large metal object?
5g) What is the appropriate SC6 signage for such a structure?
5h) Is this tower properly signed?
5i) What is the appropriate SC6 fencing for such a structure?
5j) Has such fencing been installed?
5k) What part does flowing water play in the reflection of microwaves?
Residents in Bayview, Long Island, NY, have gone to the Supreme Court
over a cell tower located near a park and school. Four Bayville Primary
School children have been diagnosed with leukemia or brain tumors; three
of the children have since died. In addition, six teachers and several
school aids have been diagnosed with serious cancer. Four of the adults
have subsequently died.
Dr. Andrew Goldsworthy, Biological Sciences, writes, "Being exposed to
chronic irradiation from a cell tower is not a good idea anyway, but to
put the antennas on water towers is particularly bad because of the risk
of electromagnetic contamination of the water. Treating water with weak
pulsed electromagnetic radiation is the basis of many commercial
"electronic water conditioners", which are now widely used to remove and
prevent lime scale in plumbing.
But it also has biological effects. Brief exposure of the water to such
fields (as when it flows through a conditioner) and supplying it to
yeast, plants and farm animals can, stimulate their growth. However,
when we tested exposures of more than about a minute (as it might be in
a water storage tank with an antenna attached), we found that it
inhibited the growth of yeast and was arguably harmful (See Goldsworthy
et al. 1999 "Biological effects of physically conditioned water". Water
Research 33 (7) 1618-1626).
The mechanism of the conditioning effect is controversial, but it
appears to depend on the presence of colloidal impurities, and not all
water supplies are equally affected. Its biological effect is probably
because it removes structurally-important calcium ions from cell
membranes in much the same way as it removes lime scale from plumbing.
This would then make them leak and affect metabolism in the same way as
direct exposure to electromagnetic fields (See http://tinyurl.com/28Lo82 ).
In so much as water treated with pulsed electromagnetic radiation can
have unusual and sometimes harmful biological effects, there should be a
moratorium on placing cell phone antennas on water tanks until
electromagnetically treated water has received full FDA approval."
6a) Is HC aware of Dr. Goldsworthy's work?
6b) Why is his work not included in SC6?
6c) Why does Industry Canada give preference to siting cell towers on
6d) What science does Industry Canada cite for such a preference?
The residents were never consulted on the siting of the cell tower and
many have become ill, many seek medical attention and are on
medications. [Name withheld] SC6 tells us the tower is safe. Our bodies
tell us differently. Soon after the tower was erected, one family was
forced from their home due to illness. Their home lies within the shadow
of the tower. The husband has been diagnosed with
electro-hypersensitivity (EHS) by a specialist. [Name withheld] and his
scientists will tell you that EHS sufferers have not been proven
sensitive to low-level radiation.
Is it within the Canadian Government's ethical standards to erect such a
Whereas Safety Code 6 is 8 years old and in dire need of being updated,
the BioInitiative Report (2007) is a very recent document compiled by an
international working group of scientists, researchers and public health
policy professionals. The document presents serious scientific concerns
about current limits that regulate exposure to EMFs from power lines,
cell phones, and many other sources. The excerpt below gives an
excellent overview of the current problem:
"You cannot see it, taste it or smell it, but it is one of the most
pervasive environmental exposures in industrialized countries today.
Electromagnetic radiation (EMR) or electromagnetic fields (EMFs) are the
terms that broadly describe exposures created by the vast array of wired
and wireless technologies that have altered the landscape of our lives
in countless beneficial ways. However, these technologies were designed
to maximize energy efficiency and convenience; not with biological
effects on people in mind. Based on new studies, there is growing
evidence among scientists and the public about possible health risks
associated with these technologies.
Human beings are bioelectrical systems. Our hearts and brains are
regulated by internal bioelectrical signals. Environmental exposures to
artificial EMFs can interact with fundamental biological processes in
the human body. In some cases, this can cause discomfort and disease.
Since World War II, the background level of EMF from electrical sources
has risen exponentially, most recently by the soaring popularity of
wireless technologies such as cell phones (two billion and counting in
2006), cordless phones, WI-FI and WI-MAX networks. Several decades of
international scientific research confirm that EMFs are biologically
active in animals and in humans, which could have major public health
Today's public exposure limits for telecommunications are based on the
presumption that heating of tissue (for RF) or induced electric currents
in the body (for ELF) are the only concerns when living organisms are
exposed to RF. These exposures can create tissue heating that is well
known to be harmful in even very short-term doses. As such, thermal
limits do serve a purpose. For example, for people whose occupations
require them to work around radar facilities or RF heat-sealers, or for
people who install and service wireless antenna tower, thermally-based
limits are necessary to prevent damage from heating (or, in the case of
power-frequency ELF from induced current flow in tissues).
In the past, scientists and engineers developed exposure standards for
electromagnetic radiation based on what we now believe are faulty
assumptions that the right way to measure how much non-ionizing energy
humans can tolerate (how much exposure) without harm is to measure only
the heating of tissue (RF) or induced currents in the body (ELF).
In the last few decades, it has been established beyond any reasonable
doubt that bioeffects and some adverse health effects occur at far lower
levels of RF and ELF exposure where no heating (or induced currents)
occurs at all; some effects are shown to occur at several hundred
thousand times below the existing public safety limits where heating is
7a) Does the CCRPB agree with the above statements?
7b) What in particular causes the disagreement and how can the
disagreement be proved 100%, with no doubts?
Speaking earlier this year in San Francisco, Dr. M Havas said, "The
Federal Communications Commission (FCC) (22) Guideline is similar to the
international guideline ICNIRP guideline (15) and is based on short-term
thermal effects. This guideline is based on the assumption that if
microwave energy does not heat tissue it is not harmful. This assumption
is incorrect. Adverse biological effects have been documented at levels
below federal guidelines and there are no federal guidelines for
non-thermal effects, nor are there guidelines for long-term exposure.
The technological developments and uses of wireless devices are running
well ahead of the policy decisions necessary to ensure their safety."
According to Norbert Hankin, Environmental Scientist, U.S. Environmental
"The U.S. Federal Communications Commission, (FCC's) exposure guidelines
is considered protective of effects arising from a thermal mechanism but
not from all possible mechanisms. Therefore, the generalization by many
that the guidelines protect human beings from harm by any or all
mechanisms is not justified."
Organizations that set safety standards such as ANSI/IEEE or ICNIRP are
quick to point out that "safe" radio frequency exposure rests on the
fact that exposure is too weak to produce a rise in body temperature, or
a "thermal" effect. Whether non-thermal effects occur is no longer the
issue, the issue is at what level do these non-thermal effects occur and
what are the safe levels of long-term exposure."
8a) Does SC6 take into account non-thermal effects and long term exposure?
8b) What are the studies to back this claim?
Canada is subject to guidelines enforced by Industry Canada but
generated by HC under the document SC6. There are only 3 sentences
referencing biological effects in the whole document. It references
biological effects thus: "Biological effects of RF fields at levels too
low to produce significant heating have also been reviewed (3,6). These
effects are not well established, nor are their implications for human
health sufficiently well understood. Thus, they cannot provide a basis
for making recommendation towards the restriction of human exposures to
such low-intensity RF fields."
9) In a document as important to the safety of Canadians as SC6, why are
there only 3 sentences referring to biological effects? How in the light
of all the studies can it be said, "These effects are not well
established, nor are their implications for human health sufficiently
Their references 3 and 6 are as follows:
3) World Health Organization. Environmental Health Criteria 137:
Electromagnetic Fields (300 Hz - 300 GHz), 1993 (Available from: WHO,
Geneva, or Canadian Public Health Association, Ottawa, Ontario)
6) M.H. Repacholi. Low-Level Exposure to Radiofrequency Fields: Health
Effects and Research Needs. Bioelectromagnetics, Vol. 19, pp. 1-19, 1998.
10) With the biological effects of radiation so important, how can a
document as important as SC6 have only two references to biological
Note the first reference is dated 1993 and both involve Dr. Michael
Repacholi. In the first study he was chairman of the study while at the
Royal Adelaide Hospital, the second study while heading the Project into
EMFs by the WHO. He was also emeritus chairman of ICNIRP, the body
charged with setting "safe" International Exposure limits.
