ON THE CLEAR EVIDENCE OF THE RISKS TO CHILDREN FROM SMARTPHONE AND WIFI RADIO FREQUENCY RADIATION

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ON THE CLEAR EVIDENCE OF THE RISKS TO CHILDREN FROM SMARTPHONE AND WIFI RADIO FREQUENCY RADIATION
On the Clear Evidence of the Risks to
Children from Smartphone and WiFi
Radio Frequency Radiation

Professor Tom Butler | University College Cork | tbutler@ucc.ie

Children’s health and well-being is under significant threat from
everyday digital technologies, as the past 15 years have seen
the proliferation of microwave Radio Frequency Radiation (RFR)
devices in the home, school and society. The safety standards
for such devices—smartphones, tablets etc.—were based on the
proven thermal or heating effects of microwave devices in
adults, not children. Scientists in the life sciences have long
been aware of equally harmful non-thermal effects. However,
physicists and engineers have operated on the theory that non-
ionizing RFR could not directly damage human DNA and lead to
cancer, as it was far less powerful than ionizing radiation (x-
rays, nuclear etc.). That theory has been solidly and roundly
refuted, as this paper illustrates. Cancer risks aside, research
studies have demonstrated that low-intensity RFR elicits a range
of pathophysiological conditions in experimental animals and
humans. This is why parents, educators and governments
should be alarmed and take immediate and appropriate action.
In an Irish, and indeed international context, there is clear
ignorance on such matters. In response, this paper aims to
inform by presenting clear evidence, in a balanced manner, of
the risks to children based on proven scientific theories and
empirical evidence. The paper concludes by offering practical
advice on how the risks to children, and indeed adults, can be
minimised.

                                                 1
ON THE CLEAR EVIDENCE OF THE RISKS TO CHILDREN FROM SMARTPHONE AND WIFI RADIO FREQUENCY RADIATION
On the Clear Evidence of the
Risks to Children from
Smartphone and WiFi Radio
Frequency Radiation

Professor Tom Butler
University College Cork
tbutler@ucc.ie

    “The level of proof required to justify action for health
   protection should be less than that required to constitute
               causality as a scientific principle”
                                    Professor Rainer Frentzel-Beyme MD

Contents

Abstract ............................................................................ 3
Introduction ...................................................................... 3
Proof of the Potential Toxicity and Carcinogenicity of RFR ........ 4
What are the Biological Mechanisms that Produce Ill-health in
Children and Adults? ......................................................... 7
Evidence that Microwave RFR Promotes the Development of
Existing Cancers ................................................................ 9
Why are Existing Standards Unsafe? ..................................... 9
What do Insurance Companies and Regulators and Telecoms
Operators have to say about the Risks? ............................. 11
Discussion ....................................................................... 12
Conclusions ..................................................................... 14
About the Author.............................................................. 17
References ...................................................................... 17

                                          2
ON THE CLEAR EVIDENCE OF THE RISKS TO CHILDREN FROM SMARTPHONE AND WIFI RADIO FREQUENCY RADIATION
Abstract                                         male       infertility;     neuropsychiatric
                                                 conditions, including post-natal neural
Children’s health and well-being is under        development, and learning and cognitive
significant threat from everyday digital         problems; and melatonin reduction
technologies, as the past 15 years have          leading to sleep disruption; among
seen the proliferation of microwave              others. There is a considerable body of
Radio Frequency Radiation (RFR) devices          evidence on the harmful effects of
in the home, school and society. The             electromagnetic pollution that should
safety standards for such devices—               have the World Health Organization
smartphones, tablets etc.—were based             (WHO)        and        governing    bodies
on the proven thermal effects of                 establishing guidelines to protect public
microwave devices in adults, not                 health, as they have with environmental
children. Scientists in the life sciences        pollution. In light of recent scientific
have long been aware of equally harmful          evidence, in May 2015 over 200 eminent
non-thermal effects. However, physicists         scientists have launched an international
and engineers have operated on the               appeal to the United Nations and the
theory that non-ionizing RFR could not           WHO based on the conviction that there
directly damage human DNA and lead to            is a real and present danger to children,
cancer, as it was far less powerful than         in particular, by what they consider
ionizing radiation (x-rays, nuclear etc.).       outdated industry standards in relation
That theory has been solidly and roundly         to microwave radiation.
refuted, as this paper illustrates. Cancer
                                                 On November 1st 2018, the final report
risks aside, research studies have
                                                 of a 10-year $30m comprehensive study
demonstrated that low-intensity RFR
                                                 by      US     National     Institute    of
elicits a range of pathophysiological
                                                 Environmental Health Sciences’ National
conditions in experimental animals and
                                                 Toxicology Program (NTP) confirmed that
humans. This is why parents, educators
                                                 radio frequency radiation (RFR) from
and governments should be alarmed and
                                                 Smartphones caused cancer in animals.1
take immediate and appropriate action.
                                                 That study clearly refutes the long-held
In an Irish, and indeed international
                                                 theory that non-ionizing radiation, such
context, there is clear ignorance on such
                                                 as RFR, cannot cause cancers or lead to
matters. In response, this paper aims to
                                                 other effects on the health and well-
inform by presenting clear evidence, in a
                                                 being of humans. The findings of this
balanced manner, of the risks to children
                                                 study opens an ethical Pandora’s Box for
based on proven scientific theories and
                                                 mobile phone companies and BigTechs
empirical evidence. The paper concludes
                                                 such as Apple, Facebook, Google and
by offering practical advice on how the
                                                 others, as the use of microwave RFR
risks to children, and indeed adults, can
                                                 technologies underpin their business
be minimised.
                                                 models. Such technologies are now
                                                 ubiquitous in society, whether it is in the
Introduction                                     home, classroom, workplace, or in
                                                 transport systems. The fact that they
Exposure of humans to non-ionizing
                                                 might pose a real risk to the health and
radio frequency radiation (RFR) has
                                                 well-being of users and particularly
increased dramatically over the past 20
                                                 children was never considered. This
years, particularly where children are
                                                 creates a dilemma for parents and
concerned.      Epidemiological       and
                                                 educators, as the evidence on the risks
experimental research reports increased
                                                 to    human      health  and     well-being
risk of pathophysiological conditions with
                                                 associated      with    widespread     and
current exposures to Smartphone and
                                                 indiscriminate exposure to RFR is clear
WiFi RFR that include: cellular DNA
                                                 and unambiguous, with children being
damage, leading to a range of cancers;
                                                 particularly at risk.
sperm and testicular damage leading to

