but you cannot fool all the people all the time…
The advisory body AGNIR (Advisory Group on Non-Ionizing Radiation) was disbanded in 2017 as it had ‘completed its work’. Dr Simon Mann, Head of Dosimetry at Public Health England, and member of ICNIRP, was Secretary to AGNIR.
|To:||WRAGG, William <firstname.lastname@example.org>, email@example.com, Jeremy.firstname.lastname@example.org, email@example.com, firstname.lastname@example.org|
2012 AGNIR Report
‘You can fool all the people some of the time and some of the people all the time, but you cannot fool all the people all the time.’
Prof. Dariusz Leszczynski: ‘One thing seems to be clear, unlike the claims on HPA website, the UK HPA AGNIR Report 2012 is not a comprehensive review but it is a biased review’.
From Dr Sarah Starkey’s ‘Inaccurate official assessment of radiofrequency
safety by the Advisory Group on Non-ionising Radiation’ (https://www.degruyter.com/downloadpdf/j/reveh.2016.31.issue-4/reveh-2016-0060/reveh-2016-0060.pdf):
‘Abstract: The Advisory Group on Non-ionising Radiation (AGNIR) 2012 report forms the basis of official advice on the safety of radiofrequency (RF) electromagnetic fields in the United Kingdom and has been relied upon by health protection agencies around the world. This review describes incorrect and misleading statements from within the report, omissions and conflict of interest, which make it unsuitable for health risk assessment. The executive summary and overall conclusions did not accurately reflect the scientific evidence available.‘
‘The executive summary of the AGNIR report included “Taken together, these studies provide no evidence of health effects of RF field exposures below internationally accepted guideline levels” and “the evidence considered overall has not demonstrated any adverse health effects of RF field exposures below internationally accepted guideline levels” … These conclusions did not accurately reflect the evidence, as described in examples below. a) Studies were omitted, included in other sections but without any conclusions, or conclusions left out; (b) evidence was dismissed and ignored in conclusions; (c) there were incorrect statements. Terms such as ‘convincing’ or ‘consistent were used to imply that there was no evidence. Some examples fall into more than one category.’
‘Only 7 studies were included in the section on reactive oxygen species. These were summarised by “production of reactive oxygen species (ROS) were increased in some studies, but not others”. ... At least 40 studies were omitted. If these had been included, 79% of studies (61 out of 77) would have demonstrated evidence of significantly increased ROS or oxidative stress in response to RF field. By only including a few of the available studies, not referring to many scattered throughout the report and not mentioning ROS or oxidative stress in any conclusions or the executive summary, this important area of research was misrepresented. Oxidative stress is a toxic state which can lead to cellular DNA, RNA, protein or lipid damage, is accepted as a major cause of cancer, as well as being implicated in many reproductive, central nervous system, cardiovascular, immune and metabolic disorders.’
‘The conclusion for male fertility studies in animals was “A substantial number of studies have investigated the effects of RF fields on testicular function, principally in rats, and most report large, obvious effects. However, these results are largely uninterpretable due to inadequate dosimetry or other shortcomings in the studies, and thus are unsuitable for the purposes of health risk assessment. One well-conducted study reported no effects on testicular function in rats exposed to 848 MHz CDMA signals”. For male fertility in humans (in vivo), it was concluded, “The evidence on the effect of RF fields on sperm quality is still weak and the addition of the two new studies does not allow reliable evaluation of the presence or absence of a health effect. Some suggestive positive results, although not convincing, give justification for further studies with improved methods. The evidence on effects on male subfertility is very limited, and allows no conclusions”. At least 22 studies on male fertility were omitted. … If the 22 references identified as omitted had also been included, this would have been 35 out of 45, 78%.‘
‘Inaccurately, in the overall and executive summaries, the evidence for adverse effects on male fertility disappeared: “Despite many studies investigating effects on male fertility, there is no convincing evidence that low level exposure results in any adverse outcomes on testicular function” and for humans, in vivo, “The limited available data on other non-cancer outcomes show no effects of RF field exposure”.’
‘For direct effects on proteins, 15 out of 16 studies listed found significant effects of RF fields. The conclusion was “In general, most of the studies that have investigated changes in protein function or structure due to exposure to RF fields have found effects. However, at the present time the effects have not been demonstrated to be robust by independent replication; so although the concept of a direct effect of RF field exposure on protein structure is interesting, further research is needed to establish if this is a real phenomenon.” Ninety-four percent of the studies listed on direct effects on proteins, from 14 different groups, found significant effects, but the conclusion was turned around to imply that these may not be real.’