While leading the WHO EMF project Repacholi funneled industry donated
money through the Royal Adelaide Hospital to the WHO. Seven years ago,
Norm Sandler, a Motorola spokesman said, "This is the process for all
supporters of the WHO program." At the time Motorola was sending $50,000
each year and the Mobile Manufacturers Forum gave the project $150,000 a
year. (Microwave News)
A WHO Progress Report lists its funding as follows: Income: $249,682
Governments, $529,820 others, for a total USD of $779,502. If the
"Others" listed above were sourced from the Royal Adelaide Hospital
(industry), then only less than 1/3 of the WHO EMF funding came from
Governments around the world." (Microwave News)
Despite the UK Health Protection Agency's own advice that children under
16 should use mobile phones and other wireless equipment as little as
possible because they are more prone to harm from them, Dr. Repacholi
promoted wireless/microwave emitting devices to children at the Handheld
Learning Conference, 10-12 October, 2007 in London, England.
11a) Mr. Repacholi was chairman of the Royal Adelaide Hospital studies,
WHO studies, and chairman emeritus of ICNIRP. He has had great influence
on world-wide standards for EMFs. Mr. Repacholi has ties to Industry.
Did Mr. Repacholi at any time work for HC?
11b) What was his position?
11c) What influence did he have in the creation of SC6?
In a correspondence [name and position withheld], HC, wrote, "SC6 limits
are based on both thermal and non-thermal effects. For frequencies from
3 kHz to 100 kHz, the biological endpoint on which the limits are based
is nerve and muscle stimulation. Although these are acute effects, they
are non-thermal in nature. At higher frequencies, non-thermal effects
have not been convincingly demonstrated. Thus, they have not been
accepted by either this Bureau or other international bodies such as
ICNIRP and IEEE to be used as a basis for setting exposure limits. SC6
is protective of the identified non-thermal effect indicated above."
12a) Are there frequencies below 3kHz? What happens biologically at
frequencies below 3 kHz?
12b) Exactly how is SC6 protective of non-thermal effects?
[Name wihheld] also says, "In addition, the biological tests that have
been used in our examination of non-thermal effects are standard
toxicological assays that are used throughout the scientific world for
examining the effects of a multitude of environmental toxins. They are
used primarily to detect damage to the genetic material in cells exposed
to toxic agents. Before each test is applied, it is checked for
sensitivity against agents such as a known dose of x-rays, which has a
clearly defined and quantifiable effect on the genetic material in the
cells. In this way, it is assured that the tests are able to detect any
damage to the cells caused by electromagnetic radiation." And, "To date,
experimental and epidemiological studies throughout the world have
failed to provide clear support for a causal relationship between
electromagnetic fields and complaints. The experimental studies strongly
suggest that EHS symptoms are not related to actual exposures to
electric or magnetic fields, and that electromagnetically hypersensitive
individuals are no better than non-hypersensitive individuals in
detecting the presence of EMF. EHS has no clear diagnostic criteria and
there is no scientific basis to link electromagnetic hypersensitivity
symptoms to EMF exposure.
At this time, neither HC nor the WHO recognize that symptoms attributed
to EHS from low-level RF fields (as located around cell towers) are
causally related to RF field exposure."
13a) I ask HC to name 3 such studies.
13b) What part did industry play in these studies?
13c) What was the background of the scientists running the study? Did
any of them have a background in EHS?
13d) Did any of the scientists suffer and therefore understand EHS?
13e) Why would anyone with EHS put themselves through the pain of a study?
13f) Were EHS sufferers consulted on the design of the study?
13g) Most importantly, how many EHS dropped out of the study? How did
these drop-outs influence the results of the study?
In the report, "Electrohypersensitivity (EHS) in the Netherlands - A
Questionnaire survey" by Hugo Schooneveld and Juliette Kuiper of the
Dutch Electrohypersensitivity (EHS) Foundation, December 2007, they
state "Some persons have become electrosensitive and respond to some
specific EMFs in their environment and show some of the possible health
effects induced by their personal stress system.One of the main problems
is that many people with EHS symptoms have no idea which type of EMF -if
any- is specifically annoying to him or her. This is caused by the
length of time usually elapsing between EMF exposure and health effect:
several hours is not unusual (Schooneveld and Arends-Zimmermann, 2006).
One simply does not see the connection.The point never contemplated so
far is that EHS is a problem of the individual, not of a group. We all
tend to expect the classical picture of an illness: much like measles
would make the skin of children appear reddish, and influenza would
elevate body temperature, we expect a similar marker for EHS. An obvious
marker apparently does not exist so far and we should perhaps stop
looking for physically recognizable signs of EHS.There have been quite a
few studies in which EMF sensitive and non-sensitive volunteers were
exposed to high-frequency EMFs, signals mimicking those of GSM or UMTS
transmitters. The question was whether EHS people could demonstrate
-under controlled conditions- that they could `feel' whether the
transmitter was `on' or `off''.The outcome was mostly negative and
authors like Rubin et al. (2006) and others conclude that there was no
evidence for an EMF-feeling talent. The present data show that the
situation is more complex: not all EHS people will react to
high-frequency EMFs. In future experiments, more attention should be
paid to the specific conditions under which EHS can be demonstrated by
individual volunteers.Therefore, it seems essential that volunteers
participating in such studies should be selected with care and
questioned in detail about their personal experiences. Exposure
conditions should be adjusted to those individual preferences."
14) Were the above characteristics of EHS sufferers taken into account
in the EHS studies cited by [name withheld]?
As mentioned, soon after the tower was erected, one family was forced
from their home within the shadow of the tower. The husband has been
diagnosed with electro-hypersensitivity (EHS) by specialists. [Name
withheld] and his scientists will tell you that EHS sufferers have not
been proven sensitive to low-level radiation. [Name withheld] states
that "At this time, neither HC nor the WHO recognize that symptoms
attributed to EHS from low-level RF fields (as located around cell
towers) are causally related to RF field exposure."
15) When a family is forced from their home due to policies set forth by
HC and implemented by IC, what government instituted recourse do they
have to regain their family home?
In 1998, 1/3 of Canadian households owned a computer and today the
figure is 70%. Canadian cell phone users have increased from 98,000 in
1987 to 18,000,000 to-day (Ottawa Citizen). In 1999, worldwide there
were 86.1 million cell phones (World Almanac and book of facts
2001.571). 3 billion are in use today (Reuters). Although I have no
statistics for Toronto, the city of San Francisco, with an area of only
seven square miles, has over 2,500 licensed cell phone antennas
positioned at 530 locations throughout the city. In practical terms,
this city, like thousands of others, is being wave-nuked 24 hours day.
16a) How many towers were in Canada in Jan 2000? How many towers are in
Canada today? How many towers are projected for Canada in 2010?
16b) How many people are subjected to cell tower radiation ˝ hour a day;
8 hours a day and 24 hours a day?
Of the references used in Safety Code 6, 29 are from the 1990's, 14 from
the 1980's and 6 pre 1980. There are no references beyond the year 2000
when Canada experienced an explosion of cell tower construction. Of the
references in Magda Havas' paper, 17 are dated between 2000-2004, 20 in
the 1990's and 3 are from between 1988-89.
17a) Why are there so few studies referenced in SC6?
17b) When is the next published update?
The following studies are not referenced in SC6.
1) Santini et al. (2002). A study of the health of people living in the
vicinity of mobile phone base stations. Pathologie Biologies, 50,
369-373 Investigation on the health of people living near mobile
telephone relay stations: Incidence according to distance and sex.
A survey study, using questionnaire was conducted in 530 people (270
men, 260 women) living or not in the vicinity of cellular phone base
stations, on 18 Non Specific Health Symptoms. Comparisons of complaints
frequencies (CHI-SQUARE test with Yates correction) in relation with
distance from base station and sex, show significant (p < 0.05) increase
as compared to people living > 300 m or not exposed to base station,
till 300 m for tiredness, 200 m for headache, sleep disturbance,
discomfort, etc. 100 m for irritability, depression, loss of memory,
dizziness, libido decrease, etc. Women significantly more often than men
(p < 0.05) complained of headache, nausea, loss of appetite, sleep
disturbance, depression, discomfort and visual perturbations. This first
study on symptoms experienced by people living in vicinity of base
stations shows that, in view of radioprotection, minimal distance of
people from cellular phone base stations should not be < 300 m.