                                             3
This paper begins by reporting on a             safety standards were, and still are,
ground-breaking study by the National           centred on the thermal effects (i.e.
Toxicology Program’s (NTP) at the U.S.          heating of tissues from microwaves) and
Department of Health and Human                  not on the non-thermal effects. To be
Services. The final report was issued on        sure, the findings of extant research at
November 1st 2018 and in the press              the time were mixed, with no clear
release    Dr.   John   Bucher,    Senior       evidence either way of potential negative
Scientist, at the National Toxicology           health implications of low-intensity RFR,
Program stated, “We have concluded              especially where cancer was concerned. 4
that there was clear evidence that male         In 2011 the IARC classified WiFi and
rats developed cancerous heart tumors           microwave radiation from cordless and
called malignant schwannomas. The               mobile phones as a possible Class 2B
occurrence of malignant schwannomas in          carcinogen. While the findings of
the hearts of male rats is the strongest        epidemiological    studies   have    been
cancer    finding    in  our   study.” 2        debated, and chiefly focus on the long-
Categorising the major findings as “clear       term development of brain tumours, a
evidence” is significant as this is the         recent review of such studies is
highest burden of proof in a scientific         unequivocal and states that “[m]obile
study by the NTP. It employs 4 levels of        phone radiation causes brain tumors and
evidence.      Other    findings    were        should be classified as a probable
categorised as Some Evidence (brain             human carcinogen (2A)” by the WHO’s
tumours such as glioma and adrenal              International Agency for Research on
gland tumours) and Equivocal (cancers           Cancer (IARC).5
of the prostate and pituitary glands).
                                                The NTP study is not the first of its
None of the findings were at level 4, No
                                                kind—it confirms the findings of previous
Evidence. The paper discusses these
                                                research on the links between RFR
findings in the context of previous
                                                exposure and various cancers—it is the
research. It then presents the biological
                                                most comprehensive, however. Since
and cellular mechanisms found to be
                                                1999 when the FDA flagged the issue of
responsible for these effects. The paper
                                                potential    non-thermal      effects    of
then presents evidence that RFR
                                                microwave radiation, a wealth of new
promotes the development of existing
                                                experimental       and     epidemiological
cancers and examines why the existing
                                                research demonstrated the very real
safety standards are not fit for purpose.
                                                biological effects of RFR on the brain,
Next explored are the perspectives of
                                                nervous systems, hearts and testes of
insurance          companies         and
                                                mammals, including humans. Cancers
telecommunications operators on the
                                                aside, many of these studies consistently
risks.
                                                report a range of side-effects in humans,
                                                from sleep deprivation and headaches,
Proof of the Potential Toxicity and             to neurological damage, and learning
Carcinogenicity of RFR                          disorders. Consequently, in 2014, the
                                                California Medical Association (CMA) 6
In 1999, the US Food and Drug                   stated that “peer reviewed research has
Administration's   (FDA)   Center   for         demonstrated adverse biological effects
Devices    and    Radiological   Health         of wireless EMF [i.e. RFR] including
commissioned the National Toxicology            single and double stranded DNA breaks,
Program study on the potential toxicity         creation of reactive oxygen species,
and carcinogenicity of RFR. 3 The FDA’s         immune         dysfunction,       cognitive
concerns followed the emergence and             processing     effects,  stress     protein
widespread use of first generation cell         synthesis in the brain, altered brain
phone devices in the early 1980s and            development,      sleep   and      memory
second generation (2G) systems in the           disturbances, ADHD, abnormal behavior,
1990s. The health focus and associated

                                            4
sperm dysfunction, and brain tumors.”             brains of rats and mice exposed to RFR.
The CMA were following the lead of the            The findings also reported reduced birth
American Academy of Paediatrics, which            weights of rat pups whose mothers were
in 2013 petitioned the US Federal                 exposed to RFR, in addition to
Communications Commission (FCC) and               cardiomyopathy of the right ventricle in
to the Food and Drug Administration               the rats studied.12
(FDA) to reassess safety standards to
                                                  After more than 20 years of widespread
RFR in order to “protect children’s health
                                                  cell phone use, one would expect to see
and well-being throughout their lifetimes
                                                  a rise in cancers, particularly brain
and reflect current use patterns.”7
                                                  tumours. A research review of the
The final peer-reviewed findings of the           incidence of glioblastoma multiforme
NTP study were released on November               tumours in England during 1995–2015
1st 2018. Given the significance of the           reported a “a sustained and highly
findings there was a muted response               statistically significant ASR [(incidence
from the press. Coverage from the New             rate)] rise in glioblastoma multiforme
York Times argued that the focus on 2G            (GBM) across all ages. The ASR for GBM
and 3G technologies somehow weakened              more than doubled from 2.4 to 5.0, with
the study’s findings. 8 This is a spurious        annual case numbers rising from 983 to
argument, as 4G Smartphones are                   2531. Overall, this rise is mostly hidden
backward compatible with 2G and 3G.               in the overall data by a reduced
More     worryingly    the    International       incidence of lower-grade tumours.”13 The
Commission on Non-Ionizing Radiation              study did not focus on RFR as the cause,
Protection (ICNIRP) decided that the              so the findings must be considered ‘open
findings did not provide a reason to              to interpretation’ in this regard, as other
revise current (i.e. 20-year-old) RFR             environmental mechanisms cannot be
exposure     standards.    However,     Dr.       ruled out. Another recent review study
Ronald Melnick rebutted the ICNIRP                on epidemiological studies on brain and
analysis stating it contained several false       salivary gland tumours and mobile phone
and misleading statements. 9 Dr Fiorella          use found the cumulative evidence to be
Belpoggi, Director of the Cesare Maltoni          inconclusive, but indicated that cancers
Cancer Research Center of the Ramazzini           may have longer latency (i.e. greater
Institute, which had recently conducted           than 15 years) and childhood use to be
separate research that reproduced the             of concern. 14 In contrast, the French
findings of the NTP Study, also took              CERENAT study stated that, “Consistent
issue    with   the    ICNIRP—“We       are       with previous studies, we found an
scientists, our role is to produce solid          increased risk in the heaviest users,
evidence for hazard and risk assessment.          especially for gliomas.” 15 While these
Underestimating the evidence from                 studies emanate from natural scientists,
carcinogen bioassays and delays in                two social scientists found that “that
regulation have already proven many               mobile phone subscription rates are
times to have severe consequences, as             positively and statistically significantly
in the case of asbestos, smoking and              associated with death rates from brain
vinyl chloride.” 10   In their study, Dr          cancer 15-20 years later. As a
Belpoggi and her colleagues found an              falsification test, we find few positive
“increase in the incidence of tumors of           associations between mobile phone
the brain and heart in RFR-exposed                subscription rates and deaths from
Sprague-Dawley rats. These tumors are             rectal, pancreatic, stomach, breast or
of the same histotype of those observed           lung cancer or ischemic heart disease.” 16
in some epidemiological studies on cell
                                                  Commenting on the general issue of a
phone users.” 11 The NTP study also
                                                  rise   in     brain    tumours,     cancer
reported that DNA damage (strand
                                                  epidemiologist Geoffrey Kabat, argues
breaks) was significantly increased in the
                                                  that the risk of brain cancer in the US is

