The Former Health Protection Agency
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)
Calls for the Health Protection Agency to take precautionary action now
Below you will find some of the arguments why SSITA is both disappointed and frustrated with the reluctance of the HPA to take any action or to recognise the urgency of the need to review their advice to schools in light of the recent developments in Europe in May 2011. (See Council of Europe below)
As a decision of the Coalition Government, established in May 2010, The Health Protection Agency is being subsumed into The Department of Health, whose Secretary of State for Health, Andrew Lansley, has indicated that he holds himself accountable in his new post.
We ask him to look into the use of Wi-Fi in schools as a matter of great urgency. This is especially the case with regard to primary schools.
Local authorities have been telling us that they have been waiting for the Health Protection Agency to produce their latest report, in conjunction with AGNIR, before deciding whether to review their policy on Wi-Fi in schools, or to review the advice they give to schools. SSITA organisations have begun an analysis and critique of this report. This assessment will take a long time and we have only just embarked on it. However, within forty-eight hours of the HPA release, Wi-Fi in Schools, one of the organisations within SSITA, worked very hard to produce the initial assessment which you can read here.
A misleading report has been produced by the UK Health Protection Agency about the safety of radio frequency electromagnetic fields. The report concludes that there is still no convincing evidence that mobile phone technologies cause adverse effects on human health. The report lists many studies finding damaging biological and health effects, but manages to dismiss them for various reasons. Some studies were omitted. No mention was made of the decision by the World Health Organization to classify radio frequency radiation as possibly carcinogenic to humans. We illustrate the misleading and dishonest nature of the report with the example of male fertility, where 78% of the male fertility studies mentioned in the report found decreased measures of fertility or sperm damage. Amazingly the report’s conclusion is that the results provide no substantial evidence of adverse health effects, in particular for reproductive function. More information
Other organisations within SSITA are also analysing this report. More information will be given here at on-going intervals.
Letter from SSITA to schools:
This letter was sent from SSITA on May 21st.2012 to UK schools (both State and Independent), Nursery Units, Special Schools, Children’s Centres/Sure Start Centres
Many current educational initiatives promote the use of Wi-Fi and mobile communication devices in class. Our organisation would like to make you aware of some information which may be vitally important to you in terms of the health and safety of children and staff.
Health Protection Agency Report (April 2012)
The Advisory Group on Non-Ionising Radiation (AGNIR) has produced a report on behalf of the UK Health Protection Agency (HPA) entitled ‘Health Effects from Radiofrequency Electromagnetic Fields’.
The HPA state, “The report finds that although a substantial amount of research has been conducted, there is no convincing evidence that radiofrequency field exposure below internationally agreed guideline levels (which are applied in the UK) causes health effects in adults or children.”
However, the conclusions do not accurately represent the science presented within the report. For example, 78% (18/23) of the male fertility studies listed found decreased measures of male fertility or damage to sperm from radiofrequency field exposure. In addition, many relevant studies were omitted.
Professor Dariusz Leszczynski (Finnish Radiation Protection Authority) has called the report biased and misleading. Read more
Medical Statements, Classifications and Resolutions
At the International Childhood Cancer Conference, Dr Annie Sasco, MD and Professor Dariusz Leszczynski both said that they supported a classification of radiofrequency fields as probably carcinogenic to humans (Class 2A). They are currently classified as 2B, possibly carcinogenic, but this is often a first step towards the higher classification of 2A (IARC 2011).
Medical organisations have been voicing their concerns, with the American Academy of Environmental Medicine speaking out about wireless smart meters in schools and calling for a precautionary approach to wireless technologies. More information
The Austrian Medical Association is opposed to the use of mobile phones or Wi-Fi in schools and has recently called for wireless smart meters not to be used in Austria. The Swiss Doctors for Environmental Protection have also recently called for caution with respect to wireless technologies. Read more here.
Dr. Peter Kälin states “From the medical point of view, it is urgent to apply the precautionary principle for mobile telephony, Wi-Fi, power lines, etc.”
A Call for Safe Environments in Schools
The Safe Schools IT Alliance (SSITA); are asking schools to safeguard pupils by using wired ICT connections, as called for in the Council of Europe Resolution 1815 in 2011.
SSITA also sent the following letter to UK Councils: Letter to Councils
Health and Safety recommendations to schools: Wireless Technologies.
Health Protection Agency Report
The Advisory Group on Non-Ionising Radiation (AGNIR) has produced a report on behalf of the UK Health Protection Agency entitled ‘ Health Effects from Radiofrequency Electromagnetic Fields‘.