2) Naila Study, Germany (November 2004) - see
http://www.tetrawatch.net/papers/naila.pdf . The influence of being
physically near to a cell phone transmission mast on the incidences of
The result of the study shows that the proportion of newly developing
cancer cases was significantly higher among those patients who had lived
during the past ten years at a distance of up to 400 metres from the
cellular transmitter site, which bas been in operation since 1993,
compared to those patients living further away, and that the patients
fell ill on average 8 years earlier.
In the years 1999-2004, i.e. after five years' operation of the
transmitting installation, the relative risk of getting cancer had
trebled for the residents of the area in the proximity of the
installation compared to the inhabitants of Naila outside the area.
3) Ecolog, 2000, T-Mobile\Ecolog Institute - Mobile Communications and
health; review of current scientific research in view of precautionary
This review of over 220 peer-reviewed and published papers found strong
indications for the cancer-initiating and cancer-promoting effects of
high frequency electromagnetic fields used by mobile telephone
technology. Experiments on cell cultures at power flux densities much
lower than the guidelines, yielded strong indications for genotoxic
effects of these fields, like single and double stranded DNA breaks and
damage to chromosomes. The findings that high frequency electromagnetic
fields influence cell transformation, cell growth promotion and cell
communication also point on a carcinogenic potential of the fields used
for mobile telephony. The study also found teratogenic effects (birth
deformities) and loss of fertility in animal studies. Moreover,
disruptions of other cellular processes, like the synthesis of proteins
and the control of cell functions by enzymes, have been demonstrated.
4) BioInitiative Report, Aug, 2007 - An international working group of
scientists, researchers and public health policy professionals (The
BioInitiative Working Group) released a report on electromagnetic fields
(EMF) and health. They document serious scientific concerns about
current limits regulating how much EMF is allowable from power lines,
cell phones, and many other sources of EMF exposure in daily life. The
report concludes the existing standards for public safety are inadequate
to protect public health.
18) When will these studies be reflected in SC6?
According to [name withheld], "SC6 limits are based on both thermal and
non-thermal effects. For frequencies from 3 kHz to 100 kHz, the
biological endpoint on which the limits are based is nerve and muscle
stimulation. Although these are acute effects, they are non-thermal in
nature. At higher frequencies, non-thermal effects have not been
convincingly demonstrated. Thus, they have not been accepted by either
this Bureau or other international bodies such as ICNIRP and IEEE to be
used as a basis for setting exposure limits. SC6 is protective of the
identified non-thermal effect indicated above."
19) How does HC reconcile [name withheld] words with the above studies?
[Name withheld] makes the claim that studies are considered as long as
they are "referenced in the context of peer-reviewed publications".
20a) Why are the studies listed in the above ignored?
20b) They are all valid studies, and they all show biological effects at
levels many, many times below Safety Code 6. I would like an explanation
as to why the studies listed above have not played a role in informing
Of the studies referenced in SC6, all before 2000, there are no
acknowledgements of EHS symptoms relating to EMR.
Regarding EHS, Dr. Havas writes, "Symptoms of EHS include: cognitive
dysfunction (memory, concentration, problem-solving); balance, dizziness
& vertigo; facial flushing, skin rash; chest pressure, rapid heart rate;
depression, anxiety, irritability, frustration, temper; fatigue, sleep
disruptions; body aches, headaches; ringing in the ear (tinnitus) and
are consistent with chronic fatigue and fibromyalgia.
`Electro hypersensitivity (EHS) is now recognized by the World Health
Organization (WHO) and is defined as: ". . . a phenomenon where
individuals experience adverse health effects while using or being in
the vicinity of devices emanating electric, magnetic, or electromagnetic
fields (EMFs). . . Whatever its cause, EHS is a real and sometimes a
debilitating problem for the affected persons, while the level of EMF in
their neighborhood is no greater than is encountered in normal living
environments. Their exposures are generally several orders of magnitude
under the limits in internationally accepted standards.'
EHS is classified as a disability in Sweden and health care facilities
with low exposure to electromagnetic fields and radio frequency
radiation are available for sensitive individuals. Approximately 2%
(more probably 3%) of the population has severe symptoms of EHS. These
people are unable to live in our modern society with its electrical and
electronic appliances and with the increasing exposure to radio
frequency radiation. Another 35% of the population has moderate symptoms
represented by an impaired immune system and by chronic illness."
21) On what basis can SC6 ignore these facts?
Canada's population is 33,000,000. 2% is 660,000, 35% is 11,550,000. If
we just consider the 2% who are highly sensitive, their illness will
surely bring them to their physicians. Let's say they only visit their
doctors once. That is 660,000 visits to the doctor. If the doctor
prescribes medication, there will be a further 660,000 visits to renew
whatever medication is prescribed. Multiply this by the length of time
the patient is on medication and we are talking about a lot of medical
visits at great cost to Canada.
22) What is the cost to the Canadian health care system of EHS? Why are
there no statistics on the cost to the Canadian health care system of EHS?
I have neighbours within 300 metres of a cell tower who are not in the
2% of the highly sensitive and they visit their doctors concerning
cognitive dysfunction (memory, concentration, problem-solving); balance,
dizziness & vertigo; facial flushing, skin rash; chest pressure, rapid
heart rate; depression, anxiety, irritability, frustration, temper;
fatigue, poor sleep; body aches, headaches; ringing in the ear
(tinnitus) and are consistent with chronic fatigue and fibromyalgia.
23) Why are there no HC initiatives to recognize EHS? What is HC doing
to inform the general public and physicians of EHS?
The Santini, Naila, Ecolog and BioInitiative studies are just the tip of
a multitude of similar studies. The Bioinitiative Reoprt alone has over
600 pages and 1387 references covering multiple topics relating to
electromagnetic radiation (EMR) or electromagnetic fields (EMF's).
24) I have talked to CCRPB's scientists and they pooh-pooh these
studies. They can cite opposing views, and yet by conceding the
existence of opposing views, is it not logical to conclude that doubt
exists in the science?
When it was pointed out that Palm Beach County, FL., Greece, New
Zealand, and the state of California all prohibit cellular antennas near
schools due to safety concerns, [name withheld] replied "Certain
municipalities and states have chosen to implement more restrictive
measures than current science-based exposure limits. These decisions are
often based on social policy considerations."
25) If the precautionary principle is referred to by [name withheld] as
"social policy considerations" why are we not taking it into account in
Canada as well?
It is because of this doubt I reference the precautionary principle.
The precautionary principle is a moral and political principle which
states that if an action or policy might cause severe or irreversible
harm to the public, in the absence of a scientific consensus that harm
would not ensue, the burden of proof falls on those who would advocate
taking the action. As taken from the Canadian government pamphlet on the
precautionary principle - http://www.ec.gc.ca/econom/pamphlet_e.htm ,
"The precautionary approach recognizes that the absence of full
scientific certainty shall not be used as a reason to postpone decisions
where there is a risk of serious or irreversible harm. Even though
scientific information may be inconclusive, decisions have to be made to
meet society's expectations that risks be addressed and living standards
26) Was the precautionary principle used in the formulation of SC6?
The Vorsorgeprinzip, or "foresight" principle, only emerged as a
specific policy tool during the German debates on the possible role of
air pollution as a cause of "forest death" in the 1970-80s. However,
[name withheld], one of Bush's science policy advisors, and trenchant
critic of the precautionary principle, has noted that:
"Precaution, whether or not described as a formal principle, has served
mankind well in the past and the history of public health instructs us
to keep the spirit of precaution alive and well". ([Name withheld] 2002).
[Name withheld] might have been thinking of the cholera episode of 1854
when precaution did indeed serve the people of London well. Dr. John
Snow, a London physician, used the spirit of precaution to advise
banning access to the polluted water of the Broad St. pump which he
suspected was the cause of the cholera outbreak. He based his
recommendation on the evidence he had been accumulating for some years
including his study of S. London populations served by both piped and
well water. Snow's views on cholera causation were not shared by The
Royal College of Physicians who considered Snow's thesis and rejected it
as `untenable' as they and other "authorities" of the day believed that
cholera was caused by airborne contamination. It took 30 years of
further scientific inquiry. Such a long time lag between acknowledging
compelling associations and understanding their mechanisms of action is
a common feature of scientific inquiry, as the histories of TBT, PCBs,
DES, the Great Lakes pollution, beef hormones and the other cases in the
EEA report illustrate.