                                              5
low, 6 in every 100,000, compared to             during these early life stages is a major
150 in every 100,000 for breast                  risk factor for cancer later in life.
cancer. 17 He therefore implies that the         Because young people have many
cancer risk from RFR is overhyped, as            expected years of life, the clinical
epidemiological data can be open to              manifestations of cancers caused by
various interpretations. Whichever way           carcinogens have more time in which to
one looks at it, the incidence of such           develop during characteristically long
tumours is indeed low. But if recent             latency periods.” 20 A recent study
studies are accurate, then this rate may         demonstrated that in a child’s brain
more than double over a 20 year                  the hippocampus and hypothalamus
period11 or increase in line with mobile         absorb 1.6–3.1 times the microwave
phone use,14 as RFR is now accepted as           energy of an adult brain. The
either a causal or a contributory                absorption rate is 2.5 times higher than
mechanism in the occurrence of brain             an adult’s where a child’s cerebellum is
tumours and other cancers. However,              concerned. The same study found that
what none of these studies take into             the bone marrow in a child’s skull
account is that the number of RFR                absorbs microwave radiation at a level
sources has increased dramatically               10 times greater than that of an adult.21
throughout the home, school and work             In addition, a child’s eyes absorb higher
environments over the past 10 years,             levels of microwave radiation than
with WiFi routers, 2-4G enabled tablets,         adults. 22 If, as the latest scientific
the proliferation of WiFi enabled devices        evidence indicates, low-level microwave
and wearables, and the number of                 radiation poses a health risk, and if
mobile phones per person.                        safety standards are outdated, then it is
                                                 logical to assume that children are at
There is also evidence that RFR from cell
                                                 significant risk from any device radiating
phones may be triggering breast cancer
                                                 microwave radiation.23
in young women who carry their devices
on or near their breasts.18 To compound          Dr Christopher J. Portier, Associate
matters even further, one of the                 Director,     National     Institute     of
significant findings of the NTP study was        Environmental Health Sciences and
the presence of RFR promoted the                 Director, Office of Risk Assessment
growth of tumours caused by other                Research, co-authored an article with Dr
carcinogens.1,8,10,11 The findings of the        Wendy Leonard in Scientific American,
cumulative     body    of   research  are        following the initial release of the NTP
objective, and particularly disturbing           study findings in 2016. They conclude
where children are concerned. Rigorous           that, “Cellphones probably cause cancer
experimental studies on laboratory rats          if the exposure is close enough, long
have found that daily exposures to low-          enough, and in sufficient magnitude. We
levels of microwave radiation, such as           don’t yet know the risk for a given level
that emitted by WiFi devices, causes             of exposure in humans. We need more
significant biological changes in a range        data in this area, not only for cellphones,
of major organs such as the brains,              but for bluetooth devices, wifi and all the
hearts, reproductive systems, and eyes           other RF-EMF devices out there. Until
of the rats being studied.19                     then, reduce your exposure whenever
                                                 possible.” 24
All this has profound implications for the
increasing numbers of children and               Clearly, this is a complex matter, made
adolescents exposed to RFR on a daily            even more so by the fact that there was
basis. And the risks to children are             no hope of a paradigm change, until the
considerable: “Because cells are rapidly         ‘smoking gun’ provided by the NTP study
dividing    and   organ    systems     are       removed any doubt that RFR can act
developing     during   childhood     and        directly, via identified mechanisms, to
adolescence, exposure to carcinogens             induce tumours in biological organisms

                                             6
Figure 1 Mechanisms and Pathways to Pathophysiological Effects (Reproduced from Pall
                                      2018)
exposed to radiation levels within those         and antioxidant enzymes are associated
permitted by existing standards and to           with various human diseases including
which users are typically exposed. This          various cancers. ROS are also implicated
should stimulate a reassessment of the           in diabetes and neurodegenerative
risks in relation to all RFR use,                diseases” 26 . Research on mobile phone
particularly children. “The level of proof       RFR and WiFi pulsed microwave signals
required to justify action for health            has also demonstrated that they produce
protection should be less than that              elevated levels of reactive oxygen
required to constitute causality as a            species (ROS) which in turn cause
scientific principle”.25 We are far beyond       oxidative stress in cell. 27 , 28 , 29 Oxidative
that level of proof where RFR is                 stress is caused by an imbalance
concerned.                                       between ROS and the counter effects of
                                                 antioxidants that help detoxify and repair
What are the Biological Mechanisms               biological systems. Thus, the body
that Produce Ill-health in Children              normally employs antioxidant defence
                                                 mechanisms to counter ROS and help
and Adults?
                                                 avoid diseases such as cancer, which are
While the direct effects of certain              trigged by oxidative stress and its
carcinogens are widely acknowledged,             tendency to cause strand breaks in a
research illustrates that “carcinogens           cell’s DNA.
may also partly exert their effect by            A raft of studies indicate that a chain of
generating reactive oxygen species               biological mechanisms produces the
(ROS)     during    their  metabolism.           observed negative health outcomes in
Oxidative damage to cellular DNA can             laboratory animals and humans. Martin
lead to mutations and may, therefore,            Pall, Professor Emeritus of Biochemistry
play an important role in the initiation         and Basic Medical Sciences, Washington
and     progression     of   multistage          State University points to the role of
carcinogenesis…Elevated levels of ROS            voltage-gated calcium channel (VGCC)
and down regulation of ROS scavengers

