Essential terms in need of definition
Extremely low frequency pulsed electromagnetic radiation does affect living organisms.
That means you and me. We are the experiment.
Tetrawatch demands clarity
When I use a word, Humpty Dumpty said, in rather a scornful tone, it means just what I choose it to meanneither more nor less.
The question is, said Alice, whether you can make words mean so many different things.
The question is, said Humpty Dumpty, which is to be master thats all.
Lewis Carroll, Through the Looking Glass
Whilst it might seem with the volume of documents produced by the National Radiological Protection Board (NRPB), the World Health Organisation (WHO), and the international committees advising on safety, not to mention the dependence on them by UK law, by our Health Protection Agency, Department of Health, Health and Safety Executive and all planning authorities, that we all know what we are talking about ... some clarity is missing.
As the Mad March Hare also observed (!) in Alice in Wonderland, to mean what you say is not the same thing as to say what you mean. We are sure that the sincerity is there, whilst the definition is not.
These are already explicitly present in the Stewart Report 2000 as occurring below recommended guidelines, and non-heating effects are explicitly excluded from the ICNIRP exposure guidelines. Prof. Lawrie Challis, head of the Mobile Telephones Health Research (MTHR) programme, describes light falling on the eyes to give vision, as a biological effect, and explains that biological effects are not necessarily harmful.
What about sleep deprivation and its effects on drivers, doctors, mothers? What about melatonin suppression and its effect on the immune system and protection from cancer? What about repeated acute nosebleeds and the effects on childrens schooling? Or what about the resultant stress from fearing the long-term effects on your children? Many biological effects are known in the laboratory as a result of exposure of living tissue to electromagnetic radiation at particular low levels, frequencies and modulations (see our Health Links). Some are certainly a great cause of concern, many symptoms are widely reported from residential mast sites, and five international studies make explicit correlation between masts and health effects.
Are you clear that biological effects are irrelevant in defining the risk from masts, the precaution, daily chronic exposure, and sensitive siting?
The Rio Declaration on Environment and Development, 1992 states:
In order to protect the environment the Precautionary Approach shall be widely applied by states according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.
However, the precautionary approach is not to be confused with the precautionary principle, which itself has several definitions (use your browser back button to return here). NRPB has redefined the terms, so perhaps we now know whats what?
Precaution is care beforehand: a preventive measure, something done beforehand to ward off evil. Taking precautions is commonplace in personal life and is usually determined by intuition, experience, behaviour or role models, personal values etc. The decision on what to do will be based on balancing the effectiveness of the practical precautionary measures against the sacrifices involved in adopting them. The decision should seek to ensure that the effort is proportional to the threat and that the end effect sought is proportional to the means to secure it.
(In Terms of Risk, NRPB 15, 4; 2004)
And so they go on to reserve the precautionary principle as a political term, and the precautionary approach as a scientific one:
The precautionary approach is a scientific term used to describe the cautious process that scientists use when converting experimental data into advice on acceptable levels of public or occupational risk to any agent ...
Where data cannot provide a reliable estimate, it is customary to use the most pessimisitic estimate of the risk when setting standards. Risks are inferred from direct experimental data, logical biological mechanisms and similarities to analogous situations.
The contradiction inherent in the UK interpretation of the precautionary principle: On the Precautionary Approach and the Stewart & NRPB Reports.
Read this statement from the International Commission for Electromagnetic Safety (ICEMS): The Precautionary Principle and Regulation of Exposure to Electromagnetic Fields.
To summarise: trademark precautionary approach® if you will for the NRPB and WHO; it might not mean what you think. It means, play safe if it is worth it. And play safe means assume you know what could happen and that nothing unexpected can happen.
Example: Should you run across a quiet road without looking? Does this still apply if there are electric cars around?
So, in the case of TETRA, despite the lack of research, despite the widespread reports of adverse effects, despite the concern in the science, either the contract is worth the risk, or the causes are outside the box and should be ignored or both.
Even the EU Commission document (29 pages): Communication from the Commission on the precautionary principle, states:
Community rules and those of many third countries enshrine the principle of prior approval (positive list) before the placing on the market of certain products, such as drugs, pesticides or food additives. This is one way of applying the precautionary principle, by shifting responsibility for producing scientific evidence. This applies in particular to substances deemed a priori hazardous or which are potentially hazardous at a certain level of absorption.
In this case the legislator, by way of precaution, has clearly reversed the burden of proof by requiring that the substances be deemed hazardous until proven otherwise. Hence it is up to the business community to carry out the scientific work needed to evaluate the risk. As long as the human health risk cannot be evaluated with sufficient certainty, the legislator is not legally entitled to authorise use of the substance, unless exceptionally for test purposes.