The Broad St. pump, TBT, DES, PCBs and Great Lakes Pollution examples
described here also serve to illustrate the contingent nature of
knowledge. Today's scientific certainties can be tomorrow's mistakes,
and today's research can both reduce and increase scientific
uncertainties, as the boundaries of the "known" and the unknown expand.
Waiting for the results of more research before taking action to reduce
threatening exposures may not only take decades but the new knowledge
may identify previously unknown sources of both uncertainty and
ignorance, as awareness of what we do not know expands, thereby
supplying further reasons for inaction. "Paralysis by Analysis " can
then follow. "The more we know, the more we realize what we don't know"
is not an uncommon scientific experience. Socrates observed some time
ago: "I am the wisest man alive, for I know one thing, and that is that
I know nothing". (Plato's Apology 1.21).
Some measures that could help limit the consequences of ignorance and
the impacts of surprises are:
a.. using intrinsic properties as generic predictors for unknown but
possible impacts e.g. the persistence, bioaccumulation and spatial range
potential of chemical substances. (Stroebe et al., 2004) b.. reducing
specific exposures to potentially harmful agents on the basis of
credible `early warnings' of initial harmful impacts, thus limiting the
size of any other `surprise' impacts from the same agent, such as the
asbestos cancers that followed asbestosis; and the PCB
neurotoxicological effects that followed its wildlife impacts. c..
promoting a diversity of robust and adaptable technological and social
options to meet needs, which limits technological `monopolies' (such as
those like asbestos, CFCs, PCBs etc.), and therefore reduces the scale
of any `surprise' from any one technological option. d.. using more
long-term research and monitoring of what appear to be "surprise
sensitive sentinels", such as frogs and fetuses.
27a) Does HC use intrinsic properties as generic predictors for unknown
but possible impacts e.g. the persistence, bioaccumulation and spatial
range potential of chemical substances when formulating SC6?
27b) Does HC reduce specific exposures to potentially harmful agents on
the basis of credible `early warnings' of initial harmful impacts, thus
limiting the size of any other `surprise' impacts from the same agent,
such as the asbestos cancers that followed asbestosis; and the PCB
neurotoxicological effects that followed its wildlife impacts when
27c) Does HC promote a diversity of robust and adaptable technological
and social options to meet needs, which limits technological
`monopolies' (such as those like asbestos, CFCs, PCBs etc.), and
therefore reduces the scale of any `surprise' from any one technological
option when formulating SC6?
27d) Does HC use more long-term research and monitoring of what appear
to be "surprise sensitive sentinels", such as frogs and fetuses when
The distinction between prevention and precaution is also important.
Preventing hazards from "known" risks is relatively easy and does not
Banning smoking, or asbestos, today requires only acts of prevention to
avoid the well-known risks. However, it would have needed precaution,
(or foresight, based on a sufficiency of evidence), to have justified
acts to avoid exposure to the then uncertain hazards of asbestos in the
1930s -50s, or of tobacco smoke in the 1960's). Such precautionary acts
then, if implemented successfully, would have saved many more lives in
Europe than today's bans on asbestos and smoking are doing. As Cogliano
has recently pointed out, the difference between prevention and
precaution can be further illustrated by showing that prevention is used
to justify the restriction of exposure to an IARC Category 1 carcinogen
whereas precaution is necessary to justify restricting exposure to a
Category 2A or B carcinogen, where the evidence is less strong. 
28a) How is foresight used to formulate SC6?
28b) Does the existing strength of evidence justify precautionary
28c) Or will exposure reduction be delayed until the evidence is clear
enough to justify the more belated and overall less protective
prevention of "known" causes, so that EMF replicates the fate of
asbestos, smoking and most of the other cases in the EEA report?
The key to understanding the added value of the PP requires a)
acknowledging the distinction between prevention and precaution
described above; b) an appreciation of the further distinctions between
the primary, secondary and tertiary preventative measures that have long
between adopted in public health, and the prior justification for any
such measure, which the PP brings; and c) a recognition of the increased
legitimacy and transparency that arises from the articulation and
adoption of the PP in legal texts, international agreements and
conventions, as opposed to being merely part of general practice.
More empirically, the evidence that many scientific disciples, legal
scholars (de Sadeleer, 2007),and international policymakers, have, since
the 1970s, recognized the need for legitimizing the PP as a new policy
tool that is better able to deal with systems complexities, ignorance
and uncertainties, suggests that the PP brings added value to the
protection of the environment and the public.
There is much discussion generated by the different meanings often
attached to the common terms "prevention", "precaution", "risk",
"uncertainty" and "ignorance".
There are some relatively rare but successful acts of "precautionary
prevention" in the EEA report such as on cholera in1854, on TBT in
France in the 1980s, and on CFCs in the 1970s. Together with the many
other examples of the failure to use the precautionary principle in the
other case studies (EEA, 2001), these illustrate the wisdom of taking
appropriate precautionary actions to avoid plausible and serious threats
to health or environments, especially when the impacts are irreversible
and likely to be much more costly to society than the precautionary
29) The failure to use the precautionary principle in the other case
studies (EEA, 2001), these illustrate the wisdom of taking appropriate
precautionary actions to avoid plausible and serious threats to health
or environments, especially when the impacts are irreversible and likely
to be much more costly to society than the precautionary measures. When
it comes to EMR is there wisdom to change SC6 to reflect new information?
Some commentators have stressed the need for policymakers to take
account of the foreseeable, or plausible, countervailing (secondary)
costs of otherwise genuine precautionary attempts to protect the
environment and health. This consideration of countervailing costs has
long been recognized by the better policymakers, even if it is difficult
in practice to anticipate and account for all consequences of actions.
And of course there are the secondary benefits of precautionary actions
as well, which tend to be less stressed, such as the benefit of reduced
respiratory and cardiovascular disease from the reduced combustion of
fossil fuels: a large and early secondary benefit of that climate change
The outcomes of some controversial actions based on the PP, such as the
EU ban on antibiotics as growth promoters, which is a Late Lessons case
study, have since been scrutinized, and have been considered sound ,or
unsound, depending on the science used and its interpretation by
Any policy effectiveness analysis of measures taken to deal with such
multi-causal and long term hazards as antibiotics as growth promoters is
fraught with methodological difficulties and is hampered by long
latencies and complex biological systems: untangling the causal impact
of one stressor amongst many inter-dependent ones is virtually
impossible. The value of applying more probabilistic and value of
information data to such conundrums is recognized by many risk managers.
However, this cannot remove the need for scientific and political
judgment about how to take appropriate and proportionate action in the
face of irreducible uncertainties, ignorance and plausible hazards which
could have serious, widespread and irreversible impacts and for which
probabilities are not possible at the time when they are most needed.
This is the current case with many EMF exposures. 
30a) Would the CCRPB scientists agree with this statement?
30b) If not, specifically why not?
30c) If yes, specifically what parts of the statement do they agree with?
30d) Does SC6 take into account the foreseeable, or plausible,
countervailing (secondary) costs of otherwise genuine precautionary
attempts to protect the environment and health?
The increasing awareness of complexity and uncertainty during the
1980/90's led to the German debates on the Vorsorgeprinzip shifting to
the international level, initially in the field of conservation (World
Charter for Nature UN 1982), but then particularly in marine pollution,
where an overload of data accompanied an insufficiency of knowledge.
(Marine Pollution Bulletin, 1997) This generated the need to act with
precaution to reduce the large amounts of chemical pollution entering
the North Sea.
Since then many international treaties have included the PP (including
the often cited version from the Third North Sea Ministerial Conference,
1990) reference to the precautionary principle, or, as they refer to it
in the USA, the precautionary approach.
The N. Sea declaration called for "action to avoid potentially damaging
impacts of substances, even where there is no scientific evidence to
prove a causal link between emissions and effects".