The HPA state “The report finds that although a substantial amount of research has been conducted, there is no convincing evidence that radio frequency field exposure below internationally agreed guideline levels (which are applied in the UK) causes health effects in adults or children”.
However, the report’s conclusions do not accurately represent the science presented within the report. This can be illustrated by the example of male fertility. 78% (18/23) of the male fertility studies listed in the report found decreased measures of male fertility or damage to sperm from radiofrequency field exposure. Many studies were omitted. More information
Professor Dariusz Leszczynski (Finnish Radiation Protection Authority) has called the report biased and misleading. Read more
Medical Statements, Classifications and Resolutions.
At the International Childhood Cancer 2012 Conference speakers were concerned about the possibility that wireless phones could be causing brain tumours in children, now the biggest cancer killer for young people. More information
Dr Annie Sasco, MD and Professor Dariusz Leszczynski both said that they supported a classification of radio frequency fields as probably carcinogenic to humans (Class 2A). It is currently classed as 2B, possibly carcinogenic to humans (IARC 2011). More information
Medical organisations have recently been voicing their concerns, with the American Academy of Environmental Medicine speaking out about wireless smart meters in schools and calling for a precautionary approach to wireless technologies. The Austrian Medical Association is opposed to the use of mobile phones or Wi-Fi in schools and has recently called for wireless smart meters not to be used in Austria. The Swiss Doctors for Environmental Protection have also recently called for caution with respect to wireless technologies. Dr Peter Kälin, President, states “From the medical point of view, it is urgent to apply the precautionary principle for mobile telephony, Wi-Fi, power lines, etc. The Austrian Medical Chamber has moreover just formulated the same requirement in regard to smart meters”.
In addition, the European Environment Agency has called for the exposures of children and young people to radio frequency radiation to be reduced and for the current guidelines levels to be revised . The UK Trades Union Congress recommends that caution should be taken to prevent exposure to substances in group 2B (possible carcinogens, such as radiofrequency radiation). The UK Chief Medical Officers advise children under the age of 16 not to use mobile phones, except for essential purposes. Read More
A Call for Safe Environments in Schools
The Safe Schools IT Alliance (SSITA) are asking Local Authorities to recommend wired connections for ICT in schools, as called for in the Council of Europe Resolution in 2011
Local Authorities have a legal responsibility to safeguard children, which means not damaging their health, wellbeing or development or preventing them from entering adulthood successfully. If fertility, cognitive abilities, brain or immune system development are damaged or the child develops cancer as a result of exposures at school, then it could be argued that the Local Authority and school did not adequately safeguard the pupils.
Further concerns about the Health Protection Agency response (25th April 25th 2012) to the AGNIR Report (April 2012)
Here is a letter sent from our sister organisation, the Charity, Mobilewise, to the Health Protection Agency delineating their criticisms of the HPA response to the the AGNIR report.
HPA AGNIR MobileWise letter 260612
Dr John Cooper
Director of Centre for Radiation, Chemical and Environmental Hazards
Health Protection Agency
By email: firstname.lastname@example.org
26 June 2012
Dear Dr Cooper
Health Effects from Radiofrequency Electromagnetic Fields
We note publication of the AGNIR Report “Health Effects from Radiofrequency Electromagnetic Fields – RCE 20” dated April 2012 and the HPA Statement dated 25 April 2012 in response. We set out here our criticisms of the HPA Statement and ask the HPA to revise its response to the AGNIR Report in the light of these. We believe the HPA’s response as set out in the HPA Statement is inadequate in the following respects:
Failure to consider all relevant evidence.
1. The HPA Statement, by describing the AGNIR Report as comprehensive fails to recognise that the report reflects an incomplete body of evidence, or to assess the implications of this shortcoming. The AGNIR Report, by its own admission, is out of date (with a cut-off date for papers considered of December 2010, a full 16 months prior to publication). Additionally, numerous relevant studies published before that cut-off date were omitted from the references, while a few studies from 2011 have been included, suggesting a selective application of the cut-off.
2. The HPA Statement fails to discuss the findings of relevant scientific authorities other than AGNIR, especially the International Agency for Research on Cancer (IARC) Monograph classification of radio-frequency electromagnetic fields as possibly carcinogenic under IARC Class 2B. The World Health Organization’s Preamble to the IARC Monographs states that “the Monographs are used by national and international authorities to make risk assessments, formulate decisions concerning preventative measures, provide effective cancer control programmes and decide among alternative options for public health decisions.” They are widely regarded as the “gold standard” in cancer risk assessment. Therefore, the failure of the AGNIR Report and the HPA Statement to explicitly consider the IARC monograph assessment of radio-frequency electromagnetic fields and to explain the reasons for disagreeing with it are major omissions.