                                             7
activation, which is triggered by RFR             lipids and DNA is at the root cause of
sources such as 2-4G and Wifi, as being           many of the ill-effects of microwave RFR.
one of primary causal mechanisms. 30 In           Most worrying in all of this is that
his review published in 2018, he cites            scientists have found that the mutagenic
over 120 empirical research papers in             effects on the DNA of living cells occurs
support of his thesis. There is, therefore,       under low-levels of exposure to the
a cumulative body of evidence which               pulsed microwave radiation found in
refutes the proposition that RFR has no           most of these devices. The consequences
biological effects, other than local              for children are obvious, given their
thermal effects on tissue.        Professor       greater exposure levels and susceptibility
Pall’s earlier 2013 review paper cites 22         to health ill-effects and also that their
research studies that specifically point to       bodies are constantly growing and
the role played by VGCC activation. 31            developing.33, 34
The number of studies replicating
                                                  A recent study illustrates relatively low
experiments that corroborate this theory
                                                  level of exposure required to produce
has grown significantly, while none
                                                  adverse biological effects. Chauhan et
appear to refute it.       The figure 1
                                                  al.8 published the results of their
illustrates the posited mechanisms,
                                                  experiment on Wistar rats in 2016. The
pathways and outcomes. A detailed
                                                  rats in this experiment were exposed to
discussion is beyond the scope of this
                                                  RFR at 25% of the normal level at the
paper,     however,   several    important
                                                  human ear and 15% of the level when
mediating          mechanisms          and
                                                  carried for 2 hours per day for 35 days.
pathophysiological outcomes are now
                                                  Autopsies of the rats exposed to RFR
discussed.
                                                  revealed significantly high levels of ROS
A recent review of scientific studies             in the livers, brains and spleens of the
concluded that relatively brief, regular,         exposed animals. In addition, histological
and also long-term use of microwave               changes were also found in brains,
devices resulted in negative impacts on           livers, testes, kidneys and spleens. In
biological systems, especially the brain.32       line with a wealth of other similar
This review by Kesari et al. squarely             studies, the researchers concluded that
highlights the role played by reactive            the “results indicate possible implications
oxygen species (ROS) as a key                     of such exposure on human health.”
mechanism (generated by exposure to               Earlier studies found that rat brains
microwaves)      in  producing     serious        exposed to RFR exhibited an increase in
negative effects in living organisms.             single    strand    DNA      breaks     and
Exposure to ionizing radiation has been           chromosomal damage in brain cells.
long known to disturb the balance                 Thus it is beyond doubt that the
between ROS and the antioxidants that             substantial increase in ROS in living cells
neutralise them. Usually this imbalance           under RFR at low signal strength could
results in a high probability that the            be causing a broad spectrum of health
subject will develop cancers and other            disorders and diseases, including cancer,
chronic conditions. A wealth of studies           in humans and particularly in children.
now illustrate, however, that non-                Certainly, recent studies have provided
ionizing radiation emitted from smart             empirical evidence to support this
phones, cordless phones, WiFi, Bluetooth          theory.
and other wireless technologies, such as
                                                  Another recently discovered mechanism
those powering the Internet of Things
                                                  found    to    affect the  growth    of
(IoT) can severely disturb this balance
                                                  glioblastoma multiforme tumours in
also, by amplifying ROS, suppressing
                                                  humans      is   the  p53   protein. 35
antioxidants, and increasing oxidative
                                                  Glioblastoma are the most common and
stress. There is substantial evidence that
                                                  most malignant of the glial tumours
oxidative damage to cellular proteins,
                                                  found in the brain and central nervous

                                              8
system. These researchers studied 63             significant tumour-promoting effects.39 A
patients with this type of tumour and            study by Lerchl et al. in 201540 replicated
found that patients that used “mobile            the earlier study using higher numbers
phones for ≥3 hours a day show a                 of animals in both the control and
consistent pattern of increased risk for         experimental groups.         Lerchl et al.
the mutant type of p53 gene expression           confirmed and extended the previous
in    the    peripheral   zone    of   the       findings. They report that numbers of
glioblastoma, and that this increase was         tumours of the lungs and livers in
significantly correlated with shorter            exposed animals in were significantly
overall survival time.”        This is a         higher than in the control groups. They
significant finding. More worrying is a          also reported significantly elevated
recent study conducted on the Swedish            lymphomas through RFR exposure. The
National Inpatient Register: “The main           scientists       hypothesized          that
finding in this study was increasing rate        cocarcinogenic effects may have been
of brain tumor of unknown type in the            “caused by metabolic changes due to
central nervous system.” 36 The research         exposure.”    It   is    significant,   and
being conducted by the ‘Hardell Group’           extremely     worrying,     that   tumour-
in Sweden, which is responsible for this         promoting effects were produced “at low
study, has consistently demonstrated a           to moderate exposure levels (0.04 and
link between mobile phone use and                0.4 W/kg SAR), thus well below
cancer. Two recent studies from the              exposure limits for the users of mobile
group confirm the link between RFR and           phones.” The authors conclude that their
cancers in humans. In the first, both            “findings may help to understand the
mobile and cordless phones were                  repeatedly reported increased incidences
associated with an increased the risk of         of brain tumors in heavy users of mobile
glioma, a type of brain tumour. 37 It            phones.” The mechanisms presented in
found that the “First use of mobile or           the previous section help explain why
cordless phone before the age of 20              and how RFR exposures induce the
gave higher OR [odds ratio] for glioma           observed findings in these and other
than in later age groups.” Which                 studies.
indicates that children or teenagers are
at significant risk. In the second,              Why are Existing Standards Unsafe?
researchers found that the rise in thyroid
cancers in Sweden was linked with                The existing standards for mobile (2,3, &
increase in exposure to RF-EMF.38 To be          4G) and WiFi are considered unsafe. The
sure, epidemiological studies such as the        US Federal Communications Commission
latter are akin to looking for a needle in       (FCC) mandates that “The safe limit for a
a haystack, and are criticised by some as        mobile phone user is an SAR of 1.6 watts
being flawed, however their findings             per kg (1.6 W/kg), averaged over one
need to be viewed in a new light given           gram of tissue, and compliance with this
the scientific evidence emerging from            limit must be demonstrated before FCC
laboratory experiments such as the NTP           approval is granted for marketing of a
study.                                           phone in the United States.” SAR is the
                                                 Specific Absorption Rate. Expressed in
Evidence that Microwave RFR                      Watts (a unit of electrical power) per
Promotes the Development of                      kilogram of human tissue, SAR measures
                                                 of the rate at which RFR energy is
Existing Cancers                                 absorbed by the human body. In the
                                                 testing procedures the FCC uses to
One important recent finding is that RFR
                                                 certify that cell phones don't exceed the
has cocarcinogenic effects. In research
                                                 1.6 W/kg SAR limit, the devices are
published in 2010, carcinogen-treated
                                                 tested 0.59 inches and 0.98 inches
mice exposed to RFR demonstrated
                                                 (1.5cm to 2.5cm) from the body. Hence,