This definition has often, and sometimes mischievously, been used to
deride the precautionary principle by claims that it appears to justify
action even when there is "no scientific evidence" that associates
exposures with effects. However, the N. Sea Conference definition
clearly links the words "no scientific evidence" with the words "to
prove a causal link". We have already seen with the Broad St. pump and
TBT examples that there is a significant difference between evidence
about an "association" and evidence that is robust enough to establish a
"causal" link. (Hill, 1965). 
31a) Is there enough evidence to establish a causal link between EMR and
31b) "Where there is uncertainty as to the existence or extent of risks
to human health, the institutions may take protective measures without
having to wait until the reality and seriousness of those risks become
fully apparent" (Christoforou, 2002). Would the CCRPB agree with this
statement? Would the CCRPB take this into account when formulating SC6?
31c) How are developing children taken into account in SC6?
31d) EHS is irreversible, is this irreversibility taken into account in
SC6? If SC6 does not protect from citizens developing EHS, is HC legally
liable? Would scientists who have suppressed this information be legally
liable? Would they be fired?
31e) Is the goal of SC6 to protect public health, consumer safety and
the safety of the environment? Is the consumer given a high, medium or
low "balance of evidence or probability" when formulating SC6
guidelines? Since the broad shoulders of the telecommunications industry
are able to bear the costs of mistaken judgments rather better than the
much narrower shoulders of the injured citizen, should the citizen be
given broader leeway when determining safety standards such as SC6?
31f) Is it possible to use different levels of proof when formulating SC6?
31g) How robust, and over what periods of time, does the evidence on the
absence of harm have to be before concluding that a restricted substance
or activity is without significant risk?
31h) Why is the bias within SC6 towards avoiding "false positives",
thereby generating more "false negatives", and the dominance within
decision-making of short-term, specific, economic and political
interests over the longer term, diffuse, and overall welfare interests
31i) Are HC conducting any long term studies on EMR and young children?
If not, why not?
[Name witheld], July 13, 2007 wrote. "To date, experimental and
epidemiological studies throughout the world have failed to provide
clear support for a causal relationship between electromagnetic fields
Bradford Hill established nine criteria for helping to move from
association to causation in environmental health which have been, and
still are, widely used in debates on issues such as EMF. Two of the
apparently more robust of the "criteria" may not be so robust in the
context of multi-causality, complexity and gene/host variability. For
example, "consistency" of study findings is not always to be expected.
As Prof. Needleman, who provided the first of what could be called the
second generation of early warnings on lead in petrol in 1979 has
observed: It follows that the presence of consistency of results between
studies on the same hazard can provide robust evidence for a causal
link, but the absence of such consistency may not provide very robust
evidence for the absence of a real association. In other words, the
"criterion" of consistency is asymmetrical, like most of the other
Bradford Hill "criteria". 
32a) Are every decision of HC based on causality?
32b) What determines how causality is used in HC's decision making?
33c) Why are HC decisions on EMR pinned to causality when the absence of
consistency may not provide very robust evidence for the absence of
Similarly, the criterion of "temporality", which says that the putative
cause X of harm Y must come before Y appears, is robust in a simple,
uni-causal world. In a multi-causal, complex world of common biological
end points that have several chains of causation this may not
necessarily be so. For example, falling sperm counts can have multiple,
co-causal factors, some of which may have been effective at increasing
the incidence of the biological end point in question in advance of the
stressors in focus, thereby confusing the analysis of temporality. The
resulting overall sperm count trends could then be rising, falling or
static, depending on the combined direction and strengths of the
co-causal factors and the time lags of their impacts. It follows that
say, chlorine chemicals, may or may not be co-causal factors in falling
sperm counts: but the use of the "temporality" argument by the WHO, who
observed that sperm counts began to fall before chlorine chemistry
production took off, does not provide robust evidence that they are not
causally involved. 
34a) If people living near cell towers are becoming ill, if HC cannot
guarantee their health, if HC does not test for non thermal effects at
cell tower sites, then how can they use causality as an excuse to do
34b) Does HC allow risk managers to provide risk assessors with guidance
on the science policy to apply in their risk assessments of SC6?
34c) Does HC do risk analysis? Has a risk analysis been done on SC6? Is
HC willing to wait 30-100 years to review the consequences of their
actions regarding EMR?
34d) It appears it is the INFORMATION conveyed by electromagnetic
radiation (rather than heat) that causes biological changes - some of
these biological changes may lead to loss of wellbeing, disease and even
death. Is this HC's position? If not, why not?
34e) There may be no lower limit at which exposures do not affect us.
Until we know if there is a lower limit below which bioeffects and
adverse health impacts do not occur, is it unwise from a public health
perspective to continue "business-as-usual" deploying new technologies
that increase ELF and RF exposures, particularly involuntary exposures?
A WHO definition states that: "(A)nnoyance or discomforts caused by EMF
exposure may not be pathological per se, but, if substantiated, can
affect the physical and mental well-being of a person and the resultant
effect may be considered as an adverse health effect. A health effect is
thus defined as a biological effect that is detrimental to health or
well-being. According to the WHO Constitution, health is a state of
complete physical, mental, and social well-being and not merely the
absence of disease or infirmity." www.who.int/peh-emf 
35) [Name withheld] states that "At this time, neither HC nor the WHO
recognize that symptoms attributed to EHS from low-level RF fields (as
located around cell towers) are causally related to RF field exposure."
When [name withheld] refers to WHO does he take the above into account?
Environmental Issue Report Number 29 from the World Health Organization
(2002) cautions about the effects of radiofrequency radiation on
children's health. As part of a publication on "Children's Health and
Environment: A Review of Evidence" the World Health Organization (WHO)
"The possible adverse health effects in children associated with
radiofrequency fields have not been fully investigated."
"Because there are suggestions that RF exposure may be more hazardous
for the fetus and child due to their greater susceptibility, prudent
avoidance is one approach to keeping children's exposure as low as
"Further research is needed to clarify the potential risks of ELF-EMF
and radiofrequency fields for children's health." 
36a) Does the HC support cell phone use by children and pregnant mothers?
36b) When findings prove EMR is a threat to the health of children will
HC recommend age limits for cell phone use as there are age limits for
36c) Has childhood leukemia increased in Canada with increased use of
cell phone technology?
36d) What specifically in SC6 protects children from cancer?
The Parliament of the United Kingdom commissioned a scientific study
group to evaluate the evidence for RF health and public safety concerns.
In May of 2000, the United Kingdom Independent Expert Group on Mobile
Phones issued a report underscoring concern that standards are not
protective of public health related to both mobile phone use and
exposure to wireless communication antennas.
Conclusions and recommendations from the Stewart Report (for Sir William
Stewart) indicated that the Group has some reservation about continued
wireless technology expansion without more consideration of planning,
zoning and potential public health concerns. Further, the Report
acknowledges significant public concern over community siting of mobile
phone and other communication antennas in residential areas and near
schools and hospitals.
"Children may be more vulnerable because of their developing nervous
system, the greater absorption of energy in the tissue of the head and a
longer lifetime of exposure."
"The siting of base stations in residential areas can cause considerable
concern and distress. These include schools, residential areas and
"There may be indirect health risks from living near base stations with
a need for mobile phone operators to consult the public when installing
"Monitoring should be especially strict near schools, and that emissions
of greatest intensity should not fall within school grounds."
"The report recommends "a register of occupationally exposed workers be
established and that cancer risks and mortality should be examined to
determine whether there are any harmful effects." (IEGMP, 2000) 
37a) It may be noted that the Simcoe cell tower is located near a
school, hospital and nursing home, let alone the dense residential area.
There was no notification given of the erection of the cell tower. Why,
with all the warnings about EMR, was there no consideration to resident
37b) Was this an isolated incident or was it general policy to allow
cell towers near hospitals, nursing homes and schools?
37c) The policy of notifying residents begins in January 2008. Will
special arrangements be made for schools, hospitals and nursing homes?
If not, why not?
The evidence that power lines and other sources of ELF are consistently
associated with higher rates of childhood leukemia has resulted in the
International Agency for Cancer Research (an arm of the World Health
Organization) to classify ELF as a Possible Human Carcinogen (in the Group
2B carcinogen list). Leukemia is the most common type of cancer in
38a) Is there doubt that exposure to ELF causes childhood leukemia?