‘Out of 33 studies on direct effects on proteins or cell membranes, 32 described significant effects of RF signals below high power heating, but these disappeared in the conclusions. By the end of the report, the conclusion on cellular studies had incorrectly become “There are now several hundred studies in the published literature that have looked for effects on isolated cells or their components when exposed to RF fields. None has provided robust evidence for an effect”.
‘A summary for human brain EEG recordings stated, “the EEG studies published since 2003 do provide some evidence that RF fields could influence brain function, and this should remain an area of interest” . Many EEG studies (awake or asleep subjects) reported changes in electrical field potential oscillations, evoked responses or interhemispheric coupling, but these were dismissed…’
‘For risks of brain tumours or acoustic neuromas in humans, “the similar results of all investigators except the Hardell group, with no methodological inferiorities in these other investigators’ studies overall, suggest that the results of the Hardell group are the problematic ones”. However, some significantly increased risks of brain tumours or acoustic neuromas were described in Hardell and non-Hardell studies’
‘The executive summary stated for cells in vitro: “In particular, there has been no convincing evidence that RF fields cause genetic damage or increase the likelihood of cells becoming malignant” and in the chapter on cellular studies: “Results from studies using other cell types are also contradictory. Epithelial cells exposed to …”. However, all in vitro studies included on epithelial cells [four, one retracted], from more than one laboratory, found damage to DNA or chromosomal aberrations in response to RF signals. Forty six percent of genotoxicity studies identified as included in the report (36 out of 78) described evidence for genotoxicity in response to RF fields, but at least 40 genotoxicity studies were omitted. … AGNIR found the genotoxicity evidence unconvincing, but a more accurate conclusion could have been that RF signals appear to be genotoxic under certain circumstances, but not others.’
‘The executive summary included “There has been no consistent evidence of effects on the brain, nervous system or the blood-brain barrier, on auditory function, or on fertility and reproduction”. The term ‘consistent’ dismissed areas for which the majority of studies had found adverse effects’
‘The denial of the existence of adverse effects of RF fields below ICNIRP guidelines in the AGNIR report conclusions is not supported by the scientific evidence. Studies have, as described as examples in this review, reported damage to male reproductive health, proteins and cellular membranes, increased oxidative stress, cell death and genotoxicity, altered electrical brain activity and cognition, increased behavioural problems in children and risks of some cancers.’
‘PHE and AGNIR had a responsibility to provide accurate information about the safety of RF fields. Unfortunately, the report suffered from an incorrect and misleading executive summary and overall conclusions, Inaccurate official assessment of radiofrequency safety by AGNIR inaccurate statements, omissions and conflict of interest. Public health and the well-being of other species in the natural world cannot be protected when evidence of harm, no matter how inconvenient, is covered up.’
Because I think it sums the situation up perfectly, I’ll include a correspondence with my friend, a trained medical researcher, about the glaring discrepancies between cited research in the report and AGNIR’s conclusions:
On 14 Dec 2018, at 19:55, Jane Gregory <email@example.com> wrote: 'https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/333080/RCE-20_Health_Effects_RF_Electromagnetic_fields.pdf 102 - 114 plus following conclusions.' My friend's reply: 'I have now read through this and feel that they are finding ways to dismiss the alarming number of positive (ie negative) effects. Their conclusion should be “An alarming number of different studies show biological effects that could be adverse on a wide number of different cells and proteins, at a wide variety of different frequencies and the longest any of them have been done for is 6 days.“ When what they do say is "But hey, they are all different studies so they are “inconsistent”, none have been exactly replicated so we can ignore them and ICNIRP say it is fine so we’ll be off the hook when it all goes pear shaped, or whatever shape humans might become.”
In spite of the misrepresentations stated above, something which is clearly evident is that the AGNIR report doesn’t even approach the ”All-clear” PHE is claiming because it still provides enough indication of risk to justify urgent implementation of the precautionary principle. For instance:
‘production of reactive oxygen species (ROS) were increased in some studies’
‘A substantial number of studies have investigated the effects of RF fields on testicular function, principally in rats, and most report large, obvious effects. … Some suggestive positive results, although not convincing, give justification for further studies with improved methods.’
‘… so although the concept of a direct effect of RF field exposure on protein structure is interesting, further research is needed to establish if this is a real phenomenon.’
“Results from studies using other cell types are also contradictory.” (but still evident)
“the EEG studies published since 2003 do provide some evidence that RF fields could influence brain function, and this should remain an area of interest” … should remain an area of interest?
My next email will be about the 2015 SCENIHR report. Please will you forward this to your Westminster researcher. Thank you. I’ll be forwarding it to the Science and Technology/Health and Safety Committee members.