                                             9
smartphone manufacturers provide these               (www.bioinitiative.org), the World Health
guidelines    buried    in   their   safety          Organization (WHO) and governmental
information. If users operate their                  agencies in many countries have not
devices within these limits, which most              taken steps to warn of the health
do, they are in breach of the safe                   hazards resulting from exposures to
operating limits and are more at risk                EMFs at low, non-thermal intensities, nor
from both thermal and non-thermal                    have they set exposure standards that
effects. To make matters worse, 75% of               are adequately health protective.”
smartphones regularly exceed FCC
                                                     The industry safety standard for WiFi
safety limits as a recent correspondence
                                                     was established in 1996 by the FCC. It
between Washington DC law firm,
                                                     adopted the IEEE standard for safety
Swankin & Turner, who sent a letter to
                                                     levels with respect to human exposure to
the FCC indicates. The letter questioned
                                                     radio frequency electromagnetic fields, 3
whether the agency adequately enforced
                                                     kHz to 300 GHz, of 1991, which was
its cell phone radiation exposure limits.41
                                                     based on that issued by the National
If a smartphone is on, but not being                 Council on Radiation Protection (NRCP)
used for calls, text, or to browse online,           in 1986. This standard covers only the
it still communicates with cell phone                thermal hazards from Radio Frequency
base towers to maintain internet access.             Radiation (RFR). RFR is also known as
This allows app notifications, instant               non-ionizing microwave radiation. There
message texts, updates, and so on. So                is    a    long-standing    belief among
your phone is never off. Hence, when                 physicists and electronics engineers that,
you carry it in your pockets or on a belt            unlike ionizing radiation such as X-rays,
wallet, it’s not being operated within the           non-ionizing radiation such as RFR is not
safe     distance     and     the      phone         powerful enough to cause damage to
manufacturer is not liable. Note that the            human DNA. Non-ionizing microwave
safety limits for cell phones and Wifi               radiation could not, therefore, according
focus on thermal effects only. Remember              to that theory be a cause of cancer or
also that non-thermal effects have been              other non-thermal biological effects in
observed at much lower SAR levels from               humans. This theory has, however, been
individual devices and also cellular base            falsified, as indicated above.
stations and WiFi router. 42 Russian
                                                     The hazards covered by the FCC
scientist Dr. Yuri Grigoriev, Chairman of
                                                     standard are based on the specific
the Russian National Committee on Non-
                                                     absorption     dose-rate    (SAR)    that
ionizing Radiation Protection (RNCNIRP)
                                                     produces thermal effects in body tissue.
points      out    that    “National     and
                                                     As indicated SAR is typically measured in
international     regulatory    limits    for
                                                     Watts/Kilogram. So, put simply, SAR
radiofrequency radiation (RFR) exposure
                                                     estimates    the   amount     of   energy
from cell phones and cell towers are
                                                     absorbed by a human body or part
outdated.” 43 He argues that Western
                                                     thereof when exposed to an RFR signal.
standards are inadequate to protect
                                                     While accurate, it chiefly focuses on
human health, in contrast with those in
                                                     thermal effects of RF-EMF.       The FCC
Russia, especially where the health of
                                                     guidelines are based on a 4 W/Kg
children is concerned. In Belpomme et
                                                     adverse    level   effect   observed   in
al. study42, whose authors include cancer
                                                     laboratory animals. This excerpt from
researchers, it is argued that “In spite of
                                                     the Code of Federal Regulations (CFR
a large body of evidence for human
                                                     47/2.1093) is instructive:
health hazards from non-ionizing EMFs
at intensities that do not cause                     “The     SAR    limits    for   general
measureable tissue heating, summarized               population/uncontrolled exposure are
in an encyclopaedic fashion in the                   0.08 W/kg, as averaged over the whole
Bioinitiative                         Report         body, and a peak spatial-average SAR of

