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Complaint to The Health Protection Agency/Public Health England

SSITA Complaint to Public Health England. Update (June  29th. 2015)  re this complaint:

This complaint has now been passed up to the Ombudsman’s Casework Team. Members of the public have used the template document below and inserted their personal story in answer to Question 9. All submissions are in support of the Group Complaint as shown here. To the best of our knowledge some 90 + complainants have now asked their MPs to sign this document and to submit it on their behalf to the Parliamentary and Health Service Ombudsman.

Please download the updated “Complaint Template” (updated 4 November 2016)   

Below is the formal complaint addressed to:
Health Protection Agency Complaints Manager,
Communications
61 Colindale Avenue,
London NW9 5EQ

It was sent on March 18th. 2013
and was headed as coming from:
UK Organisations in Association with the International EMF Alliance

Complaint to the HPA concerning failure to provide appropriate precautionary advice regarding radiofrequency electromagnetic fields

Following the World Health Organisation’s International Agency for Research on Cancer (IARC) classification of radiofrequency electromagnetic fields as Group 2B possibly carcinogenic to humans1, we, the undersigned organisations and individuals, hereby formally lodge a complaint to and against the Health Protection Agency with regard to their failure to provide appropriate precautionary advice on pulsed microwave-emitting technologies other than mobile phones, particularly the use of wireless networks in schools and homes, and Smart Meters in homes and small businesses. 

In addition, we wish to further include a complaint about the absence of any reference to the IARC classification of radiofrequency electromagnetic fields as a Group 2B possible human carcinogen in their recent submission to the Commons Select Committee Inquiry into Smart Meter Roll-out. This is a particularly serious omission in view of the fact that the presently proposed smart meter roll-out would affect the entire population as even those who opt out would be exposed to the pulsed radiofrequency microwaves of meters in their neighbourhood.

In the HPA response2 to the IARC statement, dated 31 May 2011  –

“HPA advice is that there is no clear scientific evidence of a cancer risk from exposure to radio frequencies at levels below international guidelines but the possibility remains. The HPA has always advocated some precaution in the use of mobile phones in case there are long term effects which are presently unknown. Given the possibility of long term cancer effects, excessive use of mobile phones by children should be discouraged.”

However, when referring to Wi-Fi –

“HPA advice on the use of wireless networks in schools and elsewhere is also consistent with this classification. Exposures from Wi-Fi equipment are much less than from mobile phones, and are well within international guidelines, so there is no reason why schools and others should not continue to use the technology.”

Likewise, in the HPA smart meter information sheet3 –

“HPA acknowledges that there remain some areas of scientific uncertainty and HPA’s advice takes this into account”

Nevertheless –

“HPA consider exposure to radio waves does not provide a basis to decline having a smart meter”. 

This is justified by stating that –

“Using mobile phones leads to greater exposures than other radio devices in widespread use by the general public, including smart meters”. 

Failure to promote precaution in the case of other wireless technologies such as Wi-Fi and smart meters cannot be justified on the grounds that exposures are less than from mobile phones.  This does not take into account the fact that exposure from Wi-Fi in schools and smart meters is constant whereas mobile phone exposure only occurs during phone calls.  Furthermore, mobile phone exposure is voluntary4 whereas in the case of Wi-Fi in schools and smart meters in homes it is involuntary, i.e. people are being forced to be exposed to the pulsed microwaves and cannot choose to exercise precaution.  This is arguably a violation of the Right to Health Protection as outlined in Section 4 of the article ‘Precautionary Environmental Protection and Human Rights’ (2007).5

The HPA has failed to mention that studies have reported biological effects of Wi-Fi and similar wireless signals in humans.  Such evidence, whilst limited, is important for enabling adults and schools to make choices about whether they wish to reduce their exposures, from an informed position.

Regarding the recent (February 2013) written evidence6 submitted by the HPA to the Commons Select Committee Inquiry into Smart Meter Roll-out, although links were provided to some relevant documents, there was no reference whatsoever in the submitted document to the fact that radiofrequency electromagnetic fields have been classified as possibly carcinogenic to humans. The HPA mentioned a precautionary approach in their response to the 2012 AGNIR Report 7, i.e.

“Excessive use of mobile phones by children should be discouraged, while adults should make their own choices as to whether they wish to reduce their exposures, but be enabled to do this from an informed position.”