Are you clear what precaution is being taken on all our behalf?
This used to mean that if you work directly with a hazard, you understand this, and are prepared in order to do the job, to expose yourself to more than allowed for the general public. The understanding assumes that your employer is aware of the risk and further protects you.
However, can you now compare a fully protected mast engineer, with limited exposure, to a secretary with a mast on the roof, a wireless network and two DECT phones on the desk?
Are you clear what occupational exposure means any more?
Beam of greatest (or maximum) intensity
Referred to in the Stewart Report (IEGMP, 2000) and elsewhere: what does this mean? It is important because it relates to sensitive sites such as schools. The suggestion is that it means between 50m and 200m from a mast. Why?
It implies that at some given distance until some further distance, with some given and varying width, at some particular vertical and horizontal angle from a mast, at some particular height in relation to a person in some particular position perhaps in a particular building made from given materials, the exposure from some particular mast will be at its greatest in respect to that particular mast running at perhaps maximum power ?
What is the greatest? Within 5% or 10% of the maximum level as measured around the antennae? What is the difference between TETRA, 3G and GSM? Or between a T-Mobile omnidirectional antenna and an Orange 120 degree sectoral antenna? How much of this is specified in any way? None.
Is a mast beam sidelobe at ground level at 10m additional to the beam of greatest intensity? And how does this compare with the beam from an adjacent mast at a different power and frequency? Or the reflection from a metal building opposite? Does it make a difference if the antenna is pointing up or down, or its footprint coincides with that of another mast? Is there a difference in the safety of the beam of maximum intensity from different masts and different types?
How does the greatest intensity of one antenna relate to another, or even to the irrelevant ICNIRP? What kind of greatest intensity might present what kind of risk? Might not a greatest intensity outside a childs bedroom window be very much worse than a lesser one for 6 hours a day in term days at school?
Are you clear what the beam of maximum intensity means?
Schools and hospitals are sensitive sites, so presumably are nurseries and nursing homes. But not workplaces? Are children safer if they go to school with no mast within 200m, for 6 hours, yet return home to a TETRA running 24/7 outside their bedroom window; for 18 hours? Why are peoples homes and bedrooms not sensitive sites?
And why, if hospitals are sensitive sites, are there masts on many hospital roofs? It is entirely false to say that there is no radiation striking down from a mast. It may be an unwanted by-product, but it is there.
Here is a typical quote from an Orange spokesperson:
A spokesman for Orange said: The latest independent review of phone masts concluded that there were no scientific grounds for setting precautionary distances between masts and schools or nurseries. (Staffs Sentinel, 18 March 2005)
The latest NRPB review they draw this from, however, endorses (para 86) the Code of Best Practice that speaks of these distances from sensitive sites such as schools! Maybe there is no scientific basis because the work on biological effects in situ simply has not been done, so we certificate safety on the basis of ICNIRP, which has nothing to do with the observed effects!
Are you clear what is a sensitive site, and what notice is taken of this, and why?
Exceptional circumstances (for consideration of health effects)
This arose as a result of the Harrogate mast appeal. Perceptions of risk to health are a material planning consideration. The ODPM guidelines (PPG8) however, say that planning is not the place to decide this. So perceived health risk is decided by ... well; whom? The NRPB in Mobile Phones and Health 2004 (published 2005), para 83 says that the Government takes the view that this assessment: is best taken nationally. But again, by whom? By Government? Every Government department takes its advice and lead from the NRPB, so we come full circle and nobody gets the job!
Or is it simply good enough that each individual mast has an ICNIRP certificate? The judges in the Harrogate case said that health considerations should not be taken into account except in exceptional circumstances. What on earth could be exceptional, if certification, which is guaranteed, is sufficient?
Are you clear what might possibly constitute exceptional circumstances, having read all the above? Would any judge or planning inspector?
Perhaps the most elusive term. Safe from what? Being cooked? Or safe, for the 5 per cent of the population who are sensitive to the radiation? Safety, we see above, is a judgement of cost and benefit. Compared with the cost and consequence (to the profiteering mobile operators) of ensuring no-one suffers from all-pervasive masts, the risk that some may become ill or die, that some may lose jobs, endanger others, families break apart, become trapped in mast-shadowed homes, and stressed is worth it. TETRA everywhere at full power 24/7 and at its particular frequency mix? Those 3G videos? Are they worth someones life? We must develop alternatives.
Are you clear what the industry spokespeople mean when they say TETRA and mobile masts are safe? Or dont they?
Unsightly but harmless? Is that all there is to be concerned about? 50,000 mobile masts in the UK may be more than we can take. And TETRA has special concerns of its own.