                                                10
1.6 W/kg, averaged over any 1 gram of                 certainly never envisaged children using
tissue (defined as a tissue volume in the             these devices on a regular basis. Note
shape of a cube). Exceptions are the                  too that adults and children carry WiFi-
parts of the human body treated as                    enabled smartphones on their person,
extremities, such as hands, wrists, feet,             less than 1 cm from their bodies and well
ankles, and pinnae, where the peak                    within the 20 (8”) cm limit of safe
spatial-average SAR limit is 4 W/kg,                  operation. This is also true of WiFi-
averaged over any 10 grams of tissue                  enabled WhatsApp and Skype calls.
(defined as a tissue volume in the shape              However, today such devices are in
of a cube). Exposure may be averaged                  widespread daily use by children across
over a time period not to exceed 30                   developed countries. Furthermore, given
minutes to determine compliance with                  the observable patterns of use, the 30-
general    population/uncontrolled   SAR              minute maximum exposure is being
limits.”                                              breached on a regular basis by both
                                                      adults and children. Given the scientific
Based on existing theories and research
                                                      evidence, it is troubling to think that
data, the FCC recognised the safety
                                                      children are carrying or operating WiFi
problems with WiFi and recommended
                                                      devices on or near their person,
that such devices are not operated less
                                                      breaching the safety guidelines set by
than 20 cm from the human body for 30
                                                      the FCC, and for periods much, much
minutes. However, as far back as 2002,
                                                      longer than 30 minutes.
the Environmental Protection Agency
(EPA) stated that the “FCC’s exposure                 Opposing views come from the BigTech
guideline is considered protective of                 and telecommunications companies, who
effects     arising    from    a    thermal           like the tobacco lobby before them, are
mechanism but not from all possible                   arguing that there is no danger in using
mechanisms.            Therefore,        the          WiFi technology or mobile phones. This
generalisation      by   many     that   the          view is based on the aforementioned
guidelines protect human beings from                  belief that non-ionizing radiation such as
harm by any or all mechanisms is not                  microwaves are not powerful enough to
justified”44. The EPA’s reservations were             cause damage to human DNA. However,
justified,    given     research    findings          as Professor Martin Pall concludes
published over the past 15 years that                 “Repeated Wi-Fi studies show that Wi-Fi
refute the theory that hazards were                   causes oxidative stress, sperm/testicular
confined to thermal effects.                          damage,       neuropsychiatric      effects
                                                      including    EEG    changes,     apoptosis,
                                                      cellular    DNA     damage,      endocrine
                                                      changes, and calcium overload.”30

                                                      What do Insurance Companies and
                                                      Regulators and Telecoms Operators
                                                      have to say about the Risks?
                                                      In 2010 Lloyds of London 45 published a
                                                      paper on the emerging risks of RFR. At
                                                      the time it likened links between non-
                                                      ionizing radiation and cancer to that
  When is laptop not a laptop? When it’s WiFi-
enabled. Such devices must be 20 cm or 8” from        which exists between asbestos and
       the body— an adult body, that is.              cancer, indicating that time and more
                                                      research would establish a causal link. In
We might add that at the time, the FCC                2015, rumours spread across the web
never envisaged adults carrying WiFi                  that Lloyds of London had stopped
enabled devices on their person, and                  covering health risks associated with RFR

                                                 11
devices. However, it appears that the               “7. Our business may be impacted by
exclusion of RFR from insurance policies            actual or perceived health risks
was issued by an individual underwriter,            associated with the transmission of
CFC Underwriting Ltd to the effect that:            radio waves from mobile telephones,
“The Electromagnetic Fields Exclusion               transmitters         and         associated
(Exclusion 32) is a General Insurance               equipment. Risk: Concerns have been
Exclusion and is applied across the                 expressed that the electromagnetic
market as standard. The purpose of the              signals emitted by mobile telephone
exclusion is to exclude cover for illnesses         handsets and base stations may pose
caused by continuous long-term non-                 health risks. We are not aware that such
ionising radiation exposure i.e. through            health risks have been substantiated,
mobile phone usage.” It was reported                however, in the event of a major
that this exclusion applied to insurance            scientific finding supporting this view this
cover for architects and engineers in               might result in prohibitive legislation
Canada,      following    health   concerns         being introduced by governments (or the
centering on a programme to install Wi-             European Union), a major reduction in
Fi in all British Columbian schools                 mobile phone usage (especially by
without parents’ consent. Lloyd’s 2010              children), a requirement to move base
report predated the IARC’s decision in              station      sites,  significant    difficulty
2011 to classify RFR as a Class 2B                  renewing or acquiring site leases, and/or
carcinogen. As research on the health               major litigation. An inadequate response
risks of RFR produces more empirical                to electromagnetic fields (‘EMF’) issues
evidence, insurance companies will act              may result in loss of confidence in the
accordingly.       Indeed,      occupational        industry and Vodafone.”1
insurance for medical practitioners now
specifically     excludes    any    medical         Discussion
conditions that arise from exposure to
non-ionizing radiation such as RF-EMF,              In a submission to the United Nations in
including that from phones and mobile               2015, over 200 scientists requested it to
devices. Indeed, expect a strong                    address “the emerging public health
response from the insurance industry as             crisis” related to the use of RFR emitting
its actuaries evaluate the risks posed by           devices.46 They urged the United Nations
long-term exposure to RFR in the weight             Environmental Programme (UNEP) to
of recent scientific evidence.                      review current exposure standards and
                                                    to identify measures to substantially
Regulators, such as the Securities and              lower human exposures to microwave
Exchange Commission, also recognise                 radiation. The scientists argued that
the economic impact of risks, as do                 existing “guidelines do not cover long-
mobile phone and internet services                  term exposure and low-intensity effects”
providers. Take, for example, that                  and are “insufficient to protect public
Vodafone and Verizon, among others,                 health.” They note the urgency in this,
now include, and make provision for in              as children are more vulnerable to the
their financial reports, the risks of               effects of RFR.
litigation in relation to the health effects
of products and services involving RFR,             Microwave radiation is considered by
whether from smartphones or WiFi                    majority of informed scientists as an
routers. Clearly neither believes that the          invisible source of potentially toxic
small print in the safety information
issued with RFR devices is sufficient.
Take, for example, the following excerpt            1
                                                      Vodafone Group PLC, Annual Report 2012.
from Vodafone Group PLC, Annual                     https://www.vodafone.com/content
Report.                                             /annualreport/annual_report12/downloads/perform
                                                    ance_vodafone_ar2012_sections/principal_risk_fac
                                                    tors_and_uncertainties_vodafone_ar2012.pdf.