Could HC explain?
38b) Is it true there is some evidence that other childhood cancers may
be related to ELF exposure but not enough studies have been done?
38c) Children who have leukemia and are in recovery have poorer survival
rates if their ELF exposure at home (or where they are recovering) is
between 1mG and 2 mG in one /study; over 3 mG in another study. Is this
something to be taken into account in SC6?
Factors that determine effects can depend on head shape and size, the
location, size and shape of internal brain structures, thinness of the
head and face, hydration of tissues, thickness of various tissues,
dialectric constant of the tissues and so on. Age of the individual and
state of health also appear to be important variables. Exposure
conditions also greatly influence the outcome of studies, and can have
opposite results depending on the conditions of exposure including
frequency, waveform, orientation of exposure, duration of exposure,
number of exposures, any pulse modulation of the signal, and when
effects are measured (some responses to RF are delayed). There is large
variability in the results of ELF and RF testing, which would be
expected based on the large variability of factors that can influence
test results. However, it is clearly demonstrated that under some
conditions of exposure, the brain and nervous system functions of humans
are altered. The consequence of long-term or prolonged exposures have
not been thoroughly studied in either adults or in children. 
39) The consequence of prolonged exposures to children, whose nervous
systems continue to develop until late adolescence, is unknown at this
time. This could have serious implications to adult health and
functioning in society if years of exposure of the young to both ELF and
RF result in diminished capacity for thinking, judgment, memory,
learning, and control over behavior. What child studies has HC (not
others) initiated to investigate the effects of long-term or prolonged
The National Toxicology Program (NTP) is a part of the National
Institute for Environmental Health Sciences, National Institutes for
Health. Public and agency comment has been solicited on whether to add
radiofrequency radiation to its list of substances to be tested by NTP
as carcinogens. In February 2000 the FDA made a recommendation to the
NPT urging that RF be tested for carcinogenicity (www.fda.gov.us). The
recommendation is based in part on written testimony stating:
" Animal experiments are crucial because meaningful data will not be
available from epidemiological studies for many years due to the long
latency period between exposure to a carcinogen and the diagnosis of a
"There is currently insufficient scientific basis for concluding either
that wireless communication technologies are safe or that they pose a
risk to millions of users."
"FCC radiofrequency radiation guidelines are based on protection from
acute injury from thermal effects of RF exposure and may not be
protective against any non-thermal effects of chronic exposures."
In March of 2003, the National Toxicology Program issued a Fact Sheet
regarding its toxicology and carcinogenicity testing of
radiofrequency/microwave radiation. These studies will evaluate
radiofrequency radiation in the cellular frequencies.
"The existing exposure guidelines are based on protection from acute
injury from thermal effects of RF exposure. Current data are
insufficient to draw definitive conclusions concerning the adequacy of
these guidelines to be protective against any non-thermal effects of
chronic exposures. "
40) The American National Institute for Environmental Health Sciences -
National Toxicology Program is considering going away from the acute
injury from thermals theory and the short term exposure concept. Is HC
considering such a move?
An Assessment of Non-Lethal Weapons Science and Technology by the Naval
Studies Board, Division of Engineering and Physical Sciences (National
Academies Press (2002) has produced a report that confirms the existence
of non-thermal bioeffects from information transmitted by radiofrequency
radiation at low intensities that cannot act by tissue heating.
In this report, the section on Directed-Energy Non-Lethal Weapons it
"The first radiofrequency non-lethal weapons, VMADS, is based on a
biophysical susceptibility known empirically for decades. More in-depth
health effects studies were launched only after the decision was made to
develop that capability as a weapon. The heating action of RF signals is
well understood and can be the basis for several additional
directed-energy weapons. Leap-ahead non-lethal weapons technologies will
probably be based on more subtle human/RF interactions in which the
signal information within the RF exposure causes an effect other than
simply heating: for example, stun, seizure, startle and decreased
spontaneous activity. Recent developments in the technology are leading
to ultrawideband, very high peak power and ultrashort signal
capabilities, suggesting the phase space to be explored for subtle, yet
potentially effective non-thermal biophysical susceptibilities is vast.
Advances will require a dedicated effort to identify useful
This admission by the Naval Studies Board confirms several critical
issues with respect to non-thermal or low-intensity RF exposures. First,
it confirms the existence of bioeffects from non-thermal exposure levels
of RF. Second, it identifies that some of these non-thermal effects can
be weaponized with bioeffects that are incontrovertibly adverse to
health (stun, seizure, startle, decreased spontaneous activity). Third,
it confirms that there has been knowledge for decades about the
susceptibility of human beings to non-thermal levels of RF exposure.
Fourth, it provides confirmation of the concept that radiofrequency
interacts with humans based on the RF information content (signal
information) rather than heating, so it can occur at subtle energy
levels, not at high levels associated with tissue heating. Finally, the
report indicates that a dedicated scientific research effort is needed
to really understand and refine non-thermal RF as a weapon, but it is
promising enough for continued federal funding. 
41) Is HC aware of the above information? If not, why not, considering
the health implications for Canadians? If yes, why have they withheld it
from Canadians by not factoring it in to SC6?
For brain tumors, people who have used a cell phone for 10 years or
longer have a 20% increase in risk (when the cell phone is used on both
sides of the head). For people who have used a cell phone for 10 years
or longer predominantly on one side of the head, there is a 200%
increased risk of a brain tumor. This information relies on the combined
results of many brain tumor/cell phone studies taken together (a
meta-analysis of studies). 
42a) People who have used a cell phone for ten years or more have higher
rates of malignant brain tumor and acoustic neuromas. It is worse if the
cell phone has been used primarily on one side of the head. Does the
Canadian government take this information into account when issuing
42b) The current standard for exposure to the emissions of cell phones
and cordless phones is not safe considering studies reporting long-term
brain tumor and acoustic neuroma risks. Is this the position of the
42c) In formulating SC6 Canadian government officials may have ignored
relevant studies. In ignoring these studies are the Canadian government
scientists negligent? Have they broken any oaths to uphold the safety of
Canadians? What process is in place to address negligent Canadian
It can no longer be said that the current state of knowledge rules out
or precludes risks to human health. The enormous societal costs and
impacts on human suffering by not dealing proactively with this issue
require substantive public health policy actions; and actions of
governmental agencies charged with the protection of public health to
act on the basis of the evidence at hand. 
43a) Why does HC ignore this current state of knowledge? Is it
reasonable to conclude that HC would rather err on the side of Industry?
43b) Alzheimer's disease is a disease of the nervous system. There is
strong evidence that long term exposure to ELF is a risk factor for
Alzheimer's disease. Is this correct or does HC ignore this? Are the
doctors, scientists, health care professionals, and beauraucrats all
willing to let their fellow Canadians submit to such exposure?
Cancer risk is related to DNA damage, which alters the genetic blueprint
for growth and development. If DNA is damaged (the genes are damaged)
there is a risk that these damaged cells will not die. Instead they will
continue to reproduce themselves with damaged DNA, and this is one
necessary pre-condition for cancer. Reduced DNA repair may also be an
important part of this story. When the rate of damage to DNA exceeds the
rate at which DNA can be repaired, there is the possibility of retaining
mutations and initiating cancer. 
44a) A person like myself who lives 90% of his time within 300 metres of
a cell tower is bombarded by microwaves day after day after day. What
are the effects of such close bombardment?
44b) Does the bombardment bounce off the skin? Does the bombardment pass
through the body? On average how much of the bombardment penestrates the
skin? To what depth? Does it dissipate? Does it just sit there? Does it
interact with the body in any way? Does it affect cellular structure? Is
the bombardment benign?
44c) If there is any penetration of the skin and if there is some doubt
whether or not it might be harmful, should the precautionary principle
44d) For a person living 90% of their time within 300 metres of the
Simcoe cell tower, how many units of radiation is the person bombarded
with per day/per year/per lifetime?
In nearly every living organism, there is a special protection launched
by cells when they are under attack from environmental toxins or adverse
environmental conditions. This is called a stress response, and what are
produced are stress proteins (also known as heat shock proteins).