Absence of risk assessment – failure to consider implications of evidential uncertainty
3. The HPA Statement fails to acknowledge that the conclusions contained in the Executive Summary of the AGNIR Report do not flow from the content of the report, or to assess the implications of this. In particular, there is no substantiation of the “no convincing evidence” verdict in the AGNIR Report, and this conclusion is contradicted by the other sections of the Report, which contain references to many studies which have found harmful effects. The term “convincing” is a subjective term that has no place in risk assessment, especially if not explained by reference to specific assessment criteria.
4. The HPA Statement recognises that some studies have identified adverse effects, and that the possibility of harm remains, but fails to consider the implications of this evidence. It fails to draw out the implications of the confused scientific picture contained in the AGNIR Report or to offer any recommendations to address the possible harm.
5. The HPA Statement fails to acknowledge that the Executive Summary of the AGNIR Report ignores the areas of controversy and disagreement within the scientific community. AGNIR presents its findings as uncontroversial, despite the issues being hotly debated amongst scientists, and the HPA has not considered the policy implications of alternative views of the science.
Failure to consider and assess policy options
6. The HPA Statement fails to consider and assess all relevant policy options. In particular, it does not consider the range of guidance that it could provide (in the light of the uncertainty over safety acknowledged in both the AGNIR Report and the HPA Statement) and the various means available to it to communicate such guidance. The response offers only one policy option, namely to continue with the existing approach, despite the evidential landscape having changed significantly since that policy was arrived at in 2000.
7. The HPA Statement recognises that a precautionary approach is appropriate, then fails to recommend any precautionary measures. Continuing with the existing policy is not, in practice, precautionary because steps are not being taken to communicate current guidance to the public.
8. The HPA statement fails to acknowledge the implications of duties imposed by Council of Europe resolution 1815 (2011) and European Parliament resolution 2008/2211(INI) of 2 April 2009 to take action to reduce exposures to electromagnetic fields, for example to reduce exposures to children in schools. No explanation is provided for the failure to recommend policy measures to give effect to these resolutions.
In the light of these concerns, we urge the HPA to revise its response to the AGNIR Report. In particular, the HPA should:
- acknowledge the limitations of the AGNIR report as outlined above;
- consider and evaluate policy options reflecting the acknowledged uncertainties over safety and the above-mentioned IARC monograph assessment, Council of Europe resolution and European Parliament resolution, in order to arrive at a genuinely precautionary policy in accordance with the stated intention; and
- consider whether institutions who follow contemporaneous HPA advice which contradicts the above-mentioned IARC monograph assessment, Council of Europe resolution and European Parliament resolution could be exposed to litigation.
Note: in this letter, references are as follows:“AGNIR Report”: is the report entitled
1. “Health Effects from Radiofrequency Electromagnetic Fields – RCE 20”, dated April 2012.
2. “HPA Statement” is the statement referred to on the HPA website as “ HPA Response to the 2012 AGNIR Report on the Health Effects from Radiofrequency Electromagnetic Fields” dated 25 April 2012
What does ICNIRP say?
The UK government relies on such agencies as ICNIRP ( International Commission on Non-Ionising Radiation Protection) for advice. Under the Commission’s section entitled “People being protected”
ICNIRP pays recognition to the fact that some groups in the population may be more vulnerable, or more affected, than others:
People being protected
Different groups in a population may have differences in their ability to tolerate a particular NIR exposure. For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the population. Under such circumstances, it may be useful or necessary to develop separate guideline levels for different groups within the general population, but it may be more effective to adjust the guidelines for the general population to include such groups. Some guidelines may still not provide adequate protection for certain sensitive individuals nor for normal individuals exposed concomitantly to other agents, which may exacerbate the effect of the NIR exposure, an example being individuals with photosensitivity. Where such situations have been identified, appropriate specific advice should be developed-within the context of scientific knowledge. In some circumstances, it may be advisable to distinguish between members of the general public and individuals exposed because of or while performing their work tasks (occupational exposure). In its exposure guidelines, ICNIRP distinguishes occupational and public exposures in general terms. When applying the guidelines to specific situations, it is ICNIRP’s opinion that the relevant authorities in each country should decide on whether occupational or general public guideline levels are to be applied, according to existing (national) rules or policies. Environmental conditions may also influence the effect of whole-body exposure to optical or RF radiation.