                                               12
pollution that scientific research in the        levels of ROS and attenuated levels of
sciences has identified as being harmful         anti-oxidants associated with exposure
to biological systems and, ultimately,           to microwave radiation. However, the
human health and well-being. Think of a          bright light shining on his face is also
smoke-filled bar of yore, where smokers          affecting his developing eyes, which are
and non-smokers alike are subjected to           more sensitive to those of an adult.
toxic carcinogens. Now, think of that
                                                 Vision issues aside, this light acts to
same bar in countries where smoking is
                                                 significantly      attenuate      melatonin
banned from such premises. However,
                                                 production in the brain. The first order
have we replaced one hazard with
                                                 effect here is interference with the
another, if one considers the RFR being
                                                 circadian rhythm and sleep disturbance.
emitted by the WiFi routers, and radio
                                                 The research literature on the effect that
units all of the smart devices in pubs,
                                                 LED screens have in suppressing
cafes, restaurants, homes, schools, and
                                                 melatonin      levels    is    unequivocal.
the workplace in the age of the Internet
                                                 Cajochen et al. provide convincing
of Things (IoT), the scale of the dilemma
                                                 evidence of the effect that “A 5-h
that we have unthinkingly drifted into
                                                 evening exposure to a white LED backlit
becomes clear. That, is of course, if one
                                                 screen… elicited a significant suppression
accepts the scientific evidence.
                                                 of the evening rise in endogenous
All this is of concern to informed               melatonin and subjective as well as
computer scientists and technologists,           objective sleepiness, as indexed by a
who find the exposure to a multiplicity          reduced      incidence    of    slow    eye
of, and close proximity to, WiFi signals         movements and EEG low-frequency
problematic. Take, for example, Ajay             activity (1–7 Hz) in frontal brain
Malik, SVP of Engineering and Products,          regions.” 48 Sleep disruption is also
Network World, who has also called for           problematic as “sleep mediates learning
the WiFi standard to be reviewed by the          and memory processing” and is vital for
FCC. He argues that the “amount of               memory “encoding, consolidation, and
radiation exposure today is over 100             reconsolidation, into the constellation of
times higher as we live in proximity to a        additional processes that are critical for
very    large    number     of   actively        efficient    memory      development.” 49
transmitting Wi-Fi Devices and Wi-Fi             However, as melatonin is also one of the
Access Points/Routers.” 47 He therefore          body’s most effective antioxidants and
raises questions on the cumulative               ROS scavengers, it is putting him at
impact on adults and children of these           particular risk of second-order effects. It
unplanned for levels of exposure that            specifically increases the probability, low
often can go beyond SAR safety limits.
Of course, he is unaware of the non-
thermal health effects which are,
perhaps, of greater concern, as the
relevant mechanisms operate at lower
exposure levels and durations.
The child in the image below is not
operating his tablet device safely—that
is, he is not in compliance with existing
safety standards, inappropriate as they
may be. As a consequence, his vital
organs, eyes and brain are being
exposed to unacceptable and potentially
unsafe levels of microwave radiation.
Over time the cells in his body will                 What’s wrong with this picture?
develop oxidative stress, due to elevated

                                            13
Figure 2 RFR Mechanisms and Outcomes

that this may be, that at some point in            routine problem solving 50 , 51 ,42. The
the future he may develop cancer as an             implications for brain development in
adult. One must also consider the                  children    is  clear,  as    are    the
remote probability that he may develop             consequences for their immediate well-
cancers or other ill-effects conditions in         being.
childhood.       However,        scientific
experiments have also demonstrated                 Conclusions
that exposure to WiFi radiation also
affects brain development in young rats            As far back as 1973, a review and study
and their ability to learn and engage in           by Russian scientists on the effects of
                                                   low-intensity  RFR    on    experimental

                                              14
animals indicated clear evidence of                 devices, and their expose to RFR sources
effects on the brain and nervous system,            should be minimized. This might seem
and also the heart and testes, of                   impractical in the digital world, but in our
subjects. 52 Historically, Russia has more          real analogue world, children and
stringent safety standards than the                 teenagers are no longer permitted legal
West, whether it is the EU or US, when it           access to cigarettes, nor is it socially
comes to RFR.43 The evidence provided               acceptable for adults to smoke in their
by    Russian      scientists    and   their        presence. Given the current scientific
contemporaries in the US and Europe                 evidence,       the      pathophysiological
should have given pause to the                      properties of RFR appear to be no
telecommunications          industry    and         different than cigarette smoke or similar
regulators      in     relation    to   the         carcinogens.
commericalisation and widespread use of
                                                    Thus, in light of the evidence, the
mobile telephony in the 1980s. However,
                                                    precautionary principle should be applied
in 2019 the cumulative body of scientific
                                                    and governments should implement
evidence should have governments and
                                                    policies that result in the removal of WiFi
regulators take immediate action to
                                                    routers and all WiFi devices from the
change       policy      and      implement
                                                    classrooms of elementary/primary and
appropriate safety standards for digital
                                                    secondary/high schools. Just to remind
technologies, as it is children that are
                                                    the reader what the precautionary
most at risk.
                                                    principle means: "When an activity
Given the clear risks that RFR-based                raises threats of harm to human health
technologies present, it is also vital for          or    the   environment,      precautionary
parents and educators to take immediate             measures should be taken even if some
action on the use of microwave emitting             cause and effect relationships are not
devices where children are concerned. As            fully established scientifically.” 2 We are
there is overwhelming evidence that                 well beyond that point, as this paper
safety standards are woefully outdated,             illustrates. The application of the
the action to be taken is clear. The                precautionary principle is a statutory
precautionary principle should be applied           requirement in some areas of law in the
and the use of all microwave RFR-                   European Union, as expressed in the
enabled devices, from WiFi-enabled                  Charter of Fundamental Rights. Thus EU
tablets (and smartphones) to WiFi                   governments at least have a political and
routers, should be heavily curtailed or             an ethical responsibility to act.
eliminated. The figure above summarizes
                                                    In    the    absence    of   appropriate
this paper’s findings and provides
                                                    government policy, educators need to
compelling reasons for why such action
                                                    reconsider the untrammeled use of WiFi
is necessary.
                                                    in schools and not employ iPads or
As indicated, Figure 2 summarises the               tablets for use by children in class.
evidence of risk and indicates the role of          Devices that use e-Ink, or similar types
specific mechanisms in producing the                of electronic paper display, as opposed
various threats to human health and                 to LED screens, should be used in the
well-being. Each of the outcomes                    classroom and at home to access e-
identified are independent of each other;           books/texts, but these should be
hence, the risk of some form of ill-health          operated in airplane mode when reading.
to children due to RFR exposure is highly
                                                    Parents and guardians also need to act
probable.
                                                    and should consider the following
At the risk of repetition, there is only one
realistic course of action. Children and
adolescents     should    not    be    using        2
                                                      https://en.wikipedia.org/wiki/Precautionary_princi
smartphones, or WiFi-enabled tablet                 ple