Plants, animals and bacteria all produce stress proteins to survive
environmental stressors like high temperatures, lack of oxygen, heavy
metal poisoning, and oxidative stress (a cause of premature aging). We
can now add ELF and RF exposures to this list of environmental stressors
that cause a physiological stress response. 
45) Very low-level ELF and RF exposures can cause cells to produce
stress proteins, meaning that the cell recognizes ELF and RF exposures
as harmful. This is another important way in which scientists have
documented that ELF and RF exposures can be harmful, and it happens at
levels far below the existing public safety standards. What studies does
HC have to refute this statement?
The immune system is another defense we have against invading organisms
(viruses, bacteria, and other foreign molecules). It protects us against
illness, infectious diseases, and tumor cells.
There are many different kinds of immune cells; each type of cell has a
particular purpose, and is launched to defend the body against different
kinds of exposures that the body determines might be harmful. 
46) There is substantial evidence that ELF and RF can cause inflammatory
reactions, allergy reactions and change normal immune function at levels
allowed by current public safety standards. Oxidative stress through the
action of free radical damage to DNA is a plausible biological mechanism
for cancer and diseases that involve damage from ELF to the central
nervous system. Is HC in agreement with this statement? If not,
specifically why not?
[Name withheld] wrote the following about SC6, "All aspects were
reviewed, including possible effects related to cancer. It is important
to note that this safety code, and all other codes and guidelines
produced by this Bureau, rely on an understanding and assessment of the
body of science, not selected studies that support a preconceived
conclusion. This is the only approach that is justifiable and defensible
in dealing with matters related to health and safety of the Canadian
47) How can HC defend such a statement in light of the overwhelming
[Name withheld] also wrote, "In addition to these documents, HC staff
participated in a specific review of the evidence for a link between EMR
and cancer and this document contains more references: Moulder JE,
Foster KR, Erdreich LS, McNamee JP. Mobile phones, mobile phone base
stations and cancer: a review. Int J Radiat Biol. 2005
Mar;81(3):189-203) which is available at:
48a) I have read this paper. It was written before both the Wolf & Wolf
(2004) study and before the Naila study. What is HC's response to this
considering the Naila study is not referenced by HC?
48b) Are studies being selectively omitted from HC documents because
they do not agree with the current administration's theories or objectives?
Many people are surprised to learn that certain kinds of EMFs treatments
actually can heal.
These are medical treatments that use EMFs in specific ways to help in
healing bone fractures, to heal wounds to the skin and underlying
tissues, to reduce pain and swelling, and for other post surgical needs.
Some forms of EMFs exposure are used to treat depression.
EMFs have been shown to be effective in treating conditions of disease
at energy levels far below current public exposure standards. This leads
to the obvious question. How can scientists dispute the harmful effects
of EMF exposures while at the same time using forms of EMF treatment
that are proven to heal the body? 
49a) Medical conditions are successfully treated using EMFs at levels
below current public safety standards, proving another way that the body
recognizes and responds to low-intensity EMF signals. Otherwise, these
medical treatments could not work. The FDA has approved EMFs medical
treatment devices, so is clearly aware of this paradox. Is HC aware of
the paradox? Will HC resolve the paradox?
49b) No one would recommend that drugs used in medical treatments and
prevention of disease be randomly given to the public, especially to
children. Why then do random and involuntary exposures to EMFs occur all
the time in daily life?
In July, 2007, The Alaska Supreme Court (Court) upheld the decision of
the Alaska Workers' Compensation Board (Board) awarding an AT&T
equipment installer 100% disability as a result of his workplace
electromagnetic field exposure to radiofrequency (RF) radiation at
levels slightly above the FCC RF safety limit. The award was based on
the psychological and cognitive effects of RF radiation over-exposure.
This decision is significant because the FCC RF limit is designed to
keep people from being heated and ignores evidence of other adverse
biological effects at much lower levels. The RF radiation exposure level
in question was well below the FCC's recognized level of "thermal" harm.
The FCC contends that there are no scientifically established harmful
health effects below the thermal threshold. The Board decision agrees
with the medical experts who found adverse health effects from this RF
radiation exposure, which occurred above the FCC safety limit but below
the thermal threshold. The complete text of Alaska Supreme Court OPINION
No. 6139 - July 6, 2007 is found at:
50) When I contacted CCRPB on this ruling I was told the subject was
overexposed to radiation. However, overexposure is not what the judge
used to make his decision. I suggest CCRPB review the judgment more
According to the Canadian Human Rights Commission Policy on
Environmental Sensitivities, "Individuals with environmental
sensitivities experience a variety of adverse reactions to environmental
agents at concentrations well below those that might affect the `average
person'". This medical condition is a disability and those living with
environmental sensitivities are entitled to the protection of the
Canadian Human Rights Act, which prohibits discrimination on the basis
of disability. The Canadian Human Rights Commission will receive any
inquiry and process any complaint from any person who believes that he
or she has been discriminated against because of an environmental
sensitivity. Like others with a disability, those with environmental
sensitivities are required by law to be accommodated. EHS is considered
a disability in Canada. The Canadian Human Rights Commission Policy on
Environmental Sensitivities accommodates EHS.
51) HC maintains Canadians are protected by SC6 but it does not protect
Canadians with EHS, therefore the Ministry of Health is in violation of
the Canadian Human Rights Commission. Is this statement correct?
Recently Europe's top environmental watchdog, the European Environment
Agency (EEA), has called for immediate action to reduce exposure to
radiation from Wi-Fi, mobile phones and their masts. It suggests that
delay could lead to a health crisis similar to those caused by asbestos,
smoking and lead in petrol. The warning follows an international
scientific review which concluded that safety limits set for the
radiation are "thousands of times too lenient", and an official British
report which concluded that it could not rule out the development of
cancers from using mobile phones.
52) Is any such warning proposed by HC?
And the evidence keeps poring in. In a lecture held on 1 October 2007 at
the "Open University" in Gelsenkirchen, Germany, Prof. Franz Adlkofer
presented his research results regarding the effect of UMTS radiation on
human cells for the first time. There is no doubt - UMTS is ten times
more damaging to genes than GSM radiation. He pointed out that the
evidence of DNA strand breaks in conjunction with the formation of
micronuclei does not allow any further doubting of the genotoxic effect
of UMTS signals. This means that Prof Adlkofer demonstrated for UMTS
what he had already demonstrated for GSM in the REFLEX project, which he
headed: Mobile phone radiation damages the genetic material and raises
the risk of cancer. The European Environment Agency , the highest
scientific body within the EU, published a statement on
17 September 2007 in which it ranked the danger potential from mobile
radiation and the policies supporting it in one line with Asbestos and
And the evidence keeps poring in. Washington, DC, November 16, 2007 - A
groundbreaking scientific study published this week in the peer-reviewed
"Australasian Journal of Clinical Environmental Medicine" warns that
wireless communication technology may be responsible for accelerating
the rise in autism among the world's children. (J.Aust.Coll.Nutr.&
Env.Med, 2007; Vol.26, No.2 pages 3 - 7)
And the evidence keeps pouring in. Recently from the "Indian Express",
November 26, 2007, "ICMR Study Confirms Health Risks From Mobile
Phones". "Continuous use of cell phones can pose a serious threat to
your reproductive health, says a study conducted by the Indian Council
of Medical Research (ICMR). The Preliminary results of the study have
indicated significant reduction of testicular size, weight and sperm
count due to the Radio Frequency Radiation (RFR) emitted from cell phones.
53) What are HC's views on these three studies in light of the fact they
cast doubt on the protection afforded Canadians by SC6?
The tobacco industry, 40 years ago, reacted to the historic Surgeon
General's report linking cigarette smoking to cancer and other lung
diseases by organizing a disinformation campaign. One of their memos,
prepared in the 1960's, was recently uncovered during one of the
lawsuits against the tobacco companies on behalf of millions of people
who have been killed by their product. It is interesting to read it 40
years later in the context of the intransigence of HC: "Doubt is our
product, since it is the best means of competing with the "body of fact"
that exists in the mind of the general public. It is also the means of
establishing controversy." Brown and Williamson Tobacco Company memo,
54) Is HC stalling the reviewing of SC6 thereby allowing Industry more
time to build more towers?