However, when referring to this report in the recent submission to the Commons Select Committee only the ‘main conclusion’ of AGNIR was quoted where it was stated that:

“although a substantial amount of research has been conducted in this area, there is no convincing evidence that radio wave exposures below the ICNIRP guideline levels cause health effects in adults or children.” 8

In 2011 the IARC concluded that there was enough convincing evidence that radio wave exposures below the ICNIRP guideline levels might cause cancer to classify radio frequencies as a Class 2B possible human carcinogen.  The Commons Select Committee Inquiry into Smart Meter Roll-out, as well as the general public, would be better enabled to make informed choices about wireless technologies if the HPA had mentioned the decision of the IARC and offered appropriate precautionary advice.

1.  IARC classifies Radiofrequency Electromagnetic Fields as possibly carcinogenic to humans

2.  Electromagnetic Fields

3.  Understanding Radiation

4.  Passive RF exposure to mobile phones can be involuntary

5. Precautionary Environmental Protection and Human Rights

6. http://data.parliament.uk/writtenevidence/WrittenEvidence.svc/EvidencePdf/445

7.  http://www.hpa.org.uk/Publications/Radiation/HPAResponse

8.  It should be pointed out that we strongly disagree with this AGNIR statement. A large body of published scientific data has found that pulsed radiofrequency microwaves below the guideline levels can cause biological and adverse health effects, although many of these papers were omitted from the AGNIR 2012 report. Many studies were described in the Bioinitiative Report 2007 and 20129 and the Ecolog Report (2000)10. As stated in the Benevento Resolution (2006) from the International Commission for Electromagnetic Safety, “Arguments that weak (low intensity) EMF cannot affect biological systems do not represent the current spectrum of scientific opinion.”11

9.  The Bioinitiative Report 2012

10.  Mobile Telecommunications and Health

11.  Benevento Resolution

 Signed by the following Organisations:

BEMRI (Bio Electromagnetic ResearcBh Initiative)
CAVI (Children As Victims Inquiry) Society
Electric Forester Investigations Ltd
ElectroSensitivity UK
FoodsMatter
Interconnections
International EMF Alliance
Mast Sanity
Mast-Victims
MobileWise
Powerwatch
EM Radiation Research Trust
SSITA (Safe Schools Information Technology Alliance)
Stop Smart Meters! (UK)
Wifi in Schools
WiredChild 

Individual Signatories

Rachel Acworth RGN, BA (Hons), MA, MMus, CIMI, MISP
Michelle Berriedale-Johnson, Editor, FoodsMatter websites
Philip Clemo
Dr Zac Cox BDS
Ingrid Dickenson, BRCP EMR, BEMRI
Dr Clare Edwards BSc PhD
Dr Elizabeth Evans, MA (Cantab), MBBS (Lond), DRCOG, Medical Advisor, SSITA
Dr Catarina Geoghan, BSc (Hons), PhD (Sussex), BEMRI
Dr Andrew Goldsworthy BSc (1st Class Hons) PhD (Wales)
Lecturer in Biology (retired) Imperial College London
A Gray, Trustee, Mast Sanity
Jennifer Griffiths, Reverend
Diana Hanson, Chair, For and on behalf of all Trustees, CAVI Society. SSITA
Cert.Ed.University of Birmingham (City of Birmingham College of Education)
James Healy-Pratt BA (Hons), LLM, MRAeS
Paula Healy, BA (Hons), MSc Cognitive Neuroscience
Robert F Howie, BEd (Hons), Class Teacher
Andrew Hughes, Support Worker for people with learning disabilities
Paul Jenkins
Professor Olle Johansson, The Experimental Dermatology Unit
Department of Neuroscience, Karolinska Institute Stockholm, Sweden
Paul Lewis FCCA, FMAAT, DipPFS
Martina Jirankova-Limbrick
Annabel Kapp BA (Hons)
Peter Limbrick, Interconnections
Dr Erica Mallery-Blythe BM,
Trustee Radiation Research Trust, Medical Advisor ES-UK, Board Member CPTF
Damian May
Roger Moller BSc.Ind.Eng, Founder & Director, Electric Forester Investigations Ltd
Eileen O’Connor, Director, EM Radiation Research Trust
Adrienne Obbard, ES-UK
Alasdair Philips, BSc(Eng),DAgrE,MIAgrE,MIEEE, Director, Powerwatch
Brenda Short LLB. LLM
Dr Sarah Starkey, BSc, MSc, PhD
Julia Taylor, Nutritional Therapist, MBANT Dip ION
Susan Thompson B.Ed (Hons) SSITA
Margaret White BSc (Hons); MA; MBPsS
Sarah Wright, MA Hons (Cantab), Wired Child, Mast Sanity

Many other people who work alongside us would very much have liked to have signed this complaint, but because of career considerations, or the need to protect their or their children’s privacy, have understandably declined to do so. The above signatures therefore only constitute a sample list of people within the above organisations who in fact endorse this document in spirit.

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