                                               15
recommendations in order to exercise                     If children are using screen
their personal duty of care:                              device for games, they should be
      Educate children and adolescents                   operated in airplane mode.
       about the health risks of all smart               Ensure WiFi routers are not in or
       devices.                                           near or directly beneath children’s
      Restrict device time to 30                         bedrooms and they should be
       minutes for all RFR-enabled                        switched off at night. No RFR
       devices, not just screen time.                     device, including some types of
                                                          baby monitors, should in in a
      In respect of screen time, all LED                 child’s bedroom.
       screen devices should have a Blue
       Light Filter. Apps like F-Lux are                 Minimise the use in the home of
       ideal   here.    This   minimises                  all Internet of Things (IoT)
       melatonin reduction in users.                      devices such as Smart Meters,
                                                          Virtual     Assistants,    Hive,
      Smart phones have 2/3/4G, WiFi                     Chromecast, WiFi dongles, and so
       and Bluetooth radio units all of                   on.
       which are normally switched on.
       These should be used only when              There is also a clear onus on scientists
                                                   and practitioners in the computing and
       required. In addition, the small
                                                   IT industry to act and ensure that the
       print on Health and Safety
                                                   safety standards for all RFR and WiFi
       information that comes with a
                                                   devices are reviewed in light of the
       smartphone typically indicates              recent    scientific    findings. To     do
       that they should NOT be carried             otherwise would be irresponsible. There
       nor operated less than 2.5 cm               will be enormous resistance to change
       from the body.                              from vested interests and the political
                                                   establishment.       This     has  already
      Remember that the WiFi Safety               happened, with orchestrated campaigns
       standards for ALL devices is that           against natural scientists conducting
       they must be operated 20 cm or              independent research on the health
       8” from the body and for no more            implications of RFR, particularly in the
       than 30 minutes.                            US. An excerpt from a recent article in
                                                   The Guardian newspaper summarises
          o   Given the risk handing a             the type of response to be expected from
              young child an active RFR            industry with respect to microwave RFR
              device,     such      as   a         and in particular the release of the
              smartphone or an iPad, to            findings of the NTP study. “Central to
              hold     in     their    car         keeping the scientific argument going is
              seat/pram,     is   for   all        making it appear that not all scientists
              intents and purposes the             agree. Towards that end, and again like
              same as giving them a                the tobacco and fossil-fuel industries, the
              cigarette to smoke.                  wireless industry has “war-gamed”
                                                   science, as a Motorola internal memo in
      If children or adolescents have             1994 phrased it. War-gaming science
       access to smartphones and WiFi              involves playing offence as well as
       devices, the devices should not             defence – funding studies friendly to the
       be carried or operated on or near           industry while attacking studies that
       their person.                               raise questions; placing industry-friendly
                                                   experts on advisory bodies such as the
           o Ear & microphones should
                                                   World Health Organisation and seeking
               be used for all calls.

                                              16
to discredit scientists whose views differ         About the Author
from the industry’s.”53
                                                   Professor Tom Butler is a social scientist
Returning to the quote at the beginning
                                                   at University College Cork. A former
of this paper by Professor Frentzel-
                                                   satellite and microwave communications
Beyme MD, we have, as the evidence
                                                   engineer and IT professional, he is more
adduced herein indicates, far exceeded
                                                   than familiar with the traditional safety
the “level of proof required to justify
                                                   issues relating to microwave RFR. His
action for health protection.” The theory
                                                   Pauline conversion from the engineering
that non-ionizing RFR exposure could
                                                   perspective on RFR thermal safety
not cause cancer has been refuted using
                                                   occurred through research engagements
the scientific method. It is ironic, in the
                                                   with the Chief Risk Officer of a global
era of neoconservatism, neoliberalism,
                                                   corporation     who     pointed   out   the
and the anti-environmental policies of
                                                   significant risks to children from the non-
necon      cheerleader-in-chief     Donald
                                                   thermal effects of RFR. These discussions
Trump, that the smoking gun should be
                                                   and related events in his personal life
provided by the National Toxicology
                                                   stimulated Professor Butler’s interest in
Program of the US Department of Health
                                                   this important topic.
and Human Services. This study, as
indicated above, is just the latest of             In a research context, Professor Butler is
many to provide the “clear evidence”               a   former     Government     of   Ireland
required for policy and social change.             Research Fellow, Principal Investigator
                                                   (PI) of the Governance Risk and
The need for social change is this area is
                                                   Compliance Technology Centre (2013-
as important, and no less controversial,
                                                   2018), PI of the SmaRT and SamRT4Reg
than that required to respond to the
                                                   Commercialisation Fund Projects (2017-
challenge of global warming. However,
                                                   2019), and Co-PI of two Marie
the forces resisting change to the status
                                                   Skłodowska-Curie Career-FIT Fellowships
quo are considerable. Take for example
                                                   in Artificial Intelligence (2019-2022).
that “Not one major news organisation in
                                                   With over €8.5 million in research
the US or Europe reported [the] scientific
                                                   funding on the application of digital
news [published by the NTP]. But then,
                                                   technologies to date, he has 220
news coverage of mobile phone safety
                                                   publications and 11 inventions. Tom is a
has long reflected the outlook of the
                                                   member of the European Commission’s
wireless industry.”53 In order to combat
                                                   Expert Group on Regulatory Obstacles to
vested interests and protect children,
                                                   Financial Innovation (ROFIEG) in the
parents and grandparents, aunts and
                                                   area of FinTech, a member of the Global
uncles, need to act to change extant
                                                   RegTech Council, and a member of the
social   perspectives     on   seemingly
                                                   Financial    Industry   Enterprise    Data
harmless    digital   technologies    that
                                                   Management Council (EDMC).
entertain and beguile, and which offer
affordances        without       apparent
consequences. That will be the challenge
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