Devra Lee Davis, Ph. D., MPH, is author of the recently released book
"The Secret History of the War on Cancer. Dr. Davis is Professor at the
University of Pittsburgh as well as Honorary Professor, London's School
of Hygiene and Tropical Medicine, and an Expert Advisor to the World
Health Organization. President Clinton appointed Dr. Davis to the
Chemical Safety and Hazard Investigation Board, (1994-99), an
independent executive branch agency that investigates, prevents, and
mitigates chemical accidents.
As the former Senior Advisor to the Assistant Secretary for Health in
the Department of Health and Human Services, she has counseled leading
officials in the United States, United Nations, World Health
Organization and World Bank. She was also a Distinguished Visiting
Professor at The Yeshiva University and Stern College for 1996- 97 and
Scholar in Residence and Executive Director of the Board on
Environmental Studies and Toxicology at the U.S. National Research
Council, of the National Academy of Science,
Dr. Davis holds a B.S. in physiological psychology and a M.A. in
sociology from the University of Pittsburgh. She completed a Ph.D. in
science studies at the University of Chicago, as a Danforth Foundation
Graduate Fellow and a M.P.H. in epidemiology at the Johns Hopkins
University, as a Senior National Cancer Institute Post-Doctoral Fellow.
She has also authored more than 170 publications.
What Dr. Davis has to say about cancer and cell phones should be
listened to although it is predictable HC will not listen.
"Cell phones transform and save lives.Then think of Ronald Regan and
George Bush Sr.'s political adviser Lee Atwater, General Electric's Jack
Welch, Dan Case, the high empowered brother or AOL founder Steve Case,
Calgary business leader Clark H. Smith, writer Bebe Moore Campbell and
other heavy users of the first generation of cell phones when they were
first introduced. Each of these brain cancer cases spent hours with some
of the early cell phones next to their skulls. The problems posed by
cell phones in the real world are like huge simultaneous equations.
When it comes to sorting through the risks of cell phones, we have
lately been assured that there are none based upon reports from what
appear to be independent scientific reviewers. For example, researchers
from the Danish Cancer Society reported in the Journal of the National
Cancer Institute in 2006 that they found no evidence of risk in persons
who had used cell phones. Headlines around the world boasted of this
latest finding from an impeccable source published in a first tier
But let's look at what the researchers actually studied.
They reviewed health records through 2002 of about 421,000 people who
had first signed up for private use of cell phones between 1982 and
1995. A "cell phone user" in the study was anyone who made a single
phone call a week for six months during the period 1981 to 1995. The
study kicked out anyone who was part of a business that used cell
phones, including only those who had used a cell phone for personal
purposes for eight years.
This research design raises a lot of questions. Why did they not look at
business users - those with far more frequent use of cell phones? Why
lump all users together, putting those who might have made a single
phone call a week with those who used the phones more often?
Why stop collecting information on brain tumors in 2002 when we know
that brain tumors often take decades to develop and be diagnosed?
When you are looking at a large population to find an effect, generally
the more people you study, the better your chance of finding something.
But if you merge a large number of people with very limited exposure
together with a small number of people with very high exposure, you
dilute the high-exposure group and so lower your chances of finding any
effect at all. It would be better to compare the frequent users with
non-users, omitting the limited users altogether. Lumping all these
various users together is like looking all over a city for a stolen car
when you know it's in a five-block radius. Perhaps you'll find what
you're looking for, but the chances are greater that you won't. The
Danish study was designed to look definitely thorough - 421,000 people!
- but in fact it was biased against positive findings from the start.
Given how broadly cell signals now penetrate coffee shops, airports, and
some downtown areas of major cities, it is very difficult to find any
truly unexposed groups against which to compare results. Because cell
phone use has grown so fast and its technologies change every year, it
is as if we are trying to study the car in which we are driving.
Another study that s well published in 2000 found no increased risk in
most types of brain cancer in cell phone users; but the average length
of use among participants was less than three years. Still, the study
found that those people who had used phones for even this short period
of time had twice the risk of a very rare brain tumor -
neuroepitheliomatous cancers, the kind that wraps itself around the
nerve cells of the lining of the brain, right at the locus that cell
signals can reach.
Of course, epidemiologic research is the research that works best when
we have solid information on the nature of the use or exposure we are
trying to understand. All of us have cell phone bills that provide
detailed records of our use, and most of these can be accessed online.
These were not used in the study, nor in any study of the industry to
date. A gold mine of data lies untapped that could enable researchers to
distinguish non-users from low frequency users from high frequency
users, thereby increasing the validity and sensitivity of the studies.
Underlying this whole body of research is clear evidence that cell phone
signals penetrate the brain. As the Danish researchers admitted in their
own study, "During operation, the antenna of a cellular telephone emits
radio frequency electromagnetic fields that can penetrate.
The studies to date that have not found a general, clear and consistent
risk from cell phones need to be understood as tentative. They have for
the most part looked at older technologies over short periods of
exposure. None is asking about the impact on of cell phones on the
brains of children and teenagers - one of the fastest growing groups of
users in the world today. The governments of England, Israel and Sweden
advise that those persons under eighteen should not use cell phones at
all. American toddlers learn to play with toy versions of them.
What makes this especially troubling are the results from several other
studies that have looked at more recent regular users. After a decade of
heavy use, cell phone users have double the risk of brain cancer. The
tumors tend to occur on the side of the head that the user favors.
Another, entirely different set of data on electromagnetic fields,
exposures of which cell phone signals are but one type, come from
looking at an illness even more extraordinarily rare than brain cancer -
breast cancer in men. The total number of cases of male breast cancer in
the United States today is thought to be less than 4,000 but some 1,400
new cases are reported each year, according to the American Cancer
Society. Studies of men who work with electromagnetic fields in radio
and television or in assembling cell towers have found that they have a
much greater risk of breast cancer as well as cancer of the brain.
Men typically don't get breast cancer, and when they do, the disease is
often much more difficult to treat. that for many professions involving
work with electronics, men have between two and four times more breast
cancer than those without such experiences.
Much of the research funding is provided by the telecommunications
industry just as much of the research funding on more general
electromagnetic field research was provided by the electric power
industry. It may not surprise you to learn that the highly publicized
Danish study that exonerated cell phones and the yet to be completed
IARC study are directly funded by the industry."
55) Exactly how many more voices will it take to make Safety Code 6 more
humane? This is not rhetorical.
John Updike wrote, "It is impossible for a man to understand something
if his income depends on not understanding it." Public microwave
exposure levels tolerated by Health/Industry Canada are a national
health disaster. Yet, for pragmatic and lucrative reasons, federal
exposure limits have been deliberately set so high that no matter how
much additional wireless radiation is added to the national burden, it
will always be "within standards". SC6 is outdated, lacking in modern
EMR studies, does not adequately take into account low level radiation
nor the long term effects of radiation exposure. SC6 fails to protect
Canadians adequately by lacking a precautionary principal and in light
of certain recent studies and court cases may even be considered lacking
due diligence. SC6 discriminates against those with EHS, a recognized
disability. SC6 does not protect Canadians' health and contributes to
their ill health at significant cost to the health care system. On
September 5, 2000 the court ruled that HC's civil servants and
scientists are responsible to the Canadian people, and that politicians
cannot shut them up when it suits them or their corporate friends.
56) Are whistleblowers like Dr. Chopra discouraged in the Consumer and
Clinical Radiation Protection Bureau of Canada?
Again I would ask for a yes/no or percentage answer to the following
57) "Are the residents in the vicinity of the Union Street Water Tower
Cell Tower in Simcoe, Ontario as safe today as they were before the cell
tower was enabled?"
I submit the attached petition to have the responsible government agents
answer for SC6's failings.
[Original signed by Frank Woodcock]
 Bio Initiative Report: A Rationale for a Biologically-based Public
Exposure Standard for Electromagnetic Fields (ELF and RF) 2007
 Analysis of Health and Environmental Effects of Proposed San
Francisco Earthlink Wi-Fi Network, Magda Havis, B. Sc., Ph.D,
Environmental & Resource Studies, Trent University.
 Microwave News,
Informant: Martin Weatherall